In early July, the Israeli Tax Authority (ITA) issued an update to Form 1385 - "Declaration of International Transaction.” ... - Continue reading
The US IRS will once again examine allocations between group members of employee stock-based compensation in cost-sharing arrangements for transfer pricing purposes. ... - Continue reading
Statistics published earlier this week by the European Commission on member state advance pricing agreement (APA) and mutual agreement procedure (MAP) programs suggest that the OECD/G20 base erosion profit shifting (BEPS) project has increased the scope for differences of opinion between tax authorities of different countries. ... - Continue reading
The Hong Kong Inland Revenue Department (IRD) on 19 July published Departmental Interpretation and Practice Notes (DIPNs) Nos. 58, 59, and 60, and an updated version of DIPN No. 28. ... - Continue reading
A Danish tax administration decree, published 12 July in response to the Supreme Court’s decision in the Microsoft case, establishes a new practice for determining whether transfer pricing documentation must be available at the time the taxpayer is required to file its tax return. ... - Continue reading
Intangibles are key sources of differentiation for businesses and typically, they help drive revenue, manage cost or both. As a result, many businesses make significant investments in developing, enhancing, maintaining and protecting unique and valuable intangibles to help drive their businesses. ... - Continue reading
On July 12 the Netherlands government published a legislative proposal implementing the EU mandatory disclosure directive. This follows an internet consultation on a draft legislative proposal which ran from December 19, 2018 — February 1, 2019. ... - Continue reading
The Directorate General of GST Intelligence (DGGSTI), an arm of the indirect tax administration, has unearthed a racket involving 90 firms which issue fake invoices to errant companies for tax evasion, the agency said on Friday. ... - Continue reading
G7 finance ministers, at their meeting in Chantilly, France on July 17–18, agreed to several aspects of a revised system for taxing multinationals. ... - Continue reading
The Inter-American Center of Tax Administrations (CIAT), on July 15, released comprehensive and detailed proposals aimed at preventing abusive transfer pricing in low-income countries and in countries on the path to development. ... - Continue reading
Hot topics for discussion at the conference included taxation of the digital economy, approaches for "hard to value intangibles", the adoption of technology within the tax department, and lessons learned from country-by-country reporting. ... - Continue reading
TRANSFER pricing — the pricing of commodities traded between or within multinational enterprises — is a legal practice and a key feature of cross-border and intra-firm transactions. The United Nations prefers to use the broader phrase ‘trade pricing’ in addressing this practice and defines it as a ‘normal incident of… – Continue reading
Tax authority of Australia takes measures on tax issues ... - Continue reading
"Substance" - the new rule of the tax world ... - Continue reading
New tax legislation for India's 2019 Budget ... - Continue reading
Duff & Phelps' Transfer Pricing Alliance Partner, TP EQuilibrium AustralAsia, contributed their insights, expertise and perspectives on this new development. ... - Continue reading
Guide to Cash Pools And Transfer Pricing ... - Continue reading
The UK’s Upper Tribunal has decided that three special purpose vehicles (SPVs) incorporated in Jersey as part of a tax planning arrangement were not tax resident in the UK for tax purposes, overturning a 2017 decision from the First-tier Tax Tribunal. Development Securities, a property and investment group based in… – Continue reading
Tax rules regarding offshore tax planning amended ... - Continue reading
Transfer pricing positions to be reviewed by IRS ... - Continue reading
The union cabinet, chaired by Prime Minister Narendra Modi on Wednesday approved the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The Convention will modify India’s treaties in order to curb revenue loss through treaty abuse and base erosion… – Continue reading
Ivan Pelle, one of the Founders and Executive Director, expert in International Taxation at Recontam Global Network (RGN) is on a mission to make its clients and partners aware of the rollout of CRS and AEOI across Asia-Pacific and how this might affect tax planning and investment strategies. He addressed… – Continue reading
HMRC loses case against tax planning arrangements ... - Continue reading
Here are some factors about offshore trusts that you need know. ... - Continue reading
The length of time taken to settle tax investigations into large businesses has increased by 10% to a record 43 months as of March 2019 ... - Continue reading
National Board of Revenue is building up profiles of the multinational companies operating in the country for the purpose of conducting audits on the MNCs’ accounts to prevent tax evasion through misuse of transfer pricing system. Transfer Pricing Cell (TPC) of NBR is also conducting risk assessment of the companies’… – Continue reading
It has been over a year since the Tax Cuts and Jobs Act (“TCJA”) was enacted. The transfer pricing rules set forth in the treasury regulations with respect to IRC Sec. 482 (“the Section 482 regulations”) have remained relatively unchanged since 1986. Nonetheless, multinational corporations doing business within the United… – Continue reading
In the last decade, OECD officials have recommended measures to combat tax avoidance, culminating first in the BEPS (Base Erosion and Profit Shifting) initiative in 2015 and then the MLI (Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS) effective from July 2018 – yet have all their… – Continue reading
New guidelines to tackle profit shifting and transfer pricing ... - Continue reading
On July 4, 2018, Hong Kong’s Inland Revenue Department passed the country’s final Inland Revenue (Amendment) (No. 6) Bill 2017, (the Amendment Bill). This Amendment Bill (which became law on July 13, 2018) specified the documentary requirements from a transfer pricing perspective and also introduced measures to address various recommendations… – Continue reading
After consulting with professionals in the Mediterranean island’s service sector the Finance Ministry is drafting a bill on Transfer Pricing guidelines. The Transfer Pricing regime concerns tax treatment of intra-group financing transactions. The draft bill aims to put an end to the over-pricing of intra-group invoices so that any low… – Continue reading
Finance minister AHM Mustafa Kamal has said that the foreign companies will be required to have local partners for doing business in Bangladesh as the government wants to bring them under the tax net. ‘No foreign company can do business alone here any longer,’ he told reporters on Thursday after… – Continue reading
Globalisation of the economy has resulted in a shift in the way Singapore corporations operate – from local country-specific business models, to global integrated supply chains which centralise functions at a regional or global level. Singapore, in particular is a popular location to house regional and global operations, due to… – Continue reading
The winners of International Tax Review’s 2019 Asia Tax Awards have been announced with Ernst & Young named Tax Firm of the Year. After three consecutive crowns in the Asia Tax Awards’ Tax Firm of the Year category, KPMG has this year been bumped from the podium by fellow Big… – Continue reading
As per the agreement, it is intended to provide relevant and reliable information to perform an efficient and robust transfer pricing risk assessment analysis. Aimed at providing relief to subsidiaries of US multinationals and ensuring a check on cross-border tax evasion, India has notified the inter-governmental agreement with the United… – Continue reading
The income tax department is said to have adopted at least six different ‘out of the ordinary’ methods to recover tax dues The income tax department this year also used a rare provision to collect dues directly from a company’s bank accounts Mumbai: Every year in March, the income tax… – Continue reading
HMRC sent 1,414 requests to professional services firms demanding confidential information on clients suspected of tax evasion in the 12 months to 31 March 2018, according to law firm RPC. The production orders are issued by HMRC’s Criminal Investigation Directorate to force third parties, such as accountants, lawyers and other… – Continue reading
European Union lawmakers released a report on Wednesday (Feb. 27) recommending that the EU create a police unit dedicated to the investigation of tax and financial crimes, as well as a watchdog organization to fight money-laundering, according to a report by Reuters. The report, which is the result of a… – Continue reading
European Union lawmakers released a report on Wednesday (Feb. 27) recommending that the EU create a police unit dedicated to the investigation of tax and financial crimes, as well as a watchdog organization to fight money-laundering, according to a report by Reuters. The report, which is the result of a… – Continue reading
In December, the Virgin Islands implemented a new Base Erosion and Profit Shifting (BEPS) measure, according to Government Information Services. The Organisation for Economic Co-operation and Development created a BEPS “action plan” in 2013 to combat “tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift… – Continue reading
Supreme Court verdict a slap in the face for SKAT A case that has been going on for almost ten years has now come to an end, and the outcome has not been favourable to Danish taxpayers. The SKAT tax authority took Microsoft to court because it felt the company… – Continue reading
Tax advisory revenue at professional services firms expanded 8.6 percent to $20.3 billion in 2017, and grew by around $5 billion in just the three years from 2014 to 2017, according to a new report. The report, from Source Global Research, found that the main tax advisory services around the… – Continue reading
Complicated, aggressive corporate tax-planning strategies can produce uncertainty and confusion among investors not only about the companies’ taxes, but also the basics of their operations and finances, leading to some negative outcomes, according to a new academic study. The study, by Jennifer Blouin and Wayne Guay of the University of… – Continue reading
FIRST proposed by the European Commission (EU) in 2016, a set of new tax rules aimed at eliminating most common corporate tax avoidance practices came into force on 1 January 2019. The commission posted on its website on 30 December 2018 that the new tax rules known as Atad (anti-tax… – Continue reading
Once the UAE fully implements the BEPS minimum standard, it will become a very good location, say tax experts The UAE’s position as an attractive destination for foreign investment will substantially improve once it fully implements minimum standards for base erosion and profit shifting (BEPS), tax analysts said on Saturday…. – Continue reading
Ireland and Malta have agreed to close the “Single Malt” – an aggressive tax planning structure in which some multinational corporations use a company incorporated in Ireland but tax-resident in Malta. The Competent Authority Agreement – entered into as per the provisions of Article 24 (mutual agreement procedure) of the… – Continue reading
In general, investment and tax provisions relating to non-resident Indians (NRIs) returning to live in India are fairly generous. However, NRIs must carefully plan their return to India to ensure there are no surprises with respect to managing their overseas income and investments. In this article, we examine some of… – Continue reading
The Federal Inland Revenue Service (FIRS) recently released the Income Tax (Transfer Pricing) Regulation 2018 (‘the Regulation’). The Regulation took effect from 12th March 2018 and replaces the Income Tax (Transfer Pricing) Regulations, 2012. The Regulation sets out the legal framework for the application of the arm’s length principle to… – Continue reading
