The Internal Revenue Service lacks a strong operation to audit a critical international tax compliance area, according to a watchdog report released Thursday. At issue is transfer pricing, a cost structure used by multinational companies to price goods and services they sell to subsidiaries in foreign locations. The IRS requires… – Continue reading
A “number” of European Union countries are blocking a push to include zero corporate tax rates as criteria for the bloc’s tax haven blacklist, according to Slovakia, which holds the rotating EU presidency. EU members have been unable to reach an agreement on cracking down on offshore structures aimed at… – Continue reading
Global governments battling tax avoidance increasingly are pushing multinational corporations for a bigger picture of how and where they pay taxes, leading to increasingly narrow questions from company tax officers. “We have a number of entities that are disregarded for U.S. tax purposes. When I fill out the country-by-country form,… – Continue reading
Wednesday, 2 November, Finance Minister Dana Reizniece-oak and Swiss Ambassador Latvian Marcus Niklauss Paul Dutli ( Markus Niklaus Paul Dutly ) signed the Latvian Republic and the Government of the Swiss Federal Council Protocol amending the two parties on 31 January 2002 concluded the Convention for the Avoidance double taxation… – Continue reading
The Australian Tax Office (ATO) has updated its guidance for those non-resident businesses that make supplies of goods, services, or digital products to consumers or GST-registered businesses in Australia, with a couple of changes due to occur next year and a change last month. Since October 1, 2016, certain transactions… – Continue reading
Historically, the Middle East and North Africa (MENA) region has been perceived as a region where taxation and transfer pricing initiatives are not high up on government agendas. Although this has been the case for a significant period of time, recent changes in the region such as decreases in global… – Continue reading
Romania plans to join the Base erosion and profit shifting (BEPS) program as an associate member. The program equips governments with domestic and international instruments to address tax avoidance. The program’s objective is to have profits taxed where economic activities generating the profits are performed. The Finance Ministry has published… – Continue reading
The Philippines is eyeing to seal tax treaties with all nine other Asean member-states, according to the Bureau of Internal Revenue (BIR). The country already has effective double taxation agreements (DTAs) with Indonesia, Malaysia, Singapore, Thailand and Vietnam, BIR Assistant Commissioner Marissa O. Cabreros noted in a presentation at last… – Continue reading
The OECD has started to review how effectively the U.S. and five other countries handle cases in which multinational companies assert double taxation under the mutual agreement procedure of bilateral tax treaties. As part of the review, the Organization for Economic Cooperation and Development is inviting multinationals to answer a… – Continue reading
After getting approval from Finance Minister Ishaq Dar on the pilot project of automatic exchange of information (AEOI), the Federal Board of Revenue (FBR) has approved a team to execute the project with the Organisation for Economic Cooperation and Development OECD Member countries. According to a notification issued by the… – Continue reading
The British arm of McDonald’s paid £123m for “franchise rights” last year, as part of a controversial structure that is under investigation for enabling unfair tax avoidance. The European Commission launched a probe last year into whether Luxembourg’s tax arrangements for McDonald’s amounted to illegal state aid, as part of… – Continue reading
On October 26, Hong Kong’s Government launched a public consultation on the implementation of base erosion and profit shifting (BEPS) measures proposed by the OECD. “Hong Kong is supportive of international efforts to promote tax transparency and combat tax evasion,” said Secretary for Financial Services and the Treasury K C… – Continue reading
India and New Zealand also vowed to press for successful negotiations of the Regional Comprehensive Economic Partnership (RCEP). India and New Zealand decided to amend the bilateral tax treaty and expressed commitment to work towards a comprehensive free trade agreement with a view to boost economic ties on Wednesday. The… – Continue reading
Panama will take a big step towards ending its status as an offshore tax haven on Thursday by signing a multilateral convention to share foreign taxpayer details with other governments, the OECD‘s head of tax said. Panama’s role as a major offshore tax haven came into the public spotlight earlier… – Continue reading
Hong Kong has signed agreements with Japan and the United Kingdom with a view to commencing automatic exchange of financial account information in tax matters (AEOI) with these two tax jurisdictions in 2018, a Government spokesman said today (October 26). In September 2014, Hong Kong indicated its support for the… – Continue reading
The International Monetary Fund (IMF), the Organisation for Economic Co-operation and Development (OECD), the UN Department of Economic and Social Affairs (DESA), and the World Bank Group introduced a joint initiative, the Platform for Collaboration on Tax, to UN Member States. Marijn Verhoeven, World Bank Group, expressed excitement that the… – Continue reading
With the exception of British Antarctica, the U.K.’s overseas territories and offshore dependencies are all surrounded by sun-winking ocean water. But that’s not their only common feature—they are all under increasing political pressure to become more transparent with their financial information. In a parliamentary report on tackling overseas corruption, the… – Continue reading
Indonesia’s government must make it clear to errant taxpayers that an amnesty program, which has revealed almost $300 billion in undeclared assets, is the last chance to fix their affairs before full penalties are applied, the Organisation for Economic Cooperation and Development said. “Authorities must communicate clearly that this offer… – Continue reading
New Chief Minister Howard Quayle MHK has restated the island’s commitment to tax transparency at an Organisation for Economic Co-operation and Development event in Paris. Mr Quayle was in Paris for the Manx government’s signing of a new OECD agreement on automatic exchange of country by country reporting by large… – Continue reading
Pakistan’s authorities are making efforts to seek information about tax details of 270 offshore companies from nine known tax havens around the globe where 444 individuals have invested billions of dollars, and, finally, their names appeared through PanamaLeaks, The News has learnt. The cases of 444 individuals involving nine jurisdictions… – Continue reading
The OECD has set the minimum standards it requires from countries submitting Mutual Agreement Procedure (MAP) profiles, with only 41 countries currently having a completed profile, which will be used as a tool for resolving cross-border tax disputes The MAP falls under Action 14 on the Base Erosion and Profit… – Continue reading
The narrowing figure of £36bn roundly condemned for ignoring estimated tens of billions lost in profit shifting and tax avoidance by multinationals Tax experts warned that HM Revenue & Customs was underestimating the size of Britain’s tax avoidance problem after the agency claimed that Britain’s annual tax shortfall was only… – Continue reading
FATCA disclosure agreement takes effect, worrying some Israeli-Americans Dual American-Israeli citizens finally need to pay up. After years of the US Internal Revenue Service gradually baring down on American citizens living in Israel who evaded reporting income or paying taxes and numerous rounds of amnesty for those belatedly coming forward,… – Continue reading
On October 14, 2016, Andorra became the 86th territory to join the OECD’s new inclusive framework on base erosion and profit shifting (BEPS). As a member of the framework, Andorra will commit to implementing the minimum standards put forward by the OECD on BEPS. These are on: harmful tax practices,… – Continue reading
The OECD tax team is calling on tax professionals and multinationals to participate in an online survey on tax certainty, responding to widespread concerns about the increasing complexity of tax rules and lack of stability for companies and multinationals over tax regulations. This follows the detailed work on the OECD’s… – Continue reading
Talks on a data exchange agreement have progressed following Panama President Varela’s state visit to Berlin. Panama is looking to clean up its reputation in the aftermath of the “Panama Papers” leak earlier this year. Germany and Panama moved a step closer towards signing an information-sharing agreement, German Chancellor Angela… – Continue reading
Argentina and Chile yesterday announced the implementation of a long-awaited agreement to eliminate double taxation for residents of both countries in order to encourage investment and prevent tax evasion. Chile’s Foreign Minister Heraldo Muñoz, Public Works Minister Alberto Undurraga, and Finance Minister Rodrigo Valdés met with Argentina’s Finance Minister Alfonso… – Continue reading
On 30 September 2016 Ukraine signed a protocol (the “Protocol”) modifying the not-yet-in-force Convention between the Government of Ukraine and the Government of the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital (the “Convention”)…. – Continue reading
One of the most common ways multinationals take advantage of current laws to reduce their tax bill is through what’s known as transfer pricing. Former Treasurer Wayne Swan last week accused mining giant BHP of “aggressive transfer pricing,” denying the Australian government A$5.7 billion in tax revenue. For most companies,… – Continue reading
Applicable to transfer pricing for MNCs whose consolidated annual revenue is over Rs 5,000 crore The finance ministry will issue rules and guidance to address some concerns and ambiguity over mandatory reporting norms with respect to transfer pricing for multinational companies whose consolidated annual revenue is over Rs 5,000 crore…. – Continue reading
Singapore and Japan have agreed to automatically exchange financial account information under the OECD’s Common Reporting Standard. The CRS, the new global standard for the automatic exchange of information for tax purposes, requires all participating countries and jurisdictions to obtain information from their financial institutions and to exchange that information… – Continue reading
European Union plans to regulate tax advisers in an effort to clamp down on aggressive tax planning and tax avoidance could prove excessive, ineffective and trigger unfair competition, accountants and lawyers warn. The caution comes after EU finance ministers moved Oct. 11 to authorize the European Commission to draw up… – Continue reading
The Inland Revenue Authority of Singapore (IRAS) has published detailed guidance on the implementation of a new country-by-country (CbC) reporting requirement in the territory. The guidance, released on October 10, sets out which entities are obliged to report and how to complete and submit a CbC report to IRAS. For… – Continue reading
In July 2016 the then Indonesian finance minister Bambang Brodjonegoro, in conjunction with the launch of the widely publicized tax amnesty program (TAP) for undeclared offshore assets, also laid out less publicized plans for a new tax haven on the islands of Bintan and Rempang (Proposed Tax Haven). A key… – Continue reading
During a recent speech, the Secretary for Financial Services and the Treasury, K C Chan, reiterated Hong Kong’s commitment to meeting the international standards on tax transparency, and to implementing the Organisation for Economic Co-operation and Development’s (OECD’s) base erosion and profits shifting (BEPS) package. In his speech on October… – Continue reading
Ethiopia recently adopted new transfer pricing rules in the form of Directive 43/2015 (“the Directive”) issued by the Ministry of Finance and Economic Development. The Directive provides detailed guidance as to the application of Article 29 of the Income Tax Proclamation (ITP) 286/2002, which requires taxpayers to ensure transactions between… – Continue reading
Ireland, accused of being a tax haven for multinationals such as Apple to pay nearly zero tax on the bulk of its profits earned outside the United States, finds itself with a new adversary in the global fight against unfair tax practices — Brazil. As of October 1, Brazil will… – Continue reading
Around 35 per cent of businesses in India have changed their tax approach following the OECD Base Erosion and Profit Shifting (BEPS) tax plan, higher than the global average, says a report. The Grant Thorntons recently conducted global survey of 2,600 businesses in 36 countries, found little impact of the… – Continue reading
A list on non-cooperative tax jurisdictions around the world, the first ever common EU list, is being under preparation, Commissioner for Economic and Financial Affairs, Taxation and Customs Pierre Moscovici has said. “This month, we started the process that will lead, by the end of 2017, to the first ever… – Continue reading
A report by the Independent Commission for Aid Impact (ICAI) has criticised the Department for International Development’s (DfiD) approach to tackling tax avoidance and its alleged failure to achieve value for money on HMRC collaboration DfiD has failed in its efforts to fully include developing countries so that they benefit… – Continue reading
A multi-billion euro back tax bill handed to Apple by the European Commission should not be seen as a precedent for future tax cases as it was based on state aid rather than tax law, the OECD official spearheading global tax reform said on Monday. European Union antitrust regulators last… – Continue reading
More than 2,000 files under review, 85 taxpayers under audit National Revenue Minister Diane Lebouthillier said in a statement Monday that a few thousand files are now being pursued by the tax agency after it sifted through the Panama Papers. Canadians implicated in the Panama Papers shouldn’t expect any leniency… – Continue reading
The Director of the OECD’s tax policy and administration unit has said there is no pressure on Ireland to change its 12.5% tax rate. “There is no question about the 12.5% rate, even the French have understood that Ireland will not change the rate,” Pascal Saint-Amans said. He said the… – Continue reading
Paving the way for the automatic exchange of tax information with India and other nations, Switzerland has ratified the multilateral convention on administrative assistance in taxation matters. The move marks a significant step in the continuing global efforts to crackdown on illicit fund flows in the system and do away… – Continue reading
The threshold could be R5,400 crore of annual consolidated group revenue for the purpose of country-by-country reporting Not more than 120 India-headquartered firms — along with their global associates — are likely to be impacted by the base erosion and profit shifting (BEPS) protocol once it is implemented, as the… – Continue reading
Five months after the Panama Papers exposed the offshore dealings of government leaders and influential people, a new leak of 1.3 million files has revealed the names of individuals associated with companies registered in the Bahamas, a notorious tax haven. The files – received by the German newspaper Süddeutsche Zeitung… – Continue reading
The Manx government has signed a Tax Information Exchange Agreement (TIEA) with the Turks and Caicos Islands. The deal ensures the Island continues to meet international tax co-operation and transparency standards. Treasury Minister Eddie Teare and Peter Beckingham – Governor of the Turks and Caicos Islands – both signed the… – Continue reading
The European Commission has put nine Middle Eastern and North African countries on notice that they are at risk of measures being taken against them to deter tax avoidance. The nine countries (see table below) are Bahrain, Israel, Jordan, Morocco, Oman, Qatar, Saudi Arabia, Tunisia, and the United Arab Emirates… – Continue reading
China’s State Administration of Taxation (SAT) issued the Announcement on the Administration of Related-party Transactions and Contemporaneous Documentation (SAT Announcement [2016] No. 42), which introduces a three-tiered documentation framework that will replace its current transfer pricing documentation rules. The June 29 announcement followed the publication of the opinion-seeking draft by… – Continue reading
The Federal Board of Revenue (FBR) will now be able to obtain the data of offshore bank accounts of Pakistani nationals for the last 15 years under the international tax treaty that it signed with the Organization for Economic Cooperation and Development (OECD), officials said on Saturday. “The signatories of… – Continue reading
