ZURICH (Reuters) – The Swiss government said on Friday it is doing away with a frequently criticised privileged tax status for holding companies based in Switzerland, which will lead to a billion-franc shortfall in annual tax revenue. “While these arrangements made a valuable contribution to the business location’s appeal in… – Continue reading
June 5: The Organisation for Economic Co-operation and Development (OECD) yesterday released a discussion draft concerning work in relation to Action 8 under the base erosion and profit shifting (BEPS) project concerning hard-to-value intangibles. Read the BEPS Action 8 discussion draft [PDF 62 KB] The following discussion provides initial impressions… – Continue reading
The FINANCIAL — Members of the Deloitte network have been named European Tax Innovator of the Year at the recent International Tax Review (ITR) European Tax Awards. Deloitte member firms won 15 ITR tax awards in total this year, more than any other organization, for work completed in the last… – Continue reading
McClay visits European capitals to talk Trade and sign tax agreement Minister of Revenue and Associate Trade Minister, Todd McClay has concluded a European lobbying mission by signing a tax agreement in Paris to focus on tax avoidance by multinationals. Tax Agreement The OECD’s Multilateral Competent Authority Agreement brings New… – Continue reading
The leaders of the Group of Seven nations are contemplating a framework for joint tax audits to enhance co-operation in international tax matters. “We have to make progress not just with regards to the rules but also in everyday tax administration,” German Finance Minister Wolfgang Schäuble told a press conference… – Continue reading
THE South African Revenue Service (SARS ) is to significantly beef up its capacity to deal with base erosion and profit shifting, which has received intense focus by MPs over the last few months. SARS commissioner Tom Moyane said on Wednesday 24 more tax specialists would be employed in the… – Continue reading
The Abbott government didn’t get costings from Treasury on how much revenue its multinational tax avoidance budget measure would bring. The revelation explains why costings were not given by Treasurer Joe Hockey when he announced the measure or included budget papers. Speaking at a Senate estimates hearing on Tuesday, finance… – Continue reading
A powerful business lobby is sounding the warning to lawmakers about a global effort to crack down on offshore tax evasion. The National Association of Manufacturers warned the top congressional tax writers that the so-called Base Erosion and Profit Shifting project “could have a negative impact on the global competitiveness… – Continue reading
London: A UK Treasury minister has dismissed Brussels’ latest move to combat tax avoidance as “an answer still looking for a question”. David Gauke, financial secretary to the Treasury, said the UK remained sceptical about a proposal for a pan-European tax system, which was relaunched by the European Commission last… – Continue reading
On May 20, 2015, the U.S. Treasury Department released for public comment draft updates to the U.S. model income tax convention and its accompanying Technical Explanation (collectively, the “Model Treaty”), which was last updated in 2006. The Model Treaty is the template that Treasury uses as its starting point in… – Continue reading
Since the beginning of the global financial crisis, politicians, the media and people on the street have engaged in a series of “blame games” to point fingers and punish those responsible for their own economic ills. For the past few years, one “culprit” has been firmly in the spotlight –… – Continue reading
Argentina and Chile have signed a new double tax treaty to replace the treaty unilaterally terminated by Argentina in 2012. Ignacio Rodriguez and Andres Edelstein of PwC in Argentina outline the new structuring opportunities that are available for taxpayers. Argentina and Chile signed a new double tax treaty on May… – Continue reading
The European Commission is to propose a mandatory common corporate tax base next month as part of a wide-ranging clampdown on corporate tax avoidance. Put simply, a common tax base seeks to harmonise the way companies calculate taxable profits across Europe. For many years in Europe there has been talk… – Continue reading
A full and fascinating roundtable discussion based around the island’s place as an international finance centre was held at KPMG’s headquarters in Athol Street, Douglas. Around the table were David Karran, managing director, IQE, Simon Scott, managing director, Barclays Isle of Man, Andrew Thomas, chief executive, Isle of Man Enterprises… – Continue reading
A “very interesting political situation” can be expected in the autumn when a number of different strands of the ongoing European, and global, debate on what to do about aggressive tax planning by multinationals, come together, one of the players involved said during a recent visit to Dublin, reports Irish… – Continue reading
Africa is known as the ‘paradox of plenty’. How can a continent so rich in natural resources be so poor? Economic growth is predicted to increase by 4.5% across the continent this year, despite falling oil prices and the Ebola crisis. South Africa’s economy, the second biggest in Africa is… – Continue reading
New Zealand: Budget 2015 The New Zealand Budget was handed down on 21 May 2015 and included a new tax on residential property sold within two years of purchase (with some exceptions). For further information on the New Zealand Budget see PwC New Zealand’s Budget commentary. New Zealand: Issues paper… – Continue reading
Gibraltar’s Chief Minister, Fabian Picardo, has met with the new TAXE committee of the European Parliament and defended the territory’s tax ruling regime. The TAXE Committee was established earlier this year in the wake of the leak of confidential tax rulings provided by EU member states to certain multinationals. The… – Continue reading
The International Monetary Fund has welcomed plans for corporate tax reform in Switzerland and called for its “timely completion.” Switzerland has faced international pressure in recent years to reduce the favorable tax treatment provided to multinational corporations in many cantons, the IMF noted in its 2015 Article IV Consultation report… – Continue reading
Following our article at the end of last year on the potential changes to the UK patent box regime further details have been released on the new regime, timings and additional work to be done. On 6 February 2015, the Organisation for Economic Co-operation and Development (OECD) published a paper… – Continue reading
Muscat: Taxpayers across the globe, including Oman, are facing increased scrutiny of their tax returns and positions taken as the pressure on governments increases to raise revenues from taxes, says an expert at KPMG. Ashok Hariharan, partner and head of tax for KPMG in the Middle East and South Asia… – Continue reading
The Organization for Economic Co-operation and Development (OECD) published its Base Erosion Profit Sharing (BEPS) action plan in July 2013 to address perceived flaws in international tax rules. The Plan was endorsed by G20 with implementation to be completed by the end of 2015. WRIN.tv spoke with John O’Leary, a… – Continue reading
Investments Derived From Structural Reforms The approved structural Reforms are an unprecedented opportunity for a transformational economic growth in Mexico, being the most relevant from an investment point of view the reforms related to Energy, Telecommunications and Antitrust, which have put Mexico in the radar of Multinational companies seeking to… – Continue reading
The FINANCIAL — Tax transparency is becoming the new norm as the OECD, European Commission and national governments demand more data from businesses. However, many companies do not have systems or resources in place to meet new requirements, according to EY’s report, A new mountain to climb: tax reputation risk,… – Continue reading
MANY businesses lack the systems or resources to meet new global tax disclosure and transparency requirements, according to an EY report. The report, which surveyed 962 tax and finance executives in 27 jurisdictions, found more than two thirds of respondents said they would need additional resources in order to gather… – Continue reading
The countries of the Central American region have incorporated and reformed their legislations to the international regulations of Transfer prices and practically all the applicable legal provisions to related parties have already been expanded in the region, which implies, that the companies with regional presence must visualize, review and engage… – Continue reading
E-commerce giant Amazon has begun booking revenue in individual European companies, a move that tax expert Heather Self of Pinsent Masons, the law firm behind Out-Law.com, said is probably influenced by upcoming regulatory changes.26 May 2015 “As of 1 May, Amazon EU Sarl is recording retail sales made to customers… – Continue reading
A delegation from the European Parliament’s Special Tax Rulings Committee visited Switzerland on May 22. The delegation was received by Switzerland’s State Secretary for International Financial Matters, Jacques de Watteville. According to the Swiss Federal Council, talks focused on international corporate tax reform efforts and Switzerland’s work in this area…. – Continue reading
On May 20, 2015, the US Department of the Treasury released for public comment draft updates to the US Model Income Tax Convention, including provisions to deny treaty benefits to companies that change their tax residence via inversion transactions. The Treasury said other changes are intended to ensure that the… – Continue reading
The UK’s introduction of the diverted profits tax (DPT) has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) and in effect as of April 1, the DPT seemed intended to appease public anger at multinationals failing to pay their ”fair… – Continue reading
The Treasury Department announced draft changes for the U.S. Model Income Tax Treaty — the baseline text used by the Treasury Department when it negotiates tax treaties. The current U.S. Model was last updated in 2006. The proposed changes in the draft provisions are intended to combat so-called Base Erosion… – Continue reading
OECD, G20 team up to plug loopholes that allow companies evade taxes in jurisdictions they operate to prevent tax base erosion There is now a serious global attempt to ensure that multinationals pay taxes in the jurisdiction in which they carry out their business. The attempt is being made keeping… – Continue reading
1. Global focus on transfer pricing There has been a recent surge in regulatory attention around the world towards pricing arrangements within multinational corporate groups. Regulators are concerned that these pricing arrangements may be used as a means of profit shifting and therefore tax avoidance. The price at which an… – Continue reading
In 2014, the Organization for Economic Co-operation and Development (“OECD”) began making recommendations to Member States for the implementation of certain actions aimed at limiting base erosion and profit shifting, known as “BEPS”. The project includes 15 actions, representing 15 areas of regulation that allow states to monitor data which… – Continue reading
ALTHOUGH there is no conclusive evidence as to how much money South Africa is losing in terms of transfer pricing, the mining and extractive industries are responsible for R3.4bn of it. Dumisani Jantjies, financial analyst of the parliamentary budget office, singled out the mining industry as one of the biggest… – Continue reading
Cape Town – Arts and Culture Minister Nathi Mthethwa wants artists and performers to get a financial break and will ask the Davis tax committee to give them tax incentives. Mthethwa told journalists in Parliament on Tuesday, during a briefing on his budget vote, that the department would meet the… – Continue reading
The finance ministry will in the near future add Controlled Foreign Corporation (CFC) rules to the Income Tax Act in order to prevent the tax deferral that many Indian multinational companies resort to by not repatriating the profits of their foreign subsidiaries for long periods. The proposed rules will come… – Continue reading
Introduction Tax avoidance, however legitimate its mechanism, has become the new focus for public opprobrium in parts of the world. High-profile cases and media attention examining the tax strategies of major global companies operating primarily in the digital economy have all contributed to this shift of focus. How are the… – Continue reading
Authorities worldwide have increased scrutiny of tax-avoidance strategies in the past year, CFOs and finance directors of multinational clients told global tax consulting firm network Taxand. Sixty per cent of multinationals reported an increase in audits by tax authorities in the past year, and 70% said authorities had increased their… – Continue reading
In 1934, a distinguished American jurist, Judge Learned Hand, famously opined that “one may so arrange his affairs so that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to… – Continue reading
The Organisation for Economic Co-operation and Development (OECD) has published stakeholders’ comments on its discussion draft on base erosion and profit shifting (BEPS) Action 11, on improving analysis of BEPS. Through Action 11, the OECD hopes to develop recommendations to better chart the scale and economic impact of BEPS issues,… – Continue reading
Last night, the Federal Treasurer, Joe Hockey MP, released the 2015-16 Federal Budget. After public self-evaluation of its last budget as over-reaching, the Government has gone back to basics whilst still focussing on repairing the budget deficit in the medium to long term. The budget deficit is projected to be… – Continue reading
Even as the action plan to address Base Erosion and Profit Sharing (BEPS) is being worked out, multinationals are bracing for some turbulent times in India. For some time now, transfer pricing – the price of goods and services determined by a company when two of its subsidiaries transact –… – Continue reading
Current international tax rules are based on principles that have not kept up with globalisation and the rise of the digital economy. Over the years the rules have been patched up but, almost two years ago, the Organisation for Economic Co-operation and Development (OECD), acknowledging that a substantial overhaul was… – Continue reading
The corporate community is increasingly sounding the warning to Congress: Europe is coming after us on taxes. With tax reform talks stumbling in Washington, the fear for corporate titans is that other countries are already implementing a global set of recommendations meant to crack down on offshore tax avoidance. Lobbyists… – Continue reading
If you are moving or trading goods across borders, this topic should be of primary importance from both a Transfer Pricing and Customs perspective. There is potential for you to have Transfer Pricing and Customs exposures in your supply and value chains as a result of the OECD/G20 initiative on… – Continue reading
New rules applicable to payments made by Chinese companies to ‘related’ companies offshore will prevent them from artificially shifting profits to lower tax jurisdictions through “unreasonable” service and royalty payments, the State Administration of Taxation (SAT) has said. Circular 16, which came into force on 18 March, and its accompanying… – Continue reading
Grant Wardell-Johnson, KPMG Tax Partner, has said that while it would have been better for Australia to await the outcome of the OECD’s base erosion and profit shifting Action Plan, the international tax measures proposed recently by Treasurer Joe Hockey “have the benefit of being highly targeted.” On May 11,… – Continue reading
South African companies are unable to compete with multinationals selling goods and services online in the country, partly as a result of tax laws. This is according to financial services group PwC, which argues that the country has not kept pace with the changing global economy. “Currently, multinationals in the… – Continue reading
Deloitte managing tax partner Thomas Pippos says the IRD are using electronic payments and websites to pursue tax cheats Budget-conscious tax collectors are increasingly turning to popular websites and other e-channels to chase undeclared taxable income, a top accountant says. Inland Revenue Department no longer had capacity or interest in… – Continue reading
