MUMBAI: India has been an active participant in the Base Erosion and Profit Sharing (BEPS) action plan, the final package of which was rolled out by the Organisation for Economic Co-operation and Development (OECD) in October. The action points, set down by the OECD, aim at closing loopholes that enable… – Continue reading
From the start of 2016, multinational companies found to be avoiding tax will have pay back the tax owed, plus a 100 per cent penalty, reports ZD Net. The Australian Greens have voted with the Coalition to pass legislation that will see multinational companies with annual revenue above AU$1 billion… – Continue reading
The agenda of the meeting of the European Economic and Financial Affairs Council (ECOFIN) of December 8, 2015 has been published on the website of the European Council/Council of the European Union. According to the Agenda, ECOFIN will a.o. discuss 2 tax subjects. First of all the proposal for a… – Continue reading
“The Business Council welcomes the passage of the government’s multinational tax bill through the Parliament. The legislation will see Australia play its part in responding to the OECD’s Base Erosion and Profit Shifting package. It will provide companies with certainty around their obligations, and provide the community with greater confidence… – Continue reading
Multinationals in India will soon have to forgo to a great extent the flexibility in managing their tax outgo in the country and have to report their global operations in elaborate detail to the tax authorities here. This is because New Delhi is set to adopt a new regime to… – Continue reading
Corporate tax revenues have been falling across OECD countries since the global economic crisis, putting greater pressure on individual taxpayers to ensure that governments meet financing requirements, according to new data from the OECD’s annual Revenue Statistics publication. Average revenues from corporate incomes and gains fell from 3.6% to 2.8%… – Continue reading
x MUMBAI: India has been an active participant in the Base Erosion and Profit Sharing (BEPS) action plan, the final package of which was rolled out by the Organisation for Economic Co-operation and Development (OECD) in October. The action points, set down by the OECD, aim at closing loopholes that… – Continue reading
Developments driven by Base Erosion and Profit Shifting (Beps) boost Irish tax The closing down by Irish multinationals of tax planning arrangements involving offshore or foreign subsidiaries is part of the reason for Ireland’s increased corporation tax receipts, according to an informed source. Under country-by-country reporting rules, Irish companies with… – Continue reading
Some of the DTAAs entered into by India with other countries allow taxation of capital gains on shares only in the country of which the taxpayer is a resident. The government on Friday told the Lok Sabha that it has started negotiations with some countries to amend provisions on capital… – Continue reading
Tax authorities around the world could take a “cowboy” attitude towards captive tax rights when following guidance from the Base Erosion and Profit Shifting (BEPS) papers, according to Dr Pierre Olivier Gehriger, partner and certified tax expert at Pestalozzi Attorneys at Law. Speaking on a Captive Review webinar hosted by… – Continue reading
The Government of India is aware of the potential loss of revenue from tax avoidance, and has been taking all necessary measures for preventing it. As a part of these measures, India has actively participated n the Base Erosion and Profit Shifting (BEPS) project undertaken by the OECD and G-20… – Continue reading
The highly significant changes to transfer pricing guidance planned for under the SAT’s public discussion draft on ‘Special Tax Adjustments’ (yet to be finalised at the time of writing), and the impact of these changes in the light of evolving Chinese transfer pricing enforcement practice is the focus of this… – Continue reading
Leaders from the Group of 20 largest economies (G20) met in Turkey last month to put their final stamp of approval on a major overhaul of the international rules governing corporate taxes. The vote was the icing on a cake that the Organization for Economic Cooperation and Development (OECD) has… – Continue reading
The Organisation for Economic Co-operation and Development (OECD) sees treaty shopping as an important source of Base Erosion and Profit Shifting (BEPS). In this context, it identified the prevention of treaty abuse as one of fifteen issues or “actions” in respect of which recommendations were to be formulated as part… – Continue reading
HONG KONG, Dec. 2, 2015 /PRNewswire — Demand for asset protection, wealth planning and funds by high net worth individuals in Asian countries will drive continued growth in the offshore industry, according to OIL’s sixth “Offshore 2020” annual market research study. OIL, the leader in international incorporations and corporate services… – Continue reading
We are all aware of “base erosion and profit shifting” or “BEPS”. On 5 October 2015, the OECD released its final reports in connection with its BEPS Action Plan including its final report on Action 15 dealing with the development of a multilateral instrument to modify bilateral tax treaties (“Final… – Continue reading
Corporation tax receipts for the year came to €4.6bn in 2014. By October this year, receipts had already exceeded that, with the expectation that the full-year receipts will be around €6.5bn with the Budget projecting growth in receipts in 2016 of 10 per cent. In a little over a year,… – Continue reading
Lawmakers seek late deal to scale back ‘Cadillac tax’ Lawmakers are making a late push to repeal or scale back Obamacare’s “Cadillac tax” by the end of the year, eying inclusion of changes in a broader tax package, wrote Peter Sullivan of The Hill. But lawmakers in both parties say… – Continue reading
The Government has recently launched a consultation on amending the UK’s interest deductibility rules for companies. The consultation follows the OECD’s recommendations as part of the Base Erosion and Profit Shifting (BEPS) project. In line with those recommendations, it is proposed that a company’s net interest deductions be limited to… – Continue reading
Inland Revenue is looking at the tax treatment of hybrid debt and equity instruments and the use of related party loans funding local subsidiaries as part of a global clamp-down on tax avoidance. Acting deputy commissioner of policy and strategy David Carrigan told Parliament’s finance and expenditure select committee that… – Continue reading
Republicans in both chambers of Congress said international tax reform is necessary to retain companies in the United States following pharmaceutical giant Pfizer’s announcement it is moving its headquarters overseas after its merger with Ireland-based Allergan, citing the country’s high corporate tax rates. During hearings in the House Ways and… – Continue reading
A new international framework is targeting tax avoidance—and it has implications for captive insurers. Jenny Coletta of Ernst & Young explains In recent years, tax authorities around the world have been increasingly scrutinising captive insurance arrangements, focusing on questions relating to commercial purpose, pricing and substance. In what is likely… – Continue reading
On 17 September, 2015, China State Administration of Taxation (“SAT”) released the Discussion Draft of Implementation Measures for Special Taxation Adjustments (“Discussion Draft”), as a complete revamp to the existing trial version of the Implementation Measures, i.e., Circular 2. Circular 2 has been serving as a backbone transfer pricing (“TP”)… – Continue reading
“Luxembourg is famous for two things: its steel industry and its rose cultivation industry”. This quote from an Italian guidebook of the 1930s was uttered by Luxembourg’s Finance Minister Pierre Gramegna at the annual conference of the Luxembourg Directors’ Association on 17 June 2015[1]. The economic outlook of the tiny… – Continue reading
Some U.S. lawmakers on Tuesday used a pair of hearings in the Senate Finance Committee and the House Ways and Means Committee to showboat for corporate special interests and oppose a growing worldwide movement to crack down on international tax avoidance. Last month, leaders of the 20 largest economies in… – Continue reading
The 28 nations of the European Union lose up to $1 trillion per year in revenue thanks to multinational corporations that use a spider’s web of completely legal constructs to lower their taxes. Now, Europe’s law enforcers and lawmakers want to wipe away these intricate tax-avoidance systems. If they have… – Continue reading
Today, the Senate Finance Committee met to discuss the Organization for Economic Co-operation and Development’s (OECD) project on Base Erosion and Profit Shifting (BEPS), a set of proposals on international tax policy approved earlier this fall that will place U.S. companies at a competitive disadvantage globally. Testifying with me today… – Continue reading
“It is not the strongest or the most intelligent who will survive but those who can best manage change”-Charles Darwin The Organization for Economic Co-operation and Development (OECD) released its final recommendations on the Base Erosion and Profit Shifting (BEPS) Project on October 5, 2015. The BEPS project consist of… – Continue reading
The House and Senate held hearings Tuesday on the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting action plan, also known as OECD BEPS, for combating tax avoidance by multinational corporations. A number of the lawmakers expressed a skeptical view of the international tax reforms. “The OECD’s… – Continue reading
Pension schemes should review their holdings in infrastructure heading into 2016, with the dual threat of incoming regulation and high prices potentially threatening returns, Kames Capital has said. Infrastructure has been an increasingly popular asset class for many schemes since bond yields tumbled in the wake of the financial crisis,… – Continue reading
The current international tax regime was developed in the last century when the internet was not yet invented. At that time, a foreign company would typically require a substantial physical presence in Australia before it could be in a position to earn significant amount of income from Australian customers. This… – Continue reading
EU committee to vote on plans to curb tax avoidance EU countries should be compelled to inform other member states in advance of plans to introduce tax initiatives that could affect their own or another country’s effective tax rate, according to a report to be considered by the European Parliament’s… – Continue reading
The Australian Board of Taxation has released for public comment a discussion paper on the implementation of the anti-hybrid rules developed by the Organisation for Economic Co-operation and Development (OECD). As part of the 2015 Budget, on May 12, 2015, Australian Treasurer Joe Hockey wrote to Michael Andrew, Chair of… – Continue reading
New Article 76-A of the Income Tax Law was published in the Federal Official Gazette on November 18, 2015, establishing three new transfer pricing information returns: Master File, Local File and Country-by-Country Report. Background These measures arise in response to the commitment assumed by Mexico before the Organization for Economic… – Continue reading
Multinationals operating in Kenya, Tanzania and Uganda will be among the first in Africa to feel the impact of new measures to be adopted in January to curb tax losses caused by manipulation of contracts between related companies. The three countries together with Nigeria, Ghana, Burkina Faso, Senegal, Botswana and… – Continue reading
KUWAIT CITY, Nov 29: “The world of taxation has changed tremendously impacted by FATCA, transfer pricing, Base Erosion and Profit Sharing, and others which require dramatic changes in existing operating models and structures,” remarked Fouad Douglas, PwC Country Senior partner, at a tax seminar organised by the PwC in conjunction… – Continue reading
(OECD) In Paris on the occasion of the COP21, the Honourable Billy Graham Talagi, Minister for Ministry of Natural Resources of Niue signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters in the presence of Deputy Secretary General Rintaro Tamaki. Developed by the OECD and the Council of… – Continue reading
NEW DELHI: With a view to weed out commercial activities under the garb of charity, the tax department has said any general public service that involves trade, commerce or business for a consideration will not be treated as Charity under the Income Tax act. Issuing ‘Explanatory Notes to the Provisions… – Continue reading
While the U.S. is plagued by inertia when it comes to tax policy, the rest of the world hasn’t been standing still. The biggest change of late has been the completion of the Organization for Economic Cooperation and Development’s (OECD) Base Erosion and Profit Shifting Project, or BEPS, a multiyear… – Continue reading
Legislative Activity Tax-Writers Begin to Focus on BEPS, Tax Extenders Still Remain Though international tax reform negotiations may have fallen apart for 2015, tax-writers this week will hold their first hearings to address efforts by the Organisation for Economic Co-operation and Development (OECD) to counter corporate tax avoidance as part… – Continue reading
The law, at present, is replete with a complex web of cross-references, often causing confusion The clamour for simplifying tax legislations gets louder as a new government, in its interaction with businesses and the civil society, holds out a promise of a non-adversarial tax regime. The reform of indirect taxes… – Continue reading
Government officials say multinational technology giants are reluctant to pay anything The Korean affiliates of Microsoft (MS) and Oracle are under increasing pressure to pay taxes here, with government officials saying the two multinational technology giants were reluctant to pay anything, although they generated huge a lot of money from… – Continue reading
Action Plan 10 of the Base Erosion and Profit Shifting (BEPS) project of the Organisation for Economic Co-operation and Development (OECD) seeks to align transfer pricing (TP) outcomes with value creation by clarifying the conditions under which transactions between related parties can be re-characterized. It also sheds light on how… – Continue reading
What is the whole point of the 15 actions in the Base Erosion and Profit Shifting (BEPS) code? How will they curb tax dodging and make taxation of multinationals more transparent? Historically, the interaction of different tax policies lead to instances where taxes paid are not commensurate to economic value… – Continue reading
East African countries expect to collect more revenue under a new code drawn, by the world’s richest economies to stop foreign multinationals from dodging taxes in host countries. The new code — Base Erosion and Profit Shifting (BEPS) — adopted by G20 at its meeting in Turkey two weeks ago,… – Continue reading
When it comes to planning for tax season, corporate tax reporting should be considered as part of Enterprise Performance Management. As Margaret Mitchell exclaimed in the classic novel, Gone with the Wind: ‘Death, taxes and childbirth! There’s never any convenient time for any of them.’ And while I hope that… – Continue reading
As Common Reporting Standard (CRS) comes into operation. OHANNESBURG – South Africans with undeclared offshore funds may only have a few months to get their affairs in order or risk facing significant penalties and even criminal prosecution as revenue authorities start the automatic exchange of information. The Common Reporting Standard… – Continue reading
The OECD published 13 final reports along with an explanatory statement under its base erosion and profit shifting (BEPS) project on the 5th October 2015. This was endorsed three days later on the 8th October 2015 by the G20 Finance Ministers’ meeting in Peru’. The BEPS project outlines 15 action… – Continue reading
Introduction Transfer pricing is a term used to define the price charged between associated enterprises for the transfer of goods, services and intangible property. Increasing cross-border activities have made transfer pricing a real issue as enterprises seek to use transfer pricing as a tool for tax avoidance. Consequently, HK has… – Continue reading
FOCUS: Significant changes to the international tax system planned for the next five years, coupled with a major shift in attitudes towards tax avoidance, has all but killed off the traditional tax scheme. So what does the future hold for businesses seeking to engage in tax planning? To celebrate Out-Law’s… – Continue reading
