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Get updated on news on Transfer Pricing, including Press Releases, recent developments on BEPS, TP Software Solutions, Value Chain Analysis, global TP events, and other significant changes in global tax legislation. To search on a topic, just use Ctrl-F in your browser for the best result. Using our Search option will provide you side wide search results (in addition to any news topics).

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Global Tax Controversy - Workshop for Corporates
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June 21st, 2018
The BEPS Action Plans, in an attempt to tackle extreme cases of tax evasion, have inevitably blurred the line between strategic tax planning and fraudulent tax evasion for corporate taxpayers. This, coupled with latest publications of the OECD on ‘Fighting Tax Crime’ where taxpayers’ rights find a bleak mention as ‘ suspects’ rights ’ has given force to many governments to enact a number of aggressive (and often, unjust) regulations.
Shell Defends 7 Billion Tax Bill From Dutch Government
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June 19th, 2018
Shell is exposed to a potential €7 billion tax payment, which is a possible consequence of a state aid. Paul Tang, a Dutch member of the European Parliament, requested European Commission to investigate a controversial deal that Dutch government made with Shell in 2005, which exempts the UK-based shareholders from dividend tax in the Netherlands and has cost Dutch treasure loss over 7 billion euros.
US Tax Reform Blamed For Encouraging Avoidance And Creating Top 1 Haven
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June 19th, 2018
The fact that many big US companies enjoy a significantly lower tax rate than that in previous year makes US Tax Reform be blamed for encouraging such tax avoidance practice. The recent effect seems to deviate from dissuading US companies moving profits overseas, which is in part the initial goal of the Tax Cuts and Jobs Act (TCJA).
Ireland Issues Guidance On Mandatory Disclosure Rules
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June 19th, 2018
The Irish Revenue issued a new Tax & Duty Manual related to the Directive regarding mandatory exchange of information in relation to reportable cross-border arrangements (DAC6). The manual provides a general overview of the scope of DAC6 and emphasizes that the Directive comes into force on June 25, 2018.
G7 Leaders Agree On Collaboration To Tax Digitalized Economy
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June 14th, 2018
The Leaders of the G7 met in Charlevoix, Quebec, Canada to discuss common issues on investing in growth, environment protection, etc. The Charlevoix G7 Summit Communique has been published by the Japanese government, in which the leaders agreed on joint efforts to tackle tax challenges brought by digitalization of economy.
SAT Clarifies Corporate Tax Deduction For Shared Service Among Related Parties
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June 14th, 2018
The State Administration of Taxation issued a Bulletin (SAT Gong Gao [2018] No.28) to clarify what kind of accounting documents may be used for corporate tax deduction purpose.
TTI Achieves SAP Integration Certification For Its ERP2Tax Product
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June 13th, 2018
Tax Technologies, Inc. (TTI), a U.S. provider of high-end corporate income tax software serving large corporate customers and TPA Global Member , announced this week that its ERP2Tax, version 1.0, has achieved certified integration with the SAP® ERP application.
Reducing The Cost Of Transfer Pricing Compliance For MNEs
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June 13th, 2018
Many countries have become more focused on combating tax avoidance. As such, transfer pricing compliance has become much more burdensome due to substantial documentation requirements and multiple filing deadlines.
Switzerland Is Recommended To Rectify Withholding Tax Rules
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June 13th, 2018
The Swiss Federal Council was informed about the recommendation on a reform of withholding tax from the advisory board for the future of the Swiss financial centre.
Three Options .
EU: New Directive To Punish Money Laundering Criminals
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June 13th, 2018
The EU Council (at ambassadors' level) confirmed the agreement reached between the Bulgarian Presidency and the Parliament on new rules on using criminal law to counter money laundering. Member states will transpose it into national law within 24 months after the linguistic revision is done.
2018 TP Country Summary Updates
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June 12th, 2018
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical Transfer Pricing Country Summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
Austria (NEW) .
How to run Value Chain Analysis in 2018? - 3 Practical Case Studies
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June 7th, 2018
With the mandatory filing and automatic exchange of CbC reports that has been implemented by a number of countries, most MNEs have filed CbC reports with 2016 data and will file 2017 data before the end of this year. CbC Reporting is intended to provide increased transparency to tax authorities by providing a breakdown of where a MNE recognizes revenues and profits, the taxes paid on such profits, and certain other economic data such as tangible assets and headcount.
Italy Consults The Public On Digital Tax
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June 7th, 2018
The Department of Finance in Italy has opened a public consultation on two directives and a recommendation released by the EU Commission the taxation of the digital econom y . All interested parties are asked to comment on each of the documents proposed.
UN Urges To Plug Tax Loopholes Before Fighting Illegal Financial Flows
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June 7th, 2018
The annual meeting of UNCTAD in Geneva (Switzerland) looked at plugging the financial leakages as one of the most effective ways to help the governments to raise additional revenue and fund the trillion-dollar investment projects associated with the UN-endorsed 17 Sustainable Development Goals (SDGs).
Plugging Tax Loopholes .
Switzerland Proposes To Amend Anti-Money Laundering Legislation
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June 7th, 2018
The Swiss Federal Council started the consultation procedure on amendments to the Anti-Money Laundering Act (AMLA). The consultation will last until 21 September 2018.
Suite 2020 - You Are in Control!
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June 6th, 2018
With the introduction of BEPS, tax and transfer pricing compliance is no longer straightforward. MNE’s are facing more and more challenges to manage tax risks in a growing number of jurisdictions.
UN Consults The Public On Updating TP Manual
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June 5th, 2018
The UN Tax Committee published an invitation for input into the next update of the UN Practical Manual on Transfer Pricing for Developing Countries from all Manual users. Comments and feedbacks should be submitted in written format no later than 10 September 2018.
Amazon Responds To Australian Tax Action By Geo-blocking Australian Users
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June 5th, 2018
The US online retailing giant, Amazon, has announced that Australian shoppers had no longer access to its international e-commerce website, Amazon.com, from June 1. This change results from a new sales tax levied by Australian government.
Japan Comments On Central Corporate Services In New TP Guidelines
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May 31st, 2018
The Japanese Ministry of Finance has revised the administrative instructions on transfer pricing that takes place in, among other things, the central corporate services performances. In principle, these changes are in line with the OECD BEPS reports of October 2015.
EU Proposes To Fight Against Fraud With €181 Million Budget
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May 31st, 2018
The EU Commission announced the budget plan for the next long-term during 2021-2027. In order to support Member States' efforts to fight fraud, corruption and other irregularities affecting the EU budget, the Commission proposes a new EU Anti-Fraud Programme by making €181 million available to finance targeted training and the exchange of information and best practice between anti-fraud enforcers across Europe.
Australia To Kick Off Corporate Tax Cut Plan
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May 31st, 2018
It has been confirmed by Mathias Cormann, the Finance Minister in Australia, that a new company tax legislation and an income tax package will be submitted to the Senate before parliament rises in late June. Under the new package, the government proposes to cut the company tax rate from 33% to 25%.
Tax Agreement Between Hong Kong And Finland Signed
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May 29th, 2018
Hong Kong (China) and Finland signed a comprehensive agreement for avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (hereinafter as “the agreement”). This agreement will come into force on the 30 th day after both contracting parties notify the completion of their domestic ratification procedures and the Double Taxation Agreement with respect to Taxes on Income from Aircraft Operation signed in 2007 will cease to have effect.
EU Removes Bahamas And Saint Kitts And Nevis From Its Blacklist
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May 29th, 2018
The Council of the European Union removed the Bahamas, Saint Kitts and Nevis from the EU’s list of non-cooperative tax jurisdictions which is established for preventing tax fraud and is promoting good governance worldwide. Accordingly, 7 jurisdictions remain on the list, including American Samoa, Guam, Namibia, Palau, Samoa, Trinidad and Tobago and the US Virgin Islands.
What The Boardroom Needs To Know About Tax Today
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May 28th, 2018
In today’s world the OECD, and as a consequence a multiple of tax authorities, requires the tax operating model of any multinational to be 100% aligned with the people that create the value for this multinational. In essence, economic reality is the main driver.
UN Releases 2017 Edition Of Tax Model Convention
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May 24th, 2018
After the 16 th Session of UN Committee of Experts on International Cooperation in Tax Matters in New York during May 14 to 17, the United Nations updates the 2017 UN Model Double Taxation Convention between Developed and Developing Countries (UN MC).
2017 Update .
Tax Cooperation On “One Belt One Road" Initiative Removes Trade Barriers
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May 24th, 2018
The Conference on Tax Cooperation within the framework of the " One Belt One Road " Initiative was held by the tax agencies of China and Kazakhstan and the OECD from May 14 to 16. Delegates from over 50 countries, regions and international organizations arrived in Astana, the capital of Kazakhstan, to attend the conference.
Ireland Explains How To Implement Automatic Exchange Of Information
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May 24th, 2018
The Irish Revenue released three Manuals on implementing the automatic exchange of information. The new guidance replaces the former respective documents.
How Much Automation of Tax Flows Is Possible?
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May 22nd, 2018
Technology is developing at the speed of light, and it is sometimes difficult to keep up with new features available in the market. Meanwhile, software sales people are knocking at the door and promising magic solutions that will solve all the problems.
US Tech Giant Starts Paying €1.5 Billion For EU Bill And Relocates Data Centre
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May 22nd, 2018
Apple has deposited its first payment of €1.5 billion in an escrow account in response to the €13 billion Irish tax bill due to violation of State Aid made by the European Commission.
UN Decides To Launch Its Own Digital Economy Tax Proposal
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May 22nd, 2018
The United Nations (UN) has made up its mind to conduct its own research on tax matters of the digitalized economy. This decision was made by the UN Committee of Experts on International Cooperation in Tax Matters on its sixteenth session during May 14 to 17 in New York.
EU Adopts New Rules On Money Laundering
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May 18th, 2018
The Council of the European Union adopted a directive strengthening EU rules to prevent money laundering and terrorist financing. This is the follow-up work of the political agreement reached last December by the Presidency and the European Parliament .
Italy Issues Transfer Pricing Decree In Compliance to BEPS Action 8-10
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May 18th, 2018
The Minister for the Economy and Finance of Italy issued the Decree of Transfer Pricing Guidelines to cross-border transactions between associated companies. It implements the provision contained in Article 59, paragraph 1 of the Decree Law of April 14, 2017 n.
Chardan And ICBCFS Got US Fine On Breaching Anti-Money Laundering Rule
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May 18th, 2018
The Securities and Exchange Commission (SEC) in the US has settled charges against Chardan Capital Markets and Industrial and Commercial Bank of China Financial Services (ICBCFS) for failing to file suspicious activity reports (SARs).
The Actions by SEC and Its Findings .
The Netherlands Publishes New Transfer Pricing Decree
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May 15th, 2018
The Netherlands published a new Transfer Pricing decree, in place of the decision of November 14, 2013, no. IFZ 2013 / 184M, providing further details on the application of the arm’s length principle.
Switzerland Adopts Dispatch On AEOI With Financial Centres Including Hong Kong And Singapore
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May 15th, 2018
The Swiss Federal Council adopted the dispatch on approving the agreements on the automatic exchange of financial account information (AEOI) with Singapore and Hong Kong. The Federal Council is proposing the introduction of the AEOI with other financial centres to Parliament with the same dispatch.
OECD Consults The Public On Revising Transfer Pricing Guideline
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May 11th, 2018
OECD indicated the intention to commerce two new projects to revise the guidance in Chapter IV (administrative approaches) and Chapter VII (intra-group services) of the Transfer Pricing Guidelines. Interested parties are invited to send their comments no later than June 20, 2018.
Switzerland For The First Time Shares Advance Tax Rulings Information
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May 11th, 2018
The Federal Tax Administration (FTA) in Switzerland has for the first time transmitted information on advance tax rulings to spontaneous exchange of information partner states. For the first batch, Switzerland has transmitted 82 reports to a total of 41 states, including France, Germany, the United Kingdom, the Netherlands, and Russia.
Readiness for Country by Country Reporting
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May 10th, 2018
Is your company up to date with the CbC challenges and risk analysis?
With the mandatory filing and automatic exchange of CbC reports that has been implemented by a number of countries, most MNEs have filed CbC reports with 2016 data and will file 2017 data before the end of this year. CbC Reporting is intended to provide increased transparency to tax authorities by providing a breakdown of where a MNE recognizes revenues and profits, the taxes paid on such profits, and certain other economic data such as tangible assets and headcount.
Australia Reveals New Tax Incentives Including Crackdown on R&D
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May 9th, 2018
The Australian government has used its 2018-19 Budget to announce a crackdown on research and development (R&D) tax incentives. Australian Treasurer Scott Morrison said he would unveil new proposals for taxing multinational digital companies within weeks.
Pakistan - Senate Approves 5% Tax Tech Giants’ Revenue And CFC Rule
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May 8th, 2018
The Pakistani Senate Standing Committee on Finance approved three revisions suggested by the OECD for revising fiscal laws on digital economy taxation.
Dr Mohammad Iqbal, Policy Member of the Federal Board of Revenue (FBR) announced that the changes would lead Pakistani law to be compliant with OECD regulations.
Ireland Issues Country-by-Country Reporting Manual
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May 8th, 2018
The Irish Revenue released a new Tax and Duty Manual on Country-by-Country Reporting (CbCR). The manual responds to some frequently asked questions on the interpretation of the CbCR legislations in Ireland.
Switzerland Places Itself The Blockchain Capital of the World
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May 3rd, 2018
After the 20% decrease in the banking institution number during past decades, Switzerland has put forward a new plan to battle against this loss. Johann Niklaus Schneider-Ammann, the Swiss Minister of Economic has indicated to support the in-country cryptocurrency startups and transform the country into the “Blockchain Capital of the World.
France Intends To Quit Its 30% Exit Tax In 2019
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May 3rd, 2018
President Macron of France indicated in an interview for Forbes the planning to attract foreign investment and boost business by abolishing the French exit tax. The policy is expected to be landed in 2019.
US Highlights Sharing Economy Tax For Small Business
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May 3rd, 2018
As from April 29 to May 5, 2018, the Inland Revenue Service (IRS) in the US holds the alleged National Small Business Week to coach small business owners and the self-employed on identifying their tax liability and enhancing tax compliance, considering there are new tax law changes enacted last December affecting them. Typically, the IRS highlights the sharing economy tax.
2018 TP Country Summary Update - Germany
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May 1st, 2018
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical Transfer Pricing country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
TP Country Summary Germany .
ECOFIN - Oncoming EU Efforts To Tackle Tax Fraud And Challenges Brought By Economy Digitalization
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May 1st, 2018
The Economic and Financial Affairs Ministers (ECOFIN) held an informal meeting in Bulgaria. Documents regarding the meeting have been available to the public, indicating oncoming efforts on the Union level to tackle tax fraud and challenges brought by economy digitalization.
Canada Takes A Step Forward On Digital Economy Tax
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May 1st, 2018
The Canadian Standing Committee on International Trade recently published a policy report on E-commerce. The recommendations on taxing the online platform are getting considerable attention.
Apple And Ireland Tax Appeal To Be Heard This Autumn
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April 26th, 2018
Irish Finance Minister Paschal Donohoe indicated that the appeal by Ireland and Apple against the EU Commission is to be heard this autumn, with the first hearing commencing in September. The Appeal pertains to the State Aid recovery of 13 billion euros from Apple, which was decided by the Commission in 2016.
EU To Harmonise Online Incorporation And M&A Activities
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April 26th, 2018
The EU Commission proposed new company law rules, aiming at digitalising the incorporation procedure and harmonising the merger, division and re-establishment of an enterprise within the Single Market. The new proposal is expected to curb abuse for undue tax benefit and protect legitimate interests of the interested parties, including employees, shareholders and creditors.
Dutch Dividend Tax Abolition Arises Fierce Debate
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April 26th, 2018
The Dutch government released 12 memo files of over 50 pages in total, outlining the decision-making process to abolish the Dutch dividend tax. However, this does not ease the political pressure on the Dutch Prime Minister Rutte, as already last October, the Netherlands proposed to abandon the withholding tax on dividend of domestic source to lighten tax burden on tax payers.
Hong Kong To Triple R&D Incentives
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April 24th, 2018
The Hong Kong government gazetted the Inland Revenue (Amendment) (No. 3) Bill 2018. The Bill draft provides an enhanced tax deduction for expenditure incurred by enterprises on qualifying research and development (R&D) activities.
EU Rail Giants With Irish Hubs For Avoidance Purposes Are Targeted
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April 24th, 2018
A group of railway giants with operation in Europe have been brought to light about employing Irish hubs to circumvent their domestic tax liability. By transferring significant value of assets to Irish subsidiaries and signing leasing contract, the rail companies managed to lighten their overall tax burden and hoarding huge profits in the lower-tax jurisdiction, namely, Ireland.
2018 TP Country Summary Update - UK and India
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April 24th, 2018
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical Transfer Pricing country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
TP Country Summary UK TP Country Summary India .
China To Levy 187.6% of Anti-Dumping Premium On US-Origin Grain Sorghum
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April 24th, 2018
The Ministry of Finance (MoF) in China recently issued a Circular, announcing to collect anti-dumping duties on the import of grain sorghum with US origin. This Circular follows up of the dumping investigation opened this February, with a preliminary decision provided in the attachment.
TPA Global Opens Regional Hub In The Philippines
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April 20th, 2018
TPA Global B.V., a leading independent provider of global support solutions to multinational corporations ranging from tax, transfer pricing, business restructuring, strategy setting and valuation services, is proud to announce the opening of its regional hub in Manila, the Philippines.
The expert hub in the Philippines places TPA Global in a strategic location to work with and provide services to its clients in the Asia-Pacific region.
Hong Kong To Exchange Financial Account Info In Tax Matters Soon And Expanding CDTAs With One-Belt-One-Road Countries
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April 19th, 2018
James Lau, the Secretary for Financial Services and the Treasury in Hong Kong, announced the plan for Hong Kong to implement Automatic Exchange of Financial Account Information in Tax Matters and further expand its Comprehensive Avoidance of Double Taxation Agreements (CDTAs) network. The Secretary also indicated that Hong Kong is not going to expand its tax base considering the healthy fiscal reserve held currently by the Government.
OECD And IGF Consult Mining Sectors on BEPS Issues In Developing Countries
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April 19th, 2018
It has been noted that multinationals frequently employ excessive interest deductions as a conduit to transfer their profits out of the minor jurisdictions. On April 18, 2018, OECD and Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF) jointly issued a discussion draft on Limiting the Impact of Excessive Interest Deductions on Mining Revenues.
Blockchain - The New Future Of Supply Chain?
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April 18th, 2018
Do you know about blockchain? And do you know what the blockchain technology is and how it works? Most persons answer “yes” to the first question, but when it comes to the basics of how blockchain works, people seem to be in the dark. In the media the blockchain technology is said the be ‘’the next big thing’’ and that it is ‘’the technology that will change the world’’.
UK - HMRC Releases Proposed Changes To Implement The MLI
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April 17th, 2018
HMRC released a Guidance on the upcoming implementation of the Multilateral Instrument (MLI), which has not yet come into force in UK. The Guideline includes two documents, that is (1) Provisional List Of UK Reservations And Notifications Under The MLI As Made At Signature , and (2) Proposed Changes To The Provisional List of UK Reservations And Notifications Under The MLI As Made At Signature .
EU Digital Economy Tax Gains Traction From The US
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April 17th, 2018
The digital economy tax proposal put forwarded by the EU Commission, including a 3% sales tax on certain transactions and a virtual permanent establishment reform , is held back by the United States. The US indicates to bring the EU proposal before the tribunal of the World Trade Organization.
India To Enhance Transparency By Exchanging Rulings Under BEPS Action 5
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April 12th, 2018
The Central Board of Direct Taxes (CBDT) announced a proposing amendment to domestic law (rule 44E, Form 34C, 34D and 34DA) based on recommendations in BEPS Action 5. This revamp intends to improve transparency regarding tax rulings.
UK Consults The Public On Tax Avoidance Involving Profit Fragmentation
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April 12th, 2018
On April 10, 2018, the Her Majesty's Revenue and Customs (HMRC) opens a public consultation on an anti-avoidance legislation draft, which tackles tax avoidance by moving UK profits outside the charge of UK tax with offshore trusts and companies. The new legislation is expected to enact in April 2019.
China Slightly Reduces VAT Rate
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April 12th, 2018
The State Administration of Taxation in China released a Circular (Cai Shui [2018] No.32), announcing a reduction to the current Value Added Tax (VAT) rate since May 1, 2018.
How Is The International Tax And Transfer Pricing Landscape Evolving In India?
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April 11th, 2018
India has an observer status with OECD, represents G20 countries and is an active participant in OECD’s initiatives. India has applied several BEPS recommendations in last few years, namely signing of Multilateral Instruments, introduction of Country by Country Reporting (CbCR), Master file, secondary adjustments, GAAR, thin capitalisation rules, reinforcing substance requirement in the tax statute with inclusion of Significant Economic Presence there.
Singapore Activates AEOI Relationships With Panama, China And Malaysia
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April 10th, 2018
The Ministry of Finance in Singapore has announced that the country has activated three new Automatic Exchange of Financial Account Information (“AEOI”) relationships with China, Malaysia and Panama for exchange in 2018. So far, there are 64 jurisdictions and regions having established the AEOI relationship with Singapore for the first exchange to take place in 2018.
Africa Suffered A Financial Leak Of $1.4 Trillion During The Past 30 Years
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April 10th, 2018
Logan Wort, the Executive Secretary of African Tax Administration Forum (ATAF) has recently disclosed that the amount outflowing from Africa ranges from $1.2 trillion to $1.4 trillion since 1980 to 2009 due to illegal financial practice, mostly tax evasion and tax avoidance.
UK Opens Inquiry On Improper Tax Practice
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April 5th, 2018
The Treasury Committee in the UK recently opened an inquiry on Tax Avoidance and Evasion. With the investigation, the government hopes to examine what progress has been made in reducing the amount of tax lost to avoidance and offshore evasion and whether HMRC has the resources, skills and powers needed to bring about a real change in the behaviour of tax dodgers and those who profit by helping them.
IMF Announces Luxembourg Tax System Fragile To External Uncertainty
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April 5th, 2018
The International Monetary Fund (IMF) released a report on Luxembourg’s economic outlook and assessment of possible risks. In the report, the IMF points out that both the tax system of the country and the incentives are fragile and less durable to potential uncertainties and risk.
Denmark - Tax Authority Turns To Uber Drivers
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April 5th, 2018
Recently, the Demark Authority has issued tax letters to nearly 1200 Uber drivers who are found in avoidance cases during tax year 2014 and 2015. The total amount required by the tax authority reaches 11.
Biggest Beverage Producer Challenges Tax Bill Of 3.3 Billion Dollars In America
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April 3rd, 2018
The biggest beverage producer, Coca-Cola Company, has been tangled with an enormous-figure tax bill. The letter was first sent in 2015 September, in which the company was charged 3.
IRS Issues Guidance On Partnership Interests Transfer Withholding Tax
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April 3rd, 2018
On April 2, 2018, the Treasury Department and the Internal Revenue Service in the United States issued a guidance on the withholding on the transfer of non-publicly traded partnership interests, but exemptions or reductions from the withholding tax is possible for some qualifying cases.
General Tax Treatment .
Round Table Meeting - "How Can You Move From Staying Out of Trouble to Being in Full Control on Tax Matters?"
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April 3rd, 2018
The world of taxation is changing rapidly. It is becoming more and more important for the managing boards, and especially the CFO, to move from a ‘Staying out of trouble’ attitude and adopt a proactive role in the journey towards full control on tax matters.
Russia & Ukraine - 2018 TP Country Summary Update
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March 29th, 2018
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical Transfer Pricing country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
TP Country Summary Russia TP Country Summary Ukraine .
TAX3 Members Exchange Views With Moscovici
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March 28th, 2018
Commisioner Moscovici (Economic and Financial Affairs, Taxation and Customs) had an exchange of views with the Members of TAX3 on issues related to taxation. The Recommendation following the inquiry on money laundering, tax avoidance and tax evasion , published, last December was presented during the meeting as well.
MLI Will Enter Into Force On 1 July, 2018
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March 28th, 2018
The OECD has announced that the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting ('Multilateral Instrument' or 'MLI') will enter into force on July 1, 2018. Up to March 22, 2018, there are 78 jurisdictions in total that have signed the MLI.
UK Updates Anti-Money Laundering Guidance For The Accountancy Sector
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March 28th, 2018
HMRC published the updated Anti-Money Laundering Guidance for the Accountancy Sector, which was firstly issued in August 2008. The latest amendment was from January 2018 and is based on the 2017 Anti-Money Laundering Draft Guidance.
Foreign Direct Investment in Europe: Facilitating Expansion of Your Business
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March 28th, 2018
TPA Global and the One Belt One Road Culture and Trade Promotion Association invite you to participate in our International Conference in The Netherlands,
Foreign Direct Investment in Europe: Facilitating Expansion of Your Business .
TPA Global Forms Alliance With PIRGROUP (The Netherlands)
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March 27th, 2018
PIRGROUP (Partners in Relocation Group) is an award-winning Global Mobility Service Provider with more than 20 years of experience in the immigration and relocation field in The Netherlands. They also service 12 own destinations in the Baltic States, Central and Eastern Europe, Caucasus, Kazakhstan and worldwide.
Profit Allocation in the Pharma Industry—Who Wants a Slice of the Tax Pie?
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March 27th, 2018
As many countries are now fully armed to combat corporate tax avoidance, tax authorities have started insistently claiming their ‘‘fair share’’ of tax income. They all are looking at the same profit, yet aiming to get a bigger piece, if not the whole ‘pie’.
India Budget 2018 – The Road Ahead
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March 22nd, 2018
This informative webinar on major changes proposed in India’s Union Budget 2018 will help you to understand the fine print of some such latest changes and how they could impact your businesses.
Key Highlights of the webinar .
South Africa Announces Substantively Enacted Tax Rates And Tax Laws
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March 22nd, 2018
The Minister of Trade and Industry in South Africa published the final notice on Financial Reporting Pronouncement 1 (FRP 1) which has been issued by the Financial Reporting Standards Council. The notice provides the substantively enacted tax rates and tax laws under IFRS and IFRS for small and medium enterprises.
Singapore Updates R&D Tax Treatment Guidance For Pharma Industry
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March 22nd, 2018
The Inland Revenue Authority of Singapore updates the third edition of the Guidance on Tax Treatment of Research & Development and Intellectual Property-Related Expenditure for the pharmaceutical manufacturing industry, with four types of measures regarding deduction being illustrated. The guidance also provides a visualisation of value chain in the pharmaceutical industry in its Annex A.
India Asks Public Feedbacks On Drafting New Direct Tax Law
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March 22nd, 2018
The Ministry of Finance in India announced that the Central Board of Direct Taxes (CBDT) has established a task force to review the Income Tax Act (1961) and a new Direct Tax Law is expected to be drafted. In order to have the draft fit the current and practical economic needs of the country, the CBDT is aware of the importance of taking suggestions and feedback from stakeholders and general public into consultation and is issuing a questionnaire for public views.
EU Commission Releases New Measures On Digital Economy Taxation
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March 21st, 2018
The European Commission has proposed new rules to ensure that digital business activities are taxed in a fair and growth-friendly way in the EU. The first initiative aims to reform corporate tax rules to capture user created value and forms the Commission's preferred long-term solution; the second proposal responds to calls from several Member States for an interim tax which covers the main digital activities that currently escape tax altogether in the EU.
TPA Global Opens New Offices In Eindhoven and Nijmegen (The Netherlands)
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March 21st, 2018
TPA Global B.V., one of the leading independent providers of global support solutions to multinational corporations ranging from tax, transfer pricing, business restructuring, strategy setting and valuation services, is proud to announce the opening of its new offices in Eindhoven and in Nijmegen, the Netherlands.
Eindhoven .
OECD Releases Digital Economy Taxation Interim Report
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March 19th, 2018
The OECD released the Tax Challenges Arising from Digitalisation –Interim Report 2018 of 8 chapters. This interim report is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project.
Clearly With One Eye On The UK - Dutch Withholding Tax
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March 19th, 2018
The Dutch aren’t big on withholding taxes (WHTs), even less than the UK. There’s no WHT on royalties and WHT on interest is limited to loans that work like equity (so the interest is a proxy for dividends).
Switzerland Issues Position Paper On Taxing The Digital Economy
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March 16th, 2018
The State Secretariat for International Financial Matters (SIF) of Switzerland released a position paper, stating that the digitalised economy should be tax properly without being hindered.
Principles Not to be Undermined .
UK Updates Digital Economy Tax Position Paper And Consults Platform’s Role
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March 16th, 2018
Following the first position paper published in 2017 November, on March 13, 2018, the British government updated the position paper to reflect feedback from stakeholders, explaining in more detail how the government thinks this challenge can be solved. On the same day, the government opened a public consultation on how to tax digital economy effectively with the assistance of digital platforms.
OECD Releases New Peer Reviews Reports And Calls For Taxpayer Inputs
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March 16th, 2018
The OECD released another eight peer review reports, which highlight how well jurisdictions are implementing the Action 14 minimum standards. The BEPS Action 14, as agreed to in the OECD/G20 BEPS Project, is continuing the efforts to make dispute resolution more timely, effective and efficient.
China - 2018 Country Summary Update
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March 15th, 2018
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
Download .
ECOFIN - EU Ministers Negotiate The Draft On Tax Transparency Of Intermediaries
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March 13th, 2018
On the Economic and Financial Affairs Council (ECOFIN) regular meeting in Brussels on March 13, 2018, the Ministers are supposed to reach an agreement on a proposal for greater transparency in tax planning schemes. The proposal intends to deal with tax transparency for intermediaries by mandatory reporting, such as tax advisors, lawyers or accountants, aiming to fight tax avoidance and potentially harmful planning schemes.
EU Blacklist: Bahrain, Marshall Islands, Saint Lucia Are Out, While Bahamas, US Virgin Islands, Saint Kitts Are In
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March 13th, 2018
The EU list of non-cooperative jurisdictions will be further changed based on recent efforts by some countries in the list and latest assessment of the Code of Conduct Group, following the last revision this January to remove eight countries . This list is supposed to be agreed by the Ministers on their monthly meeting in Brussel on March 13, 2018.
Poland - 2018 Country Summary Update
; posted on
March 11th, 2018
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
Download .
How To Reduce Transfer Pricing Compliance Costs?
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March 9th, 2018
As G20 countries have become increasingly aggressive in their aim to combat corporate tax avoidance, full tax transparency is the new norm. The global transfer pricing (“TP”) compliance has become more burdensome due to multiple deadlines and complex documentation requirements.
EU Highlights Seven Member States For Tax Avoidance Risks
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March 9th, 2018
The European Commission released the 2018 European Semester Winter Package, in which economic and social situations are reviewed on a yearly basis. “I want to highlight the fact that for the first time, the Commission is today stressing the issue of aggressive tax planning in seven EU countries: Belgium, Cyprus, Hungary, Ireland, Luxembourg, Malta and The Netherlands”, according to the European Commissioner Pierre Moscovici.
China Enhances Favourable Tax Policy to Corporate Tax Payers in 2018
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March 9th, 2018
Premier Li Keqiang presented the Government Work Report on the First Session of the 13th National People’s Congress in Beijing, reviewing the outcome of government work for last five years and providing suggestions for the coming year. During the press conference after Premier Li’s presentation, the Finance Minister Xiao Jie indicated to enhance the beneficial tax policy to both individual and corporate tax payers.
Australia To Implement Hybrid Mismatch Rules
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March 9th, 2018
The Australian government opened a public consultation on the draft legislation for adopting the OECD recommendations to eliminate double non-taxation benefits from hybrid mismatch arrangements. This intention of the government was firstly announced in the 2016-17 Budgets and repeated in 2017-2018 Budget.
“Future Of Intercompany Financing – Survive or Disappear?”
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March 8th, 2018
A presentation on future of intercompany financing companies after BEPS. As we are all aware, substance is of utmost importance in the post-BEPS world and structures involving financing companies are under scrutiny as well.
Germany Continues Common Corporation Tax With France
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March 6th, 2018
German Chancellor Angela Merkel announced during her weekly podcast that Germany will push forward the cooperation regarding “Common Corporation Tax Plan” with France. The collaboration between the two countries is becoming closer following the US tax reform by President Trump and Brexit.
EU Establishes Special Committee For Financial Crime And Tax Avoidance
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March 6th, 2018
The European Parliament had its plenary session in Brussel, where it established a new 45-member task force to work on the EU’s Special Committee on Tax Rulings. This task force is a response to the Paradise Papers leak in 2017, and it will also contribute to investigations by the Committee of Inquiry into Money laundering, tax avoidance, and tax evasion.
UK Updates Anti-Avoidance Disclosure Guidance & Interest Deduction Limits
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March 2nd, 2018
Her Majesty's Revenue and Customs (HMRC) updated two legislations on making a tax avoidance scheme disclosure and group interest deduction limitation respectively.
Disclosure of Tax Avoidance Schemes: Guidance .
The Netherlands Proposes The Anti-Avoidance Measures Package
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March 2nd, 2018
The Dutch Ministry of Finance released two policy letters to set out priorities in tax matters for until 2021. In the letters, the government announced a package of tax measures to tackle tax avoidance and evasion consisting of the following two pillars.
OECD And Brazil Review Differences In Brazilian Cross-Border Tax Rules
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March 2nd, 2018
The OECD and Brazil launched a joint project to examine the similarities and gaps between the Brazilian and OECD approaches to valuing cross-border transactions between associated firms for tax purposes. The project will also assess the potential for Brazil to move closer to the OECD’s transfer pricing rules.
The UK’s Corporate Offence of Failure to Prevent Facilitation of Tax Evasion
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March 1st, 2018
On 30 September 2017, a new corporate offence came into force in the UK aimed at businesses that fail to prevent the facilitation of tax evasion. The new rules do not change the scope of what constitutes tax evasion in the UK, but puts a requirement on businesses to put in place various preventative procedures.
France To Cut Corporate Tax Rate To 25% By 2022
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February 27th, 2018
The Budget Act for 2018 in France has introduced a series of significant changes to tax treatments of business, including a reduced corporate tax rate, abolition of tax on dividend distributed, more tolerant financial expense deduction, and transfer pricing documentation requirement.
Reduced Corporate Income Tax .
EU Puts Forward Equalisation Levy Of 1%-5% On Tech Giants
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February 27th, 2018
The European Commission is planning to choose a levy on gross revenue to tax the digital giants with operation in Europe, according to a drafting document of the Commission. This proposal is similar to the equalisation levy proposal provided by France, and it is supposed to be published in the second half of this March.
Lithuania - 2018 Country Summary Update
; posted on
February 27th, 2018
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
Download .
Hungary - 2018 Country Summary Update
; posted on
February 27th, 2018
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
Download .
Italy - 2018 Country Summary Update
; posted on
February 26th, 2018
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
Download .
How To Reduce Transfer Pricing Compliance Costs?
; posted on
February 26th, 2018
As G20 countries have become increasingly aggressive in their aim to combat corporate tax avoidance, full tax transparency is the new norm. The global transfer pricing (“TP”) compliance has become more burdensome due to multiple deadlines and complex documentation requirements.
Global Trade Management
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February 26th, 2018
In the ever changing and dynamic world of global trade, customs management and trade compliance management are mandatory prerequisites for a sound and secure supply chain. Companies need customs- and trade compliance management tools to comply with applicable laws and regulations while importing and/or exporting goods across international borders.
UN Tax Committee Publishes Report On 15th Session
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February 22nd, 2018
The Committee of Experts on International Cooperation in Tax Matters of the UN has published the report on its fifteenth session held during last October in Geneva. The Session discussed several substantive issues related to international cooperation in tax matters, including the updating of the UN Model Double Taxation Convention between Developed and Developing Countries, and other issues in tax practice of developing countries, and procedural issues for the Committee.
UK Updates Mutual Agreement Procedure Guidance
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February 22nd, 2018
Her Majesty's Revenue and Customs (HMRC) published the Statement of Practice 1 (2018) to supersede the Statement of Practice 1 (2011). The new statement outlines the mutual agreement procedure (MAP) process and the use of MAP under the relevant UK Double Taxation Agreements and/or the EU Arbitration Convention (EUAC).
EU Releases Consultation Outcome On Digital Economy Taxation Issue
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February 22nd, 2018
The EU Commission released feedbacks from the public on the Fair Taxation of The Digital Economy consultation during October 26, 2017 to January 3, 2018. The public consultation received 446 replies and 121 position papers to further explain views of the repliers.
CFO’s Roadmap | Step 6: Clear/Efficient Communication to Stakeholders
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February 21st, 2018
The world of taxation is changing. The release of BEPS, although driven by a tax motive, has wide ranging implications for a CFO, as it not only demands full transparency on tax sensitive data but also requires a full disclosure of the operational and governance model of the company, in order to check for misalignments between all three. Hence, it is becoming more and more important for a CFO to move away from the ‘’staying out of trouble’’ attitude and adopt a proactive role in the journey towards full control.
Singapore 2018 Budget: Lighter Income Tax And GST On Digital Economy
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February 20th, 2018
The Singapore Finance Minister Heng Swee Keat presented his Budget for Financial Year 2018 to the Parliament. In the statement, Heng announced several tax changes for regional economic promotion.
New Zealand Rectifies Error In Restricted Transfer Pricing Rule
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February 20th, 2018
The Inland Revenue in New Zealand issued a note on revising the drafting error in the Taxation (Neutralizing Base Erosion and Profit Shifting) Bill, which is currently considered by the Finance and Expenditure Committee. Wording in the Bill means that the interest deduction limitation rule applying to cross-border related party loans is not applied as widely as it should.
Azerbaijan Plans Stimulating Policy With Tax Transparency Ensured
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February 15th, 2018
Mikayil Jabbarov, Minister of Taxes in Azerbaijan, announced at the conference on "Taxes - Transparency: Development" that the country intends to pursue a stimulating tax policy, transparency will be ensured in the tax system of Azerbaijan and extensive work is ongoing in this direction.
Economic Image and Tax policy .
UK Updates Business Investment Relief (BIR) Guidance
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February 15th, 2018
HM Revenue & Customs (HMRC) updated the Business Investment Relief (BIR) legislation which was introduced on April 6, 2012. With the amendments, a new category of qualifying target company is added to the target company list.
Germany Tackles 'Goldfinger' Tax Evasion
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February 15th, 2018
Recently, the German authority has raided over 200 private and domestic business presences, where potential risks of tax evasion were highly expected to be detected, with many investors and tax professionals arrested. The arrested were found involved in illegal gold trading to circumvent their tax liability.
India - Budget Analysis 2018
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February 14th, 2018
These are changing times in India with dynamic change happening in every aspect of Indian economic society and fiscal laws are also evolving around such changes in the economy. This budget 2018 has primarily focused its spending on social economic sector of India.
SAT Clarifies Partnership Treatment And PE Criteria For Tax Treaty Purposes
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February 13th, 2018
The State Administration of Taxation issued a Bulletin (SAT Gong Gao [2018] No.11) to clarify several practical issues in implementing bilateral tax treaty signed by China, including the treatment of partnership, the scope of Artists & Sportsman article.
Australia Consults The Public To Toughen The Multinational Anti Avoidance Law
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February 13th, 2018
The Australian government opened a public consultation on a legislation draft regarding implementation issues of the Multinational Anti Avoidance Law (MAAL). The new proposal intends to strengthen the MAAL from inappropriate use of foreign trust or partnership to circumvent the application of the MAAL.
CFO’s Roadmap | Step 5: Manage In-House Challenges (HR, IT and Succession Planning)
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February 12th, 2018
The world of taxation is changing. The release of BEPS, although driven by a tax motive, has wide ranging implications for a CFO, as it not only demands full transparency on tax sensitive data but also requires a full disclosure of the operational and governance model of the company, in order to check for misalignments between all three. Hence, it is becoming more and more important for a CFO to move away from the ‘’staying out of trouble’’ attitude and adopt a proactive role in the journey towards full control.
China SAT Clarifies Beneficial Owner Rules For Tax Treaty Purposes
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February 8th, 2018
The State Administration of Taxation issued a Bulletin (SAT Gong Gao [2018] No.9) to clarify the recognition of “beneficial owners” for bilateral tax treaty purpose.
France And Germany Drive EUTo Tax Digital Economy
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February 8th, 2018
The German coalition government composed of Chancellor Angela Merkel’s conservatives (CDU/CSU) and the Social Democrats (SPD) announced to step forward in the cooperation with France. One intention of this is to establish a pan-European corporate tax scheme to tax the tech giants and tackle tax avoidance through the common corporate tax base and a minimum rate.
India Issues FAQ On Long-term Capital Gain Tax Under Finance Bill 2018
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February 8th, 2018
T he Central Board of Direct Taxes(CBDT) in India released announcement, responding to the frequently asked questions regarding taxation of long-term capital gains proposed in the Budget 2018 (Finance Bill 2018). The budget was presented by the Finance Minister Arun Jaitley on February 1, 2018, which proposed several significant changes in the country’s tax scheme.
BEPS Action Calendar - Are You In Control of Your Compliance Deadlines?
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February 7th, 2018
Multinational Enterprises (MNE) have always been aware and cautious of risks and penalties associated with non-compliance with their filing requirements. But in the post-BEPS world, the risks of compliance without appropriate ‘risk management’ undoubtedly outweigh those of mere non-compliance.
How to Align the Value Creation Factors on the Rubik’s Cube: Techniques to Excel in Value Chain Analysis
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February 7th, 2018
China has made significant contributions in driving forward the roll-out of the G20/OECD BEPS actions. In the last two years, with the release of Bulletin 42 on transfer pricing documentation, Bulletin 64 (1) on advance pricing arrangements (2) , and Bulletin 6 on further developing its transfer pricing regime (3) by the State Administration of Taxation (SAT), China has entered into a new era for combating base erosion and profit shifting through transfer pricing.
Tax Highlights Of Indian Budget 2018
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February 7th, 2018
The India budget 2018 presented by the Finance Minister Arun Jaitley to the parliament has arisen highly attention due to its radical reforming measures, in particular in the field of direct taxation. Alongside a proposed reduction in corporate income tax to 25% for resident companies , there are other tax proposals worthy to be noted.
Bulgarian Presidency Releases Tax Policy Roadmap
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February 6th, 2018
The European Union Presidency of Bulgaria released its roadmap for the coming months on tax issues. Taking into account the latest development in tax practice and governmental negotiations, the roadmap set future work regarding direct taxation and indirect taxation, with both short-term and medium-term proposals.
Australia Publishes Country-by-Country Reporting Guidance
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February 6th, 2018
The Australian Taxation Office (ATO) issued a guidance document on the implementation of Country-by-Country (CbC) reporting in Australia.
Country-by-Country (CbC) Report in Australia
US Equipment Manufacturing Giant Could Face $2B Of Tax Bill From IRS
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February 1st, 2018
Caterpillar, the American Giant specialized in machinery and equipment manufacturing, has been negotiating with the US Inland Revenue Service(IRS) since last March when the officers raided Caterpillar’s offices and warehouses in Illinois. Now it could face a tax bill of 2 billion dollars from the IRS.
India Proposes To Cut Corporate Tax Rate For SME To 25%
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February 1st, 2018
Arun Jaitley, Finance Minister of India, proposed in the 2018 budget that the corporate tax rate for resident enterprises should to be decreased from to 25%, but only companies with annual turnover no more than Rs250 crore (around 31.3million euros) may apply for this policy.
Financial Secrecy List Issued With Switzerland And US
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February 1st, 2018
The Tax Justice Network (TJN), a British research group, released the Financial Secrecy Index - 2018 Results. Jurisdictions are ranked based on their secrecy and the scale of their offshore financial activities without interactions by political factors.
CFO’s Roadmap | Step 4: Align Governance and Operational Conduct (RACI)
; posted on
February 1st, 2018
The world of taxation is changing. The release of BEPS, although driven by a tax motive, has wide ranging implications for a CFO, as it not only demands full transparency on tax sensitive data but also requires a full disclosure of the operational and governance model of the company, in order to check for misalignments between all three. Hence, it is becoming more and more important for a CFO to move away from the ‘’staying out of trouble’’ attitude and adopt a proactive role in the journey towards full control.
Tech Giants Are Paying More Taxes
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January 31st, 2018
Tech companies are not taxed sufficiently under the current tax framework due to their lesser demand on physical hubs. This raised attention from tax authorities globally and many jurisdictions have recently taken measures to collect more tax from the tech giants, such as Web tax in Italy and Cryptocurrency tax in South Korea , while the European Union also launched a proposal introducing “virtual Permanent Establishment” to tackle the digital economy tax issue.
IMF Worries US Tax Cut Reform Disturbs Global Economic Growth
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January 31st, 2018
Christine Lagarde, the Managing Director of the International Monetary Fund, expressed the worrying concern during the World Economic Forum in Davos that the favourable tax reduction under US tax reform could be a threat to the stability of global growth.
Shorter-term Engine but Increased Serious Risk .
'One Stop' Inbound Investment Service to Europe
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January 29th, 2018
With the fast growth of China’s economy and the continuous improvement of the comprehensive strength of domestic enterprises, as well as the implementation of the “One Belt, One Road” policy, an increasing amount of Chinese enterprises are beginning to expand their global footprint and establish their presence in Europe.
Headquartered in Amsterdam, the Netherlands, TPA Global is committed to providing one-stop.
OECD: Six More Jurisdictions Sign The MLI To Strengthen Tax Cooperation
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January 27th, 2018
Six more countries have signed the BEPS Multilateral Convention, namely Barbados, Côte d’Ivoire, Jamaica, Malaysia, Panama and Tunisia. Up to date, the total number of signatories reaches 78.
UK Launched A New Regulator On Anti-Money Laundering
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January 25th, 2018
The British government established the Office for Professional Body Anti-Money Laundering Supervision (OPBAS). The new organisation is housed within the Financial Conduct Authority, and it constitutes part of a wider package of reforms to strengthen the anti-money laundering (AML) supervisory regime in the country.
EU Council Approved To Remove Eight Jurisdictions From EU Blacklist
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January 25th, 2018
The European Council agreed to remove eight jurisdictions from its Non-Cooperative Jurisdiction List, based on an expert assessment by the Code of Conduct Group that commitments made by these jurisdictions to address deficiencies identified by the EU may justify the delisting decision. The alleged EU Blacklist was issued by the EU Council on December 5, 2017, and the countries contained may commit to meet the EU criteria to be delisted.
CFO’s Roadmap | Step 3: Risk Planning & Provisioning, ETR Impact (APAs, Tax Rulings)
; posted on
January 25th, 2018
The world of taxation is changing. The release of BEPS, although driven by a tax motive, has wide ranging implications for a CFO, as it not only demands full transparency on tax sensitive data but also requires a full disclosure of the operational and governance model of the company, in order to check for misalignments between all three. Hence, it is becoming more and more important for a CFO to move away from the ‘’staying out of trouble’’ attitude and adopt a proactive role in the journey towards full control.
Korean Heavy Cryptocurrency Tax Terrifies The Digital Currency Market
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January 23rd, 2018
The Ministry of Strategy and Finance in South Korea announced to impose tax on cryptocurrency exchange, including a 22 percent income tax in addition to a 2.4 percent local income tax. Consequently, this will give rise to a tremendous amount of tax liability to the digital currency exchanges.
IRS Released Five Directives On Transfer Pricing
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January 23rd, 2018
The IRS Large Business and International (“LB&I”) Division released five Directives on new transfer pricing examination procedures and policies. All these Directives enter into force on their publication date.
US Tax Reform – Context, New Tax Concepts, and Impact on Your Business Models
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January 23rd, 2018
US Tax Reform Readiness: Time to Re-evaluate Your Global ETR Plan
In the aftermath of BEPS, US Tax Reform and other evolutions, it is critical that multinational businesses keep pace with regulatory tax developments and how such changes will impact their global ETR plans and business models..
IMF: British Territorial Taxation Largely Boosts ODI In Low Tax Jurisdictions
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January 19th, 2018
The International Monetary Fund (IMF) released the working paper ‘Where Does Multinational Investment Go with Territorial Taxation? Evidence from the UK’. The paper illustrates the outcome of British favourable tax framework on investment, including the influence of UK’s territorial taxation regime and free of dividend tax.
UK Simplified Arrangements On Losses Carried-forward For Group CIT
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January 19th, 2018
HMRC released a notice to announce changes in group relief regulation, under which simplified arrangements are provided for groups to carry forward losses. The new measure will have effect for losses incurred on or after April 1, 2017.
EU Is Delisting Eight Jurisdictions Under Its Tax Haven Blacklist
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January 19th, 2018
The Code of Conduct Group of the European Union proposed to delist eight jurisdictions out of the seventeen from its Non-cooperative Jurisdictions For Tax Purposes , namely, Panama, South Korea, the United Arab Emirates, Barbados, Grenada, Macao, Mongolia and Tunisia.
Background .
Are You BEPS Proof? BEPS 2018 Readiness Test and Report in One Week
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January 17th, 2018
Today tax executives are feeling the heat due to enduring pressure to improve efficiency, grow revenue and ensure control. Increasing tax regulatory requirements are making “being in control” even more challenging.
Slovakia Plans To Tax Digital Platform And Cryptocurrencies Like Bitcoin
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January 16th, 2018
Earlier this month, Peter Kažimír, the Finance Minister in Slovakia announced that the Income Tax Act has been amended to cover digital platforms such as Airbnb, Booking.com and Uber. He also indicates the plan to draft a proposal on taxation of cryptocurrencies, such as bitcoin.
Australia Identifies Over 1000 Taxpayers Based On Paradise Papers
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January 16th, 2018
Since last November when the Paradise Papers were released, the information leak has enabled Australia Taxation Office (ATO) to identify 1075 taxpayers in total during the past two months, with 731 individual taxpayers and 344 corporate entities respectively.
Commoditization of Tax Avoidance Practice for Individuals .
Tax Treaty Between Cyprus And Saudi Arabia Signed
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January 12th, 2018
The Convention for the avoidance of double taxation with respect to taxes on income and for the prevention of tax evasion between the Republic of Cyprus and the Kingdom of Saudi Arabia was signed in Riyadh. The Convention was signed during the official visit of the President of the Republic of Cyprus to Saudi Arabia.
UK Recovers £137m Tax From Tech Giant
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January 12th, 2018
Apple Europe, the wholly-owned subsidiary of Apple in the UK, announced that an agreement has been reached with Her Majesty's Revenue and Customs (HMRC) after the long auditing and negotiation. Under the agreement, Apple accepts the tax adjustment and will recover extra tax of £137 million to the HMRC.
Pakistan Is To Exchange Tax Info With Switzerland
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January 12th, 2018
The Senate Standing Committee on Finance in Pakistan was notified that the country is starting to exchange tax information with Switzerland in January 2018. The process will be carried out under Art.
CFO’s Roadmap | Step 2: Global Tax Compliance (CIT, VAT, MF, CbC)
; posted on
January 12th, 2018
The second step in the journey to be fully in control is the implementation of a global tax compliance approach. After running your financial ratio analysis and selecting the data to be reported for tax purposes, it is also equally important to actually document it in an efficient and compliant manner.
How To Deal With PE Risks In Practice? - A 5-step Approach
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January 11th, 2018
In an attempt to close the loopholes of the existing PE definition through BEPS Action 7, the OECD has, inadvertently, also lowered the threshold for the classification of the local business activities of a foreign enterprise as a PE of such enterprise. It has, in turn, opened the road for many governments to adopt diverse interpretations of Article 7 to attribute additional profit to the local operations of foreign enterprises.
China’s State Administration of Taxation (SAT) issued Bulletin 46 on Clarifying Country-by-Country Reporting Related Issues and Subsequent Interpretation
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January 11th, 2018
The Multilateral Convention on Mutual Administrative Assistance in Tax Matters (Convention) has been launched officially in China since January 1, 2017. In order to ensure appropriate cohesion between the Convention and Bulletin 42 (*) issued by the SAT in 2016, on 19 December 2017, the SAT issued Bulletin 46 to clarify that Article 7 and Article 8 stipulated in Bulletin 42 will not be applicable to the fiscal year (FY) 2016 Country-by-Country report (CbCR).
SAT Clarifies Details And Procedural Requirements To Exempt Foreign Investment Return From Withholding Tax
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January 10th, 2018
The State Administration of Taxation (SAT) issued an announcement (SAT [2018] No.3) clarifying the executive issues on the Circular (Cai Shui [2017] No.
US Disputes Guam & American Samoa To Be Included In The EU Blacklist
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January 10th, 2018
The US Treasury Secretary Steven Mnuchin has recently sent a letter to the EU Secretary General Jeppe Tranholm-Mikkelsen. In the document, the US presents its position in the BEPS project and Global Forum, as well as expressing its counterview on the EU Blacklist of Non-Cooperative Jurisdictions for tax purpose released by the European Council on December 5, 2017.
France Comforts Ireland About The Worries On Its Digital Tax Proposal
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January 10th, 2018
The French President Emmanuel Macron re-affirmed the willing to establish a pan-European tax scheme on digital economy during his New Year's press conference. He also indicated that interests of smaller countries like Ireland, Malta, and Luxembourg are not to be impeded if US tech giants such as Google and Apple are taxed on the Union level.
Australia Consults Public On Diverted Profit Tax Draft Law Companion Guideline
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January 4th, 2018
The Australian Taxation Office (ATO) issued a notice to consult the public on a draft Law Companion Guideline (LCG) on the Australian diverted profits tax. The draft LCG explains how the new law will apply and explains concepts introduced by the measure.
SAT Clarification On Credit Policies On Enterprise Income Tax Outside China
; posted on
January 4th, 2018
The State Administration of Taxation (SAT) and the Ministry of Finance jointly issued an announcement (Cai Shui [2017] No. 84) clarifying the credit policies on the enterprise income tax paid outside China.
EU - New Rules To Prevent Tax Evasion And Money Laundering Enter Into Force
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January 4th, 2018
On January 1, 2018, the new amended rules regarding anti-tax evasion and anti-money laundering came into effect, which obliges Member States to give tax authorities access to data collected under anti-money laundering legislation. The new rules welcomed by the EU Commission are enshrined in the Directive on Administrative Cooperation (Directive 2011/16/EU).
India Signs Three More Advanced Transfer Pricing Agreements
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January 2nd, 2018
During 2017 December, the Central Board of Direct Taxes (CBDT) in India has entered into three more Advance Pricing Agreements (APAs). Up to date, the number of APA entered into force by the CBDT reaches 189, with 173 Unilateral APAs and 16 Bilateral APAs.
Hong Kong Implements BEPS Package To Tackle Tax Avoidance
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January 2nd, 2018
On December 29, 2017, the Inland Revenue (Amendment) (No. 6) Bill 2017 (Amendment Bill) was published in the Official Gazette.
CFO’s Roadmap - Step 1: Robust synchronization of financial data analytics
; posted on
January 2nd, 2018
The first step to being fully in control is obtaining control over your financials and ensuring that they are fully aligned with your operational conduct. This is absolutely essential in the current tax arena as availability of information via CbC reporting and automatic exchange of such information mandates companies to be extremely careful in their selection of reported data.
Italy Is To Open Web Tax Of 3% On Digital Service
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December 21st, 2017
The Budget Commission of Italy’s lower house approved the “web tax” measure. Under this proposal, companies are obliged to pay a 3 percent levy on certain online transactions.
New Zealand Issues Tax System Comparison Report And Sets Up Tax Working Group
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December 21st, 2017
The Inland Revenue (IRD) in New Zealand released the report on the New Zealand tax system and how it compares internationally. On the same day, the IRD also announced members to join Sir Michael Cullen on the Tax Working Group.
EU Revises Anti-Money Laundering Directive By Improving Transparency
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December 21st, 2017
The presidency and the European Parliament reached a political agreement on strengthening EU rules to prevent money laundering and terrorist financing. By amending Directive 2015/849, the revised transparency rules are expected to shed light on the large-scale concealment of funds without hindering the normal functioning of financial markets and payment systems.
US Conference Committee Issues Unified Tax Reform Bill
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December 19th, 2017
Members of the Tax Cuts and Jobs Act (H.R. 1) House-Senate Conference Committee signed the conference report for this legislation. The bill is now moving forward to be voted on 19th or 20th by the entire House of Representatives and Senate.
EU Has Concerns over Dutch Tax Ruling to IKEA as State Aid
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December 19th, 2017
The European Commission announced to open an in-depth investigation into the tax treatment of IKEA in Netherlands. The investigation concerns two Dutch tax rulings granted to Inter IKEA in 2006 and 2011 respectively.
PANA: Debate And Vote On The Final Report
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December 16th, 2017
The PANA committee held a debate on the regulation of financial intermediaries, protection of whistle-blowers and a single definition of tax havens. Subsequently, a final vote on the recommendation of the PANA Committee was held on December 13 in Strasbourg.
Ukraine: Roadmap On Tax Transparency Standard And Information Exchange
; posted on
December 16th, 2017
The Ukrainian Ministry of Finance presented a Roadmap, with which the country commits to implement international standards of transparency and exchange of information, “Tax transparency: EOIR / AEOI CRS”, in Ukraine.
Assessment .
EU Announces Oncoming Legislative Priority
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December 16th, 2017
On December 12, 2017, the European Council approved the EU's legislative priorities for 2018-2019, and initiatives listed in the declaration have been agreed by the European Parliament and the Commission. Substantial progress and agreement on these legislative initiatives are expected to be achieved before the 2019 European elections.
Mapping The Trends In MAP Resolution Of Tax Treaty Disputes After BEPS
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December 13th, 2017
A presentation on the improvements BEPS has made to the resolution of international tax disputes through the Mutual Agreement Procedure (MAP) under tax treaties.
The traditional failures of the MAP procedure are all too well known.
More BEPS Measures By New Zealand On Transfer Pricing Audit (2)
; posted on
December 12th, 2017
The recently introduced BEPS Tax Bill has been submitted to the Parliament for its first reading. Alongside the Tax Bill, the country has also launched other measures to deal with taxation of multinationals, including transfer pricing audit on specific group of companies.
EU Warns US Tax Reform May Lead To Barriers To International Trade
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December 12th, 2017
Recently, a warning letter to Steven Mnuchin, the US Treasury Secretary, from the EU is showing worrisome signs. The letter was sent jointly by financial ministers in the UK, France, Germany, Spain and Italy.
Controversy Management After BEPS – A Unique Network Of Global Experts (2)
; posted on
December 9th, 2017
The post-BEPS world of tax brings with it increased transparency, burdensome and costly compliance obligations and heightened personal liability that may even turn into criminal liability in some jurisdictions. At the same time, the OECD (and local jurisdictions) do not have sufficient dispute avoidance/resolution mechanisms to fully support the increased compliance burden, thereby paving the road for increasing controversy.
EU Agrees Equalization Levy And Virtual PE Concept On Digital Economy Tax
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December 8th, 2017
The ECOFIN Council has approved Conclusions on Taxation of the Digital Economy , aimed at facilitating the Union to be better involved in the international discussions on digital economy taxation. It also serves as a reference to further work on the subject at EU level, including expected legislative proposals by the Commission early in 2018.
New Zealand Introduces BEPS Tax Bill
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December 8th, 2017
The Neutralizing Base Erosion and Profit Shifting (BEPS) Bill has been introduced into Parliament. It is expected to counter BEPS practices by multinational companies and prevent profits from being shifted out of New Zealand to reduce domestic taxable income.
EU Tax Haven Blacklist Including 17 Jurisdictions
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December 8th, 2017
The Finance Ministers of EU Member States agreed to the first ever EU list of Non-Cooperative Tax Jurisdictions during their meeting in Brussels. In total, 17 countries for have been listed failing to meet agreed tax good governance standards.
UK Issues Consultation Outcome On Notifying Offshore Structure Requirement
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December 6th, 2017
HM Revenue & Customs (HMRC) published the consultation outcome on a proposed new legal requirement and responded to issues concerned. In the proposal, if intermediaries create or promote certain complex offshore financial arrangements, they need to notify HMRC of these structures and their clients using them.
India Signs Bilateral APA With the Netherlands
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December 6th, 2017
The Central Board of Direct Taxes (CBDT) has entered into two Bilateral Advance Pricing Agreements (APAs). These Agreements are the first ever Bilateral APAs with The Netherlands.
CbCR Filing Health Check
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December 6th, 2017
Now that the deadline for filing your Country-by-Country Report (“CbCR”) is approaching rapidly for many jurisdictions, a CbCR health check before filing is a must. Therefore, take the following five steps into account prior to the submission of your CbCR:
5 Action Steps .
Potential increase Of Tax Liability Of Luxembourg Financing Companies
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December 4th, 2017
Intra-group financing companies have undergone significant scrutiny in the OECD/G20 BEPS project. Following this policy, Luxembourg tax authorities issued circular LIR n° 56/1 at the end of December 2016 having effect per 1.
Italian Guideline On CbCR And Automatic Information Exchange Released
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November 30th, 2017
The Internal Revenue Agency (Agenzia Entrate) in Italy released an order, which provides information for multinationals based in Italy to disclose data of their subsidiaries in the context of automatic country-by-country reporting. The order covered necessary information concerned the reporting arrangements, the deadlines for reporting the content of communication, and the language regime.
PANA Final Meeting Held With A Hearing on Paradise Papers
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November 30th, 2017
The final meetings of the Committee of Inquiry into Money Laundering, Tax Avoidance and Tax Evasion (PANA) took place with a Hearing on Paradise Papers in the afternoon. During the 15-month investigation by the Committee, 25 hearings, workshops and 11 studies took place.
Dutch Law Amended Regarding Access to Anti-Money Laundering Information
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November 30th, 2017
The Dutch Senate approved the bill on the implementation of the EU Directive on the access of tax authorities to anti-money laundering information in Dutch law. This bill is the amendment to the Act on the International Assistance in Taxation and thus implements the EU Directive 2016/2258 .
Increased controversy in Africa after BEPS – An analysis of recent TP disputes
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November 30th, 2017
A webinaron increased controversy expected after BEPS and the MLI in Africa, and an update on current TP disputes going to court in Africa.
9 African jurisdictions have signed the MLI: South Africa, Nigeria, Seychelles, Mauritius, Cameroon, Egypt, Gabon, Burkina Faso and Senegal.
Oxfam - Four EU Member States Could Be Found Tax Havens
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November 28th, 2017
Based on information leaked from the Paradise Papers , the EU has announced to compile a blacklist on the low-tax and non-cooperative jurisdictions, and the final version of such a list is expected to be released on December 5, 2017. Accordingly, Oxfam, an NGO based in UK, has issued a report on November 28 to give its opinion on jurisdictions with problematic tax scheme.
Australia Seeks Public Comments On Hybrid Mismatch Legislation Draft
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November 28th, 2017
The Australian government announced to implement the targeted rules on hybrid mismatch arrangements recommended by the OECD to eliminate double non-taxation benefits. Simultaneously, a public consultation is opened for the community’s views on the corresponding exposure draft legislation.
UK Issues Position Paper on Corporate Tax and Digital Economy
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November 24th, 2017
The British Government released a position paper to give its view on challenges posed by the digital economy for the corporate tax system and its preferred solutions. The objective is to ensure that the corporate tax rules respond to the modernisation of the economy and deliver appropriate results for digital businesses that generate value in unique ways.
US Updates Table for CbC Reporting Jurisdictions
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November 24th, 2017
The US Internal Revenue Service (IRS) published a notice to announce that the country-by-country reporting jurisdiction status table has been updated. The table states a last reviewed date of November 14, 2017.
The Netherlands Combats Tax Evasion Via Stricter Trust Rules
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November 24th, 2017
Since publication of the Paradise Papers , many jurisdictions have taken measures to respond and made use of the information released. Recently, the Dutch government also announced to tighten its rules for trust office and trust managers as a resort to combat the evasion which makes use of trusts.
Poland - New Transfer Pricing Regulations Since 1 January 1st 2017 (2)
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November 23rd, 2017
The amended regulations concerning transfer pricing became valid on 1 January 2017. The most significant change is that under the new regulations, taxpayers’ obligations are differentiated by revenues/costs value (in accordance with accounting regulations) exceeded in the previous tax year.
Pakistan Clarifies CBCR, Master And Local Files Requirements
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November 22nd, 2017
On November 16, 2017, the Federal Board of Revenue (FBR) in Pakistan has issued SRO 1191(1)/2017, which inserts chapter VIA to the Income Tax Rules, 2002. The new chapter, "Documentation and CbC reporting requirements", identifies the connotation of reporting entities, clarifies the reporting deadlines and gives a brief explanation to the contents of the country-by-country (CbC) reports, master files and local files.
EU State Aid Rules Hit UK CFC Rule And Greek Rule
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November 22nd, 2017
Recently, the European Commission released its latest findings on the investigations into the domestic legislations of UK and Greece respectively. The Commission finds that the British CFC exemption constitutes illegal state aid and decides to initiate the formal investigation procedure to the UK scheme, while the Greek defence system is found to fall outside the scope of the state aid, with a small proportion of illegal measures to be recovered.
Implementation of BEPS Action 13 - Argentina, Mexico and other countries of Central America
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November 22nd, 2017
Whilst many countries around the world have been implementing Action 13 of BEPS, countries in Latin and Central America also continue gradually advancing in the incorporation of the Country by Country report, Master File and Local file in their domestic legislation and therefore assuming the new challenges on transfer pricing documentation recommended by the OECD.
Current Status and Implications .
Peru - Modify The Regulations Of The Income Tax Law: Formal Transfer Pricing Obligations
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November 20th, 2017
The Peruvian Government published the regulations for the new transfer pricing documentation that have been implemented in the Peruvian legislation.
The official newspaper "El Peruano" has announced Supreme Decree No.
The impact of BEPS Action 13 for MNEs operating in LATAM
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November 15th, 2017
Countries in LATAM as Chile, Colombia, Mexico and Uruguay have been implementing in their domestic legislations some or all of the three-tiered transfer pricing documentation (Country by Country report, Master File and Local file) recommended by the OECD on Action 13 of BEPS project. Hence, multinational enterprises operating in the region are required to fill this new TP documentation in compliance with the OECD standards and the specific regulations of the particular country.
New Transfer Pricing Regulations In Poland In Force Since January 1st, 2017
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November 15th, 2017
New transfer pricing regulations in Poland were introduced into the tax system to implement the instruments developed by OECD within BEPS framework. However, there are some different items and obligations included in Polish regulations that are not part of the OECD Guidelines.
Global Tax Authorities Raid Taxpayers With Evasion Risks Based On Paradise Papers
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November 14th, 2017
The recent publication of Paradise Papers has raised another worldwide wave of anti-tax evasion/avoidance investigation and fast track. Tax authorities in several countries have opened an investigation according to names presented on the report; for example, the EU is compiling a blacklist , and India is pushing investigations on 426 cases.
PANA Committee Report Confirms Malta Is Not A Tax Haven
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November 14th, 2017
The EU PANA Committee published Report 2017/2013(INI), which presents the Committee’s findings on the investigation into Malta's tax scheme and political sphere. Some of the results illustrate an opposite view to the “Maltese tax haven” opinion held by many scholars and politicians.
India Issues Statements and Updates Investigation Based on Paradise Papers
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November 14th, 2017
The Central Board of Direct Taxes (CBDT) in India published two press releases on future actions to be carried out by the Indian Income Tax Department and an update of previous investigation cases respectively. Both announcements referred to the recent Paradise Papers , in which India ranks 19th in terms of number of names with 714 Indians reported in the tally.
CFO's Journey From 'Staying Out Of Trouble' To Being 'Fully In Control'
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November 14th, 2017
The world of taxation is changing. The release of BEPS, although driven by a tax motive, has wide ranging implications for a CFO as it not only demands full transparency on tax sensitive data but also requires a full disclosure of the operational and governance model of the company, in order to check for misalignments between all three.
Because of this, it is more crucial than ever that CFOs step out of their comfort zone and begin their journey from ‘’staying out of trouble’’ towards being ‘’fully in control’’ of business operations, to avoid controversies and consequential reputational and personal risks.
EU Compiling A Blacklist Based On Paradise Papers
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November 12th, 2017
On the ECOFIN monthly meeting of November 2017 in Brussels, the ministries discussed the agenda to set up a tax haven blacklist based on the recent Paradise Paper s, as well as corresponding measures to improve tax transparency and combat evasion, including listing countries reluctant to collaborate on tax issues.
Blacklist for Tax Haven and Non-Cooperative Jurisdictions .
UK - Diverted Profit Tax Turns A Transfer Pricing Game Changer
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November 12th, 2017
The Comptroller and Auditor General, HMRC presented oral evidence to the Public Accounts Committee (PAC) to look into the annual report and accounts, as well as the respond to the Paradise Paper . During the meeting , Jim Harra, Director General of Customer Strategy and Tax Design, gave a speech on the implementation of Diverted Profit Tax in financial year 2016-2017.
Last Opportunity On CbCr Filing To Avoid 'Leakage Of Data'
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November 9th, 2017
When filing your Country-by-country report, multinationals should - by way of a seperate letter - request their tax authorities where they file their CbC report, to not disclose their CbC report to governments who are not compliant with the ISO/IEC 27000-series standards .
Although OECD has made clear statements on 'security of data' in their handbooks and other publications, it is not always clear who has been given the authority to validate the ISO compliance status of other governments who are receiving these CbC reports.
IRS Large Business And International Division Launches Compliance Campaigns
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November 8th, 2017
The IRS Large Business and International division (LB&I) announced the identification and selection of 11 additional compliance campaigns, following the campaign plan announced in January 2017. The campaigns are the culmination of an extensive effort to redefine large business compliance work and build a supportive infrastructure inside the LB&I.
An Anticipated Wave Of Transfer Pricing For EU MNEs
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November 8th, 2017
The tax cut and job incentive plan in the US is moving forward. Accordingly, for the sake of combating transfer pricing abuse and gathering revenue, the US Congress recently released the Republican tax bill, under which multinationals are charged a 20% tax on cross-border transactions among related parties.
Paradise Papers - One More Glimpse of Tax Haven
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November 8th, 2017
Last week, the International Consortium of Investigative Journalists (ICIJ) published the Paradise Paper, a leak of 13.4 million documents. It releases the scale of the offshore wealth concealed in the tax havens, involving about ten dozen of politicians and a group of multinationals, such as members of Donald Trump’s cabinet, son-in-law of President Putin, Queen Elizabeth II, Facebook, and Apple, etc.
Bridging The CCCTB And The Arm’s Length Principle – A Value Chain Analysis Approach
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November 8th, 2017
This article provides an analysis of the proposals for a common consolidated tax base (CCTB) and common consolidated corporate tax base (CCCTB) in the European Union in the context of transfer pricing, concluding that a value chain analysis approach is the only possible means of aligning the CCCTB rules with the arm’s length principle.
1. Introduction .
Mexico - New Digital Platform services Local File, Master File and Country-by-Country Declaration
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November 2nd, 2017
The Mexican Tax Administration Service (Servicio de Administración Tributaria, SAT) recently announced that a digital platform on the SAT’s website was to come into service on November 1, 2017. The platform provides obliged tax payers with access to presenting declarations regarding Transfer Pricing information returns and corresponding digital forms.
India Notifies Country-by-Country Reporting Rules and Master File Forms
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November 2nd, 2017
On November 1, 2017, the Central Board of Direct Taxes (CBDT) notified the rules for maintaining and furnishing Transfer Pricing documentation in the Master File and Country-by-Country Report. Under the new rules, multinational group companies (MNCs) in India must submit their global parents’ operation in detail.
Implementation Of BEPS Action 13 - Chile, Colombia, Peru and Uruguay
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November 2nd, 2017
Whilst many countries around the world have been implementing Action 13 of BEPS, countries in Latin and Central America also continue gradually advancing in the incorporation of the Country by Country report, Master File and Local file in their domestic legislation and therefore assuming the new challenges on transfer pricing documentation recommended by the OECD.
Current Status and Implications .
India - GST Updates For October 2017
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November 2nd, 2017
Goods & Service Tax (GST) is a land mark change in the way business is done in India.
GST in the current form has tried to organize the highly fluid space of Indirect taxes which are currently being levied on supply chain both by the central union government and the state government.
Tax Dispute Resolution Directive: An Important Step for the EU
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November 1st, 2017
Piergiorgio Valente is our TPA Global Member in Italy.
A Directive on Tax Dispute Resolution was adopted by European Member States early in October 2017.
Belgium - Details of Tax Reform on Rates Released
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October 31st, 2017
On October 27, 2017, the Belgian government approved a proposal on tax reform, which forms part of the Revival Act. This is the second major fiscal reform of the government, and new rules under the proposal will be enacted by the end of this year.
EU Commission Opens Public Consultation On Digital Economy
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October 31st, 2017
The European Commission launched a public consultation on how the EU can ensure that the digital economy is taxed in a fair and growth-friendly way. This is the following up of the Commissions’ Communication on digital taxation, also as a response of the request by leaders at the European Council on October 19, when digital taxation became an politically and economically pressing issue.
A Second Panama-Style Leak from Bermuda Based Law Firm
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October 31st, 2017
The Australian Taxation Office (ATO) recently noticed the investigation by the International Consortium of Investigative Journalists (ICIJ) into Appleby, a Bermuda-based law firm. The company experienced a “data security incident” in 2016, with clients’ information being leaked.
Tech Giant Receives Tax Bill Of €193 Million From India
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October 27th, 2017
The Income Tax Appellate Tribunal (ITAT) in India issued an order, after consecutively dismissing six appeals from Google India, requiring the subsidiary of Google International LLC(US) in India to pay the tax demand of Rs 1457 crore (around €193). Accordingly, Google India is to file another lawsuit to contest this decision.
EU Commission Opens State Aid Investigation On British Tax Scheme
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October 27th, 2017
The European Commission issued an announcement that an in-depth probe into a UK scheme has been open. The British national legislation at issue exempts certain transactions by multinational groups from the application of UK rules targeting tax avoidance, and the Commission is to investigate whether the scheme breaches EU State aid rules or not by allowing these multinationals to pay less UK tax.
France Tries Pushing Digital Tax Reform On EU Level For US Tech Giants
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October 25th, 2017
French Economy Minister Bruno Le Maire gave a speech at the U.S. Chamber of Commerce and had a conference with U.
EU: Less Veto Power - Favoring Tax Reform
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October 25th, 2017
On October 24, Jean-Claude Juncker, the President of the EU Commission, announced to have 24 proposals "turning into law, into practice." Among the incoming proposals, the European Commission is planning to impose a restriction on the veto power of smaller Member States, which is expected to significantly remove the obstacles regarding current tax reform on a Union level.
UN - Tunde Fowler Elected Vice Chairman Of Committee of Tax Experts
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October 25th, 2017
On the Fifteenth Session of the UN International Cooperation in Tax Matters in Geneva from October 17 to 20, the 25 tax experts have been selected to join the committee of Experts on International Cooperation in Tax Matters. Tunde Fowler, the Executive Chairman of Federal Inland Revenue Service(FIRS) was elected 1st Vice Chairman of United Nations Committee of Experts on International Cooperation in Tax Matters.
South African Notice On Return Submission Regarding CbCR And Master File
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October 20th, 2017
South Africa issued a notice on the return to be submitted by persons in terms of the Country-by-Country Regulations. Taxpayers concerned are required to file Country-by-Country reports, master and local files.
Switzerland - Act on Country-by-Country Report Enters into Force Since 2018
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October 20th, 2017
The Federal Council decided to bring the Federal Act on the International Automatic Exchange of Country-by-Country Reports of Multinationals (CbC Act) and the Multilateral Competent Authority Agreement of 27 January 2016 on the Exchange of Country-by-Country Reports (CbC MCAA) into force.
CbC Act and CbC MCAA .
10 Practical Tips To Manage (Tax Risk) And File Your Country-by-Country Report Before Year End!
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October 19th, 2017
No other Action of the OECD’s 15 Action Points will have wider consequences than Action 13 – “ Guidance on Transfer Pricing Documentation and Country by Country Report” – in terms of the data ammunition provided to tax authorities to perform tax risk assessment!
After issuing various guidance and handbooks since the roll out of the Final BEPS Action 13 in 2015, the OECD last week published additional guidance to BEPS Action 13: “ Handbook on effective tax risk assessment ” . This publication will assist tax authorities in carrying out tax risk assessment before embarking on a full-blown tax audit of the taxpayer.
Controversy Management After BEPS – A Unique Network Of Global Experts (1)
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October 18th, 2017
Have tax disputes risen? “I firmly believe that there has been an increase” – Pascal Saint Amans
Post BEPS, it has become increasingly difficult to wholly identify and comply with all the legislative norms applicable to corporate taxpayers. While tax disputes have always come with extensive court battles and hefty economic burden, they now bring along an additional element of damage to a company’s and/or its major shareholders’ reputation.
RSA - From Functional Analysis to Value Chain Analysis
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October 18th, 2017
Attacks by the South African Revenue Service (“ SARS ”) on the transfer pricing practices of multinational enterprises (“ MNEs ”) are on the rise, leading to tax disputes with SARS over significant amounts of tax.
MNEs operating in South Africa provide information to SARS in various forms such as annual Corporate Income Tax returns, Country-by-Country reports as well as the extensive Transfer Pricing documentation.
Africa - Building Pleasant Investment Climate With Tax Certainty
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October 17th, 2017
The Consultative Workshop on Tax Certainty is to be held in Dar es Salaam, Tanzania on October 25, 2017. The three-day workshop will convene officials from 20 African tax authorities and ministries of finance, and experts from the OECD and the IMF.
Singapore’s Tax Incentives Meet BEPS Standards
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October 17th, 2017
The Forum on Harmful Tax Practices (FHTP) has released a progress report on preferential regimes that were reviewed in 2016 and 2017. Specifically, FHTP has assessed that Singapore’s tax incentives satisfy the international standards on countering harmful tax practices under the OECD/G20 Base Erosion and Profit Shifting (BEPS) project.
PANA Publishes Draft Report and Draft Recommendation
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October 17th, 2017
The next meeting of the Committee of Inquiry into Money Laundering, Tax Avoidance and Tax Evasion (PANA) will take place on October 18, 2017 on which the report on its inquiry and corresponding draft recommendation will be presented.
Indentifying Maladministration .
BEPS Software Series - Automation Through Cloud Solutions
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October 17th, 2017
Are you tired out from transfer pricing (TP) compliance burden? Now it’s time to look at automated solutions. Our BEPS Software will automate data collection and the three tiered TP documentation to ensure a streamlined BEPS compliance under BEPS Action 13 requirements.
OECD - A Further Step on BEPS Action 13
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October 12th, 2017
The OECD released the Country-by-Country Reporting (CbCR) implementation status, through activations of automatic exchange relationships under the Multilateral Competent Authority Agreement on the Exchange of CbC Reports ("the CbC MCAA"). This is a further step to implement CbC Reporting in accordance with the BEPS Action 13 minimum standard.
ECOFIN - New Framework On Tax Dispute Resolution Issued
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October 12th, 2017
The EU Economic and Financial Affairs Council (ECOFIN) adopted a directive to deal with double taxation resulting from different interpretations of bilateral tax treaties or other conventions. It is the following up work of the ECOFIN meeting on May 23, 2017.
The Netherlands Is Following The Cutting Tax Trend
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October 10th, 2017
Since October 5, 2017, the Dutch new cabinet successfully released the new tax plan in coming years. Several amendments are expected to be introduced to the present tax scheme, including changes on income tax, wealth tax and circulation tax (value added tax).
UN Releases Paper To Rise Attention To Digital Taxation
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October 10th, 2017
The United Nations published a paper on tax consequences of the digitalized economy, which gives an overview on possible issues for developing countries. It is a preparatory work for the Fifteenth Session of the Committee of Experts on International Cooperation in Tax Matters held in Geneva during October 17 to 20, 2017.
OECD - Feedback on PE Profit Allocation and Profit Splits Draft Released
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October 10th, 2017
The OECD released the public comments received on BEPS discussion drafts on attribution of profits to permanent establishments and transactional profit splits. The two discussion drafts were issued on June 22, 2017 for public feedbacks, and a public consultation will be held on November 6 to 7, 2017 in Paris.
Luxembourg Benefits Amazon With €250 million State Aid
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October 5th, 2017
The European Commission released a decision, concluding that Luxembourg has granted undue tax benefits to Amazon of around €250 million. This decision is following up the investigation launched in October 2014, when the Commission looked into a series of tax ruling practices of Member States, including the Starbucks case in the Netherlands and the Fiat case in Luxembourg.
Tallinn Summit: A Tortuous Path to Digital Taxation
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October 5th, 2017
On September 29, the leaders of the EU Member States met at the Tallinn Summit, during which the leaders gave their opinions on the digital taxation on Union level . The tax plan has received endorsement from 19 out of the 28 states, but no new agreement was reached due to the fierce division of various parties.
Ireland Failed to Recover State Aid of €13 Billion from Tech Giant
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October 5th, 2017
The European Commission announced to bring Ireland to the Court due to its negative attitude in recovering the state aid from Apple. This decision is based on Art.108(2) TFEU, Art.16(3) of Regulation 2015/1589, and the Commission's recovery notice.
TPA Global Country Summaries Update
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October 5th, 2017
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
We updated the country summaries of.
Asia - Workshop “How BEPS impacts Value Chain Analysis for Transfer Pricing purposes”
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October 5th, 2017
We would like to invite you to our Value Chain Analysis Workshop in Kuala Lumpur, Malaysia on 3 October 2017 or Jakarta, Indonesia on 5 October 2017,
“How BEPS impacts Value Chain Analysis for Transfer Pricing purposes” .
IRS Releases List Of Countries Regarding Tax Information Exchange
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October 3rd, 2017
On September 29, 2017, the Internal Revenue Service (IRS) released Revenue Procedure 2017-46, providing a list of countries regarding tax information exchange. It will form part of Internal Revenue Bulletin (IRB) 2017-41, which is supposed to be issued on October 28, 2017.
Switzerland - Act on Country-by-Country Report Adopted
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October 3rd, 2017
The Federal Council adopted the Act on the International Automatic Exchange of Country-by-Country Reports of Multinationals. The new act will enter into force on December 1, 2017, if the referendum is not called before expiry of its deadline on October 5, 2017.
OECD: Making Dispute Resolution More Effective - MAP Peer Review Report (NEW)
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October 2nd, 2017
The following BEPS related publications have been release by the OECD.
If you are interested in the theme covered by the books mentioned above, we invite you to visit www.
UK - Belarus Income Tax Treaty Ratified
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September 29th, 2017
The UK-Belarus Income Tax Treaty was signed between the Government of the United Kingdom of Great Britain, Northern Ireland and the Government of the Republic of Belarus. The new Treaty has not entered into force yet, and the UK-Soviet income treaty signed in London in 1985 will only cease to apply between the United Kingdom and the Republic of Belarus when the new treaty comes into force.
US - Revamp Of The Advanced Pricing Agreement Template
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September 29th, 2017
The IRS released a draft of the template used for advance pricing agreement (APA) for public discussion on revision. This template is designed to systematize how taxpayers propose terms for their APAs and standardize language used in executed APAs.
US - Tax Reform Framework Released With 20% CIT
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September 28th, 2017
On September 27, 2017, the White House released a framework for the US tax reform. The framework intends to both cut the income tax burden for taxpayers and slim the extremely sophisticated tax code in the US.
EU Commission - Path Set To Fair Tax On Digital Economy
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September 28th, 2017
The European Commission launched a new EU agenda to ensure that digital economy is taxed in a fair and growth-friendly way. The Commission also adopted a Communication, in which it sets out the challenges Member States currently face when it comes to acting on this pressing issue and possible solutions.
Transfer Pricing Under BEPS In Latin American And Caribbean Countries
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September 28th, 2017
The Inter-American Center of Tax Administrations (CIAT) recently reported the outcome of seven activities since 2014 to disseminate the content of the BEPS Action Plan. The countries gave their view on the level of priority of the different actions based on their respective contexts and shared their experience in applying BEPS reports, among which Actions 8 to 10 keep receiving the highest priority level.
Are US Bodies Terrified By The EU Unilateral Measure On Digital Economy?
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September 28th, 2017
Since the European Commission announced the tax reform plan to digital economies on union level on the Tallinn Digital Conference , it has received doubts and criticism about its impact on both economic growth and its efficiency, in particular, from the US bodies.
Economic Concerns .
Value Chain Analysis Event - Functional Analysis post BEPS
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September 25th, 2017
This event is provided jointly by TPA Global and Maastricht University.
As a result of the OECD’s BEPS Action Plan, MNEs are experiencing increased exposure to tax controversies if they are not simultaneously in control of their Operating and Transfer Pricing models.
The Netherlands: Amendments On Corporate Tax In 2018 Released
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September 21st, 2017
The Dutch government announced the Budget 2018, which includes the Tax Plan 2018 with several proposals. According to the document, there will be some amendments on the corporate tax law to be adopted starting January 1, 2018, unless otherwise indicated.
US: Concession On The Cutting Tax Reform
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September 21st, 2017
Last Wednesday, The US president Donald Trump reaffirmed his resolution to cut the federal corporate income to 15%, as was his promise during the campaign. However, such a low rate received more doubts and counterview than support.
Romania - Country Summary Update
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September 21st, 2017
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
Visit our country summary page .
Transfer Pricing Contributes Nearly £6 Billion To UK Tax
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September 19th, 2017
HMRC published the 2016/17 Transfer Pricing and Diverted Profits Tax Statistics, which shows the latest statistics data. The Transfer Pricing rules and the Diverted Profits Tax are important elements in a range of measures to make sure multinationals pay the right amount of tax on the share of their profits deriving from the UK.
EU - Oncoming Tax Rules On Digital Economy
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September 19th, 2017
The ministers of EU Member States reached a consensus on amending the existing international tax rules to plug the evasion of digital economy during the informal meeting of the EU Finance Ministers in Tallinn. Before the meeting, several Member States had proposed to update the taxing rules to collect a fair share from the digital giants, such as Estonia and the G4 countries .
Dutch Decree To Update Conditions For Business Reorganisation
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September 19th, 2017
The Dutch Ministry of Finance issued Decree No. 167217 to amend standard conditions for business re-organisations, including business mergers, legal divisions and legal mergers.
Your Tax Technology Plan
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September 18th, 2017
In the post-BEPS era, a surge in the number of deadlines to meet has led to an increase in the compliance burden. This, coupled with escalating disputes in numerous locations across the globe, leaves limited opportunities for cost savings and tax optimization.
Increasing Controversy For Offshore Structures After BEPS
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September 18th, 2017
A presentation on increasing controversy for offshore structures after BEPS.
Offshore (tax) planning structures have been used by multinational enterprises (MNEs) for decades.
Brazil-Argentina Treaty - Interpretation on Exemption of Dividend in Brazil
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September 14th, 2017
The Brazil Government published the Ruling 400/2017. The Ruling clarified that the exemption of dividend under Art.
Ireland - Corporate Tax Keeps Growing with Tax Rate Unchanged
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September 14th, 2017
A Government-commissioned report on the Irish tax scheme following the Apple Tax Ruling from the European Commission has been released. The report is given by economist Seamus Coffey, the chairman of the Government’s Fiscal Advisory Council.
OECD Report Releases Global Taxation Trends
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September 13th, 2017
On September 13, 2017, the OECD is released a new report on the worldwide tax reforms. This report is the second edition of the annual publication Tax Policy Reforms: OECD and Selected Partner Economies .
Four Countries Ask EU To Take More Effective Measures To Plug Tax Evasion By Digital Economy
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September 13th, 2017
On September 9, Finance Ministers of France, Germany, Italy and Spain jointly issued a political statement. In the document, the Member States appealed the European Commission to take more effective measures to plug tax evasion by digital economy.
The UN Publishes New Handbook on Developing Countries’ Tax Base
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September 12th, 2017
UN has published a new Handbook on several selected issues to assist developing countries to guard their tax base and strengthen their capacity to gather domestic revenue. The Handbook is the fruit of a project undertaken by the Financing for Development Office on the basis of draft papers discussed at a workshop in June 2014 in New York and in September 2014 in Paris.
EU Plans Rule Change - Online Tech Giants To Be Taxed Where They Create Value
; posted on
September 7th, 2017
The Estonian presidency of the EU released a document prepared for the meeting of the EU Finance Ministers on September 15, 2017 in Tallinn, Estonia. The meeting will discuss how to plug evasion by digital multinationals, and the document alleged that the current legal framework should be amended as it in effect favors digital companies.
UK - Extension Of Deadline On Trusts Tax Planning Register
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September 7th, 2017
HM Revenue & Customs (HMRC) has extended its time constraint on the registration of trusts for money laundering supervision. The previous deadline of October 5, 2017 is extended to December 5, 2017.
Tax Technology Event 2017 - From ‘Staying Out Of Trouble’ To ‘Being In Control’
; posted on
September 7th, 2017
This workshop is organized to assist businesses in finding their way through the world of tax technology solutions.
Thursday, 7 September 2017
France - Second Highest Tax Bill To Be Paid By Tech Giant
; posted on
September 6th, 2017
The French Microsoft subsidiary received a notification from the French tax competence. The multinational was required to pay a 600 million euros bill in France for its activities regarding online advertising and search engine.
EU Notice on Freedom of Capital: Commission vs. France Published
; posted on
September 6th, 2017
The Action (2017/C 293/27) brought on July 10, 2017 by the European Commission versus the French Republic has been published in the Official Journal of European Union. The Action was about a French national provision on tax treatment of dividends, which the Commission finds discriminatory and may restrict the free movement of capital.
BRICS Countries Announced to Plug Evasion
; posted on
September 6th, 2017
The leaders of Brazil, Russia, India, China and South Africa met at the ninth BRICS Summit and jointly issued the BRICS Leaders' Xiamen Declaration. The declaration discussed international and regional issues of common concern, including facilitating tax cooperation to plug evasion and provide technical assistance regarding tax governance.
Self-assessment Of Tax Risk By MNEs With A Centralised Business Model - A New Tax Screening Tool Developed By The ATO
; posted on
September 1st, 2017
In early 2017, the Australian Tax Office (‘ATO’) released a guideline, setting out a compliance approach to assess the transfer pricing outcomes based on self-assessment of tax risks in existing and newly created offshore centralised operating models (‘hubs’). This guideline is applicable from 1 January 2017 to hubs performing a wide range of activities such as the marketing, sale, distribution and procurement of goods and commodities as well as financial services.
Luxembourg - Legislation On Mutual Agreement Procedure
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August 31st, 2017
Luxembourg issued a Circular (L.G. - Conv. D.I. n° 60) on procedures for the implementation of the Mutual Agreement Procedure (MAP) for bilateral tax treaties concluded by Luxembourg.
Scope and Access .
Ecuador - Amendments on Withholding Tax Rates
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August 31st, 2017
the Ecuadorian Internal Revenue Service published a resolution to amend the previous resolution on the income tax withholding rates at source. The new resolution comes into force since its issue.
UN Appoints 25 Members To The Committee Of Experts On International Cooperation In Tax Matters
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August 30th, 2017
The Committee of Experts on International Cooperation in Tax Matters comprised 25 members nominated by Governments and acting in their personal capacity. The members are drawn from the fields of tax policy and tax administration and selected to reflect an adequate equitable geographical distribution, representing different tax systems.
Belgian DTAs With Mexico And Uruguay Enter Into Force
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August 29th, 2017
The Belgian Ministry of finance issued a press release, announcing that the Protocol amending the existing Belgian – Mexican Double Taxation Agreement (DTA) entered into force on August 19, 2017. At the same time, Belgian Ministry of finance announced that the DTA between Belgium and Uruguay entered into force on August 4, 2017.
ATO Aims At Big Pharmaceuticals
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August 29th, 2017
Deputy ATO commissioner Mark Konza told Parliament that ATO's ongoing corporate investigations are looking at companies in the pharmaceutical industry. ATO has already interviewed between 30 and 40 employees in one of the large pharmaceutical companies and has launched another 12 audits of big pharma companies.
PANA Publishes A Study Addressing Member States' Anti-Tax-Avoidance Capacity
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August 25th, 2017
The European Parliament's Committee of Inquiry into Money laundering, tax avoidance and tax evasion (PANA) published a new study addressing Member States' capacity to fight tax crimes. The study consist of ex-post impact assessment and investigates national provisions to combat tax avoidance and tax evasion, plus money laundering laws and their enforcement.
Tech Giant Reaches Undisclosed Settlement With Australian Tax Office
; posted on
August 25th, 2017
Microsoft announced this week that it has settled the Australian tax audit. At the same time, Apple's managing director informed that the five-year audit by the ATO has been concluded with no penalty imposed.
US Court Rules IRS Lawfully Denied Discretionary Tax Treaty Benefits
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August 25th, 2017
On August 14, the United States District Court for the District of Columbia ruled in Starr International Company, Inc. v. United States case that the Internal Revenue Service (IRS) was not arbitrary or capricious in finding at least one of the taxpayer’s principal purposes for moving its residency to Switzerland was to obtain tax benefits under the US-Swiss Treaty.
SARS - Draft Public Notice Requiring The Submission Of CbC, Master File And Local File Returns
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August 23rd, 2017
This draft public notice requires specified persons to submit returns in respect of transfer pricing documentation for reporting fiscal years and financial years commencing on or after 1 January 2016.
The proposed deadline for submission will be 12 months from the last day of the reporting fiscal year, in the case of country-by-country returns, and 12 months from the last day of the financial year, in the case of the master file and local file.
China - New Measures to Boost Foreign Investment
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August 22nd, 2017
On August 16, 2017, China’s State Council issued a notice (Guo Fa [2017] No.39) on measures to boost foreign investments.
Singapore - A Positive Response to Digital Economy (GST)
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August 22nd, 2017
During the SMU-TA Centre for Excellence in Taxation Conference on August 17, Ms. Indranee Rajah, Senior Minister of State for Law and Finance, announced the state’s resolution on revising its Goods and Services Tax (GST) of digital economy and future policy orientation.
HMRC Publishes Additional Guidance on CbC Reporting
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August 17th, 2017
On August 15, the HMRC published guidance on country-by-country reporting titled as “Check if you must send a country-by-country report” and "Country-by-Country XML Schema Guidance." The XML Schema Guide provides information on specific data elements and any attributes that describe that data element.
EU Releases a Taxation Paper on R&D Under a CCCTB
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August 17th, 2017
An assessment of R&D Provisions under a Common Consolidated Corporate Tax Base written by Diego d’Andria, Dimitris Pontikakis and Agnieszka Skonieczna has been published by the European Commission in its Taxation Papers publications. The outcomes of the paper conclude that the CCCTB without an R&D incentive would significantly deteriorate incentives to invest in R&D.
South Africa - Retrospective Country-by-Country Reporting And Transfer Pricing Documentation Requirements
; posted on
August 16th, 2017
South Africans who think that their tax burden is going to decrease because country-by-country (“ CbC ”) reporting does not apply to their company should think again!
In addition to the recently released draft notice requiring the submission of CbC reports, master file and local file returns, the South African Revenue Service (“ SARS ”) has recently issued the External Business Requirements Specification (“ BRS ”) document, setting out CbC and Financial Data Reporting (“ FDR ”) requirements..
IRS Is Now Accepting Country-by-Country Reports
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August 15th, 2017
On August 11, the IRS issued a press release announcing that it is now accepting country-by-country (CbC) reports and advised that parent entities of US multinational enterprise groups should now file Form 8975 with their annual income tax return.
US Multinationals to File CbC Reports .
France and Germany Target US Home-Sharing Platform Giant
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August 15th, 2017
Airbnb faces EU clampdown for not paying 'fair share' of tax as France and Germany initiate a new European Union fight to force home-sharing platforms to pay more tax. The French finance minister Bruno Le Maire said Airbnb’s low tax bill was “unacceptable”.
ATO to Collect CbC Information from the US
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August 15th, 2017
The US and Australia have agreed to share detailed information of companies as countries signed a country-by-country report agreement. The Australian Labor party also proposed a private senators’ bill on Monday that would require private companies with more than $100m in turnover to release their annual tax information to the public.
US Tech Giants Will Face Tax Clampdown from France and Germany
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August 10th, 2017
France and Germany and other partners have paired up to secure loopholes allowing U.S. tech giants such as Alphabet Inc.’s Google, Apple Inc., Facebook Inc. and Amazon.com Inc. to reduce taxes and take hold of market share in Europe, at the cost of European companies.
Cyprus - New Transfer Pricing Rules on Intra-Group Loan
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August 10th, 2017
Cyprus Tax Department has published a new circular regarding detailed transfer pricing rules which came into force on July 1, 2017. The new rules replaced the existing rules to determine the tax base of the “back-to-back” intra-group loan on the basis of a minimum margin.
Argentina - Brazil Tax Treaty: Latest Revision
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August 10th, 2017
Argentina and Brazil signed a protocol on several significant amendments on the bilateral tax treaty between the two countries during the Mercosur Summit. The new version, however, is not in force yet, as future feedback from the public may be needed.
New Zealand - BEPS Decision on Multinationals
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August 7th, 2017
The New Zealand government confirmed final decisions regarding taxation of multinationals to address Base Erosion and Profit Shifting (BEPS) and facilitate a fairer taxation. All these changes will be implemented via a tax bill and come into force by July 2018.
Joint Action On Offshore Indirect Assets Tax
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August 3rd, 2017
The IMF, OECD, UN and World Bank Group released a draft toolkit designed to help developing countries tackle the complexities of taxing offshore indirect transfers of assets. Public feedback on practice of multinational corporations to minimize their tax liability is sought by the Platform for Collaboration on Tax.
Hong Kong - Legislation On Transfer Pricing, CbCR, Dispute Resolution
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August 3rd, 2017
On July 31, the Hong Kong’s Inland Revenue Department (IRD) has released a consultation report that follows the work of the public on the BEPS plan in 2016, which is to be implemented in Hong Kong. Comments from 26 parties can be found in the report and future policy trends are indicated.
UK Not to Become A Tax Haven
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August 2nd, 2017
In an interview with French newspaper Le Monde, Chancellor Philip Hammond has said the UK will not reduce taxes or regulations to become a tax haven in a bid to compete with European rivals after Brexit .
Background .
BRICS Agree on Memorandum of Cooperation in Tax Matters
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August 2nd, 2017
During the annual meeting of the heads of the BRICS revenue administrations held in Hangzhou on July 28, tax officials from Brazil, Russia, India, China and South Africa signed a memorandum of cooperation to enhance their mutual work on international tax matters.
Background: International Taxation .
US Border Tax Proposal Denied
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August 2nd, 2017
On July 27, a proposed controversial border-adjusted tax proposal was denied in the House of Representatives. In a released statement, the officials informed that the goal of a tax reform is to reduce tax rates “as much as possible,” but the details yet remain unclear.
TPA Global Forms Alliance With Grupo Consultor EFE™ (Mexico)
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August 1st, 2017
Grupo Consultor EFE™ is an award-winning tax consulting firm with presence in the most entrepreneurial cities in Mexico and LATAM. The firm is the leading transfer pricing advisory services provider for the mid-sized company in the LATAM region, being named Best Transfer Pricing Advisory Firm for the last consecutive years by some of the largest tax-specialized media in the world.
Value Chain Analysis After BEPS - The Roadmap To Being In Control
; posted on
August 1st, 2017
Authors: Steef Huibregtse , Raymund Gerardu and Avisha Sood - TPA Global Network, Amsterdam (the Netherlands).
As Value Chain Analysis is now a mandatory part of the annual TP documentation exercise of MNEs, it can also serve as a.
Research: The Netherlands Is The Main Channel For Corporate Tax Avoidance
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July 27th, 2017
Almost 40% of corporate investments channeled away from authorities and into tax havens travel through the UK or the Netherlands, according to a study of the ownership structures of 98m firms. The Netherlands was a conduit for 23% of corporate investments that ended in a tax haven, while the UK accounted for 14%, ahead of Switzerland (6%), Singapore (2%) and Ireland (1%).
India - ‘Capital Gains’ Taxation Affair With The Netherlands
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July 27th, 2017
Andhra Pradesh High Court has concluded that gains arising from a Dutch company’s sale of shares of an Indian immovable property company to a Singapore company do not amount to a sale of immovable property situated in India since India-Netherlands tax treaty exempts such transaction.
Background .
Saudi Arabia To Be The First GCC Country to Implement VAT In 2018
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July 25th, 2017
Saudi Arabia has issued draft implementing legislation and implementing regulations in preparation of the 1 January 2018 launch of Value Added Tax, VATlive informes. It is based on the Gulf Co-Operation Council (GCC) VAT Treaty, which provides broad guidance on the VAT regime to be introduced in 2018 in all 6 GCC states.
Ireland Launches Apple State Aid Recovery Procurement Process
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July 25th, 2017
The Irish Ministry of Finance announced the launch of the procurement process in relation to Apple state aid recovery. The Department of Finance also revealed that funds may be higher than initial €13bn estimate.
Cyprus Adjusts Tax Treatment Of Intra-Group Financing Arrangements
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July 25th, 2017
On July 21, the Cypriot Ministry of Finance informed that the Commissioner of Taxation has issued a Circular for the tax treatment of intra-group financing arrangements. This follows constructive contact with the European Commission's Directorate General for Competition.
New Memory Trainers Will Help You To Become A Knowledgeable VCA, BEPS and/or TP Business Professional
; posted on
July 23rd, 2017
e-Bright is preferred partner of TPA Global.
e-Bright will soon introducing new Memory Trainers that will help you to become a knowledgeable business professional in the following fields:.
India - A Further Step On Tax Info Exchange To Tackle Evasion
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July 21st, 2017
The Indian Finance Ministry announced that India had taken part in the global joint task force meet to discuss the information exchange issue with other countries as a follow-up work on the Panama Papers.
Collaboration with the JITSIC .
Cayman Islands - Reinforcing Financial Services
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July 21st, 2017
Cayman's Minister of Financial Services, Tara Rivers, made her first visit to London to meet UK officials and industry leaders addressing its position on Brexit, beneficial ownership, and the EUs work on blacklist of non-cooperative jurisdictions, Cayman iNews reported on July 19.
Reinforcing The Strength Of Cayman's Financial Services .
EU Consults The Public On Customs Information Exchange With 3rd Countries
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July 21st, 2017
The European Commission opened a consultation to all interested parties on exchange of customs related information with third countries. This view seeking will continue until October 16, 2017.
BEPS Action 8 on Hard-to-Value Intangibles: is this the last piece of the puzzle required by SARS to issue its updated Transfer Pricing Practice Note?
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July 19th, 2017
One of the main action items identified by South Africa’s National Treasury in its summary of the country’s position on the G20/Organisation for Economic Co-operation and Development (“ OECD ”) action plan on base erosion and profit shifting (“ BEPS ”), is the requirement for the South African Revenue Service (“ SARS ”) to update the Transfer Pricing Practice Note in line with the OECD Transfer Pricing Guidelines to include new guidance on the arm’s length principle and an agreed approach to ensure appropriate pricing on intangibles that are difficult to value.
Action 8 of the BEPS Action Plan mandated the development of transfer pricing rules or special measures for the transfer of Hard-To-Value Intangibles (“ HTVI ”) and the general rules of how to deal with HTVI can be found in section D.
Switzerland To Exchange Information with Singapore
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July 18th, 2017
Switzerland announced that it has signed an agreement on the automatic exchange of information with Singapore. On the same day, a working meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) has started in Geneva.
New Zealand Might Implement A Diverted Profits Tax
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July 18th, 2017
New Zealand's Labour party informed that, in order to fight against tax avoidance of multinational companies, it aims to introduce a diverted profits tax (DPT) which would collect an extra $600 million from multinationals over three years.
Implementing the Diverted Profits Tax .
Reminder - Mandatory CbC Reporting Notification In The Netherlands Before 1 September 2017
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July 17th, 2017
As of 1 January 2016 local Dutch entities, belonging to a multinational group that meets the threshold for Country-by-Country Reporting, must notify the Dutch tax authorities (“Belastingdienst”) of the identity and the tax residence of the Reporting Entity no later than the last day of the reporting fiscal year of such multinational group. For the first calendar year 2016 and fiscal years starting in financial year 2016 and ending later but before or on 31 August 2017, the notification deadline has been extended to 1 September 2017 .
Managing Controversy after BEPS
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July 14th, 2017
Has BEPS increased the risk of tax controversy?
Yes, the lack of clarity around the implementation of the BEPS Action Plans by countries is invariably leading us to a world of unavoidable tax disputes. It is increasingly difficult to wholly identify and comply with all the legislative norms applicable to corporate taxpayers in today’s post-BEPS world.
OECD Releases 2017 Transfer Pricing Guidelines
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July 13th, 2017
The OECD released the 2017 Edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. Based on the 2010 Transfer Pricing Guideline, the updated edition provides guidance on how to apply the Arm’s length principle under BEPS context.
ECOFIN - Process On Modernizing VAT And Intermediaries
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July 13th, 2017
On July 11, an Economic and Financial Affairs (ECOFIN) meeting was held in Brussels. Priorities were given to the Estonian presidency as concerns economic and financial affairs.
OECD Publishes MLI Matching Database In Beta Version
; posted on
July 11th, 2017
The OECD published its “MLI Matching Database” for tax treaties in beta in a preliminary (beta) version. The database makes projections on how the MLI modifies a specific tax treaty covered by the MLI by matching information from Signatories’ MLI Positions.
French Minister Of Finance Calls To Pressure MNEs
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July 11th, 2017
French finance minister Bruno Le Maire said that the European Union should finally make US multinationals, such as Google, Amazon and Facebook, pay their fair share of taxes. "Since we have to deal with Mr Putin, Mr Trump or Mr Erdogan, it's time for Europe to pull itself together and defend its own interests," he said.
Dutch Government Opens Consultation On ATAD1
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July 11th, 2017
The Dutch Government opened a public consultation on a proposal that aims to implement the Anti Tax Avoidance Directive (ATAD1) in Dutch national law. ATAD1 aims to provide minimum harmonization to protect the tax base with a possibility to go beyond the minimum standard in the next stage.
Are You Ready For Your FY 2016 Value Chain Analysis To Be Shared With Your Tax Inspector In China? (2)
; posted on
July 10th, 2017
This second webinar is the English spoken version of our recent Chinese web event and is scheduled for Asia/Pacific audiences.
Although, the arm’s length principle in essence still is the driving force for analyzing intercompany transactions, how we apply that has changed in important ways.
OECD - This week's updates on BEPS
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July 7th, 2017
This week the OECD launched some important announcement regarding BEPS:
OECD, CREDAF and UNDP hold a regional meeting of the Inclusive Framework on BEPS for French speaking countries .
EU Parliament Approves Proposal On Tax Transparency
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July 6th, 2017
The EU parliament approved the proposal to amend Directive 2013/34/EU on disclosing the financial information of multinationals for tax purpose, including branches outside the EU.
Threshold for Country-by-Country report .
OECD Report On Boosting Taxation Efficiency And Fairness
; posted on
July 6th, 2017
The latest report of July 2017 has been submitted by the OECD Secretary-General Angel Gurría to G20 Leaders. The report consists of two parts, covering issues such as closing down loopholes, improving transparency, matching tax due with economic activities, etc.
PANA Publishes Draft Report And Draft Recommendation
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July 5th, 2017
On June 30, the draft inquiry report that provides conclusions identifying contraventions of EU law and instances of maladministration and the draft recommendations of the PANA Committee were published. On the same day, the European Parliament provided Briefing on EU Legislation in Progress regarding public country-by-country reporting.
EU Commission Concludes Polish Tax On Retail In Breach Of EU State Aid Rules
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July 5th, 2017
The European Commission informed that a Polish tax on the retail sector is in breach of EU state aid rules. The Commission concluded that the progressive tax rates based on turnover give companies with low turnover an advantage over their competitors.
OECD: Progress And Facilitation On International Tax Transparency
; posted on
June 29th, 2017
The OECD informed that on the request of G20 countries, the Global Forum on Transparency and Exchange of Information for Tax Purposes is to provide a list of non-cooperative jurisdictions for the G20 Leaders Summit in Hamburg in July 2017.
Improvements in compliance with the EOIR standard .
EU Commission Promotes Tax Fairness
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June 29th, 2017
At the 2017 Tax Fairness Conference in Brussels, Pierre Moscovici (EU Commissioner for Economic and Financial Affairs, Taxation and Customs) said that the realization of tax fairness is to be supplemented with anti-abuse rule on EU level, the support of tax transparency, reasonable allocation of tax base, and cooperation on anti-avoidance among jurisdictions.
Principles Concerned Tax Policy .
Korea's NTS Chief Nominee Pledges To Tackle Tax Evasion
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June 27th, 2017
Korea's National Tax Service (NTS) Chief Nominee Han Seung-hee vowed to tackle tax evasion by multinational firms by ensuring successful implementation of comprehensive reporting system for international transactions. He also promised to strengthen investigations of "intelligent tax-dodging practices" of foreign multinationals, the local news reported.
OECD Addresses Tax Issues During Tax Talk #6
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June 27th, 2017
The OECD held Tax Talks #6 addressing the Inclusive Framework on BEPS and other related subjects. The OECD officials said an important update to the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations will be released soon.
PANA Committee To Discuss Anti-Money Laundering Directive
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June 27th, 2017
EU's Committee of Inquiry into Money Laundering, Tax Avoidance and Tax Evasion (PANA) scheduled a meeting on July 3, 2017 with Věra Jourová, European Commissioner for Justice, Consumers and Gender Equality , who is in charge of anti-money laundering (AML) policy in the Commission.
Beneficial Ownership .
LATAM Country Summaries Update (3)
; posted on
June 27th, 2017
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
Updates .
EU Member Countries Object To Proposed VAT Reductions
; posted on
June 22nd, 2017
In a summary sent to the Dutch House of Representatives, the Dutch Minister of Finance provides further insights on developments from the EuroGroup meeting of June 15 and the ECOFIN Council of June 16, International Tax Plaza informed. During the meeting, certain countries objected to VAT reduction for electronic publication as well as to reverse charge mechanism .
US Administration To Come Up With A Decision Over Tax Avoidance
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June 22nd, 2017
President Donald Trump and Republican leaders in Congress are addressing profit-shifting schemes that involve transfer pricing, earnings stripping and tax inversions. According to Reuters, a decision on on how to handle these in tax legislation could be announced already in June.
European Commission Introduces Indicators for Intermediaries to Report Tax Evasion
; posted on
June 22nd, 2017
The European Commission has proposed new transparency rules for intermediaries that design or sell potentially harmful tax schemes. Under the new rules, intermediaries will have to report any cross-border arrangement containing given characteristics that would indicate tax avoidance.
Swiss Council Adopts Dispatch On AEOI With 41 States And Territories
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June 21st, 2017
The Federal Council adopted the dispatch on the introduction of the automatic exchange of financial account information (AEOI) with 41 states and territories. At the same time, Swiss banks informed they will keep a close watch on data protection measures taken by countries.
PoEM Rules - The Indian Government Issues A Draft Notification For Comments
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June 19th, 2017
Recently the government vide draft notification dated 15 th June, 2017 provided exceptions, modification, and adoption in respect to PoEM rules on which comments and suggestions from the general public are invited.
The concept of Place of Effective Management in India (“PoEM”) was introduced in Finance Act, 2015.
Hong Kong To Exchange Information (AEOI) With Indonesia
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June 17th, 2017
Hong Kong has signed an agreement with Indonesia for conducting automatic exchange of financial account information in tax matters (AEOI). Following the agreement with Indonesia, Hong Kong now has 13 AEOI partners.
Indonesia Reaches Tax Settlement With Google
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June 15th, 2017
On June 13, Indonesian Finance Minister Sri Mulyani Indrawati informed that Indonesia has reached a tax settlement with Alphabet Inc's Google for 2016. This follows an ongoing dispute over allegations that Google avoided paying tax for its advertisement activities.
PANA To Address Financial Intelligence Units And The "Russian Laundromat Case"
; posted on
June 15th, 2017
On June 21, the Committee of Inquiry into Money Laundering, Tax Avoidance and Tax Evasion (PANA) will hold a meeting on "Financial Intelligence Units (FIUs) – Ins and Outs, and the Russian Laundromat case".
Bank records .
OECD Requests Feedback On Dispute Resolution Peer Reviews
; posted on
June 13th, 2017
The OECD informed it invites taxpayers to answer questions regarding specific issues related to access to the Mutual Agreement Procedure (MAP), clarity and availability of MAP guidance and the timely implementation of MAP agreements for the Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore and Spain.
Background: MAP .
EU JURI and PANA Committee To Hold Hearing On The Protection Of Whistleblowers
; posted on
June 13th, 2017
On June 21, the Members of the EU Committee on Legal Affairs (JURI) and PANA Committee will hold a hearing with experts on legitimate measures to protect whistle-blowers acting in the public interest when disclosing the confidential information of companies and public bodies.
Protection for whistleblowers .
Members of European Parliament Adopt Public Cbc Reporting With A "Safeguard Clause"
; posted on
June 13th, 2017
On June 12, MEPs from the economic affairs and legal affairs committees voted for a public Country-by-Country (CbC) reporting draft directive implementing a 'safeguard clause'. The clause will allow increased tax transparency but ensure no disruption in fair competition by preventing sensitive information to be shared publicly.
Goods & Service Tax (GST) - A True Game Changer For Tax Efficiency In India
; posted on
June 13th, 2017
Goods & Service tax (GST) is a land mark change in the way business is done in India.
GST in the current form has tried to organize the highly fluid space of Indirect taxes which are currently being levied on supply chain both by the central union government and the state government.
Cayman Islands Committed to BEPS Because Of Reputational Reasons
; posted on
June 9th, 2017
On June 7, over 70 countries and jurisdictions have signed, or formally expressed their intention to sign, an innovative multilateral convention. According to former Minister for Cayman's Financial Services Wayne Panton, the effects of the BEPS project on Cayman are relatively “benign,” but the government committed to the initiative “for reputational reasons,” Cayman Compass reported.
Eight Countries Discuss Cooperation In Risk Assessment
; posted on
June 9th, 2017
The OECD International Tax Conference sponsored by the OECD, USCIB, and BIAC was hosted in Washington, DC. The annual conference allowed the USA business community to interact with key representatives from the OECD Tax Officials.
U.S. and South Africa to Exchange CbC Reports
; posted on
June 6th, 2017
On June 5, the South African Revenue Service (SARS) released the text of an arrangement between the United States of America and the Republic of South Africa on the exchange of Country-by-Country (CbC) Reports.
Exchange of Country-by-Country Reports .
Multinationals Alter Tax Plans Over U.S. Tax Reform
; posted on
June 6th, 2017
A new research provided by Taxand that is based on 136 interviews with financial officers and tax directors concluded that more than half of multinationals have altered their tax plans, or delayed decisions, due to the tax reforms in the U.S.
Background: Trump's Tax Plan .
HMRC Carried Out Over 360 Transfer Pricing Reviews
; posted on
June 6th, 2017
According to research from the law firm Pinsent Masons, HMRC launched 362 reviews into business transfer pricing in 2015/16. The amount potentially under dispute reached £3.
Thailand Joins The Inclusive Framework On BEPS And Participates In First Joint Programme For The Implementation Of International Tax Standards
; posted on
June 4th, 2017
Thailand has become the 98 th jurisdiction to join the Inclusive Framework on BEPS ("IF") and will participate on an equal footing with all other IF members at the next plenary meeting of the IF that will be held on 21-22 June 2017 in Noordwijk , the Netherlands.
The IF was established in January 2016, after the G20 Leaders urged the timely implementation of the BEPS package released in October 2015 and called on the OECD to develop a more inclusive framework with the involvement of interested non-G20 countries and jurisdictions, including developing economies.
South Africa - Draft Notice To Submit CbC, Master File And Local File Returns
; posted on
June 2nd, 2017
On 2 June 2017, the South African Revenue Service (“SARS”) has published a draft public notice requiring the submission of country-by-country (“CbC”), master file and local file returns. This marks an important step towards the finalisation of South Africa’s transfer pricing documentation requirements.
PANA Committee Meets EC President Juncker
; posted on
June 1st, 2017
On May 30, The PANA committee held a hearing with European Commission President Jean-Claude Juncker, stating that a draft law that targets accountants and lawyers running tax-avoidance schemes will be made available before the end of June. The EC President was also accused of helping tax avoidance schemes during his period of Prime Minister and Finance Minister of Luxembourg.
Rocha Andrade Defends Legality Of Madeira’s Free Trade Zone
; posted on
June 1st, 2017
On May 30, the European Parliament held a hearing with Fernando Rocha Andrade, the Portuguese Secretary of State of Tax Affairs, addressing Portugal’s approach in the fight against money-laundering, tax evasion and tax avoidance. Andrade had to defend the legality of Madeira’s free trade zone arguing it functions within EU rules.
CJEU - Question Dividend Withholding Tax To Non-Dutch Investment Funds
; posted on
May 31st, 2017
The Official Journal of the European Union published two requests for preliminary rulings of the Court of Justice of the European Union (CJEU). The requests question rejection of investment funds established outside the Netherlands on the ground that it is not subject to an obligation to withhold Netherlands dividend tax.
EU Council Adopts Directive On Hybrid Mismatches With Third Countries (ATAD2)
; posted on
May 31st, 2017
The EU Council adopted the rules to close down hybrid mismatches with the tax systems of third countries (ATAD 2), which aims to prevent corporate tax avoidance and contributes to the implementation of OECD's base erosion and profit shifting (BEPS) measures.
Hybrid Mismatch Arrangements .
India: Pharma Companies Questioned Over Transfer Of IP Assets To Offshore Subsidiaries
; posted on
May 31st, 2017
Reserve Bank of India is questioning pharma companies operating in India over the transfer of their intellectual property (IP) assets to offshore subsidiaries. The central bank is looking at ways the foreign subsidiaries have raised loans abroad to pay for the intellectual property assets transferred to them, the Economic Times reported.
LATAM Country Summaries Update (2)
; posted on
May 31st, 2017
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
Updates .
OECD releases peer review document for assessment of the BEPS Action 6 minimum standard
; posted on
May 29th, 2017
Today the OECD released the key document, approved by the Inclusive Framework on BEPS, which will form the basis of the peer review of the Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate circumstances.
The Action 6 minimum standard is one of the four BEPS minimum standards.
USA Country Summary Update
; posted on
May 29th, 2017
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
Updates .
EU Council Agrees Its Position On Dispute Resolution Procedures
; posted on
May 29th, 2017
The EU Council agreed on a new system for resolving double taxation disputes within the EU. The Council reached compromise on the scope of the directive, 'independent persons of standing' and standing committee.
BEPS Project Potentially Harmful To Asset Management Industry
; posted on
May 29th, 2017
During a panel discussion at the Guernsey Funds Forum in London, tax experts warned that the asset management industry could be harmed by the proposed Base Erosion and Profit Shifting (BEPS) project. The experts warned that the rules ignore how the asset management industry works and that every country has its own version of what BEPS really means.
OECD Seeks Feedback on Hard-To-Value Intangibles Guidance
; posted on
May 23rd, 2017
OECD invited interested stakeholders for public comments on a discussion draft which provides guidance on the implementation of the approach to pricing transfers of hard-to-value intangibles described in Chapter VI of the Transfer Pricing Guidelines.
Background: Hard-to-value Intangibles .
US to Consult Destination-Based Taxation And Border Adjustments
; posted on
May 23rd, 2017
The House Committee on Ways and Means published a document prepared by the staff of the Joint Committee on Taxation that provides an overview and analysis of destination-based taxation and border adjustments. The document has been published ahead of a public hearing on border adjustments and international tax reform that takes place on May 23.
Schelling - Agreement On A European Tax On Financial Transactions Is Within Reach
; posted on
May 23rd, 2017
On May 21, during the interview with Austrian broadcaster ORF, Austrian Finance Minister Hans Joerg Schelling said that an agreement on a European tax on financial transactions is within reach as more countries sign up for the final version of the measure and the new French government gives it a final review, Reuters reported.
Background .
We Provide Solutions - Let's Talk Business!
; posted on
May 23rd, 2017
TPA Global provides solutions in the area of BEPS, Value Chain Analysis for multinationals along with variety of tax, business and educational technologies. Tax departments are facing an increased compliance burden and fewer opportunities for optimization.
China Further Develops Its Transfer Pricing Regime - Issuance Of Bulletin 6
; posted on
May 22nd, 2017
The China State Administration of Taxation (SAT), on March 17, 2017 has issued new transfer pricing rules: Bulletin 6 – the “Administrative Measures on Special Tax Investigation, Adjustment and Mutual Agreement Procedures”, which has taken effect as of May 1, 2017. Bulletin 6 revised and refined certain provisions stipulated in the 2009 "special tax adjustment implementation measures (Trial)" (Circular 2) and further clarified the transfer pricing investigation procedures and adjustment methods applied by the Chinese tax authorities.
LATAM Country Summaries Update
; posted on
May 19th, 2017
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
Updates .
EU Commission Requests France To Abolish Certain Withholding Tax
; posted on
May 18th, 2017
The European Commission released its “May infringements' package: Part 1: key decisions” including Commission’s request to France to abolish withholding tax imposed on non-resident companies in deficit.
Free Movement Of Capital .
The Netherlands Opens Consultation On Dividend Withholding Tax For Holding Cooperatives
; posted on
May 18th, 2017
The Dutch Government published a draft law containing new obligation to withhold withholding taxes for so-called holding cooperatives. The Dutch Government invites interested parties to provide their feedback on the draft law.
US Companies Demand Higher Cuts On Offshore Profits
; posted on
May 16th, 2017
Major US multinationals push US Government to further deepen the tax break on corporate profits being held offshore. Some of the lobbyists said that in order to bring their corporate profits to the US, they need a sharply reduced tax rate even below the recently proposed reduction to 10 percent, Reuters reports.
Research Paper Provides Perspectives on Corporate Tax Avoidance
; posted on
May 16th, 2017
The US academics Jaron Wilde and Ryan Wilson published a paper summarizing the academic perspectives on corporate tax avoidance highlighting the main developments over the last decade.
The Context .
G7 Finance Ministers Address Taxation Digital Economy
; posted on
May 16th, 2017
During the meeting on May 12-13 in Italy, G7 finance ministers and central bank governors expressed the need to address the tax challenges associated with the digitalization of the economy. During the event, U.S. Treasury Secretary Steven Mnuchin defended the Trump protectionist tax plan.
Value Chain Analysis Workshops for Corporates.
; posted on
May 12th, 2017
The Bridge to Align the Operating Model, Corporate Governance Framework and the Tax/Transfer Pricing Structure of an MNE.
Due to globalization and increasing business complexities, management boards are experiencing difficulties in being in control of their operating model and transfer pricing model simultaneously.
German Finance Minister Claims Malta Has Become The Panama Of Europe
; posted on
May 11th, 2017
Germany's North Rhine-Westphalia finance minister Norbert Walter-Borjans claimed that Malta has become the Panama of Europe after a data leak revealed by German Journalists that there are 70,000 offshore companies in Malta. In response, Ministry of Finance informed that public register can be accessed online while its Finance Minister Edward Scicluna tweets "Pull another one".
Australia Releases Budget 2017-18 Documents
; posted on
May 11th, 2017
During the Federal Budget 2017-18, Australian Treasurer Scott Morrison announced that Australia will introduce hybrid mismatch provisions applicable to banks and financial institutions and tighten its multinational anti-avoidance law (MAAL). The Budget documents and a new Black Economy Taskforce interim report have been published.
OECD Launches Facility To Disclose CRS Avoidance Schemes
; posted on
May 9th, 2017
The OECD launched a disclosure facility on the Automatic Exchange Portal which allows interested parties to report potential schemes to circumvent the CRS. The OECD also informed that over 1800 relationships are now in place to automatically exchange CRS information between tax authorities.
PANA Questions Channel Islands, Gibraltar, and Madeira
; posted on
May 9th, 2017
On May 9, the PANA Inquiry Committee held a public hearing on the “Cooperation in tax matters with European jurisdictions,” during which Members of the EU discussed tax regimes with representatives of the Channel Islands, Gibraltar, and Madeira.
Background .
EU Parliament Releases CCTB and CCCTB Briefings
; posted on
May 9th, 2017
The European Parliament informed that it released briefing for the Common Consolidated Corporate Tax Base (CCCTB) Project. The briefing provides background information, information about the proposal and its impact as well as views of advisory committees, national parliaments and stakeholders.
Amsterdam Workshop Value Chain Analysis for Corporates
; posted on
May 6th, 2017
Value Chain Analysis Workshop for Corporations - the bridge to align the operating model, corporate governance framework and the tax/ transfer pricing structure of MNE .
You are running major company and individual risks for not having prepared a Value Chain Analysis fully synced with your traditional transfer pricing compliance.
Dutch Railway Company Again Accused Of Tax Evasion
; posted on
May 5th, 2017
Dutch railway company NS, which operates services in Germany and Britain, continues to avoid corporation tax through its subsidiary Abellio in Ireland, despite the Dutch government’s warning to abstain from using this tax avoidance scheme, Dutch Newspaper Trouw reported.
Background .
Moscovici Details New Measures Against Intermediaries Who Help Tax Evasion
; posted on
May 5th, 2017
The PANA Committee held a hearing with Pierre Moscovici, European Commissioner for Economic and Financial Affairs, Taxation and Customs, who gave details of the planned EU blacklist of tax havens to be published this year, addressed the further work on the role of intermediaries and informed about recent exchanges with members of the new US administration.
Background .
Tech Giants Forced to Book Profit in Australia
; posted on
May 2nd, 2017
Recently published financial results of Google and Facebook revealed significantly higher Australian revenue and profit following Australia's implementation of tougher anti-avoidance measures including the Multinational Anti-avoidance Law (MAAL) and the Diverted Profits Tax. The companies acknowledged the new laws contributed towards the large boost in booked revenue.
Russian Federation And Japan Sign New DTA
; posted on
May 2nd, 2017
The Government of Japan and the Government of the Russian Federation have agreed in principle on a new Tax Convention.
Previous Tax Convention
European Parliament Adopts Hybrid Mismatch Rules
; posted on
May 2nd, 2017
The European Parliament adopted a legislative resolution on a proposal for a Council Directive amending the Anti-Tax Avoidance Directive on hybrid mismatches involving third countries (ATAD 2). The report will be considered for final approval by the European Council.
EU PANA Committee Presents Studies on Tax Evasion
; posted on
April 28th, 2017
The EU PANA Committee has presented the findings of three studies focusing on the impact of money laundering and tax evasion on EU Member States’ economies and finances. The Committee also presented the roles played by Member State administrations in fighting tax evasion and money laundering.
Italy Updates Transfer Pricing Rules And Patent Box Regime
; posted on
April 28th, 2017
Italy publishes Decree n. 50 that implements changes to its transfer pricing and patent box regime, including arm’s length principle and updated list of intellectual property, MNE Tax Reported.
Arm's Length Principle .
Trump Reveals New Tax Plan
; posted on
April 28th, 2017
US president Donald Trump proposed sharp reductions in individual and business income tax rates, reducing the “business tax rate” to 15 percent and moving to a territorial tax system.
Main Proposals .
Transfer pricing in Hungary and Romania
; posted on
April 28th, 2017
"A readiness check on whether your Romanian and Hungarian subsidiaries are fulfilling the local transfer pricing requirements"
Transfer pricing is a hot subject for companies operating in Romania and in Hungary. This is because the local tax authorities are focusing more on this topic, with the number of transfer pricing audits increasing significantly in the last few years.
Are you currently preparing your own Value Chain Analytics (VCA) for Tax/Transfer pricing purposes?
; posted on
April 26th, 2017
Free One to One Consultation (Reserve a slot with one of our Professionals!)
How are you preparing for your value chain in China?
The United Arab Emirates Sign The Multilateral Convention On Mutual Administrative Assistance in Tax Matters
; posted on
April 26th, 2017
On April 21, the OECD informed that the United Arab Emirates signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. By doing so, the United Arab Emirates became the 109 th signatory to the convention.
Mossack: The Number Of US Tax-Shelters Increase After Panama Papers
; posted on
April 26th, 2017
Juergen Mossack, who partnered with Ramon Fonseca to create the Panamanian firm Mossack Fonseca, said in a document that the number of tax shelters has been decreasing in many tax havens while raising in the US jurisdictions such as Delaware or Nevada.
Panama Papers Adopts Transparency .
LATAM Country Summaries Update
; posted on
April 25th, 2017
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
Updates.
VCA Workshop for Corporates
; posted on
April 25th, 2017
During this workshop the following has been discussed:
Up to 10 VCA case studies to train you on performing your own VCA;
EU Releases Study On Impact Of Panama Schemes
; posted on
April 21st, 2017
The European Parliament's PANA Committee on Money Laundering, Tax Avoidance and Tax Evasion published a study on the "Impact of Schemes revealed by the Panama Papers on the Economy and Finances of a Sample of Member States." The impact is measured from a financial, economic and budgetary point of view.
France Might Be A New Tax Haven For Investors in India
; posted on
April 21st, 2017
During a meeting with financial ministry officials in India, global financial giant Citi pointed out that foreign funds and global banks are taking advantage of India’s treaty with France to escape tax. India might soon review its tax treaty with France to address issuance of participatory notes in France, reports The Economic Times .
Sweden May Force Tax Advisers To Report Clients
; posted on
April 18th, 2017
The Swedish finance ministry said in a statement that it has set up a parliamentary commission to examine whether tax advisers should be required to report clients who use tax avoidance structures, International-Adviser informed.
Advisors to Report Clients .
Ghana And Czech Republic Sign Double Taxation Agreement
; posted on
April 18th, 2017
Ghana and the Czech Republic have signed a double taxation agreement to prevent fiscal evasion with respect to taxes on income. The countries also agreed on enhancing the mutual assistance in the collection of taxes.
Australian Tax Office Explains Detailed Design Of CbC Reports
; posted on
April 18th, 2017
The Australian Taxation Office (ATO) released additional guidance with an overview of the detailed design of the local file / master file. The guidance addresses IT specifications for software developers to use in business management software to enable the generation of a valid XML file.
Tech Giant Slapped By Korea's Tax Agency
; posted on
April 15th, 2017
The National Tax Service (NTS) has imposed a US$ 275.74 million fine on Oracle Korea for alleged tax evasion involving tax haven during the period of seven years.
OECD Meets to Discuss VAT Challenges
; posted on
April 15th, 2017
On April 12-14, the OECD Global Forum holds its fourth meeting on Value Added Tax (VAT; also known as Goods and Services Tax, under the acronym GST in a number of OECD countries) addressing the policy and operational challenges faced by tax authorities. On that occasion, the OECD published The International VAT/GST Guidelines that were adopted as a Recommendation by the Council of the OECD in September 2016.
UN Releases TP Manual For Developing Countries
; posted on
April 13th, 2017
During UN meetings last week, the UN’s Committee of Experts on International Cooperation in Tax Matters released an updated version of the 'United Nations Practical Manual on Transfer Pricing for Developing Countries,' the MNE Tax reported.
Background: UN Committee .
Hong Kong Updates Guidance for Financial Institutions
; posted on
April 13th, 2017
The Inland Revenue Department of the Government of Hong Kong released updated versions of Chapters 11 and 12 of the Guidance for Financial Institutions. The changes include the procedures that reporting financial institutions must apply.
Germany Provides Status Update On The 10 Step Plan
; posted on
April 13th, 2017
The German Ministry of Finance provided a status update on the 10 step plan, released in April 2016 as a reaction to Panama Papers to combat tax fraud, de­vi­ous tax avoid­ance and mon­ey laun­der­ing, the International Tax Plaza reported.
Background: Schaeuble's 10-Point Plan .
Singapore Workshop Value Chain Analysis for Corporates
; posted on
April 10th, 2017
Value Chain Analysis workshop for Corporations in Singapore - the bridge to align the operating model, corporate governance framework and the tax/ transfer pricing structure of MNE
You are running major company and individual risks for not having prepared a Value Chain Analysis fully synced with your traditional transfer pricing compliance..
The implementation Of BEPS Action Plan 13 In LATAM
; posted on
April 7th, 2017
The implementation of BEPS Action Plan 13 in LATAM
Tax administrations and international economic organizations have reached consensus for implementing international measures that will promote tax transparency amongst the business community..
Romanian Transfer Pricing Requirements
; posted on
April 6th, 2017
A readiness check on whether your Romanian subsidiary is fulfilling the local transfer pricing requirements.
Transfer pricing is a hot subject for companies operating in Romania.
EU Court To Review German Law Regarding Withholding Tax
; posted on
April 6th, 2017
The European Court of Justice has published a request for preliminary ruling filed by Finanzgericht Köln, which challenged German law that denies relief from withholding tax on some distributions of profits made to a nonresident parent companies.
Article 43 EC .
Hong Kong To Exchange Information With Portugal And South Africa
; posted on
April 6th, 2017
The Inland Revenue Department of Hong Kong announced that Hong Kong has signed agreements with Portugal and South Africa for conducting automatic exchange of financial account information in tax matters (AEOI).
Background: Hong Kong Support AEOI .
ATO To Recover $2.9 Billion From Seven Multinationals
; posted on
April 6th, 2017
On April 6, Australian Treasurer Scott Morrison said that Australia can claim $2.9 billion from seven audits of multinational companies, which are expected to be finalized before July.
UN Discusses International Cooperation In Tax Matters
; posted on
April 4th, 2017
During its 14th session run on 3 - 6 April, the UN Committee of Experts on International Cooperation in Tax Matters released several documents including modifications to the UN Model Double Taxation Convention between Developed and Developing Countries and draft guidance on transfer pricing issues in Extractive industries.
BEPS Changes to UN Model DT Convention .
Singapore And Ghana Sign DTA
; posted on
April 4th, 2017
The Singapore Government announced that it signed an Agreement for the Avoidance of Double Taxation (DTA) with the Republic of Ghana on March 31.
Background
Technology Solutions In A Post-BEPS World
; posted on
April 4th, 2017
There has been a complete paradigm shift in global taxation with the rise in audit risks caused by new global initiatives like the OECD’s BEPS Project.
JD Choi, CEO at Tax Technologies and TPA Global Member, explores the technology solutions that should be administered to mitigate these audit risks in a post-BEPS world.
OECD Publishes New Report on Technology Tools
; posted on
March 31st, 2017
The OECD published 'Technology Tools to Tackle Tax Evasion and Tax Fraud' report, which provides overview of the technology tools that tax authorities have implemented to address tax evasion and tax fraud.
Technology Tools Report .
UK Amends Country-By-Country Reporting
; posted on
March 31st, 2017
On March 30, the UK Her Majesty’s Revenue & Customs (HMRC) published amendments to Country By Country (CbC) reporting that extend the original statutory requirements to partnerships and adds new obligations for UK entities.
Updates .
Exposing The Real Economic Activity Of European Banks
; posted on
March 28th, 2017
On March 27, Oxfam published a report based on an analysis of Country-by-country reporting data exposing Europe’s 20 biggest banks that are registering over a quarter of their profits in tax havens, but just 12% of their revenue and 7% of their employees.
Oxfam Report .
OECD Publishes Comments Received on BEPS Action 6
; posted on
March 28th, 2017
OECD publicly published 33 comments received on draft examples prepared as part of the follow-up work on the interaction between the treaty provisions of the report on BEPS Action 6 and the treaty entitlement of non-CIV funds.
Treaty Entitlement Of Non-CIV Funds .
European Parliament Agrees on Hybrid Mismatch Amendments
; posted on
March 28th, 2017
EU Economic and Monetary Affairs Committee MEPs have voted in favor of amendments on EU’s anti-tax avoidance directive on Hybrid Mismatch with regards to third countries by 44 votes to 0 with 2 abstentions.
Background: Hybrid Mismatch .
Amazon Wins $1.5 Billion Dispute With IRS
; posted on
March 25th, 2017
On March 23, Amazon won more than $1.5 billion tax dispute with the Internal Revenue Service (IRS) over transactions involving a Luxembourg unit. The court concluded that the IRS acted in an arbitrary, capricious, and unreasonable manner when it applied a discounted-cash-flow method to a cost-sharing.
Israel Investigates Local Activities of Tech Giants
; posted on
March 25th, 2017
The Israel Tax Authority is undertaking an assessment of the activity of Facebook and Google in Israel by collecting information from media companies and customers that work with the Tech Giants. The Tax Authority aims to obtain better understanding of the economic activity and operational methods of Facebook and Google in Israel.
OECD Publishes Report On Tax Certainty And Other Subjects
; posted on
March 21st, 2017
The OECD published an OECD Secretary-General Report to G20 Finance Ministers that consists of the latest developments in the international tax agenda and an IMF/OECD report for G20 finance ministers on tax certainty. The report also includes a Progress Report to the G20 by the Global Forum on Transparency and Exchange of Information for Tax Purposes.
G20 Finance Ministers Address Digitalization And Tax Certainty
; posted on
March 21st, 2017
G20 finance ministers and central bank governors met in Baden-Baden (Germany) and called on OECD and the IMF to assess progress in enhancing tax certainty in 2018 and to produce an interim report on the implications of digitalization for taxation by spring 2018. The ministers further addressed developments in the areas of BEPS and Beneficial Ownership Information.
Australian Treasurer Says Tech Giants Are Forced to Pay Tax
; posted on
March 21st, 2017
On March 21, Treasurer of Australia Scott Morrison told Parliament that the Australian Taxation Office managed to get Facebook, Google and other multinational companies to pay tax in Australia based on their Australian profits as ATO could use "the power, the resources and the penalties to get the job done."
Facebook And Google Changed Their Tax Arrangements .
ATO Expects Seven Major Multinational Audits Soon
; posted on
March 17th, 2017
The Commissioner of Taxation, Chris Jordan, has delivered a speech reflecting on ATO's achievements. He informed that ATO observed positive changes in behavior from taxpayers and advisors, while notifying that at least seven major multinational audits are expected before July.
OECD Announces Further Developments
; posted on
March 17th, 2017
OECD announced further developments in international tax co-operation informing about six treaty partners of Hong Kong signing a competent authority agreement, the Global Forum monitoring the implementation of tax transparency standards and Panama depositing its instrument of ratification for the Convention on Mutual Administrative Assistance.
Hong Kong to Exchange Information .
Views On UK Spring Budget
; posted on
March 15th, 2017
On March 8, Chancellor Philip Hammond delivered the Spring Budget addressing long-term economic stability, fiscal responsibility, lowering corporate tax rate and fair tax system, among other subjects. Various industry leaders have provided their view on the new measures.
Swiss Federal Council Approved Withholding Tax Changes
; posted on
March 15th, 2017
On 10 March, The Federal Council approved the changes to the Withholding Tax Ordinance in order to strengthen the financing activities of groups in Switzerland. The reforms will affect groups in which a Swiss group company provides a guarantee for a bond of a foreign group company.
Singapore To Exchange Information with Belgium and Luxembourg
; posted on
March 15th, 2017
On March 10, the Government of Singapore signed Agreements on the Automatic Exchange of Financial Account Information with Belgium and Luxembourg. Luxembourg's Finance Minister Pierre Gramegna pointed out "green finance", alternative investment funds and fintech as the areas to deepen the cooperation with Singapore, and stressed the importance of open financial centers.
EU Report: "The US Emerging as Tax and Secrecy Haven Leader"
; posted on
March 13th, 2017
The European Parliament’s Inquiry Committee into Money Laundering, Tax Evasion and Tax Avoidance (PANA) published in-depth analysis on EU-US trade and investment relations and their impact on tax evasion, money laundering and tax transparency. One day earlier, the PANA Committee also held its third and last public hearing on “the role of intermediaries in the Panama Papers”.
The Netherlands Informs About Information Exchange With Iceland
; posted on
March 13th, 2017
The Ministry of Finance in the Netherlands published the text of Memorandum of Understanding (MoU) between Iceland and the Netherlands regarding the exchange of information in tax matters.
Information Content .
OECD Global Forum on VAT Meets in April
; posted on
March 8th, 2017
The OECD released a draft agenda on the 4th meeting of the OECD Global Forum on VAT, which will take place on April 12-14. The meeting will focus on the policy and operational challenges faced by tax authorities and on the efficient and the effective implementation of the International VAT/GST Guidelines.
Malaysia Joins BEPS Inclusive Framework
; posted on
March 8th, 2017
The OECD announced that Malaysia has joined the “Inclusive Framework on BEPS." Malaysia commits to the BEPS Project to participate as a BEPS Associate of the OECD's Committee on Fiscal Affairs.
India - Advance Pricing Agreements Help Resolving TP Issues
; posted on
March 8th, 2017
For the first time, the government may end up resolving about 100 transfer pricing issues by signing advance pricing agreements (APAs) with multinationals this fiscal, people in the know said according to The Economic Times .
Background: APA Program .
EU Collects Information On Member State Practices
; posted on
March 5th, 2017
The European Parliament's Committee on money laundering, tax avoidance and tax evasion (PANA) has updated the latest responses obtained from Member States on national definition, practices and methods related to tax evasion, tax avoidance and money laundering. The Parliament obtained 27 responses, awaiting the last reply from Malta.
The Australian Treasury Published Submission From DPT Consultation
; posted on
March 5th, 2017
The Australian Treasury published 21 submissions received on the exposure draft legislation for a Diverted Profits Tax (DPT), which was launched by the Australian Government on November 29.
Background: DPT .
"UK Corporate Tax Cuts Likely To Fail"
; posted on
February 28th, 2017
Following the suggestions of Prime Minister Theresa May and Chancellor Philip Hammond to lower UK corporation tax, concerns were raised by JPMorgan saying that lowering corporate tax rate "would not come close to offsetting the shock of a very hard Brexit," and would only lower UK's corporate tax revenues.
Background .
Singapore DTAs with India and Uruguay Enter Into Force
; posted on
February 28th, 2017
On February 27, the Inland Revenue Authority of Singapore informed that the Third Protocol amending DTA with India entered into force on February 27. The new DTA between Singapore and Uruguay will enter into force on March 14.
IRS Released Draft Instructions for Filing CbC Reports
; posted on
February 28th, 2017
The IRS published instructions for filing Form 8975 and accompanying the draft Schedule A (Country-by-Country Report) that apply to US multinational companies with more than $850 million in annual consolidated gross income.
Background: IRS Reports .
BEPS Action 4: Policy Considerations and Implementation Status
; posted on
February 27th, 2017
This article addresses BEPS Action 4. The authors provide a historical perspective of the relevant BEPS and EU measures, explain the highlights of BEPS Action 4, discuss the overlap between the different Actions, update readers on countryspecific implementation of BEPS Action 4, summarize existing case law in the area, present practical examples dealing with the impact of Action 4 on certain structures and, finally, provide concluding remarks.
Authors: René Offermanns ( IBFD ) - Steef Huibregtse , Louan Verdoner and Avisha Sood , TPA Global (Amsterdam) .
TPA Global Top-10 Solutions: "Are You 'In-Control' of Tax and Transfer Pricing?"
; posted on
February 27th, 2017
As G20 countries have become increasingly aggressive in their aim to combat corporate tax avoidance, full tax transparency is the new norm. The global tax and transfer pricing (“TP”) compliance has become more strict and complex due to new documentation requirements.
Adoption of the CUP Method for Commodity Transactions in new Colombian Tax Law
; posted on
February 24th, 2017
The recent tax reform -issued by Law 1819 of December 29/2016- introduced some changes in international tax law and transfer pricing rules. Relevant changes were adopted to introduce CbC report, adopt CFC legislation and define a legal framework regarding preferential tax regimes and beneficial owner to control base erosion and prevent tax deferral (see BEPS Action 5).
Irish Department of Finance Seeks Feedback On Corporate Tax Code
; posted on
February 24th, 2017
The Irish Department of Finance released public consultation paper seeking public feedback in connection with a review of Ireland’s Corporation Tax Code. The Government appointed an independent expert, University College Cork economist Seamus Coffey, to review Ireland's corporate tax code using the information collected during the public consultation.
ATO Publishes Simplified TP Record Keeping Options
; posted on
February 24th, 2017
On February 22, the Australian Taxation Office (ATO) released Practical Compliance Guideline outlining simplified transfer pricing record-keeping options intended to minimize the record-keeping for eligible taxpayers.
Purpose of the Guidelines .
Meet us at the International Job Fair Maastricht, the Netherlands
; posted on
February 22nd, 2017
Work @ TPA Global will be represented at The International Job Fair on Thursday the 23rd of February at Castle Vaeshartelt, Maastricht, The Netherlands.
During this day we will be giving various presentations, which would be the perfect opportunity to get to know us better.
The EU Commission Agrees on Hybrid Mismatch Rules
; posted on
February 22nd, 2017
On February 21, the European Commission welcomed the agreement reached on hybrid mismatches with regard to non-EU countries. A day earlier, the Council of the European Union has released two documents addressing the general approach and presidency compromise with respect to hybrid mismatches with third countries.
UAE: DTA With Lichtenstein And TIEA With Norway Enter Into Force
; posted on
February 22nd, 2017
The Agreement between the United Arab Emirates (UAE) and Liechtenstein for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital enters into force on February 24, 2017. The agreement between the UAE and Norway for the exchange of information relating to tax matters (TIEA) entered into force on February 15, 2017.
"EU made fundamental errors in State Aid Decision"
; posted on
February 22nd, 2017
On February 20, the EU published arguments of Apple’s appeal against the EU Commission’s State Aid Decision of August 30, 2016, in which the Commission concluded that Ireland gave illegal tax benefits to Apple worth 13 billion Euro. The tech giant says EU made fundamental errors in interpreting the way in which Apple generated its profits.
“We Talk Business” - TPA Global Announces New Global Service
; posted on
February 21st, 2017
Quick and professional advice is now just one click away!
Tired of going through pages after pages of regulations without knowing how they affect your company in practice? Spending hours trying to figure out which of the multitude of services offered by consultancy firms are best suited to your needs? Then book an hour of face-to-face communication with a TPA Global professional and receive an immediate answer to your question(s) today!.
EU's Financial Transaction Tax under Siege
; posted on
February 17th, 2017
Responding to recent news suggesting that the Financial Transaction Tax (FTT) has lost the support of Belgium and Slovakia (who are concerned over its impact on pension funds), Deputy Laurent Mosar of Luxembourg’s Christian Social People's Party (CSV) called on Luxembourg Finance Minister Pierre Gramegna to clarify the situation.
Background: FTT .
Irish Minister of Finance Addresses Corporate Tax
; posted on
February 17th, 2017
During the Plenary Session on February 16, Irish Minister for Finance Michael Noonan addressed the recent development of international taxation and problems with aggressive tax practices. Minister praised OECD BEPS project, but warned against the EU efforts that deviate from BEPS recommendations.
TPA Global Forms Alliance With SILC Global, The Netherlands
; posted on
February 16th, 2017
TPA Global, leading independent provider of global transfer pricing and valuation services, is pleased to announce that it has entered into an alliance with SILC Global, an independent consultancy firm based in Amsterdam, the Netherlands.
SILC Global is recognized as a leading independent consultancy firm in Europe, based in Amsterdam.
Transfer Pricing On Mining With A Focus On Africa - A Reference Guide For Practitioners
; posted on
February 16th, 2017
Amsterdam, 16 February 2017
This book presents the results of a study on transfer pricing (TP) with specific focus on mining in Africa commissioned in 2014 by the World Bank Group (WBG) in partnership with the International Mining for Development Centre (IM4DC). It sets a standard of reference for all tax practitioners in the mining industry dealing with transfer pricing.
Sharing Ideas And Experiences with Cross-border Dispute Settlement
; posted on
February 15th, 2017
Many tax treaties offer the possibility of resolving tax disputes through a Mutual Agreement Procedure (MAP). An increasing number of cross-border tax disputes and new international initiatives, however, ask for considering alternative ways of dispute settlement such as arbitration.
Swiss Voters Reject Corporate Tax Reform In Referendum
; posted on
February 15th, 2017
On February 12, Swiss voters blocked the government’s attempts to reform its corporate tax regime by abolishing ultra-low tax rates for multinational companies. Almost 60 percent of voters refused the plans that political and business elite embraced under international pressure.
EU PANA Committee Meets Lawyers, Accountants and Bankers
; posted on
February 15th, 2017
During the PANA meeting held on February 9, the committee held a second session on "The role of lawyers, accountants and bankers in Panama Papers", addressing the Scandinavian and German practice. In addition, insights from EU Member States regarding their country specific tax-related crime practices were published.
Australian Government Opens Consultation on Beneficial Ownership Register
; posted on
February 15th, 2017
The Australian Government invited interested stakeholders to share their views on the government's plan to establish the Beneficial Ownership Register. The government is seeking views on the details, scope and implementation of a beneficial ownership register for companies.
TPA Global Forms Alliance With GAW Consultancy, The Netherlands
; posted on
February 14th, 2017
GAW Consultancy is an innovative and leading independent Customs & Trade Compliance firm located in the EU. Having successfully managed and implemented projects for various different customers throughout the past five years, it is through this acquired diversified level of expertise which allows us to fully understand and meet the customer’s requirements from both a strategic and operational level.
A Simplified Guide to Increasing your Chances of Survival in Battles with Tax Authorities
; posted on
February 14th, 2017
Multinational enterprises (MNEs) have been facing disputes on tax and/or transfer pricing with tax authorities since their very inception. In light of the Base Erosion and Profit Shifting (BEPS) Action Plan of the OECD and the many UN initiatives to set new norms for tax and transfer pricing, many tax authorities around the globe will use the grey areas in these plans to challenge as many tax structures as they can, sometimes leading to nothing more than pure aggressive behavior.
Mining Industry Solutions
; posted on
February 13th, 2017
The mining industry is facing unprecedented pressures due to lack of market stability and major developments in regulations. At the same time G20 countries have become increasingly aggressive in their aim to combat corporate tax avoidance, imposing much more strict global tax compliance and new complex documentation requirements.
Introducing TPA Global's Greater China Practice
; posted on
February 13th, 2017
As a means to best serve our multinational clients operating in China as well as Chinese outbound “Go Out” companies to overseas, we are sending this email to inform you that TPA Global has recently reorganized its Greater China practice .
The new Greater China practice orchestrates all service areas of TPA Global through an experienced and multilingual team of professionals that possess the know-how and resources needed to perform engagements of all sizes.
EU Council Releases Presidency Draft Roadmap on BEPS
; posted on
February 11th, 2017
The European Council released a Draft EU-BEPS Roadmap by the Maltese Presidency of the Council setting out future work in the coming months. The roadmap addresses subjects such as hybrid mismatches, dispute resolution mechanism, the list of non-cooperative jurisdictions, renewed CCCTB, Patent Boxes, Code of Conduct (Business Taxation) and the Mandatory Disclosure rules.
Australian Proposal Diverted Profits Tax Bill 2017
; posted on
February 11th, 2017
The Australian Government introduced a proposal into the Australian Parliament for legislation to implement a new Diverted Profits Tax (DPT). This measure will apply in relation to tax benefits for an income year that starts on or after July 1, 2017.
Value Chain Analysis – the bridge between operating, governance and tax/TP models of an MNE
; posted on
February 9th, 2017
Value Chain Analysis has become a burning topic for discussion for many after the publication of the final report on BEPS Action Plan 13 and subsequent notifications by governments (especially the Chinese government) on the extent of information to be included in such analysis. Due to lack of consistent and clear guidance on what triggers the need for a value chain analysis, what a value chain analysis should entail, how the value chain analysis will be used by tax authorities around the globe etc.
TP Alert in Indonesia
; posted on
February 7th, 2017
As tax administrations and international economic organizations reach consensus for implementing international measures that will promote tax transparency amongst the business community, uncertainties rise around the scope and extent of some of the action points proposed to drive tax transparency between jurisdictions. For example, the implementation of Action plan 13.
Ireland's Appeal In The Apple State Aid Case Is Published
; posted on
February 7th, 2017
On February 6, the Irish government’s summary of legal proceedings was published in the Official Journal of the European Union. Just one week earlier, Irish Finance Minister Michael Noonan criticized the European Commission's decision at an EU meeting.
Britain’s Overseas Territories Meet To Discuss Brexit
; posted on
February 7th, 2017
On February 7, ministers of Britain’s overseas territories met with U.K. officials to discuss the fallout from Britain’s planned exit from the European Union, Cayman Compass informed.
India And Austria Amend DTA
; posted on
February 7th, 2017
On February 6, India and Austria signed the protocol for avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Background .
Japan and Austria Sign New DTA
; posted on
February 3rd, 2017
The Japan and Austria signed the Convention for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance.
Background .
EU To Contact US Administration Over Tax Haven Blacklist
; posted on
February 3rd, 2017
The United States appeared on the EU draft list of countries perceived as potential tax havens according to the list obtained by Handelsblatt Global . To make the final list of non-cooperative jurisdictions by the end of 2017, American and other tax authorities will be contacted this week by the European Union to clarify certain taxation policy.
A Career @ TPA Global
; posted on
February 3rd, 2017
TPA Global provides international businesses with integrated and value-added solutions in improving financial performance, operational efficiency, strategic development, talent coaching and tax / transfer. TPA Global identifies the right solutions for customers and targets; efficient and streamlined advisory and implementation processes which cut through operational complexities across functions and borders.
OECD Invites Multinationals For Feedback On MAP Peer Reviews
; posted on
January 31st, 2017
On January 30, OECD invited multinationals to provide input on the Mutual Agreement Procedure (MAP) peer review and monitoring process, which was launched in December 2016 under Action 14 of the BEPS Action Plan. At this stage, OECD gathers input on Austria, France, Germany, Italy, Liechtenstein, Luxembourg and Sweden.
USA - GAO Analyzed Potential Impact of BEPS
; posted on
January 31st, 2017
On January 27, the Government Accountability Office published a report that examines the potential impact of the OECD BEPS initiative’s revised international transfer pricing guidance on both the IRS and U.S. multinationals.
BEPS Analysis .
ATO Publishes Tax Risk Governance Review Guide
; posted on
January 31st, 2017
The Australian Taxation Office (ATO) published a tax risk management and governance review guide that sets out principles for board-level and managerial-level responsibilities and provides examples of design and operational effectiveness of control framework for tax risk.
Background .
Financial Services Industry Solutions
; posted on
January 31st, 2017
The financial services industry is facing unprecedented pressures due to lack of market stability and extensive development of new technologies. At the same time G20 countries have become increasingly aggressive in their aim to combat corporate tax avoidance, imposing much more strict global tax compliance and new complex documentation requirements.
Pharmaceutical Industry Solutions
; posted on
January 31st, 2017
The pharmaceutical industry is facing unprecedented pressures due to lack of market stability and major developments in regulations. At the same time G20 countries have become increasingly aggressive in their aim to combat corporate tax avoidance, imposing much more strict global tax compliance and new complex documentation requirements.
TPA Global Forms Alliance With CrossTax, The Netherlands
; posted on
January 30th, 2017
TPA Global, leading independent provider of global transfer pricing and valuation services, is pleased to announce that it has entered into an alliance with CrossTax, an independent tax advisory firm in the Netherlands.
CrossTax is recognized as a leading independent professional service firm dedicated to serving companies and individuals, both Dutch and foreign based, in optimising their cross-border transactions and activities from a tax and legal point of view.
Seven More Jurisdictions Join The Automatic Sharing of CbC Reporting
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January 27th, 2017
On January 27, the OECD informed that Gabon, Hungary, Indonesia, Lithuania, Malta, Mauritius and the Russian Federation have now signed the Multilateral Competent Authority Agreement for Country-by-Country Reporting (CbC MCAA), bringing the total number of signatories to 57.
Background: CbC Reporting for Tax Transparency .
Panama Papers - EU PANA Committee Meets to Discuss Tax Avoidance and Evasion
; posted on
January 27th, 2017
On January 24 and 26, the Inquiry Committee on the Panama Papers (PANA) held meetings addressing "The role of lawyers, accountants and bankers in Panama Papers" and the "Report on the inquiry into Money Laundering, Tax Avoidance and Tax Evasion". The recordings of the meetings have been published for the public.
Draft Toolkit On The Lack Of Comparables Released For Comments
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January 27th, 2017
On January 24, 2017 the so-called Platform for Collaboration on Tax (a joint initiative of the IMF, OECD, UN and World Bank Group) published a Discussion Draft on the Toolkit for Addressing Difficulties in Accessing Comparables Data for Transfer Pricing Analyses, which addresses the ways developing countries can overcome a lack of data on "comparables."
Background .
Valuation Services after BEPS
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January 24th, 2017
Apart from being a crucial tool for businesses for placing a value on their business to be used in case of sale of a business, partnership dissolution, mergers and acquisitions, loan/financing arrangements, the importance and need for valuation has been further strengthened by the OECD under BEPS Action Plans 8 – 10 by stating that valuation techniques may be used as a part of one of the five OECD approved transfer pricing methods. In situations where reliable comparable uncontrolled transactions for a transfer of one or more intangibles cannot be identified, it may also be possible to use valuation techniques to estimate the arm’s length price for intangibles transferred between associated enterprises.
VCA – A Bridge To Align Operating And Governance Models With Tax/TP Set-up
; posted on
January 24th, 2017
The value chain refers to the entire performance process of a company, which begins with the research and development and ends with the delivery to the end consumer. While a functional and risk analysis is geared to individual group companies, a value chain analysis applies on crosscompany processes within the Group.
Representation before tax authorities and Courts
; posted on
January 24th, 2017
Multinational enterprises (MNEs) have been facing disputes on tax and/or transfer pricing with tax authorities since their very inception. Over the course of time, a wide variety of instruments have been developed in order to address these disputes.
Oil & Gas Industry Solutions
; posted on
January 24th, 2017
The oil & gas industry is facing unprecedented pressures due to lack of market stability and major developments in regulations. At the same time G20 countries have become increasingly aggressive in their aim to combat corporate tax avoidance, imposing much more strict global tax compliance and new complex documentation requirements.
IRS Released A New Withholding Agreement And CbC Filing Guidance
; posted on
January 23rd, 2017
US IRS released an updated withholding foreign partnership agreement (WP agreement) and a withholding foreign trust agreement (WT agreement). The IRS also published an advance version of the Revenue Procedure 2017-23 addressing the process for filing the Country-by-Country (CbC) Report and other related documentation by ultimate parent entities of U.
EFTA Provides Guidelines On State Aid
; posted on
January 23rd, 2017
The EFTA Surveillance Authority (ESA) has adopted new guidelines on when a public measure does or does not involve state aid. The guidelines correspond to similar guidance adopted by the European Commission.
Britain to Leave EU Single Market
; posted on
January 20th, 2017
British Prime Minister Theresa confirmed that Britain will leave the EU single market, but will seek to establish a favorable free trade agreement. She stressed that the government is ready to take tax breaks to stay competitive if the EU would insist on punitive tariffs.
ATO Publishes TP Guidelines for Offshore Hubs
; posted on
January 20th, 2017
ATO published Practical Compliance Guideline PCG 2017/1 that addresses transfer pricing issues related to centralized operating models involving procurement, marketing, sales and distribution functions.
Centralized Operating Models .
US IRS Issue Tax Regulations On Disregarded Stock In Inversions
; posted on
January 18th, 2017
On January 18, the IRS has published final tax regulations and guidance on disregarded stock in inversions designed to fight tax avoidance associated with the inversion. The IRS also requests comments on proposed rulemaking by cross-reference to temporary regulations on Inversions and Related Transactions.
Trump Refuses Republican Border Adjustment Tax Reform
; posted on
January 18th, 2017
US President-elect Donald Trump has criticized the border adjustment provision, a feature of the House Republicans' corporate-tax plan, during an interview on January 16.
Border Adjustment .
Belarus and Hong Kong Conclude DTA
; posted on
January 18th, 2017
On January 16, Hong Kong and Belarus signed a comprehensive agreement for the avoidance of double taxation (CDTA) to eliminate double taxation with respect to taxes on income and on capital.
Allocation of taxing rights .
Juncker Blocked Secretly EU's Anti Tax Avoidance Efforts
; posted on
January 11th, 2017
European Commission President Jean-Claude Juncker faces renewed pressure as the leaked documents show he secretly blocked EU efforts to tackle tax avoidance by multinational companies during his time as Luxembourg's Prime Minister.
Background .
India - Portfolio Investors Shifting Base to Europe
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January 11th, 2017
Due to amended tax treaties with Singapore, Mauritius and Cyprus, Foreign Portfolio Investors (FPIs) are looking to shift their base to European jurisdictions such as France, Spain and the Netherlands, the Economic Times reported.
Tax Treaties .
HMRC Releases Criminal Case Highlights of 2016
; posted on
January 11th, 2017
On January 7, the HM Revenue and Customs revealed its top ten most significant fraud and organized crime cases of the last year, together with other statistics from 2016.
2016 Overview .
Argentina Succeeds With Tax Amnesty Programme
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January 11th, 2017
Argentinean Government announced that the country declared $97.842 billion in assets by the completion of a second phase of a broad tax amnesty programme that ended on December 31, 2016.
Global Tax Compliance Solutions For MNEs
; posted on
January 9th, 2017
With the increasing regulatory requirements, the globalization has brought its own challenges with respect to global tax compliance to multinational enterprises (“MNEs”). The answer to ‘growing tax related complexities’ in today’s world is the implementation of automated software solutions, in order to tackle the increased tax compliance burden in a timely, cost effective and efficient manner.
Colombia's New Anti Tax Evasion Law Not Enough
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January 9th, 2017
Colombia's newly approved tax reform law that imposes higher penalties for tax evasion will still fail to tackle tax evasion according to chief prosecutor. Néstor Humberto Martínez wrote a letter to the Minister of Finance earlier in January, criticizing the insufficient measures.
US Signs FATCA With Belgium And Taiwan
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January 6th, 2017
US Treasury Department informed that it has signed Model 1 FATCA intergovernmental agreement (IGA) with Belgium and a Model 2 FATCA intergovernmental agreement (IGA) with Taiwan.
Background: FATCA .
India and Kazakhstan Amend Existing DTA
; posted on
January 6th, 2017
On January 6, The Central Board of Direct Taxation (CBDT) announced that India and Kazakhstan have signed a protocol to amend the existing Double Taxation Avoidance Agreement.
Amended DTA in line with BEPS .
EU Commission Publishes New State Aid Investigation
; posted on
January 6th, 2017
On January 5, the EU Commission published the non-confidential version of the decision to open an in-depth investigation into Luxembourg's tax treatment of GDF Suez (now Engie) that is believed to be in breach of EU state aid rules.
Opening an In-Depth Investigation .
Cyprus calls for notification from MNEs with regards to Country-by-Country reporting
; posted on
January 6th, 2017
On December 30, 2016, the Ministry of Finance in Cyprus published a Decree regarding country-by-country reporting for multinational enterprises.
Country-by-Country Reporting
Application Of New Rules Regarding The Mandatory Exchange Of Information On Cross-Border Rulings
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January 4th, 2017
As of 1 January 2017 EU Member States are required to apply the automatic exchange of information on all new cross-border tax rulings that they release.
Application of Council Directive .
Peru - "Sixth Method" provisions are being replaced by other approach that seems more in line with Arm´s Length Principles
; posted on
January 3rd, 2017
On Saturday, December 31, 2016 Government published Legislative Decree 1312, in the Official Gazette Decree that modifying parts of the Income Tax, particularly related to Transfer Pricing:
Amends in paragraph 1 of point e) article 32-A of the Income Tax Law. Basically most of the "Sixth Method" provisions are being replaced by other approach that seems more in line with Arm´s Length Principles.
German Federal Council Adopts BEPS Legislation
; posted on
December 20th, 2016
The German Federal Council approved Country-by-Country Reporting and other BEPS related measures. These were approved by the Federal Parliament earlier on December 2 after several months of discussions on the approval of specific measures.
EU Commission Publishes The Apple Case Decision
; posted on
December 20th, 2016
The EU Commission has published the non-confidential version of the final negative decision adopted on 30 August 2016 concluding that Ireland gave illegal tax benefits to Apple, worth up to €13 billion.
Background .
IRS And Treasury Officials Meet at International Tax Conference
; posted on
December 19th, 2016
At the 29th Annual Institute on Current Issues in International Taxation, held on December 15-16, IRS and Treasury officials discussed recently released regulations on outbound transfers of goodwill, pending EU State aid cases and other related subjects.
Recently Released Documents .
Malta Issues Guidance On Mutual Agreement Procedure
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December 19th, 2016
The Commissioner for Revenue has published guidance issued under the provisions of Article 96(2) of the Income Tax Act on the use of Mutual Agreement Procedure (MAP).
Mutual Agreement Procedure (MAP) .
US Tax - President-Elect Trump Meets Top US Multinationals
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December 16th, 2016
On December 14, top executives of US Multinationals including Amazon, Facebook, Google, IBM, Apple and Tesla met with president-elect Donald Trump at Trump Tower in Manhattan to discuss country's taxation system and tax cuts among other topics such as creation of jobs or country's global competitiveness.
Invited Executives .
New Zealand To Update TP And Permanent Establishment Measures
; posted on
December 16th, 2016
On December 14, the Minister of Revenue Michael Woodhouse has released information on BEPS measures being considered by the Government that would strengthen the transfer pricing and permanent establishment rules to address base erosion and profit shifting (BEPS).
Background .
The Netherlands - Tax Treaty 2017 Update
; posted on
December 14th, 2016
On December 12, the Dutch Ministry of Finance issued a press release informing about its 2017 tax treaty negotiations agenda. The country will start tax treaty negotiations with with Andorra, Liechtenstein and Panama, and continue with other already initiated negotiations.
UK Publishes Draft Guidance on Hybrid Mismatch
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December 14th, 2016
On December 9, The HM Revenue & Customs published draft tax guidance to assist understanding of the application of the hybrids mismatch legislation that comes into effect on January 1, 2017. The HMRC seeks comments on the draft guidance on the hybrids mismatch legislation.
France Rejects Public Country-by-Country Reporting
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December 14th, 2016
On December 9, France’s Constitutional Council rejected public country-by-country reporting as it violated the freedom of enterprise guaranteed under the French Constitution.
Background: CbC Reporting in France .
EU Council Adopts New Directives At ECOFIN Meeting
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December 8th, 2016
On December 6, during the ECOFIN meeting the Council of the EU adopted directive granting access for tax authorities to beneficial ownership information. The Council also achieved consensus on a 'hybrid mismatches' draft directive with regards to third countries.
BRICS Countries Enhance Tax Cooperation
; posted on
December 8th, 2016
On December 5-6, BRICS Heads of Revenue and Experts on Tax Matters held a meeting in Mumbai during which they enhanced their mutual cooperation in international taxation and their efforts to combat BEPS. The countries reaffirmed their support for the automatic exchange of information and will begin exchanging by 2018 at the latest.
IRS Will Update Rules On Triangular Reorganizations
; posted on
December 6th, 2016
On December 2, the US IRS announced that it will issue regulations under Code Sec. 367 to modify the rules relating to the treatment of property used to acquire parent stock or securities in certain triangular reorganizations involving one or more foreign corporations.
OECD Discusses New Guidance on CbC Implementation
; posted on
December 6th, 2016
During a OECD BEPS webcast on December 5, senior members from the OECD's Centre for Tax Policy and Administration (CTPA) discussed BEPS related issues and further OECD's tax agenda. The CTPA addressed guidance on implementation of Country-by-Country (CbC) reporting, which was released on the same day.
Spain Announces Changes in Corporate Taxation
; posted on
December 6th, 2016
The Spanish Government announced a new Budget keeping the nominal rate (25%) but implementing additional measures to limit the tax deductibility of certain items of expenditure in order to increase country's revenue.
Tax Measures .
TPA Global Forms Alliance With Global Tax Support LLC, USA
; posted on
December 5th, 2016
TPA Global, leading independent provider of global transfer pricing and valuation services, is pleased to announce that it has entered into an alliance with Global Tax Support LLC, an independent tax advisory firm in the U.S.
Global Tax Support LLC offers a broad range of international tax and transfer pricing services.
TPA Global Forms Alliance With Stehlin & Associés, France
; posted on
December 3rd, 2016
TPA Global, leading independent provider of global transfer pricing and valuation services, is pleased to announce that it has entered into an alliance with Stehlin & Associés, an independent business law firm with headquarters in Paris (France) and ranked among the top 30 law firms in France.
Combining their technical expertise and industry experience, Stehlin & Associés' tax attorneys work together in a pragmatic way to implement their client’s projected operations and solve problems encountered by clients in their transfer pricing tax issues, such as transfer pricing tax planning, transfer pricing documentation (in particular selection of the appropriate method and profit level indicator), assistance to transfer pricing tax audits, litigation in front of the tax Courts.
TPA Global Forms Alliance With TPS, Spain
; posted on
December 1st, 2016
TPA Global, leading independent provider of global transfer pricing and valuation services, is pleased to announce that it has entered into an alliance with Transfer Pricing Specialists (TPS) , a leading independent Transfer Pricing firm in Spain.
Founded by professionals with many relevant years of experience doing business in the field, TPS is currently the main independent player in the country.
Singapore's MAS Concerned About Global Politics
; posted on
December 1st, 2016
The Monetary Authority of Singapore (MAS) released Financial Stability Review 2016, in which it warned against anti-globalization saying that political constraints together with rise of anti-globalization sentiment could impede effective policy-making. The Review further assessed potential risks within global financial market, property industry in Singapore and other related subjects.
ATO Welcomes Comments on Diverted Profits Tax
; posted on
December 1st, 2016
On November 29, the Australian government released draft legislation for implementation of the Diverted Profits Tax, designed to identify large multinationals seeking to avoid tax by shifting profits and will impose a penalty tax rate of 40 percent.
Background: DPT .
Value Chain Analysis (VCA) 'Survival Kit'
; posted on
December 1st, 2016
The year 2016 has been a bumpy ride for many corporations having to tackle multiple conflicting unilateral regulations as the implementation of BEPS gains further stronghold across the globe.
Therefore, keeping in mind the imminent need for clarity on preventive actions to be taken by corporations, TPA Global organised a conference in Amsterdam last week on ' Value Chain Analysis - The BEPS Generation of Functional Analysis'.
Canada Rolling Out A Crackdown On Tax Havens
; posted on
November 30th, 2016
The new strategy of Canada Revenue Agency to crack down on tax havens by reviewing every single electronic funds transfer (EFT) of more than $10,000 has delivered 750 audits and 20 criminal investigations.
Background .
Hungarian Parliament Approved 9% Corporate Tax Rate
; posted on
November 30th, 2016
Hungarian Parliament has approved the government’s tax package that cuts the corporate tax rate. Following the announcement of Prime Minister Viktor Orbán two weeks ago, the Parliament voted on the measure with 131 MPs in favour, 38 against and 25 abstentions.
Protocol to Singapore-Russia DTA Enters Into Force
; posted on
November 28th, 2016
On November 25, the Protocol amending the existing Singapore-Russian Federation Avoidance of Double Taxation Agreement (DTA) entered into force.
Protocol to DTA
Slicing the Pie - A Quantitative Value Chain Analysis
; posted on
November 23rd, 2016
Authors: Steef Huibregtse is CEO and Senior Partner and Maria Grigoryeva is Junior Associate at TPA Global .
Following BEPS publication on profit split on October 5, 2015 and July 4, 2016, MNEs are being challenged to apply the holistic view on their value chain.
OECD Reports Significant Progress on Tax Inspectors Without Borders
; posted on
November 23rd, 2016
On November 11, the OECD informed that a significant progress has been made within the Tax Inspectors Without Borders (TIWB) Project that provides assistance to countries on revenue recovery and improving local audit capacity. It currently runs thirteen projects in different countries and several new programs will be launched in the coming year.
European Parliament Approves Automatic Exchange of Bank Data
; posted on
November 23rd, 2016
On November 22, Members of the European Parliament voted in favor of the automatic exchange of bank data to track account owners by 590 votes to 32, with 64 abstentions.
Background .
The Netherlands Informs about first CbC Notification Deadline
; posted on
November 22nd, 2016
The Dutch State Secretary for Finance informed that it approved the deadline for taxpayers to file the first notification, which has to be done no later than September 1, 2017.
Background .
New Zealand Calls for Excluded Entities and Accounts within AEOI
; posted on
November 22nd, 2016
The New Zealand Inland Revenue published a fact sheet summarizing the criteria for financial institutions to categorize entities and accounts as “low risk”, which would allow them to be excluded from due diligence and reporting obligations under the Automatic Exchange of Financial Information (AEOI).
“Low Risk” Excluded Entities .
Cyprus and India Sign New DTA
; posted on
November 22nd, 2016
On November 18, the Republic of Cyprus and the Republic of India have concluded a new DTA, which will replace the previous DTA signed on June 13, 1994. The DTA is expected to come into effect in India, in respect of income derived in fiscal years beginning on or after April 1, 2017.
US And India Conclude Terms On Advance Pricing Agreement
; posted on
November 18th, 2016
The finance ministry of India informed that India and the US reached a deal on the terms and conditions of the first bilateral advance pricing agreement (APA) that will contribute to a more tax friendly environment for US multinationals. The two countries also resolved 108 pending transfer pricing disputes.
Singapore Agrees to Exchange Information with Canada
; posted on
November 18th, 2016
On November 16, Singapore and Canada concluded an Agreement on the Automatic Exchange of Financial Account Information to Improve International Tax Compliance. The two countries will commence the Automatic Exchange of Information under the CRS by September 2018.
Switzerland Plans to Make Fines and Bribes Non-Deductible
; posted on
November 17th, 2016
On November 16, the Swiss Federal Council informed that Switzerland plans to disallow companies to deduct financial sanctions with a penal character and bribes for tax purposes. The companies will however still be able to write off illegally gained profits seized by regulators.
UK and Switzerland Terminate Withholding Tax Agreement
; posted on
November 17th, 2016
On November 14, the Swiss Federal Department of Finance informed that the withholding tax agreement between Switzerland and the United Kingdom will be terminated on January, 1 2017. On the same day, the agreement between Switzerland and the EU on the automatic exchange of information in tax matters will enter into force.
Saudi Arabia Signs FATCA IGA
; posted on
November 17th, 2016
On November 15, Saudi Arabia has signed a Model 1 intergovernmental agreement (IGA) with the United States to Improve International Tax Compliance and to Implement FATCA.
Background .
Luxembourg to See More Economic Activity
; posted on
November 11th, 2016
Luxembourg is expected to have an economic impulse as a new unregulated fund product, the Reserved Alternative Investment Fund (RAIF), company law reforms and recent moves of Chinese banks to the country will significantly stimulate the activity in the country.
Brexit Shifts Some Economic Activity .
EU Commission Examines Possible Disincentives for Tax Avoidance Advisors
; posted on
November 11th, 2016
The European Commission has launched a public consultation to gather views on whether there is a need for EU action aimed at introducing more effective disincentives for intermediaries or tax payers engaged in operations that facilitate tax evasion and tax avoidance and how such action should be design.
Background: Intermediaries Assisting Tax Avoidance .
UK Signs DTAs With Lesotho And Colombia
; posted on
November 9th, 2016
On November 4, HM Revenue & Customs announced that the UK has signed the double taxation agreements with Lesotho and with Colombia. The agreements will enter into force when both countries have completed their legislative procedures and exchanged diplomatic notes.
Post-Brexit PE Investment in EU Hit Harder than in UK
; posted on
November 9th, 2016
According to a research the private equity (PE) industry in the UK will be hit less harder than in the EU following the Brexit.
UK Private Equity Fundraising .
Global Forum Furthers in International Tax Transparency Work
; posted on
November 5th, 2016
On November 2-4, The Global Forum on Transparency and Exchange of Information for Tax Purposes held its annual meeting in Tbilisi, Georgia. The meeting marked the completion of the first round of the Forum’s peer review process.
Saudi Arabia and Uruguay Sign MCAA
; posted on
November 4th, 2016
Saudi Arabia and Uruguay signed the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (MCAA) during the 9th Meeting of the Global Forum in Georgia on November 2.
Background: MCAA .
Cyprus, a Post-Brexit Partner to UK Funds Industry
; posted on
November 4th, 2016
On November 2, fund managers met in London as the Cyprus Investment Funds Association (CIFA) presented possibilities to use Cyprus’ financial services infrastructure. CIFA positioned itself as potential strategic partner to the UK funds industry due to uncertainty over UK’s ability to export financial services to the European Union following Brexit.
New India-Japan Tax Treaty Comes into Force
; posted on
November 2nd, 2016
The Indian Department of Revenue informed that the amended bilateral tax treaty between India and Japan has come into force as of October 29.
The Amending Agreement .
Reviewing Hedge Fund Administration M&A 2016 Report
; posted on
November 1st, 2016
A report containing recently published articles on hedge fund administration argues that custodian banks will extend fund administration services to alternative fund managers and addresses several key areas of hedge fund administration including, standardization, strategy, convergence and cultural fit.
M&A Will Improve Standardization .
European Commission's Research: EU To Benefit From CCTB & CCCTB
; posted on
November 1st, 2016
The European Commission released a report that investigates the economic impact of the common corporate tax base (CCTB) and a common consolidated corporate tax base with formula apportionment (CCCTB) within the EU. The paper concludes that the policy would result in a fairer and more efficient tax system and could have positive impact on GDP and welfare.
China Takes the Lead on Transfer Pricing Policy: Combating BEPS Through a Value Chain Analysis
; posted on
October 29th, 2016
Authors: Steef Huibregtse is the CEO and the founding partner of TPA Global, and Ying van Galen Wang is a project manager with the firm.
China’s State Administration of Taxation on June 29, 2016 issued a new transfer pricing regulation - Bulletin 42, which replaced specific sections stipulated in previous transfer pricing circulars2 in relation to annual filing of related-party transactions and contemporaneous transfer pricing documentation.
Top Transfer Pricing Challenges for the Agricommodities Industry (BEPS)
; posted on
October 28th, 2016
Authors: Steef Huibregtse is the CEO and the founding partner of TPA Global and Katerina Miari is an Associate at TPA Global in Amsterdam.
The complexities of transfer pricing, particularly in the midst of BEPS-driven reforms, have created significant burdens for multinational enterprises.
Singapore Agrees to Exchange Information with South Africa and Norway
; posted on
October 28th, 2016
On October 26, the Inland Revenue Authority of Singapore announced that Singapore has signed agreements for automatic exchange of financial account information (AEOI) with South Africa and Norway.
Automatic Exchange of Information .
EU To Take a Big Step in Corporate Tax Reform
; posted on
October 28th, 2016
The EU Commission published the proposals for Common Consolidated Corporate Tax Base (CCCTB) directive, Common Corporate Tax Base (CCTB) directive, the Amendments for Anti-Tax Avoidance Directive and Double Taxation Dispute Resolution Mechanisms.
CCCTB .
UK Might Use Tax Reductions to Put Pressure on the EU
; posted on
October 25th, 2016
Britain might slash corporation tax to 10 percent if EU member states block a free trade deal with the UK or block UK-based banks from accessing its market.
Background .
Five New Jurisdictions Will Exchange Country-By-Country Reports
; posted on
October 25th, 2016
The OECD announced that Brazil, Guernsey, Jersey, the Isle of Man and Latvia signed the Multilateral Competent Authority Agreement (MCAA) for the automatic exchange of Country-by-Country reports. At the same time, Brazil also signed the CRS Multilateral Competent Authority Agreement‎ (CRS MCAA).
South Korea’s IMM Private Equity Closed its Third Investment Fund
; posted on
October 25th, 2016
IMM Private Equity has closed its third investment fund focused on Korean market on KRW1.25trn ($1.15bn) after almost two years.
IMM Private Equity is based in Seoul and specializes in growth capital, turnaround, mezzanine, and buyout investments and cross-border transactions.
OECD Releases Document on MAP (Action 14)
; posted on
October 21st, 2016
On October 20, the OECD released key document that will form the basis of the Mutual Agreement Procedure (MAP) peer review and monitoring process under Action 14 of the BEPS Action Plan. The document was approved by the Inclusive Framework on BEPS and OECD will be seeking taxpayer input in the coming weeks.
Japan And Austria Agree In Principle On a New DTA
; posted on
October 21st, 2016
On October 20, the Government of Japan and the Government of the Republic of Austria have agreed in principle on the New Tax Convention for the Avoidance of Double Taxation with respect to Taxes on Income.
New Convention .
TPA Global Event 2016 - "Value Chain Analysis - the BEPS generation of functional analysis"
; posted on
October 21st, 2016
TPA Global conference topic is:
"Value Chain Analysis - the BEPS generation of functional analysis"
How to fight State Aid cases through a full "value chain analysis" - the Starbucks and Apple cases? (2)
; posted on
October 21st, 2016
In the public version of the “Starbucks decision” of the European Commission, quite often reference is made to the transfer pricing report of Starbucks. Although no public version of this transfer pricing report is made available, it seems reasonable to conclude that the report did not include a proper value chain analysis.
US and Mexico Revise Unilateral APA Applications Involving Maquiladoras
; posted on
October 18th, 2016
On October 14, the Internal Revenue Service (IRS) announced that US taxpayers with maquiladora operations in Mexico will not be exposed to double taxation if they enter into a unilateral advance pricing agreement (APA) with the Large Taxpayer Division of Mexico’s Servicio de Administración Tributaria (SAT) under a new agreement.
Background: Maquiladoras .
September Shift in Hedge Funds
; posted on
October 18th, 2016
Following a year of criticism over high fees and the disappointing performance of the global hedge fund industry, September has brought hope for change with outperforming equity hedge and event-driven strategies.
Background: Last Year in Hedge Fund Industry .
BRICS Countries Target Tax Avoidance
; posted on
October 18th, 2016
On October 16 at the BRICS summit, the BRICS countries stressed the need for a mutually acceptable mechanism among BRICS nations to fight tax avoidance. The countries also agreed to set up an independent rating agency based on market-oriented principles to further strengthen global financial architecture.
Singapore Issues e-Tax Guide for Country-by-Country Reporting
; posted on
October 13th, 2016
The Inland Revenue Authority of Singapore (IRAS) issued an e-Tax Guide on Country-by-Country Reporting. Singapore-headquartered MNEs meeting certain conditions are required to prepare and file CbC Reports to the IRAS for financial years beginning on or after January 1, 2017.
European Council - Conclusions on Tax Transparency
; posted on
October 13th, 2016
During the European Council meeting on October 11, the Council adopted conclusions on tax transparency in response to a Commission communication on tax transparency following the April 2016 Panama Papers revelations.
Large-Scale Concealment of Funds .
UN Tax Committee Suggest Changes in its TP Documents
; posted on
October 12th, 2016
The UN Committee of Experts on International Cooperation in Tax Matters has released several reports that suggest changes to the UN’s transfer pricing manual for developing countries. Other reports addressing issues such as model tax treaty or mutual agreement procedure were released in advance of UNs annual meeting taking place in Geneva on October 11-14.
EU: Agreement Reached on Financial Transaction Tax
; posted on
October 12th, 2016
On October 10, the finance ministers of the 10 EU member states that work on developing financial transaction tax (FTT) held a meeting in Luxembourg. The ministers had agreed on some important measures that form "the core engine" of FTT, but further details have to be agreed on in the coming weeks.
Commissioner Vestager Discusses State Aid with Irish MEPs
; posted on
October 12th, 2016
During the European Commission's structured Dialogue with EU's Competition Commissioner Margrethe Vestager held on October 10, the Commissioner defended the position of the Commission on the Apple Ireland case.
Problem .
BEPS and Transfer Pricing in MNCs: Policy Considerations and Practices
; posted on
October 11th, 2016
The changes proposed by the OECD BEPS Action Plan in October 2015 have the potential to substantially challenge the whole tax and transfer pricing landscape for many taxpayers. More specifically, with a radical attack on preferential regimes and tax avoidance schemes and enhanced transparency through, for example, for example, Country-by-Country (“CbC”) reporting, tax authorities and other governmental units will be able to understand and where appropriate challenge how MNEs allocate their profits and taxes globally.
UK Will not Cut Corporate Tax Rate to 15 Percent
; posted on
October 7th, 2016
During the Conservative Party conference in Birmingham held on October 3, the new Chancellor Philip Hammond said the government will follow its plans to lower Britain's corporation tax rate to 17 percent by 2020, instead of 15 percent as suggested by his predecessor George Osborne.
Background: Rate of 15 percent .
Four Updates on Japanese DTAs
; posted on
October 7th, 2016
The Japanese Ministry of Finance announced that the country will begin negotiations for Tax Convention with Austria. The Ministry also informed that it signed DTA with Slovenia and that Protocol Amending Tax Convention with India and new tax agreement with Germany will enter into force by the end of October 2016.
DTA between Hong Kong and Korea Enters into Force
; posted on
October 7th, 2016
Hong Kong’s tax authority announced that the agreement between Hong Kong and Korea for the avoidance of double taxation and prevention of income tax evasion came into force.
The agreement was initially signed in July 2014, which was followed by the ratification procedures in Hong Kong and Korea.
Irish Finance Minister Elaborates on Apple Case
; posted on
October 7th, 2016
On October 4, Irish Minister for Finance Michael Noonan published an opening statement to the Irish Senate regarding the European Commission’s decision that Ireland provided unlawful state aid to Apple. The minister provides wide background information and elaborates on the flaws in the Commission's argumentation.
Foreign Banks Targeted in Germany
; posted on
October 7th, 2016
German state prosecutors are investigating 57 foreign banks for tax evasion using information obtained from self-declared tax evaders. According to the media, the voluntary disclosures provide very valuable information and became a favorite method of tax prosecutors to track down the evasions.
Switzerland Ratifies Multilateral Agreement on Tax Transparency
; posted on
September 29th, 2016
Switzerland deposited the instruments of ratification for the Multilateral Convention on Mutual Administrative Assistance in Tax Matters (Administrative Assistance Convention) with the OECD in Paris.
To Enter into Force .
Draft Guidance on Northern Ireland Corporate Tax Regime
; posted on
September 29th, 2016
The HMRC has released a 120 pages draft guidance on the operation of Northern Ireland’s corporation tax regime and invites interested parties for comments. The guidance covers calculations of 'profits or losses', corporate tax rate of 12.
Thailand Will Amend its Tax Collection Rules for Internet and Tech Firms
; posted on
September 28th, 2016
Thailand’s Revenue Department head, Prasong Poontaneat said in the interview that Thailand is planning to toughen tax collection rules for internet and technology firms to update the country's tax laws.
Background .
Switzerland: Consultation on Amending the Withholding Tax Ordinance
; posted on
September 28th, 2016
The Swiss Federal Council issued a press release announcing that it has initiated the consultation procedure on an amendment to the Withholding Tax Ordinance. The aim of the proposed amendments is to strengthen financing activities of groups in Switzerland.
Canada: Too Late for Voluntary Disclosure Program
; posted on
September 28th, 2016
On September 26, the Canada Revenue Agency (CRA) announced in a statement that those taxpayers that have been identified in the Panama Papers and are being reviewed or audited cannot qualify for the Voluntary Disclosure Program anymore.
Background .
Value Chain Analysis - The BEPS Generation of Functional Analysis (2)
; posted on
September 26th, 2016
The value chain for any firm links value-creating processes and activities. It refers to the entire performance process of a company, which begins with the research and development and ends with the delivery to the end consumer.
Singapore and the UK Sign Agreement for AEOI
; posted on
September 25th, 2016
On September 16, the Inland Revenue Authority of Singapore (IRAS) and Her Majesty’s Revenue and Customs (HMRC) signed a Competent Authority Agreement on the automatic exchange of financial account information (AEOI) based on the Common Reporting Standard.
Exchange of Information .
Revitalizing Your Digital Strategy | Tax scandles and strategic challenges faced by Apple in 2016!
; posted on
September 22nd, 2016
A 13 billion tax penalty for Apple, yet who’s to blame? Apple had sweet-heart deals paying less than 1% tax since 2004.
According to Apple, no laws were broken, the tax breaks were permitted by the Irish government.
Tax Risk Management & Transfer Pricing for Life Sciences
; posted on
September 22nd, 2016
As regulations around the world become both more numerous and stringent, and enforcement and penalties increase in the highly regulated life sciences sector, companies may benefit from taking a risk-based approach to tax planning compliance, execution, and tracking.
The conference agenda will focus on the most problematic areas in tax risk management such as tax compliance and governance, transfer-pricing and country-by-country reporting issues management and others:.
Tech Giant Receives Another Tax Bill
; posted on
September 22nd, 2016
Japan's Tokyo tax authorities ordered a Apple iTunes unit in Japan to pay $118 million in penalty taxes for failing to properly pay withholding tax on usage rights for software allowing online music and video distribution. Following the series of Apple's tax bills, the EU Competition Commissioner Margrethe Vestager defended the EU's Apple Ireland case during her visit in Washington on September 19.
ATO Warns Multinationals Over Two Avoidance Schemes
; posted on
September 22nd, 2016
On September 20, the Australian Taxation Office (ATO) has cautioned multinationals against international profit shifting by multinational companies. In two alerts, ATO addressed 'Cross-Border Round Robin Financing Arrangements' and 'Restructures in response to the Multinational Anti Avoidance Law (MAAL) involving foreign partnerships'.
Indonesia Investigates Internet Search Giant Over $400m Tax Bill
; posted on
September 22nd, 2016
The Indonesian Tax office launched investigation on Google over suspicion of tax avoidance over last five years. If found guilty, Google would have to pay $400m (€358m) back in taxes with an $18 million fine.
EU Launches Work On EU's Tax Haven Blacklist
; posted on
September 22nd, 2016
The European Commission has launched its work to create first common EU list of non-cooperative tax jurisdictions by presenting a pre-assessment ('scoreboard of indicators') of all third countries according to key indicators.
Member States Select Non-cooperative Jurisdictions .
How through a proper Value Chain Analysis the tax payer takes in control of the new generation of TP documentation requirements (BEPS Action 13)
; posted on
September 19th, 2016
How through a proper Value Chain Analysis the tax payer takes in control of the new generation of TP documentation requirements (BEPS Action 13).
A Value Chain Analysis (‘VCA’) considers an end to end view of a company’s activities, enabling a better perspective on the way a business works and how each component contributes and creates value.
European Parliament Supports Decision On Irish State Aid
; posted on
September 15th, 2016
During the debate on September 13, the European Parliament has strongly supported the European Commission’s conclusion that Ireland granted Apple illegal tax benefits, which enabling the company to pay substantially less tax than other businesses over many years.
Background .
Pakistan Signs OECD's Convention on Tax Assistance
; posted on
September 15th, 2016
Pakistan signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters and became the 104th jurisdiction to join the Convention.
Background
New Course: Transfer Pricing – BEPS for Beginners
; posted on
September 14th, 2016
e-Bright and TPA Global have launched the 4th course of the Transfer Pricing courses
‘BEPS for Beginners’
Indonesia - Shell Companies Not Allowed Under Tax Amnesty
; posted on
September 14th, 2016
The Indonesian government is requiring individuals or entities that want to take part in its new tax amnesty program to dissolve any shell companies they own overseas.
Background .
India & Mauritius: Foreign Investors Surprised by Aggressive Stance
; posted on
September 14th, 2016
The Indian tax office has started questioning foreign direct investors using Mauritius to bet on Indian stocks regarding special purpose vehicles and their establishments in Mauritius.
Background .
US-Korean FATCA Entered Into Force
; posted on
September 14th, 2016
On September 8, a Model 1 intergovernmental agreement (IGA) signed by the US and South Korea entered into force.
Background
HMRC Opens the Worldwide Disclosure Facility
; posted on
September 8th, 2016
On September 5, HMRC opened the Worldwide Disclosure Facility allowing multinationals to disclose a UK tax liability that relates wholly or in part to an offshore issue. On September 6, HMRC followed with a guidance to tax avoidance elaborating on how to get help to settle the tax affairs.
Impact of Apple Case On Singaporean Companies In Question
; posted on
September 8th, 2016
Local media in Singapore have questioned the situation in the EU after the Apple case. Singapore firms could be targeted by the EC if these companies enter into anti-competitive agreements that distort competition within the EU.
G20 Leaders Push For Tax Transparency
; posted on
September 7th, 2016
G20 leaders have met during the summit in Hangzhou, China, held September 4–5, where they shared their views on current international tax environment. The countries endorsed a proposal on the objective criteria to identify non-cooperative jurisdictions with respect to tax transparency.
Singapore And Australia To Share Data
; posted on
September 7th, 2016
On September 6, the Inland Revenue Authority of Singapore has informed that Singapore and Australia have entered into a Competent Authority Agreement on the automatic exchange of financial account information (AEIO) based on the Common Reporting Standard (CRS).
Background: Singaporean Hubs .
European Commission Criticized Over Apple Case
; posted on
September 7th, 2016
Following the EU's decision on Apple Ireland case, several US politicians including treasury secretary Jack Lew have strongly criticized the European Commission over its conclusion. The International Chamber of Commerce have expressed strong disagreements and warned against possible negative outcomes of the decision.
OECD to Hold First 'Inclusive Framework for BEPS Implementation' Meeting
; posted on
September 7th, 2016
On June 30 and July 1, representatives of countries and jurisdictions worldwide will gather in Kyoto, Japan, for a first meeting of the inclusive framework organized to take forward the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project.
Governance, Structure and Work Program .
TPA Global Launches New Global Portal
; posted on
September 2nd, 2016
TPA Global is proud to announce that it has launched a completely redesigned and enhanced web site.
"Moving forward, we will be updating and improving the web site on a continual basis, but it should be clear today that TPA Global and its professionals are committed to doing a better job communicating with the information demanding corporate transfer pricing market and using technology to operate more efficiently," said managing partner Steef Huibregtse.
Dutch-Ethiopian DTA Entered into Force
; posted on
September 1st, 2016
On August 30, the Dutch Government announced that the convention between the Kingdom of the Netherlands and the Federal Democratic Republic of Ethiopia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes and income entered into force on September 1, 2016.
Background .
US Tech Giants Warn the Netherlands over Changing Its Tax Regime
; posted on
September 1st, 2016
The Silicon Valley Tax Directors Group (SVTDG), which unties 85 biggest US technology companies, have sent a letter addressed to the Dutch prime minister, State Secretary of Finance and to the ministers of Finance, Economic Affairs and Trade, warning the country not to change its favorable tax regime and to resist the pressure from the EU.
Background .
Brazil Expected to Push Against Tax Havens
; posted on
September 1st, 2016
At the upcoming G20 Summit in Hangzhou, China, Brazilian officials will join several non-governmental agencies that focus on fiscal havens and tax evasion. Brazil also plans to expand cooperation in trade and services with China and schedule a seminar for Chinese investors during the summit.
China Policy in the Lead – A Full Value Chain Analysis for FY 2016 required
; posted on
September 1st, 2016
The China State Administration of Taxation ("SAT"), on June 29, 2016 issued "the Public Notice on Matters Regarding Refining the Filing of Related Party Transactions and Administration of Contemporaneous Transfer Pricing (“TP”) Documentation Public Notice of the State Administration of Taxation [2016] 42” ("Notice 42"), which replaced certain sections laid down in “Guoshuifa [2008] Circular 114 in relation to annual filing of related party transactions and certain sections laid down in the “Guoshuifa [2009] (“Circular 2”) in relation to contemporaneous TP documentation.
Notice 42 mainly reflects the Chinese tax authority’s position in responding the international standard set out in the OECD/G20 BEPS Action 13 ~~ (“Action 13”) in relation to TP documentation and country-by-country (“CbC”) reporting.
Corporate ‘Tax’ Governance: A Necessary Addition to Best Practices for Businesses?
; posted on
September 1st, 2016
Management of an entity’s tax strategy has historically been down to finance directors and has received little attention from boards. However, the growing reputational risk attached to strategies that incur a notably low tax bite and the ensuing BEPS project has forced boards to focus on their taxes as much as they do other areas of corporate governance.
Exchange of Information on Tax Rulings and APA’s
; posted on
August 30th, 2016
In reference to the rules issued by OECD/G20 and EU, the Dutch tax authority (‘DTA’) is asking taxpayers to provide the required information on the tax ruling they agreed with the DTA. The rules are aimed at improving transparency on tax rulings granted by jurisdictions and are driven by the outcomes of Action 5 of the OECD/G20 BEPS Project and by the amendments of EU Directive 2011/16/EU provide for the mandatory spontaneous exchange of information between Member States.
Japan and Panama Sign a Tax Information Exchange Agreement
; posted on
August 30th, 2016
On August 26, the Japanese ministry of finance announced that the government of Japan has signed a Tax Information Exchange Agreement (TIEA) with the government of the Republic of Panama.
Effective Exchange .
EU: Ireland Granted Illegal Tax Benefits to Apple Worth of €13 Billion
; posted on
August 30th, 2016
On August 30, the European Commission concluded that Ireland gave Apple illegal tax benefits of €13 billion between the years 2003 to 2014. The Irish government has been ordered to recover the funds plus interest.
OECD Publishes Comments On Amendments To Chapter IX TP Guidelines
; posted on
August 26th, 2016
On August 24, The OECD published the comments it received on the conforming amendments to Chapter IX of the OECD Transfer Pricing Guidelines, "Transfer Pricing Aspects of Business Restructurings."
Background .
Singapore Signs DTA With Ethiopia and BIT with Mozambique
; posted on
August 26th, 2016
On August 24, the Singaporean Ministry of Finance informed that it signed an Avoidance of Double Taxation Agreement (DTA) with Ethiopia and a Bilateral Investment Treaty (BIT) with Mozambique.
DTA with Ethiopia .
OECD Publishes Comments On Amendments To Chapter IX TP Guidelines
; posted on
August 26th, 2016
On August 24, The OECD published the comments it received on the conforming amendments to Chapter IX of the OECD Transfer Pricing Guidelines, "Transfer Pricing Aspects of Business Restructurings."
Background .
OECD Releases Discussion Draft On Branch Mismatch (Action 2)
; posted on
August 24th, 2016
The OECD invited interested parties to provide comments on branch mismatch structures under Action 2 (Neutralizing the Effects of Hybrid Mismatch Arrangements) of the BEPS Action Plan.
Background .
Sweden Warns UK Against Corporate Tax Cuts
; posted on
August 24th, 2016
During an interview on August 21, Swedish Prime Minister Stefan Loefven warned the UK against cutting corporate taxes or implementing similar competitive measures. He said that such moves would damage the relations with the EU states and make Brexit talks 'more difficult'.
Trinidad and Tobago Signs IGA With US
; posted on
August 24th, 2016
On August 19, Trinidad and Tobago and the United States have signed an Inter-Governmental Agreement (IGA) as part of the implementation of the Foreign Account Tax Compliance Act (FATCA).
Background .
OECD Releases Discussion Draft On Branch Mismatch (Action 2)
; posted on
August 24th, 2016
The OECD invited interested parties to provide comments on branch mismatch structures under Action 2 (Neutralizing the Effects of Hybrid Mismatch Arrangements) of the BEPS Action Plan.
Background .
Irish - Ethiopian DTA Entered Into Force
; posted on
August 16th, 2016
The Irish Revenue announced that the Convention between Ireland and Ethiopia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income entered into force on August 12, 2016.
Background .
Mauritius and Korea Sign Tax Information Exchange Agreement
; posted on
August 16th, 2016
On August 11, Mauritius and the Republic of Korea signed a Tax Information Exchange Agreement (TIEA). Finance Minister of Mauritius, Pravind Jugnauth, reaffirmed the intention to initiate negotiations on a Double Taxation Avoidance Agreement with Korea.
ATO Warns about Specific Tax Avoidance Arrangements
; posted on
August 12th, 2016
On August 10, the Australian Taxation Office (ATO) issued 3 Taxpayer Alerts cautioning large companies and multinationals seeking to avoid tax. The Taxpayer Alerts regard the arrangements involving offshore permanent establishments, GST implications in response to the Multinational Anti-Avoidance Law (MAAL) and Thin capitalization.
Intergovernmental Agreement Curacao-USA Is Now In Force
; posted on
August 12th, 2016
The intergovernmental agreement (IGA) between Curacao and the United States that implements FATCA Model 1 is now in force, Curacao Chronicle informed.
Background
Indonesia to Cut Corporate Tax Rate to Stay Competitive
; posted on
August 12th, 2016
Indonesia's President Joko Widodo informed that he is considering cutting the corporate tax rate to 17 percent from 25 percent in order to match Singapore's corporate tax rate.
Tax Rate Cut .
New Zealand - Simplified Tax Processes and Tighter Foreign Trust Rules
; posted on
August 11th, 2016
Revenue Minister Michael Woodhouse informed that New Zealand has introduced a tax bill to simplify tax processes, reduce compliance costs for smaller businesses, and tighten foreign trust disclosure rules. The bill includes the necessary measures to implement the G20/OECD standard for the Automatic Exchange of Information for financial institutions.
BEPS implemented into the LATAM countries: what is happening in that region?
; posted on
August 4th, 2016
In the case of LATAM countries the majority are not OECD members and their contribution to BEPS measurements has been limited. Nevertheless, some LATAM countries already have or have announced to implicitly or explicitly implement regulations that are anti-BEPS.
OECD - Discussion Draft on Action 4 in the Banking and Insurance Sectors
; posted on
August 3rd, 2016
The OECD invited interested parties to provide comments on a discussion draft which deals with approaches to address BEPS involving interest in the banking and insurance sectors under Action 4 (Interest deductions and other financial payments) of the BEPS Action Plan.
Action 4 - Background .
IRS seeks $3-5bn from Social Media Giant over Transfer Pricing
; posted on
August 2nd, 2016
Facebook has informed that the US Internal Revenue Service delivered a "notice of deficiency" seeking $3bn (€2.68bn) to $5bn, plus interest and penalties, based on the agency's audit of Facebook's transfer pricing.
OECD - Discussion Draft on Action 4 in the Banking and Insurance Sectors
; posted on
August 2nd, 2016
The OECD invited interested parties to provide comments on a discussion draft which deals with approaches to address BEPS involving interest in the banking and insurance sectors under Action 4 (Interest deductions and other financial payments) of the BEPS Action Plan.
Action 4 - Background .
IRS - Jurisdictions Need To Have IGA Implementation Plan In Place
; posted on
August 2nd, 2016
The US Treasury has announced that it will begin updating the Intergovernmental Agreement (IGA) List and will stop treating a country as if it has the Foreign Account Tax Compliance Act (FATCA) IGA “in effect” if the country does not prove that it has a plan to bring the IGA into force.
Background .
New Zealand Not Afraid of EU's Blacklist
; posted on
August 2nd, 2016
New Zealand is not likely to end up on EU's blacklist despite the local media’s claim that New Zealand has been put on the EU's radar especially due to many links revealed by the Panama Papers, for which the European Union set up a special investigation committee.
Background: EU Blacklist .
South African Treasury To Curb Tax Avoidance Through Trusts
; posted on
August 2nd, 2016
The National Treasury informed its plans to introduce a new section into the Income Tax Act that will address the avoidance of estate duty by moving assets to a trust. The National Treasury is concerned abut the interest free loans or loans with interest below market rates without being subject to either donations tax or estate duty, which is a common approach in South Africa.
Investors and Private Equity Associations Are Concerned About India-Singapore Tax Treaty
; posted on
August 1st, 2016
Foreign portfolio investors and private equity associations are concerned about the India-Singapore tax treaty, which is expected to be signed later this year. In the last month, the associations have written to the government requesting several changes on the tax treaty.
Egypt Joins the Global Forum on Exchange of Information
; posted on
July 28th, 2016
The OECD announced that Egypt has joined the Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum), bringing its membership to 135. The last members to join the Global Forum were Lebanon and Paraguay in May.
Insights into BEPS Implementation By MNEs
; posted on
July 22nd, 2016
A new 2016 Global BEPS Readiness Survey examined how multinational enterprises are reacting to and preparing for the BEPS, revealing problems multinationals have adjusting to the new rules. The findings uncovered trends, revealed risks and exposed pain points on a global scale.
Insights into BEPS Implementation By MNEs
; posted on
July 21st, 2016
A new 2016 Global BEPS Readiness Survey examined how multinational enterprises are reacting to and preparing for the BEPS, revealing problems multinationals have adjusting to the new rules. The findings uncovered trends, revealed risks and exposed pain points on a global scale.
Jamaica Joins Inclusive Framework on BEPS Implementation
; posted on
July 21st, 2016
The OECD announced that Jamaica has become the 85th member of the Inclusive Framework on BEPS Implementation. The OECD informed that more countries that attended the Kyoto meeting on June 30, are expected to join the Framework.
OECD Releases Discussion Draft on Group Ratio Rule (Action 4)
; posted on
July 11th, 2016
On July 11, the OECD invited interested parties to provide comments on a discussion draft which deals with elements of the design and operation of the group ratio rule under Action 4 (Interest deductions and other financial payments) of the BEPS Action Plan.
Fixed Ratio Rule .
Hong Kong Ready for Automatic Exchange of Information
; posted on
July 6th, 2016
On June 30, The Inland Revenue (Amendment) (No. 3) Ordinance 2016 (the Amendment Ordinance) came into effect, the Hong Kong Inland Revenue Department has informed.
OECD Releases Two Discussion Drafts on BEPS Actions 7 and 8 - 10
; posted on
July 6th, 2016
The OECD has released BEPS discussion drafts on attribution of profits to permanent establishments, which deals with work in relation to BEPS Action 7, and revised guidance on profit splits, which deals with work in relation to BEPS Actions 8-10.
Discussion Draft - Action 7 .
OECD Releases Guidance on the Implementation of CbC Reporting
; posted on
July 1st, 2016
The OECD has released guidance on implementing country-by-country (CbC) reporting, as set out in Action 13 Report “Transfer Pricing Documentation and Country-by-Country Reporting” of the base erosion and profit shifting (BEPS) project.
Country-by-Country Reporting .
European Parliament Adopts Anti-Tax Avoidance Directive
; posted on
June 10th, 2016
The European Parliament voted overwhelmingly in favor of the Anti-Tax Avoidance Directive, proposed by the European Commission in January 2016, which aims at tightening rules against tax avoidance. At the same time, the parliament has also set up a “Panama Papers” inquiry committee to investigate alleged contraventions and maladministration.
EU Investigate Members' TP Rulings under State Aid
; posted on
June 7th, 2016
The EU Commission released a working paper identifying problematic areas in profit allocations and arm’s length standard across Member States’ transfer pricing rulings. The working paper investigates whether certain rulings would be prohibited under EU's state aid rules.
EU: Multinationals Grilled at TAXE Meeting
; posted on
March 19th, 2016
Representatives from Apple, Google, Ikea and McDonald’s were questioned on their tax structures in Europe at a special hearing of the European Parliament’s special committee on tax on Tuesday, March 15, in Brussels. The MEPs also asked on feedback on specific areas of BEPS project.
How to make intercompany loans BEPS proof
; posted on
March 17th, 2016
In this article we provide four “true or false” statements on how the intercompany debt financing has become vulnerable and how to resolve the transfer pricing issues around that.
Debt as intercompany financing with excessive interest deductions has come under greater scrutiny of the tax authorities after the OECD published its final work on Action Points relating to intercompany financing in October last year.
How To Make Intercompany Loans BEPS Proof
; posted on
March 17th, 2016
Authors: Steef Huibregtse, Virender Sharma and Maria Grigoryeva (consultants at TPA Global)
Debt as intercompany financing with excessive interest deductions has come under greater scrutiny of the tax authorities after the OECD published its final work on Action Points relating to intercompany financing in October last year. In the light of the aforementioned, and the current practice of MNEs on intercompany loans, this article delves into 4 “true or false” statements which are relevant for various stakeholders including MNEs to ponder over.
Standardize Your Transfer Pricing Documentation System in light of OECD project on BEPS Action 13 report
; posted on
February 18th, 2016
In order to standardize, simplify and streamline multinational enterprises’ (MNEs) transfer pricing (“TP”) documentation and to improve global consistency, but still complying with local TP requirement, especially in the light of the OECD project on BEPS Action 13 report 1, TPA has designed this project to provide global TP documentation on a standardized approach through building up the following TP framework:
Master File template.
TAXe | Countries that Granted State Aid Should not Be Recovered
; posted on
January 20th, 2016
On January 19, the European Parliament agreed that money that a member state should recover from a company due to infringements of tax-related state aid rules should be returned either to the EU budget or to member states that have suffered an erosion of their tax bases.
The Report .
USA - New regulations on Country-by-Country Reporting by MNEs
; posted on
December 23rd, 2015
On 21 December, The US Treasury Department released a proposal on regulations that would require annual country-by-country reporting by US companies that are the ultimate parent entity of a multinational enterprise (MNE) group.
International Context .
TPA German BRICS+ Desk
; posted on
December 22nd, 2015
What the BRICS countries do for German Multinationals has a significant economic relevance – at least 1,800 German corporates already have a presence in India, and in Russia one may find 6,000 active corporates with a German origin. Next to these countries, some important markets for the German business community exist, such as Mexico, Turkey, Singapore or Indonesia.
ATAF to Reduce Double Taxation across Africa
; posted on
December 15th, 2015
The African Tax Administration Forum (ATAF) has come up with a draft document on avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income in Africa.
Model Agreement .
Curaçao Malta DTA Available
; posted on
November 24th, 2015
The English version of DTA with respect to Taxes on Income between the Republic of Malta and the Kingdom of the Netherlands in respect of Curaçao has been published on the website of the Malta Financial Services Authority (MFSA).
Convention .
Multinationals Endorse Patent Box in US
; posted on
November 19th, 2015
A collection of some of America’s leading companies working under American Innovation Matters (AIM) released a statement pushing for the introduction of a US patent box, or an "innovation box" as it is known in the United States.
American Innovation Matters .
European Commission Aims to Deal with Corporate Tax Regimes that Favor Debt Over Equity
; posted on
October 1st, 2015
The European Commission will propose a draft law aimed at eliminating tax regimes that favor raising corporate debt over equity, as it tries to reduce the amount of company loans on banks' books and to cut companies' leverage, the Commission announced on 30 September in its Capital Markets Union Action Plan.
Tackling the Debt-Equity Tax Bias .
China is Expected to Progress Its Global Corporate Tax Rules
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August 4th, 2015
On 30 September 2015, China Daily has reported that China will be at the forefront of embracing the emerging international tax rules to combat base erosion and profit shifting, known as BEPS, as it shifts toward becoming a "capital-export" country.
Modernization .
China is introducing BEPS legislation
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April 15th, 2015
On March 18, 2015, the State Administration of Taxation in China (SAT) released the ‘Public Notice Regarding Certain Corporate Income Tax Matters on Outbound Payments to Related Parties Abroad’ (SAT Public Notice [2015] No.16, hereinafter referred to as “Notice 16”).
Criticism on OECD’s Modified Nexus Approach
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March 17th, 2015
In a joint statement, two business organizations from the Netherlands and Germany have stated their concerns about the development of the proposals under the OECD’s work on Action 5 of its BEPS project. This Action focusses on tackling harmful tax practices and patent box regimes regarding the IP income.
Italy Improves New Patent Box Regime
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March 14th, 2015
The Italian Government has passed improvements to its new patent box preferential tax regime, even though it was only introduced this month, after approval of the 2015 Budget Law in December.
As a means of encouraging the development of intellectual property (IP) in Italy, the patent box regime was introduced along similar lines to the incentives granted in other European Union countries, covering income deriving from the use or licensing of qualifying intangible assets.
Dissecting BEPS Action Plan 6 Preventing The Granting Of Treaty Benefits In Inappropriate Circumstances
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December 10th, 2014
Action Plan 6 of the BEPS Action Plan identified treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns.
The most important aspects of the report are :.
Release of discussion draft on the transfer pricing aspects of cross-border commodity transactions
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December 7th, 2014
Public comments are invited on this discussion draft which deals with work in relation to Action 10 (“Assure that transfer pricing outcomes are in line with value creation” in relation to “other high risk transactions”) of the Action Plan on Base Erosion and Profit Shifting (BEPS).
The OECD Action Plan on Base Erosion and Profit Shifting, published in July 2013, identifies 15 actions to address BEPS in a comprehensive manner and sets deadlines to implement these actions.
UK Patent Box – a pre-Action Plan recipe?
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April 28th, 2014
The UK’s Patent Box system is becoming rather controversial. The scheme is scheduled to provide a predicted amount of £367M (€446M) in tax breaks and was introduced in April 2013.
India to audit transfer pricing based on risk assessments
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April 28th, 2014
A proposal has been set forward for the transfer pricing audit threshold in India to be removed in favour of a risk management, finger-picking approach. Currently, firms engaging in transactions above INR 15 crore (€1.
UK expecting no changes to Patent Box regime
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December 12th, 2013
HMRC, the British tax authority, has no current intention of making changes to the UK’s Patent Box system. The Patent Box has been under investigation by the European Commission, but the UK is confident that the arrangement is consistent with international guidelines and therefore will not require further tweaking.
Panama taxpayers must now document transactions with all foreign related parties
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September 1st, 2012
Recent amendments to Chapter IX of the Fiscal Code “Standard of Adaptation of Treaties to Avoid the Double International Taxation” will now reach any operation that a taxpayer in Panama has with its foreign related parties. Prior to the introduction of these amendments, transfer pricing documentation requirements in Panama only applied to cases where a tax resident in Panama had operations with a related party located in a country with which Panama has a double tax treaty in place.
Australia – ATO risk assessments
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February 1st, 2012
The Australian Taxation Office (“ATO”) has announced that it is currently writing to large businesses about the ATO’s assessment of their level of tax risk and that it is looking to meet with the senior executives of those taxpayers to explain their assessment. These tax risk assessments address issues relating to income tax, goods and services tax and excise.
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