The OECD has published additional guidance on the implementation of the country-by-country (CbC) reporting requirement proposed under Action 13 of its base erosion and profit shifting (BEPS) project. The guidance, issued on November 30, addresses the following issues: how to report amounts taken from financial statements prepared using fair value… – Continue reading
Bermuda and the UK recently signed an agreement providing for the automatic exchange of country-by-country reports. Bermuda is the first UK Overseas Territory to sign a CbC Competent Authority Agreement with the UK, which enables the automatic reporting of corporate income on a country-by-country basis for UK-related transfer pricing enforcement… – Continue reading
Barbados says it expects to sign the new OECD BEPS Multilateral Instrument at the end of January 2018 to introduce changes to its tax treaty network to prevent base erosion and profit shifting. The “Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS)”… – Continue reading
The Canada Revenue Agency’s recently announced “postal code project” targets Canada’s richest neighbourhoods, to identify non-compliance apparent from discrepancies between residents’ tax reporting with their apparent wealth. Even prior to the postal code project, which focuses on any potential high net worth individual, the CRA had enhanced audit activity on… – Continue reading
Island tax expert Greg Jones has issued a warning saying he believes the UK taxman has ‘bulked up’ and is starting to ‘flex his muscles.’ Mr Jones, a director of KPMG at its offices in Athol Street, Douglas, has analysed the UK Budget in this special report for Business News:… – Continue reading
(Washington, D.C., Wednesday, November 29, 2017) – Senator Rand Paul is prepared to offer his FATCA repeal legislation, S. 869, as an amendment to the Senate’s tax reform bill. The Center for Freedom and Prosperity applauds this news and urges full-fledged support from his colleagues. The Foreign Account Tax Compliance… – Continue reading
Hong Kong recently finalized a series of agreements that, taken together, shift Asia’s trade and investment landscape. On November 12, Hong Kong and ASEAN signed the ASEAN-Hong Kong, China Free Trade Agreement (AHKFTA), and the ASEAN-Hong Kong Investment Agreement (AHKIA). Prior to this, on November 10, Hong Kong and India… – Continue reading
NEW DELHI The Indian Income Tax Department will accept applications for Mutual Agreement Procedure (MAP) in transfer pricing disputes, as well as for bilateral Advance Pricing Agreements (APAs), even for entities resident in countries with which India has double taxation avoidance agreements (DTAA), minus the provision to claim corresponding tax… – Continue reading
The Australian Taxation Office (ATO) has extended until February 15, 2018, the deadline for “significant global entities” to file their country-by-country (CbC) reports. The extension applies to entities that are December and January balancers filing for the first time. The extension also applies to the filing of local and master… – Continue reading
On November 22, the UK Government published for stakeholders’ comments a position paper setting out its views on the challenges posed by the digital economy for the corporate tax system and its preferred solutions. The paper, which was published alongside the 2017 Autumn Budget, states that “the Government believes in… – Continue reading
In this Update On June 7, 2017, Canada signed the OECD’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) The MLI will modify up to 75 of Canada’s bilateral tax treaties, including adding a broad anti-avoidance rule to these treaties (the… – Continue reading
On November 21, 2017, the OECD Council approved the contents of the 2017 Update to the OECD Model Tax Convention. The 2017 Update primarily comprises changes to the OECD Model Tax Convention and related commentary that were developed through the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project including changes… – Continue reading
PARIS (AFP) – Tax optimisation is no longer a matter just for the multinationals. A number of market players are now tailoring strategies originally drawn up for the corporate whales to the minnows, or small businesses and independent entrepreneurs. Whether the businesses are active in imports and exports, or in… – Continue reading
Africa is estimated to have lost over $1 trillion in illicit financial flows (IFFs) within the past 50 years, with drainage of over $50 billion annually. These outflows, according to the African Union and Economic Commission for Africa (AU/ECA) High Level Panel on Illicit Financial Flows (IFFs), refer to “money… – Continue reading
Summary: The Chancellor unexpectedly announced a U-turn to tax gains made by non-residents on UK commercial property with effect from April 2019. This will have a significant impact on overseas investors into UK real estate and creates additional uncertainty during an already volatile time as Brexit negotiations continue. Overseas investors… – Continue reading
Greece ranked first out of 35 OECD countries in tax hikes last year, according to a report by the Organization for Economic Cooperation and Development, and the budget for 2018 will lead to an even greater tax burden that will stifle growth, the Parliament’s Budget Office (PBO) warned on Thsurday…. – Continue reading
KUWAIT CITY, Nov 20: Bankers around the world disclosed there is an international trend to globalize the Foreign Account Tax Compliance Act (FATCA) on foreign accounts of the Americans under the name Global Account Tax Compliance Act (GATCA), so most countries in the world, including Kuwait, can apply it on… – Continue reading
Europe’s fierce enforcer of competition rules is threatening tech giants with tough new rules on tax if politicians fail to come to an agreement on changes to the current system. Efforts to amend rules that would apply tax more fairly to firms which largely operate online such as Google, Amazon,… – Continue reading
The Davis Tax Committee (the Committee) released a further report on “Tax Administration” on 13 November 2017 as part of the final six reports that were deliverable by the Committee. The report has five chapters covering: Governance of the South African Revenue Service Base Erosion and Profit Shifting (BEPS) Treatment… – Continue reading
The Italian government has introduced a “temporary web tax” which will be in force until the long-awaited OECD/EU strategy for the reshaping of traditional taxation systems based on the residence of companies (or on the location of permanent establishments) has been defined. Said reshaping is aimed at introducing taxation principles… – Continue reading
ISLAMABAD/LONDON: The thirty-eight-page trust deed of Pakistan Tehreek-e-Insaaf (PTI) leader Jahangir Khan Tareen’s offshore trust was signed and formalised in Geneva, Switzerland, and facilitated by HSBC Guyerzeller Trust Company Geneva – raising questions about Swiss bank accounts. During the hearing before Pakistan’s Supreme Court, Tareen was asked no questions about… – Continue reading
In the aftermath of Satoshi Nakamoto’s groundbreaking paper in 2009, money began travelling via a new financial route – virtual currencies. The first Bitcoin exchange was established on February 6, 2010 where Bitcoin traded for the first time for 0.3 cents. Last June, the American Institute of Certified Public Accountants… – Continue reading
The Ministry of Economy and Finance (MEF) recently decided to shrink the tax burden for local microfinance institutions (MFIs) by lowering withholding tax on interest from loans acquired from abroad from 14 to 10 percent, a move that the government claims will keep the massive sector sustainable. This is the… – Continue reading
Plan proposes 12.5% tax rate on intellectual-property income Bills ‘upend decades of U.S. tax policy’ on tight deadline U.S. companies that make billions of dollars from patents and other intellectual property held offshore would be eligible for a special 12.5 percent tax rate on those earnings under the Senate tax… – Continue reading
Qatar has become the 115th jurisdiction to sign the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. The Convention is touted by the OECD as “the most powerful instrument for international tax cooperation.” It provides for all forms of administrative assistance in tax matters: exchange of information on request,… – Continue reading
Bulgaria has said that multinationals covered by the country’s new transfer pricing country-by-country reporting regime should submit their first report by December 31, 2017. Through Order 3LIY-1410, Bulgaria’s National Revenue Agency has newly set out the rules concerning country-by-country documentation, including who the reporting obligations apply to and how to… – Continue reading
Under President Trump’s political and economic climate, stocks and the economy have been soaring. Trump constantly aims for three percent GDP growth as a result of cutting corporate income and individual income taxes, which aims to encourage spending across different family incomes. However, these corporations the tax cuts favor have… – Continue reading
The Senate Finance Committee released its tax reform plan on November 9, presenting a draft bill with marked differences to that agreed by the House Ways and Means Committee on the same day. The proposal was drafted by Finance Committee Republicans under the leadership of Senate Finance Committee Chairman Orrin… – Continue reading
“Reportage about hacked data from global law firm Appleby has highlighted the substantial lack of media understanding of offshore investment structures and Bermuda’s long-time reputation for tax transparency and cooperation with international authorities,” the Bermuda Business Development Agency said. “Bermuda is committed to the exchange of relevant information to legitimate… – Continue reading
Luxury yachts built in Dutch shipyards are being sold to suspect buyers around the world through tax havens, Trouw and the Financieele Dagblad reported on Friday. The dubious yacht transactions were revealed through an investigation being carried out into the Paradise Papers by the two Dutch newspapers . The documents… – Continue reading
Universities are always looking for new ways to increase returns on their endowments. The hunt for lucrative investments has reportedly led several institutions offshore. College endowments are typically exempt from federal taxes. However, when income is earned on an endowment outside of the core educational mission, it can be subject… – Continue reading
The European Union Common Consolidated Corporate Tax Base (CCCTB) has been talked about recently as a solution to the problem of an imperfect pan-EU corporate tax system, which allows large companies, particularly those with a digital presence, to detach profits from value-creation, and pay tax in low-tax jurisdictions. But what… – Continue reading
Ghana is considering promulgating laws to criminalize the abuse of transfer pricing in its petroleum sector, the Acting Chief Executive Officer of the Petroleum Commission, Mr. Egbert Faible, has disclosed. According to Mr. Faible, the abuse of transfer pricing in the country’s budding petroleum sector was worrying and there was… – Continue reading
The Department of Budget and Management (DBM) raised the possibility of granting a general tax amnesty to lure individuals and corporations with outstanding liabilities to settle their obligations without fear of being slapped with criminal charges. Following the tax settlement of cigarette-firm Mighty Corp. with the government, Budget Secretary Benjamin… – Continue reading
The International Monetary Fund (IMF) has commended the Philippines for legal changes that brought the nation’s casinos within the scope of the country’s Anti-Money Laundering Act. “[The IMF] welcomes the recent amendment… to include casinos” under the act, the IMF executive board said in a press release issued on Monday,… – Continue reading
Ghana has won international recognition for its commitment to expanding the frontiers of transparency, including progress made towards lifting the veil off the actual beneficial owners of companies operating in the country. The recognition came in the form of an award from the Extractive Industries Transparency Initiative (EITI) International Board… – Continue reading
The International Consortium of Investigative Journalists (ICIJ) has released a database of around 13.4 million documents revealing over 25,000 companies owned by the world’s rich and influential individuals. The ICIJ coordinated the Panama Papers investigation into offshore companies. The latest files have disclosed the financial details of politicians, corporations, and… – Continue reading
On October 2 the US Government released the Tax Cuts and Jobs Act, setting out in legislation its plans for comprehensive reform of the US tax code. For businesses, the bill will bring about a landmark shift to a territorial corporate tax system, replacing the current worldwide tax basis regime… – Continue reading
The Deputy Prime Minister yesterday revealed the Bahamas “may have to look at” implementing a low-rate corporate income tax, as global regulatory pressures force “hard decisions” upon it. K P Turnquest, while emphasising that such a move was a long way off, agreed that compliance with the OECD’s Base Erosion… – Continue reading
The Cayman Islands’ Premier, Alden McLaughlin, recently delivered the territory’s first two-year budget, which was notable for the absence of new borrowing or revenue-raising measures. McLaughlin said his administration will continue to pay down debt and deliver operational budget surpluses to fund capital investment plans and provide for contingency against… – Continue reading
The Treasury says the Isle of Man has become one of the first countries to sign a new international treaty against tax avoidance. The Island joins Austria in agreeing to the OECD’s Multilateral Convention to Implement Tax Treasury Related Measures to Prevent Base Erosion and Profit Shifting. The agreement aims… – Continue reading
CBDT issues final rules for Master File and Country-by-Country reporting NEW DELHI, NOV 1: The Central Board of Direct Taxes (CBDT) has notified the final rules for maintaining and furnishing of transfer pricing documentation in the Master File and Country-by-Country (CbyC) report. This is largely in line with the draft… – Continue reading
The Chartered Institute of Taxation, the UK tax professionals representative body, has urged lawmakers globally to pause for thought on the direction being taken on the taxation of the digital economy. It is urging that any measures to improve the tax rules covering the digital economy must be developed and… – Continue reading
Lawmakers warn against preferential treatment for foreign invested companies, half of which declared losses from 2007-2015. Vietnam offers many land and tax incentives to attract foreign direct investment (FDI), but the sector’s contribution to the economy is still limited, said delegates of the legislative National Assembly (NA). Despite accounting for… – Continue reading
Introduction The Organisation for Economic Co-operation and Development (OECD) is an economic organisation made up of 35 member countries, with the aim of encouraging economic progress and world trade. In 2015, the OECD developed the Base Erosion and Profit Shifting (BEPS) Project, made up of reports on 15 action plans,… – Continue reading
The OECD’s Anti Base Erosion and Profit Shifting Initiative (BEPS) significantly affects current transfer pricing regimes regarding intangibles, documentation and dispute resolution. Why is Transfer Pricing relevant for BEPS? To avoid base erosion and profit shifting of multinational companies, the OECD initiated an action plan consisting of 15 actions with… – Continue reading
In its latest report for the country, the International Monetary Fund has recommended that Croatia modernize its property tax system to enable the country to lower the burden of taxes that weigh more heavily on economic growth. It said a “modern, well-designed real estate tax that is based on objective… – Continue reading
LABUAN: Bank Negara Malaysia (BNM) Governor Tan Sri Muhammad Ibrahim says the time has come for a review of Labuan’s current tax framework. He said the review is not only to ensure alignment with international best practices but also confirm the continued relevance of such incentives in catalysing new growth… – Continue reading
T&T faces possible sanctions after the Global Forum recognised this country as the only jurisdiction not considered to have made sufficient progress towards satisfactory implementation of the agreed tax transparency standards. Speaking at a media conference on Friday afternoon, Attorney General Faris Al Rawi said this has negative implications for… – Continue reading
HYDERABAD: Income Tax sleuths on Wednesday conducted simultaneous searches in Hyderabad and Vijayawada on three top businessmen cum-realtors, who were allegedly evading tax, particularly in real estate transactions and unearthed documents pertaining to unaccounted investments running into hundreds of crores of rupees. These are the first big raids after shell… – Continue reading
