In his seminal 1987 work Crisis and Leviathan, economic historian Robert Higgs traces the pattern of government growth as a response to catastrophic events. The federal government, in particular, grows over time through a “ratcheting up” effect, as politicians respond to disasters and catastrophes with calls to “do something,” often… – Continue reading
PwC Australia Australian Taxation Office New or updated materials on ATO website, including: Decision impact statement on McGrouther & Anor v Commissioner of Taxation case concerning whether a taxpayer can waive or withdraw a notice given to the Commissioner under s14ZYA(2) of the Taxation Administration Act 1953 (requiring the Commissioner… – Continue reading
KPMG in Kuwait discusses plans to implement a tax on business profits, changes to the Kuwait tax authority’s (KTA) approach to deemed permanent establishments, and Kuwait’s shift away from tax holidays toward tax credits to attract foreign direct investment. TAXATION OF COMMERCIAL PROFITS Based on recent local media reports1, KPMG… – Continue reading
One of the amendments proposed in the Taxation Laws Amendment Bill (TLAB), relates to the revision of the definition of “immovable property.” This definition is significant when considering the potential tax liability of non-resident persons, especially when it comes to capital gains tax (CGT). Paragraph 2 of the Eighth Schedule… – Continue reading
Under Indian foreign exchange regulations, Indian companies having foreign investment participation are generally categorised either as Indian owned and controlled company (IOCC), or foreign owned or controlled company (FOCC). An Indian company in such cases is considered as IOCC where they are owned and controlled by resident Indian citizens and/or… – Continue reading
Globally, taxpayers are becoming more interdependent, and engage in cross-border financial activities with more regularity. With this, comes the need for enhanced co-operation and understanding across countries on issues such as tax administration and transparency, to curb tax evasion and ensure a fair allocation of taxes to tax jurisdictions. “The… – Continue reading
MEPs grilled eleven multinational companies on their corporate tax practices in a five-hour debate with the Special Committee on Tax Rulings on Monday. These companies had declined the committee’s first invitation to appear before it, but later changed their minds and accepted its last chance invitation. Of the 13 original… – Continue reading
Notwithstanding the NDA’s election promise to end tax terrorism the dynamics on the ground belie easy fixes The National Democratic Alliance (NDA) government is seeking to prepare a road map to reduce existing tax litigation and look into increasing pecuniary threshold limits to discourage tax departments from launching new cases…. – Continue reading
Brussels – Google and Facebook were among US companies facing questions on Monday from European Union lawmakers about their tax-reducing techniques, a month after regional antitrust regulators raised the stakes by ordering Starbucks and a Fiat Chrysler Automobiles NV unit to repay millions of euros in back taxes. The queries… – Continue reading
Fund houses and R&T agents have already started alerting investors to furnish Fatca and KYC details Mutual fund (MF) investors have to submit declarations to their fund houses to comply with the Foreign Account Tax Compliance Act (Fatca), which was passed in the US in 2010 (read more on this… – Continue reading
BY the very criteria set in the United States (US) by the Multistate Tax Commission (MTC), several states in the US are “tax havens”. But they have not been named in the legislation passed by the legislatures of Oregon, Montana and others. Among the MTC criteria for determining a tax… – Continue reading
A Ministry of Finance decree published on 11 November 2015 provides follow-up guidance concerning advanced tax rulings issued by the Dutch tax administration. BACKGROUND Adopted in July 2014, an amendment to the EU Parent-Subsidiary Directive addresses mismatches resulting from hybrid financing, and involves the inclusion of an anti-hybrid provision. Under… – Continue reading
JAKARTA (REUTERS)- Indonesia is considering offering tax incentives for employees as part of the country’s current efforts to spur economic growth through changes to its tax regime, Coordinating Minister for Economics Darmin Nasution said on Tuesday (Nov 17). The government of South-east Asia’s largest economy has introduced several other incentives… – Continue reading
President Park Geun-hye called Monday for a careful adjustment of monetary policies of advanced countries amid lingering worries over a potential Fed rate hike. Last month, the U.S. Federal Reserve kept interest rates at near zero due to global headwinds but suggested that it could raise rates by the end… – Continue reading
HM Revenue and Customs (HMRC) has published a brief on how the UK will implement the G20’s High Level Principles on Beneficial Ownership Transparency. The brief explains that the UK will require companies to report beneficial ownership information to a central register. This register will be publicly accessible and is… – Continue reading
On November 10th 2015, the European Council announced that the EU Savings Directive 2003/48/EC (EUSD) has been repealed in order to eliminate the overlap with other legislation developed in the aspect of preventing measures of tax evasion. Brief Background The 2003 EUSD, which originally came into effect on 1 July… – Continue reading
The FINANCIAL — Employees in tax functions need to fundamentally change the way they use and gather data if they are to meet the growing demands on business of tax transparency, reform and technology enabled decision making. PwC’s latest research into the Tax function of the future – Unlocking the… – Continue reading
MELAKA, Nov 17 (Bernama) — The Inland Revenue Board (IRB) has highlighted the transfer pricing (TP) and abuse of treaties in base erosion and profit shifting (BEPS) issues at the 36th Commonwealth Association of Tax Administrators Conference (CATA) here today. IRB, in a statement today, said CATA members were serious… – Continue reading
Hong Kong (HKSAR) – The Financial Secretary, Mr John C Tsang, arrived at Bucharest, Romania today (November 17, Bucharest time), for his two-day visit to strengthen economic and trade ties between Hong Kong and Romania. Mr Tsang first held a meeting with the Representatives of the Romanian Banking Association. Mr… – Continue reading
Foreign investors are still concerned about the retrospective taxation in India, but the concerns have alleviated a little due to assurances by the government, says John Hobster, global head (transfer pricing), EY. He tells Dilasha Seth that in terms of transfer pricing, things are changing in India not only at… – Continue reading
On 30 October 2015, the Global Forum on Transparency and Exchange of Information for Tax Purposes published a supplementary peer review report for Luxembourg. Luxembourg, which was rated “Non-Compliant” in November 2013, has since implemented a number of recommendations made by the Global Forum, leading to an upgrade of its… – Continue reading
The need for robust, well-informed intangible asset valuations for the purpose of transfer pricing is becoming ever more invaluable for MNEs TRANSFER pricing has been the buzz-word of the moment with extensive media coverage in recent years of multinational enterprises (MNEs) repositioning profits to more favourable tax jurisdictions. This movement… – Continue reading
Amman, Nov. 17 (Petra)– Jordan and the United Arab Emirates held a fifth round of trade talks Tuesday here with the aim of inking an Avoidance of Double Taxation Agreement (DTAA). The agreement helps the taxpayer to get relief from double taxation on the same income. Director general of the… – Continue reading
2nd Symposium of CR for transfer pricing The 2nd Symposium Transfer Pricing organized by EY Greece, exactly one year after the successful organization of the 1st Symposium was intended as the developments in transfer pricing in Greece and international tax developments, focusing on the recently finalized OECD Actions tackling Erosion… – Continue reading
New Zealand introduced a tax bill on November 16, 2015, for a new withholding tax on sales of residential property by people who live overseas and go on to sell the property within two years of purchase. The proposed measure is the third part of the Government’s investment property tax… – Continue reading
The value of import exemptions for the first nine months of this year exceeded what the government has budgeted for the period by more than a billion Ghana cedis. The revised budget of government estimated the value of import exemptions for the first three quarters of the year at a… – Continue reading
€1 trillion a year: that’s how much tax evasion and tax avoidance is costing European tax payers every year, according to the European Commission. Parliament set up a special committee to investigate these practices in the wake of the Luxleaks scandals and came up with plans to ensure multinationals pay… – Continue reading
The Brazilian Government has submitted to Congress four tax information exchange agreements (TIEAs) concluded with Uruguay, Jersey, Guernsey, and the Cayman Islands, Brazil’s Ministry of Finance said on November 11, 2015. Congress will also consider a protocol to expand and upgrade provisions for the exchange of information with India in… – Continue reading
The Organisation for Economic Co-operation and Development (OECD) has described its newly unveiled Base Erosion and Profit Shifting (BEPS) Action Plan as a “change of paradigm.”1 A few very large global groups aside, a more apt description may be a minefield for the unwary. BEPS has received considerable air time… – Continue reading
A Protocol to Double Taxation Avoidance Agreement between India and Denmark that has entered into force on February 1, 2015, has been notified by Notification No. 45/2015/F No. 503/02/1998-FDI-I, to expand the scope of Exchange of Information (EOI) clause under Article 26 by substituting the same with a new Article… – Continue reading
When in 1915 Albert Einstein developed the general theory of relativity, providing a unified description of gravity, the impression was that said theory applies to big objects (like stars) as well as to small objects (subatomic particles). But during the following 15 years it was discovered that in the “small… – Continue reading
The UK Government launched a consultation on 22 October 2015 regarding the UK corporate tax rules for interest deductibility. The consultation seeks views on the design of a general limitation for UK corporation tax deductions for interest and similar finance costs, imposing a capcalculated by reference to a fixed percentage… – Continue reading
Eight tax treaties and protocols were passed forward for a ratification vote by the full US Senate at a business hearing of the Committee on Foreign Relations on November 10, reports Tax News. The Committee approved the new US double taxation agreements (DTAs) with Chile and Hungary, and protocols to… – Continue reading
The fundamental contradiction between IndAS and taxation is that the latter is based on real income theory while the former is based on economic substance of transactions The country is undergoing an overhaul under the present government at the Centre, and so are its corporate laws. The country’s tax regime… – Continue reading
Across the globe, base erosion and profit shifting (BEPS) is making headlines and drawing the attention of not only governments and tax authorities but also non-government organizations, activists, lobbyists and the general public. As the public debate has spread to the Gulf Cooperation Council (GCC) countries, the focus now centers… – Continue reading
The US Foreign Account Tax Compliance Act (FATCA) has helped grab £5.17 billion in lost tax held in secret offshore bank accounts. The Internal Revenue Service (IRS) has revealed the figures in a FATCA update. The IRS says the controversial law has made identifying offshore cash and investments that taxpayers… – Continue reading
The Common Reporting Standard (CRS) impacts Irish funds from 1 January 2016. The CRS framework represents a globally coordinated approach to the disclosure of income earned by individuals and organisations in order to combat tax evasion. It emerged from the Organisation for Economic Co-operation and Development (OECD) in February 2014… – Continue reading
Switzerland’s new Anti-Money Laundering Ordinance will enter into force on January 1, 2016, now that it has been signed off on by the Federal Council. The AMLO amends the Anti-Money Laundering Act (AMLA) and will introduce new due diligence obligations and reporting duties for traders. These requirements will be applicable… – Continue reading
What does Uber mean for Canberra? Journalist Henry Belot explains how Uber will work in the ACT and what it means for passengers and drivers. Uber and Airbnb will be dragged before the Senate inquiry into corporate tax avoidance this week to face questions about tax structures that allow them… – Continue reading
On October 6, 2015 Poland and Sri Lanka concluded a new Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (Hereafter: the DTA). When entering into force this new DTA will replace the existing Double Taxation Agreement (stemming from 1980)… – Continue reading
DUBLIN (Alliance News) – After the European Commission ruling that multinationals received unfair tax benefits in the Netherlands and Luxembourg, Ireland is braced for an EC ruling on whether its taxation treatment of technology company Apple constituted state aid. “I don’t know what the outcome will be, but this is… – Continue reading
Recently, the Internal Revenue Service announced the exchange of financial account information with certain foreign tax administrations as the next step in efforts to combat offshore tax evasion. This is a significant portion of the IRS’s efforts to enforce FATCA, the Foreign Account Tax Compliance Act, which was enacted in… – Continue reading
As a reminder, the international automatic exchange of financial account information is considered by most countries as particularly efficient in the fight against tax evasion and international tax fraud and is becoming the new global standard (considering the US FATCA legislation, the OECD Common Reporting Standard). The Belgian Council of… – Continue reading
The voluntary disclosure is passing under the banner of the last kilometer. By November 30, the games will be made. One can already say that the operation is a success announced. Order of Chartered Accountants of Milan has estimated that the transaction will derive from the tax authorities at least… – Continue reading
Currently 15,980 foreign companies are operating in Korea. While hiring workers and producing goods and services, foreign investors encounter numerous difficulties and experience a variety of grievances. One particular grievance brought to our attention is that they suffer from a discrepancy between the value of imported goods assessed by the… – Continue reading
Antalya, Nov. 16: The Group of 20 nations today pledged to adopt sound macroeconomic policies to achieve strong, sustainable balanced growth. The near-term objective would be to support growth, create jobs and put debt as a share of gross domestic product (GDP) on a sustainable path. Data show that several… – Continue reading
The OECD’s base erosion and profit shifting (BEPS) reforms do not go far enough in changing the international corporate tax system, G20 leaders have been told. In a letter to leaders at the G20 summit in Antayla, Turkey, Nobel Prize-winning economist Joseph Stiglitz and others from the Independent Commission for… – Continue reading
Amazon, Facebook and Google in line of fire after committee backs proposals to force multinational corporations to pay tax where they make their sales MEPs have launched a scathing attack on Facebook, Google and Amazon in the European parliament, accusing them of diverting profits worth billions of pounds to low… – Continue reading
A sharper focus on offshore banking activity and tax avoidance has seen HM Revenue & Customs grow its Affluent Unit by more than 50% in the past two years. In 2013 the unit had 213 people in its function whereas now headcount sits at 327, an increase of 54%. It… – Continue reading
A number of multinational companies have been in the news recently for alleged tax malpractices. Various countries which are facing budget deficits are convinced that additional tax revenues can be collected, especially from multinational companies. What is it all about? A business typically faces many risks. A risk is the… – Continue reading
