The OECD, on February 2, released technical guidance to assist governments with implementation of the 15 percent global minimum corporate tax rate.Continue Reading
OECD publishes guidance on global minimum corporate tax rules
Africa
Transfer pricing news, BEPS news, and international tax news in Africa
Netherlands opposes UN international tax framework
The Dutch State Secretary of Finance, Marnix van Rij, has expressed the government’s concerns regarding the recent UN resolution to establish an international tax cooperation framework.Continue Reading
MAP statistics revealed for 127 tax jurisdictions
On November 22, 2022, the OECD released the latest mutual agreement procedure (MAP) statistics covering 127 tax jurisdictions.Continue Reading
UN to bolster international tax cooperation
A United Nations committee has approved draft resolution on “Promotion of inclusive and effective international tax cooperation at the United Nations.”Continue Reading
EU Council updates tax blacklist
The EU tax blacklist now consists of 12 jurisdictions: American Samoa, Anguilla, Bahamas, Fiji, Guam, Palau, Panama, Samoa, Trinidad and Tobago, Turks and Caicos Islands, US Virgin Islands, and Vanuatu.Continue Reading
Namibia signs BEPS tax convention
The Convention will enter into force on January 1, 2022, for these countries.Continue Reading
African Tax Administration Forum responds to ‘historic’ international tax reform
The two-pillar package aims to ensure that large multinational enterprises (MNEs) pay tax where they operate and earn profits, while adding much-needed certainty and stability to the international tax system.Continue Reading
Tax administrations discuss transfer pricing issues
The WCO facilitator focused on the Customs valuation treatment of related-party transactions and instruments adopted by the Technical Committee on Customs Valuation. The OECD facilitator elaborated on the arm’s length principle and its application, comparability analysis, and transfer pricing documentation. Continue Reading
Kenyan Finance Bill 2021 includes key international tax measures
By CPA David Ndiritu Mwangi (Principal Consultant, Hisibati Consulting, Nairobi, Kenya)
The Kenyan government tabled the Finance Bill 2021 in Parliament on 11/05/2021. Unlike the prior year, the bill does not introduce new taxes. However the bill proposes significant changes that will indeed have a far reaching effect on multinational organizations operating in Kenya.Continue Reading
African Tax Administration Form submits revised Pillar One proposals
The revised proposals respond to both the Inclusive Framework blueprint report released for public consultation in October 2020 and the recent proposals from the US to revise the blueprint proposals.Continue Reading
South Africa issues tax guidance on royalty, interest withholding tax
Interpretation Note 115 relates to withholding tax on interest and Interpretation Note 116 relates to withholding tax on royalties.Continue Reading
ATAF releases draft law on digital services tax
The Suggested Approach is aimed at helping African countries that are considering implementing digital service tax to tax transactions of highly digitalized businesses.Continue Reading
Significant economic presence: Nigerian perspective
By Kelechi Ugbeva (Managing Partner, Blackwood & Stone, Nigeria)
Existing global tax rules such as, the arm’s length principle and principle of physical presence may not be robust enough to accommodate the peculiarity of digital activities and digital taxation. To this end, the OECD has come up with a few proposals on how digital activities may be taxed. Continue Reading
South Africa consulting on rule to limit interest expense deduction
The Budget proposes to restrict net interest expense deductions to 30% of earnings for assessment years starting January 1, 2021.
OECD issues further guidance on country-by-country reporting
The additional interpretative guidance contains complete set of guidance concerning the interpretation and operation of BEPS Action 13 issued so far.Continue Reading
OECD seeking input on MAP peer reviews of 13 jurisdictions
Comments must be received by December 16, 2019.Continue Reading
OECD’s Work on Harmful Tax Practices on Track
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
The OECD has published a report covering the assessment of 53 preferential tax regimes as part of its work under base erosion and profit shifting (BEPS) Action 5, on harmful tax practices.
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BEPS Inclusive Framework Gets New Member in Cabo Verde
Cabo Verde is the newest member to the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).
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Mutual Agreement Procedure Statistics Published for 2017
The OECD on October 10 published its 2017 mutual agreement procedure (MAP) statistics covering 85 tax jurisdictions.
According to the 2017 MAP statistics, new transfer pricing MAP cases are up by 25 percent and other MAP cases by 50 percent. Anecdotal evidence suggests that the increase in new MAP cases is due to a range of factors including the effects of the new reporting framework and increased awareness of and expectations from taxpayers about MAP, the OECD noted.Continue Reading
Transfer Pricing Regulations Revised in Nigeria: Some Highlights
By Amaka Samuel Onyeani (Senior Manager, Transfer Pricing, Andersen Tax, Nigeria) & Abisola Agboola (Assistant Manager, Transfer Pricing, Andersen Tax, Nigeria)
Nigeria’s Federal Inland Revenue Service (FIRS) recently released the revised Income Tax (Transfer Pricing) Regulations, 2018 (the Transfer Pricing Regulations). The Transfer Pricing Regulations are one of the efforts of the FIRS in improving the administration of transfer pricing in the country, increasing revenue collection via taxes, and protecting Nigeria’s tax base.Continue Reading
OECD Transfer Pricing Profiles for 7 More Countries Published
The OECD has published new transfer pricing country profiles for Costa Rica, Greece, Republic of Korea, Panama, Seychelles, South Africa, and Turkey. The OECD has also updated the information contained in Singapore’s profile.Continue Reading
Quantera Global, Africa Transfer Pricing Now Allies
Transfer pricing advisory firm Quantera Global has announced its strategic partnership with Africa Transfer Pricing, a professional services firm specializing in transfer pricing in South Africa.Continue Reading
SARS to Revive Large Business Unit
The South African Revenue Service (SARS) is re-establishing the Large Business Unit to ensure that the unit is responsive to the challenges currently being faced by SARS.Continue Reading
Switzerland Adopts Dispatch on BEPS Convention
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
The Swiss Federal Council on Wednesday adopted the dispatch on the OECD’s Multilateral Convention to implement tax treaty-related base erosion and profit shifting (BEPS) measures.Continue Reading
Tax Treaty between Singapore, Nigeria: Read Key Provisions
The tax treaty between Singapore and Nigeria will enter into force on November 1, 2018, and will take effect on January 1, 2019.Continue Reading
Mutual Agreement Procedure Guide Issued by SARS
South Africa’s tax authority on July 25 published general guidance on the mutual agreement procedure (MAP) framework incorporated in tax treaties to resolve disputes.Continue Reading
Nigeria CbC Reporting Tax Regulations Explained
By Josh Bamfo (Partner & Head, Transfer Pricing Services, Andersen Tax, Nigeria)
The Federal Government of Nigeria finally published the much anticipated Income Tax (Country-by-Country Reporting) Regulations, 2018 (the CbC Regulations) on June 19, 2018 (with a commencement date of January 1, 2018). This is in line with Nigeria’s signing of the OECD’s Multilateral Competent Authority Agreement on January 27, 2016, providing for automatic exchange of CbC reports.
As a sequel to my earlier publication on the potential implications of the draft CbC reporting Regulations to affected taxpayers, which was published four months ago, this article presents the key highlights of the CbC reporting Regulations and re-assesses the potential implications based on the content of the final, published version.Continue Reading
South Africa’s 2018 Budget: Unpacking International Tax Measures
By Ahmed Jooma (Independent Tax, Legal, and Public Policy Consultant)
On February 21, 2018, South Africa’s Finance Minister, Malusi Gigaba, presented the country’s National Budget, which will be tougher on the populace than on multinational corporations. Most of the tax changes that will affect cross-border transactions are of a technical nature. A continued focus on base erosion and profit shifting is expected to assist in arresting the deteriorating fiscal environment. This is further exacerbated by pressure to maintain a relatively low corporate tax rate in the face of tax competition.
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Ireland, Ghana Sign New Tax Treaty
Ireland and Ghana signed a new tax treaty on February 7, 2018. The procedures to ratify the treaty are underway.
Ireland is also negotiating and renegotiating existing treaties with foreign jurisdictions.
According to the tax authority, Ireland’s existing treaty base will also be updated to incorporate provisions set out in the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting.
CbC Reporting Regulations in Nigeria: Potential Implications For Taxpayers
By Josh Bamfo (Partner & Head, Transfer Pricing Services, Andersen Tax, Nigeria)
Since the signing of the Multilateral Competent Authority Agreement by the Federal Inland Revenue Service (FIRS) and its subsequent ratification by the Federal Executive Council in 2016, most Nigerian taxpayers and tax practitioners have been keenly waiting for the implementation of a country-by-country (CbC) reporting requirement, developed under Action 13 of the base erosion and profit shifting (BEPS) project. Nonetheless, we were still surprised by the FIRS’ communication via its official Twitter handle on 24 January, 2018, that the Income Tax (Country-by-Country Reporting) Regulations, 2018, (CbC Regulations) has now been signed by the Federal Government of Nigeria, and will be gazetted soon.Continue Reading
Panama, Malaysia, Four Others Sign OECD’s BEPS Convention
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
Barbados, Côte d’Ivoire, Jamaica, Malaysia, Panama, and Tunisia have newly signed the base erosion and profit shifting (BEPS) Multilateral Convention, the OECD announced on January 24, 2018.Continue Reading
New South Africa Tax Guidance on Prohibition of Deductions for “Tainted” IP
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
The South African Revenue Service has issued detailed guidance on the interpretation and application of section 23I of the Income Tax (IT) Act, which relates to the prohibition of deductions for “tainted” intellectual property (IP).Continue Reading