Vietnam’s Ministry of Finance released a draft circular on October 11th which, if passed, is set to become the largest change to transfer pricing (TP) regulation since the implementation of Circular 66/2010/TT-BTC in 2010 – which the draft updates. Touching on conditionality of TP exemption and thresholds for defining related… – Continue reading
The OECD is calling on all jurisdictions to conform to the latest tax transparency standards under exchange of information rules at the same time as they develop their own tax transparency initiatives The majority of OECD members have committed to implement the automatic exchange of information (AEOI) standard, with a… – Continue reading
The row between commercial banks in the Caribbean and the larger ones on the American mainland just would not go away. In the past week, finance officials from across the globe and from multilateral institutions such as the International Monetary Fund (IMF) flew to Antigua for a conference on the… – Continue reading
The leading UK accountancy and tax bodies in the UK have released updated guidance on the standards expected of tax advisers and agents. The seven organizations – the Chartered Institute of Taxation, the Association of Taxation Technicians, the Association of Accounting Technicians, the Association of Chartered Certified Accountants, the Institute… – Continue reading
Historically, the Middle East and North Africa (MENA) region has been perceived as a region where taxation and transfer pricing initiatives are not high up on government agendas. Although this has been the case for a significant period of time, recent changes in the region such as decreases in global… – Continue reading
Romania plans to join the Base erosion and profit shifting (BEPS) program as an associate member. The program equips governments with domestic and international instruments to address tax avoidance. The program’s objective is to have profits taxed where economic activities generating the profits are performed. The Finance Ministry has published… – Continue reading
Creating of a Federal Tax Authority is the logical next step in seeing it through Within the span of month the UAE took two bold steps with the aim to develop a proper legislative and legal structure for the post-oil period. The first was to launch the Bankruptcy Law and… – Continue reading
The APA scheme was initiated in 2012 in the IT Act and in 2014, rollback provisions were introduced. The Dollar Business Bureau The Central Board of Direct Taxes (CBDT) on Thursday signed five Unilateral Advance Pricing Agreements (APAs) with Indian taxpayers, making the total number of APAs to 108. “The… – Continue reading
With the Internal Revenue Service (IRS), the tax-collection arm of the United States government, stepping up its global sweep to catch American individuals and corporations hiding their overseas earnings, the American Chamber of Commerce in Cambodia yesterday held a presentation for investors and financial institutions to make sure they are… – Continue reading
With the exception of British Antarctica, the U.K.’s overseas territories and offshore dependencies are all surrounded by sun-winking ocean water. But that’s not their only common feature—they are all under increasing political pressure to become more transparent with their financial information. In a parliamentary report on tackling overseas corruption, the… – Continue reading
FATCA disclosure agreement takes effect, worrying some Israeli-Americans Dual American-Israeli citizens finally need to pay up. After years of the US Internal Revenue Service gradually baring down on American citizens living in Israel who evaded reporting income or paying taxes and numerous rounds of amnesty for those belatedly coming forward,… – Continue reading
Several Swiss banks have received a letter from the United States Ambassador to Bern, Suzan LeVine, asking them not to shun US citizens who want to open accounts in Switzerland. Many Swiss banks have frozen out US clients, and even closed down existing accounts, in the wake of a damaging… – Continue reading
In order to put an end to illicit financial flows including tax havens like offshore accounts, a United Nations human rights expert urged António Guterres, the Secretary-General-designate, as well as the UN General Assembly, to consider liquidating tax havens and summoning a world conference on the matter. Alfred de Zayas,… – Continue reading
Proposed legislation is designed to curb the profit-shifting multinationals use to reduce tax liabilities on their income in Europe The European commission will redouble its crackdown on multinational tax avoidance next week with the relaunch of proposals to create an overarching corporation tax regime across all member states. The proposed… – Continue reading
Argentina and Chile yesterday announced the implementation of a long-awaited agreement to eliminate double taxation for residents of both countries in order to encourage investment and prevent tax evasion. Chile’s Foreign Minister Heraldo Muñoz, Public Works Minister Alberto Undurraga, and Finance Minister Rodrigo Valdés met with Argentina’s Finance Minister Alfonso… – Continue reading
A chartered tax body has echoed an alert that advice on complicated and unclear areas of law, such as IR35, could be hit by proposals to penalise so-called ‘avoidance enablers.’ In fact, in line with the alert by WTT Consulting, the Chartered Institute of Taxation says “many reputable” firms may… – Continue reading
One of the most common ways multinationals take advantage of current laws to reduce their tax bill is through what’s known as transfer pricing. Former Treasurer Wayne Swan last week accused mining giant BHP of “aggressive transfer pricing,” denying the Australian government A$5.7 billion in tax revenue. For most companies,… – Continue reading
Applicable to transfer pricing for MNCs whose consolidated annual revenue is over Rs 5,000 crore The finance ministry will issue rules and guidance to address some concerns and ambiguity over mandatory reporting norms with respect to transfer pricing for multinational companies whose consolidated annual revenue is over Rs 5,000 crore…. – Continue reading
Tough rules to regulate tax advisers, banks and lawyers who help companies avoid tax are set to be advanced by European Union finance ministers. The Council of Economic and Financial Affairs Oct. 11 also will likely move toward a system of automatic exchange of beneficial ownership registers to better target… – Continue reading
In July 2016 the then Indonesian finance minister Bambang Brodjonegoro, in conjunction with the launch of the widely publicized tax amnesty program (TAP) for undeclared offshore assets, also laid out less publicized plans for a new tax haven on the islands of Bintan and Rempang (Proposed Tax Haven). A key… – Continue reading
During a recent speech, the Secretary for Financial Services and the Treasury, K C Chan, reiterated Hong Kong’s commitment to meeting the international standards on tax transparency, and to implementing the Organisation for Economic Co-operation and Development’s (OECD’s) base erosion and profits shifting (BEPS) package. In his speech on October… – Continue reading
Ethiopia recently adopted new transfer pricing rules in the form of Directive 43/2015 (“the Directive”) issued by the Ministry of Finance and Economic Development. The Directive provides detailed guidance as to the application of Article 29 of the Income Tax Proclamation (ITP) 286/2002, which requires taxpayers to ensure transactions between… – Continue reading
What will happen to clean capital, tainted trusts and enveloped assets under the new tax regime? John Goodchild reports. The UK government has at last disclosed further details of the tax changes for UK resident non-domiciled individuals first announced in July 2015. The government remains determined to implement all the… – Continue reading
The United States is recommending that Trinidad and Tobago pass the Foreign Account Tax Compliance ACT (FATCA) by February next year, providing a five-month breathing space for the country. US Ambassador John Estrada in a brief statement issued from Washington said he wanted to provide an update on FATCA after… – Continue reading
House Democrats have introduced legislation that would require multinational corporations to disclose more information about the taxes they pay in other countries. The bill, known as the Corporate Transparency and Accountability Act, aims to shine more light on corporate tax avoidance strategies, requiring the disclosure of country-by-country and pre-tax profit… – Continue reading
Nearly a year after release of the OECD Base Erosion and Profit Shifting (BEPS) anti tax avoidance action plan, which introduces changes to the treatment of interest deductibility and profit shifting, the majority of businesses have not changed their approach to tax compliance. The major economies in the G7 (83%),… – Continue reading
Seven private sector organisations Tuesday called on the Trinidad and Tobago government and opposition to put aside their differences and ensure the country meets the September 30 deadline for the Foreign Account Tax Compliance Act (FATCA). They also warned that failure to do so could result in ”serious negative consequences”… – Continue reading
A former Bahamas Financial Services Board (BFSB) chairman yesterday urged the Government to resist “disingenuous” international pressure, after this nation was accused of single-handedly undermining the global “war on tax dodgers”. Michael Paton told Tribune Business that the Bahamas needed to remain steadfast and meet the commitments it has made… – Continue reading
PORT OF SPAIN, Trinidad, Sept 10, CMC – Government and opposition legislators are to meet here on Monday as the deadline for meeting the September 30 deadline for passing the Foreign Account Tax Compliance ACT (FATCA). Caribbean financial executives have in the past bemoaned what they deem as an uneven… – Continue reading
The Common Reporting Standard (CRS) for the Automatic Exchange of Information (AEOI) is the priority initiative for The Bahamas Government in its global regulatory tax compliance regime. The Bahamas committed to the Organization for Economic Cooperation and Development (OECD) CRS for the automatic exchange of Information in 2018. The optional… – Continue reading
Under EU rules it is illegal for countries to give financial help to some companies and not others in a way that distorts fair competition, writes Liza Lovdahl Gormsen. State aid rules were originally designed to protect the internal EU market and avoid retaliation among member states. The US Treasury,… – Continue reading
The US has warned the EU that it risks damaging international agreements on tax reform if it continues to act as a “supra-national tax authority”. The US Treasury Department “shares the European Commission’s concern with tax avoidance by multinational firms. The international community, including the EU and its member states,… – Continue reading
Ireland has become a destination of choice for holding companies due to its capital gains participation exemption, generous foreign tax credit system, membership of the EU, ever expanding double tax treaty (“DTT“) network (72 signed, with 70 in effect), lack of controlled foreign companies legislation, thin capitalisation rules and the… – Continue reading
The UK’s crown dependencies and overseas territories are unlikely to suffer following the Brexit vote, and may even be a model for a post-EU UK says Richard Wilson QC Even before the UK’s decision to leave the EU, offshore jurisdictions faced a number of significant challenges: increased pressure to provide… – Continue reading
The U.K. government has been consulting on a proposed “Interest Restriction” rule which will limit the amount of interest expense U.K. companies will be allowed to offset against their income for tax purposes (to 30% of their taxable earnings before interest, tax and amortization). The second consultation phase on the… – Continue reading
An IRS official said the agency is continuing its work on a mechanism to allow voluntary filings of country-by-country reports for companies required to comply with both the U.S. rules and those in a foreign country with an earlier effective date. “Actually being able to accept CBC reports for the… – Continue reading
Commenting on today’s government consultation paper on ‘Strengthening Tax Avoidance Sanctions and Deterrents’, John Cullinane, Tax Policy Director of the Chartered Institute of Taxation, said: “This is the latest in a series of measures cracking down on those who profit from tax avoidance schemes. The Government need to be careful… – Continue reading
Companies doing business in Luxembourg will be required to file global tax information now that the nation has released draft legislation to implement new international tax reporting rules. The rules—known as country-by-country reporting—would require companies to submit a global blueprint outlining the location of their operations, taxes paid, income earned,… – Continue reading
Budget 2016 introduced a new tax called Equalisation Levy (“EL”), aimed at taxing online transactions. EL was originally mooted by the OECD in Base Erosion and Profit Shifting (BEPS) Project Final Report on Action 1 – Addressing the Tax Challenges of the Digital Economy (the “Report”). We will examine Equalisation… – Continue reading
The implementation of the goods and services tax (GST) will reduce tax evasion and improve ease of doing business by engendering a common market throughout the country, finance minister Arun Jaitley said on Monday, as he moved the modified constitution amendment bill in the Lok Sabha. “GST will ensure one… – Continue reading
The Trinidad & Tobago government says it has prepared legislation aimed at compliance with the United States Foreign Account Tax Compliance Act (FATCA). FATCA is a 2010 federal law to enforce the requirement for United States national including those living outside the US, to file yearly reports on their non-US… – Continue reading
To provide certainty to taxpayers in the domain of transfer pricing by specifying the methods of pricing The Central Board of Direct Taxes (CBDT) has entered into an advance pricing agreement (APA) with an Indian subsidiary of a Japanese trading company to foster a non-adversarial tax regime. “Signing of this… – Continue reading
The government of Panama on Tuesday announced a bill that would take a range of steps against countries that put it on their blacklists of ‘tax havens’ in the wake of the Panama Papers revelations. The legislation would impose tax, trade and migration measures on companies or individuals from those… – Continue reading
The Ghana Revenue Authority (GRA) is developing a manual on the new Income Tax (Act 896, 2015) to make it easy for taxpayers to understand the provisions of the law. The manual, known as Practice Note, which will contain examples of how to calculate taxes, is expected to give directives… – Continue reading
As worldwide pressure grows to fight offshore tax evasion, new statistics obtained by the Star show the Canadian government has convicted only 49 people and levied just $13.4 million in fines for what it calls offshore activity since 2010. These numbers are far lower than in comparable countries and show… – Continue reading
Officials from the Department of Finance and the Revenue Commissioners said they are investigating recent media reports that so-called vulture funds are using a clause in Irish law to pay small amounts of tax here. Minister for Social Protection Leo Varadkar has said that the Government is “very concerned” at… – Continue reading
During a recent speech in Pretoria to the High Level Conference on Illicit Financial Flows, South African Minister of Finance Pravin Gordhan noted that tax code improvements are required in African countries so that multinational enterprises (MNEs) “pay their fair share of taxes in the countries where they generate their… – Continue reading
Polish President Andrzej Duda has signed into law a so-called fuel legislative package, a set of measures designed to clamp down on tax evasion. Under the legislation, which includes amendments to several laws, each importer of fuel, gas or oil from another EU member state will have to pay VAT… – Continue reading
Malta has maintained its place atop the Single Market Scoreboard by virtue of having the best record of transposing European legislation among EU Member States. The scoreboard, released by the European Commission earlier today, measures the performance of the various Member States’ efforts in implementing Single Market Law, by recording… – Continue reading
The German Federal Cabinet has adopted a bill to implement key aspects of the OECD’s base erosion and profit shifting (BEPS) recommendations and the European Union’s administrative cooperation directive. The Act Concerning the Implementation of Changes to the EU Administrative Cooperation Directive and of Additional Measures against Base Erosion and… – Continue reading
