Category: Base Erosion & Profit Shifting

Singapore Legislates For IP Tax Concession Reform

Singapore has gazetted a law to repeal the income tax concession for intellectual property income derived by companies benefiting from the Pioneer Service Companies Incentive (PC-S) or the Development and Expansion Incentive (DEI) schemes. The removal of this tax concession was first announced in Singapore’s 2017 Budget at the same… – Continue reading

Malta Ratifies BEPS Convention

Malta has become the latest country to ratify the OECD’s multilateral convention to counter base erosion and profit shifting (BEPS). A notice was published in Legal Notice 142 of 2018 in the territory’s Official Gazette. The Convention, negotiated by more than 100 countries and jurisdictions under a mandate from G20… – Continue reading

Dpm Pledges ‘Most Stringent Controls’ On Ownership Registry

THE Deputy Prime Minister yesterday promised that the proposed Beneficial Ownership registry will have “the most stringent controls”, amid industry concerns over the lack of prior consultation. K P Turnquest told Tribune Business that it was “not an unreasonable guess” to suggest that the Bahamas would follow the Cayman Islands’… – Continue reading

Corporate Taxation Dumped In Eu Bill

The Government has stripped corporate taxation from its anti-blacklisting response, as a top attorney yesterday warned: “Time is not our friend.” Michael Paton, who co-heads the financial sector working group dealing with the European Union (EU) concerns, told Tribune Business it will be “a long summer” as the Bahamas seeks… – Continue reading

UK Revisits Proposed BEPS Changes To Its Double Tax Treaties

The UK tax agency, HM Revenue and Customs, on April 16, 2018, released proposed changes to the list of amendments it intends to make to its bilateral double tax avoidance agreements through the OECD’s base erosion and profit shifting multilateral instrument. The new document – Proposed changes to the provisional… – Continue reading

OECD Releases More Transfer Pricing Country Guides

The OECD has published new transfer pricing country profiles for Australia, China, Estonia, France, Georgia, Hungary, India, Israel, Liechtenstein, Norway, Poland, Portugal, Sweden, and Uruguay, bringing the number of such overviews published by the OECD to 44. The profiles explain the current transfer pricing legislation and practices of each country…. – Continue reading

CBDT releases Draft Notification to Amend Income Tax Rules, 1962 [Read Draft Notification]

The Central Board of Direct Taxes ( CBDT ) yesterday released a draft notification which proposes to amend Rule 44E, Form 34C, 34D and 34DA of Income Tax Rules, 1962 as per Base Erosion and Profit Shifting (BEPS) Action Item 5. The proposal has been made with a view to… – Continue reading

Corporate Tax Promise Not ‘Concrete’ For Eu

THE Bahamas will be unable to satisfy the European Union’s (EU) demands by merely promising to implement corporate taxation, a prominent attorney has warned. Michael Paton, who co-heads the financial services industry working group assessing the Government’s ‘blacklisting’ response, told Tribune Business in a recent interview that time and the… – Continue reading

Seychelles Needs To Redouble BEPS Efforts: UN Expert

The Seychelles has been told to deploy more resources to implement recommendations from the OECD on base erosion and profit shifting. Ingela Willfors, a United Nations tax expert from the Swedish Ministry of Finance, held discussions on implementation with the Seychelles’ Minister of Finance, Trade, and Economic Planning and in… – Continue reading

VAT compliance driving digital capabilities in the GCC

Muscat: Tax authorities in the Gulf Cooperation Council (GCC) are starting to use sophisticated digital platforms that require taxpayers to submit data in real time or near-real time prompting companies in the GCC to enhance their digital capabilities. This is changing the way businesses collect, format and report tax information,… – Continue reading

India Adds BEPS Provisions To Qatar Tax Treaty

India has approved amendments to its double tax agreement with Qatar. The amendments update the information exchange provisions between the two countries in line with current international standards. A new Limitation on Benefits (LOB) provision has been introduced, which is designed to prevent “treaty shopping” (whereby companies or transactions are… – Continue reading

Argentina Extends CbC BEPS Reporting Deadline

Argentina’s Federal Administration of Public Income has extended the filing deadline for country-by-country (CbC) notifications. Taxpayers who are part of multinational enterprises now have until May 2, 2018, to file CbC notifications where the ultimate parent company of the multinational group has a December 2017 fiscal year end. The CbC… – Continue reading

TAX TALK: BEPS & ATAD RESHAPING INT’L TAX LANDSCAPE

Speakers corner: Delano asked Raymond Krawczykowski, partner and tax leader at Deloitte Luxembourg, “In your view, what have been the key changes in EU & Luxembourg tax rules in 2017, and what major shifts could be in store for 2018-19?” His response was clear: Beps and Atad. The Base Erosion… – Continue reading

Ibcs Face ‘Much Damage’ Through Blacklisting Bill

THE Bahamas’ ‘blacklisting’ response threatens to “cause a lot of damage” to its IBC business and create “much less certainty” for the financial services industry, a top attorney is warning. Michael Paton, a former Bahamas Financial Services Board (BFSB) chairman, told Tribune Business that the proposed Multinational Entities Reporting Bill… – Continue reading

BEPS Multilateral Instrument To Enter Into Force

The OECD has announced that its multilateral convention to implement tax treaty-related measures to counter base erosion and profit shifting will enter into force on July 1, 2018. The Convention, negotiated by more than 100 countries and jurisdictions under a mandate from G20 Finance Ministers and Central Bank Governors, will… – Continue reading

Corporate Taxation On The Way For Bahamas

The Government’s planned legal reforms pave the way for the introduction of “corporate taxation” on a wide range of Bahamian financial services products, it was revealed yesterday. Carl Bethel QC, the Attorney General, confirmed to Tribune Business that legislation intended to address the European Union’s (EU) ‘blacklisting’ concerns was designed… – Continue reading

Cyprus, UK sign updated double taxation treaty

Cyprus and the UK on Thursday signed an updated agreement on double taxation avoidance on income and capital, which will contribute to further develop commercial and financial relations between the two countries. The agreement, signed in Nicosia by Finance Minister Harris Georgiades and British High Commissioner Matthew Kidd, is based… – Continue reading

Ambassador To Eu Proposal In Wake Of Blacklisting

IN THE aftermath of The Bahamas’ blacklisting by the European Union for being a tax haven, Financial Services Minister Brent Symonette says it might be time for The Bahamas to consider appointing an ambassador to the EU to increase dialogue on matters concerning this country. The St Anne’s MP said… – Continue reading

Indian Master File, First CbC Report Due March 31

The deadline for multinationals to submit a master file and CbC report in India is March 31, 2018, in respect of the 2016-17 financial year. A “master file” must be furnished by multinationals if the total consolidated group revenue exceeds INR5bn and either the aggregate value of international transactions as… – Continue reading

Bahamas ‘Failed To Read Tea Leaves’ On Corporate Tax

THE Bahamas’ failure “to read the tea leaves” and introduce a corporate income tax “for ourselves” has contributed to Europe’s planned ‘blacklisting’, a financial executive argued yesterday. Paul Moss, Dominion Management Services’ president, told Tribune Business that implementing such a tax would mean the European Union (EU) “cannot accuse us… – Continue reading

Last-Ditch Bid To Halt Eu Blacklist

The Deputy Prime Minister and minister of financial services were yesterday travelling to Europe in a last-ditch bid to plead the Bahamas’ case against being ‘backlisted’. Carl Bethel QC, the Attorney General, confirmed to Tribune Business that both K P Turnquest and Brent Symonette are leading a government delegation that… – Continue reading

Egypt To Receive Tax Information Exchange Support

Egypt is to receive international support to implement new measures in the area of tax transparency and information exchange. Unveiled at a meeting on international tax reform in Cairo on March 7, the OECD and Egypt agreed a new project entitled “Enhancing Domestic Resource Mobilization in Egypt through a better… – Continue reading

Mauritius Finalizes CbC Reporting Regulations

Mauritius last month released the Income Tax (Country-by-Country Reporting) Regulations 2018, setting out the jurisdiction’s rules concerning the filing by multinational groups of transfer pricing documentation. The CbC report is one element of a new three-tiered standardized approach to transfer pricing documentation proposed under BEPS Action 13. Under the framework,… – Continue reading

India-Iran DTAA – A Step Forward in India’s Economic Engagement with Central Asia

India and Iran signed a Double Taxation Avoidance Agreement (DTAA) in February, during Iranian President Hassan Rouhani’s official visit to India. The ‘Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income’ aims to encourage the movement of investments and services… – Continue reading

Hong Kong Launches CbC Reporting Portal

Hong Kong’s Inland Revenue Department on March 5 launched its new Country-by-Country Reporting Portal. Groups can now register to file CbC reports for accounting periods beginning between January 1, 2016, and December 31, 2017, using the online portal. The CbC report is one element of a new three-tiered standardized approach… – Continue reading

Gov’t agrees to meet international tax standards

THE GOVERNMENT recently held bilateral talks with the Code of Conduct Group (COCG) to discuss tax transparency and fair taxation in the territory. A press release from the Office of the Premier issued on Tuesday (February 27), said Premier Sharlene Cartwright Robinson and other TCI representatives met with the COCG… – Continue reading

Dutch Cabinet Approves Anti-Evasion Measures

The Government of the Netherlands has announced a comprehensive package of tax anti-avoidance proposals designed to bring the jurisdiction’s rules into line with new European Union anti-avoidance laws and fulfill its obligations under the international BEPS agenda. The plans were detailed in a parliamentary paper sent by State Secretary for… – Continue reading

Barbados Agrees To Phase Out Harmful Tax Regimes

Two Barbados preferential tax regimes have been labelled “potentially harmful” in additional guidance released by the OECD in connection with its base erosion and profit shifting (BEPS) project. The guidance singles out Barbados’s international financial services regime and its credit for foreign currency earnings/credit for overseas projects or services regime…. – Continue reading

Vizor Software Launches CbC Reporting Solution for Tax Authorities

Tax Authorities in jurisdictions who have joined the OECD/G20’s Base Erosion and Profit Shifting (BEPS) inclusive framework can now avail of Vizor’s new Country-by-Country (CbC) Reporting module to fully meet their obligations set out under Action 13. DUBLIN (PRWEB) FEBRUARY 11, 2018 Today, Vizor Software announced the launch of its… – Continue reading

Bermuda Lists CbC Report Exchange Partners

The Bermuda Government on January 31, 2018, updated the lists of the countries with which it will exchange country-by-country reports filed in Bermuda in 2018 and in 2019. The Government has disclosed that it expects to exchange CbC reports with a total of 41 territories in 2018 relating to financial… – Continue reading

Costa Rica Gazettes Country-By-Country Reporting Rules

On February 2, 2018, Costa Rica published Resolution no. DGT-R-001-2018 in its Official Gazette, setting out the rules for filing a country-by-country report. The parent company of a multinational group resident in Costa Rica with consolidated group revenue of the equivalent of EUR750m in the Costa Rican currency – presently… – Continue reading

Spain Publishes 2018 Tax Compliance Plan

The Spanish tax authority has published its annual tax and customs control plan for 2018, which details the tax compliance and enforcement measures that it intends to undertake in the coming year. The plan, published by the tax authority on January 23, features four key pillars: preventative measures, including a… – Continue reading

Digital firms with ‘big presence’ in India will have to pay taxes here

Finance Ministry’s move under BEPS treaty will impact Google, Facebook, Amazon MUMBAI, FEBRUARY 5 Digital players such as Google, Facebook and mobile application services providers must pay taxes in India on income generated from Indian consumers even if the companies’ infrastructure is physically located abroad. According to a new proposal… – Continue reading

Inland Revenue (Amendment) Ordinance 2018 gazetted

Hong Kong (HKSAR) – The Inland Revenue (Amendment) Ordinance 2018 (the Ordinance) was gazetted today (February 2). The technical amendments on automatic exchange of financial account information in tax matters (AEOI) (i.e. clauses 5 to 11) under the Ordinance will come into operation on January 1, 2019, while other provisions… – Continue reading

Barbados, Jamaica Sign New International Tax Treaty

PARIS, France– Ministers and high-level officials from six countries, including two in the Caribbean, have signed the BEPS Multilateral Convention, the first multilateral treaty of its kind. The Convention will enable governments to swiftly update their networks of existing tax treaties and further reduce opportunities for tax avoidance. Barbados, Jamaica,… – Continue reading

Greece Raises BEPS Concerns With Bulgaria

The heads of the Greek and Bulgarian tax authorities have met to discuss ways in which bilateral cooperation can be boosted with a view to reducing levels of tax avoidance and evasion, particularly with respect to Greek companies shifting profits to Bulgaria. “The major issue of tax avoidance by Greek… – Continue reading

Hong Kong BEPS Bill: New Transfer Pricing Regime to Regulate Documentation

On December 29, 2017, the Inland Revenue (Amendment) (No. 6) Bill 2017 (BEPS bill) was gazetted in Hong Kong. The BEPS bill introduces a transfer pricing regulatory regime and mandatory transfer pricing documentation requirement in Hong Kong as well as a variety of other anti-BEPS changes. The BEPS bill marks… – Continue reading

OECD report shows Malta is tax compliant jurisdiction: official

VALLETTA, Jan.11 (Xinhua) — The 2017 International Tax Co-Operation Report published by the Organisation for Economic Cooperation and Development (OECD)showed Malta to be a tax compliant jurisdiction ,the Maltese Finance Ministry said on Thursday. “This is exactly what we have been stating all along in the face of unfair criticism… – Continue reading

US Treasury disputes EU decision to list Guam on tax haven blacklist

The U.S. Treasury Secretary is disputing a decision by the European Union to place Guam, and American Samoa, on its blacklist of noncooperating tax jurisdictions. In a letter to EU Secretary General Jeppe Tranholm-Mikkelsen, U.S. Treasury Secretary Steven Mnuchin wrote that “there is no basis for concluding that American Samoa… – Continue reading

Singapore Urged To Enhance Tax Offering

Ernst and Young Solutions LLP, Singapore, has released its wish list for the Singapore Budget 2018, calling for reforms to sharpen the territory’s competitiveness. The firm said that Singapore should maintain its 17 percent corporate income tax (CIT) rate, which is one of the lowest in the world, but recommended… – Continue reading

Transfer Pricing and BEPS to Increase Tax Revenues in Georgia

The FINANCIAL — Transfer Pricing Rules were implemented by the Government of Georgia in 2011, based on OECD guidelines. Since the number of international companies in Georgia is increasing steadily, Transfer Pricing Rules have become a point of obvious interest. However, multinational companies operating in Georgia are not sufficiently well-informed… – Continue reading

OECD Charts States’ Participation In Int’l Tax Initiatives

For the first time, the OECD has published a map that sets out countries’ participation and compliance with international tax initiatives, looking specifically at the exchange of information in tax matters, with the old international standard – the exchange of information on request – and the new, on the automatic… – Continue reading

New Zealand Tables Legislation To Tackle BEPS Issues

A tax bill to counter base erosion and profit shifting by multinational companies was introduced into Parliament on December 6. The Taxation (Neutralising Base Erosion and Profit Shifting) Bill contains measures to prevent multinationals from using: Artificially high interest rates on loans from related parties to shift profits out of… – Continue reading

New Paper Looks At How To Support Developing States On BEPS

The International Centre for Tax and Development has released a working paper on how to best support developing countries in the area of taxation. The paper says that developing countries would particularly benefit from support in the implementation of two areas that were covered by the OECD’s base erosion and… – Continue reading