Category: OECD

Swiss Government Welcomes BEPS Recommendations

The Swiss Government has tasked the Finance Ministry with responding to the OECD’s recommendations on base erosion and profit shifting. Welcoming the OECD’s proposals, the Council said: “In general, the project outcomes will allow for [the] better coordination of international tax law rules and make it possible to close the… – Continue reading

Lew: Treasury to implement international tax recommendations

Treasury Secretary Jack Lew said Friday that the Obama administration would implement new rules that would lead to sharing business’s information with foreign governments. Lew praised the final recommendations from an Organization for Economic Cooperation and Development project meant to battle offshore tax avoidance, saying there was a “critical need… – Continue reading

Australia Ahead Of The Curve In BEPS Response

The fallout for Australian firms from the BEPS project “won’t be radical in Australia, as we have already moved pre-emptively to strengthen our laws,” Assistant Treasurer Kelly O’Dwyer has said. Commenting on the release of the OECD’s final BEPS reports, O’Dwyer said: “The Coalition Government’s measures line up with the… – Continue reading

France: French Tax Update: Draft Finance Bill For 2016, New France/Germany Double Tax Treaty, And ECJ Steria Decision

This French Tax Update will focus on (i) the main provisions of the draft Finance Bill for 2016 (Projet de loi de finance pour 2016) issued by the French Government on September 30, 2015 and to be discussed before the French Parliament between October and December (“Draft Finance Bill for… – Continue reading

Conference on Base Erosion & Profit Shifting; Confederation of Indian Industry

EVENT OVERVIEW Globally, countries are campaigning for watertight tax regimes and gradually but definitely towards commercially driven business practices, and BEPS seems to be the way to it. Around 44 countries, including India, have come together to create a code to enable looking at transactions with a borderless lens for… – Continue reading

Italy: Italian Corporate Income Tax For Foreign Investors

Corporate income tax Italian corporate income tax (imposta sul reddito delle società, or IRES) is due by resident companies on their worldwide income. A company is deemed to be resident within the Italian territory when it has any of the following elements located in Italy for the major part of… – Continue reading

United States: The Final OECD BEPS Tome Has Arrived

Remarkably on schedule, the OECD this week issued a comprehensive and integrated set of measures to attack base erosion and profit shifting (BEPS) on a global basis. Comprising 15 “Actions” on central issues such as transfer pricing, country-by-country reporting and transfer pricing documentation, treaty abuse, preferential tax regimes, permanent establishments,… – Continue reading

Quarter of businesses to miss BEPS deadline

A quarter of companies say they won’t meet the first deadline proposed by the Organisation of Economic Co-operation and Development (OECD) in its base erosion and profit shifting (BEPS) action plan, reports Economia. Globally, 74 per cent said they will complete their country-by-country analysis by the first due date, December… – Continue reading

UPDATE 1-Germany wants monitoring of new regime to fight corporate tax dodging

Oct 8 (Reuters) – German Finance Minister Wolfgang Schaeuble said on Thursday he would propose a monitoring scheme to ensure the full implementation of a proposed system to overhaul the way international companies are taxed. The Organisation for Economic Cooperation and Development (OECD) published proposals on Monday to change outdated… – Continue reading

Singapore backs international plan to curb tax avoidance

Singapore has given the thumbs up to an international plan that aims to clamp down on tax avoidance by multinational firms, reports the Straits Times. The Republic says if the plan is soundly implemented, it will help foster free and fair economic competition. Singapore agrees with the main principle of… – Continue reading

OECD report not the last word on Ireland’s FDI corporation tax regime

The global war on corporate tax avoidance doesn’t look like being so gruesome after all. The OECD reckons that governments are losing out on at least €213bn per year from aggressive tax planning by multinationals, reports the Irish Independent. A new book by a Berkeley University economics professor estimates that… – Continue reading

Commission asks public for views on CCCTB proposals

The Common Consolidated Corporate Tax Base is strongly opposed by Ireland The European Commission has opened a public consultation into its proposed scheme for a Common Consolidated Corporate Tax Base (CCCTB) ahead of its planned re-launch next year. The EU’s executive arm is seeking insights from stakeholders by January 8th… – Continue reading

Tax Execs Expect Major Tax Changes from OECD BEPS Project

Senior tax executives are preparing for changes in the tax landscape as a result of the Organization for Economic Co-operation and Development’s base erosion and profit shifting project. A new survey by Ernst & Young, presented Thursday at its 34th Annual International Tax Conference, found 88 percent of tax directors… – Continue reading

AUSTRALIA: BEPS IMPLICATIONS FOR MULTINATIONAL ENTERPRISES

There are implications for multinational enterprises in Australia with this week’s release by the Organisation for Economic Cooperation and Development (OECD) of final recommendations for substantial international tax reform under the base erosion profit shifting (BEPS) project. OVERVIEW The final BEPS package follows on from, and is largely consistent with,… – Continue reading

Call for care on tax changes

New Zealand needs to be careful not to get out of step with the rest of the world in implementing tax changes on multinational companies seeking to minimise their tax obligations, Deloitte Dunedin tax partner Peter Truman says. The Government this week released a report on Base Erosion and Profit… – Continue reading

Automatic exchange of information key to prevent international tax evasion: Jaitley

New Delhi, Oct 8 (KNN) Finance Minister Arun Jaitley has emphasised the need to ensure that Common Reporting Standards on Automatic Exchange of Information are implemented globally on a fully reciprocal basis as this would be a key to prevent international tax evasion and avoidance. Jaitley was speaking at 49th… – Continue reading

Treasury release draft law for implementation of the Common Reporting Standard

In brief On 18 September 2015, Treasury released exposure draft legislation in relation to the implementation of the Organisation for Economic Co-operation and Development’s (OECD) Common Reporting Standard (CRS) for the automatic exchange of financial account information. The CRS is intended to reduce international tax evasion and represents the next… – Continue reading

Canada: International Tax Reform 2015-BEPS Final Reports

On October 5, 2015, the OECD released its final reports relating to the OECD/G20 base erosion and profit shifting (BEPS) project (the Final Reports). The BEPS project began in 2013 and has received unprecedented attention from governments and the private sector. The Final Reports outline the OECD’s recommendations and the… – Continue reading

Why India should defend this whistleblower from the Swiss justice system

Hervé Falciani, who exposed the global offshore industry with the HSBC data leak, is facing prosecution under skewed Swiss laws for data theft and espionage. This is his story. Swiss justice hounds those who breach banking secrecy even if in doing so they expose rogue banks. In the past decade,… – Continue reading

ATO widens its multinational tax avoidance net to 80 companies

The Australian Tax Office will open negotiations with 80 multinational companies to encourage them to “restructure” in order to pay more tax on profits generated in Australia. The move represents a near tripling of the ATO’s multinational watch list after it embedded staff inside 30 companies to learn more about… – Continue reading

United States: US Congress Considers Domestic Patent Box Regime – Should You Reevaluate Your Global Structure?

Patent box regimes typically apply deeply discounted tax rates to income derived from intellectual property. Recently unveiled draft legislation may pave the way for a US patent box regime and incentivize taxpayers to reevaluate their global structures. Introduction The US imposes the highest corporate income tax rate (35%) in the… – Continue reading

Cayman Islands: New ITC-AML Headaches For Cayman Funds In 2016

In 2016, hundreds of directors, managers, principal points of contact (PPCs), compliance officers, administrators, and Money Laundering Reporting Officers (MLROs) serving Cayman Islands funds, banks, trust companies and other Reporting Financial Institutions (RFIs) will start to feel the full force of ‘a great wind’: global tax transparency. If you are… – Continue reading

Australia widens legislation to target more companies for tax avoidance

Federal government increases number of companies under tax office scrutiny from 30 to 80 under budget measures announced in May The federal government has widened the scope of legislation aimed at tackling multinational tax avoidance, increasing the number of large companies under the tax office’s microscope from 30 to 80…. – Continue reading

Uber and Airbnb confirm they send profit offshore

Uber and Airbnb have revealed in submissions to a federal inquiry that they route profit through companies in the Netherlands and Ireland, where taxes are lower. Uber and Airbnb have told a Senate corporate tax avoidance inquiry that while they comply with Australian tax laws, their Australian operations merely provide… – Continue reading

US companies holding $2.1 trillion offshore profits

There’s enough cash sitting in offshore bank accounts to wipe out the federal deficit — if only it was subject to U.S. taxes. That’s because U.S. companies are saving some $620 billion by parking profits outside the country, according to the latest accounting from Citizens for Tax Justice and U.S…. – Continue reading

Singapore’s tax jurisdiction largely in line with OECD’s tax proposals: Experts

The proposals are aimed at preventing aggressive tax planning by multinationals. However, experts warn that the risk of double taxation may increase. SINGAPORE: Tax experts have said that Singapore’s tax jurisdiction is broadly in line with new tax proposals announced on Monday (Oct 5) by the Organisation for Economic Co-operation… – Continue reading

ECOFIN Council reaches agreement on the automatic exchange of information on tax rulings and APAs

On 6 October 2015, the Council of the European Union reached agreement on a proposal for a Council Directive (‘the New Directive’) amending Directive 2011/16/EU (Directive on administrative cooperation between Member States) and requiring automatic exchange of information on ‘advance tax rulings’ (‘Tax Rulings’) and ‘advance pricing arrangements’ (‘APAs’) between… – Continue reading

OECD proposals could save countries US$240bn in lost taxes

With the bulk of the OECD’s work on the BEPS project complete, attention will now turn to the implementation of the recommendations by member countries and others. Minister for Finance, Michael Noonan said that he welcomed the Base Erosion and Profit Shifting (Beps) report, and that the OECD’s proposals would… – Continue reading

EU: AUTOMATIC EXCHANGE OF INFORMATION, CROSS-BORDER TAX RULINGS AND APAS

EU finance ministers today agreed to introduce provisions for the automatic exchange of information on cross-border tax rulings—the latest development concerning the European Commission’s initiative to address tax avoidance and harmful tax competition. Detailed provisions to be included in a directive are expected to be finalized before the end of… – Continue reading

72% of Fortune 500 Used Foreign Tax Havens

Nearly three-quarters of Fortune 500 companies booked their profits to tax havens last year, with just 30 companies accounting for 62 percent of earnings stashed offshore, according to a new report. The report, “Offshore Shell Games,” released Tuesday by the U.S. PIRG Education Fund and Citizens for Tax Justice, found… – Continue reading

CORRECT: NZ’s biggest companies may face ‘enormous compliance burden’ from OECD tax dragnet

Oct. 6 (BusinessDesk) – Fonterra Cooperative Group is likely to be among some 20 New Zealand companies left dealing with increased red tape to comply with wide-ranging reforms to corporate tax rules proposed by the Organisation for Economic Cooperation and Development and expected to be endorsed by the world’s 20… – Continue reading

BEPS plan puts companies in the firing line, say experts

The OECD-G20 plan to stop multinational tax avoidance could put companies in the middle of border disputes between revenue authorities, tax experts have warned. But civil society groups say the plan has not gone far enough and could make it easier for some multinationals to dodge tax. Treasurer Scott Morrison… – Continue reading

25% of Global Companies Say They Won’t Meet BEPS Deadline

One-quarter of corporate tax and transfer pricing directors surveyed say their companies will fail to meet the first deadline proposed by the Organisation for Economic Co-operation and Development (OECD) in its Base Erosion and Profit Shifting (BEPS) Action Plan. Finance ministers for the G20 countries called on the OECD to… – Continue reading

OECD: countries commit to minimum standards on international tax dispute resolution

Countries should commit to minimum standards on the resolution of international tax disputes, the Organisation for Economic Co-operation and Development (OECD) said in a report published as part of its base erosion and profit shifting (BEPS) project.06 Oct 2015 The standards would include a commitment to “seek to resolve” cases… – Continue reading

CAB requests the removal of named Caribbean territories on US “Tax-haven” list

PRESS RELEASE – The Caribbean Association of Banks Inc. (CAB) is once more forced to express its deep concern over yet another “tax-haven” list which includes 15 Commonwealth Caribbean countries. The referred list appears within the District of Columbia’s 2015 Budget Support Act which expands the definition of “tax haven”… – Continue reading

Top Wall Street Banks Stash Billions Of Dollars In Nearly 400 Offshore Tax Havens

Six of the nation’s largest banks — Bank of America, Citigroup, JPMorgan Chase, Wells Fargo, Morgan Stanley and Goldman Sachs — utilize a combined 395 known tax havens to avoid potential tax bills in the billions, according to a new analysis. In total, the big six banks kept $126 billion… – Continue reading

US firms pan international tax proposal

The architects of a sweeping set of recommendations to battle offshore tax avoidance insist their project won’t allow foreign countries to simply grab cash from U.S. companies. The business community isn’t convinced. Senior officials at the Organization for Economic Co-operation and Development (OECD), a Paris-based research group sponsored by almost… – Continue reading

Mythbusters: the UK/Spain tax treaty

Writing exclusively for SuperyachtNews.com, Patrick Maflin, of Marine Accounts, advises crewmembers on how best to avoid falling foul of the UK/ SPAIN Double Taxation Agreement… The Seafarers Earnings Deduction (SED) is arguably the taxation scheme of choice for most Seafarers nowadays working on foreign going yachts. It is open to… – Continue reading

Ireland tweaks tax regime to divert avoidance criticism

The Irish government is set to make further changes to the country’s corporate tax regime as it seeks to align itself with a global initiative to clamp down on corporate tax avoidance, reports the Financial Times. The change being considered will oblige companies that have global headquarters in Ireland to… – Continue reading

Gaming the System: Underlying Problems of the U.S. Tax Code Must be Addressed

Last year at this time, news about “tax inversions” was grabbing headlines – cases where large U.S. multinationals would buy a foreign company in a tax-friendly jurisdiction, and then relocate its headquarters to reap the tax arbitrage benefits. The Obama administration responded to the rash of high-profile inversions with new… – Continue reading

OECD poised to release new tax dodge rules

Senior EY partners Andy Archer and David Snell look at some looming changes to international tax rules. In what will be the biggest change to the international tax rule book since it was put in place before World War 2, the OECD will tomorrow (4 am Tuesday 6 October) release… – Continue reading

It’s Here; The Automatic Exchange of Information Under FATCA Began September 30th

The IRS has announced that as of September 30, 2015 it will implement the automatic exchange of tax information as set forth in the Foreign Account Tax Compliance Act, (FATCA). The IRS Commissioner in announcing the implementation of the automatic exchange of information stated: “This information exchange is part of… – Continue reading

Foreign governments ready cash grab on U.S. earnings

Opposition to foreign taxes on American investment and hard work has been coded into our national DNA for almost 240 years. Yet almost two and a half centuries after resolving that we would not stand idle while others decide how to tax us, Americans once again must take decisive action… – Continue reading

US Has World’s Third-Highest Corporate Tax Rate

Not only does the United States retain the dubious distinction of having the highest corporate tax rate in the Organisation for Economic Cooperation and Development country grouping, it now has the third-highest rate of corporate tax in the world, according to the Tax Foundation. The non-partisan tax policy think tank… – Continue reading

Plans to overhaul global tax system to be published

A plan for overhauling the global system for the taxation of multinationals, to be published on Monday in Paris, will contain major challenges and opportunities for Ireland’s vital foreign direct investment (FDI) sector, according to tax experts, reports the Irish Times. The culmination of two years’ work, the report by… – Continue reading