The preliminary results of an impact assessment reveal that proposals advanced in an OECD-led effort to update the global rules for taxing digital businesses would not create large changes to countries’ existing taxing rights, Pascal Saint-Amans, OECD Director of the Centre for Tax Policy and Administration, said September 11. ... - Continue reading
The Federal Court of Australia on 3 September issued its much-anticipated judgement Glencore Investment Pty Ltd v Commissioner of Taxation of the Commonwealth of Australia [2019] FCA 1432, herein referred to as the Glencore decision. ... - Continue reading
Luxembourg and the US have amended their double taxation convention, updating the exchange of information article to harmonise it with that of the US model income tax treaty and the OECD. US ambassador to Luxembourg Randy Evans and Luxembourg finance minister Pierre Gramegna (DP) on Monday announced the ratification of… – Continue reading
In the past ten years, Switzerland has undertaken significant efforts to combat international tax fraud and tax evasion and to fight for the strict observance of foreign tax laws. In order to do so, a number of tax laws were enacted, allowing Switzerland to comply with international standards issued by the OECD (acting on behalf of the G20). In this respect, Switzerland ratified the Multilateral Convention on Administrative Assistance originally issued by the CoE and the OECD in 1988 and amended in 2011 ("OECD MC"), and it renegotiated numerous Double Taxation Conventions ("DTC"), amongst them also the DTC with Italy, in order to comply with the international standard introduced by the OECD MC in the version of July 2010. ... - Continue reading
The OECD said its initiative to have minimum standards on the collection and exchange of country-by-country (CbC) reports on large multinational businesses has reached 116 jurisdictions and has shown major progress in the delivery of international tax transparency. The OECD’s second annual peer review report on the base erosion and… – Continue reading
On June 7, 2017, Canada along with numerous other jurisdictions signed the Organisation for Economic Co-operation and Development’s (“OECD”) Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “MLI” or “multilateral instrument”). The multilateral instrument is the culmination of work undertaken as part of the OECD/G20 BEPS Project to equip governments with domestic and international instruments to address tax avoidance. ... - Continue reading
The government brought into legislation a specific element of the 2017 OECD guidelines that permits the tax authority to re-characterize an intra-group arrangement. ... - Continue reading
The OECD today released a peer review report judging whether 116 countries and their tax administrations have met standards on the collection and exchange of country-by-country (CbC) reports on large multinational businesses. ... - Continue reading
Brian Jenn, former US Treasury Deputy International Tax Counsel, has joined McDermott Will & Emery’s tax practice as a partner, the firm announced today. Jenn will be based in McDermott’s Chicago office. ... - Continue reading
Georgia, an Eastern European Country, was ranked 6th in the World Bank Group’s 2019 “Doing Business” survey. ... - Continue reading
A bill was introduced to the Mexican Congress on August 21 to tax digital platforms. ... - Continue reading
Canada and Switzerland on August 8 deposited with the OECD their instruments of ratification for the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS MLI). The BEPS MLI, negotiated by over 100 countries and jurisdictions, updates the existing network of tax treaties and… – Continue reading
The Organisation for Economic Co-operation and Development is going to propose a global minimum tax that would apply country by country before the next meeting of G‑20 finance ministers and central bankers set for 17 Oct. in Washington, DC. G7 leaders announced at their Biarritz summit meeting this week a… – Continue reading
Canada and Switzerland have deposited their instruments of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), the OECD today announced. ... - Continue reading
French President Emmanuel Macron today confirmed that the US and France have reached a compromise agreement which requires France to refund all digital services tax (DST) paid by multinationals once a new international system for taxing multinationals in the digital sector is in place. ... - Continue reading
The Directorate General of International Taxes of the Federal Board of Revenue (FBR) has started analysing a few potential multinational companies’ cases of transfer pricing where companies are directly involved in shifting their profits outside the country without payment of any taxes. In this regard, Directorate General of International Taxes… – Continue reading
ISLAMABAD: The government has kicked off a far-reaching crackdown against benami assets directing the departments concerned at the federal level and the provincial governments to track benami properties, harvesting the Benami Act, 2019 in the national and global contexts. Prime Minister Imran Khan chaired a meeting on August 20 on… – Continue reading
The Cayman Islands has published a set of frequently asked questions detailing a law requiring that companies with geographically mobile activities have economic substance for tax purposes. ... - Continue reading
On 19 July 2019, the Organisation for Economic Cooperation and Development (OECD) released its report on harmful tax practices across various jurisdictions. ... - Continue reading
On July 16, 2019, the US Senate ratified a new protocol that amends the 2013 Double Taxation Treaty signed between the US and Spain. ... - Continue reading
On 8 August, the draft law (the "draft law") implementing the EU Directive 2017/952 of 29 May 2017 ("ATAD 2") amending Directive (EU) 2016/1164 laying down rules against tax avoidance practices that directly affect the functioning of the internal market (the so-called Anti-Tax-Avoidance-Directive, "ATAD") was presented to Parliament. ... - Continue reading
19 August 2019, Since 1993, Dominica has been at the forefront of the citizenship by investment (CBI) industry, setting high standards in due diligence, processing times, and most recently, transparency. Indeed, this month the nation liaised with prominent international professional services firm PricewaterhouseCoopers (PwC) to release a report clarifying the… – Continue reading
Tax residence is one of the most important factors when ascertaining an expatriate worker's tax obligations. ... - Continue reading
"Canada has not only the largest in terms of numbers, but also the most elaborate and longest-standing skilled labour migration system in the OECD," the report says. ... - Continue reading
Today the High Court confirmed that the ATO may use information obtained from data leaks, even if leaked from a law firm. Second Commissioner Jeremy Hirschhorn said today’s decision in Glencore International v. Commissioner of Taxation means the ATO can continue to use the ‘Paradise Papers’ and other similar data… – Continue reading
In February and March of 2019, the OECD organized a public consultation process, releasing a consultation document on February 13, 2019, inviting public comments up until March 6, 2019, and holding a conference where industry experts presented key issues on March 13 and 14, 2019. ... - Continue reading
This was revealed by the Organisation for Economic Cooperation and Development (OECD) last Friday in an announcement made on its website. ... - Continue reading
Uber is moving its intellectual property arm from Bermuda to the Netherlands to save $6.1bn from its tax bid, Bloomberg reported on Friday. ... - Continue reading
CIAT’s BEPS Monitoring Database has been updated to reflect advancements made by Angola, Argentina, Bermuda, Brazil, Chile, Colombia, Costa Rica, Honduras, India, Jamaica, Mexico, Panama, Paraguay, Spain, and Uruguay. ... - Continue reading
The European Union has added further impetus to its objective of enhancing transparency against harmful tax practices with the amendment to Directive 2011/16/EU, commonly referred to as DAC6. ... - Continue reading
WELLINGTON, Aug. 8 (Xinhua) — Opportunities to dodge tax are shrinking with the completion of a new tax agreement between New Zealand and Switzerland, New Zealand’s Revenue Minister Stuart Nash said on Thursday. Nash and Swiss Ambassador to New Zealand David Vogelsanger signed documents to update the Double Tax Agreement… – Continue reading
For over 20 years the Argentine Republic has adhered to the "OECD Guidelines for Multinational Companies" ("Guidelines"), through the "Declaration on International Investments and Multinational Companies" of the Organization for Economic Cooperation and Development ("OECD"). ... - Continue reading
Statistics published earlier this week by the European Commission on member state advance pricing agreement (APA) and mutual agreement procedure (MAP) programs suggest that the OECD/G20 base erosion profit shifting (BEPS) project has increased the scope for differences of opinion between tax authorities of different countries. ... - Continue reading
The UAE Ministry of Finance on 30 April issued new tax rules setting out country-by-country reporting compliance obligations for multinational corporation groups effective for financial years beginning on or after 1 January 2019. ... - Continue reading
Proposals made by Nirmala Sitharaman at G20 Summit could alter the stasis between large corporations and tax havens. ... - Continue reading
The OECD today announced that Norway has deposited its instrument ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). ... - Continue reading
Guernsey Finance Chief Executive Dominic Wheatley reflects on the findings of the latest OECD tax report to world leaders. ... - Continue reading
The OECD has issued another update on jurisdictions' progress to amend their preferential tax regimes to remove harmful elements under the OECD base erosion and profit shifting Action Plan minimum standard on harmful tax regimes (Action 5). ... - Continue reading
An OECD-led 131-country coalition, known as the “Inclusive Framework on BEPS,” has approved an assessment which concludes that 12 low or zero-tax countries do not have “harmful” tax regimes, the OECD today announced. ... - Continue reading
Many companies looking at the Chinese market choose to establish a holding company or special purpose vehicle (SPV) to hold their Chinese investments. This typically provides flexibility and an added layer of protection to their corporate structure. Foreign investors have commonly chosen Hong Kong to set up a holding company… – Continue reading
The OECD on July 5 requested taxpayer feedback on the tax treaty dispute resolution process in Andorra, Anguilla, Bahamas, Bermuda, British Virgin Islands, Cayman Islands, Faroe Islands, Macau (China), Morocco,and Tunisia. ... - Continue reading
Hot topics for discussion at the conference included taxation of the digital economy, approaches for "hard to value intangibles", the adoption of technology within the tax department, and lessons learned from country-by-country reporting. ... - Continue reading
The Inland Revenue Board of Malaysia has released new guidance on restrictions to the deductibility of interest expenses. ... - Continue reading
The Government of Gibraltar has said it is delighted to welcome Robert Jenrick, Exchequer Secretary to Her Majesty’s Treasury, to Gibraltar to announce that HMGoG and Her Majesty’s Government have opened negotiations to enter into a Double Tax Agreement. It is anticipated that with hard work on both sides a… – Continue reading
TRANSFER pricing — the pricing of commodities traded between or within multinational enterprises — is a legal practice and a key feature of cross-border and intra-firm transactions. The United Nations prefers to use the broader phrase ‘trade pricing’ in addressing this practice and defines it as a ‘normal incident of… – Continue reading
Taiwan expected to share financial information with Japan and Australia in 2020 TAIPEI (Taiwan News) – Taiwan is expected to exchange financial information with a number of countries in September of next year as part of the Common Reporting Standard (CRS) program designed to combat tax evasion. Developed by the… – Continue reading
Taiwan expected to share financial information with Japan and Australia in 2020 TAIPEI (Taiwan News) – Taiwan is expected to exchange financial information with a number of countries in September of next year as part of the Common Reporting Standard (CRS) program designed to combat tax evasion. Developed by the… – Continue reading
"Substance" - the new rule of the tax world ... - Continue reading
6 July 2019: In the lead up to the Group of 20 (G20) Finance Ministers and Central Bank Governors’ Meeting, the Organisation for Economic Co-operation and Development (OECD) released data that show that automatic exchange of information on financial accounts is improving tax compliance and delivering concrete results for governments… – Continue reading
