Category: OECD

Automatic Exchange of Information / Canada / G20 / OECD / Tax evasion investigations

Canadian Government Combats International Tax Evasion by Joining Forces With International Tax Jurisdictions

Posted On: June 2, 2015

The Honourable Kerry-Lynne D. Findlay, P.C., Q.C., M.P, Minister of National Revenue, today signed the international Multilateral Competent Authority Agreement (MCAA), an important step towards implementing the Common Reporting Standard for the automatic exchange of financial account information with other tax jurisdictions. Economic Action Plan (EAP) 2015 reiterated the Government… – Continue reading

Automatic Exchange of Information / El Salvador / G20 / OECD / Tax evasion investigations

El Salvador signs multilateral convention to fight tax evasion

Posted On: June 2, 2015

El Salvador has become the latest country joining international efforts to fight offshore tax evasion. The Central American nation yesterday signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. In doing so, El Salvador has become the 86th member worldwide, the eighth Latin American country and the third… – Continue reading

Base Erosion & Profit Shifting / G20 / OECD / Permanent establishment / Tax treaties / USA

United States: U.S. Treasury Department Releases Proposed Model Treaty Provisions

Posted On: June 2, 2015

On May 20, 2015, the U.S. Treasury Department released for public comment draft updates to the U.S. model income tax convention and its accompanying Technical Explanation (collectively, the “Model Treaty”), which was last updated in 2006. The Model Treaty is the template that Treasury uses as its starting point in… – Continue reading

Automatic Exchange of Information / Bahamas / Brazil / FATCA / FATF / IGA / OECD / Tax Information Exchange Agreements

The Bahamas Chooses the Path of Innovation, Compliance

Posted On: June 2, 2015

The past decade or more has not been an easy road to manoeuvre for IFCs. The Bahamas like other IFCs has faced the combined challenges of international initiatives, increased competition, industry consolidation, changing client demographics, emerging market requirements; legacy market stagnation and of course the financial crisis just a few… – Continue reading

Automatic Exchange of Information / Base Erosion & Profit Shifting / British Virgin Islands / Double Taxation / FATCA / G20 / Hong Kong / Legislation / OECD / Offshore Investments / Privacy

Hong Kong: Will The Very Efforts Designed To End The Offshore Industry Finally Legitimise It?

Posted On: June 2, 2015

Since the beginning of the global financial crisis, politicians, the media and people on the street have engaged in a series of “blame games” to point fingers and punish those responsible for their own economic ills. For the past few years, one “culprit” has been firmly in the spotlight –… – Continue reading

Base Erosion & Profit Shifting / EU / Ireland / OECD

What does a European common tax base mean for Ireland?

Posted On: June 2, 2015

The European Commission is to propose a mandatory common corporate tax base next month as part of a wide-ranging clampdown on corporate tax avoidance. Put simply, a common tax base seeks to harmonise the way companies calculate taxable profits across Europe. For many years in Europe there has been talk… – Continue reading

Barclays / Base Erosion & Profit Shifting / FATCA / Gaming / Isle of Man / KPMG / OECD / Tax evasion investigations / United Kingdom

Island’s links with the Northern powerhouse worth promoting

Posted On: June 2, 2015

A full and fascinating roundtable discussion based around the island’s place as an international finance centre was held at KPMG’s headquarters in Athol Street, Douglas. Around the table were David Karran, managing director, IQE, Simon Scott, managing director, Barclays Isle of Man, Andrew Thomas, chief executive, Isle of Man Enterprises… – Continue reading

Australia / G20 / OECD / Turkey

Australia signing up to global tax effort

Posted On: June 2, 2015

AUSTRALIA is onboard for the international effort to upgrade a creaking 100-year-old global tax system. AUSTRALIAN Tax Commissioner Chris Jordan told a Senate committee on Tuesday the present tax architecture was developed in the early 1920s for the now defunct League of Nations. It also depended on the physical presence… – Continue reading

Base Erosion & Profit Shifting / G20 / OECD / Offshore Companies / South Africa / Tax competition / Transfer pricing

Africa: A Journey Toward an African Taxation Renaissance

Posted On: June 2, 2015

Africa is known as the ‘paradox of plenty’. How can a continent so rich in natural resources be so poor? Economic growth is predicted to increase by 4.5% across the continent this year, despite falling oil prices and the Ebola crisis. South Africa’s economy, the second biggest in Africa is… – Continue reading

Base Erosion & Profit Shifting / New Zealand / OECD / Permanent establishment / Transfer pricing

International tax update – June 2015

Posted On: June 1, 2015

New Zealand: Budget 2015 The New Zealand Budget was handed down on 21 May 2015 and included a new tax on residential property sold within two years of purchase (with some exceptions). For further information on the New Zealand Budget see PwC New Zealand’s Budget commentary. New Zealand: Issues paper… – Continue reading

Automatic Exchange of Information / Banking Secrecy / EU / OECD / Switzerland / USA

Switzerland and EU sign historic agreement on financial information exchange

Posted On: May 31, 2015

The European Union and Switzerland signed a bilateral agreement on the automatic exchange of financial information on Wednesday morning, reports Ahram Online. According to the Neue Zürcher Zeitung (NZZ), a major Swiss newspaper, the agreement commits both parties to collect information on banking accounts starting in 2017 and exchanging this… – Continue reading

Anti money laundering / Costa Rica / OECD / Traffic Sports USA / USA

FIFA-Gate: Costa Rica football federation says US ‘mistaken’ in Eduardo Li wire fraud allegation

Posted On: May 30, 2015

The leadership of Costa Rican football has circled the wagons around their embattled president, Eduardo Li, after Li was arrested in Zurich, Switzerland, Wednesday on charges of racketeering, wire fraud and money laundering. Jorge Hidalgo, acting president of the Costa Rican Football Federation, FEDEFÚTBOL, told the website Amelia Rueda that… – Continue reading

Beneficial Ownership / FATCA / Guernsey / IGA / Legislation / Loans / OECD / Permanent establishment / United Kingdom / USA

Guernsey: Guernsey Issues Amended Legislation And Updated Draft Guidance Notes On FATCA-Based Reporting

Posted On: May 29, 2015

On 31 March 2015 amendments were made to the Income Tax (Approved International Agreements) (Implementation) (United Kingdom and United States of America) Regulations, 2014 (the “2014 Regulations”) which brought FATCA-based reporting into force under Guernsey law. FATCA-based reporting is implemented in Guernsey pursuant to the UK-Guernsey IGA, signed on 22… – Continue reading

Double Taxation / Italy / OECD / Switzerland / Tax Information Exchange Agreements

Switzerland, Italy Talk Tax Cooperation

Posted On: May 29, 2015

Swiss and Italian foreign ministers recently met to discuss taxation, finance, transport, and other cross-border issues. Didier Burkhalter, head of Switzerland’s Federal Department of Foreign Affairs, received Italian Foreign Minister Paolo Gentiloni for official talks in Bern on May 28. The ministers welcomed the bilateral agreement on finance and taxation… – Continue reading

Netherlands / OECD / Royalties / Tax treaties

Dutch letterbox companies out of favour with tax advisors: FD

Posted On: May 29, 2015

Dutch tax advisors are increasingly questioning the way some companies use shell or letterbox companies purely to move income from interest and royalties through the Netherlands to tax havens, the Financieele Dagblad says on Friday. A committee from the European parliament is in the Netherlands on Friday to look into… – Continue reading

Channel Islands / Double Tax Treaty / Gibraltar / Isle of Man / Legislation / OECD / Portugal / Residence / Tax competition / Tax Planning

Tax Planning And Portugal’s Non Habitual Residence Scheme

Posted On: May 28, 2015

Portugal can be a very attractive country to live in from a tax point of view. The inheritance tax regime is very benign here, and there is no wealth tax. Tax efficient arrangements can lower tax liabilities on your investment and pension income. And if you are a new resident,… – Continue reading

Base Erosion & Profit Shifting / Germany / Intellectual Property / OECD / Research and Development (R&D) / United Kingdom

UK: Patent Box – More Detail On The New Regime

Posted On: May 28, 2015

Following our article at the end of last year on the potential changes to the UK patent box regime further details have been released on the new regime, timings and additional work to be done. On 6 February 2015, the Organisation for Economic Co-operation and Development (OECD) published a paper… – Continue reading

Automatic Exchange of Information / Double Taxation / FATCA / G20 / India / OECD

India to ink G20 pact, will get more data on bank a/cs

Posted On: May 27, 2015

NEW DELHI: Months after it failed to sign the G20 information sharing agreement, India is set to sign the global treaty on June 3 which will enable it to access data related to bank accounts from across the world, including tax havens that were earlier refusing to cooperate. While information… – Continue reading

EU / FATCA / Investments / Legislation / OECD / Regulatory / Tax evasion investigations / USA

Raising your next fund: the rising tide of global regulatory change

Posted On: May 27, 2015

There has recently been a wave of global regulatory reforms which affect fundraising. These changes are far-reaching and can impact how fund managers structure funds, their proposed investor base, how and where funds are marketed, the remuneration that may be received, registrations that may be required and dealings with investors…. – Continue reading

Base Erosion & Profit Shifting / G20 / OECD / Oman / Permanent establishment / Saudi Arabia / Tax treaties / Transfer pricing

Oman: Taxpayers set to face more scrutiny

Posted On: May 27, 2015

Muscat: Taxpayers across the globe, including Oman, are facing increased scrutiny of their tax returns and positions taken as the pressure on governments increases to raise revenues from taxes, says an expert at KPMG. Ashok Hariharan, partner and head of tax for KPMG in the Middle East and South Asia… – Continue reading

Base Erosion & Profit Shifting / Controlled Foreign Companies / G20 / OECD / Offshore Insurance

OECD BEPS will have big impact on taxes for multinational (re)insurers

Posted On: May 27, 2015

The Organization for Economic Co-operation and Development (OECD) published its Base Erosion Profit Sharing (BEPS) action plan in July 2013 to address perceived flaws in international tax rules. The Plan was endorsed by G20 with implementation to be completed by the end of 2015. WRIN.tv spoke with John O’Leary, a… – Continue reading

Base Erosion & Profit Shifting / Dividends / Investments / Legislation / Mexico / OECD / Residence / Royalties / Tax treaties / Transfer pricing

Mexico: Risks And Opportunities From A Mexican Tax Perspective

Posted On: May 27, 2015

Investments Derived From Structural Reforms The approved structural Reforms are an unprecedented opportunity for a transformational economic growth in Mexico, being the most relevant from an investment point of view the reforms related to Energy, Telecommunications and Antitrust, which have put Mexico in the radar of Multinational companies seeking to… – Continue reading

Base Erosion & Profit Shifting / OECD

Businesses must augment tax transparency readiness to mitigate increasing reputation risk

Posted On: May 27, 2015

The FINANCIAL — Tax transparency is becoming the new norm as the OECD, European Commission and national governments demand more data from businesses. However, many companies do not have systems or resources in place to meet new requirements, according to EY’s report, A new mountain to climb: tax reputation risk,… – Continue reading

Base Erosion & Profit Shifting / EY / OECD

Businesses lack tax transparency systems, claims EY

Posted On: May 27, 2015

MANY businesses lack the systems or resources to meet new global tax disclosure and transparency requirements, according to an EY report. The report, which surveyed 962 tax and finance executives in 27 jurisdictions, found more than two thirds of respondents said they would need additional resources in order to gather… – Continue reading

Base Erosion & Profit Shifting / El Salvador / Legislation / OECD / Permanent establishment / Transfer pricing

Transfer prices: international environment and its impact on national legislation and regional operations

Posted On: May 26, 2015

The countries of the Central American region have incorporated and reformed their legislations to the international regulations of Transfer prices and practically all the applicable legal provisions to related parties have already been expanded in the region, which implies, that the companies with regional presence must visualize, review and engage… – Continue reading

Barbados / Canada / Citibank / FATCA / Hybrids / OECD / RBC / UBS / USA

Focus on the silver lining

Posted On: May 26, 2015

The news that Royal Bank of Canada plans to sell its wealth management services in Barbados no doubt caused some people to question the island’s future as a major centre for this type of business. After all, if the biggest player is leaving the field, what might this say to… – Continue reading

Anti money laundering / Automatic Exchange of Information / Beneficial Ownership / FATCA / FATF / OECD / Regulatory / Tax competition / Tax evasion investigations / Tax Information Exchange Agreements

Caribbean IFCs: Looking Beyond the International Initiatives

Posted On: May 26, 2015

Caribbean IFCs continue to face the growing challenges as global standards struggle to manage certain risks across borders. Some of these challenges (such as cross border tax information sharing) have maintained their original format but intensified and we have seen several new initiatives (for example a push for beneficial ownership… – Continue reading

Greece / OECD / Tax evasion investigations

How clamping down on tax avoidance can unlock billions for development

Posted On: May 26, 2015

There is an existing global instrument to help prevent the £2tn annually lost to governments. The UN should focus on making it work Tax evasion is a major cause of underdevelopment. Against the backdrop of Greece struggling to plug budgetary holes, aggravated by rampant tax evasion, the upcoming UN financing… – Continue reading

Amazon / Base Erosion & Profit Shifting / EU / Legislation / Luxembourg / OECD / State Aid / United Kingdom

Amazon begins to book revenues in separate countries in what expert says is response to regulatory pressure

Posted On: May 26, 2015

E-commerce giant Amazon has begun booking revenue in individual European companies, a move that tax expert Heather Self of Pinsent Masons, the law firm behind Out-Law.com, said is probably influenced by upcoming regulatory changes.26 May 2015 “As of 1 May, Amazon EU Sarl is recording retail sales made to customers… – Continue reading

Base Erosion & Profit Shifting / EU / OECD / State Aid / Switzerland

EU Tax Committee Hears From Switzerland

Posted On: May 26, 2015

A delegation from the European Parliament’s Special Tax Rulings Committee visited Switzerland on May 22. The delegation was received by Switzerland’s State Secretary for International Financial Matters, Jacques de Watteville. According to the Swiss Federal Council, talks focused on international corporate tax reform efforts and Switzerland’s work in this area…. – Continue reading

OECD / Profit Shifting / Transfer pricing

Transfer pricing presents risks and opportunities

Posted On: May 25, 2015

Businesses that operate globally continue to face complex tax issues, and transfer pricing – the practice of establishing arm’s-length prices for related-party cross-border transactions – has become more important than ever. When it comes to transfer pricing, I consider the Organization for Economic Co-operation and Development (OECD) Guidelines for Multinational… – Continue reading

OECD / Thailand / Transfer pricing

Transfer pricing law new weapon

Posted On: May 25, 2015

Thailand’s capacity for tracking how multinational companies shift income across borders within the same group to understate tax payments will increase after a transfer pricing law comes into force. The transfer pricing law, which is being deliberated by the Council of State, will authorise Revenue Department officials to ask parent… – Continue reading

Argentina / HSBC / OECD / Tax evasion investigations

To have and have not

Posted On: May 24, 2015

Argentine political analysis is increasingly introspective but sometimes it is worth looking at developments in the wider world in order to place things in perspective. The substantial rise in the tax burden over the past decade has led to plenty of local moaning and groaning at both national and provincial… – Continue reading

Belgium / Dividends / Investments / Legislation / OECD / Permanent establishment / Real Estate / Royalties / Russia / Tax Laws / Tax treaties

Belgium and Russia sign new tax treaty

Posted On: May 22, 2015

Belgium and the Russian Federation announced in March 2007 that they would negotiate a new double tax treaty (the “Treaty”). Nearly seven years after discussions began on 20 November 2008, the Treaty was finally signed on 19 May 2015 in Brussels. This newsflash is based on an unofficial version of… – Continue reading

Base Erosion & Profit Shifting / Controlled Foreign Companies / G20 / Intellectual Property / Legislation / OECD / Permanent establishment / Research and Development (R&D) / Tax treaties / Transfer pricing / United Kingdom

Diverted Profits Tax: counterbalancing the UK’s “open for business” agenda?

Posted On: May 22, 2015

The UK’s introduction of the diverted profits tax (DPT) has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) and in effect as of April 1, the DPT seemed intended to appease public anger at multinationals failing to pay their ”fair… – Continue reading

Australia / OECD / Profit Shifting / Rio Tinto / Singapore / Tax Laws

Rio Tinto adviser appointed to board advising Abbott government on how to increase tax transparency

Posted On: May 21, 2015

Rio Tinto’s head of tax – who was recently hauled before the Senate inquiry into corporate tax avoidance about the lack of tax the miner pays – will now be also advising the Abbott government on how to improve the tax system and increase transparency in relation to the tax… – Continue reading

Gibraltar / OECD

Gibraltar: Gibraltar Financial Services Commission

Posted On: May 21, 2015

FSC restructuring plans for 2015 he Gibraltar Financial Services Commission (FSC) has recently announced restructuring plans for 2015. The restructure will take effect on 1 January 2015, focussing on supporting efficient and effective delivery of the FSC’s regulatory objectives and with a particular focus on strengthening existing sector-specific expertise. This… – Continue reading

Double Taxation / Georgia / Investments / OECD / Offshore Investments / Poland / Russia / UAE

Georgia seeks broader economic ties with Poland

Posted On: May 21, 2015

Georgia and Poland held negotiations in Warsaw this week over an agreement on avoiding double taxation on income and capital. At the bilateral meeting the sides initialed the renewal agreement, which is based on the OECD Model Convention 2014 and envisages the introduction of new standards of cooperation in taxation… – Continue reading

Amoun Pharmaceutical / Canada / Concordia Healthcare / Egypt / Inversion / OECD / Offshore Companies / Research and Development (R&D) / Tax Laws / USA / Valeant Pharmaceuticals International Inc.

Valeant Pharmaceuticals, Concordia Healthcare zoom ahead of U.S. peers

Posted On: May 21, 2015

Canada’s health-care stocks are sizzling, as Concordia Healthcare Corp. and Valeant Pharmaceuticals International Inc.’s buy-and-streamline strategy has pushed the industry’s earnings and margins ahead of U.S. peers. The drugmakers are the two top-performing stocks in the Canadian equity benchmark this year, boosting total returns for the members of the Standard… – Continue reading

FATCA / IGA / Jersey / Legislation / OECD / Permanent establishment / USA

United States: Tax Policy Update – May 19 2015

Posted On: May 21, 2015

NUMBER OF THE WEEK: 40 percent. The average combined federal and state tax rate paid by most U.S.-based firms, according to a Wall Street Journal op-ed by James Freeman today, entitled “The Tax Takeover Craze.” Freeman claims this is “roughly double the average in Europe and Asia,” and is the… – Continue reading

Base Erosion & Profit Shifting / G20 / India / OECD / Offshore Companies / Permanent establishment / Tax evasion investigations

Global attempt on to ensure MNCs cough up proper taxes

Posted On: May 21, 2015

OECD, G20 team up to plug loopholes that allow companies evade taxes in jurisdictions they operate to prevent tax base erosion There is now a serious global attempt to ensure that multinationals pay taxes in the jurisdiction in which they carry out their business. The attempt is being made keeping… – Continue reading

Jersey / OECD / Tax evasion investigations / United Kingdom

Jersey: Jersey Described As ‘One Of The First And Best’ In Shaping Transparency Landscape At London Conference

Posted On: May 21, 2015

Jersey’s positive role in helping to drive forward and shape the international transparency landscape has been praised by a senior OECD tax expert at this year’s Jersey Finance Annual London Private Client Conference. Addressing an audience of more than 400 senior private client tax, trust and wealth management professionals at… – Continue reading

Jersey / OECD / Tax evasion investigations / United Kingdom

Jersey: Jersey Described As ‘One Of The First And Best’ In Shaping Transparency Landscape At London Conference

Posted On: May 21, 2015

Australia / Base Erosion & Profit Shifting / Chevron / Ecuador / Investments / Legislation / OECD / Transfer pricing

Resolving cross border tax disputes through Australia’s investment treaties

Posted On: May 21, 2015

1. Global focus on transfer pricing There has been a recent surge in regulatory attention around the world towards pricing arrangements within multinational corporate groups. Regulators are concerned that these pricing arrangements may be used as a means of profit shifting and therefore tax avoidance. The price at which an… – Continue reading

Base Erosion & Profit Shifting / G20 / Legislation / OECD / Romania / Transfer pricing

OECD strengthens recommendations on transfer pricing documentation

Posted On: May 21, 2015

In 2014, the Organization for Economic Co-operation and Development (“OECD”) began making recommendations to Member States for the implementation of certain actions aimed at limiting base erosion and profit shifting, known as “BEPS”. The project includes 15 actions, representing 15 areas of regulation that allow states to monitor data which… – Continue reading

Base Erosion & Profit Shifting / Controlled Foreign Companies / Dividends / G20 / India / OECD

New rules soon to tackle offshore tax deferral

Posted On: May 20, 2015

The finance ministry will in the near future add Controlled Foreign Corporation (CFC) rules to the Income Tax Act in order to prevent the tax deferral that many Indian multinational companies resort to by not repatriating the profits of their foreign subsidiaries for long periods. The proposed rules will come… – Continue reading

Base Erosion & Profit Shifting / Dividends / G20 / Investments / Legislation / OECD / Tax Planning / Tax treaties / Transfer pricing

Tax planning, tax avoidance and the OECD

Posted On: May 19, 2015

Introduction Tax avoidance, however legitimate its mechanism, has become the new focus for public opprobrium in parts of the world. High-profile cases and media attention examining the tax strategies of major global companies operating primarily in the digital economy have all contributed to this shift of focus. How are the… – Continue reading

Beneficial Ownership / Court cases / Dividends / OECD / Residence / Tax treaties / USA

Switzerland: Landmark Judgments Regarding The Refund Of Swiss Withholding Tax

Posted On: May 19, 2015

INTRODUCTION On May 5, 2015 the Swiss Federal Supreme Court held a public hearing about two cases relating to the reclaim of Swiss withholding tax (WHT) in connection with arbitrage cases and issued its long awaited decisions. Two Danish banks issued the question on treaty entitlement for the refund of… – Continue reading

Legislation / OECD / Tax treaties / USA

Laffer: Keep protectionist reinsurance tax out of tax reform

Posted On: May 19, 2015

A proposal to bar insurers from claiming a tax deduction for premiums ceded to offshore affiliates would cost the U.S. economy $1.35 billion in gross domestic product, with private sector losses estimated to run roughly four times as great as the tax revenues raised, according to a new report from… – Continue reading

Australia / Intellectual Property / Luxembourg / McDonalds / OECD / Oman / Royalties / Singapore / USA

How McDonald’s dodged half a billion dollars in Australian tax

Posted On: May 19, 2015

International fast-food giant McDonald’s avoided paying half a billion dollars of tax in Australia over a five-year period by shifting profits through the low-tax nation of Singapore, a new report by a global coalition of trade unions says. The report, which has been funded and commissioned by a coalition of… – Continue reading

Category: OECD

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