The Hong Kong Inland Revenue Department (IRD) on 19 July published Departmental Interpretation and Practice Notes (DIPNs) Nos. 58, 59, and 60, and an updated version of DIPN No. 28. ... - Continue reading
Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on AML and sanctions is one of general continuity. ... - Continue reading
Article 7 – Prevention of Treaty Abuse – of the Multilateral Instrument (the MLI) contains three opt-in provisions. ... - Continue reading
Guernsey Finance Chief Executive Dominic Wheatley reflects on the findings of the latest OECD tax report to world leaders. ... - Continue reading
The US Treasury has announced on its website that the US-Dominican Republic Model 1 FATCA intergovernmental agreement (IGA) entered into force as of July 17, 2019. ... - Continue reading
The OECD has issued another update on jurisdictions' progress to amend their preferential tax regimes to remove harmful elements under the OECD base erosion and profit shifting Action Plan minimum standard on harmful tax regimes (Action 5). ... - Continue reading
The Department of Finance (DOF) has expressed the hope that President Duterte’s call in his State-of-the-Nation Address (SONA) for Congress to pass reforms in the corporate tax system along with the remaining packages of the administration’s comprehensive tax reform program (CTRP) will provide lawmakers a strong impetus to pass these… – Continue reading
The legislation encompassing the new regime for taxing non-residents' gains on the United Kingdom (UK) commercial real estate came into effect on 6th April 2019. Her Majesty's Revenue and Customs (HMRC) has additionally published draft guidance on this recently introduced regime. This article briefly summarizes the new rules. ... - Continue reading
An OECD-led 131-country coalition, known as the “Inclusive Framework on BEPS,” has approved an assessment which concludes that 12 low or zero-tax countries do not have “harmful” tax regimes, the OECD today announced. ... - Continue reading
A Danish tax administration decree, published 12 July in response to the Supreme Court’s decision in the Microsoft case, establishes a new practice for determining whether transfer pricing documentation must be available at the time the taxpayer is required to file its tax return. ... - Continue reading
Intangibles are key sources of differentiation for businesses and typically, they help drive revenue, manage cost or both. As a result, many businesses make significant investments in developing, enhancing, maintaining and protecting unique and valuable intangibles to help drive their businesses. ... - Continue reading
On July 2, 2019, the Dutch government published the legislative proposal implementing the EU Anti-Tax Avoidance Directive II (ATAD II) that was adopted on May 29, 2017. The ATAD II mandates EU Member States to implement rules that target hybrid mismatches by January 1, 2020 (specific sections by January 1, 2022). ... - Continue reading
On July 12 the Netherlands government published a legislative proposal implementing the EU mandatory disclosure directive. This follows an internet consultation on a draft legislative proposal which ran from December 19, 2018 — February 1, 2019. ... - Continue reading
On July 12 the Netherlands government published a legislative proposal implementing the EU mandatory disclosure directive. This follows an internet consultation on a draft legislative proposal which ran from December 19, 2018 — February 1, 2019. ... - Continue reading
The Japanese government on July 1 published the synthesized text of the Japan-United Arab Emirates 2013 tax treaty, taking into account changes made by the bilateral tax treaty on account of both countries’ later ratification of the the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). ... - Continue reading
The Directorate General of GST Intelligence (DGGSTI), an arm of the indirect tax administration, has unearthed a racket involving 90 firms which issue fake invoices to errant companies for tax evasion, the agency said on Friday. ... - Continue reading
G7 finance ministers, at their meeting in Chantilly, France on July 17–18, agreed to several aspects of a revised system for taxing multinationals. ... - Continue reading
Turkey comes up with another effort to fight profit shifting ... - Continue reading
The OECD on July 5 requested taxpayer feedback on the tax treaty dispute resolution process in Andorra, Anguilla, Bahamas, Bermuda, British Virgin Islands, Cayman Islands, Faroe Islands, Macau (China), Morocco,and Tunisia. ... - Continue reading
The new budget proposal to tax buybacks and dividends at the same rate of effectively 20% may curtail the flow of distribution—that companies undertake from time to time to give investors a share in their profits—to the shareholders. ... - Continue reading
Draft legislation and explanatory notes to the UK Finance Bill 2019-20 were published on 11 July. Much of the legislation was anticipated with some further clarifications provided. ... - Continue reading
The Inter-American Center of Tax Administrations (CIAT), on July 15, released comprehensive and detailed proposals aimed at preventing abusive transfer pricing in low-income countries and in countries on the path to development. ... - Continue reading
Hot topics for discussion at the conference included taxation of the digital economy, approaches for "hard to value intangibles", the adoption of technology within the tax department, and lessons learned from country-by-country reporting. ... - Continue reading
The Inland Revenue Board of Malaysia has released new guidance on restrictions to the deductibility of interest expenses. ... - Continue reading
On July 3, 2019, the Seychelles Government announced that it has signed an intergovernmental agreement (IGA) with the United States to implement the requirements of the US Foreign Account Tax Compliance Act (FATCA). ... - Continue reading
The French Parliament definitively adopted, on July 11 the digital services (DST) after a vote of the Senate. ... - Continue reading
Liquidators of Cayman Islands entities that are reporting financial institutions under Common Reporting Standard (CRS) and Foreign Accounts Tax Compliance Act (FATCA) regulations are required to comply with CRS and FATCA reporting obligations up to the year of dissolution. ... - Continue reading
The Government of Gibraltar has said it is delighted to welcome Robert Jenrick, Exchequer Secretary to Her Majesty’s Treasury, to Gibraltar to announce that HMGoG and Her Majesty’s Government have opened negotiations to enter into a Double Tax Agreement. It is anticipated that with hard work on both sides a… – Continue reading
State-run Philippine Amusement and Gaming Corp. expressed optimism the government will not impose higher taxes on offshore gaming operators in the country to encourage them to stay here. Pagcor chairman and chief executive Andrea Domingo said at the sidelines of the opening of the first Philippine-Asian Gaming Expo held on… – Continue reading
The Bank of Portugal (BdP) is to publicly disclose aggregated information about large bank debtors by 17 July, announced the chair of the Budget and Finance Committee. On 23 May, the central bank sent parliament an extraordinary report on the problematic loans and other assets that caused banking problems and… – Continue reading
TRANSFER pricing — the pricing of commodities traded between or within multinational enterprises — is a legal practice and a key feature of cross-border and intra-firm transactions. The United Nations prefers to use the broader phrase ‘trade pricing’ in addressing this practice and defines it as a ‘normal incident of… – Continue reading
The Dutch government on May 29 announced its priorities and timelines in the area tax policy, including how the Netherlands intends to deal with tax evasion and tax avoidance and improve the Dutch investment climate. ... - Continue reading
In the past three fiscals, Indian firms bought back shares at an average rate of ₹47,800 crore ... - Continue reading
Tax authority of Australia takes measures on tax issues ... - Continue reading
"Substance" - the new rule of the tax world ... - Continue reading
6 July 2019: In the lead up to the Group of 20 (G20) Finance Ministers and Central Bank Governors’ Meeting, the Organisation for Economic Co-operation and Development (OECD) released data that show that automatic exchange of information on financial accounts is improving tax compliance and delivering concrete results for governments… – Continue reading
UAE has published Cabinet Resolution 32, the introduction of new country by country reporting ("CbC reporting") obligations that multinationals will be required to comply with starting 2020. ... - Continue reading
Gibraltar joins the list of jurisdictions to sign the framework on BEPS ... - Continue reading
New tax legislation for India's 2019 Budget ... - Continue reading
New laws regarding hybrid mismatches ... - Continue reading
Bill C-82, An Act to implement a multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting, has received royal assent. ... - Continue reading
Duff & Phelps' Transfer Pricing Alliance Partner, TP EQuilibrium AustralAsia, contributed their insights, expertise and perspectives on this new development. ... - Continue reading
On April 25, 2019, the OECD released the 2017 full version of the Model Tax Convention on Income and on Capital ("MTC"). ... - Continue reading
Researchers and campaigners from around the world have been presenting radical solutions on tackling tax abuse and financial crime at the Tax Justice Network’s annual conference held in the heart of London’s finance centre, on 2 – 3 July 2019. With over 200 attendees including prominent politicians, whistleblowers and economists,… – Continue reading
This legislation will force owners of US companies to reveal their identities. ... - Continue reading
The Inland Revenue Authority of Singapore has announced that amendments made to Singapore’s bilateral tax treaties with the Netherlands and Georgia took effect today. ... - Continue reading
The US today announced it is negotiating a competent authority agreement with Monaco that would provide for the exchange of country-by-country reports concerning multinationals operating in their countries. ... - Continue reading
