The Government of India is aware of the potential loss of revenue from tax avoidance, and has been taking all necessary measures for preventing it. As a part of these measures, India has actively participated n the Base Erosion and Profit Shifting (BEPS) project undertaken by the OECD and G-20… – Continue reading
The highly significant changes to transfer pricing guidance planned for under the SAT’s public discussion draft on ‘Special Tax Adjustments’ (yet to be finalised at the time of writing), and the impact of these changes in the light of evolving Chinese transfer pricing enforcement practice is the focus of this… – Continue reading
On December 3, 2015 the OECD issued a press release in which it announced that on that same day Andorra signed the Multilateral Competent Authority Agreement (MCAA), bringing the total number of signatories to 75. Andorra signed the MCAA during a meeting of experts on automatic exchange of information convened… – Continue reading
The European Parliament has endorsed a deal between the EU and Liechtenstein that will make it harder for EU citizens to hide cash in bank accounts in the state Liechtenstein and the EU signed a deal in October this year, agreeing to automatically exchange information on the financial accounts of… – Continue reading
(CNS) UPDATED: The Cayman Islands and other overseas territories have agreed to hold beneficial ownership information in their jurisdictions via “central registers or similarly effective systems”, according to the communique released by the FCO following this week’s meeting in London with territory leaders and the UK government. The agreement on… – Continue reading
The South African Revenue Service (SARS) has issued draft regulations to require certain financial institutions (FIs) to report on accounts held or controlled by foreign residents. The OECD’s Common Reporting Standard (CRS), which the regulations are in response to, obliges countries and jurisdictions to obtain financial information from their FIs… – Continue reading
The Australian Government has introduced legislation to implement the Organisation for Economic Cooperation and Development’s (OECD’s) Common Reporting Standard for the automatic exchange of financial account information. Treasurer Scott Morrison said: “The Standard will assist the tax office to crack down on taxpayers hiding funds and investments offshore in order… – Continue reading
Australians hiding funds and investments offshore to avoid paying tax have been put on notice. The federal government on Thursday introduced to parliament legislation to enable the tax office to crack down on taxpayers hiding funds overseas. It implements an OECD scheme allowing the sharing of information between foreign tax… – Continue reading
Leaders from the Group of 20 largest economies (G20) met in Turkey last month to put their final stamp of approval on a major overhaul of the international rules governing corporate taxes. The vote was the icing on a cake that the Organization for Economic Cooperation and Development (OECD) has… – Continue reading
The Organisation for Economic Co-operation and Development (OECD) sees treaty shopping as an important source of Base Erosion and Profit Shifting (BEPS). In this context, it identified the prevention of treaty abuse as one of fifteen issues or “actions” in respect of which recommendations were to be formulated as part… – Continue reading
We are all aware of “base erosion and profit shifting” or “BEPS”. On 5 October 2015, the OECD released its final reports in connection with its BEPS Action Plan including its final report on Action 15 dealing with the development of a multilateral instrument to modify bilateral tax treaties (“Final… – Continue reading
Corporation tax receipts for the year came to €4.6bn in 2014. By October this year, receipts had already exceeded that, with the expectation that the full-year receipts will be around €6.5bn with the Budget projecting growth in receipts in 2016 of 10 per cent. In a little over a year,… – Continue reading
Royal Decree 1021/2015, of November 13, establishing the obligation to identify the tax residence of persons who hold or control certain financial accounts and to provide information concerning them in the area of mutual assistance. On November 17 last the above-mentioned Royal Decree was published in the Official State Gazette…. – Continue reading
Lawmakers seek late deal to scale back ‘Cadillac tax’ Lawmakers are making a late push to repeal or scale back Obamacare’s “Cadillac tax” by the end of the year, eying inclusion of changes in a broader tax package, wrote Peter Sullivan of The Hill. But lawmakers in both parties say… – Continue reading
The Government has recently launched a consultation on amending the UK’s interest deductibility rules for companies. The consultation follows the OECD’s recommendations as part of the Base Erosion and Profit Shifting (BEPS) project. In line with those recommendations, it is proposed that a company’s net interest deductions be limited to… – Continue reading
An EU deal with Liechtenstein, which will make it harder for EU citizens to hide cash from the tax man in bank accounts there, was endorsed by Parliament in a vote on Wednesday. Under the deal, the EU and Liechtenstein will automatically exchange information on the bank accounts of each… – Continue reading
Swiss Senate has sealed the end of banking secrecy for foreign clients, following the House of Representatives in accepting the legal groundwork for the automatic exchange of information. The decision paves the way for a “decorous funeral for tax secrecy,” as senator Roberto Zanetti of the leftwing Social Democrats put… – Continue reading
Inland Revenue is looking at the tax treatment of hybrid debt and equity instruments and the use of related party loans funding local subsidiaries as part of a global clamp-down on tax avoidance. Acting deputy commissioner of policy and strategy David Carrigan told Parliament’s finance and expenditure select committee that… – Continue reading
Republicans in both chambers of Congress said international tax reform is necessary to retain companies in the United States following pharmaceutical giant Pfizer’s announcement it is moving its headquarters overseas after its merger with Ireland-based Allergan, citing the country’s high corporate tax rates. During hearings in the House Ways and… – Continue reading
AUTOMATIC EXCHANGE OF INFORMATION IN TAX MATTERS – THE COMMON REPORTING STANDARD Introduction The Common Reporting Standard (CRS) is a tool which facilitates the automatic exchange of information at a global level. The fight against tax evasion in cross border transactions has become a priority for Government around the globe…. – Continue reading
As the Joint Ministerial Council meeting continues in London this week Financial Services Minister Hon Wayne Panton says he intends to meet with European States in a bid to have Cayman removed from their lists of third-country, Non-cooperative Tax Jurisdictions. The minister, speaking at the last sitting of the Legislative… – Continue reading
The European Commission’s use of state aid rules to challenge corporate tax agreements is causing uncertainly for businesses in Europe, Luxembourg finance minister Pierre Gramegna has said. Gramegna told the Financial Times this week that the situation “raises so many issues about predictability and certainty”. The Commission announced in October… – Continue reading
Holiday home owners and others who inadvertantly break new tax rules could be ‘criminalised’ Holiday home owners who miscalculate tax owed, and those inheriting offshore money, face having their income wiped out entirely due to new penalties and punishments being introduced in the New Year. HM Revenue & Customs has… – Continue reading
A new international framework is targeting tax avoidance—and it has implications for captive insurers. Jenny Coletta of Ernst & Young explains In recent years, tax authorities around the world have been increasingly scrutinising captive insurance arrangements, focusing on questions relating to commercial purpose, pricing and substance. In what is likely… – Continue reading
The introduction of the so-called “offshore tax” in Latvia may have adverse effects on Latvia’s accession to the Organization for Economic Cooperation and Development (OECD), reports LETA. The OECD has informed Latvia about this, urging the country to consider the potential effects of the “offshore tax” on its progress towards… – Continue reading
On 17 September, 2015, China State Administration of Taxation (“SAT”) released the Discussion Draft of Implementation Measures for Special Taxation Adjustments (“Discussion Draft”), as a complete revamp to the existing trial version of the Implementation Measures, i.e., Circular 2. Circular 2 has been serving as a backbone transfer pricing (“TP”)… – Continue reading
The Common Reporting Standard (CRS) is the standard for automatic exchange of financial account information produced by the Organisation for Economic Cooperation and Development (OECD) which provides for systematic and periodic automatic exchange of information between signatory jurisdictions. At its heart is a requirement for financial institutions, including British Virgin… – Continue reading
“Luxembourg is famous for two things: its steel industry and its rose cultivation industry”. This quote from an Italian guidebook of the 1930s was uttered by Luxembourg’s Finance Minister Pierre Gramegna at the annual conference of the Luxembourg Directors’ Association on 17 June 2015[1]. The economic outlook of the tiny… – Continue reading
Some U.S. lawmakers on Tuesday used a pair of hearings in the Senate Finance Committee and the House Ways and Means Committee to showboat for corporate special interests and oppose a growing worldwide movement to crack down on international tax avoidance. Last month, leaders of the 20 largest economies in… – Continue reading
The 28 nations of the European Union lose up to $1 trillion per year in revenue thanks to multinational corporations that use a spider’s web of completely legal constructs to lower their taxes. Now, Europe’s law enforcers and lawmakers want to wipe away these intricate tax-avoidance systems. If they have… – Continue reading
Today, the Senate Finance Committee met to discuss the Organization for Economic Co-operation and Development’s (OECD) project on Base Erosion and Profit Shifting (BEPS), a set of proposals on international tax policy approved earlier this fall that will place U.S. companies at a competitive disadvantage globally. Testifying with me today… – Continue reading
“It is not the strongest or the most intelligent who will survive but those who can best manage change”-Charles Darwin The Organization for Economic Co-operation and Development (OECD) released its final recommendations on the Base Erosion and Profit Shifting (BEPS) Project on October 5, 2015. The BEPS project consist of… – Continue reading
The House and Senate held hearings Tuesday on the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting action plan, also known as OECD BEPS, for combating tax avoidance by multinational corporations. A number of the lawmakers expressed a skeptical view of the international tax reforms. “The OECD’s… – Continue reading
Pension schemes should review their holdings in infrastructure heading into 2016, with the dual threat of incoming regulation and high prices potentially threatening returns, Kames Capital has said. Infrastructure has been an increasingly popular asset class for many schemes since bond yields tumbled in the wake of the financial crisis,… – Continue reading
The current international tax regime was developed in the last century when the internet was not yet invented. At that time, a foreign company would typically require a substantial physical presence in Australia before it could be in a position to earn significant amount of income from Australian customers. This… – Continue reading
EU committee to vote on plans to curb tax avoidance EU countries should be compelled to inform other member states in advance of plans to introduce tax initiatives that could affect their own or another country’s effective tax rate, according to a report to be considered by the European Parliament’s… – Continue reading
The Organization for Economic Co-operation and Development (OECD) common reporting standard (CRS) is a standard that provides for the automatic exchange of financial account information between participating governments. The requirements under this standard are in addition to any Foreign Account Tax Compliance Act (FATCA) requirements. The Cayman Islands has recently… – Continue reading
New Article 76-A of the Income Tax Law was published in the Federal Official Gazette on November 18, 2015, establishing three new transfer pricing information returns: Master File, Local File and Country-by-Country Report. Background These measures arise in response to the commitment assumed by Mexico before the Organization for Economic… – Continue reading
(OECD) In Paris on the occasion of the COP21, the Honourable Billy Graham Talagi, Minister for Ministry of Natural Resources of Niue signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters in the presence of Deputy Secretary General Rintaro Tamaki. Developed by the OECD and the Council of… – Continue reading
While the U.S. is plagued by inertia when it comes to tax policy, the rest of the world hasn’t been standing still. The biggest change of late has been the completion of the Organization for Economic Cooperation and Development’s (OECD) Base Erosion and Profit Shifting Project, or BEPS, a multiyear… – Continue reading
Legislative Activity Tax-Writers Begin to Focus on BEPS, Tax Extenders Still Remain Though international tax reform negotiations may have fallen apart for 2015, tax-writers this week will hold their first hearings to address efforts by the Organisation for Economic Co-operation and Development (OECD) to counter corporate tax avoidance as part… – Continue reading
The law, at present, is replete with a complex web of cross-references, often causing confusion The clamour for simplifying tax legislations gets louder as a new government, in its interaction with businesses and the civil society, holds out a promise of a non-adversarial tax regime. The reform of indirect taxes… – Continue reading
Government officials say multinational technology giants are reluctant to pay anything The Korean affiliates of Microsoft (MS) and Oracle are under increasing pressure to pay taxes here, with government officials saying the two multinational technology giants were reluctant to pay anything, although they generated huge a lot of money from… – Continue reading
Action Plan 10 of the Base Erosion and Profit Shifting (BEPS) project of the Organisation for Economic Co-operation and Development (OECD) seeks to align transfer pricing (TP) outcomes with value creation by clarifying the conditions under which transactions between related parties can be re-characterized. It also sheds light on how… – Continue reading
What is the whole point of the 15 actions in the Base Erosion and Profit Shifting (BEPS) code? How will they curb tax dodging and make taxation of multinationals more transparent? Historically, the interaction of different tax policies lead to instances where taxes paid are not commensurate to economic value… – Continue reading
East African countries expect to collect more revenue under a new code drawn, by the world’s richest economies to stop foreign multinationals from dodging taxes in host countries. The new code — Base Erosion and Profit Shifting (BEPS) — adopted by G20 at its meeting in Turkey two weeks ago,… – Continue reading
Tech titans powering the economy shelter money through insane tax-avoidance havens. It’s wrong — and adding up Offshore tax havens enable not only individuals to dodge taxes—they also enable multinational corporations to do so. Often this tax avoidance is done within the letter of the law: multinational groups exploit the… – Continue reading
When it comes to planning for tax season, corporate tax reporting should be considered as part of Enterprise Performance Management. As Margaret Mitchell exclaimed in the classic novel, Gone with the Wind: ‘Death, taxes and childbirth! There’s never any convenient time for any of them.’ And while I hope that… – Continue reading
As Common Reporting Standard (CRS) comes into operation. OHANNESBURG – South Africans with undeclared offshore funds may only have a few months to get their affairs in order or risk facing significant penalties and even criminal prosecution as revenue authorities start the automatic exchange of information. The Common Reporting Standard… – Continue reading
The European Parliament has overwhelmingly approved a suite of corporate tax reforms that will ensure multinational companies pay taxes where profits are made and increase transparency. A total of 508 MEPs voted in favour of the adoption of recommendations put forward by the Special Committee on Tax Rulings last month…. – Continue reading
