Transfer pricing (TP) issues have never been such a critical part of the global economic agenda as they are today. Following the release of the report addressing Base Erosion and Profit Shifting (BEPS) in February 2013, OECD and G20 countries (including India) adopted a 15-point Action Plan to address BEPS… – Continue reading
Kenya enacted a new law targeting units of foreign companies that escape remitting most of their domestic taxes by allocating income to tax havens while attributing expenses to the East African nation, a practice known as transfer pricing. The Tax Procedures Act gives the Kenya Revenue Authority powers to investigate… – Continue reading
Revenue spike sees tech firm’s parent company, Alphabet, valued at $568bn – surpassing Apple’s valuation of $535bn Google has become the world’s most valuable listed company after announcing that its global revenues rose 13% to $75bn (£52bn) last year, and the group’s tax rate fell to just 17%. The group… – Continue reading
MUMBAI: In what could lead to an increase in domestic tax liabilities of many Indian conglomerates and multinationals, the government is set to introduce a framework for Base Erosion and Profit Shifting (BEPS), a global agreement to check tax avoidance by multinationals, in the upcoming Budget. Industry sources expect the… – Continue reading
ARLINGTON, Va., Jan. 14, 2016 /PRNewswire-USNewswire/ — Bloomberg BNA today announced the publication of the Daily Tax Report’s 2016 Outlook on tax and accounting policy. Dozens of policy experts, along with current and former members of Congress, congressional staffers and federal agency officials provided insights on the year ahead regarding… – Continue reading
Eleventh-hour legislation in December kept many tax breaks alive for the 2014 tax year, but they weren’t extended beyond that. (See chart on page 26.) So clients who want to take advantage of those breaks need to get with a knowledgeable practitioner—and quickly. “CPA firms nationwide face a staffing challenge… – Continue reading
The Australian Tax Office is pushing ahead with a controversial plan to allow the country’s biggest corporations to audit themselves through their own private auditors, despite mounting public anger over corporate tax avoidance. An ATO spokesman said 56 public companies with a turnover of between $100 million and $5 billion… – Continue reading
South Africa has lost out on billions in tax revenue in the past decade as large corporations, wealthy individuals and criminal syndicates slipped nearly R1-trillion out of the country. A Washington DC research and advocacy group, Global Financial Integrity, believes South Africa suffered “illicit financial flows” totalling more than $122-billion… – Continue reading
India enacted transfer pricing rules in 2001, which require companies to conclude international transactions with associated enterprises at an arm’s length. The legislation is primarily targeted at large business groups who engage in base erosion and profit shifting to avoid paying corporate income tax in India. This article is the… – Continue reading
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
In recent court filings made in various federal district courts in Washington and California, the Internal Revenue Service is seeking to enforce testimonial summonses issued to current or former Microsoft employees, including former CEO Steven A. Ballmer. The summons had been issued earlier this fall. Microsoft’s outside tax counsel responded… – Continue reading
The Internal Revenue Service has sued former Microsoft CEO Steve Ballmer and a slate of other former and current executives, seeking to compel them to testify in a long-running investigation into how the company’s sales through subsidiaries affected its taxable income. The Internal Revenue Service has sued former Microsoft Chief… – Continue reading
Bravura Solutions reflects on a year of reform and looks forward to 2015. The Chancellor’s Autumn Statement last week didn’t deliver anything as revolutionary as the reforms announced in his March budget, but there were a few early Christmas crackers around ISA rules. After a monumental year, let’s look at… – Continue reading
Transfer pricing has been an area of high importance for years. We are seeing that multinational companies operating in Germany are being increasingly examined by tax auditors. The level of transfer pricing expertise of the tax auditors is also increasing. Therefore, the transfer pricing environment in Germany is getting more… – Continue reading
Heading into the G20 in Brisbane last month, Treasurer Joe Hockey thundered that multinational companies who avoided paying tax were akin to “thieves” whose actions rendered it harder for governments to tackle poverty. Sadly however the government’s actions have failed to match its rhetoric. This week’s crafty back-down on Section… – Continue reading
Former PricewaterhouseCoopers auditor charged with theft and violating trade secrets in wake of LuxLeaks scandal speaks out A 28-year-old former PricewaterhouseCoopers auditor charged with theft and violating trade secrets in Luxembourg in the wake of the LuxLeaks tax avoidance scandal has revealed his identity and claimed he acted out of… – Continue reading
At its Fall Meeting in Nashville, Tennessee on December 11-12, the MTC’s Executive Committee voted to formally contact states to solidify whether there is sufficient financial commitment to fund any potential MTC transfer pricing program. The MTC also formally announced that Iowa, Pennsylvania and Rhode Island will join the MTC… – Continue reading
The Australian Tax Office is auditing 10 multinational corporations and the government will consider introducing new laws aimed at targeting tax avoidance, Joe Hockey has said. The treasurer said on Tuesday the ATO was “embedded in the offices” of multinationals operating in Australia to closely scrutinise whether those companies were… – Continue reading
Some of the world’s leading tech companies are reportedly being audited by the tax office for off-shore ‘super profit’ shifting. Up to 10 multinational companies, one believed to be the Google, have been forced to open their books as the ATO begins a $1.5 billion tax hunt. Commissioner of Taxation… – Continue reading
Perhaps it was just a matter of time until the Internal Revenue Service decided to “outsource” its tax audit and litigation function to a private entity, i.e., a law firm. As reported in the December 8th issue of Tax Notes, the Service has hired the law firm of Quinn Emanuel… – Continue reading
Please credit and share this article with others using this link:http://www.bangkokpost.com/business/telecom/448032/officials-use-it-to-catch-tax-dodgers. View our policies at http://goo.gl/9HgTd and http://goo.gl/ou6Ip. © Post Publishing PCL. All rights reserved. The Revenue Department has adopted an IT system to track taxpayers with irregularities in their tax payments as part of its effort to increase collection… – Continue reading
Greece is currently implementing a fiscal adjustment programme aimed at tackling tax evasion. This column discusses the impact of recent tax administration reforms on tax compliance in Greece. The intensification of audits, enforcement of penalties, and efficient collection of past debts can induce tax compliance and raise the collected revenue…. – Continue reading
During his address to the General Assembly on Wednesday Russian President Vladimir Putin stated that Russian business should be freed from obsessive control. MOSCOW, December 4 (Sputnik) — Russian President Vladimir Putin stated Thursday that it is necessary to lift restrictions for Russian business, freeing it from obsessive control. “As… – Continue reading
Business people often believe that the only consequence of a tax offence will be the claim for the outstanding (non-paid) taxes and administrative penalties. The issue of potential criminal liability of the chief executive officer is usually disregarded. This may be a serious mistake of the affected company and its… – Continue reading
BVI Business Companies A1. What is the law on keeping and retaining records? Section 98 of the BVI Business Companies Act 2004 (BCA) has always provided that a BVI business company must keep records that: are sufficient to show and explain the company’s transactions; and will, at any time, enable… – Continue reading
A Canada Revenue Agency crackdown on tax-free savings accounts has some people wondering whether TFSAs will always be shielded from a federal government that might be looking to generate cash. Here’s what will get your TFSA audited by the CRA Bank of CanadaCanada’s Taxman has an audit project targeting Canadians… – Continue reading
MOSCOW, Nov. 25 (Xinhua) — Russian entrepreneurs must report to tax authorities about their ownership of shares in the off- shore jurisdictions, according to the law signed by President Vladimir Putin on Tuesday. The new law introduces an amendment to the Russian Tax Code that will force Russian owners of… – Continue reading
TRANSFER pricing (TP) audit is a bit different from normal tax audits. It primarily focuses on reviewing transfer pricing returns and supporting TP documentation submitted by taxpayers who had engaged in related party transactions in the preceding year of assessment. This approach is necessary in order for the tax authority… – Continue reading
THE South African Revenue Service (SARS) is investigating possible changes to the law to make it easier for it to audit transfer pricing by multinational companies to ensure that they pay their rightful tax dues to the government. The need to maximise tax revenue has become particularly acute in the… – Continue reading
UK and multinational enterprises are starting to consider (re)organising themselves under a UK holding company for their global operations, rather than using other traditional onshore holding company jurisdictions. This new trend is the result of a number of factors, which have moved the UK from an outside choice as an… – Continue reading
Domestic banks are to be required to allocate 1.5 percent of their total housing loans as provision for bad debts within the next three years to reduce risks should the property market slow down, the Financial Supervisory Commisson (FSC) said yesterday. The announcement came after the commission reached an agreement… – Continue reading
IN July 2014, the Federal Inland Revenue Service (FIRS) sent letters to some tax consultants requesting their non-resident clients operating in Nigeria to file complete tax returns effective from 2014 tax year. In practice, non-resident companies file their tax returns on the deemed profit basis. Following an initial period of… – Continue reading
A slew of regulatory changes including Companies Act 2013, GST and Transfer Pricing (TP) are likely to redefine the role of chief financial officers (CFOs) according to a report unveiled by KPMG in India and CII. The report titled ‘Playing to Win in a VUCA Environment’ was unveiled at the… – Continue reading
The National Tax Service (NTS) said Thursday that it will help foreign companies in Korea reduce potential tax uncertainty regarding their cross-border transactions with parent firms. From 2015, the NTS will allow foreign firms that earn less than 50 billion won ($46 million) a year in sales to focus on… – Continue reading
Nov 5 (Reuters) – The Hong Kong Monetary Authority (HKMA) has launched an onsite examination into Hong Kong-based Taiwanese banks’ loan exposure to mainland Chinese companies, banking sources said on Tuesday. The HKMA, which is responsible for maintaining Hong Kong’s monetary and banking stability, stepped up its supervision of Hong… – Continue reading
For more than a decade, tax gurus at PricewaterhouseCoopers helped Caterpillar Inc., the U.S. heavy equipment maker, move profits produced by its lucrative spare-parts business from the U.S. to a tiny subsidiary in Switzerland. Little changed except the bookkeeping. Parts were still shipped from suppliers to a warehouse in Morton,… – Continue reading
In a recent Senate Estimates hearing, Greens Senator Christine Milne probed ASIC representatives to explain why they consider Facebook Australia a ‘small’ company, especially considering the parent organisation is worth a staggering $US33.3 billion. Facebook Australia is a ‘small’ company by its own determination and it is registered as such… – Continue reading
Christine Milne says Australian Securities and Investments Commission should target ‘smaller enterprise’ exemption Facebook Australia has not lodged annual accounts since 2009 because it says it is a smaller enterprise and exempt from having to file. Photograph: Jonathan Nackstrand/AFP/Getty Images The Greens are calling on the Australian financial services watchdog… – Continue reading
On 29 July 2014, the China State Administration of Taxation (SAT) released an internal notice to the China tax authorities at the provincial levels, in the name of “Notice on Antiavoidance Investigation against Large Amount Outbound Payments” (Circular Shui Zong Ban Fa [2014] No. 146, Notice 146), urging a nationwide… – Continue reading
Twitter is funnelling much of the revenue it generates in Britain through an offshore sales structure, newly published annual accounts suggested today. Twitter UK has filed abbreviated 2013 accounts for a small company under Companies House rules, which are usually applicable to a business with an annual turnover of less… – Continue reading
Clients of UBS AG (UBSN), Switzerland’s largest bank, have led a five-fold surge in the number of Canadian residents reporting hidden offshore income over the past eight years. Almost 6,000 taxpayers came forward in the past 12 months as part of the Canada Revenue Agency’s voluntary disclosure program to report… – Continue reading
HONG KONG – The government of Hong Kong has recently announced that it will support the Organization for Economic Cooperation and Development’s (OECD) new global standards on the automatic exchange of information for the purpose of enhancing tax transparency and combating cross-border tax evasion. Earlier this year, the OECD released… – Continue reading
The Commodity Futures Trading Commission (CFTC) is wary of banks invoking guarantees on foreign swap deals, and is taking steps to scrutinize such activity. The Commodity Futures Trading Commission (CFTC) is wary of US banks shifting their trading activities offshore and has urged other regulators to scrutinize banks involved in… – Continue reading
FIFA’s financial monitoring panel has asked one of its members to explain his arrest in a corruption case. Canover Watson was detained in his native Cayman Islands on Aug. 28 by police anti-corruption and financial crime units. Local media reported that Watson was quizzed about alleged money laundering and abuse… – Continue reading
India is set to scrap the R15-crore threshold for referring every international transaction between an MNC’s arms for compulsory transfer pricing audit, and about to embrace a more focused approach to zero in on cross-border transactions with potential for tax evasion. The proposed risk-based selection of transactions between MNC arms… – Continue reading
Section 3 and 4 of the Companies (Miscellaneous Provisions) Act 2013 commenced on Monday 10th March 2014. This Act removes the requirement for accounts documents filed with the CRO to include handwritten signatures of Directors, Auditors etc and instead requires that the signatures appear in TYPED form on each document. Where accounts… – Continue reading
