The 2023 ECOSOC Special Meeting on International Cooperation in Tax Matters will take place on March 31.Continue Reading
UN to discuss international tax issues in March
Other-News
Worldwide transfer pricing news, BEPS news & international tax news
OECD Centre for Tax Policy and Administration gets new director
Manal Corwin shall be the next Director of the OECD Centre for Tax Policy and Administration from April 3, 2023.Continue Reading
Janet Yellen welcomes EU agreement on global minimum tax
US Treasury Secretary, Janet Yellen, has welcomed EU agreement on implementation of a global minimum tax on corporations.Continue Reading
OECD notes progress on tackling harmful tax practices
Almost 50,000 exchanges of tax information have taken place to date in respect of 23,000 tax rulings, as per a new OECD report.
The 2021 Peer Review Reports on the Exchange of Information on Tax Rulings includes the latest peer review assessments for 131 jurisdictions in relation to the compulsory spontaneous exchange of information on tax rulings.
Released on December 14, this is the sixth annual peer review of the implementation of the BEPS Action 5 minimum standard on tax rulings, which aims to provide tax administrations with the necessary information concerning their taxpayers to efficiently tackle tax avoidance and other BEPS risks.
The new peer review results show that 73 jurisdictions are fully in line with the BEPS Action 5 minimum standard, with the remaining 58 jurisdictions receiving a total of 61 recommendations to improve their legal or operational framework to identify the relevant tax rulings and exchange information.
Platform for Collaboration on Tax releases progress report
The Platform for Collaboration on Tax (PCT) has released its Progress Report 2022, which provides an update on the world’s four leading multilateral organizations’ collaboration in the area of revenue mobilization since October 2021.
The PCT is a joint initiative of the International Monetary Fund (IMF), the Organization for Economic Cooperation and Development (OECD), the United Nations (UN), and the World Bank Group (WBG).
The four PCT Partners continued their support to countries seeking to strengthen their tax systems through the development of joint products, dissemination of their toolkits, and exchanges on critical issues.
The PCT remained active throughout the pandemic as the world transitioned into hybrid working modes. The platform will continue to serve as a mechanism for exchange and collaboration among the four Partners in their efforts to support tax system reform, particularly for developing countries, beyond 2024.
This Progress Report is part of PCT’s commitment to operating transparently and to making its workplan and outputs widely available, through its publicly accessible website, to governments, capacity development providers and their donors, civil society organizations, and the general public.
The report gives a snapshot of PCT activities under five workstreams with new priorities identified in light of global challenges: tax and SDGs with a primary focus on tax and environment, international taxation, medium-term revenue strategy (MTRS), resilience to and preparedness for shocks, and stakeholder engagement, information dissemination, and internal exchanges.
OECD consulting on Pillar One transfer pricing rules
The OECD is consulting stakeholders on the main design elements of Amount B under Pillar One as part of its ongoing work on digital economy taxation.Continue Reading
Netherlands publishes comments on draft Minimum Tax Rate Act
The Dutch government has published 15 responses to its public consultation on the draft Minimum Tax Rate Act, 2024.Continue Reading
Ireland boasts strong corporate tax receipts
Ireland’s Department of Finance has revealed that corporation tax receipts amounted to EUR 21.1 billion in the year to end-November.Continue Reading
OECD schedules webinar to discuss digital economy taxation
Registration is open for an OECD webinar on Amount B under the Two-Pillar Solution to tackle digital economy taxation.Continue Reading
UK shares public input on mandatory tax disclosure rules
The UK government has received 20 written responses from tax and law firms on the proposed mandatory disclosure rules (MDR). Continue Reading
Shell paid USD 5.7 billion in corporate income tax in 2021
Oil major Shell paid USD 12.6 billion in corporate income tax and government royalties after recording a profit before tax of USD 30 billion in the year 2021.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
Spain, Ireland fastest in closing MAP cases under tax treaties
Spain has been awarded for taking the shortest time in closing transfer pricing cases under the mutual agreement procedure (MAP) set out in tax treaties.
The 2021 MAP Statistics were presented during the OECD Tax Certainty Day, where tax officials and stakeholders took stock of the tax certainty agenda and discussed ways to further improve dispute prevention and resolution. The MAP Award is given in recognition of efforts by competent authorities in dealing with MAP cases.Continue Reading
UK updates tax provision to reflect latest OECD transfer pricing guidance
The update comes into effect for accounting periods beginning on or after January 1, 2023, for corporation tax purposes.Continue Reading
EU finance ministers agree to broaden corporate tax measures
The revision of the code, the first one since 1997, means that member states will broaden the scope of the tax measures under scrutiny when examining harmful tax practices within the EU.Continue Reading
Australia gets over AUD 68 billion in corporate income tax
This year’s report represents 2,468 corporate entities, who paid a combined AUD 68.6 billion in income tax, AUD 11.4 billion or 19.8 percent more than the previous year and the highest since reporting began.Continue Reading
Biden administration rebuked over Hungary tax treaty termination
The letter calls upon the Biden administration to withdraw its termination of the tax treaty and promptly consult with Congress on a bipartisan basis to address any concerns with the tax treaty or any other of the United States’ current bilateral tax treaties.Continue Reading
Namibia signs BEPS tax convention
The Convention will enter into force on January 1, 2022, for these countries.Continue Reading
Ireland confirms new DAC6 reporting format
DAC6 Schema Version 1.1 is applicable for all exchanges until July 31, 2021.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
French tax authority suspends DAC6 filing
The suspension will continue the beginning of September 2021.Continue Reading
Moroccan tax authority publishes MAP guidance
The guidance clarifies the terms and conditions that taxpayers must fulfil to avail MAP, including access to MAP, submitting MAP requests, and the various deadlines, among others.Continue Reading
EU Commission asks Bulgaria, Sweden to address tax issues
Under this tax scheme, interest deductibility is denied in relation to loan arrangements between affiliated companies established within the EU, irrespective of whether the terms and conditions of those arrangements remain at arm’s length or not.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
Cyprus extends DAC6 penalty relief
On March 18, 2021, the Government approved Law to require taxpayers/ intermediaries to report information on certain tax arrangements.
The Cyprus Tax Department will not impose administrative fines for overdue submission of DAC6 information that will be submitted until the September 30, 2021.
The penalty relief applies to:
- Reportable cross-border arrangements that have been made between 25 June 2018 and 30 June 2020 and had to be submitted by 28 February 2021.
- Reportable cross-border arrangements that had been made between 1 July 2020 and 31 December 2020 and had to be submitted by 31 January 2021.
- Reportable cross-border arrangements made between 1 January 2021 and 31 August 2021, that had to be submitted within 30 days from the date they were made available for implementation or were ready for implementation or the first step in the implementation has been made, whichever occurred first.
- Reportable cross-border arrangements for which secondary intermediaries provided aid, assistance or advice, between 1 January 2021 and 31 August 2021 and had to submit information within 30 days beginning on the day after they provided aid, assistance or advice.
On March 18, 2021, the Government approved Law to require taxpayers/ intermediaries to report information on certain tax arrangements.
EU Commission launches research lab to tackle aggressive tax planning
The Observatory will be fully independent in conducting its research, objectively informing policymakers and suggesting initiatives that could help to better tackle tax avoidance and aggressive tax planning, among other things.Continue Reading
Australian tax authority announces launch of R&D portal
The portal includes improved security using myGovID digital identity services, linked to your company’s ABN using Relationship Authorisation Manager (RAM).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
Australian tax office issues draft guidance on intangibles arrangements
Public comments on the draft guidance must be received by June 18, 2021.Continue Reading
Hungary dismisses 15% global minimum corporate tax rate
Tállai emphasized that Hungary would not relinquish one of the most important elements of its economic sovereignty, the right to set taxes. According to him, the idea of a global minimum tax is in the interests of several high-taxing economic powers, because they were disadvantaged by international tax competition.Continue Reading
European Commission reveals tax agenda for next two years
On the agenda are measures to ensure greater public transparency by proposing that certain large companies operating in the EU publish their effective tax rates.Continue Reading
OECD releases MAP peer review reports for eight tax jurisdictions
These reports evaluate the progress made by these eight tax jurisdictions in implementing any recommendations resulting from their stage 1 peer review. The results from the peer review and peer monitoring process demonstrate positive changes across all eight jurisdictions, although not all show the same level of progress.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
OECD releases new MAP peer review reports
The reports evaluate the progress made by these eight jurisdictions in implementing any recommendations resulting from their stage 1 peer review. They take into account any developments in the period January 2018- August 2019 and build on the MAP statistics for 2016-2018.Continue Reading
OECD releases MAP arbitration profiles of 30 tax jurisdictions
The Arbitration Profiles have been developed to provide taxpayers with additional information on the application of Part VI of the MLI for each jurisdiction choosing to apply that Part. The Arbitration Profiles also allow those jurisdictions to make publicly available clarifications on their position on the MLI Arbitration.
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Janet Yellen takes oath as first female US Treasury Secretary
Vice President Kamala Harris administered the oath of office to Janet Yellen on January 26, 2021.Continue Reading
OECD updates guidance on COVID-19 pandemic and tax treaties
The update revisits the guidance issued by the OECD Secretariat on the impact of the COVID-19 pandemic on tax treaties in April last year.Continue Reading
Ireland updates corporate tax roadmap
According to the update, Ireland will seek to implement interest limitation rules in accordance with the Anti-Tax Avoidance Directive (ATAD) standard; legislate for new international tax transparency rules for digital platforms; legislate for reverse hybrids aspect of ATAD anti-hybrid rules; adopt the authorized OECD approach for transfer pricing of branches; and consider actions that may be needed in respect of outbound payments from Ireland and our wider withholding tax regime.Continue Reading
Platform for Collaboration on Tax releases toolkit on transfer pricing documentation
The toolkit aims to help countries implement effective transfer pricing documentation requirements so that they can protect their tax bases, reduce profit shifting, and raise much-needed revenues for the recovery phase.Continue Reading
Estonia ratifies BEPS MLI to tackle MNE tax avoidance
For Estonia, the BEPS MLI will enter into force on May 1, 2021. Continue Reading
Malta makes available online DAC6 registration process
Access to submit DAC6 reports shall be available in the coming days, the tax authority said.Continue Reading
OECD Inclusive Framework on BEPS to meet on January 27-28
The meeting will be held virtually and will be open to the public.
Portuguese EU Presidency to focus on digital economy taxation
In particular, the Presidency will address the challenges of European taxation, including the model for taxation of the digital economy, under the principles of fairness and tax efficiency.Continue Reading
OECD releases agenda for public consultation on Pillar One, Pillar Two Reports
The Blueprints reflect the convergent views of the Inclusive Framework on many of the key policy features, principles and parameters of both Pillars, and identify remaining technical and administrative issues as well as policy issues where divergent views among Inclusive Framework members remain to be bridged.Continue Reading
Singapore sets indicative margin for related party loans for 2021
If taxpayers choose to apply the indicative margin, they will apply the indicative margin on the appropriate base reference rate selected for the related-party loan.Continue Reading
OECD schedules public consultation on the Pillar One, Two Blueprints
The meeting will be held on January 14-15, 2021.Continue Reading
Barbados ratifies BEPS MLI to tackle MNE tax avoidance
Barbados has ratified the BEPS MLI covering 31 of its tax treaties.Continue Reading
UK to repeal DAC6 in 2021
The UK tax authority, HM Revenue and Customs, has announced that it will repeal the DAC6 reporting requirement in 2021 and replace it with the OECD’s mandatory disclosure rules (MDR).
The announcement was made after completion of the negotiations between the UK and the EU on a Free Trade Agreement (FTA).
In a letter sent to stakeholders on December 31, HMRC said that reporting under DAC6 will still be required for a limited time, but only for arrangements which meet hallmarks under Category D, in line with the UK’s obligations under the FTA.
Category D sets out specific hallmarks concerning automatic exchange of information and beneficial ownership.
The International Tax Enforcement (Disclosable Arrangements) (Amendment) (No. 2) (EU Exit) Regulations, 2020 – laid before the House of Commons on December 30 – state that “(5) For the purposes of these Regulations, the DAC is to be read as if— (h) in Annex IV, Part 1 [the Main Benefit Test] and hallmark categories A, B, C and E in Part II were omitted.”
In the coming year, the UK will consult on and implement the OECD’s MDR as soon as practicable, to replace DAC6 and transition from European to international rules, HMRC told stakeholders.
Italy publishes draft guidance on DAC6
Comments on the draft Circular on DAC6 must be submitted to the Italian tax authority by January 15, 2021.Continue Reading
Greece publishes 2019 list of preferential tax regimes
Greece has dropped Oman and Seychelles from the list of preferential tax regimes for 2019.Continue Reading
Germany, Pakistan ratify BEPS MLI to tackle tax avoidance
Germany and Pakistan have deposited their instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).Continue Reading
200+ organizations respond to OECD reports on Pillar One and Pillar Two blueprints
The public consultation meeting will be held virtually on January 14-15, 2021.Continue Reading
OECD reveals country practices on hard-to-value intangibles
The information provides with a better understanding of the extent to which the HTVI approach described in Chapter VI of the Transfer Pricing Guidelines has been adopted and is applied in practice by countries around the world. Continue Reading
Singapore to participate in International Compliance Assurance Programme from 2021
The MNE’s suitability for ICAP will be considered on a case-by-case basis. The MNE may propose for participating tax administrations it wishes to involve in its ICAP risk assessment, which will be subject to the participating tax administrations’ agreement.Continue Reading
Canada objects to Denmark’s BEPS MLI reservation on arbitration
Canada states that Denmark’s reservation “exceeds the scope of cases for which a reservation may be made under that provision.”Continue Reading
US Treasury releases 2020-2021 Priority Guidance Plan
The Plan – released on November 17 – includes guidance projects that will be the focus of efforts during the 12-month period from July 1, 2020, through June 30, 2021.Continue Reading
Malta releases DAC6 XML Schema and User Guide
DAC6 has been implemented into Maltese legislation by virtue of legal notice L.N. 342 of 2019.Continue Reading
UN tax committee to hold 21st session from October 20
The exact meeting times during this band of dates and the modalities of the meetings will be advised shortly.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
Jordan ratifies BEPS Multilateral Instrument
For Jordan, the BEPS MLI will enter into force on January 1, 2021.Continue Reading
Albania, Costa Rica ratify BEPS MLI
The BEPS MLI will enter into force for both countries on January 1, 2021.Continue Reading
US tax authority prioritizing projects for 2020-21
Comments must be received by July 22.Continue Reading
Finland issues tax treaty guidance
The guidance states that the OECD’s Multilateral Instrument on BEPS adopted in Finland on February 13, 2019, must be taken into account when applying tax treaties.Continue Reading
EU member states agree on ‘optional’ postponement of DAC6 reporting deadlines
The DAC6 reporting requirement was originally intended to take effect from July 1, 2020, postponement has been agreed in view of COVID-19 pandemic.Continue Reading
Australia broadens definition of ‘significant global entity’
The amendments generally apply from July 1, 2019.
Poland suspends DAC6 reporting until June 30
The suspension of DAC 6 reporting obligation applies both to domestic and cross-border tax arrangements.Continue Reading
OECD issues MAP peer review reports for further eight jurisdictions
The reports highlight how well these jurisdictions are implementing BEPS Action 14 minimum standard on making tax treaty dispute resolution more timely, effective, and efficient.Continue Reading
BVI to accept country by country report filings from March 2020
International Tax Authority informs BVI Constituent Entities, that are part of Multinational Entity Group, that it will soon be ready to receive filings for CbC reporting.Continue Reading
OECD to hold live webcast on digital economy taxation
The webcast will be held on January 31, 2020, at 14:00-15:00 (CET).Continue Reading
Cyprus, Saudi Arabia ratify BEPS MLI to tackle MNE tax avoidance
The BEPS MLI will enter into force for these two countries on May 1, 2020.Continue Reading
Liechtenstein ratifies BEPS MLI to tackle MNE tax avoidance
The BEPS MLI will enter into force for Liechtenstein on April 1, 2020.Continue Reading
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
EU Commission warns Austria, Ireland to transpose interest limitation rules
The Commission may bring the cases before the Court of Justice of the EU if Austria and Ireland do not act by February 1, 2020.Continue Reading
India approves tax treaty with Chile
The tax treaty and Protocol implement the BEPS minimum standards to tackle tax planning strategies that exploit gaps and mismatches in tax rules.Continue Reading
Estonia, Guernsey sign tax treaty
The tax treaty will enter into force after both countries have completed their respective internal procedures.Continue Reading
OECD seeking input on MAP peer reviews of 13 jurisdictions
Comments must be received by December 16, 2019.Continue Reading
Switzerland amending tax treaties with New Zealand, Netherlands, Norway, and Sweden
The protocols contain an anti-abuse clause.Continue Reading
OECD issues new guidance on country-by-country reporting
The additional interpretative guidance will help MNE Groups in avoiding common errors made in preparing CbC reports.Continue Reading
Denmark ratifies BEPS MLI to tackle MNE tax avoidance
For Denmark the BEPS MLI will enter into force on January 1, 2020.Continue Reading
Hong Kong, Estonia sign tax treaty
The tax treaty will enter into effect after both countries complete their respective ratification procedures.
Australian tax board consulting on corporate tax residency rules
Comments must be received by October 4, 2019.Continue Reading
Japan, Peru to conclude a tax treaty
Japan and Peru have “in principle” agreed to conclude a tax treaty.Continue Reading
US, Luxembourg ratify tax treaty protocol
The Protocol will be effective for requests for information made on or after the date of entry into force for tax years on or after January 1, 2009.Continue Reading
US releases details about tax treaty protocols with Japan, Spain
Mandatory binding arbitration clause is included in the tax treaty protocols to resolve tax treaty disputes.Continue Reading
Hong Kong issues guidance on transfer pricing documentation requirements
Hong Kong issues guidance to ensure compliance with the country’s transfer pricing documentation requirements.Continue Reading
Canada, Switzerland ratify instrument to tackle tax avoidance
The BEPS MLI will enter into force in both countries on December 1, 2019.Continue Reading
Georgia ratifies tax instrument to tackle BEPS
For Georgia the BEPS MLI will enter into force on July 1, 2019. Continue Reading
Armenia joins OECD’s BEPS Inclusive Framework
Armenia has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting.Continue Reading
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
New Swiss-Ukraine tax treaty protocol signed
The treaty protocol provides for a low withholding tax rate of five percent for royalty and interest payments. An arbitration clause is also included to increase legal certainty for taxpayers.Continue Reading
Hong Kong, Finland tax treaty to take effect in April 2019
The treaty will be effective from April 1, 2019.Continue Reading
Cook Islands now part of BEPS Inclusive Framework
Cook Islands has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting.Continue Reading
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
Malta ratifies tax instrument to tackle base erosion and profit shifting
The BEPS MLI will enter into force for Malta on April 1, 2019.
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
Denmark publishes draft tax proposal to ratify BEPS MLI
The legislation is intended to enter into force in July 2019. Continue Reading
Qatar signs BEPS Multilateral Instrument to tackle tax avoidance
Qatar is the 85th jurisdiction to sign the BEPS Convention, which now covers nearly 1,500 bilateral tax treaties.Continue Reading
New tax treaty between Switzerland, Pakistan effective from January 2019
An arbitration clause is included in the new tax treaty to resolve double taxation disputes.Continue Reading
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
Australian tax authority extends deadline to file CbC reports
The Australian tax authority has allowed “significant global entities” time until January 15, 2019, to lodge their country-by-country (CbC) reports.
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Australia reviewing MNE tax arrangements concerning intangible assets
The Australian Taxation Office is reviewing international arrangements that mischaracterize intangible assets to understate Australian profits.
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Norway to Ratify BEPS Multilateral Instrument
The Norwegian Government has submitted to the Parliament a proposal to ratify the OECD’s Multilateral Instrument to implement tax treaty-related measures to tackle base erosion and profit shifting (BEPS).Continue Reading
Global Solution Needed to Tax Digital Economy: DIGITALEUROPE
DIGITALEUROPE, which represents the digital technology industry in Europe, has called upon governments to negotiate a comprehensive, global, long-term tax solution at the OECD-level to address the tax challenges of the digital economy.
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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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Google, Facebook to Appear Before EU Tax Committee
European Parliament’s Special Committee on Tax Avoidance (TAX3) is going to hold a hearing on November 27 with representatives from the Kering Group, Google, and Facebook.
The aim of the hearing is to assess the progress made by these multinational enterprises in the implementation of the base erosion and profit shifting project.Continue Reading
Ireland Consulting on Corporate Anti-Tax Avoidance Measures
On November 14, 2018, Ireland’s Department of Finance published for public comments a consultation document on the hybrid mismatch and interest limitation measures to be introduced as part of the implementation of the EU Anti-Tax Avoidance Directives (ATAD and ATAD2).
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OECD Seeks Input on MAP Peer Reviews of Further Eight Jurisdictions
The OECD is seeking taxpayers’ input for the seventh round of base erosion and profit shifting (BEPS) Action 14 Stage 1 peer reviews of further eight jurisdictions.
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OECD Issues Guidance on the Impact of BEPS MLI
The OECD has published new guidance for the development of synthesised texts to facilitate the interpretation and application of tax agreements modified by the Multilateral Convention to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shifting (BEPS MLI).Continue Reading
Countries Discuss Implementation of BEPS Minimum Standards
More than 60 delegates from 16 countries met recently at the regional meeting of the Inclusive Framework on base erosion and profit shifting (BEPS) in Eastern Europe and Central Asia to discuss implementation of the BEPS measures.Continue Reading
Jersey Explains Tax Rules on Substance Requirement
The Jersey Government has issued details of new legislation that would introduce economic substance requirements for companies resident in Jersey for tax purposes.Continue Reading
UK Launches Consultation on Digital Services Tax
The UK Government is seeking stakeholders’ views on the detailed design, implementation, and administration of the proposed two percent digital services tax (DST).Continue Reading
Grenada Newest Tax Jurisdiction to Join BEPS Inclusive Framework
Grenada has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).Continue Reading
Tax Officials Discuss BEPS Implementation Challenges
Senior tax experts met at an event in Portugal on October 23 to discuss the strategic importance of the OECD’s work on base erosion and profit shifting (BEPS) and the challenges faced by tax administrations in implementing the BEPS proposals.Continue Reading
Further Three Jurisdictions Join BEPS Inclusive Framework
Antigua and Barbuda, Dominica, and Saint Vincent and the Grenadines have newly joined the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).
The Inclusive Framework on BEPS allows interested countries and jurisdictions to work with the OECD and Group of Twenty nations on monitoring the implementation of the BEPS proposals.Continue Reading
Switzerland Expands Country List for Exchange of CbC Reports
The Swiss Federal Council on October 17 decided to expand the list of countries with which Switzerland would exchange country-by-country (CbC) reports.
The legal basis for the exchange of CbC reports entered into force for Switzerland on December 1, 2017. Switzerland had then submitted to the OECD a list of 108 countries with which the Government will exchange CbC reports.Continue Reading
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
Australia Updates Mutual Agreement Procedure Guidance
The Australian Taxation Office has updated its guidance on the mutual agreement procedure (MAP) framework contained in tax treaties to resolve disputes.Continue Reading
BEPS Inclusive Framework Gets 119th Member in Dominican Republic
Dominican Republic has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).Continue Reading
Countries Share Ideas on Country by Country Reporting Implementation
Senior tax officials from over 20 countries recently met at a workshop to share experiences from the first year of country-by-country (CbC) reporting and explore how information can be used most effectively in the tax risk assessment of MNE groups.Continue Reading
Aruba Newest to Join BEPS Inclusive Framework
Aruba has now joined the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).
The Inclusive Framework on BEPS allows interested countries and jurisdictions to work with the OECD and Group of Twenty nations on monitoring the implementation of the BEPS proposals.Continue Reading
More Countries Ratify BEPS Convention
Australia, France, Japan, and the Slovak Republic have deposited their instruments of ratification of the OECD’s Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS).
For these four countries, the BEPS Convention would enter into force from January 1, 2019. The Convention entered into force last month for New Zealand, Serbia, Sweden, and the UK.Continue Reading
Saudi Arabia Signs OECD’s BEPS Multilateral Instrument
Saudi Arabia has become the 84th tax jurisdiction to sign the base erosion and profit shifting (BEPS) Multilateral Convention.
The BEPS Convention, negotiated by over 100 countries and jurisdictions, updates the existing network of 1,400 bilateral tax treaties and reduces opportunities for tax avoidance by multinational enterprises.Continue Reading
ICC Welcomes OECD Draft on Transfer Pricing Aspects of Financial Transactions
The International Chamber of Commerce (ICC) has largely welcomed the OECD’s public discussion draft on the transfer pricing aspects of financial transactions.
The discussion draft deals with follow-up work in relation to base erosion and profit shifting (BEPS) Actions 8-10, on assuring that transfer pricing outcomes are in line with value creation.Continue Reading
Liechtenstein, Bermuda to Exchange CbC Reports
The OECD has published a set of newly established bilateral for the exchange of country-by-country (CbC) reports with respect to Bermuda, Curaçao, Hong Kong (China), and Liechtenstein.Continue Reading
Further Country by Country Reporting Guidance Issued
The OECD has issued further interpretative guidance on the implementation of country-by-country (CbC) reporting to provide certainty to tax administrations and multinational enterprises (MNEs).Continue Reading
BEPS Instrument to Enter into Force in January 2019 for Israel, Lithuania
Israel and Lithuania have newly deposited with the OECD their instrument of ratification for the Multilateral Instrument to implement tax treaty-related base erosion and profit shifting (BEPS) measures.Continue Reading
Transfer Pricing Aspects of Financial Transactions: Read TEI’s Comments
The Tax Executives Institute has responded to the OECD’s public discussion draft on the transfer pricing aspects of financial transactions.
The discussion draft deals with follow-up work in relation to base erosion and profit shifting (BEPS) Actions 8-10, on assuring that transfer pricing outcomes are in line with value creation.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
Countries Lowering Corporate Income Tax Rates
A new OECD report reveals that countries have used recent tax reforms to lower corporate income tax.
Tax Policy Reforms 2018 highlights the continuation of a trend toward corporate income tax rate cuts, which has been largely driven by significant reforms in a number of large countries with traditionally high corporate tax rates.Continue Reading
Indian Tax Authority Extends ‘Significant Economic Presence’ Consultation Deadline
India’s tax authority has extended the earlier deadline of August 10 to submit comments on the newly introduced “significant economic presence” test to tax profits of foreign businesses.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
Macedonia Now Part of BEPS Inclusive Framework
The Former Yugoslav Republic of Macedonia has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).Continue Reading
Singapore’s Tax Authority Updates Country by Country Reporting Guidance
Taxpayers can report rounded figures in their country-by-country (CbC) reports, Singapore’s tax authority has clarified.Continue Reading
India’s CBDT Signs More APAs
India’s Central Board of Direct Taxes (CBDT) entered into nine new unilateral advance pricing agreements (APAs) in July 2018, the tax authority has announced.Continue Reading
Guernsey to Introduce Substance Requirements in Tax Law
Guernsey’s Government is consulting businesses on a law that would require companies tax-resident in Guernsey to demonstrate they have sufficient substance in the island.Continue Reading
Australian Taxation Office Issues Draft Guidance on Related Party Financing Arrangements
The Australian Taxation Office (ATO) has published for public comments Schedule 2 to Practical Compliance Guideline (PCG) 2017/4DC, which discusses the tax authority’s compliance approach to tax issues relating to cross-border, related-party financing arrangements and related transactions.Continue Reading
New Zealand Government Ratifies BEPS Convention
New Zealand’s Inland Revenue today announced that the Government has ratified the OECD’s Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS).Continue Reading
Taiwan Begins International Tax Training for 2018
Taiwan’s Finance Ministry is holding the 2018 International Tax Academy from July 30 to August 17 this year.
The event was launched in 1984 and is conducted every year in cooperation with the School of Law of Southern Methodist University.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
Canada Completes 36 Advance Pricing Agreements in 2017
Canada’s tax authority has completed 36 advance pricing agreements (APAs) in the 2017 calendar year, according to latest statistics published on the country’s APA program.Continue Reading
Transfer Pricing Examination Process Set Out by US IRS
The US Internal Revenue Service (IRS) has issued key guidance on best practices and processes to assist with the planning, execution, and resolution of transfer pricing examinations.Continue Reading
Taxpayer Input Sought on Fresh Round of MAP Peer Reviews
The OECD is seeking taxpayers’ input for the sixth round of base erosion and profit shifting (BEPS) Action 14 Stage 1 peer reviews of eight new jurisdictions.Continue Reading
Ukraine Signs OECD’s BEPS Convention
Ukraine has become the 83rd tax jurisdiction to sign the base erosion and profit shifting (BEPS) Multilateral Convention.Continue Reading
Countries Discuss Ways to Implement BEPS Measures
Senior tax officials from 20 countries in Europe and Central Asia recently met in Georgia to discuss ways to tackle tax avoidance and to implement the base erosion and profit shifting (BEPS) proposals.Continue Reading
Report on Taxation of Offshore Indirect Transfer of Assets Issued
The Platform for Collaboration on Tax – a joint initiative of the IMF, the OECD, the UN, and the World Bank Group – has published for public comments a revised version of its report on taxation of offshore indirect transfers of assets.Continue Reading
UK Finalizes BEPS Convention Reservations
The UK Government has published a final list of its reservations and notifications under the Multilateral Convention to implement tax treaty-related base erosion and profit shifting (BEPS) measures.Continue Reading
Canada Successfully Initiates CbC Tax Info Exchange
Canada has successfully initiated its first round of exchanges of country-by-country (CbC) tax reports of multinational enterprises (MNEs), Diane Lebouthillier, Minister of National Revenue, has announced.Continue Reading
New ATO Guidance on ‘Direct Connection Test’ Under MAAL
The Australian Taxation Office (ATO) on July 4 issued Tax Determination (TD) TD 2018/12, which provides guidance on the application of “direct connection test” under the Multinational Anti-Avoidance Law (MAAL).Continue Reading
Indian Tax Authority Signs Three New Unilateral APAs
India’s Central Board of Direct Taxes (CBDT) entered into three new unilateral advance pricing agreements (APAs) in the months of May and June 2018, the tax authority revealed.Continue Reading
OECD Consulting on Transfer Pricing Aspects of Financial Transactions
The OECD today called for stakeholders’ input on a discussion draft on financial transactions, which deals with follow-up work in relation to base erosion and profit shifting (BEPS) Actions 8-10, on assuring that transfer pricing outcomes are in line with value creation.
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ATO Issues Draft Tax Guidance on Hybrid Mismatch Rules
On June 21, 2018, the Australian Taxation Office (ATO) published for stakeholders’ comments draft Practical Compliance Guideline (PCG 2018/D4) to assist taxpayers who may be affected by the country’s hybrid mismatch rules and wish to unwind or restructure out of existing hybrid arrangements.Continue Reading
Indian Tax Authority Consulting On BEPS Action 5 Changes
The Indian tax authority has published for public comments a draft Notification, which will implement the OECD’s proposals under Action 5 of the base erosion and profit shifting (BEPS) project.Continue Reading
OECD Issues Further Guidance on PE Profit Attribution
The OECD has released additional guidance on the attribution of profits to permanent establishment (PE), as part of its work on base erosion and profit shifting (BEPS) Action 7.Continue Reading
OECD Publishes Third Round of MAP Peer Reviews
On March 12, 2018, the OECD published mutual agreement procedure (MAP) peer review reports of the following eight jurisdictions: Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, and Spain. Continue Reading
Hong Kong CbC Reporting Portal Launched
On March 5, 2018, the Hong Kong Government launched an online portal to enable Hong Kong entities to file their country-by-country (CbC) reports. The Portal can be accessed through: https://aeoi.ird.gov.
Anguilla Joins BEPS Inclusive Framework
Anguilla has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).Continue Reading
UK Updates Definition of ‘Transfer Pricing Guidelines’
The UK Government has published an Order, which would update the definition of “transfer pricing guidelines” in the UK legislation.Continue Reading
Guidance on Australian Thin Cap Regime Expected Soon
The Australian Taxation Office (ATO) will release this year detailed advice and guidance on the country’s thin capitalization regime contained in Division 820 of the Income Tax Assessment Act, 1997.Continue Reading
Indian Tax Authority Enters Into More APAs
India’s Central Board of Direct Taxes (CBDT) entered into a further seven unilateral advance pricing agreements (APAs) in February 2018, taking the total number of APAs signed to 203.Continue Reading
Accountants Concerned About New Zealand’s BEPS Tax Bill
Chartered Accountants Australia and New Zealand (CA-ANZ) has stressed that by implementing the Taxation (Neutralising Base Erosion and Profit Shifting) Bill in its current form, the New Zealand Government would be “going further than most other OECD countries.”Continue Reading
Serbia Joins BEPS Inclusive Framework
Serbia has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).Continue Reading
New Zealand to Modify Transfer Pricing Rule in BEPS Bill
By Alex Cooper
The New Zealand Inland Revenue is seeking to rectify a drafting error in a new rule to limit the rate of deductible interest on related-party, cross-border debt (the restricted transfer pricing rule) in the Taxation (Neutralising Base Erosion and Profit Shifting) Bill.Continue Reading
Indian Tax Authority Enters Into Two Further Bilateral APAs
On February 7, 2018, the Indian tax authority announced that it entered into two bilateral advance pricing agreements (APAs) in the month of January 2018.Continue Reading
Bermuda Updates CbC Reportable Tax Jurisdictions List
On January 31, 2018, Bermuda’s Finance Ministry released an updated list of tax jurisdictions that will be treated as “reportable jurisdictions” for the purposes of the country-by-country (CbC) reporting standard for the 2016 and 2017 reporting periods.Continue Reading
Greece, Bulgaria Discuss Ways to Address BEPS Concerns
Senior officials from Greece and Bulgaria met on January 18, 2018, to discuss ways to tackle base erosion and profit shifting by certain Greek businesses, who transfer their headquarters to Bulgaria to benefit from a low corporate tax rate in Bulgaria.Continue Reading
Hong Kong, French Tax Administrations to Exchange CbC Reports
On January 15, 2018, the Government of Hong Kong announced that it has entered into a bilateral arrangement with France to automatically exchange country-by-country (CbC) reports filed by multinational corporations.Continue Reading
Malta’s Tax Regime BEPS Compliant: Finance Minister
Maltese Finance Minister, Edward Scicluna, has stressed that the country’s international tax regime is in line with the OECD’s BEPS proposals.Continue Reading
Indian IT Giant Infosys Signs APA with US
Indian IT giant Infosys Limited has announced the successful conclusion of an advance pricing agreement (APA) with the US Internal Revenue Service (IRS), a move that will enhance predictability of the company’s tax obligations in respect of its US operations.Continue Reading
Mongolia Joins BEPS Inclusive Framework
Mongolia has joined the OECD’s Inclusive Framework on BEPS, bringing the total number of countries participating in the project on an equal footing to 111.
Members of the framework work together with other OECD and G-20 countries on implementing the BEPS package consistently and on developing further standards to address BEPS issues.