Category: Profit Shifting

Australia Adds To Diverted Profits Tax Guidance

The Australian Tax Office on February 7 released draft Practical Compliance Guideline 2018/D2 on the operation of Australia’s Diverted Profits Tax for consultation. In the 2016-17 Budget, the Government announced that it would introduce a diverted profits tax (DPT), intended to ensure that the tax paid by significant global entities… – Continue reading

IRB Casts Dragnet For Tax Dodgers This Year

SUBANG: The Inland Revenue Board (IRB) will this year put in place strong measures to deter tax avoidance and evasion by focusing on individuals and firms engaging in such misconduct. Chief Executive Officer (CEO) Datuk Dr Sabin Samitah said the offences included those who engaged in aggressive tax planning, by… – Continue reading

There Is a Raging Battle of Tax Codes with China and the US Starting the Race

The GOP tax bill that was signed into law by the white house late last year, significantly reduced corporate taxes which has piled pressure on other significant economies around the world to adjust so as not to lose investors to the United States. Just hours after President Trump signed the… – Continue reading

Switzerland agrees to share tax information on multinationals

ZURICH (Reuters) – Switzerland said on Wednesday it would start sharing information on the activities of multinationals in its territory with other countries in 2020, joining an international push to fight tax evasion. The new measures will force about 200 large companies in the low-tax haven to prepare country-by-country reports… – Continue reading

New Dutch Law Leaves Repentant Taxpayers Out in the Cold

The abolition of a scheme allowing Dutch taxpayers to fess up to their tax sins and avoid criminal charges is likely to discourage high-net worth individuals from ever disclosing money hidden abroad to local authorities, practitioners say. Deputy Minister of Finance Eric Wiebes announced that it was time to draw… – Continue reading

HONG KONG, SINGAPORE AND CHINA GET TOUGH ON TAX HAVENS

In an effort to create a ‘level playing field’, Asian economies are committing to new standards of transparency At the risk of losing some foreign investors, Asian jurisdictions are stepping up efforts to combat corporate tax avoidance to meet new global transparency standards. More than a dozen Asia-Pacific jurisdictions have… – Continue reading

EU lawmakers pass new rules to tackle multinationals’ tax avoidance

The European Parliament on Tuesday passed a directive requiring big multinationals to report tax and financial data separately in all countries where they operate, a measure aimed at tackling tax avoidance and profit shifting to countries with lower taxes. The new rules are part of a wider overhaul of tax… – Continue reading

Nigeria ratifies treaties to curb tax evasion by multinationals

Nigeria has ratified multilateral conventions on tax related treaties to end profit shifting and tax evasion by multinational companies. The ratification of the treaties Wednesday followed the approval of a memo submitted by the Minister of Finance, Kemi Adeosun, who said this was part of government’s plan to widen its… – Continue reading

Malta Pushes to Ease EU Cross-Border Interest, Withholding Tax

European Union presidency holder Malta has launched a new attempt to salvage pending EU legislation designed to eliminate withholding taxes for cross-border interest and royalty payments in the EU single market. One of the key hurdles the Interest and Royalties Directive has faced in the Council of Economic and Financial… – Continue reading

OECD’s BEPS 13 implemented in Croatia

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

Cyprus: Abolition Of Profit Margins On Intra Group Loans – Upcoming Transfer Pricing Legislation – Transfer Pricing Studies Requirement

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

New Chinese tax rule to take aim at multinationals’ profit shifting

Move shows that Beijing is joining the global move against diversion of profits to low-tax jurisdictions Beijing on Saturday posted a new rule on scenarios that could trigger tax-avoidance investigations of multinationals, under¬lining its commitment to a global move to combat profit shifting. The new rule, posted on the website… – Continue reading

Chile Leads Region to Test Companies’ International Tax Links

Chile is leading a regional push across Latin America to clamp down on tax avoidance and profit-shifting by multinational and local firms, with the country’s tax authority making companies with interests and assets one of its priorities for inspections this year. Outlining its tax enforcement plan for 2017 on March… – Continue reading

Countries ‘losing £400bn in taxes a year to profit shifting’

Governments around the world are losing as much as half a trillion US dollars (£400 billion) a year in tax revenue due to so-called “profit shifting” by multinational companies, according to research. The research published by the Tax Justice Network found that poorer countries were hardest-hit by the practice, which… – Continue reading

Adani’s coal mine to shift millions to a company in a tax haven: Australian media reports

Gautam Adani’s Australian entity will reportedly be shifting nearly Rs 150 billion from its Carmichael mine in Queensland to a secretive entity based in a tax haven. An analysis of the company’s findings done by the Australian Broadcasting Corporation shows that the company will be shifting up to 3 billion… – Continue reading

Can Pay, Won’t Pay: Tax Evasion, Profit Shifting Rife in Central, Eastern Europe

The LuxLeaks and Panama Papers scandals aroused shock and outrage the world over. However, reaction from Central and Eastern European statesmen and citizens was decidedly more muted. A new report has suggested profit shifting and tax dodging by businesses in the region is endemic – perhaps accounting for the lack… – Continue reading

U.S. Agents Raid Caterpillar Over Offshore Tax Practices

Federal agents raided three Caterpillar buildings near its Illinois headquarters on Thursday, company and law enforcement officials said, in an escalation of an inquiry into the heavy equipment manufacturer’s offshore tax practices. Caterpillar has been dogged by accusations that it slashed its domestic tax bill by shifting corporate profits from… – Continue reading

Taxing issues: multinationals still routing profits through Ireland

New Oxfam report indicates Government measures to tackle tax avoidance are failing Multinationals are continuing to route billions of euro in profit to and through Ireland to avoid tax, according to a new report by Oxfam Ireland. The study, which suggests that Government measures aimed at tackling tax avoidance are… – Continue reading

Mind the gap – HMRC’s crackdown on SME directors

Last Autumn, HMRC issued “Measuring Tax Gaps”, an annual report on the estimated UK tax gap. The tax gap being the shortfall in tax estimated by HMRC as being due in any one tax year from that which is eventually collected. In the accompanying press releases and in comments made… – Continue reading

Diverted Profits Tax introduced into Parliament

The Government has introduced the Diverted Profits Tax Bill 2017 and the 35 page Treasury Laws Amendment (Combating Multinational Tax Avoidance) Bill 2017 into Parliament to implement the Diverted Profits Tax (DPT), as one of its first Parliamentary items of business in 2017, indicating the priority attached to this measure…. – Continue reading

Bermuda – the world’s former ‘No.1 tax haven’ – joins fight against multinationals

Bermuda – the world’s former “top tax haven” – has joined the Organisation for Economic Cooperation and Development’s fight against multinational profit shifting. Bermuda disputes it is a tax haven despite companies such as Apple and Google in the past being accused of using the British overseas territory to minimise… – Continue reading

ATO warns energy giants over offshore profit hubs

The Australian Taxation Office has its sights on a $30 billion-a-year natural gas export bonanza expected over the next few years, warning oil and gas giants not to follow the lead of the big miners and “inappropriately shift profits” by selling through tax haven Singapore. At the same time, it… – Continue reading

Plans for Australia to adopt a ‘Google tax’ welcomed by advocacy group

Coalition’s proposed diverted profits tax could capture billions in revenue from multinationals using profit-shifting practices, says Tax Justice Network One of the biggest critics of multinational tax avoidance has welcomed the Coalition’s proposed “Google tax”, saying a similar tax in the UK looks likely to increase corporate tax payments by… – Continue reading

Corporate tax-dodging in Australia costs billions

Two reports on company taxation show that more than a third of the largest companies operating in Australia paid no tax in 2014–15 and that multinational tax evasion cost an estimated $4.8 billion that year. These reports show the fraud of the claims being made by the Australian government and… – Continue reading

Oxfam: Luxembourg, Ireland, Netherlands among worst tax havens

The NGO’s report exposes the worst offenders in the ‘race to the bottom on corporate tax.’ Luxembourg, Ireland, Cyprus, and the Netherlands are among the world’s 10 worst tax havens, despite an ongoing EU crackdown on tax avoidance and profit shifting across the bloc. The findings come in a report… – Continue reading

Australia’s Google Tax may be the second in the world but it’s too early to tell if it’s the ‘toughest’

When introducing the draft legislation for the Diverted Profits or so-called “Google Tax”, Federal Treasurer Scott Morrison claimed it would: …reinforce Australia’s position as having amongst the toughest laws in the world to combat corporate tax avoidance. Australia is the second country to introduce this type of tax, after the… – Continue reading

Australian ­Taxation Office turns to Facebook to catch cheats

Social media posts, private school records and immigration data are being used by the Australian Taxation Office as part of an increasingly sophisticated crackdown on tax cheats that yielded nearly $10 billion last year. ATO Commissioner Chris Jordan said the tax office had been investing in data collection analysis of… – Continue reading

EU Agrees Criteria For ‘Tax Haven’ Blacklist

The European Council has reached an agreement on the criteria and the process for the establishment of an EU list of non-cooperative jurisdictions in taxation matters. On November 8, the Council resolved that an EU list of non-cooperative jurisdictions “will be determined by the Council in 2017.” The “screening” of… – Continue reading

New Zealand Planning More BEPS Measures

New Zealand’s tax agency has set out the international tax initiatives it intends to pursue, in particular in response to the OECD’s base erosion and profit shifting plan. It said it will undertake further work on a package of BEPS initiatives, which will include hybrid mismatch rules to prevent companies… – Continue reading

German chemicals firm BASF avoided nearly €1bn in tax, says report

Network of foreign subsidiaries reported key to €923 million windfall over five years German chemicals manufacturer BASF has been accused of avoiding close to €1 billion of tax. In a report published on Monday, the company is alleged to have used aggressive tax-planning strategies in the Netherlands, Belgium, Switzerland and… – Continue reading

PH eyes tax treaties with Asean peers

The Philippines is eyeing to seal tax treaties with all nine other Asean member-states, according to the Bureau of Internal Revenue (BIR). The country already has effective double taxation agreements (DTAs) with Indonesia, Malaysia, Singapore, Thailand and Vietnam, BIR Assistant Commissioner Marissa O. Cabreros noted in a presentation at last… – Continue reading

Ireland braced for new EU corporate tax plan

A new EU corporate tax proposal could fundamentally change how multinationals pay their tax bills in Ireland. It comes at a sensitive time for the State, following so closely after the commission ruled phone giant Apple tapped illegal tax breaks worth around €13bn. In proposals to be unveiled tomorrow, the… – Continue reading

Experts dismiss HMRC’s shrinking tax gap estimate

The narrowing figure of £36bn roundly condemned for ignoring estimated tens of billions lost in profit shifting and tax avoidance by multinationals Tax experts warned that HM Revenue & Customs was underestimating the size of Britain’s tax avoidance problem after the agency claimed that Britain’s annual tax shortfall was only… – Continue reading

European commission to resurrect overarching corporate tax proposals

Proposed legislation is designed to curb the profit-shifting multinationals use to reduce tax liabilities on their income in Europe The European commission will redouble its crackdown on multinational tax avoidance next week with the relaunch of proposals to create an overarching corporation tax regime across all member states. The proposed… – Continue reading

Democrats Introduce Corporate Tax Transparency Bill in Congress

House Democrats have introduced legislation that would require multinational corporations to disclose more information about the taxes they pay in other countries. The bill, known as the Corporate Transparency and Accountability Act, aims to shine more light on corporate tax avoidance strategies, requiring the disclosure of country-by-country and pre-tax profit… – Continue reading

Australia Singles Out Multinational Profit Shifting Arrangements

The Australian Taxation Office (ATO) has published two new taxpayer alerts that warn against international profit shifting by multinational companies. Taxpayer Alert 2016/11 concerns a new scheme that the ATO said attempts to avoid the Multinational Anti-Avoidance Law (MAAL). The MAAL applies to multinational groups that avoid a taxable presence… – Continue reading

UAE companies to benefit from transfer pricing as profit-shifting plan comes into force

The international tax landscape has been changing rapidly and the Organisation for Economic Co-operation and Development (OECD) has agreed on a base erosion and profit shifting (Beps) action plan that could affect businesses operating in the UAE. The plan addresses the issue of artificial shifting of profits and its proposals… – Continue reading

OECD consults on branch mismatch structures to curb profit shifting

The OECD is consulting on the mechanics of dealing with branch mismatch structures under Base Erosion & Profit Shifting (BEPS) Action 2, designed to neutralise the effects of hybrid mismatch arrangements as part of the wider anti-avoidance action plan The BEPs project has already released a report on Action 2,… – Continue reading

Republicans Take New Tack on Taxing Companies’ Overseas Profits

Democrats are likely to object to the House GOP’s and Donald Trump’s plans for sharply lower rates President Ronald Reagan once chided government’s approach to the economy as following this mantra: “If it moves, tax it.” Today’s Republicans are following Mr. Reagan’s ideas by trying the exact opposite approach. The… – Continue reading

G20 ministers urge tighter tax rules for multinationals

The world’s major economies need to deepen cooperation on tax collection as companies seek to minimise the amount they pay to governments, finance ministers said Saturday. The issue has become controversial in many countries, with multinational firms from Google to Starbucks facing accusations of not contributing appropriately to the economies… – Continue reading

Brexit Risks Losing Corporate Tax Break Worth Billions in U.K.

British multinational companies face new withholding taxes that may cost hundreds of billions of euros a year if U.K. voters decide to leave the European Union, international tax specialists say. A so-called Brexit “would have a major impact” on British corporations that have subsidiaries in the EU, said Daniel Gutmann,… – Continue reading

European Commission gets closer to agreeing anti-tax avoidance directive

The European Commission is on the brink of agreeing its far-reaching anti-tax avoidance directive, but is waiting on approval of some elements of the package by the Belgian and Czech governments, before it introduces new rules at midnight on Monday 20 June At the end of last week the Commission’s… – Continue reading

Implications of a Brexit: A U-turn in tackling global tax avoidance?

With just days remaining until Britain decides on its EU membership, the UK is at a crossroads. It has a historical choice to make, with various consequences attached to the decision on the 23rd of June on whether it becomes the first ever country to leave the EU. Those consequences… – Continue reading

Mauritius pact: A laudable reform

Last month the government announced an amendment to the Double Tax Avoidance Agreement between India and Mauritius. The DTAA was signed between the two countries in August 1982 and notified in December 1983. For the past thirty-three years it has been a key factor affecting foreign investment flows into India…. – Continue reading

Ireland delays EU corporate tax deal

Ireland has helped delay an EU deal on corporate tax-dodging over fears it could harm the economy. Finance Minister Michael Noonan told his EU counterparts in Brussels he would not sign up to the deal because it affects Ireland’s sovereign right to set tax rates. “We want to make sure… – Continue reading

US Lawmakers Further Challenge EU’s Tax Ruling Probe

Members of the US Senate Committee on Finance have called on the US Secretary of the Treasury, Jack Lew, to continue aggressive engagement with the European Commission to ensure its ongoing tax ruling probe does not inappropriately target US multinationals. In their letter submitted to Lew on May 23, 2016,… – Continue reading

Russia Signs OECD Agreement on Common Reporting Standard

May 18 — Russia agreed to automatically share financial account information but passed up an opportunity the same day on a similar agreement to exchange company country-by-country reports. Russia signed the OECD’s common reporting standard (CRS) multilateral competent authority agreement May 12 at a meeting of tax administration heads in… – Continue reading