Category: Related party Transactions

Business / Canada / Compliant / Controlled Foreign Companies / Corporate Tax / Insurance / Related party Transactions / Tax Authority / Transfer pricing

Canada: The Importance Of Tax Due Diligence When Buying A Business

Published by: Mondaq - July 8, 2022

Buying a business is rarely a straightforward decision. In order to get the most out of a potential deal, buyers need to be aware of key risks and pitfalls so they can incorporate mitigation strategies into their deal negotiations. The challenge for buyers is ensuring that no significant risks are missed when making their assessment. This can be difficult, particularly when buyers focus primarily on quality of earnings analyses or other non-financial and tax diligence reviews. ... - Continue reading

Canada / Canada Revenue Agency / Government Bodies / Related party Transactions / Transfer pricing

Canada: COVID-19 Just Made Transfer Pricing More Difficult

Published by: Mondaq - October 28, 2020

The COVID-19 pandemic has made the lives of hundreds of millions of people around the world uncertain, wreaking havoc on all aspects of our daily lives. Governments and taxing authorities are grappling with not only how to keep the broader macroeconomy viable over the short run, but also how to bring the economy back to fiscal balance in the medium and longer term. In an article published by the Gowling WLG Transfer Pricing & Competent Authority Group entitled "CRA Audit Activity: The Calm before the Storm?", it was hypothesized that the Canada Revenue Agency ("CRA") would likely step up audit activity, after the COVID-19 episode is finally behind us, to reign in government deficits. ... - Continue reading

Business / Jurisdiction / Multinationals / OECD / Philippines / Profit Shifting / Related party Transactions / Tax Collection / Transfer pricing

Enhanced transfer pricing regime amidst the pandemic

Posted On: August 31, 2020

Globally, the coronavirus disease 2019 (Covid-19) pandemic is requiring governments to design and implement strategies to cope with the deepening impact of the virus. They are introducing measures to cushion the blow from the economic downturn, such as drawing from reserves and intensifying tax collection efforts. As entire countries and… – Continue reading

Australia / Debt / Directors / Income Tax / Interest / Interest Rate / Multinationals / Qatar / Related party Transactions / Revenue / Royalties / Tax Avoidance / Tax Deductions / Tax Haven / USA

Chevron: a game-changer for multinational tax avoiders

Posted On: April 24, 2017

The Australian Tax Office had a superb win against Chevron in the Federal Court last week, but there is something everyone is missing, something that will turn the art of tax avoidance on its head; a game-changer for multinationals. Put simply, Chevron borrowed US$2.5 billion in the US at less… – Continue reading

Controlled Foreign Companies / Internal Revenue Service (IRS) / Legislation / Offshore Companies / Offshore Tax Evasion / Property / Related party Transactions / Tax Laws / USA

Combatting Foreign Tax Evasion With New Filing Requirements for Foreign-Owned Disregarded Entities: Tax Update, Volume 2017, Issue 2

Posted On: March 13, 2017

The new regulations expand the filing requirements for Form 5472 to include disregarded entities with foreign owners when there are certain reportable transactions. If a non-U.S. person (individual or corporation) owns 100 percent of the stock of a U.S. corporate subsidiary, the subsidiary needs to obtain an employer identification number… – Continue reading

Business / China / Intragroup Services / Jurisdiction / Legislation / Multinational Corporations / Related party Transactions / Transfer pricing

Transfer Pricing in China

Posted On: February 27, 2017

Transfer pricing—the price charged for intercompany transactions between entities in different tax jurisdictions—can be used to shift funds within a multinational corporation (MNC), and serves as an effective means to manage a firm’s finances. Transfer pricing—the price charged for intercompany transactions between entities in different tax jurisdictions—can be used to… – Continue reading

Base Erosion & Profit Shifting / Budget / Corporate Tax / Corporates / Debt / Dividends / India / Interest / Legislation / Mutual Agreement Procedure / Related party Transactions / Transfer pricing

Abusive Tax Structures, Make Way For Budget 2017’s Transfer Pricing Combat Weapons

Posted On: February 1, 2017

Among other things, Union Budget 2017 will be remembered for two firsts – the introduction of secondary adjustment and thin capitalisation rules. Both are transfer pricing provisions which will have a far-reaching impact on corporates. Secondary Adjustment Since the concept of secondary adjustment is introduced for the first time in… – Continue reading

Base Erosion & Profit Shifting / Earnings stripping / G20 / Germany / Income Tax / Income Tax Act / Jurisdiction / OECD / Offshore / Related party Transactions / Royalties / Tax Authority / Tax Deductibility / Tax Evasion / Tax Planning

BEPS – Germany on the way to limit the tax deductibility of royalties

Posted On: January 23, 2017

A new legislative approach of the German tax authorities leaked last December 19 will have a significant impact on the tax deductibility of royalties owed to related persons being subject to a preferential back end tax regime for IP not being in compliance with the Organisation for Economic Co-operation and… – Continue reading

Advance Pricing Agreement / Arbitration / Double Taxation / Income Tax / Jurisdiction / Legislation / Mutual Agreement Procedure / Nigeria / OECD / Regulatory / Related party Transactions / Revenue / Tax Authority / Tax Dispute / Tax Laws / Tax treaties / Transfer pricing

Dispute resolution under the Nigerian transfer pricing regime

Posted On: November 16, 2016

Background The Federal Inland Revenue Service [FIRS] has begun Transfer Pricing [TP] audits and has been requesting TP documentation and other documents from taxpayers relating to their related party transactions. These actions are in line with its powers under the Income Tax (Transfer Pricing) Regulations No. 1 of 2012 [Regulations]… – Continue reading

Business / Debt / Exemptions / Fees / Government Bodies / Investments / Legislation / Related party Transactions / Revenue / Tax Evasion / Transfer pricing / VAT / Vietnam

Vietnam Set to Update Transfer Pricing Thresholds from 2017

Posted On: November 7, 2016

Vietnam’s Ministry of Finance released a draft circular on October 11th which, if passed, is set to become the largest change to transfer pricing (TP) regulation since the implementation of Circular 66/2010/TT-BTC in 2010 – which the draft updates. Touching on conditionality of TP exemption and thresholds for defining related… – Continue reading

Adidas / Business / Coca-Cola / Interest / Loans / Multinational Corporations / PepsiCo / Related party Transactions / Tax Evasion / Tax Fraud / Transfer pricing / Vietnam

Vietnam plans new transfer pricing rules to curb tax fraud

Posted On: October 5, 2016

Various agencies are expected to work together to draft a decree and keep the practice in check. In a move that signals Vietnam’s apparent stronger stance against tax evasion, the Ministry of Finance has sought to work with other ministries and agencies to draft a new decree on transfer pricing… – Continue reading

Base Erosion & Profit Shifting / Business / China / Country-by-Country (CbyC) Reporting / Framework / Income Tax / Investments / Non-resident Enterprises / OECD / Related party Transactions / Revenue / Tax Avoidance / Tax Collection / Transfer pricing

China Introduces Sweeping New Transfer Pricing Rules

Posted On: September 19, 2016

China’s State Administration of Taxation (SAT) issued the Announcement on the Administration of Related-party Transactions and Contemporaneous Documentation (SAT Announcement [2016] No. 42), which introduces a three-tiered documentation framework that will replace its current transfer pricing documentation rules. The June 29 announcement followed the publication of the opinion-seeking draft by… – Continue reading

Aldi / Australia / Australian Taxation Office / BHP Billiton / Business / Corporate Tax / Fairfax Media / Multinationals / Property / Related party Transactions / Rio Tinto / Statutory / Tax Arrangement / Tax Avoidance / Tax Planning

Wesfarmers urges Aldi to sign tax code in ‘corporate peer pressure’

Posted On: August 15, 2016

Coles has urged its German rival Aldi to sign up to a new tax transparency code that will lead to more big businesses, particularly multinationals, releasing detailed information about the tax they pay. Aldi has yet to sign up to the Voluntary Tax Transparency Code, which targets more than 1500… – Continue reading

Africa / Business / Corporate Tax / Ghana / Income Tax / Jurisdiction / Mining Companies / OECD / Related party Transactions / Revenue / Royalties / South Africa / Transfer pricing

Ghana losing tax revenue to extractive sector over lack of data

Posted On: July 8, 2016

The absence of adequate data on the operations of businesses in the extractive sector continues to impede the GRA’s ability to fully implement Ghana’s transfer pricing policy. According to the Deputy Commissioner in charge of Policy Programs at the GRA, Edward Gyamerah, the issue makes it difficult to fully assess… – Continue reading

Asia / Australia / Australian Taxation Office / Bahrain / Base Erosion & Profit Shifting / Beijing / Bermuda / Budget / Business / Canada / China / Common Reporting Standard / Corruption / Debt / DTA / Framework / G20 / Germany / Goods and Services Tax / HM Revenue & Customs / Hong Kong / Iceland / India / Indonesia / Interest / Israel / Japan / Korea / Lebanon / London / Malaysia / Multilateral Competent Authority Agreement / Nauru / New Zealand / OECD / Panama / Permanent establishment / PWC / Regulatory / Related party Transactions / Revenue / Singapore / Tax Evasion / Tax Laws / Transfer pricing / United Kingdom / Vanuatu / Withholding Tax

Global Tax Update – June 2016

Posted On: June 1, 2016

Asia Pacific The January – March edition of tax highlights for the Asia Pacific region highlights industry developments from Australia, China, Hong Kong, India, Indonesia, Korea, Malaysia and Singapore including: Australia’s new tax system for Managed Investment Trusts The final stage of China’s B2V reform to be rolled out from… – Continue reading

Asia / Base Erosion & Profit Shifting / Business / China / OECD / Related party Transactions / Revenue / Royalties

Transfer Pricing in China 2016 – New Publication from China Briefing

Posted On: May 13, 2016

Transfer Pricing in China 2016, the latest publication from China Briefing and Dezan Shira & Associates, is out now and available for purchase through the Asia Briefing Bookstore. Transfer pricing is a reality for any multinational company. As a result of a globalized economy and increasing complexity in business models,… – Continue reading

Base Erosion & Profit Shifting / Corporate Tax / OECD / Related party Transactions / Revenue / South Korea / Transfer pricing

S Korean Companies Unprepared For BEPS: Survey

Posted On: March 23, 2016

The Federation of Korean Industries (FKI) has disclosed that 81 percent of respondents to a survey of South Korean companies professed that, although they were aware of the OECD’s base erosion and profit shifting (BEPS) project, they were not, as yet, making any preparations. The South Korean Government is preparing… – Continue reading

Bahrain / Beneficial Ownership / British Virgin Islands / Business / Canada / Directors / Hong Kong / India / Interest / Inversion / Isle of Man / Jersey / Jurisdiction / Offshore Tax Haven / Panama / Related party Transactions / Shares / Trust / Trustee / UAE / United Kingdom

Vijay Mallya’s secrets buried in offshore tax havens

Posted On: March 9, 2016

It’s not just the Indian banks that business tycoon Vijay Mallya has taken for a ride. The chairman of United Breweries (UB) group and promoter of now defunct Kingfisher Airlines also concealed in his election affidavit, filed before the Rajya Sabha, his business interests in offshore tax havens elsewhere. dna… – Continue reading

Business / Corporates / Cyprus / Dividends / Employment / EU / Exemptions / Fees / Immovable Property / Individuals / Legislation / OECD / Offshore / Permanent establishment / Related party Transactions / Residence / Shares

CYPRUS TAX UPDATE

Posted On: January 12, 2016

On 10 December 2015 the remaining changes to the income tax and the capital gains tax laws aiming to improve the tax system of Cyprus and make it more attractive to both the local and international business community were voted. The changes came into effect with their publication in the… – Continue reading

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