On December 28, 2014 Ukrainian Parliament has adopted the Draft law No. 1264-1 “On amending the Tax Code of Ukraine regarding improvement of tax control over transfer pricing” as of 22.12.2014 (the Draft Law). In order to become effective, the Draft law has to be signed by the President of… – Continue reading
The 4,029-page tax code is so complex both parties want to revise it. On business tax reform, they share surprising common ground, raising the potential for partial tax reform to be enacted this year. As the 114th Congress convenes this week, it has a golden opportunity to rid itself of… – Continue reading
The Inland Revenue Authority of Singapore (IRAS) has published an updated consolidated e-Tax Guide on the country’s transfer pricing regime. The e-Tax Guide, which was released on January 6, 2015, is divided into three main parts. Part I of the Guide provides background on the treatment of related-party transactions and… – Continue reading
THE South African Revenue Service (SARS) has already begun to tackle the erosion of the tax base through profit shifting, which was addressed in an interim report of the Davis tax committee that was released last month for public comment. SA loses billions of rand in revenue annually through the… – Continue reading
New research shows that 2014 saw many fundamental changes across the global tax system as governments look to reform their regimes for the long term, complying with new OECD guidelines, whilst significantly clamping down on multinationals in light of increasing public media scrutiny. The research was undertaken by Taxand, a… – Continue reading
SINGAPORE – On December 9, 2014, Singapore became the first country in Southeast Asia to sign an Intergovernmental Agreement (IGA) on tax information sharing with the United States. The signing follows an in substance agreement reached between Singapore and the US in May 2014. Most countries around the world have… – Continue reading
The Federal Board of Revenue (FBR) is planning to introduce amendments to the income tax law in next federal budget (2015-16) to effectively deal with the transfer pricing issues of non-resident companies. Sources told Business Recorder on Monday that the first meeting of the FBR’s transfer pricing unit would be… – Continue reading
The Federal Board of Revenue (FBR) is planning to introduce amendments to the income tax law in next federal budget (2015-16) to effectively deal with the transfer pricing issues of non-resident companies. Sources told Business Recorder on Monday that the first meeting of the FBR’s transfer pricing unit would be… – Continue reading
Controversial proposals for a law to make failing to declare offshore income a criminal offence seem to have been put on the backburner by The Treasury. Chancellor George Osborne announced the measure as part of a campaign to stamp out tax evasion as part of his Budget 2014. However, no… – Continue reading
TWO noteworthy taxation amendments came into effect on the 1st of January 2015. The first tax amendment relates to the deductibility of interest paid to a person who is not liable to tax in South Africa, for example non-residents. The section in question, section 23M of the Income Tax Act,… – Continue reading
As a means of encouraging the development of intellectual property (IP) in Italy, rather than elsewhere, a “patent box” preferential tax regime has been introduced with effect from January 1, 2015, at the same time as a restructuring of the country’s research and development (R&D) tax credit system. Following the… – Continue reading
Easy access drawdown rules for Qualifying Recognised Overseas Pension Scheme (QROPS) come with a twist in the tail. The Treasury and HM Revenue & Customs (HMRC) have confirmed QROPS are included in pension reforms that start from April 6, 2015 – which means retirement savers can access their QROPS fund… – Continue reading
Holley Nethercote commercial & financial services lawyers David Court, a partner at Holley Nethercote Commercial and Financial Services Lawyers was recently interviewed by an international publication regarding the implementation of FATCA in Australia. Below are some of David’s thoughts – How have you approached FATCA? What’s your biggest challenge? What… – Continue reading
The future for offshore tax planning, also known as “aggressive tax planning” is likely to be limited to if not curtailed by the global exchange of information agreement signed in October, 2014 by 51 countries and growing. The link below is to a video summary of the predicted consequences of… – Continue reading
Trusts established by Portuguese resident individuals are now to be taxed for the first time after new rules were introduced on 1 January. On 17 December last year, the Government of Portugal introduced a change to its tax law meaning distributions from trusts to Portuguese residents would be taxed at… – Continue reading
Chief Palestinian negotiator Saeb Erekat on Saturday described as “piracy” an Israeli decision to stop the transfer of Palestinian tax revenues collected on behalf of the Palestinian Authority. “We were unofficially told a few hours ago that the Israeli government had decided to hold back tax revenues it collects on… – Continue reading
IN A PREVIOUS column (http://www.bworldonline.com/content.php?section=Economy&title=the-oecd-action-plan-on-base-erosion-and-profit-shifting&id=99561), we wrote about the general framework of the Base Erosion and Profit Shifting (BEPS) initiative, why addressing BEPS is a key priority for many governments across the globe, and the 15-point BEPS Action Plan drafted by the Organization for Economic Co-operation and Development (OECD). The… – Continue reading
COUNCILLORS will consider a call to join a national campaign against tax dodging at the next meeting of West Dorset District Council. Beaminster councillor Caroline Payne has submitted a notice of motion, which will be considered by members at the meeting on Thursday, January 8. The motion reads: “Please could… – Continue reading
Europe’s tax showdown could be headed straight to people’s wallets. With the new year, a change in fiscal rules in the European Union is increasing the tax on many purchases of digital content like e-books and smartphone applications. Under the new rules, first approved in 2008, the tax rate on… – Continue reading
NEW DELHI, JANUARY 2: The dispute resolution mechanism for matters relating to international tax and transfer pricing has been streamlined. The Finance Ministry has put in place a new framework that seeks to bring much-needed rigour and neutrality to dispute resolution on international tax issues. The move should encourage multinationals… – Continue reading
The new deoffshorisation legislation that passed with lightning speed through Russia’s Parliament and then hastingly signed by President Putin in the time span of a week and a half, comes into force on January 1, 2015. The new deoffshorisation legislation that passed with lightning speed through Russia’s Parliament and then… – Continue reading
The new year could bring important changes to the tax landscape. Here are several issues that will affect how much taxpayers owe for 2015 and beyond: Federal tax policy There is serious talk of overhauling the federal tax code. “There appears to be a consensus” on making changes, says Stephen… – Continue reading
BRUSSELS – As political honeymoons go, it was short and ended abruptly. Just one week into his job as European Commission president, Jean-Claude Juncker was broadsided by a series of newspaper articles outlining the depth and breadth of corporate tax avoidance schemes in Luxembourg. Schemes thought up and enacted while… – Continue reading
Businesses in the island’s vital financial services are gearing up for ‘substantial changes’ dealing with tax. That was one of the important messages to come out of a seminar organised by KPMG in the island. More than 200 experts attended the event which covered a series of changes in property… – Continue reading
New Zealand’s tax authorities have been given more power to pursue tax evaders who go offshore under changes which come into effect this year. Inland Revenue will have more power to go after tax evaders who leave New Zealand under changes that come into effect this year. The Convention on… – Continue reading
The Cayman Islands Government today issued a report stating that it will continue its current method of providing beneficial ownership information to law enforcement, tax and regulatory authorities, as the method adheres to global standards. As explained in its Consultation Report on Maintenance of Legal and Beneficial Ownership Information, Government’s… – Continue reading
CMS Bureau Francis Lefebvre, a leading French law firm, has noted that the 2015 Finance Act and the Rectificative Finance Act for 2014 were adopted by the French Parliament on December 18. Certain provisions have been reviewed by the Constitutional Court, which issued its ruling on December 29. Both laws… – Continue reading
Once a niche proposal, the recent public focus on corporate tax avoidance has sparked real interest in the idea of eliminating corporation tax altogether. Surprisingly, the statistics suggest that employees and other stakeholders may also benefit from this In winter 2012, hundreds of activists packed inside their local Starbucks after… – Continue reading
The Indian Constitution has empowered only the Central Government to levy and collect taxes. Every person whose total income exceeds the maximum exemption limit shall be chargeable to the income tax at the rate or rates prescribed in Income Tax Act. Such income tax shall be paid on the total… – Continue reading
TOKYO (Kyodo) — Japan’s ruling parties on Tuesday adopted fiscal 2015 tax reform policies entailing corporate tax cuts and an expansion of tax breaks for the wealthy, with an eye on propping up sluggish household spending and boosting business investment to aid the economic recovery. By bolstering the… – Continue reading
CAPE TOWN — South Africa needs to finalise the renegotiation of its tax treaty with Mauritius as soon as possible to prevent the loss of large sums of money through “treaty shopping” the Davis tax committee has urged. The committee released its interim report on ways to prevent base erosion… – Continue reading
Currently, there is a tendency among those who take an interest in international tax developments to look to the future and try to guess how the international tax landscape will look in, say, three of four years, once countries begin to implement the OECD’s base erosion and profit shifting (BEPS)… – Continue reading
Indonesia has only met its tax revenue collection target two times in the past 10 years, but President Joko “Jokowi” Widodo has vowed to transfer his past success in boosting tax revenue at the regional level in Jakarta and Surakarta to the nationwide level. Jokowi has laid out his plan… – Continue reading
Interview: Outgoing Revenue Commissioners head is proud of her time leading the department The international tax environment is still too unsettled for one to predict how any changes taking place will affect the State’s attractiveness for foreign direct investment, according to outgoing chairwoman of the Revenue Commissioners Josephine Feehily. Feehily… – Continue reading
NEW DELHI: India and some other countries have got one more month from the US to sign the Foreign Account Tax Compliance Act (FATCA), an agreement which seeks to facilitate flow of financial information. “US has given a month’s extension to India and some other counties to sign FATCA,” Revenue… – Continue reading
The informal Washington D.C. dinner that took place 40 years ago has become the stuff of legend. That’s when economist Arthur Laffer used a beverage napkin to sketch a chart that became known as the “Laffer Curve.” The following four decades proved Laffer’s point: People change their behaviors in response… – Continue reading
ISLAMABAD: The government has prepared draft bills to introduce amendments to four relevant laws to declare tax evasion as an offence related to money laundering, aimed at curbing misuse of foreign investment and remittance schemes. The step is being taken to meet a condition of the International Monetary Fund (IMF) that… – Continue reading
Two Australian mining companies will be forced to disclose how much tax they pay in every country around the world by new transparency laws introduced in Canada. Paladin Energy and OceanaGold, both dual-listed in Australia and Canada, will have to comply with new Canadian laws requiring all oil, gas and… – Continue reading
There’s an interesting letter in The Guardian arguing that the LuxLeaks leaker should not be prosecuted for what they did is of such public interest that, well, they shouldn’t be prosecuted. The letter is, of course, from the usual suspects and manages, quite heroically, to miss the basic point about… – Continue reading
KPMG has responded to the ATO’s recent taxation ruling TR 2014/8 (documentation requirements) and practice statements PSLA 2014/2 (penalties) and PSLA 2014/3 (simplification). Anthony Seve, KPMG transfer pricing partner, said the ruling places increased compliance and documentation obligations on larger companies. This, he said, is reflective of global developments. “Although… – Continue reading
Nilesh Ashar, partner and head of Tax for KPMG in the UAE, analyses the impact of investment regulations and tax laws on foreign businesses foraying into the Middle East. In the last decade, the Middle East region has witnessed significant economic growth, primarily driven by the surge in oil revenues…. – Continue reading
As part of the Indonesian Government’s drive to improve tax administration and compliance, the Ministry of Finance recently announced that, following a proposal from the Director General of Taxation (DGT), it has placed a temporary ban on overseas travel by senior personnel of 147 companies and 21 individuals. The action… – Continue reading
Japan has remained a cornerstone of Pakistan’s economy for the past many years. Japanese Companies have invested in all sectors across Pakistan. Be it auto, trading, manufacturing, infrastructure development, packaging, steel manufacturing, indenting, etc a large number of Japanese Companies have a strong presence in Pakistan. Pakistan’s Investment and Corporate… – Continue reading
It’s self-assessment time again and although millions of taxpayers are honest and diligent in filing their returns, some are tempted to see what they can get away with not declaring or just cannot be bothered to submit a return on time. To help persuade anyone considering tax avoidance, HM Revenue… – Continue reading
The Federal Board of Revenue (FBR) has constituted a transfer pricing unit to enhance the capacity of the tax officials to effectively deal with the transfer pricing related issues. According to a notification issued by the FBR here on Monday, a transfer pricing unit is set up at the FBR… – Continue reading
Jakarta. A leading business lobby with strong ties to the administration of President Joko Widodo has called for a tax amnesty, in which the authorities will waive off past taxes and penalties to conglomerates and individuals parking billions of dollars worth of funds overseas, in a bid to reinvest that… – Continue reading
“The religion of socialism is the language of priorities,” said Nye Bevan, Labour saint and creator of the National Health Service. Now we have discovered the principal priority of one of his heirs, Ed Balls; taxing the homes of the rich. The shadow Chancellor, once so relaxed about the wealth… – Continue reading
*Ernst & Young LLP, New York, NY The BEPS beat plays on. Congratulations to the OECD for meeting (mostly) the ambitious goals for release of their reports on seven action items in September 2014 – right on schedule on September 16. The documents released on September 16 relate to Action… – Continue reading
The Luxembourg Government is to provide the European Commission with a list of the tax rulings issued by its tax authorities, along with a list of the beneficiaries of its concessionary tax regime for intellectual property (IP) income. Luxembourg Prime Minister Xavier Bettel announced that the decision had been made… – Continue reading
The disclosure of thousands of pages of confidential documents on Luxembourg tax deals was a “game changer” that led European Union regulators to expand their probe of such accords to all 28 nations in the bloc, Luxembourg Finance Minister Pierre Gramegna said. The EU’s expanded investigation “is not a surprise… – Continue reading
