When it comes to planning for tax season, corporate tax reporting should be considered as part of Enterprise Performance Management. As Margaret Mitchell exclaimed in the classic novel, Gone with the Wind: ‘Death, taxes and childbirth! There’s never any convenient time for any of them.’ And while I hope that… – Continue reading
As Common Reporting Standard (CRS) comes into operation. OHANNESBURG – South Africans with undeclared offshore funds may only have a few months to get their affairs in order or risk facing significant penalties and even criminal prosecution as revenue authorities start the automatic exchange of information. The Common Reporting Standard… – Continue reading
The OECD published 13 final reports along with an explanatory statement under its base erosion and profit shifting (BEPS) project on the 5th October 2015. This was endorsed three days later on the 8th October 2015 by the G20 Finance Ministers’ meeting in Peru’. The BEPS project outlines 15 action… – Continue reading
Introduction Transfer pricing is a term used to define the price charged between associated enterprises for the transfer of goods, services and intangible property. Increasing cross-border activities have made transfer pricing a real issue as enterprises seek to use transfer pricing as a tool for tax avoidance. Consequently, HK has… – Continue reading
FOCUS: Significant changes to the international tax system planned for the next five years, coupled with a major shift in attitudes towards tax avoidance, has all but killed off the traditional tax scheme. So what does the future hold for businesses seeking to engage in tax planning? To celebrate Out-Law’s… – Continue reading
Israel has joined 90 other countries in signing up to the OECD’s instrument to combat offshore tax avoidance and increase transparency in tax matters. The middle-eastern country became the 91st jurisdiction to sign the Multilateral Convention on Mutual Administrative Assistance in Tax Matters yesterday, which enables the exchange of information,… – Continue reading
Greater China, Southeast Asia Seen as Global Leaders in Use of Offshore Vehicles, Drawn by Efficiency & Legal Frameworks Key Highlights: OIL’s sixth annual survey shows: The offshore industry will be a leaner, more resilient and confident member of the global economy by 2020, driven by demand from increasing numbers… – Continue reading
The Senate Finance Committee and the House Ways and Means Committee’s Subcommittee on Tax Policy today both announced hearings relating to the OECD’s base erosion and profit shifting (BEPS) project. Both hearings are scheduled for Tuesday, December 1, 2015. SENATE FINANCE HEARING According to today’s release, the Senate Finance Committee’s… – Continue reading
Hong Kong is tipped to become the world’s largest offshore corporate services centre by 2020, helped ironically, by the industry’s own struggles against reform demands coming from western governments and pressure groups. On notice after high profile money laundering and tax avoidance scandals, traditional offshore havens like the British Virgin… – Continue reading
Transfer pricing adjustment cannot be made in a case where the tax rate in the country of the Associated Enterprise is higher than the Indian rate and where, accordingly, establishment of tax avoidance or manipulation of prices or establishment of shifting of profits is not possible. Only after proper application… – Continue reading
News Hour: Today the European Parliament voted in favor of specific recommendations aimed at stopping corporate tax avoidance across the European Union. The plenary adopted the report of its special committee on tax rulings, which had been created after the Luxleaks scandal. Oxfam welcomes the parliament’s broad consensus on ending… – Continue reading
Protecting the tax base of extractive industries, moving toward more responsive and flexible fiscal regimes, and improving international cooperation have become priorities in the Andean region, as commodity prices and revenues from extractive industries continue to decline, participants at a recent IMF conference heard. The three-day conference, Determining the Tax… – Continue reading
The evidence is in: company tax harms investment, innovation, and entrepreneurship — and even reduces wages. Not that you’d know this from reading some stories this week, which claim advocates of company tax cuts had avoided using evidence. This seems to be wilfully ignoring the strong evidence that is in… – Continue reading
NEW DELHI: India proposes a major clean-up of decade-and-a-halfold rules that govern the prices of imports by related parties – such as arms of multinationals from their parent – in an attempt to reduce delays and disputes and make it easier to do business. The finance ministry is not just… – Continue reading
Wealth inequality is a scourge of many countries. Last year, Credit Suisse reported that the richest 0.7% of adults in the world owned 44% of global wealth. Closer to home, earlier this year, the Lien Centre for Social Innovation’s ‘A Handbook on Inequality, Poverty and Unmet Social Needs in Singapore‘… – Continue reading
On July 22 2015, National Treasury released for comment the Draft Taxation Laws Amendment Bill, 2015 (DTLAB 2015), the Draft Tax Administration Laws Amendment Bill, 2015 (DTALAB 2015), and related Explanatory Memoranda. Section 9D currently provides for diversionary income rules which seek to impute into the income of South African… – Continue reading
Today, the Organization for Economic Cooperation and Development (OECD) released statistics for the 2014 reporting period on the mutual agreement procedure (MAP) caseloads of all of its member countries and of non-OECD economies that agreed to provide such statistics. The OECD has already provided MAP statistics for reporting periods 2006… – Continue reading
Through tweaks to the Model Tax Convention, the OECD believes its work on profit shifting will stem elaborate structures, such as commissionaire arrangements, used by large multinationals to avoid the creation of a permanent establishment. The Organization for Economic Cooperation and Development, however, responded to concerns from taxpayers by narrowing… – Continue reading
Big name companies have faced a lot of criticism from the media about the low taxes they pay in some countries. Lately, the Organisation of Economic Cooperation and Development (OECD) has finalised a set of recommendations to stop base erosion and profit shifting (BEPS). The rules are aimed at curbing… – Continue reading
The OECD’s final report on Action 13 under the base erosion and profit shifting project—which calls for countries to adopt a country-by-country reporting template, master file and local file—has the potential to be one of its “greatest legacies.” Marlies de Ruiter, head of the Organization for Economic Cooperation and Development’s… – Continue reading
The creation of the Group of Twenty (G20) was believed to serve as a remedy to the harsh realities of the world today. The initial formation of the Group of Seven G7 could do little to avert pertinent challenges both the developing and the developed nations face frequently. So a… – Continue reading
MUMBAI: India’s forthcoming budget may draw from some of the recommendations, especially in the realm of transfer pricing, contained in the final package of ‘Base Erosion and Profit Shifting’ (BEPS) measures, rolled out in October. Certain anti-abuse measures, such as thin capitalization, which for tax purposes disallows interest payments beyond… – Continue reading
On 18 June 2013, the Progressive led government issued a press release titled, “Cayman’s Action Plan Includes Beneficial Ownership”. The press statement came on the heels of the UK taking over the Presidency of G8, at the 17-18 June 2013 G8 Summit in Northern Ireland. The most interesting part of… – Continue reading
Now that’s what I call a Big Tax Case A long running court case that has become known as the ‘Big Tax Case’ appears to be reaching a conclusion. It involves Scottish football club Rangers, who went bust in 2012. After it failed, a new company was created. It bought… – Continue reading
Malta recently ranked first for efficiency in transposing directives into national legislation – but the chairman of Finance Malta, Kenneth Farrugia, believes that the pace of innovation needs to accelerate. “We claim to be nimble, but we need to push it much more. Innovation needs to be much faster paced…. – Continue reading
In recent days, the new Speaker of the House Paul Ryan (R-Wis.) signaled a priority for international tax reform in 2016. And if the newest recommendations from the Organization of Economic Cooperation and Development (OECD) are any indication of what’s ahead on the global tax scene for American businesses, it… – Continue reading
Measures Will Impact Financial Services, Investment Fund, Aviation Leasing and Other Sectors G20 finance ministers last week finally approved the wide-ranging “BEPS” reforms to the international tax system. The measures include a proposed new OECD treaty definition of “Permanent Establishment” under which the mere negotiation of contracts could create a… – Continue reading
Tax administrators want to maximise the amount of revenue collected without stifling the county’s competitiveness as a business destination. How should ASEAN countries navigate changing international conditions to meet this goal? By Rebecca Tan – As Benjamin Franklin once famously said, “In this world, nothing can be said to be… – Continue reading
Hong Kong is tipped to become the world’s largest offshore corporate services centre by 2020, helped ironically, by the industry’s own struggles against reform demands coming from western governments and pressure groups. On notice after high profile money laundering and tax avoidance scandals, traditional offshore havens like the British Virgin… – Continue reading
Perhaps in theory there are ways to fix tax avoidance, but they aren’t politically feasible. Libertarian anarchists used to say “taxation is theft.” New research by economist Gabriel Zucman suggests that there is some truth to this—when tax havens are taken into consideration. In his new book The Hidden Wealth… – Continue reading
The Isle of Man’s role as an offshore finance centre will come under the spotlight on television following a Welsh town’s experiment in how to avoid paying UK tax. Independent traders in Crickhowell, led by the salmon smokery, the local coffee shop, the adventure clothes shop, the optician, the book… – Continue reading
Google is said to have evaded paying an estimated $1.3 billion earned from selling apps in Korea based on the argument that their server is based in Ireland. The so called ‘Google Tax’, also known as the Base Erosion & Profit Shifting (BEPS) regulation, has been adopted this week by… – Continue reading
Tax Commissioner Chris Jordan says multinationals are already approaching the Australian Taxation Office to negotiate before the Turnbull government’s tougher anti-avoidance laws take effect in January, and he expects the office to reap $1.1 billion from them. We at the ATO acknowledge Australia needs investment by foreign companies in infrastructure… – Continue reading
Brussels – Google and Facebook were among US companies facing questions on Monday from European Union lawmakers about their tax-reducing techniques, a month after regional antitrust regulators raised the stakes by ordering Starbucks and a Fiat Chrysler Automobiles NV unit to repay millions of euros in back taxes. The queries… – Continue reading
Some people think popular furniture store IKEA is being naughty, and not paying its proper share of tax in Australia. The franchise is a behemoth, both literally in terms of store size and figuratively in that it collected a US$5 billion profit for the 2014 financial year. A community action… – Continue reading
The FINANCIAL — Employees in tax functions need to fundamentally change the way they use and gather data if they are to meet the growing demands on business of tax transparency, reform and technology enabled decision making. PwC’s latest research into the Tax function of the future – Unlocking the… – Continue reading
MELAKA, Nov 17 (Bernama) — The Inland Revenue Board (IRB) has highlighted the transfer pricing (TP) and abuse of treaties in base erosion and profit shifting (BEPS) issues at the 36th Commonwealth Association of Tax Administrators Conference (CATA) here today. IRB, in a statement today, said CATA members were serious… – Continue reading
The need for robust, well-informed intangible asset valuations for the purpose of transfer pricing is becoming ever more invaluable for MNEs TRANSFER pricing has been the buzz-word of the moment with extensive media coverage in recent years of multinational enterprises (MNEs) repositioning profits to more favourable tax jurisdictions. This movement… – Continue reading
The Organisation for Economic Co-operation and Development (OECD) has described its newly unveiled Base Erosion and Profit Shifting (BEPS) Action Plan as a “change of paradigm.”1 A few very large global groups aside, a more apt description may be a minefield for the unwary. BEPS has received considerable air time… – Continue reading
The UK Government launched a consultation on 22 October 2015 regarding the UK corporate tax rules for interest deductibility. The consultation seeks views on the design of a general limitation for UK corporation tax deductions for interest and similar finance costs, imposing a capcalculated by reference to a fixed percentage… – Continue reading
Antalya, Nov. 16: The Group of 20 nations today pledged to adopt sound macroeconomic policies to achieve strong, sustainable balanced growth. The near-term objective would be to support growth, create jobs and put debt as a share of gross domestic product (GDP) on a sustainable path. Data show that several… – Continue reading
The OECD’s base erosion and profit shifting (BEPS) reforms do not go far enough in changing the international corporate tax system, G20 leaders have been told. In a letter to leaders at the G20 summit in Antayla, Turkey, Nobel Prize-winning economist Joseph Stiglitz and others from the Independent Commission for… – Continue reading
Amazon, Facebook and Google in line of fire after committee backs proposals to force multinational corporations to pay tax where they make their sales MEPs have launched a scathing attack on Facebook, Google and Amazon in the European parliament, accusing them of diverting profits worth billions of pounds to low… – Continue reading
A number of multinational companies have been in the news recently for alleged tax malpractices. Various countries which are facing budget deficits are convinced that additional tax revenues can be collected, especially from multinational companies. What is it all about? A business typically faces many risks. A risk is the… – Continue reading
French lawmakers sought to tackle corporate tax avoidance on Thursday, voting to require big French companies to report tax information on their foreign activities on a country-by-country basis from 2016. The French government wants to get an early start on implementing an OECD recommendation for country-by-country reporting that aims to… – Continue reading
Canada is expected to join other G20 countries to sign off on an international deal in Turkey aimed at cracking down on “profit shifting” by large multinational companies seeking to reduce their tax bills. The changes, which are also aimed at exposing the corrupt use of tax havens to launder… – Continue reading
Tax: Luxembourg among countries helping US firms cut their tax bills by more than a quarter, campaigners say. The abuse of holding company structures in the Grand Duchy, and fiscal regimes in several other countries, allows American firms to avoid paying billions of dollars in corporate profit taxes, two NGOs… – Continue reading
European Union lawmakers have called 13 multinational companies to a meeting next week to talk about the low-tax deals they have struck with EU jurisdictions, reports CBC News. Among the companies to be questioned on Nov. 16 will be Amazon.com, Disney, Coca-Cola Co, Anheuser-Busch InBev NV, HSBC Holdings, Ikea Group… – Continue reading
THE South African Revenue Service (SARS) is planning to pay more attention to ensuring that medium and smaller companies, and those in the “cash economy”, pay their taxes. This comes after several years in which the focus has been mainly on tackling non-compliance in the large business sector. SARS group… – Continue reading
LONDON – Both developed countries and developing countries are loosing out on tax revenues due to a continued lack of progress in fighting international tax avoidance. Large multinational businesses are still using international tax rules to avoid paying taxes in the countries where they raise profits, according to information contained… – Continue reading
