Foretelling significant changes in tax structures around the world, newly released PricewaterhouseCooper (PwC) report reveals that the future of businesses is dependent on how well their asset managers deal with this emergent tax risk. Titled, ‘Asset Management 2020 and beyond: Transforming your business for a new global tax world’, the… – Continue reading
What has happened? On 5 October 2015 the OECD issued its final paper on BEPS Action 12 Mandatory Disclosure Rules, Action 12 – 2015 Final Report (Paper). In this Alert we highlight the main issues and recommendations for taxation reform raised in the Paper. The Australian Treasurer’s BEPS Press Release… – Continue reading
Zambia Revenue Authority-ZRA- Commissioner General Berlin Msiska says Africa needs to work together to address illegal Financial Flows. Mr Msiska says international cooperation is required because illegal financial flows affect all regions of the continent. He says African Tax administrations can achieve a more effective and efficient relationship through initiatives… – Continue reading
Ireland’s budget statement for 2016 (Budget) was delivered by the Minister for Finance last week. The Budget’s primary focus was on personal tax matters, which is somewhat unsurprising given the general election early next year. However, the Budget also contained two key announcements on Ireland’s corporation tax system. In line… – Continue reading
Following last week’s publication of the various OECD/G20 reports on the Base Erosion and Profit Shifting (“BEPS”) project, the Irish Budget delivered on 13 October 2015 contains the first Government initiative on implementing some of the recommendations. Key features are the introduction of the first of its kind knowledge development… – Continue reading
A recent Thomson Reuters survey report reveals that European companies are outpacing all others in developing their Base Erosion and Profit Shifting (BEPS) action plans by Dec. 31, 2017 – the deadline set by the Organization for Economic Cooperation and Development (OECD). But most respondents voiced several concerns about BEPS… – Continue reading
CHINA may implement new rules by the end of this year to prevent tax evasion by multinational companies as the G20 has endorsed a plan to enhance fairness of international tax revenue, Ernst & Young said. The State Administration of Taxation last Friday finished collecting feedback for amendments to a… – Continue reading
On October 5, 2015, the Organization for Economic Cooperation and Development (“OECD”) released its final report on the 15 key elements of international tax rules set out in its Base Erosion and Profit Shifting (“BEPS”) Action Plan. The OECD launched the BEPS Action Plan in 2013 at the request of… – Continue reading
On 17 September, 2015, China State Administration of Taxation (“SAT”) released the Discussion Draft for the Implementation Measures for Special Tax Adjustments (“Discussion Draft”) to overhaul the existing trial version of the Implementation Measures, i.e., Circular 2. In the chapter of “Contemporaneous Documentation” of Discussion Draft, SAT introduces an entirely… – Continue reading
National Treasury has decided to scrap a recently introduced incentive to make South Africa’s service sector more competitive, despite an impassioned appeal from multinational companies not to do so. The special foreign tax credit for service fees has protected companies from double taxation where South Africa’s treaty partners levied withholding… – Continue reading
On Oct. 5, 2015, the Organization for Economic Cooperation and Development (OECD) released a set of final reports on its 15 point action plan to address Base Erosion and Profit Shifting (BEPS). In an accompanying explanatory statement, the OECD also included plans for additional work on technical matters and a… – Continue reading
Most of yesterday’s pre-election budget statement for 2016 (the “Budget“) by Ireland’s Minister for Finance (the “Minister“) focused on personal taxation. In the portion of his statement covering corporation tax, two key announcements were made in line with expectations following on from the publication of the final reports under the… – Continue reading
NUMBER OF THE WEEK: 0 The number of House Republicans who want to be speaker and can actually secure the necessary 218 votes as of today. After Majority Leader Kevin McCarthy’s dramatic exit from the race last week, the House GOP conference is taking the week-long Columbus Day recess to… – Continue reading
The impact of the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting action plan is still unclear, but tax executives are planning ahead for changes on the international tax front. Earlier this month, the OECD unveiled its plan for combating tax evasion strategies by multinational corporations (see… – Continue reading
The Luxembourg government submitted draft legislative proposals to Parliament—legislation that, if enacted, would both implement certain provisions of the OECD’s base erosion and profit shifting (BEPS) actions and provide for certain EU-compliant measures. The proposals also would be intended to improve the competitiveness of the Luxembourg tax system. The proposals… – Continue reading
What economists and tax practitioners expect to see. JOHANNESBURG – Finance minister Nhlanhla Nene (pictured) will once again be between a rock and a hard place when he presents his Medium-Term Budget Policy Statement (MTBPS) on Wednesday. With the economy under pressure and concerns about how government will balance its… – Continue reading
South Korea is seeking ways to levy a corporate tax on profits of global technology companies and other multinationals as early as next year in response to growing criticism of their tax avoidance structures. The diverted profits tax is more widely called the “Google tax,” as U.S. tech giants such… – Continue reading
The BEPS Project involves input from the 34 member countries of the OECD, all G20 members, and more than 40 developing countries. The objective of the BEPS Project is to close gaps in international tax rules, effectively eliminating or substantially reducing BEPS; and to secure government revenues by ensuring that… – Continue reading
On 17 September, 2015, China State Administration of Taxation (SAT) released the Discussion Draft for the Implementation Measures for Special Tax 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… – Continue reading
Shadow Assistant Treasurer Andrew Leigh will tell parliament on Monday that his party plans to support the coalition’s multinational tax avoidance crackdown. The federal government has welcomed support from the opposition for its planned crackdown on multinational tax dodgers. Extending the olive branch, the federal government is also prepared to… – Continue reading
The Base Erosion and Profit Shifting (BEPS) project, a joint initiative between G20 countries and the OECD, works towards the development of a coherent global taxation system which addresses BEPS concerns. The main purpose of such initiative is to address the gaps in the current international tax rules relating to… – Continue reading
Legislative Activity House Lawmakers Schedule Markup of Transportation Bill Without Revenue Provisions Last week, on Friday, October 16, the House Transportation and Infrastructure Committee released a six-year, $325 billion highway funding bill (the Surface Transportation Reauthorization and Reform Act of 2015); a markup of the legislation is scheduled for Thursday,… – Continue reading
Introduction On 5 October 2015, the OECD delivered the final package (“Final Package”) of its comprehensive Action Plan on Base Erosion and Profit Shifting (“BEPS“). This marks a culmination of a process that started in September 2013, when the Group of 20 (“G20”) Leaders first endorsed the Action Plan on… – Continue reading
The Irish Government has published an update on its International Tax Strategy, in which Finance Minister Michael Noonan stresses that the country is “well positioned for the post-base erosion and profit shifting (BEPS) world.” According to Noonan, “This is not something that has happened by accident. Difficult but necessary changes… – Continue reading
JAKARTA, Oct 19: As ‘tax-havens’ are now routing some 60 per cent of international trade, multinational corporations (MNCs) have become more aggressive in evading taxes. As the volume of global trade was estimated at $23.5 trillion in 2013, of which $18.5 trillion was trade in goods and the rest was… – Continue reading
A little over a week ago the British parliamentarian, Sir Eric Pickles – a cabinet member until May of this year and a former Chairman of the Conservative Party – told the London Guardian that the British Prime Minister, David Cameron, was determined to have the BVI and the Cayman… – Continue reading
UK Labour party leader Jeremy Corbyn’s adviser wants Irish corporate taxes hiked Ireland is viewed as a “pariah state” by the international community due its corporate taxation policies, according to the man behind many of Jeremy Corbyn’s economic ideas. Economist Richard Murphy also said that Ireland should bring its corporate… – Continue reading
The French Finance Minister, in an October 2015 press release, welcomed the agreement reached by the EU Finance Ministers on the introduction of provisions for the automatic exchange of information on cross-border tax rulings and the publication of the OECD reports on base erosion and profit shifting (BEPS). The French… – Continue reading
We are entering a new world of tax revenue wars, and no one can say who will emerge as the victor. All we know is that there will be tension over the next five years as governments seek to implement the global plan to end to tax havens from Luxembourg… – Continue reading
Finance professionals will play a key role in dealing with changes brought about by a global project to combat corporate tax avoidance. A GLOBAL effort to tackle the problem of companies that attempt to reduce their tax burden by exploiting loopholes in tax rules will impact the way global businesses… – Continue reading
The Dutch government presented its Tax Bill 2016 on 15 September 2016. Three elements of this bill could specifically affect multinationals, international investors and investment funds with Dutch headquarters or group companies: The anti-avoidance rules in respect of non-resident taxation of foreign corporate shareholders and the dividend withholding tax treatment… – Continue reading
As Noonan moves to stimulate domestic growth we need to think about the global debate The Irish economy is now in better shape than at any time since the beginning of the financial crisis. After many years of tough austerity measures, last year’s budget marked a turning point where Minister… – Continue reading
David Gauke, the Financial Secretary to the UK Treasury, has said that international agreement on the OECD’s base erosion and profit shifting (BEPS) reports “is just the start of the process of reform.” In a speech to EY’s 34th Annual International Tax Conference, Gauke said: “To ensure timely, effective implementation,… – Continue reading
Last week’s OECD release of the final package of measures for a coordinated international approach to the reform of the international tax system, under the OECD/G20 base erosion and profit shifting (BEPS) project, marks the end of the discussion and recommendation phase, and the start of the implementation and practical… – Continue reading
Central Board of Direct Taxes (CBDT) chairperson Anita Kapur today said that the new black money law, which is intended to be harsh, will help clear the menace that had not been able to address the problem for many years. Kapur, who inaugurated the 12th International Tax Conference organized by… – Continue reading
The Organization of Economic Cooperation and Development (OECD) released its final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) Project on Monday October 5th, 2015. The final package of BEPS measures includes new minimum standards on: country-by-country reporting, which for the first time will give tax administrations a… – Continue reading
The National Assembly member (NAM) for Foni Bintang Karanai constituency has said that during the recent annual general meeting (AGM) of African Parliamentarian Network on Illicit Financial Flows and Tax (APNIFFT) held in Entebbe, Uganda, African parliamentarians present had applauded the Public Accounts Committee and Public Enterprises Committee (PAC/PEC) of… – Continue reading
MUMBAI: Several multinationals, including Indian companies with a global presence, have initiated impact assessments to identify and fix potential problems in their tax reporting when countries start implementing a new international standards to check tax avoidance by multinationals. The Organisation for Economic Co-operation and Development (OECD) last week released the… – Continue reading
In 2014, seven major tech groups in Spain Declared collective profits of € 48.2 million, on Which They paid € 18.3 million in taxes. These online giants Real Their reduced corporate profits-through complex legal structures and accounting techniques That allowed them to shift part of the profits from Spain to… – Continue reading
Companies around the world are scrambling to overhaul how they communicate with the public when it comes to how much tax they pay, according to professional services firm KPMG. While the Senate is currently investigating multinational firms such as Apple and Google over potential tax avoidance, other countries are also… – Continue reading
The OECD has finally released its long-expected set of reports regarding its Base Erosion and Profit Shifting (BEPS) project. Reducing the number of action points from 15 to 13, the OECD presented recommendations and common responses to align international tax rules and tackle base erosion and profit shifting. All recommendations… – Continue reading
Israeli importers and exporters, hi-tech and trading groups will all be in the base erosion and profit shifting firing line. On October 5 the Organization for Economic Cooperation and Development published a final comprehensive package of measures aimed at multinational corporations, large and small, that engage in BEPS – base… – Continue reading
With the adoption of the BEPS package, OECD and G20 countries, as well as all developing countries that have participated in its development, will lay the foundations of a modern international tax framework under which profits are taxed where economic activity and value creation occurs. Focus will now shift to… – Continue reading
The Minister for Finance has announced that the Knowledge Development Box will be provided for in the Finance Bill. The measure was first signaled in Budget 2015. He said qualifying income would be subject to a reduced rate of corporation tax of 6.25%, half the regular corporate tax rate of… – Continue reading
The tax world followed with great interest today´s launch of the final package of BEPS. Having the BEPS report finalized is indeed a great achievement and, as pointed out by Mr. Angel Gurría, OECD Secretary General, in his Twitter, “Agreement of #BEPS package is a historic day in our effort… – Continue reading
PwC welcomes this effort to update international tax system and boost transparency. The tax landscape has been transformed by the globalisation of business and the advent of the digital age. We believe the existing international tax rules need to be modernised to reflect how business is done today, and it… – Continue reading
What has happened? On 5 October 2015, the OECD issued its final report on BEPS Action 4 – Limiting Base Erosion Involving Interest Deductions and Other Financial Payments (Paper). In this Alert we consider the main issues, recommendations and options for taxation reform raised in the Paper and consider the… – Continue reading
China has pledged to promote a plan to stop multinational companies from avoiding taxes by shifting profits to destinations with lower corporate tax requirements. The plan was endorsed by G20 finance ministers Friday during the annual meetings of the World Bank and the International Monetary Fund in Lima, Peru, reports… – Continue reading
Developing countries must continue raising more in domestic taxes while taking advantage of wider efforts to combat tax evasion by multinationals, the IMF/World Bank annual meetings were told. Liz Ditchburn, director of policy at the UK’s Department for International Development, said initiatives such as BEPS (base erosion and profit shifting),… – Continue reading
The Norwegian conservative government on 7 October 2015 published both the proposed state budget for 2016 and a “white paper” containing proposals for tax reform. The proposed tax reform in the white paper is a follow-up action from a report on tax reform, presented by the Tax Commission in late… – Continue reading
