Category: Base Erosion & Profit Shifting

UK: Consultation Over Fixed Cap On UK Tax Deductibility Of Corporate Interest Expense: Plucking The Feather In The Cap?

The UK Government launched a consultation on 22 October 2015 regarding the UK corporate tax rules for interest deductibility. The consultation seeks views on the design of a general limitation for UK corporation tax deductions for interest and similar finance costs, imposing a capcalculated by reference to a fixed percentage… – Continue reading

BEPS AND QATAR OUTBOUND INVESTORS – MANAGING REPUTATIONAL RISK AND PREPARING FOR CHANGE

Across the globe, base erosion and profit shifting (BEPS) is making headlines and drawing the attention of not only governments and tax authorities but also non-government organizations, activists, lobbyists and the general public. As the public debate has spread to the Gulf Cooperation Council (GCC) countries, the focus now centers… – Continue reading

G20 vows balanced growth – Capital flow a concern

Antalya, Nov. 16: The Group of 20 nations today pledged to adopt sound macroeconomic policies to achieve strong, sustainable balanced growth. The near-term objective would be to support growth, create jobs and put debt as a share of gross domestic product (GDP) on a sustainable path. Data show that several… – Continue reading

BEPS tax reforms ‘cannot be the endpoint’, G20 told

The OECD’s base erosion and profit shifting (BEPS) reforms do not go far enough in changing the international corporate tax system, G20 leaders have been told. In a letter to leaders at the G20 summit in Antayla, Turkey, Nobel Prize-winning economist Joseph Stiglitz and others from the Independent Commission for… – Continue reading

MEPs accuse US multinationals of diverting profits to low tax havens

Amazon, Facebook and Google in line of fire after committee backs proposals to force multinational corporations to pay tax where they make their sales MEPs have launched a scathing attack on Facebook, Google and Amazon in the European parliament, accusing them of diverting profits worth billions of pounds to low… – Continue reading

180 Participants From 47 Countries Attend CATA Confab In Melaka From Tomorrow

MELAKA: Some 180 participants from 47 countries will attend the five-day 36th annual Technical Conference of the Commonwealth Association of Tax Administrators (CATA) here from tomorrow. The Inland Revenue Board (IRB) said among the countries taking part in the conference are Australia, South Africa, Brunei, India, New Zealand, Canada, Pakistan,… – Continue reading

Indonesia to end ‘bank secrecy’ in 2017

Indonesia is set to end its “bank secrecy” policy in September 2017, allowing the country to exchange tax information with other countries, which would be a major step in the fight against tax evasion and financial fraud. Finance Minister Bambang Brodjonegoro said that Indonesia would be an early adopter of… – Continue reading

UPDATE 1-G20 leaders pledge robust fight against patchy economy -draft communique

* G20 leaders say they will deliver on vow to lift global growth * G20 promise not to surprise markets with policy decisions * World leaders agree to tackle tax dodgers, pledge to cooperate on migrants (Adds details, background) BELEK, Turkey, Nov 15 The heads of the world’s 20 largest… – Continue reading

Cantillon: no escape from tax talk at G20 summit

Leaders of world’s major economies gather in Turkish city of Antalya Leaders of the world’s major economies gather in the Turkish city of Antalya this weekend for the tenth annual G20 summit. The summit takes place at a sensitive moment in international affairs. The war in Syria and the resulting… – Continue reading

OECD holds first Asia-Pacific Technical Meeting on BEPS in Indonesia

3/11/2015 – On 11-12 November 2015, the first Asia-Pacific Technical Meeting on BEPS discussed the outcomes of the BEPS Project, and the challenges countries face in the region in implementing BEPS, and explored how countries in the region can engage in the implementation, on-going development and monitoring of the measures… – Continue reading

Australia-Germany Sign Tax Treaty; Michael Turnbull Visits for Submarine Bid

In the first step towards boosting trade and investment between the two nations, Australia and Germany have signed a new tax treaty in Berlin. It also marks an attempt to improve the integrity of the tax system by pinning down on multinational tax evasion. The deal, which preceded the arrival… – Continue reading

U.S. Implementation of BEPS Changes Begins

As at least the first phase of the OECD’s BEPS project1 wound down with the October release of the “final” BEPS deliverables, questions remained regarding how much of the recommended changes would be implemented in the United States in the near term. Because many of the recommendations require legislative changes… – Continue reading

G-20 summit At Turkey: India has a lot to learn and deliver

The group, as a whole, will have to contend with adopting the BEPS framework and fulfilling the commitments made under the Brisbane Action Plan 2014 The tenth G-20 meeting at Antalya, Turkey, (that starts day after tomorrow) is gaining momentum. The challenges before the G-20 nations are many and varied…. – Continue reading

Canada to join G20 effort to limit ‘profit shifting’ by multinationals

Canada is expected to join other G20 countries to sign off on an international deal in Turkey aimed at cracking down on “profit shifting” by large multinational companies seeking to reduce their tax bills. The changes, which are also aimed at exposing the corrupt use of tax havens to launder… – Continue reading

Opening Bell: Ireland told not to rely on low taxes to grow, NAMA’s dispute with Dunnes, Draghi’s statement on Ireland

The Organisation for Economic Co-operation and Development’s (OECD) chief economist has warned that Ireland cannot rely on low corporation taxes to fuel growth. “Ireland is going to have to seek real investment based on comparative advantages other than tax,” Prof Catherine Mann told a conference hosted by the Irish Department… – Continue reading

OECD Warns Ireland That Growth Will Take More Than Just Low Taxes

Ireland has among the lowest taxes in Europe. However, the Organization for Economic Cooperation and Development (OECD) is not impressed. They warned Ireland that it will have to spend more time selling itself in the new era of global tax transparency if it wants to experience meaningful economic growth. OECD… – Continue reading

Modi, Obama unlikely to meet during G20 summit in Turkey

Both leaders recently discussed key bilateral issues on the new ‘hotline’ NEW DELHI, NOVEMBER 12: In a major deviation from earlier times, the much-publicised bilateral meeting between Prime Minister Narendra Modi and US President Barack Obama is unlikely to happen on the sidelines on the 10th G20 summit in Turkey…. – Continue reading

MULTINATIONALS HIDING BILLIONS, SAYS REPORT

Tax: Luxembourg among countries helping US firms cut their tax bills by more than a quarter, campaigners say. The abuse of holding company structures in the Grand Duchy, and fiscal regimes in several other countries, allows American firms to avoid paying billions of dollars in corporate profit taxes, two NGOs… – Continue reading

Low taxes alone not enough for growth, says OECD

Chief economist says clampdown on tax avoidance will be ‘negative for Ireland’ Ireland will have to sell itself as more than just a low-tax destination in the new era of global tax transparency, OECD chief economist Catherine Mann has said. She said moves to better align taxable profits with real… – Continue reading

BEPS and real estate investment funds: What are sponsors to do?

The final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) project were issued on 5 October (the “Reports”) after a two-year consultation period during which 62 countries and many other stakeholders (such as the World Bank, the IMF, and many trade associations) participated. These Reports, split into 15… – Continue reading

The Proposed Australian Multinational Anti-Avoidance Law — Leapfrogging the OECD’s BEPS Process to Devise a New Nexus Rule for Remote Sales

On September 16, 2015, the Australian government introduced into Parliament Tax Laws Amendment (Combating Multinational Tax Avoidance) Bill 2015, which contains, among other items (including the implementation of country-by-country reporting), the proposed legislative language to implement Australia’s version of the United Kingdom’s diverted profits tax. The bill was accompanied by… – Continue reading

ANDY: IS OUR “ECONOMIC RECOVERY” BASED ON A SILICON BUBBLE?

Irish corporation tax returns are behaving oddly: the Department of Finance estimates that they are running €2 billion (74 percent) ahead of forecast for the year. Economist Seamus Coffey has described these figures as “very strange”. Coincidentally (or perhaps not) the global accounts of the Apple corporation revealed an increase… – Continue reading

Transfer pricing — the global phenomenon

THE world appears to be getting much smaller. Rapid technological advances, increased people mobility, and changes in the international political climate have all helped to break down many of the traditional barriers to global and regional trade. For dynamic, fast-growing businesses, this increased globalisation represents an excellent opportunity for businesses… – Continue reading

Senior Tax Officials Meet To Discuss BEPS Project

On November 3-4, 2015, more than 260 senior tax officials from 102 jurisdictions and international organizations met to discuss the tax treaty-related outcomes of the OECD’s base erosion and profit shifting project. Participants at the 20th Annual Global Forum on Tax Treaties welcomed the tax treaty-related measures agreed upon in… – Continue reading

UK: CHANGES TO INTEREST DEDUCTIBILITY RULES, IMPLICATIONS FOR TRANSFER PRICING

Following the October 2015 release of the OECD’s base erosion and profit shifting (BEPS) deliverables, some consultations in the UK have already been opened—including one on the UK’s rules concerning the deductibility of corporate interest expense and how this treatment would be affected by BEPS Action 4 (which seeks to… – Continue reading

European Commission releases press material for the upcoming G20 summit in Antalya

On November 10, 2015 the European Commission published a brochure titled “Did you know… Facts and figures about the European Union and the G20 – 2015 Turkey G20 Antalya, 15>16 November 2015”. According to the European Commission, the brochure sets out the European Commission’s aims for the G20 summit. The… – Continue reading

Still Broken: major new report on global corporate tax cheating

“In 2013 the OECD, supported by the G20, promised to bring an end to international corporate tax avoidance which costs countries around the world billions in tax revenues each year. However, with the recently announced actions against corporate tax dodging, G20 and OECD countries have failed to live up to… – Continue reading

Paradigm shift in tax landscape through BEPS must also engender tax certainty

A paradigm shift in the way business is conducted is taking place as new base erosion of profit shifting (BEPS) rules are aligned with tax systems, but more tax certainty and rules that suit specific African circumstances are needed, a Deloitte OECD Transfer Pricing Guidelines seminar heard on Wednesday, 04… – Continue reading

BEPS: Financial transparency – the taxing question for multinationals

While proponents of the base erosion and profit shifting project claim it will facilitate appropriate taxing of global corporate profits, enforcement remains the elephant in the room, writes FX-MM’s Paul Golden. In October, the OECD presented the final package of measures for reform of international tax rules, stating that annual… – Continue reading

NAM Highlights Concerns with BEPS, Critical Need for International Tax Reform

Dorothy Coleman, the NAM’s Vice President, Tax and Domestic Policy, today joined U.S. Senator Rob Portman (R-OH) and a panel of experts, including representatives from the Organization for Economic Co-Operation and Development (OECD), to discuss key international tax issues, including the Base Erosion and Profit Shifting (BEPS) project recommendations recently… – Continue reading

US corporations avoid an estimated $2 billion tax every year in Australia: report

United States corporations avoid an estimated $US1.45 billion ($2.06b) of tax in Australia each year by shifting their profits to low or no tax countries, research shows. A joint report by advocacy and union groups Tax Justice Network, Oxfam, Global Alliance for Tax Justice and Public Services International says in… – Continue reading

Governments have taken an important step towards ensuring cross border consumption tax

Governments have taken an important step towards ensuring that consumption taxes on cross-border transactions are effectively paid in the jurisdiction where products are consumed, while minimizing the risks that uncoordinated tax rules distort international trade. The decision by representatives of more than 100 countries and jurisdictions to endorse the new… – Continue reading

NZ welcomes Cook Islands measures to tackle tax avoidance

NZ welcomes Cook Islands measures to tackle tax avoidance Minister of Revenue Todd McClay has welcomed a decision by the Cook Islands government to implement the ‘Automatic Exchange of Financial Account Information in Tax Matters Agreement’ (AEOI) and says the Cooks Islands and New Zealand will play their part to… – Continue reading

FRANCE: STATUS OF TRANSFER PRICING DOCUMENTATION, COUNTRY-BY-COUNTRY REPORTING

Legislative proposals being considered in France would require the automatic filing of transfer pricing documentation and, as part of this documentation, country-by-country reporting. STATUS OF PROPOSALS The Finance Committee of the French National Assembly has started its consideration of tax provisions relating to the second part of the Finance Bill… – Continue reading

Countries Agree Common VAT Rules For Digital Services

Representatives from more than 100 countries and jurisdictions have endorsed new OECD International VAT/GST Guidelines, which are intended to establish international standards for the “coherent and efficient” application of value-added tax (VAT)/goods and services tax (GST) to the international trade in services. The countries endorsed the new guidelines at the… – Continue reading

Deloitte Poll: US Business Executives Cite Concerns and Priorities for OECD’s Final BEPS Package

NEW YORK, Nov. 9, 2015 /PRNewswire/ — Business executives cited an increased compliance burden as their biggest concern with the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting initiative (37.7 percent), according to an October Deloitte poll. Other concerns included double taxation of income (17 percent) and… – Continue reading

Transfer pricing drains us of tax blood

Transfer pricing by multinationals has cost South Africa an estimated R250 billion over three years and, with it, lost tax revenue. This is according to Sunia Manik, group executive for the large business centre at the SA Revenue Service (Sars), adding that it was being done through “service payments” made… – Continue reading

Tax system slow to adapt to digital economy’s rise

LOST REVENUE:A lack of regulations on taxing cross-border Web-based content and services providers puts their local peers at a disadvantage, Ernst & Young said The nation’s tax system is relatively behind developed markets in adapting to the proliferation of the digital economy, which has resulted in lost revenues for the… – Continue reading

Bleak growth exposes malaise of revenue shortfalls

First it was the scourge of public sector corruption, until now the mortifying spectacle of South Africa’s post-apartheid transition. Now, with the ground shifting beneath the world’s sclerotic economy – and the past few years have produced more tremors than ever in the 21 years of democracy – it’s a… – Continue reading

POLAND: EXPANDED TRANSFER PRICING, COUNTRY-BY-COUNTRY REPORTING ENACTED

New law in Poland expands the requirements for transfer pricing documentation, and includes country-by-country (CbC) reporting. The new provisions essentially reflect the recommendations made in Action 13 the OECD’s base erosion and profit shifting (BEPS) project, and provide for CbC, master file and local file reporting. The legislation was passed… – Continue reading

OECD BEPS Heralds Big Changes for Tax Pros and Corporate Treasurers

The Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting action plan is likely to have a major impact on tax planning at multinational corporations by both tax professionals and corporate treasurers. Tom Driscoll, U.S. managing partner for international tax, transfer pricing, and indirect tax at Deloitte Tax… – Continue reading