Category: OECD

OECD aims to win over cynics of tax reforms

THE ORGANISATION for Economic Co-Operation and Development (OECD) must win over cynics when it announces its recommendations for a co-ordinated international approach to reform the international tax system later today. The measures will range from debt relief and harmonising rules on subsidiary companies, to linking sales and tax in each… – Continue reading

Why landmark OECD tax reform is doomed before it starts

The OECD’s final package of proposals for reforming the international system for taxing companies brings to an end the two-year BEPS project led by the OECD and other G20 countries which also included participation by representatives of developing countries, business, academia and NGOs. Developing the BEPS, or Base Erosion and… – Continue reading

S. Korea, China, Japan finance ministers to hold talks in Lima

SEJONG, Oct. 5 (Yonhap) — Finance ministers of South Korea, China and Japan will hold talks to coordinate policies on the sidelines of the Group of 20, International Monetary Fund (IMF) and World Bank meetings in Peru this week, the government said Monday. The finance ministry said the meeting, scheduled… – Continue reading

KPMG Statement On OECD’s Final Recommendations On Base Erosion And Profit Shifting (BEPS) Initiative

NEW YORK, Oct. 5, 2015 /PRNewswire/ — The following statement is being issued today by KPMG LLP on the final recommendations released on Oct. 5 by the Organisation for Economic Co-operation and Development (OECD) on its coordinated Action Plan on Base Erosion and Profit Shifting (BEPS): “The OECD’s final recommendations… – Continue reading

Bye bye Mauritius? With BEPS, tax havens will be viewed differently

With the final draft of the OECD’s BEPS initiative – Base Erosion and Profit Shifting – out later today, the taxman’s ability to tax international transactions as well as those of foreign firms operating in India will go up dramatically; the idea behind the initiative is to treat all cross-border… – Continue reading

Commonwealth finance ministers to focus on global tax reforms co-operation

LONDON: Creating a more participatory approach to tax co-operation tops the agenda of this year’s meeting of Commonwealth finance ministers in Lima on October 7. Delegates will discuss the need for developing countries to be more active in global negotiations to prevent international tax avoidance and illegal tax evasion. The… – Continue reading

Political & Economic week ahead: will TPP deal close?

Two big offshore deals kick off the week. The first is the Trans-Pacific Partnership Agreement. The long-awaited deal is a bit like the Jabberwocky poem in Alice in Wonderland – the alarmism means the political atmosphere is full of strange and threatening noises which only leave a general impression that… – Continue reading

Global Tech Firms Brace for Tax Rules Which Could Create New Disputes

PARIS–Global tech firms such as Amazon.com Inc. are already preparing for new tax rules that could force them to pay corporate taxes in more countries where they operate, but are also girding for what some say will be more fights with–and between–national tax authorities. The Organization for Economic Cooperation and… – Continue reading

A Tax Revolution in the Making in EU

Europe’s stiff-neckedness is difficult to cure. To come to an agreement for supranational treatment of a certain issue there needs to be a large cataclysm or at least a large scandal. In the case of taxation policy the problem begins to gain urgent and most importantly European status after the… – Continue reading

Revealed: how AstraZeneca avoids paying UK corporation tax

Pharmaceuticals group defends use of legal avoidance scheme, after paying no UK corporation tax over two years despite global profits of £3bn AstraZeneca, one of Britain’s largest businesses, is using a multimillion-pound tax avoidance scheme in the Netherlands, set up months after the UK relaxed its tax laws for multinationals… – Continue reading

OECD to unveil global tax plans

The OECD’s measures to reform international corporate tax systems will cause Ireland fewer problems than forecast, but for eurozone countries it will be just the beginning of greater and more detailed change. Following two years of constant meetings between tax experts from its 34 country members, the Paris-based body releases… – Continue reading

OECD Beps: Biggest corporate tax reform plan since 1920s

On Monday (5 Oct) the Paris-based Organisation for Economic Cooperation and Development (OECD) will present its final Base Erosion and Profit Shifting (Beps) project corporate tax reform proposals and on Tuesday the Ecofin council of EU finance ministers, is expected to agree on the exchange of tax rulings between member… – Continue reading

Taxation of undistributed profits of foreign companies controlled by Indian MNCs’, an evident outcome?

By: Jayesh Sanghvi, Partner & National Leader – International Tax Services, EY India Multinational groups can create non-resident affiliates in low tax jurisdictions to which income is shifted, wholly or partly for tax reasons rather than for non-tax business reasons. Such overseas profits are not subjected to tax in the… – Continue reading

Osborne to net billions as huge global crackdown on multinational tax avoidance begins

The world’s richest nations will launch a huge crackdown on multinational tax avoidance on Monday as part of the biggest shake-up of international tax rules for decades. The move could lead to a multi- billion pound gain for Chancellor George Osborne and higher tax bills for a raft of blue-chip… – Continue reading

Cyprus: Double Tax Agreement Round-Up

The new Protocol to the Cyprus – Ukraine double taxation agreement The Cyprus Ministry of Finance has announced that agreement has been reached with Ukraine on a Protocol that will amend the existing DTA between the two countries. The existing DTA was signed in 2012 and entered into force on… – Continue reading

Caribbean countries under attack

Once again, Commonwealth Caribbean countries are under attack as “tax havens”, even though they are nothing of the sort. This time it is not only the usual countries which have been listed. Trinidad and Tobago has been included, and we can bet that Jamaica and Guyana will be added unless… – Continue reading

Corporate tax regime to face renewed scrutiny

EU member states to reveal information on tax rulings offered to companies Ireland’s corporate tax regime is to come under renewed scrutiny next week as EU finance ministers sign off on a proposal obliging member states to reveal information on tax rulings offered to companies. EU finance ministers meeting in… – Continue reading

Tax Court Decision in Altera Overturns Important Transfer Pricing Regulations

On July 27, 2015, the U.S. Tax Court issued a stunning rebuke to the IRS by invalidating the part of the Internal Revenue Services’ (IRS) cost-sharing regulations under section 482 of the Internal Revenue Code that says taxpayers have to take into account, among other costs, the costs of stock-based… – Continue reading

Denmark Legislates For CbC Reporting

On September 18, 2015, the Danish Ministry of Taxation published draft legislation to introduce a new country-by-country reporting obligation for multinational corporations. The draft Bill would introduce the new three-tiered approach to transfer pricing documentation that is to be proposed formally by the OECD as part of the BEPS deliverables… – Continue reading

National Assembly committee wants to hear from banks at tax haven hearings

Quebec — Tax havens are depriving Quebecers of at least $1.5 billion a year, said Québec solidaire MNA Amir Khadir on the opening day of parliamentary hearings on the worldwide phenomenon. The National Assembly’s public finances committee decided last June to dedicate several days this fall to the study of… – Continue reading

Bermuda: Impact Of The Organisation For Economic Co-Operation And Development’s Common Reporting Standards On Cayman Islands Entities

On 16 June 2015, the Department of International Tax Cooperation of the Cayman Islands (the “DITC”) announced that it would be implementing the CRS into domestic law. The draft Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations, 2015 are currently under review and it is expected that these… – Continue reading

New tax landscape imposes burdens on corporate entities –PwC report

A new report by global consulting outfit, Price¬waterhouseCoopers (PwC), released on Monday has indicated that expanding com¬pliance burden, more audits and the potential for increased and double taxation remain key hurdles facing companies due to the rapidly evolving global tax landscape. The report’s findings showed that the demand for greater… – Continue reading

Ambassador Newry protests Bahamas’ tax haven status in DC

WASHINGTON, D.C., Sept. 30, 2015 –His Excellency Dr. Eugene Newry, Bahamas Ambassador to the United States, has written a letter to Municipal Officials of the District of Columbia and Federal Congressional Officials protesting “in the strongest terms” The Bahamas’ designation as a “tax haven” by D.C. authorities in the District… – Continue reading

Preventing BEPS by assuring transfer pricing outcomes are in line with “value creation”

The OECD/ G20 Action Plan on Base Erosion and Profit Shifting (BEPS) published in July 2013, identifies 15 actions to address BEPS in a comprehensive manner. Actions 8-10 of the BEPS Action Plan relate to a number of closely related topics. These include the development of rules to prevent BEPS… – Continue reading

Hammer of BEPS on Harmful Tax Practices in disregard of transparency and substance

By: Pinakin D Desai, Partner – Tax & Regulatory services, EY India The term Base Erosion and Profit Shifting (BEPS) refers to tax avoidance strategies which, by exploiting gaps and mismatches in tax rules, shift profits of Multinational Enterprise (‘MNE’) Groups to low or no tax locations where there is… – Continue reading

OECD eyes rules to curb tax avoidance

The Yomiuri Shimbun The Organization for Economic Cooperation and Development will establish a comprehensive package of international rules to clamp down on tax saving tactics by multinational companies, The Yomiuri Shimbun learned Tuesday. The pillar of the package is to halt tax-saving practices like unrealistic lending and borrowing as well… – Continue reading

Bill n° 6847 – amendment to the participation exemption regime in Luxembourg

On 5 August 2015, the Luxembourg government presented a bill implementing Council Directives 2014/86/UE and 2015/121/UE amending Council Directive 2011/96/UE of 30 November 2011 on the common taxation applicable in the case of parent companies and subsidiaries of different Member States (the Parent-Subsidiary Directive). In accordance with Directive 2014/86/UE, the… – Continue reading

Tax experts call for €1bn package to boost entrepreneurship

Ireland ‘needs to end its dependence on multinationals’ Ireland needs to end its dependence on multinationals and broaden its support to indigenous businesses, tax experts said yesterday, as they called for a €1 billion package to boost entrepreneurship. “While Irish tax policy must ensure that Ireland remains a competitive location… – Continue reading

BEPS recommendation: Lower thresholds for permanent establishments may impact MNEs going global

At the request of the G20, OECD published its Action Plan on addressing ‘base erosion and profit shifting’ (BEPS) in July 2013, wherein it identified 15 actions on BEPS for future work, intending to carry out fundamental changes to the international tax standards. Amongst other, Action 7 deals with ‘preventing… – Continue reading

Steps to avert treaty abuse makes treaty access more taxing!

Tax treaties serve to reduce or eliminate double taxation which, if unrelieved, would be a significant barrier to cross-border trade and investment. At the same time, there was need felt to protect against granting of treaty benefits in inappropriate circumstances. In this background, the work of the OECD and G20… – Continue reading

New SwissLeaks analysis reveals how tax haven secrecy harms developing countries

30 September 2015 -New, detailed examination of the SwissLeaks files by Christian Aid working with the US-based Financial Transparency Coalition (FTC) graphically reveals the harm tax haven secrecy does to the economies of developing countries. The SwissLeaks scandal involves thousands of secret accounts at HSBC’s Swiss subsidiary HSBC Private Bank… – Continue reading

Luxembourg bill of law introduces EU anti-hybrid and anti-abuse rules and horizontal fiscal unity

In light of the global Base Erosion and Profit Shifting (BEPS) initiative and the European developments against tax evasion and aggressive tax planning, two European Directives were adopted in July 2014 and January 20151 by the European Council, amending the Parent-Subsidiary Directive (2011/96/EU). These two Directives, in a nutshell, aim… – Continue reading

US$7.6tn hidden in tax havens – almost half annual US GDP

Gabriel Zucman, one of 3 French economists who in recent times have published extensive research on wealth and equality, in a book, ‘The Hidden Wealth of Nations: The Scourge of Tax Havens,’ published this month, estimates that 8% of the world’s financial wealth — some US$7.6tn — is hidden in… – Continue reading

OECD says Ireland to benefit post-BEPS

The OECD has said that its base erosion and profit shifting (BEPS) project will create policy challenges for Ireland, but the nation should emerge well placed to attract foreign direct investment, reports Tax News. The report states: “Given the strong presence of intellectual property-intensive information technology and pharmaceutical companies in… – Continue reading

China Pushes Ahead with Localisation of BEPS Actions

China’s State Administration of Taxation (SAT) has been busy during recent months pushing ahead with its own plans to update/revise a series of domestic tax laws and regulations as well as Sino-foreign tax treaties. The most prominent of these changes is a proposed update of Circular Guoshuifa 2009 No.2 (Circular… – Continue reading

Big business avoids tax, yet wants to lower rate

One in five corporations with annual profits greater than $100 million paid no tax last year, the Australian Tax Office has revealed. Michael Cranston, one of the ATO’s deputy commissioners, revealed the figure to a Senate hearing into corporate tax avoidance. Corporations avoid paying tax by what is euphemistically called… – Continue reading

Crunchtime for OECD global tax-avoidance push

Efforts to amend details of new rules on corporate profits raise questions, reports the Wall Street Journal. Nearly 50 governments are set to agree this fall to a new set of rules to clamp down on tax avoidance among multinational corporations. Their chance of success, however, is unclear. If the… – Continue reading

Op-Ed: Anti-corruption march must tackle illicit financial flows

If the anti-corruption march goes ahead on Wednesday, it will be remiss if it doesn’t address one of the key issues of 2015: illicit financial flows. Institutions around the world are committing to combatting these and Unite Against Corruption needs to push the government to take action locally while lobbying… – Continue reading

SMU-TA CENTRE FOR EXCELLENCE IN TAXATION INAUGURATES ITS FIRST CONFERENCE

Since its inception in August 2014, the SMU-TA Centre for Excellence in Taxation has worked tirelessly with industry practitioners, international academics and various key stakeholders to produce its first set of research works. On September 17, the Centre successfully presented its inaugural conference titled “A New Equilibrium in Tax Competition… – Continue reading

Country-by-country reporting implementation: not so simple after all!

The Base Erosion and Profit Shifting (BEPS) Action Plan adopted by the OECD and G20 countries in 2013 recognised that enhancing transparency for tax administrations by providing them with adequate information to assess high-level transfer pricing and other BEPS-related risks is a crucial aspect for tackling the BEPS problem. Against… – Continue reading

Canada: CBSA Issues Revised Customs Guidance On Related Party Transactions And Value For Duty: New Opportunities And Obligations

On September 17, 2015, the Canadian Border Services Agency (“CBSA“) released a revised D-Memorandum D13-4-5, “Transaction Value Method for Related Persons” (the “Memorandum“), addressing the impact of income tax transfer pricing on the value for duty to be declared on goods imported into Canada. This new guidance will have a… – Continue reading

Emergence of a new order in tax policies

India must align domestic laws with international treaties A recent ruling of the Punjab & Haryana High Court (HC) in the Serco BPO case has once again underlined the need for consistency between tax policies and the jurisprudence that evolves around it, thus, leaving little to interpretational hazards. The HC,… – Continue reading

Tax treaty access, a challenge going forward? – Impact of BEPS Action 6 on collective investment vehicles

In 2013, the Organisation for Economic Cooperation and Development (OECD) released a series of proposed tax measures for eliminating corporate tax structures that shift profits to foreign jurisdictions. This corporate tax practice is commonly referred to as base erosion and profit shifting or BEPS. Towards this, the OECD and G20… – Continue reading

The Common Reporting Standard: Automatic Information Exchange Goes Global

Automatic exchange of information for tax law enforcement purposes started first in Europe with the EU Savings Tax Directive, went international with the US Foreign Accounts Tax Compliance Act, and, from 2017, will go global with the recently-agreed Common Reporting Standard, the subject of this feature. Introduction To The Common… – Continue reading