The OECD is seeking taxpayer input on the tax treaty dispute resolution process in a second tranche of countries and is seeking comments on the mutual agreement procedure (MAP) in Austria, France, Germany, Italy, Liechtenstein, Luxembourg and Sweden. Improving the tax treaty dispute resolution process is identified as a priority… – Continue reading
A key outcome of the Organisation for Economic Development and Co-operation’s (OECD’s) final Report on Action Plan 13 (Transfer Pricing Documentation and Country-by-Country reporting) is the commitment of OECD and G20 countries to introduce Country-by-Country (CbC) reporting along with the associated master file and local file documentation for large Multinational… – Continue reading
CROSS-border taxation in current times is poised for significant changes. Tax is key in foreign ventures. Absent tax strategies and foreign tax leakages would erode margins and return of investment. Although international tax-efficient strategies to mitigate capital gains tax (CGT), withholding tax (WHT) and the risk of creating a taxable… – Continue reading
The programme includes measures to combat base erosion and profit shifting, based on four main measures that can challenge exploitation of tax agreements, monitor developing international tax work rules, and ensure a more transparent environment. Egypt was chosen by the Organisation for Economic Cooperation and Development (OECD), in a conference… – Continue reading
In a significant step, Mauritius will soon start automatically sharing of tax information with India and other countries as part of global efforts to curb multinational companies from profit shifting activities. The development also comes months after the island nation, long perceived to be a jurisdiction for alleged illegal fund… – Continue reading
What GAO Found In 2015, the Organization for Economic Co-Operation and Development (OECD) issued revised guidelines, including 15 actions to help reduce base erosion and profit shifting (BEPS) of multinational enterprises (MNEs). One action focuses on transfer pricing guidance with the intent of aligning MNE profits with the location of… – Continue reading
A European leader in financial, tax and regulatory reporting for the banking and insurance sectors, Invoke is expanding its software range to meet CRS/AEoI cross-country tax reporting requirements. As part of the global fight against tax evasion, the G20 and OECD program for the exchange of tax payers’ financial information… – Continue reading
The OECD is seeking feedback on a draft toolkit designed to assist developing countries in work on transfer pricing, which specifically addresses the ways developing countries can overcome a lack of data on ‘comparables’, or the market prices for goods and services transferred between members of multinational corporations The toolkit… – Continue reading
Several countries in Latin America have established new transfer pricing documentation obligations associated with the OECD’s Base Erosion and Profit Shifting (BEPS) initiative. In this new year, Mexico, Colombia and Peru have included in their local legislation new documentation requirements that follow a three-tiered approach: country-by-country (CbC) report, master file,… – Continue reading
Bermuda – the world’s former “top tax haven” – has joined the Organisation for Economic Cooperation and Development’s fight against multinational profit shifting. Bermuda disputes it is a tax haven despite companies such as Apple and Google in the past being accused of using the British overseas territory to minimise… – Continue reading
The OECD recently released a public discussion draft entitled the “BEPS Action 6 Discussion Draft on non-CIV examples” to clarify when investors like private equity funds, real estate funds and hedge funds should be entitled to tax treaty benefits. The release of the 2017 Discussion Draft is timely, given that… – Continue reading
Nassau, The Bahamas – The Bahamas has taken many steps to comply with global standards in the financial services sector. One such step is the implementation of the Common Reporting Standard (CRS). The Common Reporting Standard (CRS), developed in response to the G20 request and approved by the OECD Council… – Continue reading
The move comes after HM Revenue & Customs received representations from the Association of Charitable Foundations and the Charity Finance Group HM Revenue & Customs has updated its guidance on the forthcoming common reporting standard after receiving concerns from charities. The CRS is an international standard for the automatic exchange… – Continue reading
A new legislative approach of the German tax authorities leaked last December 19 will have a significant impact on the tax deductibility of royalties owed to related persons being subject to a preferential back end tax regime for IP not being in compliance with the Organisation for Economic Co-operation and… – Continue reading
On December 21, 2016, the new Canada–Israel tax treaty entered into force. The new treaty was signed on September 21, 2016 in New York, and replaces the existing treaty that dates from 1975. For most purposes, the provisions of the new treaty took effect as of January 1, 2017. Overall,… – Continue reading
MUMBAI: The Multilateral Instrument (MLI), a new global tax avoidance agreement, that is in the process of being signed by 100 countries, is now causing a lot of anxiety among foreign portfolio investors (FPIs). MLI is an agreement put out by OECD, the intergovernmental economic organisation, to stop Base Erosion… – Continue reading
KARACHI: Finance minister Ishaq Dar on Friday said that tax evaders will find no place to park their ill-gotten money, as Pakistan will begin automatic-exchange of information from next year. “As per international agreement with OECD (Organisation of Economic Cooperation and Development), Pakistan will start automatic exchange of information regarding… – Continue reading
The Bahamian financial services industry “will do all we can” to ensure this nation does not appear on a threatened European Union (EU) ‘blacklist’, Tribune Business was told yesterday. Tanya McCartney, the Bahamas Financial Services Board’s (BFSB) chief executive, said this nation’s implementation of the Common Reporting Standard (CRS) for… – Continue reading
There is a possibility that the General Anti-Avoidance Rules (GAAR, on taxes) and the tax treaties signed by the government with those of Mauritius, Singapore and Cyprus, and even other nations such as Netherlands, could be overtaken by another event. These could, say experts, be partially or fully overridden by… – Continue reading
Multinational companies headquartered in Germany worry that when they report their global tax and profits for 2016, some countries will leak their country-by-country reports to the press. German parents of multinational groups with annual consolidated group revenue of at least 750 million euros ($797 million) are required to file, with… – Continue reading
Unknown to many Kenyans, Parliament’s passing of Finance Bill, 2016 that granted amnesty to Kenyan residents who have offshore incomes and assets in foreign banks had a very global agenda. The foreign income that is subject to amnesty is for the year ended December 31, 2016 and offers a waiver… – Continue reading
An inter-governmental economic organisation could help tackle tax evasion across the Irish border following Brexit, the UK’s Treasury has suggested. The UK’s only land border with an EU state is in Northern Ireland. Without the European institutions, the Organisation for Economic Co-operation and Development (OECD) could help facilitate dialogue with… – Continue reading
In his Budget speech on 11 October 2016, the Minister for Finance announced a comprehensive programme of targeted intervention against offshore tax evasion. Positive action is required ahead of 1 May 2017 for those with undeclared income and gains from offshore assets. Finance Act 2016, which includes legislative changes required… – Continue reading
KUALA LUMPUR: The Royal Malaysian Customs Department is considering amendments to the Goods and Services Tax Act (GST Act) to start taxing foreign online service suppliers, said deputy director-general Datuk Subromaniam Tholasy. “E-commerce is pretty much catered for, except business-to-consumer (B2C) for example, downloads from overseas, how do we tax… – Continue reading
The government has quashed calls to look at extending the requirement to publish a public register of people with significant control to companies incorporated in the Crown dependencies and overseas territories, as part of a bid to increase tax transparency, saying new rules on the automatic exchange of information are… – Continue reading
In efforts towards global transparency, over 100 countries have agreed to automatically exchange information relating to financial accounts (AEOI) with each other under the Convention on Mutual Administrative Assistance in Tax Matters (Convention). The OECD had also developed the Common Reporting Standards (CRS) which set out the common information to… – Continue reading
Coalition’s proposed diverted profits tax could capture billions in revenue from multinationals using profit-shifting practices, says Tax Justice Network One of the biggest critics of multinational tax avoidance has welcomed the Coalition’s proposed “Google tax”, saying a similar tax in the UK looks likely to increase corporate tax payments by… – Continue reading
As per the Economic Survey 2016, the ratio of Indian taxpayers to voters is 4%; ideally it should be roughly 23% at existing levels of economic and political development. The tax to GDP ratio at 16.6% is well below the emerging market economy norm of 21% and OECD average of 34%…. – Continue reading
The Kuwaiti Ministry of Finance on Sunday signed a protocol with India amending the agreement between the two countries to avoid double taxation on income and to prevent tax evasion. The protocol amends the types of Kuwaiti taxes in Article two of the agreement, as well as Article 26 on… – Continue reading
The creation of a new United Nations tax body to clamp down on tax dodging, which experts say could cost developing countries more than $200 billion a year in missed revenues, will be a key priority of the Group of 77 and China under Ecuadorian leadership, according to the country’s… – Continue reading
This, like previous initiatives, seems nothing more than a thinly veiled revenue measure. A new amnesty scheme is being considered to allow those who hold wealth abroad to bring it back into the country without facing a penalty other than paying a nominal amount of tax on the value of… – Continue reading
Portuguese income tax law provides for a 20% reduced rate and, in respect to income obtained abroad, a full tax exemption, for certain types of income derived by individuals having the status of Non-Habitual Portuguese Residents (NHPR). Any individual that in a certain year becomes tax resident in Portugal will… – Continue reading
The Cayman Islands Government issued the second tranche of the Common Reporting Standard (“CRS”) regulations at the end of December 2016. Updated Guidance Notes will be issued in Q1 2017 by the Cayman Islands Tax Information Authority (“TIA”) to assist with the implementation of the regulations. Furthermore, TIA stated in… – Continue reading
Move could be a worrying indicator of investment trends post-Brexit, post-Beps Snap, the company behind Snapchat, has opted to open its new new international headquarters in London, rather than Dublin, Amsterdam or Luxembourg, bucking a trend which for decades has seen US multinationals book their international sales in one of… – Continue reading
Cyprus signed the Organisation for Economic Co-operation and Development’s Multilateral Competent Authority Agreement for the Automatic Exchange of Country-by Country Reports between its member states on 1 November 2016 after approval by the Council of Ministers at its meeting held on 28 September 2016. Following publication in the government gazette… – Continue reading
Authored by IFC Media Recent global events from the release of the Panama Papers to a series of high-profile inversions have given international tax regulators both rhetorical ammunition and public support to execute a global crackdown on multinational tax planning. The goal is to increase total taxes paid by global… – Continue reading
A further three countries have committed to participate in international base erosion and profit shifting discussions and implement minimum standards, under the OECD’s new “inclusive framework” for countries. The OECD confirmed on January 6 that the three territories are: Bermuda, Côte d’Ivoire, and Kazakhstan. This brings the total number of… – Continue reading
On December 23, 2016, the US ambassadors and Alberto Abad signed an agreement for the exchange of tax information on request. 1. Introduction For the past few years, Argentina has been an active participant in the progress of exchange of international tax information. More than seventeen agreements have been signed… – Continue reading
Hong Kong’s Financial Services Development Council (FSDC) has issued a paper setting out key recommendations for the Government to consider in the area of international tax law. The paper, which was issued on December 29, 2016, recommends that the Government should issue clearer guidance on appropriate transfer pricing methodologies for… – Continue reading
The UK and Switzerland have terminated tax arrangements under the Savings Tax Directive and will instead share information in tax matters automatically under the Common Reporting Standard. The UK Government said, under the switch to the OECD’s Common Reporting Standard, UK taxpayers will no longer be able to pay a… – Continue reading
On 23 November 2016, the Swiss Federal Council adopted the dispatch on the Multilateral Agreement on the exchange of Country-by-Country Reports (CbCRs) and draft federal implementing legislation. The proposal is aimed at implementing the minimum standard of the G20 countries and the OECD to combat base erosion and profit shifting… – Continue reading
Switzerland’s reputation as a secretive tax haven looks set to end following the introduction of rules over sharing bank account data. The International Convention on the Automatic Exchange of Banking Information (AEOI) entered into force on January 1, pulling Switzerland in to line with international standards on taxation. The convention,… – Continue reading
The Cayman Islands Tax Information Authority (International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations, 2016 (the “Regulations“) were issued on 19 December 2016. The Regulations amend the Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations, 2015 currently in force in the Cayman Islands and contain the enforcement powers… – Continue reading
NASSAU, The Bahamas — December 2016 marks a significant month for the Financial Services Industry in The Bahamas. The much-anticipated Bill to provide for the implementation of the Common Standard on Reporting and due diligence for financial Account Information in Tax matters and for connected purposes was passed unanimously in… – Continue reading
New Zealand’s Inland Revenue has published draft guidance to help financial institutions prepare for the OECD’s Common Reporting Standard for the Automatic Exchange of Financial Account Information in Tax Matters. The country is expected to pass legislation to implement the CRS by March 2017. The CRS is an international standard… – Continue reading
The Mauritius IFC: Driving Growth in Africa As a jurisdiction of substance, the Mauritius International Financial Centre (Mauritius IFC) has been instrumental in driving quality investments in Africa, leading to sustained growth and prosperity across the continent. It is therefore with deep regret that we take note of the misperceptions… – Continue reading
The `Google tax’ could soon ensnare the likes of IBM, Microsoft, Amazon Web Services, Apple and Netflix, which provide online services in India. Cloud computing companies and content providers with customers in the country may be needed to pay equalisation levy on their revenue from the next financial year as… – Continue reading
According to unofficial estimates, more than $2 billion has flowed into Dubai real estate from Pakistanis every year for the past three years. Last week, account holders in a major UAE bank began receiving letters alerting them that soon they would be required to furnish information “with a view to… – Continue reading
Tax directors and CFOs at multinational companies are facing increasing numbers of tax audits, and are becoming concerned about the impact of public perception of their tax planning on their company’s reputation, according to research by Taxand. Its fifth annual global survey of CFOs, tax and finance directors across Europe,… – Continue reading
Monaco has ratified the Convention on Mutual Administrative Assistance in Tax Matters. The ratification underlines Monaco’s commitment to fighting tax evasion and avoidance. It also means the principality has taken another important step in implementing the Standard for Automatic Exchange of Financial Account Information in Tax Matters, developed by the… – Continue reading
