Category: Regulatory

Business / Finland / Legislation / Tax Authority / Transfer pricing

The Finnish Supreme Administrative Court confirms that the business model chosen by parties must be respected in transfer pricing context

Posted On: September 18, 2017

The Finnish Supreme Administrative Court published on 13 September 2017 precedent 2017:145 that further clarifies the scope of application of the Finnish transfer pricing adjustment provision (Act on Assessment Procedure (“AAP”) Section 31). In its previous landmark precedent KHO 2014:119 the Supreme Administrative Court stated that the so-called re-characterization of… – Continue reading

IRS / Tax Dispute / USA

US Hearing On Improving IRS Appeals Process

Posted On: September 18, 2017

On September 13, the US Ways and Means Oversight Subcommittee launched a hearing on improving the resolution process for taxpayer disputes and appeals with the Internal Revenue Service. The hearing is said to be the fourth in a series of attempts to reform and improve the IRS appeals process. “In… – Continue reading

Automatic Exchange of Information / Banking Secrecy / Switzerland

Swiss Bankers Urge Care In Information Exchange

Posted On: September 18, 2017

The CEO of the Swiss Bankers Association (SBA) has stressed that confidentiality, data security, and data protection requirements must be complied with when the automatic exchange of tax information gets underway. Claude-Alain Margelisch argued that there should also be a “number of security mechanisms in place that protect customers and… – Continue reading

Income Tax / Investments / Philippines / Tax Reform

Econ experts laud tax reform plan

Posted On: September 17, 2017

MANILA, Philippines — The Foundation for Economic Freedom (FEF) has expressed support for the tax reform program being pushed by the Department of Finance, saying this will lead to better lives for Filipinos. “The comprehensive tax reform program lays a solid foundation for the government’s vision of inclusive growth, improved… – Continue reading

Common Consolidated Corporate Tax Base / Corporate Tax / Cyprus / Estonia / European Commission / Ireland / Malta / Tax Equalisation

Donohoe says Ireland opposes ‘equalisation tax’ at EU meeting

Posted On: September 16, 2017

The proposals plan to tax giant digital companies on turnover rather than profits EU finance ministers have agreed to step up technical work on harmonising the taxation of the giant digital companies with a view to debating “possible solutions” at their December meeting. The ministerial consensus was a significant setback… – Continue reading

Americans / Business / Corporate Tax / G7 / Income Tax / OECD / Tax Reform

Tax Reform Advocacy Group Outlines Pro-Growth Plan

Posted On: September 15, 2017

With corporate tax reform still very much on the table, advocacy group Alliance for Competitive Taxation (ACT) has weighed in with a reform plan that it deems internationally competitive and pro-growth, and capable of driving transformational change in the U.S. economy. ACT doesn’t define its member businesses but says it… – Continue reading

Amazon / Apple / Austria / Business / Estonia / EU / Facebook / France / Google / Tax Avoidance / Tax Collection

EU Seeks a Digital Tax to Stem the ‘Bags of Money’ Lost to Loopholes

Posted On: September 15, 2017

Finance ministers discuss new tax plans in Tallinn, Estonia France’s Le Maire says EU citizens ‘outraged’ by situation European Union finance ministers are developing a new way to tax digital companies such as Amazon.com Inc. and Facebook Inc. to raise money from an industry that they say provides less than… – Continue reading

FATCA / IGA / Internal Revenue Service (IRS) / Kazakhstan / USA

Kazakhstan Signs FATCA Agreement with US

Posted On: September 15, 2017

Kazakhstan and the United States have signed a Model 1 FATCA Intergovernmental Agreement (IGA), which will enable the automatic exchange of financial information on each country’s resident taxpayers to support tax enforcement efforts. The agreement was signed in Astana on September 11, 2017. Kazakh Minister of Finance Bakhyt Sultanov emphasized… – Continue reading

Corporate Tax / Greece / Income Tax / OECD / Tax competition / Tax Reform

Greece raising taxes when other countries slashing them

Posted On: September 14, 2017

    Greece is defying the prevalent trend among the world’s industrialized nations for reducing tax rates in order to boost investment and competitiveness, a report published on Wednesday by the Organization for Economic Cooperation and Development (OECD) has shown. According to the report, in contrast to the majority of… – Continue reading

Central Board of Direct Taxes (CBDT) / Corporate Tax / Income Tax / India / Individuals / Personal Income Tax / Tax Authority / Tax Evasion / Tax Laws

Tax evaders set to face action: CBDT chairman Sushil Chandra

Posted On: September 14, 2017

CBDT chairman Sushil Chandra says income tax dept will soon conclude probe into financial dealings of about 100,000 individuals suspected of tax evasion New Delhi: The income tax department will conclude its investigations into the financial dealings of about 100,000 individuals suspected of tax evasion and persuade many other assessees… – Continue reading

HMRC / Tax Avoidance

Tax Avoidance Firm Loses ‘HMRC Approved’ Ad Challenge

Posted On: September 14, 2017

A ruling from advertising watchdogs that carrying the HM Revenue & Customs on advertising materials is misleading leaves the way open for government departments to challenge firms over misleading consumers. The Advertising Standards Authority (ASA) investigated a web site and leaflet published by tax and wealth advisors Knight Wolffe after… – Continue reading

Dividends / Double Taxation / Immovable Property / Interest / Japan / Royalties / Russia / Shares / Withholding Tax

Japan, Russia Agree New Double Tax Pact

Posted On: September 13, 2017

The governments of Japan and Russia signed a new convention on the elimination of double taxation on September 7. The convention replaces the 1986 agreement between Japan and the former Soviet Union. It lowers withholding tax rates on cross-border income from trade and investment – in most cases to zero… – Continue reading

Legislation / Offshore Trusts / Residence / Tax Avoidance / Trust / United Kingdom

UK unveils new anti-avoidance legislation targeting offshore trusts

Posted On: September 13, 2017

In its latest policy paper to target the cross-border financial services sector, the UK government today unveiled proposed legislation that seeks to prevent the use of offshore trusts to avoid tax. The measure ensures that payments from an offshore trust intended for a UK-resident individual “don’t escape tax when they… – Continue reading

Corporate Tax / Donald Trump / Multinational Corporations / Offshore / Tax Reform / USA

Multinationals would face mandatory tax on offshore profits, Steven Mnuchin says

Posted On: September 13, 2017

Multinational corporations with profits held overseas would face a mandatory one-time tax as part of the planned Republican tax legislation, Treasury Secretary Steven Mnuchin said Wednesday. “There will be a ‘deemed tax’ as a one-time charge,” Mnuchin said in an interview with Fox News at the Treasury. U.S. companies have… – Continue reading

Business / Common Reporting Standard / HMRC / Income Tax / Legislation / Offshore Partnerships / United Kingdom

Partnership tax rules overhaul by 2018

Posted On: September 13, 2017

Changes to partnership taxation are to go ahead with draft legislation now published, effectively clarifying the tax treatment for partnerships to ensure that the principle of taxing the beneficiary of partnership profit applies and to prevent a double reporting burden on investment partnership This measure makes changes to the income… – Continue reading

Brunei / G20 / Multilateral Convention on Mutual Administrative Assistance in Tax Matters / OECD

Brunei Signs OECD’s Multilateral Tax Compact

Posted On: September 13, 2017

Brunei has become the 113rd signatory to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, signing the pact at the OECD headquarters on September 12. The Convention is touted by the OECD as “the most powerful instrument for international tax cooperation.” It provides for all forms of administrative… – Continue reading

Armenia / Double Tax Treaty / Double Taxation / Legislation / USA

U.S. not going to abolish double taxation with Armenia: envoy

Posted On: September 13, 2017

PanARMENIAN.Net – The United States is not going to abolish double taxation with Armenia, U.S. ambassador to Armenia Richard M. Mills told reporters on Wednesday, September 13, Sputnik Armenia reports. According to Mills, the double taxation issue was raised by the Armenian government, and the United States has repeatedly noted… – Continue reading

Anti money laundering / China / Offshore / Tax Evasion

China issues guidelines to curb money laundering, terrorism financing and tax evasion

Posted On: September 13, 2017

BEIJING (Reuters) – China’s state council issued guidelines on Wednesday on improving supervision to curb money laundering, terrorism financing and tax evasion. China will step up monitoring of abnormal cross-border capital movements to crackdown on cross-border financial crimes, the state council said in a statement on its website, adding that… – Continue reading

Fiji / Tax Evasion / VAT

Supermarkets under spotlight for tax evasion

Posted On: September 13, 2017

Three major supermarkets are under investigation for tax evasion by the Fiji Revenue and Customs Services. In an exclusive interview with FBC News, Revenue and Customs chief executive, Visvanath Das says the non-compliance by any one of the three supermarkets could amount an average of fifty million dollars each. Hot… – Continue reading

Jurisdiction / Sri Lanka / Tax Evasion / Tax Haven / Tax Laws / Transfer pricing

New Sri Lanka tax law tightens transfer pricing loopholes

Posted On: September 13, 2017

ECONOMYNEXT – Sri Lanka’s new tax law has provisions that more effectively block companies from trying to dodge taxes by using techniques like transfer pricing, an expert said. The Commissioner-General of Inland Revenue (CGIR) has been given the power to re-examine sch transactions if they are seen to have been… – Continue reading

Canada / Canada Revenue Agency / Gaar / Tax Avoidance / Tax Evasion / Tax treaties

CRA Provides Update On Tax Avoidance Crackdown

Posted On: September 12, 2017

Canada’s Revenue Minister has provided an update on the progress made by the Government in addressing tax evasion and aggressive tax avoidance. The update concerns the recommendations on tackling tax avoidance and evasion made by the House of Commons Standing Committee on Finance (FINA) in October 2016, and the actions… – Continue reading

Anguilla / Boris Johnson / British Virgin Islands / Caribbean / Offshore / Tax Arrangement / Tax Avoidance / Tax Haven / Trustee / United Kingdom

Slow UK aid for hurricane-hit islands linked to tax haven ties

Posted On: September 12, 2017

Anguilla’s ex-attorney general says UK government may fear exposing its role in Caribbean territories’ tax arrangements Aid offered by the British government to its hurricane-battered territories in the Caribbean has been dismissed as “derisory” by a former attorney general of one of the worst-hit islands. Rupert Jones, who completed a… – Continue reading

Base Erosion & Profit Shifting / Canada / Country-by-Country (CbyC) Reporting / Income Tax / Income Tax Act / OECD / Tax treaties

OECD releases guidance to ensure BEPS country-by-country reports are used appropriately.

Posted On: September 11, 2017

Canada has implemented the country-by-country reporting requirement for large multinational enterprises (MNEs) contained in the 2015 Final Report on Action 13 of the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan.  Canada’s legislation is found in s. 233.8 of the Income Tax Act (Canada), and is supported by the… – Continue reading

Corporate Tax / France / Germany / Incorporation / Italy / OECD / Spain / Tax Avoidance / Tax competition

Eurozone’s big four demand measures against tax avoidance

Posted On: September 11, 2017

The four biggest economies in the Eurozone – Germany, France, Italy, and Spain — demand an end to the erosion of their tax base by means of incorporation in states that facilitate tax avoidance. According to the Financial Times, Bruno Le Maire, Wolfgang Schaeuble, Pier-Carlo Padoan, and Luis de Guindos,… – Continue reading

Business / Corporate Tax / EU / Europe / Facebook / Google / Permanent establishment

Google, Facebook, And Others May Have To Pay More For EU Operations

Posted On: September 10, 2017

Operations in the European Union haven’t been easy going for tech companies for quite a long time. While many European countries earlier called for strict privacy regulations and large fines on tech companies for violating them, they have now called for increased taxation for these companies for their operations in… – Continue reading

British Virgin Islands / India / Offshore / Panama / Singapore / Tax Authority / Tax Evasion

I-T steps up drive against cash abroad; charges fixed against 5 businessmen

Posted On: September 9, 2017

Dept starts prosecution against 5 people with Rs 5k cr of unaccounted wealth in British Virgin Islands. The income-tax (I-T) department has established charges against five persons with unaccounted foreign assets of Rs 5,000 crore in the British Virgin Islands (BVI), a Caribbean tax haven. Investigations are on in more… – Continue reading

British Virgin Islands / Cyprus / Income Tax / Income Tax Act / India / Jurisdiction / Offshore / Panama / Prosecutions / Seychelles / Tax Evasion / Trust

Panama probe: First prosecutions are taken to court for off-shore tax evasion

Posted On: September 9, 2017

While at the beginning of the year (The Indian Express, March 16, 2017) the number of requests sent by India stood at 283 cases, it has now crossed 300. And while the number of replies received from among these 13 jurisdictions stood at 165, that figure has now crossed 240…. – Continue reading

Corporate Tax / Estonia / EU / Multinationals / Tax Avoidance

Estonian Presidency to present the boldest plan to date against tax avoidance

Posted On: September 7, 2017

The EU 28 financial ministers are set to discuss taxation of multinational digital platforms in Tallin on September 15-16, Reuters reports. Companies such as Amazon and Google have designed tax plans that reduce their tax liability in countries they operate. The proposal put forward by the Estonian Presidency proposes to… – Continue reading

Belgium / Double Taxation / Double Taxation Agreement / Mexico / Withholding Tax

Protocol Amending the Mexico-Belgium Tax Treaty Published

Posted On: September 6, 2017

On August 17, 2017, the Protocol amending the Convention for the Avoidance of Double Taxation and the Prevention of Fraud and Fiscal Evasion (“Tax Treaty”) between Belgium and Mexico was published in Mexico’s Official Journal of the Federation (Belgium publication pending). The Tax Treaty became effective in Belgium on August… – Continue reading

Double Taxation Agreement / Interest / Panama / Tax Authority / Tax treaties / Withholding Tax / Withholding tax rules

Panama: Panama Tax Treaties

Posted On: September 5, 2017

The Panamanian Government with the aim of improving the competitiveness of the international services industry in Panama and, at the same time, comply with international standards for the effective exchange of information, initiated in 2009 a decisive agenda for the selection of countries with whom tax agreements were going to… – Continue reading

Base Erosion & Profit Shifting / EU / Jurisdiction / Legislation / Multinationals / Romania / Tax Avoidance

Analysis: Romania seeks tighter control of multinationals’ financial data

Posted On: September 5, 2017

The government is looking to implement EU Directives on tax avoidance, and is set to receive more financial information from multinational groups active in Romania. Tax experts suggest that large corporations might reassess their business models in order to meet the demands of the fiscal authorities in Romania and across… – Continue reading

Double Tax Treaty / Estonia / Japan

Japan, Estonia Sign Double Tax Treaty

Posted On: September 4, 2017

Japan and Estonia signed a convention to eliminate double taxation on cross-border trade and investment on August 30. The treaty sets out the taxing rights of both countries on cross-border income deriving from investment or trade between the two. It also provides for assistance in the collection of tax and… – Continue reading

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