Category: Statutory

Banking / Cayman Islands / Hedge Fund / Offshore / Offshore Tax Evasion / Regulatory / Tax Avoidance / Tax Haven

Cayman tops ranking of money hideouts

Posted On: February 19, 2020

Cayman is now the top enabler of financial secrecy in the world, according to the findings from the Tax Justice Network’s Financial Secrecy Index 2020. In second and third place respectively, were the United States and Switzerland. The Tax Justice Network has called on policymakers to prioritise sanctions against Cayman… – Continue reading

Canada / Dividends / Infrastructure / Investments / Lease / Legislation / Profit Shifting / Revenue / Royalties / Tax Authority / Tax treaties / Treating Shopping / Treaty Abuse

Canada: Treaty Shopping: MIL, MLI And ALTA Things In Between

Published by: Mondaq - February 19, 2020

On February 12, the Federal Court of Appeal (FCA) released its decision in The Queen v. Alta Energy Luxembourg S.a.r.l.1 (Alta Energy), a case that represents an attempt by the Canadian tax authority to relitigate the issue of whether Canada’s domestic general anti-avoidance rule (GAAR) can apply to curtail so-called “treaty shopping”.2   ... - Continue reading

EU / Forms / OECD / Revenue / Sweden / Transfer pricing

Sweden’s tax agency rejects Puma’s transfer pricing position, concludes risk borne elsewhere

Posted On: February 11, 2020

The Swedish tax agency has adjusted the taxable income for the PUMA Group’s Swedish distributor, Puma Nordic AB, concluding that, for transfer pricing purposes, the Swedish distributor could not control the main risks in the Puma Group and therefore should not have carried the local market risks. The adjustment, made… – Continue reading

Framework / G20 / Lease / Multinationals / OECD / Permanent establishment / Revenue / Transfer pricing

Countries launch review of country-by-country reporting framework for multinational groups

Published by: MNE Tax - February 9, 2020

An OECD-led group of 137 countries that work together on multinational group tax issues has released a consultation document and has requested public feedback to assist in a planned review of country-by-country reporting. The countries, known as the “Inclusive Framework on BEPS,” also scheduled a public consultation on the topic for March 17.
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Bangladesh / Czech Republic / Double Tax Treaty / Double Taxation / Investments / Tax Authority

Dhaka, Prague sign deal to avoid double taxation

Posted On: December 12, 2019

Bangladesh and the Czech Republic have signed a double taxation avoidance agreement (DTAA) in a bid to strengthen bilateral trade and investment ties between the two countries. National Board of Revenue (NBR) chairman Md Mosharraf Hossain Bhuiyan and Czech deputy prime minister and finance minister Alena Schillerova inked the agreement… – Continue reading

Base Erosion & Profit Shifting / Business / Corporate Tax / Country-by-Country (CbyC) Reporting / Framework / Multinationals / OECD / Revenue / Tax Avoidance / USA

GRI issues international corporate tax reporting standard

Posted On: December 9, 2019

The Global Reporting Initiative has issued a new international tax reporting standard that aims to ensure multinational companies are much clearer about how much they pay in taxes, and where. While the standard has no legal force, it could influence the ongoing debate in the U.S. and abroad on how… – Continue reading

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