Four of the most significant transnational organizations are working together to eliminate transfer pricing schemes and abuses. The four organizations—the International Monetary Fund, the Organization for Economic Co-operation and Development, the United Nations and the World Bank Group—are seeking to achieve global cooperation in tax matters. Transfer pricing is one… – Continue reading
Only a few days left for this financial year to end and tax filing deadline is striking the calendar. Indian Government has already taken many initiatives to simplify the tax filing process by introducing new ITR forms, online filing facility etc. Yet many taxpayers tend to make silly mistakes while… – Continue reading
Kuwait became the 110th jurisdiction to sign the Multilateral Convention on Mutual Administrative Assistance in Tax Matters on May 5, 2017. The OECD describes the Convention as the most powerful instrument for international tax cooperation. It provides for all forms of administrative assistance in tax matters: exchange of information on… – Continue reading
NEW DELHI: A complex web of 393 shell companies used for allegedly diverting funds unscrupulously to the tune of Rs 2900 crore has been unearthed by the CBI during its probe into such cases over the last three years. CBI sources said the shell companies were allegedly being used by… – Continue reading
It has been more than a year since the Australian government committed itself to remedying the nation’s double taxation scheme for cryptocurrencies. The delay in crafting a fix has left some observers wondering whether the issue had been set aside entirely. In a statement released this week, the government has… – Continue reading
NEW DELHI: India’s apex body for direct taxes has proposed new rules for bringing the value of unquoted shares on a par with the fair market value of underlying assets, seeking to prevent tax avoidance by firms that use the historical acquisition cost to set the price of unlisted stock…. – Continue reading
NEW DELHI: The Pension Fund Regulatory and Development Authority has clarified that NPS accounts of investors who have not submitted the Foreign Account Tax Compliance Act (FATCA) self certification will not be blocked. The clarification, sent to the registered email addresses of NPS investors on Thursday, comes as a relief… – Continue reading
HM Revenue and Customs has updated the International Tax Compliance Regulations to include provisions on new automatic tax information exchange agreements and to clarify how non-compliance penalties will apply. The amendment clarifies due diligence and reporting requirements for financial institutions, to ensure the UK complies with international tax reporting standards,… – Continue reading
KARACHI: The Federal Board of Revenue (FBR) has initiated audit of all those taxpayers who have made offshore transactions during the last six years, sources said on Tuesday. “All corporate and individual taxpayers, who have made offshore investments, have been selected for audit to check the tax concealment,” an official… – Continue reading
Governments are expanding their use of tax incentives to maintain their country’s international appeal to businesses, alongside the adoption of anti-base erosion and profit shifting measures, according to a survey from EY. EY’s survey of tax policy professionals in 50 countries found that, “While the long-term trend for countries to… – Continue reading
Germany will introduce “license barrier rules” as of January 2018. The new rules will limit the tax deductibility of license fees or royalty payments to foreign related parties that benefit from preferential regimes (“Patent Box”, “IP-Box”, “License Box”) which are incompatible with the “OECD nexus approach” (“unqualified preferential regimes”) (sec…. – Continue reading
The total loss to EU member states from the schemes revealed in the Panama Papers could be in the region of between EUR109bn (USD119bn) to EUR237bn, according to a new study commissioned by the European Parliament’s PANA committee. The Committee of Inquiry into Money Laundering, Tax Avoidance, and Tax Evasion… – Continue reading
In a world of data breaches and political unrest, the concept of confidentiality faces a certain death, warned British Virgin Islands lawyer Tim Prudhoe on Tuesday. Rather than fear the future, the Kobre & Kim partner advised offshore tax jurisdictions to embrace transparency and find benefit in a turbulent world…. – Continue reading
Starting on April 27, and finishing on May 2, the European Parliament (EP)’s Committee of Inquiry into Money Laundering, Tax Avoidance and Tax Evasion (PANA) is holding two meetings to present several related studies which address the impact of, and the fight against, tax evasion and money laundering, particularly in… – Continue reading
A newly published federal draft law introduces Russia to a three-tiered approach to transfer pricing documentation and brings Russian regulations in this area in line with the OECD minimum standards under Action 13 of the Base Erosion and Profit Shifting (BEPS) Action Plan. The draft law, published by the Ministry… – Continue reading
New transfer pricing regulations issued by the State Administration of Taxation (SAT), the Measures for Administration of Special Tax Investigation Adjustment and Mutual Agreement Procedures (“the Measures”), came into effect on May 1, 2017. The Measures consolidate China’s pre-existing regulations regarding self-adjustment and outbound payments with the new transfer pricing… – Continue reading
(Second of two parts) In last week’s article, we discussed the revised procedure to avail of tax treaty benefits for dividend, interest, and royalty payments under Revenue Memorandum Order (RMO) No. 8-2017. Under the amended rules, a tax treaty relief application (TTRA) is no longer required and withholding agents can… – Continue reading
The European Court of Justice (ECJ) has ruled in favor of Austria in its dispute with Germany relating to the taxation of interest from profit-participation certificates received by an Austrian bank from a German bank. The case involved the interpretation and application of Article 11 of the 2000 double tax… – Continue reading
It often occurs that a multinational company employs a foreign manager based on an employment contract or secondment. In the first case, the Hungarian company is considered as the legal and economic employer, therefore the salary is payed directly by it. In the second case, the employee maintains the employment… – Continue reading
President Trump has signed three executive orders to spark reviews of tax and financial regulations so taxes on businesses and individuals can be cut. The approach would be different from Trump’s earlier plan, which was criticized as an approach that would mostly benefit higher earners. Michael Zezas, a strategist at… – Continue reading
East Africa tax experts have raised concerns over increasing cases of tax evasion and fraud by some tax payers in the region which is crippling the economies. They made the remarks on Wednesday during the 6th East Africa regional meeting on tax investigation and enforcement in the Rwandan Capital Kigali…. – Continue reading
Witnesses call for repeal of Foreign Account Tax Compliance Act An agreement that has resulted in hundreds of thousands of Canadian banking records being sent to the U.S. Internal Revenue Service could violate the U.S. constitution, a congressional subcommittee heard Wednesday. Testifying before a subcommittee of the House Committee on… – Continue reading
The Federal Inland Revenue Service (FIRS) and the Economic and Financial Crimes Commission (EFCC) are putting a new breath to the fight against tax fraud and evasion in Nigeria, as the two agencies will soon launch an anti-tax fraud and evasion team. This collaboration, according to the FIRS Executive Chairman,… – Continue reading
Deloitte survey highlights tax predictability as key to driving investment growth in Asia Pacific New Zealand well placed against backdrop of increased uncertainty in Asia Pacific’s tax landscape New Zealand’s tax policies are seen as relatively straight forward, consistent and predictable compared to other countries in the region, according to… – Continue reading
Many of the data submissions made by early adopters over the next two months under the new common reporting standard (CRS) are likely to be rejected and returned for correction and resubmission, adding to compliance costs, according to predictions from Sovos, a global tax compliance solution provider The UK is… – Continue reading
The overwhelming majority of people in G-20 countries believe that cooperation between governments on tax policy is more important than competition to increase national tax revenue. According to a survey by the Association of Chartered Certified Accountants, the preference for cooperation over competition is strongest in Argentina, Australia, Brazil, France,… – Continue reading
The Australian Tax Office had a superb win against Chevron in the Federal Court last week, but there is something everyone is missing, something that will turn the art of tax avoidance on its head; a game-changer for multinationals. Put simply, Chevron borrowed US$2.5 billion in the US at less… – Continue reading
In early April 2017, an important taxation agreement between Monaco and Italy came into force… As a direct result, Monaco now appears on the Italian ‘White List’ of tax compliant jurisdictions. The Agreement creates both opportunities and challenges for companies or individuals that fall within its scope, and is an… – Continue reading
Indian tax authorities have initiated a $4.75 billion penalty charge against Cairn Energy for failing to pay a capital gains tax demand of $1.58 billion on a 2006 transaction. Under Section 271(1)(c) of the Income Tax Act, Indian tax authorities can levy a maximum 200 percent penalty against transactions after… – Continue reading
Overview of the Tax As expected, the Government of Ontario has introduced a new non-resident speculation tax (“NRST”) that takes effect on April 21, 2017. The NRST is a 15% tax payable on the purchase of an interest in residential property located in the “Greater Golden Horseshoe” area (which includes… – Continue reading
Tax residency certificate is required from the resident country tax authorities to claim applicable relief under the DTAA What is the purpose of a tax residency certificate? —Srivats Typically, source of income lies where the services are performed, or where the asset, from which the income arises, is located. Residential… – Continue reading
LUSAKA – Zambia and Malawi have resolved to harmonise trade barriers that affect trade between the two neighbours through the signing of the Double Taxation Avoidance Agreement (DTAA). The DTAA, also referred to as a Tax Treaty, is a bilateral economic agreement between the two nations that aims to avoid… – Continue reading
The Indian Ministry of Finance on April 11 warned that where Foreign Account Tax Compliance Act-related self-certification and due diligence in relation to financial accounts have not taken place by April 30, 2017, affected accounts may be frozen until such time as these checks have taken place. Under the Inter-Governmental… – Continue reading
The United Nations Committee of Experts on International Cooperation in Tax Matters has released, in digital format, the second edition of the UN Practical Manual on Transfer Pricing for Developing Countries. The 2017 edition of the TP Manual was launched at the UN Economic and Social Council Special Meeting on… – Continue reading
The Canada Revenue Agency (CRA) will dedicate resources to ensuring that the real estate sector in the Greater Toronto Area (GTA) complies with the tax laws. The commitment of CRA resources was one of the outcomes of a meeting between the federal and Ontarian finance ministers and the Toronto Mayor… – Continue reading
At the end of March 2017, the Ministry of Finance called for public discussion on a draft bill (the “Bill”) amending the Bulgarian Tax and Social Insurance Procedural Code (the “Code”). The Bill seeks to improve administrative cooperation in the Bulgarian tax sector. The first set of amendments relates to… – Continue reading
Filing of your income tax return (ITR) is mandatory under the Income Tax Act, 1961 under certain circumstances. For instance, if someone’s income exceeds the maximum amount not chargeable to tax, one is required to file income tax return. Similarly, filing ITR is mandatory for ordinary residents having overseas assets… – Continue reading
(Second of two parts) In last week’s article, we discussed how or why taxpayers working on international assignments have to consider the impact of different tax jurisdictions on their individual tax obligations. We also explained how most companies implement a tax equalization (TEQ) arrangement for the employees so that they… – Continue reading
Approximately 300 participants, representing over 100 delegations from countries, jurisdictions, and international organizations gathered in Paris for the fourth meeting of the OECD Global Forum on VAT on April 12-14, 2017. The keynote address was delivered by Wang Jun, China’s Minister of Taxation, who discussed the implementation of value-added tax… – Continue reading
MANILA, Philippines – Instead, the government should pursue the enactment of the proposed Comprehensive Tax Reform Program (CTRP) before pursuing a tax amnesty program, Citi economist Jun Trinidad said. He said fiscal priority remains the passage of the first component of the tax reform measure that includes income tax cut… – Continue reading
MANILA, Philippines – Investment bank Credit Suisse said an effective tax amnesty program would face hurdles in the Philippines due to the country’s strict banking secrecy law. In its Asian daily report titled “Philippines: Credible threat still lacking,” Credit Suisse economist Michael Wan said the planned program announced by Finance… – Continue reading
The German Ministry of Finance has published a progress report on its 10-point plan to combat tax evasion, which was first announced in the wake of last year’s Panama Papers leak. The plan, launched on April 12, 2016, outlines the measures that Germany wants to put in place at domestic… – Continue reading
A parliamentary commission will consider the introduction of a new legal obligation for tax advisers to disclose information about advice on tax mitigation to the Swedish Tax Agency, Skatteverket. Under the proposed rules, tax attorneys would be required to provide details of which clients have received advice on tax reduction… – Continue reading
Banks are urged to stop lending to zombie companies and shell companies in CBRC guidelines highlighting 10 types of specific risk China’s banking regulator has urged commercial lenders to be more vigilant when dishing out loans after a spate of heavily indebted companies found themselves in hot water in the… – Continue reading
Government today said Financial Institutions must obtain self-certification of account holders by April 30, 2017 in order to maintain their accounts active. The financial institutions need to obtain self-certification and carry out due diligence in respect of all individual and entity accounts opened from July 1, 2014 to August 31,… – Continue reading
With a total of 15 action points, the OECD’s Base Erosion and Profit Shifting (BEPS) project aims at fighting the artificial shift of profits from jurisdictions with high taxes to tax havens, often as a part of an entirely legal strategy used by MNEs. The BEPS Action 13 (Transfer Pricing… – Continue reading
As a rule and according to Article 33 of the Cyprus Income Tax Law, which introduces the arm’s length principle (using wording similar to that of article 9 of the OECD Model Tax Convention), all transactions between companies, including loan agreements/transactions by Cyprus companies, must be undertaken at arm’s length… – Continue reading
Muscat: One of the many changes that the Royal Decree 9 of 2017 (RD) has made in the Oman Income tax law is the introduction of withholding tax (WHT) on payment of ‘dividends on shares’ by Omani companies. This amendment requires Omani companies distributing dividends on shares to foreign persons… – Continue reading
The Revenue Department on Friday said it has detected evasion of more than Rs 1.37 lakh crore in both direct and indirect taxes and identified over 1,000 shell companies which indulged in bogus transactions worth Rs 13,300 crore in the last three financial years. Warning tax evaders, it said the… – Continue reading
A new bill introduced this week by Rep. Mark Pocan (D-WI), the Tax Fairness and Transparency Act, would rip out the offshore corporate tax avoidance system by its roots. This legislation combines into a single, comprehensive bill elements of three pieces of legislation that Rep. Pocan has proposed in previous… – Continue reading
