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
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
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
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
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
The misconceptions about transfer pricing being a tax avoidance or violation in Vietnam are creating challenges for multinational enterprises, said Adam Sitkoff, executive director of the American Chamber of Commerce in Vietnam (Amcham). In his opening speech at a workshop held to gain clarity on the changing world of transfer pricing,… – Continue reading
Many taxpayers in China have had questions about how the government would change the individual income tax (IIT) law since the amendment was passed earlier this year. Recently, however, the tax authorities released a draft of the amendment’s implementation rules and measures for comment. While the draft implementation rules and… – Continue reading
Caerphilly-based credit referencing company Creditsafe has paid Her Majesty’s Revenue and Customs almost £1 million after it was served with a ‘Diverted Profits Tax’ charge. Registered as Creditsafe Business Solutions, the company, based at Caerphilly Business Park, sells business data for credit check purposes and other uses. According to full… – Continue reading
As part of the British Virgin Islands’ (“BVI”) ongoing commitment to international tax transparency pursuant to the Common Reporting Standard (“CRS”), the BVI Mutual Legal Assistance (Tax Matters) Act, 2003 has been amended by the BVI Mutual Legal Assistance (Tax Matters) (Amendment) Act, 2018 (the “Amendment Act”). The Amendment Act… – Continue reading
The Federal Government is seeking assistance from the International Monetary Fund (IMF) on modalities for improving tax collection, especially from the International Oil Companies (IOCs), Finance Minister Zainab Ahmed, has said. She told reporters on the sidelines of the ongoing 2018 International Monetary Fund (IMF)/World Bank Group Meetings, in Bali,… – Continue reading
The more detailed scrutiny of the tax affairs of multinationals, large corporations and wealthy individuals, made possible by the formation of the Tax Avoidance Taskforce, has collected $5.6 billion in extra tax in just two years. Deputy Commissioner Mark Konza said “the $679.9 million the Government funded the ATO for… – Continue reading
The General Department of Taxation has been reviewing press information about foreign firms continuously reporting loss to have inspection plan in the upcoming time. The general department has required tax agencies to focus on inspection over these companies. According to articles published on Sai Gon Giai Phong Newspaper in May… – Continue reading
Viet Nam News HÀ NỘI —Vietnam will institute new policies designed to attract foreign direct investment (FDI) by boosting the development of local companies and setting up value chains driven by advanced technologies. FDI has been a major factor in Vietnam’s rapid socio-economic development; however, some key metrics remain below… – Continue reading
Transfer pricing cell of National Board of Revenue has remained nearly dysfunctional since its formation five years back due mainly to lack of logistic support, expert and dedicated manpower and propelling initiative of the tax authorities. The cell even could not conduct audit on any statement of international transactions of… – Continue reading
VietNamNet Bridge – Nearly 38 percent of foreign invested enterprises (FIEs) reported losses in 2017, a significant decrease from the 50 percent seen in previous years. However, transfer pricing by FIEs remains a headache for management agencies. Do Thien Anh Tuan of Fulbright University said that enterprises that most regularly… – Continue reading
Federal Inland Revenue Service has published Nigeria’s revised Transfer Pricing Regulations (NTPR). The NTPR is effective for basis periods commencing after 12 March 2018 and incorporates BEPS outcomes and suggestions from The African Tax Administration Forum. The NTPR includes significant penalties for non-compliance (a) failure to file TP declaration =… – Continue reading
The Internal Revenue Service is making some adjustments to its Compliance Assurance Process, a program aimed at large corporate taxpayers that involves cooperating with the IRS before any audits. As part of the proposed changes, the IRS said Monday it will shift the start of the application period to Oct…. – Continue reading
Last week, Medtronic Plc suffered a legal setback in its bid to avoid a $1.4 billion U.S. tax bill — a ruling that may have costly implications for other multinationals battling the Internal Revenue Service over the use of overseas payments to lower their taxes. Companies including Facebook Inc. and… – Continue reading
News that the government may bring in an ‘Amazon tax’ to help “rebalance the playing field” between physical and online retailers has been welcomed by booksellers. After department store retailer House of Fraser became the latest high street chain to go into administration on Friday (10th August) Philip Hammond said… – Continue reading
Most multinational corporations (MNCs) charge their subsidiaries for services like human resources (HR) or information technology support. The subsidiary’s payment for these services is classed as intra-group service fees when they are made within same enterprise group. Because some businesses use this method to avoid tax and shift profits, tax… – Continue reading
The introduction of an exit capital tax, envisaged by the draft law on amendments to the Tax Code of Ukraine regarding the tax on exit capital (No. 8557), will draw the attention of tax authorities to companies carrying out foreign economic operations, expert for transfer pricing at Evris law firm… – Continue reading
Media reports have suggested the Government to build a more effective mechanism to tackle the problem that prolonged loss-making FDI enterprises have still enlarged investment and production. — Photo cafebiz.vn Viet Nam News HA NOI – Prime Minister Nguyen Xuan Phuc has assigned the Ministry of Finance (MOF) and General… – Continue reading
HCM CITY — Viet Nam’s laws about transfer pricing remain inconsistent and have many loopholes, causing great loss of State revenue, speakers said on July 19 at a meeting held in Ha Noi. Speaking at the “Transfer Pricing – Issues in Management” workshop, Dr. Ho Duc Phoc, auditor general of… – Continue reading
Hong Kong (HKSAR) – The Inland Revenue (Amendment) (No. 6) Ordinance 2018, which primarily implements the minimum standards of the Base Erosion and Profit Shifting (BEPS) package promulgated by the Organisation for Economic Co-operation and Development (OECD) and codifies the transfer pricing principles into the Inland Revenue Ordinance (Cap. 112)… – Continue reading
From a commercial viewpoint it is important that the Holdco is located in a reputable jurisdiction when seeking to access international equity and debt capital markets. The choice of Holdco location will also be relevant in circumstances where private equity investment is envisaged or where a trade sale is planned…. – Continue reading
Hanoi (VNS/VNA) – The changes in tax policy and investment incentives are the issues of greatest concern for foreign investors in Vietnam, said Bui Ngoc Tuan, Deputy General Director of the Audit and Advisory firm Deloitte Vietnam at a workshop on in Hanoi on July 10. Themed “Investment incentives, related… – Continue reading
The Central Board of Direct Taxes has recently issued guidance on the appropriate use of the ‘Country-by-Country Report’. The CbC filing was introduced as a result of the OECD/G20 Base Erosion and Profit Shifting project. India also introduced the requirement to file CbC reporting recently with the completion of the… – Continue reading
CBDT issues draft notification on interest computation NEW DELHI, JUNE 20 The Central Board of Direct Taxes (CBDT) proposes to provide a relief to MNCs on the interest payable by them on the untaxed profits stashed abroad, requiring to be repatriated back to India under the transfer pricing regime. It… – Continue reading
The OECD has released the first peer reviews of the country-by-country (CbC) reporting initiative, reporting that practically all countries that serve as headquarters to large multinationals have introduced new transfer pricing documentation requirements to improve transparency. Country-by-country reporting will see tax administrations worldwide collect and share detailed information on all… – Continue reading
The OECD has endorsed New Zealand’s crackdown on multi-national tax evasion, despite significant criticism from local businesses that it departs from OECD standards, Thomas Coughlan reports. David Bradbury, head of the OECD’s tax policy and statistics division, told Newsroom that the OECD was “very pleased with the strong support that… – Continue reading
Malawi is struggling to address loss of revenues due to smuggling of minerals, unregulated artisanal and small-scale mining activities, under declaration of taxable income and transfer mispricing by mining companies. Reserve Bank of Malawi statistics show that Malawi lost $980 million (MWK78 billion) between 2010 and 2017 due to foreign… – Continue reading
HM Revenue and Customs (HMRC) has launched a consultation inviting input on proposals to tackle arrangements entered into by individuals, partnerships, or companies that aim to move UK profits outside the scope of UK taxation, typically through the use of offshore trusts and companies. The new legislation, to be drafted… – Continue reading
The OECD has published new transfer pricing country profiles for Australia, China, Estonia, France, Georgia, Hungary, India, Israel, Liechtenstein, Norway, Poland, Portugal, Sweden, and Uruguay, bringing the number of such overviews published by the OECD to 44. The profiles explain the current transfer pricing legislation and practices of each country…. – Continue reading
The Central Board of Direct Taxes ( CBDT ) has released Central Action Plan for the First Quarter April 2018 to June 2018 of the FY 2018-2019. The Key Result Areas of the Action Plan and the Time Frame in the which it is to be achieved has been categorically… – Continue reading
The Centre for Trade Policy and Development (CTPD) has commended the Zambia Revenue Authority (ZRA) for exposing the tax evasion scam worth K76.5 billion in the extractive sector. The center has also welcomed intentions by the authority to undertake an extensive audit of mining companies. CTPD Executive Director Isaac Mwaipopo… – Continue reading
Jakarta. Indonesia’s tax office plans to spend hundreds of millions of dollars to update its outdated technology to boost low tax compliance and raise revenue collection in Southeast Asia’s largest economy, the country’s tax chief told Reuters. Indonesia completed one of the world’s most successful tax amnesties in 2017, but… – Continue reading
Argentina’s Federal Administration of Public Income has extended the filing deadline for country-by-country (CbC) notifications. Taxpayers who are part of multinational enterprises now have until May 2, 2018, to file CbC notifications where the ultimate parent company of the multinational group has a December 2017 fiscal year end. The CbC… – Continue reading
The Indian Central Board of Direct Taxes has issued a statement to defer the filing obligation on surrogate parent entities with regards to country-by-country reporting. Section 286 was inserted into the Income Tax Act 1981 through the 2016 Finance Act to introduce a requirement to furnish a country-by-country report. The… – Continue reading
All international groups operating in the country will have to provide a country-by-country (CbC) report as per the revised Income tax Act, the government clarified in a finance ministry release issued today. The CbC report is to be furnished by the ultimate parent entity of an international group in the… – Continue reading
The introduction of a unilateral revenue tax on digital businesses in the UK would stymie investment and be a strangely timed gamble, says accountancy firm Moore Stephens. The Government’s position paper, “Corporate tax and the digital economy,” released at the recent Spring Statement, includes a proposal to tax certain tech… – Continue reading
Mauritius last month released the Income Tax (Country-by-Country Reporting) Regulations 2018, setting out the jurisdiction’s rules concerning the filing by multinational groups of transfer pricing documentation. The CbC report is one element of a new three-tiered standardized approach to transfer pricing documentation proposed under BEPS Action 13. Under the framework,… – Continue reading
