Category: Activity

Four things to watch in the Medium-Term Budget

What economists and tax practitioners expect to see. JOHANNESBURG – Finance minister Nhlanhla Nene (pictured) will once again be between a rock and a hard place when he presents his Medium-Term Budget Policy Statement (MTBPS) on Wednesday. With the economy under pressure and concerns about how government will balance its… – Continue reading

Starbucks and Fiat Chrysler’s tax avoidance deals to be ruled illegal

Companies face multimillion-euro repayment bills after EC’s 15-month investigation. Rulings on Amazon and Apple will follow Starbucks and Fiat Chrysler are expected to be billed for tens of millions of euros in additional taxes as the European commission prepares to rule that they had unlawful deals with the Netherlands and… – Continue reading

Brazil: Non-Applying Of Withholding Income Tax Over Foreign Remittances Of Remuneration Of Technical Services Supplied By Non-Residents In Brazil

The Brazilian Federal Revenue – RFB and the General Attorney of the National Treasury – PGFN changed the understanding that they shared in regard to the applying of Withholding Income Tax (IRRF) over foreign remittances of remuneration of technical services supplied by non-residents in Brazil. Before that, the RFB1 and… – Continue reading

Turnbull Government welcomes Labor’s support on laws targeted at MNCs tax evasion

The Turnbull government has welcomed the support of the Labor party for the new laws that will add more teeth to the government’s crackdown on multinational tax dodgers. The government also offered to consider the suggestions of the opposition in improving the scope of the legislation. Labor formally announced its… – Continue reading

HQs wooed with tax incentives

THE CABINET has approved the Finance Ministry’s proposal for more tax incentives to facilitate the creation of International Headquarters and International Trading Centres in Thailand. IHQs and ITCs in the Kingdom currently enjoy both tax and non-tax benefits, including complete income-tax exemption for out-out transactions, while in-out transactions will be… – Continue reading

Tony Wickenden: Net is closing in on offshore tax avoidance

Evading and avoiding tax through the use of offshore structures and arrangements is the source of much tax loss, according to HM Revenue & Customs. No surprise then that the current Government (and the coalition before it) has been relentless in its crackdown on it, with a special focus on… – Continue reading

Foreign portfolio investors seek stable tax policies to set up fund management businesses

NEW DELHI: Foreign portfolio investors have sought stability in taxation policies as the government looks to lure them to set up fund management business in the country. They have made a number of suggestions, Economic Affairs Secretary Shaktikanta Das said after a meeting of the finance ministry with representatives of… – Continue reading

Treasury offers tax deduction to SA firms in Africa

SOUTH African companies with operations elsewhere in Africa, such as telecommunications giant MTN, have reason to breathe a little easier having earned a tax respite, albeit considered minor by tax experts. The Treasury has made a concession on the proposed repeal of foreign tax credits for fees on services provided… – Continue reading

The President signed a law allowing the implementation of FATCA

President Andrzej Duda signed last Friday a bill whose aim is to implement FATCA legislation – said the office of President. The law is designed to prevent US taxpayers hiding income abroad. The Act creates a legal basis that will allow implementation of the provisions under the international agreement ws…. – Continue reading

Korea seeks to adopt ‘Google tax’

South Korea is seeking ways to levy a corporate tax on profits of global technology companies and other multinationals as early as next year in response to growing criticism of their tax avoidance structures. The diverted profits tax is more widely called the “Google tax,” as U.S. tech giants such… – Continue reading

The OECD/G20 base erosion and profit shifting (BEPS) project – an informed perspective

The BEPS Project involves input from the 34 member countries of the OECD, all G20 members, and more than 40 developing countries. The objective of the BEPS Project is to close gaps in international tax rules, effectively eliminating or substantially reducing BEPS; and to secure government revenues by ensuring that… – Continue reading

New tax treaty between the Netherlands and Curaçao enters into force

Executive summary A new bilateral Tax Arrangement between the Netherlands and Curaçao (TANC), which essentially functions as a tax treaty,1 was ratified by the Dutch Parliament and formally published on 9 October 2015. The TANC will apply to income received on or after 1 January 2016. This long-awaited TANC will… – Continue reading

Financial Information Month – FATCA

The local implications for the Foreign Accounts Tax Compliance Act (FATCA) are far reaching. So said First Caribbean International Bank (FCIB) representative Norlan Gabriel, who was a panel member on NBC Radio’s “Views on Issues” programme last Sunday. The latest edition of the radio programme was aimed at disseminating information… – Continue reading

Tax executives set to convene

Business Reporter Tax administrators from all over Africa are set to meet from October 20 to 22 2015 in Lomé, Togo under the auspices of the African Tax Administration Forum (ATAF),the premier tax organisation on the continent,which holds its 2nd International Conference on Tax in Africa (2ICTA). The gathering of… – Continue reading

China: Discussion Draft For The Implementation Measures For Special Tax Adjustments —A Brand-New Epoch For Transfer Pricing Administration In China

On 17 September, 2015, China State Administration of Taxation (SAT) released the Discussion Draft for the Implementation Measures for Special Tax Adjustments (“Discussion Draft”), as a complete revamp to the existing trial version of the Implementation Measures, i.e., Circular 2. Circular 2 has been serving as a backbone transfer pricing… – Continue reading

Australian government welcomes tax support from Labor

Shadow Assistant Treasurer Andrew Leigh will tell parliament on Monday that his party plans to support the coalition’s multinational tax avoidance crackdown. The federal government has welcomed support from the opposition for its planned crackdown on multinational tax dodgers. Extending the olive branch, the federal government is also prepared to… – Continue reading

India Tax in a post-Base Erosion and Profit Shifting world

The Base Erosion and Profit Shifting (BEPS) project, a joint initiative between G20 countries and the OECD, works towards the development of a coherent global taxation system which addresses BEPS concerns. The main purpose of such initiative is to address the gaps in the current international tax rules relating to… – Continue reading

House ways and means tasked with funding highway bill; Treasury moves forward with BEPS implementation

Legislative Activity House Lawmakers Schedule Markup of Transportation Bill Without Revenue Provisions Last week, on Friday, October 16, the House Transportation and Infrastructure Committee released a six-year, $325 billion highway funding bill (the Surface Transportation Reauthorization and Reform Act of 2015); a markup of the legislation is scheduled for Thursday,… – Continue reading

OECD’s Action Plan on base erosion and profit shifting – delivery of final package and its implications

Introduction On 5 October 2015, the OECD delivered the final package (“Final Package”) of its comprehensive Action Plan on Base Erosion and Profit Shifting (“BEPS“). This marks a culmination of a process that started in September 2013, when the Group of 20 (“G20”) Leaders first endorsed the Action Plan on… – Continue reading

Ireland Publishes Updated International Tax Strategy

The Irish Government has published an update on its International Tax Strategy, in which Finance Minister Michael Noonan stresses that the country is “well positioned for the post-base erosion and profit shifting (BEPS) world.” According to Noonan, “This is not something that has happened by accident. Difficult but necessary changes… – Continue reading

‘Tax-havens’ routing 60pc of global trade

JAKARTA, Oct 19: As ‘tax-havens’ are now routing some 60 per cent of international trade, multinational corporations (MNCs) have become more aggressive in evading taxes. As the volume of global trade was estimated at $23.5 trillion in 2013, of which $18.5 trillion was trade in goods and the rest was… – Continue reading

Guernsey: Guernsey Is On Track For The Next Stage In Automatic Exchange Of Information

KEY POINTS What is the issue? Guernsey will be required to gather data for the calendar year 2016 for reporting under the Common Reporting Standard (CRS) in 2017. What does it mean for me? Practitioners should be aware that due diligence and reporting procedures are set to be amended and… – Continue reading

IRS Offshore Account Penalties Go Up, More Banks Sign U.S. Disclosure Deal

The number of banks with deferred prosecution agreements with the U.S. government keeps growing. The subject is tax evasion involving American account holders. Today, under FATCA, banks everywhere want to know if you are compliant with the IRS. And the IRS keeps updating its list of foreign banks where offshore… – Continue reading

Internal Revenue Service Issues Stern Warning To Non-Compliant Taxpayers With Offshore Holdings

Just one day after the October 15 deadline for filing personal income tax returns on extension, the Internal Revenue Service issued a strongly-worded warning to non-compliant taxpayers: take action now to fix your problem, or face serious consequences. At the same time, the IRS revealed, for the first time, that… – Continue reading

EY: Four out of 10 Czech businessmen asked for bribe; Czech police reveal corruption in driving licenses for Germans; No. of Czech firms with owners in tax havens up in Q3

EY: Four out of 10 Czech businessmen asked for bribe Four out of 10 Czech entrepreneurs have been explicitly asked for a bribe and up to six out of 10 have encountered the possibility of gaining an advantage in their business in exchange for a bribe, according to a survey… – Continue reading

Banking Secrecy Law Must Be Revised: Observers

TEMPO.CO, Jakarta – The Perkumpulan Prakarsa (Center for Welfare Studies) executive director Setyo Budiantoro viewed that the government must revise the banking secrecy provisions in the Law on Banking to reduce illicit outflows from Indonesia. According to Budi, Indonesia applies regulations that require citizens to report their wealth in all… – Continue reading

Caribbean likely to suffer collateral damage from tax havens crackdown

A little over a week ago the British parliamentarian, Sir Eric Pickles – a cabinet member until May of this year and a former Chairman of the Conservative Party – told the London Guardian that the British Prime Minister, David Cameron, was determined to have the BVI and the Cayman… – Continue reading

What Singaporeans need to know when buying UK residential property

The rising wealth of Asia Pacific nations, including Singapore, means more and more people have looked internationally for opportunities to invest in overseas property markets. Recent stock market events have shown the importance of a diversified portfolio capable of riding out the storm when economic conditions put immense pressure on… – Continue reading

New tool for the taxman from January 1

Cyprus will as of January 1, 2016 have a new tool in its arsenal to identify monies hidden abroad as the island will begin implementing the Common Reporting Standard (CRS), the Institute of Certified Public Accountants said. The CRS is formally referred to as the Standard for Automatic Exchange of… – Continue reading

Ireland is now a ‘pariah state’ over tax, says Corbyn insider

UK Labour party leader Jeremy Corbyn’s adviser wants Irish corporate taxes hiked Ireland is viewed as a “pariah state” by the international community due its corporate taxation policies, according to the man behind many of Jeremy Corbyn’s economic ideas. Economist Richard Murphy also said that Ireland should bring its corporate… – Continue reading

Mauritius Wants To Be To Africa What Dubai Is To The Middle East

Concerned about the impact of tax havens, world powers are tightening the noose on multinationals seeking tax advantages. India wants changes to its tax treaty with Mauritius, forcing the island’s new government to re-examine its business model and focus elsewhere. There is debate in the new government, which took office… – Continue reading

IRS Offshore Voluntary Disclosure Program Results in $8 Billion in Collections

With more than 54,000 taxpayers coming in to participate in offshore disclosure programs since 2009, the Internal Revenue Service is reminding U.S. taxpayers with undisclosed offshore accounts that they should strongly consider existing paths established to come into full compliance with their federal tax obligations. Both the Offshore Voluntary Disclosure… – Continue reading

FRANCE: COUNTRY-BY-COUNTRY REPORTING; BEPS PROVISIONS

The French Finance Minister, in an October 2015 press release, welcomed the agreement reached by the EU Finance Ministers on the introduction of provisions for the automatic exchange of information on cross-border tax rulings and the publication of the OECD reports on base erosion and profit shifting (BEPS). The French… – Continue reading

EU tax: Brussels set for multinational crackdown

Margrethe Vestager, the EU’s competition commissioner, looks set to launch the international community’s most punitive attack on corporate tax avoidance as early as next Wednesday, with rulings that could impose heavy costs on multinationals, reports the Financial Times. Ms Vestager is understood to have postponed her first trip to China… – Continue reading

Black banks’ targeted in latest anti-graft crackdown

The central government is stepping up its anti-graft drive by cracking down on illegal lending and money-laundering operations in a bid to prevent outbound flows of stolen assets. The Ministry of Public Security says “black banks” and illegal currency exchanges have facilitated the flights of a number of former government… – Continue reading

Karnataka’s e-commerce tax will fall flat in court: Experts

BENGALURU: The Karnataka tax department’s recent proposal to e-commerce firms, considered a face-saver, may not be legally tenable, tax experts said citing High Court and apex court rulings. The Karnataka commercial taxes department, last week, asked e-commerce firms including Amazon, Flipkart and Snapdeal to deduct 1% of the money payable… – Continue reading

Rules on tax-dodging multinationals must be thoroughly implemented

The following editorial appears in Friday’s Yomiuri Shimbun: International cooperation must be bolstered to close tax loopholes that can be exploited by multinational business corporations. The Group of 20 major economies and the Organization for Economic Cooperation and Development have worked out new international taxation rules to clamp down on… – Continue reading

As tax havens disappear, global revenue wars begin

We are entering a new world of tax revenue wars, and no one can say who will emerge as the victor. All we know is that there will be tension over the next five years as governments seek to implement the global plan to end to tax havens from Luxembourg… – Continue reading

MTN bullies SA with jobs threat

South Africa is allowing MTN potentially lucrative tax credits on money sent from its African operations to a letterbox company in Mauritius. Last week, amaBhungane and Finance Uncovered, a global reporting project, exposed how MTN’s African subsidiaries send billions in management fees to MTN International in Mauritius. The Mauritian entity… – Continue reading

Transfer pricing placed in the spotlight

Transfer pricing firms have been called upon to educate foreign tax authorities and the ATO on technical areas, as the topic receives unprecedented attention. Shannon Smit, director of Transfer Pricing Solutions, winner of the 2014 Australian Accounting Awards Boutique Firm of the Year award, spoke of the emphasis placed upon… – Continue reading