Category: OECD

US ‘tax inversion’ deals skew Ireland’s FDI numbers

A spate of so-called “tax inversion” deals involving companies based in Ireland appears to be distorting the country’s foreign direct investment (FDI) numbers, The Irish Times reports. An OECD report suggests investment by Irish firms abroad more than doubled to US$75 billion in the first half of 2015. The study… – Continue reading

South Africa: South African Tax Legislation: Proposed Amendments In An International Tax Context

South African Tax Legislation: Proposed Amendments in an International Tax Context[1] This article sets out a brief summary of some of the proposed amendments introduced by recent South African draft Tax Bills. The article focuses on amendments in the context of international taxation. The draft Taxation Laws Amendment Bill, 2015… – Continue reading

OECD Talks BEPS Implementation With Eurasian Officials

In late October, public and private sector representatives from Eastern Europe and Central Asia met to discuss collaborating on the implementation of the OECD’s recommendations on base erosion and profit shifting. The meeting was hosted in Tbilisi by the Georgian Ministry of Finance and the Georgia Revenue Service, in co-operation… – Continue reading

Luxembourg removed from blacklist

Meeting in Barbados, members of the Global Forum will vote Friday night on Luxembourg on the report examining the country in line with international standards of fiscal transparency. This vote will be a mere formality since experts have already been doing an inventory of business reforms by the government for… – Continue reading

Tianjin tragedy is very much our business

Blast waves: smoke billows from the site of an explosion that reduced a parking lot filled with new cars to charred remains at a warehouse in northeastern China’s Tianjin municipality. Most of Bermuda’s major insurers and reinsurers had significant exposures to this disaster. (Photograph by Ng Han Guan/AP Photo) Tianjin… – Continue reading

Gold Fields, Sasol top in tax reporting

Gold Fields and Sasol have clinched the top awards in PwC’s Building Public Trust Awards: Excellence in the field of tax reporting in 2015. Gold Fields was the overall winner in the category for tax reporting for multinational companies, while Sasol was announced the overall winner in the category tax… – Continue reading

Barbados endorses OECD’s Global Standard for the Automatic Exchange of Information

Barbados has formally endorsed the AEOI global standard during a signing ceremony held in Barbados on Wednesday. The event was held in conjunction with a meeting of the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes that was also hosted in Barbados. “Transparency and the exchange… – Continue reading

Kuwait commits to US mandated FATCA law

(MENAFN – Arab Times) The US Foreign Account Tax Compliance Act (FATCA) model has spurred the rise of a global automatic exchange of information, informed Hannah Shipley, Director at Ernst & Young, while speaking about FATCA and its implications during a business panel discussion held at the Kuwait Chamber of… – Continue reading

Tax deductibility of corporate interest expense

HM Treasury has published a consultation on the tax deductibility of corporate interest expense in the UK. The consultation has been prompted by the recent publication by the Organisation for Economic Co-operation and Development (“OECD”) of its final Base Erosion and Profit Shifting (“BEPS”) reports, in particular BEPS Action 4,… – Continue reading

OECD Issues Final BEPS Proposal; No Response from Congress Yet

Final recommendations about how multinational companies should be allowed to shift profits among different tax jurisdictions were issued this month, and the U.S. Congress has not yet indicated whether it will consider legislation in response to the proposals. Issued by the Organisation for Economic Cooperation and Development (OECD) on October… – Continue reading

Mexico: Latin American Tax: Special Report

Mexico is experiencing a rough time, economically speaking at the moment, but hopes are high for better times ahead. With new tax laws and a relatively young government, these are interesting times for this country. To find out more about how the recent tax reforms will affect Mexico and the… – Continue reading

Fund industry must act now or face crunch time in the final countdown to Global FATCA, says Linedata

With the starting line for implementation only two months away, Justin Hayes, product manager at Linedata, the leading international software and technology provider, says fund administrators and investment managers need to get to grips with the OECD’s Common Reporting Standards, dubbed ‘Global FATCA’, before it’s too late. “Financial institutions in… – Continue reading

Australia out of step with global corporate tax rate trends

Australia’s corporate tax rate is higher than the global average, according to KPMG’s 2015 global tax rate survey, SmartCompany reports. While Australia’s corporate tax rate currently sits at 30 per cent, the global average sits at 23.68 per cent. The United States has the highest corporate tax rate at 40… – Continue reading

Linedata: The time is now for CRS

Investment managers and fund administrators should act now in order to be prepared for the Organisation for Co-operation and Development (OECD) Common Reporting Standard (CRS) ahead of the start of the first reporting period, according to Justin Hayes, product manager for Linedata. The CRS, sometimes called a global version of… – Continue reading

Fighting tax evasion: EU and Liechtenstein sign new tax transparency agreement

Under the new agreement, Liechtenstein and EU Member States will automatically exchange information on the financial accounts of each other’s residents from 2017. Pierre Moscovici, Commissioner for Economic and Financial Affairs, Taxation and Customs, said: “Today the EU and Liechtenstein are sending out a clear message: we are partners in… – Continue reading

Belgian tax official reveals details on new transfer pricing documentation requirements and BEPS plans

In a BEPS seminar organised by the Federation of Enterprises in Belgium this week, with a special focus on the practical consequences for Belgian enterprises, a representative of the Belgian Ministry of Finance, Steven Van Elsuwe;, provided more details on the new legislative proposals that have been prepared so far,… – Continue reading

Transfer pricing makes big splash on global taxes

Multinationals have generated big-time revenues with its subsidiaries spread all over the world, which means huge profits and that’s taxable income. In recent years, a number of conglomerates – Amazon, Apple, Google and Starbucks – have engaged in so-called profit-shifting (profit allocation) via transfer pricing methods to pay minuscule taxes…. – Continue reading

Fund industry must act now or face crunch time in the final countdown to Global FATCA

Sunday 1st November will mark two months until the start of the first reporting period under the OECD’s Common Reporting Standards (‘Global FATCA’). Justin Hayes, product manager at Linedata, comments on why there is now no time to waste for investment managers and fund administrators to prepare for the burdensome… – Continue reading

Brazilian wealth seeks Cayman deals in complex environment

(CNS Business): The use of Cayman Islands funds as a wealth management tool for high net worth Latin American families was debated last week at the STEP LatAm Conference in Brazil, where kidnapping is a constant worry for the wealthy and demand for outbound investments is fuelled by privacy and… – Continue reading

HUNGARY: IMPLEMENTING TRANSFER PRICING-RELATED BEPS ACTIONS

Action 13 of the final package of reports issued by the Organisation for Economic Cooperation and Development (OECD) under the base erosion and profit shifting (BEPS) project focuses on a company group’s global value chain and transfer pricing policy, and introduces a standardized three-tiered approach to transfer pricing documentation—core documentation… – Continue reading

FRANCE: RECENT TRENDS IN TRANSFER PRICING, SURVEY

The European Commission recently published new rulings, the OECD published its base erosion and profit shifting (BEPS) final reports, and many countries are reviewing and reinforcing their transfer pricing rules—and France is no exception. Tax professionals in France have observed certain recent trends with regards to transfer pricing. The current… – Continue reading

Ireland’s Finance Bill 2015 – key changes for international companies and financial institutions

Following the recent Irish budget statement (the “Budget”), the Finance Bill 2015 (the “Bill”) has been published and it implements the changes announced by the Irish Minister for Finance (the “Minister”). The Bill includes additional detail on: the new knowledge development box (“KDB”); and Ireland’s implementation of country by country… – Continue reading

Ireland cuts tax for IP profits

Ireland has announced a new 6.25 per cent corporate tax rate for intellectual property research Ireland’s 12.5 per cent corporate tax rate is already one of the lowest in Europe, Economia reports. Now, companies investing in research and development (R&D) will be able to avail of the even lower rate… – Continue reading

Managing The Changing Tax Landscape: The OECD’s BEPS Recommendations Will Impact Every Multinational

The global climate for international tax is rapidly changing. The OECD, the EU and tax authorities around the world have focused attention on tax planning implemented by leading multinational companies. The OECD believes that tax planning and related structures lead to an annual revenue loss of US$100-240 billion. Since 2013,… – Continue reading

Banks Et Al Brace For More Financial Account Information Reporting

On the heels of extensive preparation for the implementation of FACTA in St. Kitts and Nevis, banks and other financial institutions are now starring down the barrel of additional financial accounts information reporting on a wider scale. The Organization for Economic Co-operation and Development (OECD) has proposed a global version… – Continue reading

Your Taxes: Exporters beware of sales agents

On October 5 the OECD published recommended measures that purport to tackle BEPS – Base Erosion Profit Shifting. Exporters around the world need to take note of the latest recommendations of the OECD. Any business that uses overseas agents or warehouses should take note. A company resident in country A… – Continue reading

Ending EU citizens’ bank secrecy in Switzerland

Parliament adopted its stance on a deal with Switzerland to make it harder for EU citizens to hide cash from the tax man in Swiss bank accounts, in a vote on Tuesday. Under the deal, the EU and Switzerland will automatically exchange information on the bank accounts of each other’s… – Continue reading

The Latest South African Tax Proposals are Far-reaching

There was a time when, from a tax perspective, South Africa’s “mini budget” used to be a non-event. The main emphasis was on the annual budget speech delivered in February each year when they announced tax policy proposals. However, over the past few years there has been an increasing tax… – Continue reading

Government launches consultation on tax avoidance proposals

The government has launched a consultation on tax avoidance policies related to interest deductions that could have significant consequences for real estate. The proposals were released by the the Organisation for Economic Co-operation and Development (OECD) as part of a series of recommendations earlier this month designed to prevent companies… – Continue reading

Is Europe Honest Enough To Deal With Tax-Dodgers?

The EU tax rulings against Starbucks and Fiat Chrysler are but trifles compared to the ones extant against Apple and Amazon. Everyone lies about tax. Holland said it followed international tax standards when everyone knows it’s a corporate tax haven. That’s why ST has its HQ there. Ireland and Luxembourg… – Continue reading

Relaxed tax residency rules to help MNCs

Foreign companies with Indian shareholders won’t have to pay taxes here for their worldwide income unless they are managed from India on an everyday basis. If these foreign companies are managed from outside India, whether or not they are promoted by resident Indians, they will have to pay taxes in… – Continue reading

BEPS will affect around 9,000 companies globally: Grace Perez-Navarro

The Organisation for Economic Cooperation and Development (OECD) has been leading the charge to improve transparency in tax administration and curb tax avoidance by multinational companies. Endorsed by the G20 nations, including India, OECD recently came out with a package of measures and a road map to tackle base erosion… – Continue reading

Commentary: Multinationals put poor countries in fix

The African Union Advisory Board on Corruption (AUABC) recently requested major multinationals operating in Africa to be more open about the taxes and royalties they pay governments to improve transparency and accountability. Although a reasonable request, this is a tall order when you consider that often it is the governments… – Continue reading

UK: Data, Privacy And Taxation – A Very Modern Conflict

Since the revelations on government surveillance and data capture by Edward Snowden, journalists have rightfully raised concerns about governments’ insatiable appetite for data collection and the resulting encroachment on citizens’ civil liberties. In the EU an individual’s right to privacy is regarded as a human right in accordance with Art…. – Continue reading

Cayman Islands: Cayman Islands Issue OECD Common Reporting Standard Regulations

The Cayman Islands Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations, 2015 (the “CRS Regulations”) were issued on 16 October 2015. Cayman Islands Government Industry Advisory – CRS Regulations Are in Effect The CRS Regulations, which are the first part of two in the roll-out of the Cayman… – Continue reading

Ireland: Finance Bill shows signs of scrutiny of corporate tax regime

The key corporate tax measures in the Finance Bill show clear signs of the international scrutiny now surrounding multinational tax. The main new measure, the knowledge development box offering a lower tax rate on profits earned as a result of research and development, has been strictly drawn up to comply… – Continue reading

UK and Ireland move forward with ‘modified nexus’ intellectual property regimes

On October 22, the United Kingdom’s tax and customs authority announced a public consultation for its proposed modification to its existing patent box regime. The patent box regime is intended to provide incentives for companies that develop patents in the UK and to ensure new and existing patents are further… – Continue reading

Shell companies’ patents to come under domestic tax net on adoption of BEPS

MUMBAI: Technologies that are developed in India but their patents registered in tax havens may come under the domestic tax net from the next financial year, when the country is expected to adopt a new world standard aimed at preventing abuse of double taxation avoidance agreements. Many multinational and local… – Continue reading

Strategic resets under new MAP and APA revenue procedures

Introduction The Internal Revenue Service (IRS) recently replaced Revenue Procedure 2006-54 for requesting assistance under the mutual agreement procedure (MAP) article of US tax treaties, and Revenue Procedure 2006-9 for requesting advance pricing agreements (APAs). New Revenue Procedures 2015-40 and 2015-41 largely track draft procedures issued in 2013 (Notices 2013-78… – Continue reading

Corporate Pressure For US International Tax Reform

Major US investor Carl C. Icahn and the Chief Executive Officer of TechNet, Linda Moore, have both recently written letters to leading lawmakers pointing out that the passage of international tax reform by Congress has become a matter of extreme urgency. In his letter, Icahn announced that “the time has… – Continue reading

European Commission adopts first two decisions in EU tax probe in push for corporate tax reform

On 21 October, the European Commission (“EC”) adopted its first decisions in its investigation into Member States’ tax rulings. The investigation, which began in June 2013, has also targeted tax rulings given to Apple and Amazon as well as Belgium’s so-called “excess profits regime”. Although the investigation is conducted under… – Continue reading