Category: Regulatory

Osborne Signals Tax-Dodging Crackdown in U.K. Autumn Statement

Chancellor of the Exchequer George Osborne suggested he’ll announce measures next month to enshrine in U.K. law an international plan to crack down on tax dodging. Osborne said Friday the so-called base-erosion and profit-shifting plan will be implemented by Britain at the “next fiscal event,” indicating it will form part… – Continue reading

Swiss Government Welcomes BEPS Recommendations

The Swiss Government has tasked the Finance Ministry with responding to the OECD’s recommendations on base erosion and profit shifting. Welcoming the OECD’s proposals, the Council said: “In general, the project outcomes will allow for [the] better coordination of international tax law rules and make it possible to close the… – Continue reading

Lew: Treasury to implement international tax recommendations

Treasury Secretary Jack Lew said Friday that the Obama administration would implement new rules that would lead to sharing business’s information with foreign governments. Lew praised the final recommendations from an Organization for Economic Cooperation and Development project meant to battle offshore tax avoidance, saying there was a “critical need… – Continue reading

Australia Ahead Of The Curve In BEPS Response

The fallout for Australian firms from the BEPS project “won’t be radical in Australia, as we have already moved pre-emptively to strengthen our laws,” Assistant Treasurer Kelly O’Dwyer has said. Commenting on the release of the OECD’s final BEPS reports, O’Dwyer said: “The Coalition Government’s measures line up with the… – Continue reading

France: French Tax Update: Draft Finance Bill For 2016, New France/Germany Double Tax Treaty, And ECJ Steria Decision

This French Tax Update will focus on (i) the main provisions of the draft Finance Bill for 2016 (Projet de loi de finance pour 2016) issued by the French Government on September 30, 2015 and to be discussed before the French Parliament between October and December (“Draft Finance Bill for… – Continue reading

Conference on Base Erosion & Profit Shifting; Confederation of Indian Industry

EVENT OVERVIEW Globally, countries are campaigning for watertight tax regimes and gradually but definitely towards commercially driven business practices, and BEPS seems to be the way to it. Around 44 countries, including India, have come together to create a code to enable looking at transactions with a borderless lens for… – Continue reading

There is no evidence of Coca-Cola transfer pricing: Minister

VietNamNet Bridge – Minister of Planning and Investment Bui Quang Vinh has disagreed with the opinion that Coca-Cola has been conducting transfer pricing in Vietnam, affirming that the soft drink manufacturer is innocent until proven guilty. Vinh made the statement at the Vietnam Global Investment Forum held in Hanoi in… – Continue reading

Italy: Italian Corporate Income Tax For Foreign Investors

Corporate income tax Italian corporate income tax (imposta sul reddito delle società, or IRES) is due by resident companies on their worldwide income. A company is deemed to be resident within the Italian territory when it has any of the following elements located in Italy for the major part of… – Continue reading

United States: The Final OECD BEPS Tome Has Arrived

Remarkably on schedule, the OECD this week issued a comprehensive and integrated set of measures to attack base erosion and profit shifting (BEPS) on a global basis. Comprising 15 “Actions” on central issues such as transfer pricing, country-by-country reporting and transfer pricing documentation, treaty abuse, preferential tax regimes, permanent establishments,… – Continue reading

Threats revealed to Cayman’s AML regime

(CNS Business): Government faces some serious challenges over the next 18 months to update the regulatory regime that protects the country’s financial service sector ahead of a task force inspection in March 2017. Francis Arana, head of the Anti-Money Laundering Unit in the Attorney General’s Chambers, who is coordinating the… – Continue reading

Uganda: How MTN Uganda’s Offshore Stash Sent URA On the Hunt

MTN Uganda has been accused of failing to provide evidence to justify shifting huge amounts of cash out of Uganda to a briefcase company located in Mauritius, potentially lowering its tax bill in Uganda – the subject of which remains an ongoing dispute with Uganda Revenue Authority, it has emerged…. – Continue reading

Quarter of businesses to miss BEPS deadline

A quarter of companies say they won’t meet the first deadline proposed by the Organisation of Economic Co-operation and Development (OECD) in its base erosion and profit shifting (BEPS) action plan, reports Economia. Globally, 74 per cent said they will complete their country-by-country analysis by the first due date, December… – Continue reading

UPDATE 1-Germany wants monitoring of new regime to fight corporate tax dodging

Oct 8 (Reuters) – German Finance Minister Wolfgang Schaeuble said on Thursday he would propose a monitoring scheme to ensure the full implementation of a proposed system to overhaul the way international companies are taxed. The Organisation for Economic Cooperation and Development (OECD) published proposals on Monday to change outdated… – Continue reading

Singapore backs international plan to curb tax avoidance

Singapore has given the thumbs up to an international plan that aims to clamp down on tax avoidance by multinational firms, reports the Straits Times. The Republic says if the plan is soundly implemented, it will help foster free and fair economic competition. Singapore agrees with the main principle of… – Continue reading

OECD report not the last word on Ireland’s FDI corporation tax regime

The global war on corporate tax avoidance doesn’t look like being so gruesome after all. The OECD reckons that governments are losing out on at least €213bn per year from aggressive tax planning by multinationals, reports the Irish Independent. A new book by a Berkeley University economics professor estimates that… – Continue reading

Commission asks public for views on CCCTB proposals

The Common Consolidated Corporate Tax Base is strongly opposed by Ireland The European Commission has opened a public consultation into its proposed scheme for a Common Consolidated Corporate Tax Base (CCCTB) ahead of its planned re-launch next year. The EU’s executive arm is seeking insights from stakeholders by January 8th… – Continue reading

Tax Execs Expect Major Tax Changes from OECD BEPS Project

Senior tax executives are preparing for changes in the tax landscape as a result of the Organization for Economic Co-operation and Development’s base erosion and profit shifting project. A new survey by Ernst & Young, presented Thursday at its 34th Annual International Tax Conference, found 88 percent of tax directors… – Continue reading

AUSTRALIA: BEPS IMPLICATIONS FOR MULTINATIONAL ENTERPRISES

There are implications for multinational enterprises in Australia with this week’s release by the Organisation for Economic Cooperation and Development (OECD) of final recommendations for substantial international tax reform under the base erosion profit shifting (BEPS) project. OVERVIEW The final BEPS package follows on from, and is largely consistent with,… – Continue reading

Call for care on tax changes

New Zealand needs to be careful not to get out of step with the rest of the world in implementing tax changes on multinational companies seeking to minimise their tax obligations, Deloitte Dunedin tax partner Peter Truman says. The Government this week released a report on Base Erosion and Profit… – Continue reading

Govt amends ‘Netflix’ tax bill for GST on digital goods

Multinationals selling more than $75k into Australia asked to comply. The Australian government has released its revised exposure draft of legislation that would see GST added to all locally-bought digital products and services sold by overseas vendors by July 2017. In May this year former Treasurer Joe Hockey revealed plans… – Continue reading

Automatic exchange of information key to prevent international tax evasion: Jaitley

New Delhi, Oct 8 (KNN) Finance Minister Arun Jaitley has emphasised the need to ensure that Common Reporting Standards on Automatic Exchange of Information are implemented globally on a fully reciprocal basis as this would be a key to prevent international tax evasion and avoidance. Jaitley was speaking at 49th… – Continue reading

KPMG Tax Director: Tax betting and gaming activities

Government should look to the example set by Barbados and start charging Value Added Tax (VAT) on betting and gaming activities in Trinidad and Tobago. This was the advice coming from Tax Director of KPMG’s TT operations, Nicole Joseph, during a post-budget forum hosted by the American Chamber of Commerce… – Continue reading

Transfer pricing case: Vodafone gets relief from Bombay HC

The court overruled the order of Income Tax Appellate Tribunal issued last year suggesting that the income tax dept has jurisdiction in this dispute Mumbai: The Bombay high court on Thursday ruled in favour of the Indian arm of Vodafone Group Plc. in a Rs.8,500 crore transfer pricing tax dispute…. – Continue reading

Treasury release draft law for implementation of the Common Reporting Standard

In brief On 18 September 2015, Treasury released exposure draft legislation in relation to the implementation of the Organisation for Economic Co-operation and Development’s (OECD) Common Reporting Standard (CRS) for the automatic exchange of financial account information. The CRS is intended to reduce international tax evasion and represents the next… – Continue reading

New research from Fenergo and Aite Group claims financial institutions must achieve a global view of clients to ensure cross-border compliance

Fenergo, the leading provider of Client Lifecycle Management solutions for institutional banks, has today published key findings from new research commissioned from the Aite Group which suggests that financial institutions are struggling to manage regulatory compliance and entity data management obligations across multiple jurisdictions. (Logo: http://photos.prnewswire.com/prnh/20150114/724322) The research finds that… – Continue reading

Spain lionel messi royalties switzerland offshore companies tax evasion court case

Spanish prosecutors have dropped all tax fraud charges against FC Barcelona’s Argentinian star Lionel Messi, but will pursue the case against his father. Jorge Horacio Messi and the footballer were accused of defrauding Spain’s tax office by not paying €4m (£2.9m, $4.5m) due in taxes between 2007-09. If convicted, the… – Continue reading

Canada: International Tax Reform 2015-BEPS Final Reports

On October 5, 2015, the OECD released its final reports relating to the OECD/G20 base erosion and profit shifting (BEPS) project (the Final Reports). The BEPS project began in 2013 and has received unprecedented attention from governments and the private sector. The Final Reports outline the OECD’s recommendations and the… – Continue reading

Why India should defend this whistleblower from the Swiss justice system

Hervé Falciani, who exposed the global offshore industry with the HSBC data leak, is facing prosecution under skewed Swiss laws for data theft and espionage. This is his story. Swiss justice hounds those who breach banking secrecy even if in doing so they expose rogue banks. In the past decade,… – Continue reading

ATO widens its multinational tax avoidance net to 80 companies

The Australian Tax Office will open negotiations with 80 multinational companies to encourage them to “restructure” in order to pay more tax on profits generated in Australia. The move represents a near tripling of the ATO’s multinational watch list after it embedded staff inside 30 companies to learn more about… – Continue reading

Central Board of Direct Taxes feels black money recovery difficult

A senior officials say they have no legal jurisdiction over the accounts maintained in foreign countries and governments there can cooperate only in case of established criminal conspiracy While the government has threatened rigorous action against black money hoarders after tepid response to its one-time compliance window, it may have… – Continue reading

Foreign allies to help Modi government dig deeper into black money data

NEW DELHI: India has found global allies in its fight against black money. Germany, France, Switzerland, Singapore, Mauritius and the British Virgin Islands are among those that are providing information, or will soon start doing so, on assets held by Indians, helping the Narendra Modi government in its campaign to… – Continue reading

United States: US Congress Considers Domestic Patent Box Regime – Should You Reevaluate Your Global Structure?

Patent box regimes typically apply deeply discounted tax rates to income derived from intellectual property. Recently unveiled draft legislation may pave the way for a US patent box regime and incentivize taxpayers to reevaluate their global structures. Introduction The US imposes the highest corporate income tax rate (35%) in the… – Continue reading

Cayman Islands: New ITC-AML Headaches For Cayman Funds In 2016

In 2016, hundreds of directors, managers, principal points of contact (PPCs), compliance officers, administrators, and Money Laundering Reporting Officers (MLROs) serving Cayman Islands funds, banks, trust companies and other Reporting Financial Institutions (RFIs) will start to feel the full force of ‘a great wind’: global tax transparency. If you are… – Continue reading

Australia widens legislation to target more companies for tax avoidance

Federal government increases number of companies under tax office scrutiny from 30 to 80 under budget measures announced in May The federal government has widened the scope of legislation aimed at tackling multinational tax avoidance, increasing the number of large companies under the tax office’s microscope from 30 to 80…. – Continue reading

Global film scheme gang on trial for £100m tax fraud

A financial adviser and a group of film producers who set up an international scheme are facing a trial for fraud. It is alleged the scheme, which took advantage of the tax relief the UK Government offers the film industry, created the appearance of huge “paper losses”, The Times reported… – Continue reading

Uber and Airbnb confirm they send profit offshore

Uber and Airbnb have revealed in submissions to a federal inquiry that they route profit through companies in the Netherlands and Ireland, where taxes are lower. Uber and Airbnb have told a Senate corporate tax avoidance inquiry that while they comply with Australian tax laws, their Australian operations merely provide… – Continue reading

US companies holding $2.1 trillion offshore profits

There’s enough cash sitting in offshore bank accounts to wipe out the federal deficit — if only it was subject to U.S. taxes. That’s because U.S. companies are saving some $620 billion by parking profits outside the country, according to the latest accounting from Citizens for Tax Justice and U.S…. – Continue reading