Category: Activity

Cooked in cheap oil? ‘Tax-free’ Gulf states to introduce VAT to revitalise economy

Gulf states are planning to introduce value-added tax starting next year following the hit faced by the energy-rice countries due to a drop in oil prices. Gulf states are planning to introduce value-added tax starting next year following the hit faced by the energy-rich countries due to a drop in… – Continue reading

Guyanese businessmen warned of global crackdown on offshore tax evasion

Commissioner-General of the Guyana Revenue Authority (GRA), Godfrey Statia warned Guyanese businessmen against offshore tax evasion, saying that global systems are being increasingly networked to weed out tax cheats and report them to their home-countries. Addressing a luncheon organised by the Guyana Manufacturing and Services Association (GMSA) at the Georgetown… – Continue reading

Tax expert says amendment to new tax law likely before implementation next year

Removal of withholding tax on G-Sec income effectively frees foreign investors paying any taxes New tax law proposes to remove 10% withholding tax on G-Secs but makes such income liable for income tax up to 24% This likely to result in sizeable leakage of tax revenue to govt. as G-Secs… – Continue reading

Business Europe Rejects EU Digital Turnover Tax Proposal

Markus J Beyrer, Director General of Business Europe, has expressed concerns about the proposed introduction of a European Union turnover tax on digital businesses. On September 21, the European Commission launched a new agenda to ensure that the digital economy is taxed “in a fair and growth-friendly way.” This could… – Continue reading

IRS cracking down on abuses of microcaptive insurance

Forming a small insurance company known as a microcaptive can be a great way for small businesses to reduce insurance costs and realize tax savings. Abusive microcaptive arrangements, however, have attracted scrutiny from Congress and the IRS. Last month, the Tax Court decided an important microcaptive case, holding against the… – Continue reading

BEPS Actions 8-10 Most Important For Latin American, Caribbean States

The Inter-American Center of Tax Administration (CIAT) has released a new statement summarizing the feedback from Latin American and Caribbean countries from ongoing discussions on countering base erosion and profit shifting. CIAT said it and a number of regional and international organizations have brought together policymakers from countries in the… – Continue reading

Foreigners in Sri Lanka Treasury bonds may not have to pay tax

ECONOMYNEXT – Foreign investors in Sri Lanka’s rupee bonds may not have to pay taxes after April 2018, Deputy Central Bank Governor Nandalal Weerasinghe said, amid some uncertainty in markets how a new Inland Revenue law will be interpreted. Sri Lanka lifted a 10 percent withholding tax government bonds from… – Continue reading

Daily Tax Update – September 25, 2017: IRS Issues FATCA Taxpayer Identification Number Guidance

IRS Issues FATCA Taxpayer Identification Number Guidance: Today, the IRS issued Notice 2017-46, which modifies the requirements for financial institutions to collect taxpayer identification numbers (TINs) as part of the Foreign Account Tax Compliance Act (FATCA). The notice provides that foreign financial institutions (FFIs) required to report TINs for US… – Continue reading

Taxmen set their sights on digital economy

KUALA LUMPUR: The taxmen of the Inland Revenue Board (IRB) and Royal Malaysian Customs Department have set their sights on the digital economy. Treasury secretary-general Tan Sri Dr Mohd Irwan Serigar Abdullah pointed out last week that some foreign-owned digital economy players like Google, Uber and Facebook are currently not… – Continue reading

Income Tax Jitters in The Bahamas Following IMF Recommendation

NASSAU, The Bahamas, Friday September 22, 2017 – An International Monetary Fund (IMF) proposal for The Bahamas to implement a low rate income tax has drawn a mixture of skepticism, approval and downright rejection. Following its Article IV consultation with the Hubert Minnis administration, the Washington-based financial body urged the… – Continue reading

US set to lose $12bn in tax take by 2027 if multinationals relocate overseas

Tax inversions by US multinationals attempting to shift profits into lower tax jurisdictions could cost the US up to $12bn (£7.4bn) in lost corporate tax revenues by 2027, according to figures released by the US Congressional Budget Office There were 11 major corporate inversions from 2014-2015, although two significant inversions… – Continue reading

BHP willing to head to court against ATO tax bill

BHP is willing to head to court to fight the Australian Taxation Office on a more than $1 billion tax bill over its Singapore marketing hub. The world’s largest miner has continually defended its Singapore marketing hub, where it is accused of routing profits, and says it is confident of… – Continue reading

Public Country-by-Country Reporting; Taxpayers’ Rights

Appropriate Use of Country-by-Country Reports The OECD has now published Guidance (available here) on the appropriate use of Country-by-Country Reports (‘CbCRs’) by national tax authorities. This is in response to some valid MNE concerns that tax authorities may misuse CbCRs. “Appropriate use” is clarified as being for (i) high-level transfer… – Continue reading

Ghana-Morocco double tax agreement to come into force in 2018 – (Part 2)

In our last publication, we discussed the signing of the Ghana-Morocco Double Tax Agreement (“DTA”) and the provisions of the DTA in relation to the taxation of permanent establishments and business income. In the concluding part of the article, we will discuss the taxation of investment, employment and service incomes… – Continue reading

Turkish gov’t to form special team to surveil, audit e-commerce

In order to tackle irregularities and unfair competition among e-commerce companies, Ankara is planning to form a special unit to track e-commerce activities and transactions in the country The Turkish government is planning to create a special unit of 200 people to track e-commerce activities in the country, Finance Minister… – Continue reading

Multinationals Fear Japan Reports Could Spur Outside Audits

Japanese multinational companies worry that filing their first country-by-country reports in 2018 will lead to a barrage of transfer pricing audits by developing countries. Companies are currently preparing their first country-by-country reports that must be filed with the National Tax Agency by the end of March 2018. Japan adopted country-by-country… – Continue reading

OECD Criticizes Estonia’s Dividend Tax Measure

The OECD has taken issue with the Estonian Government’s plans to reduce the rate of tax on distributed dividends for established companies, warning that the measure could complicate the tax system and discriminate against small firms. Under recently enacted legislation, tax on distributed dividends will be reduced from 20 percent… – Continue reading

Review of Ireland’s Corporation Tax Regime

Ireland’s Minister for Finance (the “Minister”) welcomed the results of the independent review of Ireland’s corporation tax regime (the “Review”) issued on 12 September 2017: “I welcome the emphasis given in the Review to the importance of certainty, which is core to our corporate tax offering. Our 12.5% corporation tax… – Continue reading

Republicans launch worldwide campaign in bid for territorial taxation

Letters calling for the elimination of FATCA, among other tax issues, will be presented to the White House in about two weeks’ time. A global political organisation with affiliation to the Republican Party has recently launched a petition and letter writing campaign in protest of “citizenship-based” taxation – partly in… – Continue reading

Vodafone Ghana sues GRA over GH¢160m transfer pricing assessment

…as tax dispute escalates Vodafone Ghana has filed a motion at the High Court of Justice, Commercial Division in Accra, against the Ghana Revenue Authority (GRA) disputing tax assessments of GH¢160 million, according to the Writ obtained by ghanabusinessnews.com. The GRA has asked Vodafone to pay 30 per cent of… – Continue reading

Interpreting double tax treaties in light of the BEPS multilateral instrument

Some double tax treaties are being amended by a multilateral instrument Establishing how a particular treaty is affected can be a complicated process The UK intends to publish amended DTTs and this will help, but the MLI has added an additional layer of complexity 18 Sep 2017 Speed Read LEGAL… – Continue reading

Rope Tightens Around Global Tax Avoidance

Changes in international tax laws spurred by the OECD’s BEPS project pose challenges for finance chiefs, but also offer some opportunities. The OECD’s base erosion and profit shifting (BEPS) project, with an overall goal of reducing global loss of tax revenues due to double non-taxation, has created the need for… – Continue reading

The Finnish Supreme Administrative Court confirms that the business model chosen by parties must be respected in transfer pricing context

The Finnish Supreme Administrative Court published on 13 September 2017 precedent 2017:145 that further clarifies the scope of application of the Finnish transfer pricing adjustment provision (Act on Assessment Procedure (“AAP”) Section 31). In its previous landmark precedent KHO 2014:119 the Supreme Administrative Court stated that the so-called re-characterization of… – Continue reading

Swiss Bankers Urge Care In Information Exchange

The CEO of the Swiss Bankers Association (SBA) has stressed that confidentiality, data security, and data protection requirements must be complied with when the automatic exchange of tax information gets underway. Claude-Alain Margelisch argued that there should also be a “number of security mechanisms in place that protect customers and… – Continue reading

Kazakhstan Signs FATCA Agreement with US

Kazakhstan and the United States have signed a Model 1 FATCA Intergovernmental Agreement (IGA), which will enable the automatic exchange of financial information on each country’s resident taxpayers to support tax enforcement efforts. The agreement was signed in Astana on September 11, 2017. Kazakh Minister of Finance Bakhyt Sultanov emphasized… – Continue reading

Greece raising taxes when other countries slashing them

    Greece is defying the prevalent trend among the world’s industrialized nations for reducing tax rates in order to boost investment and competitiveness, a report published on Wednesday by the Organization for Economic Cooperation and Development (OECD) has shown. According to the report, in contrast to the majority of… – Continue reading

Japan, Russia Agree New Double Tax Pact

The governments of Japan and Russia signed a new convention on the elimination of double taxation on September 7. The convention replaces the 1986 agreement between Japan and the former Soviet Union. It lowers withholding tax rates on cross-border income from trade and investment – in most cases to zero… – Continue reading

New Sri Lanka tax law tightens transfer pricing loopholes

ECONOMYNEXT – Sri Lanka’s new tax law has provisions that more effectively block companies from trying to dodge taxes by using techniques like transfer pricing, an expert said. The Commissioner-General of Inland Revenue (CGIR) has been given the power to re-examine sch transactions if they are seen to have been… – Continue reading

OECD releases guidance to ensure BEPS country-by-country reports are used appropriately.

Canada has implemented the country-by-country reporting requirement for large multinational enterprises (MNEs) contained in the 2015 Final Report on Action 13 of the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan.  Canada’s legislation is found in s. 233.8 of the Income Tax Act (Canada), and is supported by the… – Continue reading

Eurozone’s big four demand measures against tax avoidance

The four biggest economies in the Eurozone – Germany, France, Italy, and Spain — demand an end to the erosion of their tax base by means of incorporation in states that facilitate tax avoidance. According to the Financial Times, Bruno Le Maire, Wolfgang Schaeuble, Pier-Carlo Padoan, and Luis de Guindos,… – Continue reading

Google, Facebook, And Others May Have To Pay More For EU Operations

Operations in the European Union haven’t been easy going for tech companies for quite a long time. While many European countries earlier called for strict privacy regulations and large fines on tech companies for violating them, they have now called for increased taxation for these companies for their operations in… – Continue reading

Estonian Presidency to present the boldest plan to date against tax avoidance

The EU 28 financial ministers are set to discuss taxation of multinational digital platforms in Tallin on September 15-16, Reuters reports. Companies such as Amazon and Google have designed tax plans that reduce their tax liability in countries they operate. The proposal put forward by the Estonian Presidency proposes to… – Continue reading

Panama: Panama Tax Treaties

The Panamanian Government with the aim of improving the competitiveness of the international services industry in Panama and, at the same time, comply with international standards for the effective exchange of information, initiated in 2009 a decisive agenda for the selection of countries with whom tax agreements were going to… – Continue reading

Analysis: Romania seeks tighter control of multinationals’ financial data

The government is looking to implement EU Directives on tax avoidance, and is set to receive more financial information from multinational groups active in Romania. Tax experts suggest that large corporations might reassess their business models in order to meet the demands of the fiscal authorities in Romania and across… – Continue reading

Malawi Releases 2018 Budget

Malawi’s recent budget included numerous tax changes and announced updates to the country’s transfer pricing rules. On the indirect tax front, the Budget, released in mid-August, introduced a 10 percent excise tax on television subscriptions and introduced a value added-tax exemption for dairy products, animal or vegetable fats and oils,… – Continue reading

Gov’t to tackle multinational firms’ tax evasion

The government said Wednesday that it will toughen its stance against tax evasion by multinational firms by adopting a global agreement in the country’s legal system within the year. In the mid-to-long term tax policy plan announced Wednesday, the finance ministry said that it would submit bills to enact “OECD… – Continue reading

SARS to crack down on multinational companies and subsidiaries’ tax returns

MEDIUM and large businesses with multinational ties will soon have to start supplying the South African Revenue Service (SARS) with more detailed reports of their relationships and transactions with connected entities residing in other countries. SARS has beefed up its Transfer Pricing Division and is now actively involved in the… – Continue reading

Anti-tax avoidance measures under fire from employers, tax advisors

The caretaker government may make the Netherlands a less attractive location for international business because of changes to the corporate tax system, the employers’ organisation VNO-NCW and tax advisers have warned, the Financieele Dagblad said on Monday. The employers and Dutch Order of Tax Advisors say the government is choosing… – Continue reading