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Press Releases    Tax Techonlogy

How SAT Changes Your Tax Bill With Blockchain & AI Technology
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July 20th, 2018
You must have heard about the famous ' Blockchain ' concept and may have benefited from the altcoin transactions. You must have also learned about the poor performance by tax authorities to data management and identify tax fraud, in particular, fraud pertaining to value added tax.
“Taxation Of Offshore Indirect Transfers Of Assets" Report Consults The Public For Amendments
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July 20th, 2018
The Platform for Collaboration on Tax reached out to the public for final comments on a revised version of its report on the “Taxation of Offshore Indirect Transfers (OITs) of Assets”.
Taxation of OITs .
Tax Administrations Raise The Playing Field With Technological Solutions
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July 18th, 2018
Are tax administrations paving the digitalization path?
Tax administrations worldwide are increasingly relying on digital technologies for data gathering, exchange of information and analytics. Digital systems that are already in place can even provide real-time tax collections, re-conciliations and assessments.
UK Issues Final List Of Reservations And Notifications Under The Multilateral Convention
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July 17th, 2018
The UK published its final list of reservations and notifications of the Multilateral Convention to implement tax treaty related measures and prevent base erosion and profit shifting ( BEPS ).
The Final List .
EU Adopts Best Practices Code To Strengthen State Aid Control
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July 17th, 2018
The European Commission has adopted a new Code of Best Practices for the conduct of State aid control procedures. This Code replaces the Notice on a Code of Best Practices adopted in 2009 and integrates the Simplified Procedure Notice of 2009.
2018 TP Country Summaries Update (8)
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July 16th, 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.
Today we updated the following online TP Country Summaries:.
How To Build A Global ERP Integration To Make Effective Global Tax Decisions?
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July 13th, 2018
If you are the CFO of a multinational group, are you able to make current tax decisions based on financial data from various ERP systems effectively? How do you deal with a law suit against the tax authorities of the jurisdiction in which one of your subsidiaries is located, based on their 5-year old tax returns that are supported by the financial data that you have no transparency to? These are common issues happening all around the world on a frequent basis.
Imagine, a multinational enterprise operating in the chemical industry using different Enterprise Resource Planning (ERP) systems for each of their services and administration.
TPA Global Launches a Redesigned and Enhanced Website
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July 13th, 2018
TPA Global, the leading independent provider of global transfer pricing and valuation services, is proud to announce that is has launched a redesigned and enhanced website at www.tpa-global.com.
With this fresh appearance and format, the new website contains all information about TPA Global’s activities in a demanding and competetive market and at the same time is also more visually appealing.
UK Updates Requirement To Correct Guidance On Offshore Assets
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July 12th, 2018
The UK updated the Requirement to Correct (RTC) guidance to provide information about the new RTC legislation which relates to liabilities to Income Tax, Capital Gains Tax and Inheritance Tax.
Offshore Non-compliance Tackled by RTC Legislation .
German Ministry of Finance (MOF) Repeals Administrative Guidelines on Cost Contribution Agreements
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July 12th, 2018
German ministry of finance (MOF) administrative guidelines on cost contribution arrangements as of 31.12.2018 canceled
By letter dated 5 July 2018, the German Federal Ministry of Finance (MOF) repealed the BMF administrative guidelines "Principles for the examination of deferred income through cost contribution arrangements between internationally affiliated companies" with effect from December 31, 1999.
EU Commission - Dutch Guarantee Scheme Does Not Constitute Illegal State Aid
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July 10th, 2018
The European Commission has decided that the "Growth Facility", a Dutch scheme to improve access to finance for small and medium-sized enterprises (SMEs), does not constitute illegal State Aid within the meaning of EU rules.
The Scheme Considered as Self-financing .
IRS Replaces TP Roadmap With Transfer Pricing Examination Process
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July 10th, 2018
The Internal Revenue Service (IRS) in the US released the Transfer Pricing Examination Process (TPEP) to be uses in transfer pricing examinations. The TPEP, issued by the Treaty and Transfer Pricing Operations (TTPO) of the Large Business and International (LB&I) division, is a guide of best practices and processes to assist with the planning, execution and resolution of transfer pricing examinations consistent with the LB&I Examination Process.
2018 TP Country Summaries Update (7)
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July 6th, 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.
Today we updated the following online TP Country Summaries:.
UK: HMRC Updates DTAs With Isle of Man, Guernsey and Jersey
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July 5th, 2018
In July 2017, Her Majesty's Revenue and Customs (HMRC) in the UK has announced the update of tax treaties with three jurisdictions. HMRC signed new comprehensive double taxation agreements and Protocols with Isle of Man, Guernsey, and Jersey respectively, but none of the new treaties has entered into force yet.
India Signs Three More Unilateral APAs
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July 5th, 2018
On June 4, 2018, the Central Board of Direct Taxes (CBDT) has entered into three Unilateral Advance Pricing Agreements (UAPA) during the past couple of months. With the signing of these Agreements, the total number of APAs entered into by the CBDT has gone up to 223, which inter alia include 20 Bilateral APAs.
2018 TP Country Summaries Update (6)
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July 5th, 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.
Today we updated the following online TP Country Summaries:.
US Supreme Court Decision on E-Commerce
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July 5th, 2018
The US Supreme Court decision on e-commerce concerns the possibility for states to apply sales taxes on e-commerce sales.
In 1992 this same court denied that possibility in the case - Quill Corporation vs.
Singapore Published Guide On IP Rights Valuation Report
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July 3rd, 2018
The Inland Revenue Authority of Singapore (IRAS) published an e-Tax Guide on the Intellectual Property Rights (IPRs) Valuation Report. This Guide is aimed at coaching taxpayers when the taxpayers should submit an independent valuation report on qualifying IPRs for the purposes of Section 19B of the Income Tax Act (ITA).
J5 - Unite To Tackle International Tax Crime
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July 3rd, 2018
The leaders of tax enforcement bodies of Canada, the Netherlands, the United States, the United Kingdom and Australia has allied to launch the Joint Chiefs of Global Tax Enforcement (J5). It’s a new alliance dedicated to tackling international tax crime and money laundering.
New Zealand Finalizes MNE Tax Avoidance Rules
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June 28th, 2018
The Inland Revenue in New Zealand announced the third reading of the Taxation (Neutralising Base Erosion and Profit Shifting) Bill had been passed in Parliament, which contains measures to prevent multinational companies from avoiding tax by shifting profits out of New Zealand.
Enforcement of the Bill being Next Week .
China Broadens Super-Deduction To R&D Expenses Accrued Overseas
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June 28th, 2018
The Ministry of Finance, the State Administration of Taxation, and the Ministry of Science and Technology in China jointly issued a Circular (Cai Shui [2018] No.64), announcing a broader scope of expenses entitled to the super-deduction incentive for corporate income tax purpose.
EU To Assess 3rd Countries’ Risk By The End Of 2018 For The 5th Anti-Money Laundering Directive
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June 28th, 2018
Commissioner Jourová gave a speech in front of the Special Committee on Financial Crimes, Tax Evasion and Tax Avoidance, at the European Parliament. Jourová emphasised the implementation of third countries’ risk assessment with respect to the 5 th Anti-Money Laundering Directive.
How Much Automation of Tax Flows Is Possible?
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June 28th, 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.
2018 TP Country Summaries Update (5)
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June 27th, 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.
Brazil (NEW) .
Australia Publishes Guidance For Large Public And Multinational Businesses On Assessing Tax Governance
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June 26th, 2018
The Australian Taxation Office (ATO) issues practical guidance to assist large public and multinational businesses in understanding how tax authority rates tax governance when applying justified trust methodology.
Definition of Tax Governance .
Australia Consults The Public On Restructures of Hybrid Mismatch Arrangements
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June 26th, 2018
Australia government released its draft Practical Compliance Guideline (PCG) 2018/D4 Part IVA of the Income Tax Assessment Act 1936 and Restructures of Hybrid Mismatch Arrangements. The Australian Taxation Office (ATO) has invited all interested parties to comment on this draft law by 20 July 2018.
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.
Switzerland - First CbCR Exchange Of Large MNEs
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June 21st, 2018
After the exchange of advanced tax rulings with partner jurisdictions , the Swiss Federal Tax Administration (FTA) is about to send its first multinational groups’ Country-by-Country reports (CbCR) to 35 partner states within the CbCR framework at the end of June, 2018.
Content of Exchange .
Singapore Consults Proposed Changes To Income Tax Act
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June 21st, 2018
The Ministry of Finance of Singapore asked the public for opinions on the draft Income Tax (Amendment) Bill 2018 from June 20 to July 11, 2018.
Key Changes in the Proposed Amendments .
Australia Finalises Rules On Reporting Foreign Exchange Gains And Losses In Local File
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June 21st, 2018
The Australian Taxation Office finalised the rules for reporting foreign exchange gains and losses in Local File – Part A in the second year of reporting, after considering the feedback from consultation in 2017.
Local File Transaction Categories involved .
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.
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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?"
; posted on
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
; posted on
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
; posted on
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
; posted on
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)
; posted on
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
; posted on
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)
; posted on
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
; posted on
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?
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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)
; posted on
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
; posted on
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
; posted on
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
; posted on
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?
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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%
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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)
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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
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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
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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
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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)
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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)
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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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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”
; posted on
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)
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
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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
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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
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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
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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
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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
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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)
; posted on
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
; posted on
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.
India - Goods & Service Tax (GST) Updates (2)
; posted on
July 20th, 2017
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. Some of the central and state indirect taxes currently being subsumed in GST are Central Excise Duty; Service tax; Central State Tax; Value Added tax; Entry Tax; Purchase Tax; Luxury tax etc.
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?
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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.
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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.

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