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
Austria proposes to impose a five percent digital tax to close tax loopholes and ensure that large digital corporations are called to account.Continue Reading
For Georgia the BEPS MLI will enter into force on July 1, 2019. Continue Reading
Armenia has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting.Continue Reading
Transfer pricing advisory Questro International has hired Chris Whitehouse as a transfer pricing partner for its Zurich office.
For Ireland, the BEPS MLI will enter into force in May 2019.Continue Reading
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
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
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.
The Commission is looking into five tax rulings issued by the Dutch tax authority to Nike group companies in the Netherlands between 2006 to 2015.Continue Reading
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 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.
The treaty will be effective from April 1, 2019.Continue Reading
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
Cook Islands has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting.Continue Reading
The new anti-abuse measures entered into force on January 1, 2019.Continue Reading
Jeffrey Tate has joined US law firm Arent Fox’s tax practice as a Partner.
The BEPS MLI will enter into force for Singapore on April 1, 2019.Continue Reading
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
In the 2015-16 income year, the estimated tax gap for large corporate taxpayers was 4.4 percent, as compared to 5.8 percent tax gap in the 2014-15 income year.Continue Reading
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
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.
Important process of ratifying the BEPS MLI is on. In 2019-2020, the provisions will come into effect, says Akhilesh Ranjan.
The legislation is intended to enter into force in July 2019. Continue Reading
According to IMF Chief Christine Lagarde, governments should figure out a world-wide answer on tax.Continue Reading
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
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
France and Germany urged the EU Council to adopt the proposed digital services tax by March 2019.Continue Reading
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
Qatar is the 85th jurisdiction to sign the BEPS Convention, which now covers nearly 1,500 bilateral tax treaties.Continue Reading
An arbitration clause is included in the new tax treaty to resolve double taxation disputes.Continue Reading
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.
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