NEW DELHI, MAY 19: In its ongoing quest to draw information on illegal incomes stashed abroad, the Indian revenue authorities are in negotiations with as many as 28 different countries/jurisdictions for tax information exchange agreement (TIEA). This agreement will enable Indian tax authorities to receive banking related information even from… – Continue reading
Authorities worldwide have increased scrutiny of tax-avoidance strategies in the past year, CFOs and finance directors of multinational clients told global tax consulting firm network Taxand. Sixty per cent of multinationals reported an increase in audits by tax authorities in the past year, and 70% said authorities had increased their… – Continue reading
In 1934, a distinguished American jurist, Judge Learned Hand, famously opined that “one may so arrange his affairs so that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to… – Continue reading
Marcelo Vicentini of Standard Chartered in Brazil discusses the differences between OECD member countries and non-members when it comes to asset management transfer pricing. Brazil’s diversion from the OECD is well-documented and can make life difficult for transfer pricing managers when they are trying to apply a consistent policy across… – Continue reading
THE BJP-led National Democratic Alliance government, which had made a lot of noise about black money and the illegal stashing of funds abroad in the run-up to general elections last year, finally got down to some serious work to tax ill-gotten wealth and curb its growth. Last week, the government… – Continue reading
Short cuts, loopholes and other forms of skulduggery will not be tolerated when the automatic exchange of tax information comes into force, a top official from the Organisation for Economic Co-operation and Development (OECD) has promised Swiss bankers, reports FinFacts. Grace Perez-Navarro, second in command at the OECD’s tax policy… – Continue reading
Governments and tax partners need to work to ensure confidentiality is protected when new international tax transparency rules come into force in 2017, according to OECD director, Pascal Saint-Amans. “There is a fundamental difference between the automatic exchange of information and the existing system of exchange upon request, particularly because… – Continue reading
Following on from a press release issued by the Treasurer on May 11th, the government has released a draft bill containing a new limb to the general anti-avoidance provision, which is directed at foreign multinational groups who have global revenue exceeding $1 billion. The law will apply where: • the… – Continue reading
The Organisation for Economic Co-operation and Development (OECD) has published stakeholders’ comments on its discussion draft on base erosion and profit shifting (BEPS) Action 11, on improving analysis of BEPS. Through Action 11, the OECD hopes to develop recommendations to better chart the scale and economic impact of BEPS issues,… – Continue reading
Last night, the Federal Treasurer, Joe Hockey MP, released the 2015-16 Federal Budget. After public self-evaluation of its last budget as over-reaching, the Government has gone back to basics whilst still focussing on repairing the budget deficit in the medium to long term. The budget deficit is projected to be… – Continue reading
The International Monetary Fund has urged authorities in Luxembourg to consider diversifying the nation’s revenue sources in light of international tax changes that could negatively impact the country’s economy, reports Tax News. The Fund said in a statement that it welcomed Luxembourg’s continued participation in EU and OECD/G20 tax transparency… – Continue reading
The latest changes to VAT and profit tax legislation, implications of recent measures taken to fight fiscal evasion, changes to international tax reporting rules and the need to improve holding legislation were some of the topics discussed by participants in BR’s 14th Tax & Law conference which took place in… – Continue reading
Treasurer Joe Hockey is facing criticism for both acting too quickly and not doing enough on tax avoidance by multinational ¬companies after tabling legislation on Tuesday night to stop companies shifting taxable profits out of Australia. An unnamed 30 multinational companies with more than $1 billion in revenue from Australia… – Continue reading
The OECD plans to have international agreement on new tax rules developed as part of its project to tackle aggressive tax avoidance by multinationals through the Base Erosion and Profiting Shifting (BEPS) project by the next G20 summit in November, with implementation completed before 2020 ‘at the latest’ Pascal Saint-Amans,… – Continue reading
Even as the action plan to address Base Erosion and Profit Sharing (BEPS) is being worked out, multinationals are bracing for some turbulent times in India. For some time now, transfer pricing – the price of goods and services determined by a company when two of its subsidiaries transact –… – Continue reading
Technology companies need to stop “extremely aggressive” tax planning, the man charged with reforming global tax rules has told the BBC. He says these “push the boundaries of what is legal”. Pascal Saint-Amans, who runs the OECD’s Centre for Tax Policy, said that new standards would require companies to pay… – Continue reading
The worldwide transfer pricing landscape is in a state of flux and the need for sound and reliable dispute resolution mechanisms has never been more important for multinational enterprises. In particular, where aggressive tax administrations such as India are concerned, double taxation is a key concern for businesses. Mutual agreement… – Continue reading
India is well on its way towards achieving meaningful financial sector reform and development, and time is of essence. Last month, the International Monetary Fund (IMF) stated that India will overtake China as the world’s fastest growing economy in 2015, buoyed by a rising middle-class, a young population, and competitive… – Continue reading
A Protocol amending the Agreement for the Avoidance of Double Taxation and Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital between South Africa and Cyprus was signed on the 1st of April 2015. According to the Protocol, Article 10 (“Dividends”) of the Double Tax Treaty… – Continue reading
Head of forum’s tax policy will push for reform to cut down on avoidance. The OECD has attacked the “extremely aggressive” tax planning of companies such as Google, Amazon and Apple as it pushes for reform of global tax rules to cut down on avoidance. Pascal Saint-Amans, who heads up… – Continue reading
The Swiss cabinet plans on addressing the issue of stolen data with regard to banking information requests from other countries. This comes as Switzerland is under close scrutiny for compliance with international standards. In its meeting on Wednesday, the cabinet discussed the thorny issue of stolen data. Switzerland currently does… – Continue reading
Short cuts, loopholes and other forms of skulduggery will not be tolerated when the automatic exchange of tax information comes into force, a top official from the Organisation for Economic Co-operation and Development (OECD) has promised Swiss bankers, reports Swiss Info. Grace Perez-Navarro, second in command at the OECD’s tax… – Continue reading
“Uruguay has now definitely earned its long-time nickname — the Switzerland of Latin America.” That’s what I wrote several months ago during my first visit to this small, south Atlantic costal country wedged between Brazil and Argentina. For the last week, I have been enjoying my second visit to Uruguay,… – Continue reading
HSBC Holdings’s Geneva private bank is no longer a place where wealthy people go to hide untaxed assets, according to Franco Morra, chief executive officer for HSBC in Switzerland. “Today, a new client in the first meeting will tell you he is tax compliant and even bring the files with… – Continue reading
Current international tax rules are based on principles that have not kept up with globalisation and the rise of the digital economy. Over the years the rules have been patched up but, almost two years ago, the Organisation for Economic Co-operation and Development (OECD), acknowledging that a substantial overhaul was… – Continue reading
The corporate community is increasingly sounding the warning to Congress: Europe is coming after us on taxes. With tax reform talks stumbling in Washington, the fear for corporate titans is that other countries are already implementing a global set of recommendations meant to crack down on offshore tax avoidance. Lobbyists… – Continue reading
Switzerland’s banks will benefit from the global crackdown on tax avoidance, the president of the country’s association of foreign banks and head of HSBC’s (HSBA.L) Swiss private banking arm said on Tuesday, reports Reuters. The Alpine nation famed for its banking secrecy is bowing to international pressure by committing to… – Continue reading
If you are moving or trading goods across borders, this topic should be of primary importance from both a Transfer Pricing and Customs perspective. There is potential for you to have Transfer Pricing and Customs exposures in your supply and value chains as a result of the OECD/G20 initiative on… – Continue reading
New rules applicable to payments made by Chinese companies to ‘related’ companies offshore will prevent them from artificially shifting profits to lower tax jurisdictions through “unreasonable” service and royalty payments, the State Administration of Taxation (SAT) has said. Circular 16, which came into force on 18 March, and its accompanying… – Continue reading
Grant Wardell-Johnson, KPMG Tax Partner, has said that while it would have been better for Australia to await the outcome of the OECD’s base erosion and profit shifting Action Plan, the international tax measures proposed recently by Treasurer Joe Hockey “have the benefit of being highly targeted.” On May 11,… – Continue reading
South African companies are unable to compete with multinationals selling goods and services online in the country, partly as a result of tax laws. This is according to financial services group PwC, which argues that the country has not kept pace with the changing global economy. “Currently, multinationals in the… – Continue reading
Introduction The Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) decided in mid-March 2015 that Switzerland should enter Phase 2 of the Peer Review. This decision represents a clear statement by the OECD that Switzerland’s legal and regulatory framework for information exchange complies with internationally… – Continue reading
There are two pressing concerns facing us in 2015. First, the increased crackdown on multinational corporations reportedly using offshore tax hubs to avoid taxes will make summer 2015 the make or break season for the global economy. On the one hand, the argument is made that firms such as Apple,… – Continue reading
Australia to fine tech tax-dodgers 100% of their avoided tax, plus profits Australia’s treasurer* Joe Hockey has revealed that he and other money ministers from the Organisation for Economic Co-operation and Development (OECD) have shared plans to have online retailers charging the appropriate consumption tax on intangibles and goods bought… – Continue reading
Deloitte managing tax partner Thomas Pippos says the IRD are using electronic payments and websites to pursue tax cheats Budget-conscious tax collectors are increasingly turning to popular websites and other e-channels to chase undeclared taxable income, a top accountant says. Inland Revenue Department no longer had capacity or interest in… – Continue reading
You’re just over a month to prepare for the provision of the first Russian banks reporting FATCA. In the future, Russia will reach the full exchange of information with the United States, who also contribute to the development of the domestic economy. By June 29, the Russian banks will be… – Continue reading
It may be time for another letter from Tom Cotton. Cotton, the Republican senator from Arkansas, had been in office only a few weeks back in March when he got 46 senators to sign on to an open letter to the leadership of Iran. The letter pointed out that agreements… – Continue reading
Recently the Polish Ministry of Finance has presented a new bill introducing amendments to the Tax Ordinance and proposed amendments to the income tax regulations. Deferral of the effective date of the general anti-abuse clause On May 4, 2015 the Polish Ministry of Finance published a draft amendment to the… – Continue reading
Bold step on non-resident levy likely to be first of many. A tax policy paper released yesterday proposes changes on the taxation of non-residents in respect of New Zealand-sourced interest income. These changes, if implemented, will affect large multinationals, banks and even individual New Zealand borrowers. As the first significant… – Continue reading
CFOs of multinational corporations have mixed reactions to the Organization of Economic Cooperation and Development’s crackdown on base erosion and profit shifting by global companies, according to a new survey. The survey, by the tax advisory business Taxand, found that multinational CFOs are split 52 percent (agree) versus 48 percent… – Continue reading
Major G20 tax event in Istanbul hears claims that fighting tax scams is ‘vital issue’ for developing nations ISTANBUL Fighting tax evasion is like fighting international terror, Turkey’s finance minister has claimed. Mehmet Simsek was speaking at an international G20 tax event in Istanbul on Thursday where he said that… – Continue reading
The Government and the IRD are moving to crack-down on the big banks, overseas customers, and other offshore-owned entities that are not believed to be paying their fair whack of New Zealand tax. The IRD’s produced a 46 page issues paper making suggestions for new rules that would tighten up… – Continue reading
Minister of Revenue, Todd McClay today welcomed the release of an officials’ issues paper that seeks feedback on suggestions for helping to ensure that non-resident investors pay an appropriate amount of tax. The focus of the issues paper is the current non-resident withholding tax rules on interest earned in New… – Continue reading
The government has approved the report and application to the Diet a Tax Information Exchange Agreement (TIEA) and an additional protocol, as it was from the government building on Thursday. The agreement was signed in Rome on 26 February 2015. VADUZ. The TIEA is based on the applicable international standards… – Continue reading
Exchange Traded Funds (ETFs) have gained huge popularity in recent times with Irish investors; however, there has been much complexity and uncertainty in relation to their tax treatment. The concept of an ETF is not specifically provided for in Irish tax legislation. It depends on the legal form and characteristics… – Continue reading
Shayne Nelson, Chief Executive Officer of Emirates NBD, muses how corporate governance, risk and compliance have changed beyond recognition since he first came to the region. Shayne Nelson has seen a lot of change in his extensive banking career, which has spanned several continents. With roles including Chairman of Standard… – Continue reading
As part of its 2015 Federal Budget announcements, Canada committed to implementing the “Common Reporting Standard” (CRS) promulgated by the Organization for Economic Co-operation and Development (OECD). While the OECD’s efforts to facilitate information reporting via the CRS and Canada’s corresponding implementation of such a regime will certainly have lasting… – Continue reading
Officials from Mexico’s Tax Administration Service (SAT) met with Costa Rican tax administration officials from April 20 to 22, 2015, to share their experiences in the area of tax information exchange. The Costa Rican authorities learned from Mexico’s experience in implementing the US Foreign Account Tax Compliance Act (FATCA) and… – Continue reading
Now that Costa Rica has been formally invited to go through the process of becoming a candidate nation worthy of joining the Organization for Economic Cooperation and Development (OECD), financial advisors and legal professionals are starting to ponder how their clients will be impacted by this new chapter in our… – Continue reading
The deductibility of interest has for years been a contentious issue and this has been reaffirmed with the introduction of section 23M into the Income Tax Act No 58 of 1962 (the “Act”) with effect from 1 January 2015. A further addition to the interest sphere of income tax is… – Continue reading
