The Organization for Economic Cooperation and Development recommended Tuesday changes to international tax rules that could stop U.S. multinationals from shifting revenues and profits overseas. A total of 44 large economies, including the U.S., China and Japan, agreed with the new guidelines, but each country must change their laws and may not… – Continue reading
Remember the study last year that ranked our tax code right below Zimbabwe? Now, a new study by the Tax Foundation still ranks us near last. Zimbabwe wasn’t a part of this contest, since the new study looked only at the 34 countries making up the OECD. Still, we have… – Continue reading
The OECD will today publish its first recommendations for a co-ordinated international approach to combat tax avoidance by multinational enterprises under the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project. Meanwhile there is already evidence in Europe that the confluence of massive tax avoidance and increased concerns about privacy is… – Continue reading
A proposed clampdown on global tax avoidance took a step forward on Tuesday with a leading global think tank releasing key recommendations ahead of a G-20 meeting later this month. The practice of companies shifting their profits to other country’s jurisdictions to avoid paying tax has drawn criticism from governments… – Continue reading
Strategy to stamp out avoidance by multinational groups to be unveiled today Ireland’s business tax regime is set to come under renewed scrutiny today as the OECD sets out the first phase of a plan to stamp out aggressive avoidance by big multinational groups. Moves by the OECD to overhaul… – Continue reading
On September 16, 2014, the Organisation for Economic Co-operation and Development (OECD) released its first seven of 15 deliverables under the OECD/G20 base erosion and profit shifting (BEPS) project (the 2014 BEPS Package). The 2014 BEPS Package arises from the Action Plan on Base Erosion and Profit Shifting (the BEPS Action Plan),… – Continue reading
Over the past six years, the United States has become increasingly concerned that Americans are stashing money offshore, essentially evading U.S. tax. The IRS has increased filing requirements around foreign assets through the Foreign Account Tax Compliance Act (FATCA), which requires financial institutions around the world to report activities of… – Continue reading
With an eye to next year’s federal election, the Harper government has begun to sprinkle tax-relief treats across the country. Small businesses got theirs last week with a break on employment insurance premiums. Sometimes, however, what governments don’t do can be as telling as their actions. The Finance Department has… – Continue reading
Australians are increasingly concerned about corporate tax avoidance and support greater measures to tackle profit shifting, a survey shows. Voters are also more likely to view companies such as Apple negatively because of their use of offshore tax havens, and want companies to be required to report their profits and… – Continue reading
New Delhi: Talks between India and Cyprus on amending their bilateral tax treaty appear to be deadlocked over India’s demand to include a limitation of benefit (LOB) clause, which restricts benefits under the agreement to genuine resident investors of the Mediterranean island-nation. As a result, it may take longer than… – Continue reading
Much has been written about the poor public health and clinical capacity to respond to the Ebola outbreak in West Africa. Inadequate medical and nursing staff resources, inadequate isolation wards, inadequate intensive care resources, insufficient ambulances. An international emergency response is being mounted in an attempt to fill this huge resource gap…. – Continue reading
The past few years have seen a quantum leap in globalisation, resulting in free movement of capital and labour, shifting of manufacturing bases from high-cost to low-cost locations, gradual removal of trade barriers, technological and telecommunication developments, etc. These developments have, on one hand, led to increasing sophistication in tax… – Continue reading
Outsourcing the responsible officer (RO) function under the Foreign Account Tax Compliance Act (FATCA) offers limited value to Cayman-Islands’ domiciled fund managers.The Model one Intergovernmental Agreement (IGA) between the Cayman Islands and the US does not stipulate that a responsible officer is required. The responsible officer title is a feature… – Continue reading
The DTA between Cyprus and United Arab Emirates took effect on 1 January 2014 The double taxation agreement between Cyprus and the United Arab Emirates took effect on 1 January 2014. For a detailed analysis of the new agreement, the first between the two countries, please follow this link. The… – Continue reading
Johannesburg – More than 260 cases of tax evasion were successfully prosecuted by the National Prosecuting Authority during the last financial year. Sars spokeswoman Marika Muller said about 330 tax-related criminal cases were finalised during the 2013/14 financial year, of which 267 were successfully prosecuted. Muller said to deter non-compliance, Sars… – Continue reading
On July 21, the Organisation for Economic Co-operation and Development (OECD) published its Standard for Automatic Exchange of Financial Account Information in Tax Matters. The report contains the OECD’s model competent authority agreement (CAA), the common standard on reporting and due diligence for financial account information (CRS) and commentaries on both the CAA and CRS.The… – Continue reading
The verdict serves as reference for invoking treaty abuse provisions in the absence of General Anti-Avoidance Rules Mukesh Butani September 7, 2014 Last Updated at 22:33 IST In a ruling demonstrating wise judicial discipline, the Delhi High Court (HC) recently upheld non-taxability of sale of shares in an offshore company… – Continue reading
Antony Ting describes it as “like finding treasure”. It was 18 months ago when the powerful US congressional committee blew the lid on Apple’s aggressive corporate tax structure, which allowed it to funnel $US44 billion dollars out of the countrythrough a network of tax haven subsidiaries. Dr Ting, a senior… – Continue reading
Pascal Saint-Amans, the Director of the Organisation for Economic Co-operation and Development’s (OECD’s) Center for Tax Policy and Administration, has visited Liechtenstein to discuss tax matters with Mauro Pedrazzini, Liechtenstein’s Minister of Social Affairs. Among other things, Saint-Amans’s visit focused on the adoption of automatic information exchange in tax matters… – Continue reading
ICC’s Perspectives on the Taxation of Hybrid Entitites Upon request from the United Nations Committee of Experts on International Cooperation in Tax Matters, ICC submitted its views on the taxation on hybrid entities to feed into the UN’s work on the UN Model Convention. The letter highlights that the issues… – Continue reading
A Tax Information Exchange Agreement with Swaziland has been signed by the Manx government. The TIEA was signed in the island by Treasury Minister Eddie Teare MHK and by Senator Martin G. Dlamini, Swaziland’s Minister for Finance, in the African kingdom, and exchanged by post. Mr Teare said: ‘The signing… – Continue reading
(Seychelles News Agency) – The Seychelles has become an early adopter of an agreement launched by the G5 group of countries – the United Kingdom, France, Germany, Italy and Spain – to automatically disclose details of individuals who have taxable income kept in offshore accounts. According to a press statement by Her Majesty’s… – Continue reading
The Indian government’s bid to unearth black money stashed away in hidden offshore accounts is starting to pay off. The government believes around £350 billion is hidden in undeclared bank accounts and investments outside the country and wants to bring the tax owed on the money back to India. Nine… – Continue reading
COMPLICATED transfer pricing legislation remains a burden and has become an increased risk for multinational firms doing business in SA and the rest of the continent. Transfer pricing is the price charged for goods and services in cross-border transactions between two companies within the same multinational group. Companies can become… – Continue reading
The Seychelles is the latest country to commit to the automatic exchange of tax information as part of a scheme piloted by the Group of Five (G5) nations. The G5 pilot is aimed at deterring and cracking down on tax evasion. The five countries – the UK, France, Germany, Spain,… – Continue reading
Tax authorities throughout the world are cracking down on taxpayers – individuals and corporations – that utilize some aggressive tax planning strategies. While most of these schemes are perfectly legal and merely take advantage of loopholes in theinternational tax system, there is a growing concern that they not only threaten… – Continue reading
On August 26, Burger King announced that it entered into an agreement to acquire Tim Hortons, Inc., the Canadian coffee-and-doughnut chain, in a transaction that will be structured as an “inversion” (i.e., Burger King will become a subsidiary of a Canadian parent corporation). The deal is expected to close in 2014… – Continue reading
An ex-Attorney General believes the financial services industry will survive even if the automatic exchange of tax information becomes the global standard, warning that this nation “can’t stand apart” from the initiative. #John Delaney, now managing partner at Delaney Partners, said the Bahamas’ resilience in withstanding previous global tax/regulatory initiatives… – Continue reading
This article was first published in the 2nd quarter 2014 edition of Personal Finance magazine. Most people accept that they have to pay taxes in their country of residence. But citizens of the United States and green card holders who live outside that country – even if they have never… – Continue reading
Twitter is the latest major internet multinational to have opened up a Spanish subsidiary. But the popular micro-blogging site has followed in the footsteps of Google, Apple, Facebook and Linkedin, all of whom keep their Spanish corporate taxes down to the bare minimum by shifting their income to Ireland. Created… – Continue reading
With all the talk about inversions and America’s Burger King Going Canadian, it’s easy to ignore even more prevalent tax savings by numerous American companies. Take Microsoft, which admits in its 2014 SEC filing that it avoids $30 billion in U.S. taxes. The trick? Keep about triple that amount, $93… – Continue reading
Potential inversion deal highlights dropping corporate taxes in Canada, now the lowest among 10 countries, with the U.S. in 5th place. Fast-food giant Burger King faced anger from both Washington and average Americans Monday, a day after it announced that it was in talks to buy Tim Hortons and relocate… – Continue reading
CFOs of multinationals need to prepare by assessing how much their companies engage in profit shifting to cut their taxes. Do you have responsibility, whether direct or dotted line, for the tax function in your company? Does your company have, or plan to have, operations outside the United States? If… – Continue reading
Technology companies frequently possess an international tax footprint before expanding their domestic tax footprint. That may soon change as the Organisation for Economic Cooperation and Development (OECD) and its G20 member countries undertake an ambitious agenda to fundamentally alter the international taxation system. The OECD released its Action Plan Addressing… – Continue reading
Tax investigators pursuing instances of blackmoney stashed abroad by Indians have finally been able to circumvent the Swiss secrecy code by asking over 100 such account holders to submit on their own details of personal balances in these banks, brought under the tax net recently, for lesser penal action for… – Continue reading
THE National Tax Policy (NTP) has identified double taxation as one of the major hindrances to the growth of the Nigerian economy. Double taxation has become an issue paramount to investors and top executives of multinationals as income is generally taxable both in source and residence countries. In order to… – Continue reading
Ireland can adopt ‘wait-and-see’ approach on tax breaks, says Department of Finance Ireland supports the EU review of all patent box regimes – under which certain member states offer tax breaks for intellectual property – and has decided to take a “wait-and-see approach” on the issue until guidance is provided… – Continue reading
The Delhi High Court upholds the non-taxability of gains from sale of shares of overseas entities by the Copal Group to the Moody’s Group. Interpretation of the indirect transfer tax provisions in a restrictive manner. 50% threshold for substantiality based on guidance by OECD/ UN material and Shome Committee Report… – Continue reading
Tax reform is squarely on the agenda for the G20 Brisbane summit in November. The current international tax regime is broken and it’s going to take significant effort on a global scale to fix it. In a recently released CEDA Report on securing the G20’s future, I recommended the role… – Continue reading
The Foreign Account Tax Compliance Act (FATCA) was enacted in 2010 by the US to target non-compliance by US taxpayers using foreign accounts. FATCA essentially requires foreign financial institutions to report information about financial accounts held by US taxpayers, or by foreign entities in which such taxpayers hold a substantial… – Continue reading
On July 21, 2014 the OECD released the full version of a new global standard for the exchange of financial information in tax matters “OECD\Standard for Automatic Exchange of Financial Account Information in Tax Matters” The new standard which will be presented for formal adoption by the OECD Members in… – Continue reading
To some, US companies switching their tax residency to gain a tax advantage are economic “traitors.” To others, they are victims of a United States tax code that effectively punishes them for investing at home and encourages them to look for opportunities overseas. In this Tax-News Topical Focus, we try… – Continue reading
With new laws in place, recovery from Swiss banks can be little easier provided the government shows sincerity in taking action against tax dodgers Finance Minister Senator Ishaq Dar in recent days has expressed the government’s firm conviction to bring back untaxed money of “US$ 200 billion” stashed in… – Continue reading
Since the global financial crisis struck in 2008, offshore financial centres (OFCs) have come under sustained attack. As the world’s leading economies struggled to balance their books in the face of massive declines in tax revenue, the lowest fruit was seen to be hanging from the offshore tree. Estimates of… – Continue reading
Just as financial institutions started to come to grips with the fact that the Foreign Account Tax Compliance Act (FATCA) went into effect last month in the U.S., the Organization for Economic Cooperation and Development (OECD) unwrapped a new global version. The OECD proposal is called the Global Standard for… – Continue reading
A new global standard for governments to crack down on tax evasion has been released by the Organisation of Economic Cooperation and Development (OECD). Almost 70 countries have already signed up to the charter, which will roll out a US style Foreign Account Tax Compliance Act (FATCA) law globally. FATCA… – Continue reading
The reputation of many jurisdictions, or so called ‘tax havens’, has been attacked by other nations, most which fail to apply the same policies that they advocate for others. Over the last two decades, International Financial Centers (IFCs) have made vast changes to their laws and their enforcement, aiming to… – Continue reading
MULTINATIONAL companies shifting their profits from Africa to low-tax jurisdictions are only partly responsible for the erosion of the continent’s tax revenue bases. The African Tax Administration Forum (Ataf) believes some countries have signed away their tax revenue because of weak domestic policies, and ill-conceived tax incentives and mining contracts…. – Continue reading
A decision on Northern Ireland’s bid to have the right to set its own corporate tax rate is due after next month’s referendum on Scottish independence. Conor O’Brien reflects on the latest controversy surrounding the Republic’s corporation tax regime 5 AUGUST 2014 President Obama’s recent remarks about the practice of… – Continue reading
Hong Kong’s banks, in the midst of adapting to the new US Foreign Account Tax Compliance Act (FATCA), are now facing a tax headache on a global scale. In July, the month where FATCA became a reality for the region, the OECD published guidelines on the adoption of a much… – Continue reading
