Tax

Transfer pricing news, BEPS news, and international tax news

Delving into Hong Kong’s New Transfer Pricing Landscape

Posted on by in BEPS, India, Latest, Multinational Tax, OECD, Tax, Tax Avoidance, Transfer Pricing and tagged .
Delving into Hong Kong’s New Transfer Pricing Landscape

By Maulik Doshi (Partner, Head of Transfer Pricing & International Tax, SKP Group) and Kamlesh Kaltari (Principal, Transfer Pricing Services, SKP Group)

On July 4, 2018, Hong Kong’s Inland Revenue Department passed the country’s final Inland Revenue (Amendment) (No. 6) Bill 2017, (the Amendment Bill). 

This Amendment Bill (which became law on July 13, 2018) specified the documentary requirements from a transfer pricing perspective and also introduced measures to address various recommendations under BEPS Action Plans.Continue Reading

Hong Kong tax authority notes CbC reporting deadline details

Posted on by in Asia Pacific, BEPS, Hong Kong, Latest, Multinational Tax, OECD, Tax, Tax Avoidance and tagged .

Hong Kong tax authority notes CbC reporting deadline details

Hong Kong Inland Revenue Department has clarified that starting from April 2019, the Department will not accept voluntary filing of a country-by-country (CbC) report for an accounting period ended on or before March 31, 2018.Continue Reading

Manuel Koch joins transfer pricing specialist Questro’s Stuttgart office

Posted on by in Americas, Europe, Germany, Latest, Multinational Tax, Switzerland, Tax, Transfer Pricing, US and tagged .

Transfer pricing specialist Questro International has hired Manuel Koch as a Partner for the firm’s office in Stuttgart, Germany.

Koch brings significant experience of over ten years specialization in transfer pricing consulting. Koch has wide experience in international tax planning engagements for international corporates including holding and principal structures as well as Swiss finance branches and IP boxes.Continue Reading

Jill Weise to lead Duff & Phelps’ transfer pricing practice

Posted on by in Americas, Latest, Multinational Tax, Tax, Transfer Pricing, US and tagged .

Global advisory firm Duff & Phelps has announced that Jill Weise will succeed Michael Heimert as the Global Leader for the firm’s transfer pricing practice.

Weise has nearly 25 years of expertise in transfer pricing. She previously served as the firm’s transfer pricing practice leader for North America.
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Indian tax authority sets new CbC reporting deadline for US subsidiaries

Posted on by in Americas, Asia Pacific, BEPS, India, Latest, Multinational Tax, OECD, Tax, Tax Avoidance, Transfer Pricing, US and tagged .
Indian tax authority sets new CbC reporting deadline for US subsidiaries

By Maulik Doshi (Partner, Head of Transfer Pricing & International Tax, SKP Group) and Kamlesh Kaltari (Senior Manager, SKP Group)

In India, the 2016 Finance Act introduced a three-tiered transfer pricing documentation regime with a view to aligning the Indian transfer pricing documentation rules with Action 13 of the OECD’s base erosion and profit shifting (BEPS) project.

Accordingly, Indian subsidiaries of multinational groups were required to comply with new “master” and “local” files requirements and a new country-by-country reporting requirement from the 2016-17 financial year.Continue Reading

Transfer pricing expert Mark Madrian joins Valentiam Group

Posted on by in Americas, Latest, Multinational Tax, Tax, Transfer Pricing, US and tagged .

Transfer pricing expert Mark Madrian has joined Valentiam Group as a Partner in the firm’s West Coast practice.

Madrian has advised clients on complex cross-border transfer pricing and other international tax issues. He was recently recognized as a Leading Transfer Pricing Adviser by Legal Media.
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Saudi tax authority publishes draft transfer pricing bylaws

Posted on by in BEPS, Latest, Multinational Tax, OECD, Tax, Tax Avoidance, Transfer Pricing and tagged .
Saudi tax authority publishes draft transfer pricing bylaws

By Anas Salhieh  (Senior Tax Executive, Al Tamimi & Company, Riyadh, Saudi Arabia)

Saudi Arabia’s General Authority for Zakat and Income Tax has published for public comments draft transfer pricing bylaws as part of the Kingdom of Saudi Arabia’s commitment to the OECD’s base erosion and profit shifting (BEPS) project.Continue Reading

New EU corporate tax avoidance rules enter into force

Posted on by in Austria, BEPS, Denmark, Europe, Finland, France, Germany, Ireland, Italy, Latest, Luxembourg, Multinational Tax, Netherlands, Norway, OECD, Spain, Sweden, Switzerland, Tax, Tax Avoidance, UK and tagged .
New EU corporate tax avoidance rules enter into force

The new anti-abuse measures entered into force on January 1, 2019.Continue Reading

BEPS MLI to enter into force in Australia in January 2019

Posted on by in Asia Pacific, Australia, BEPS, Latest, Multinational Tax, OECD, Tax, Tax Avoidance, Transfer Pricing and tagged .
BEPS MLI to enter into force in Australia in January 2019
From January 1, 2019, the BEPS MLI will operate to modify six of Australia’s 44 bilateral tax treaties. These include tax treaties with France, Japan, New Zealand, Poland, the Slovak Republic, and the UK.Continue Reading

Gibraltar provided illegal tax benefits to MNEs: EU Commission

Posted on by in BEPS, Europe, Latest, Multinational Tax, Tax, Tax Avoidance, Transfer Pricing and tagged .
EU Commission says Gibraltar provided illegal tax benefits to MNEs

Gibraltar must recover unpaid taxes of around EUR100m from companies that benefited from the corporate tax exemption regime for interest and royalties as well as from the five tax rulings.Continue Reading

OECD issues second peer review report on BEPS Action 5

Posted on by in BEPS, Europe, Latest, Multinational Tax, OECD, Tax, Tax Avoidance and tagged .
OECD issues second peer review report on BEPS Action 5

The OECD has made 60 jurisdiction-specific recommendations on issues such as improving the timeliness of the exchange of information and ensuring that exchanges of information are made with respect to preferential tax regimes that apply to income from intellectual property.Continue Reading

Bulgaria introduces new interest limitation and CFC regimes

Posted on by in BEPS, Europe, Latest, Multinational Tax, Tax, Tax Avoidance, Transfer Pricing and tagged .
Bulgaria introduces new interest limitation and CFC regimes

By Elizabeth Sidi (Senior Tax Consultant, PwC, Bulgaria) 

Bulgaria is introducing new interest limitation rules and a new controlled foreign corporation regime from January 1, 2019. 

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Indian tax authority undergoing ratification process for BEPS MLI

Posted on by in Asia Pacific, Australia, Austria, BEPS, Europe, France, India, Japan, Jersey, Latest, Multinational Tax, New Zealand, OECD, Sweden, Tax, Tax Avoidance, UK and tagged .
Indian tax authority undergoing ratification process for BEPS MLI

Important process of ratifying the BEPS MLI is on. In 2019-2020, the provisions will come into effect, says Akhilesh Ranjan.

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Cayman Islands publishes tax bill to implement substance requirements

Posted on by in Americas, BEPS, Latest, Multinational Tax, OECD, Tax, Tax Avoidance and tagged .
Cayman Islands publishes tax bill to implement substance requirements

The legislation seeks to incorporate the OECD’s proposals under Action 5 of the base erosion and profit shifting (BEPS) project, on countering harmful tax practices, as well as the new EU substance requirements.Continue Reading

New Agreement between Ireland and Malta to counteract the ‘Single Malt’ tax structure

Posted on by in BEPS, Ireland, Latest, Multinational Tax, Tax, Tax Avoidance and tagged .
New Agreement between Ireland and Malta to counteract the ‘Single Malt’ Structure

By Catherine O’ Meara (Partner, Matheson, Dublin) and Brian Doohan (Senior Associate, Matheson, Dublin)

On November 27, 2018, Ireland’s Finance Minister Paschal Donohoe announced the details of a Competent Authority Agreement between Ireland and Malta (Agreement). The clear aim of the Agreement is to end what is referred to as the “Single Malt” tax structure.Continue Reading

Belgium publishes draft transfer pricing guidance for public comments

Posted on by in BEPS, Europe, Latest, Multinational Tax, OECD, Tax, Tax Avoidance, Transfer Pricing and tagged .
Belgium publishes draft transfer pricing guidance for public comments

By Bram Markey (Director, Transfer Pricing, PwC Belgium)

The Belgian tax authority has issued a draft Circular on the 2017 update to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.Continue Reading

Mauritius tax authority issues guidance on place of effective management

Posted on by in Asia Pacific, BEPS, Latest, Mauritius, OECD, Tax, Tax Avoidance, Transfer Pricing and tagged .
Mauritius tax authority issues guidance on place of effective management

The majority of the Board of Directors’ meetings must be held in Mauritius, or the executive management of the company must be regularly exercised in Mauritius.

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India, Hong Kong tax treaty to take effect from April 2019

Posted on by in Asia Pacific, BEPS, Hong Kong, India, Latest, Tax, Transfer Pricing and tagged , .
India, Hong Kong tax treaty to take effect from April 2019

The tax treaty provides for a low withholding tax rate of five percent for dividend payments. Interest, royalties, and fees are subject to a low withholding tax rate of ten percent.Continue Reading