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April 26th, 2016
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The latest news

IRS Will Update Rules On Triangular Reorganizations
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December 6th, 2016
On December 2, the US IRS announced that it will issue regulations under Code Sec. 367 to modify the rules relating to the treatment of property used to acquire parent stock or securities in certain triangular reorganizations involving one or more foreign corporations.
OECD Discusses New Guidance on CbC Implementation
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December 6th, 2016
During a OECD BEPS webcast on December 5, senior members from the OECD's Centre for Tax Policy and Administration (CTPA) discussed BEPS related issues and further OECD's tax agenda. The CTPA addressed guidance on implementation of Country-by-Country (CbC) reporting, which was released on the same day.
Spain Announces Changes in Corporate Taxation
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December 6th, 2016
The Spanish Government announced a new Budget keeping the nominal rate (25%) but implementing additional measures to limit the tax deductibility of certain items of expenditure in order to increase country's revenue.
Tax Measures
TPA Global Forms Alliance With Global Tax Support LLC, USA
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December 5th, 2016
TPA Global, leading independent provider of global transfer pricing and valuation services, is pleased to announce that it has entered into an alliance with Global Tax Support LLC, an independent tax advisory firm in the U.S.
TPA Global Forms Alliance With Stehlin & Associés, France
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December 3rd, 2016
TPA Global, leading independent provider of global transfer pricing and valuation services, is pleased to announce that it has entered into an alliance with Stehlin & Associés, an independent business law firm with headquarters in Paris (France) and ranked among the top 30 law firms in France.
Combining their technical expertise and industry experience, Stehlin & Associés' tax attorneys work together in a pragmatic way to implement their client’s projected operations and solve problems encountered by clients in their transfer pricing tax issues, such as transfer pricing tax planning, transfer pricing documentation (in particular selection of the appropriate method and profit level indicator), assistance to transfer pricing tax audits, litigation in front of the tax Courts.
TPA Global Forms Alliance With TPS, Spain
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December 1st, 2016
TPA Global, leading independent provider of global transfer pricing and valuation services, is pleased to announce that it has entered into an alliance with Transfer Pricing Specialists (TPS), a leading independent Transfer Pricing firm in Spain.
Founded by professionals with many relevant years of experience doing business in the field, TPS is currently the main independent player in the country.
Singapore's MAS Concerned About Global Politics
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December 1st, 2016
The Monetary Authority of Singapore (MAS) released Financial Stability Review 2016, in which it warned against anti-globalization saying that political constraints together with rise of anti-globalization sentiment could impede effective policy-making. The Review further assessed potential risks within global financial market, property industry in Singapore and other related subjects.
ATO Welcomes Comments on Diverted Profits Tax
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December 1st, 2016
On November 29, the Australian government released draft legislation for implementation of the Diverted Profits Tax, designed to identify large multinationals seeking to avoid tax by shifting profits and will impose a penalty tax rate of 40 percent.
Background: DPT
Value Chain Analysis (VCA) 'Survival Kit'
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December 1st, 2016
The year 2016 has been a bumpy ride for many corporations having to tackle multiple conflicting unilateral regulations as the implementation of BEPS gains further stronghold across the globe.
Therefore, keeping in mind the imminent need for clarity on preventive actions to be taken by corporations, TPA Global organised a conference in Amsterdam last week on 'Value Chain Analysis - The BEPS Generation of Functional Analysis'.
Canada Rolling Out A Crackdown On Tax Havens
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November 30th, 2016
The new strategy of Canada Revenue Agency to crack down on tax havens by reviewing every single electronic funds transfer (EFT) of more than $10,000 has delivered 750 audits and 20 criminal investigations.
Background
Hungarian Parliament Approved 9% Corporate Tax Rate
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November 30th, 2016
Hungarian Parliament has approved the government’s tax package that cuts the corporate tax rate. Following the announcement of Prime Minister Viktor Orbán two weeks ago, the Parliament voted on the measure with 131 MPs in favour, 38 against and 25 abstentions.
Protocol to Singapore-Russia DTA Enters Into Force
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November 28th, 2016
On November 25, the Protocol amending the existing Singapore-Russian Federation Avoidance of Double Taxation Agreement (DTA) entered into force.
Protocol to DTA
Slicing the Pie - A Quantitative Value Chain Analysis
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November 23rd, 2016
Authors: Steef Huibregtse is CEO and Senior Partner and Maria Grigoryeva is Junior Associate at TPA Global.
Following BEPS publication on profit split on October 5, 2015 and July 4, 2016, MNEs are being challenged to apply the holistic view on their value chain.
OECD Reports Significant Progress on Tax Inspectors Without Borders
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November 23rd, 2016
On November 11, the OECD informed that a significant progress has been made within the Tax Inspectors Without Borders (TIWB) Project that provides assistance to countries on revenue recovery and improving local audit capacity. It currently runs thirteen projects in different countries and several new programs will be launched in the coming year.
European Parliament Approves Automatic Exchange of Bank Data
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November 23rd, 2016
On November 22, Members of the European Parliament voted in favor of the automatic exchange of bank data to track account owners by 590 votes to 32, with 64 abstentions.
Background
The Netherlands Informs about first CbC Notification Deadline
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November 22nd, 2016
The Dutch State Secretary for Finance informed that it approved the deadline for taxpayers to file the first notification, which has to be done no later than September 1, 2017.
Background
New Zealand Calls for Excluded Entities and Accounts within AEOI
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November 22nd, 2016
The New Zealand Inland Revenue published a fact sheet summarizing the criteria for financial institutions to categorize entities and accounts as “low risk”, which would allow them to be excluded from due diligence and reporting obligations under the Automatic Exchange of Financial Information (AEOI).
“Low Risk” Excluded Entities
Cyprus and India Sign New DTA
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November 22nd, 2016
On November 18, the Republic of Cyprus and the Republic of India have concluded a new DTA, which will replace the previous DTA signed on June 13, 1994. The DTA is expected to come into effect in India, in respect of income derived in fiscal years beginning on or after April 1, 2017.
US And India Conclude Terms On Advance Pricing Agreement
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November 18th, 2016
The finance ministry of India informed that India and the US reached a deal on the terms and conditions of the first bilateral advance pricing agreement (APA) that will contribute to a more tax friendly environment for US multinationals. The two countries also resolved 108 pending transfer pricing disputes.
Singapore Agrees to Exchange Information with Canada
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November 18th, 2016
On November 16, Singapore and Canada concluded an Agreement on the Automatic Exchange of Financial Account Information to Improve International Tax Compliance. The two countries will commence the Automatic Exchange of Information under the CRS by September 2018.
Switzerland Plans to Make Fines and Bribes Non-Deductible
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November 17th, 2016
On November 16, the Swiss Federal Council informed that Switzerland plans to disallow companies to deduct financial sanctions with a penal character and bribes for tax purposes. The companies will however still be able to write off illegally gained profits seized by regulators.
UK and Switzerland Terminate Withholding Tax Agreement
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November 17th, 2016
On November 14, the Swiss Federal Department of Finance informed that the withholding tax agreement between Switzerland and the United Kingdom will be terminated on January, 1 2017. On the same day, the agreement between Switzerland and the EU on the automatic exchange of information in tax matters will enter into force.
Saudi Arabia Signs FATCA IGA
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November 17th, 2016
On November 15, Saudi Arabia has signed a Model 1 intergovernmental agreement (IGA) with the United States to Improve International Tax Compliance and to Implement FATCA.
Background
Luxembourg to See More Economic Activity
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November 11th, 2016
Luxembourg is expected to have an economic impulse as a new unregulated fund product, the Reserved Alternative Investment Fund (RAIF), company law reforms and recent moves of Chinese banks to the country will significantly stimulate the activity in the country.
Brexit Shifts Some Economic Activity
EU Commission Examines Possible Disincentives for Tax Avoidance Advisors
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November 11th, 2016
The European Commission has launched a public consultation to gather views on whether there is a need for EU action aimed at introducing more effective disincentives for intermediaries or tax payers engaged in operations that facilitate tax evasion and tax avoidance and how such action should be design.
Background: Intermediaries Assisting Tax Avoidance
UK Signs DTAs With Lesotho And Colombia
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November 9th, 2016
On November 4, HM Revenue & Customs announced that the UK has signed the double taxation agreements with Lesotho and with Colombia. The agreements will enter into force when both countries have completed their legislative procedures and exchanged diplomatic notes.
Post-Brexit PE Investment in EU Hit Harder than in UK
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November 9th, 2016
According to a research the private equity (PE) industry in the UK will be hit less harder than in the EU following the Brexit.
UK Private Equity Fundraising
Global Forum Furthers in International Tax Transparency Work
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November 5th, 2016
On November 2-4, The Global Forum on Transparency and Exchange of Information for Tax Purposes held its annual meeting in Tbilisi, Georgia. The meeting marked the completion of the first round of the Forum’s peer review process.
Saudi Arabia and Uruguay Sign MCAA
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November 4th, 2016
Saudi Arabia and Uruguay signed the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (MCAA) during the 9th Meeting of the Global Forum in Georgia on November 2.
Background: MCAA
Cyprus, a Post-Brexit Partner to UK Funds Industry
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November 4th, 2016
On November 2, fund managers met in London as the Cyprus Investment Funds Association (CIFA) presented possibilities to use Cyprus’ financial services infrastructure. CIFA positioned itself as potential strategic partner to the UK funds industry due to uncertainty over UK’s ability to export financial services to the European Union following Brexit.
New India-Japan Tax Treaty Comes into Force
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November 2nd, 2016
The Indian Department of Revenue informed that the amended bilateral tax treaty between India and Japan has come into force as of October 29.
The Amending Agreement
Reviewing Hedge Fund Administration M&A 2016 Report
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November 1st, 2016
A report containing recently published articles on hedge fund administration argues that custodian banks will extend fund administration services to alternative fund managers and addresses several key areas of hedge fund administration including, standardization, strategy, convergence and cultural fit.
M&A Will Improve Standardization
European Commission's Research: EU To Benefit From CCTB & CCCTB
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November 1st, 2016
The European Commission released a report that investigates the economic impact of the common corporate tax base (CCTB) and a common consolidated corporate tax base with formula apportionment (CCCTB) within the EU. The paper concludes that the policy would result in a fairer and more efficient tax system and could have positive impact on GDP and welfare.
China Takes the Lead on Transfer Pricing Policy: Combating BEPS Through a Value Chain Analysis
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October 29th, 2016
Authors: Steef Huibregtse is the CEO and the founding partner of TPA Global, and Ying van Galen Wang is a project manager with the firm.
China’s State Administration of Taxation on June 29, 2016 issued a new transfer pricing regulation - Bulletin 42, which replaced specific sections stipulated in previous transfer pricing circulars2 in relation to annual filing of related-party transactions and contemporaneous transfer pricing documentation.
Top Transfer Pricing Challenges for the Agricommodities Industry (BEPS)
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October 28th, 2016
Authors: Steef Huibregtse is the CEO and the founding partner of TPA Global and Katerina Miari is an Associate at TPA Global in Amsterdam.
The complexities of transfer pricing, particularly in the midst of BEPS-driven reforms, have created significant burdens for multinational enterprises.
Singapore Agrees to Exchange Information with South Africa and Norway
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October 28th, 2016
On October 26, the Inland Revenue Authority of Singapore announced that Singapore has signed agreements for automatic exchange of financial account information (AEOI) with South Africa and Norway.
Automatic Exchange of Information
EU To Take a Big Step in Corporate Tax Reform
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October 28th, 2016
The EU Commission published the proposals for Common Consolidated Corporate Tax Base (CCCTB) directive, Common Corporate Tax Base (CCTB) directive, the Amendments for Anti-Tax Avoidance Directive and Double Taxation Dispute Resolution Mechanisms.
CCCTB
UK Might Use Tax Reductions to Put Pressure on the EU
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October 25th, 2016
Britain might slash corporation tax to 10 percent if EU member states block a free trade deal with the UK or block UK-based banks from accessing its market.
Background
Five New Jurisdictions Will Exchange Country-By-Country Reports
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October 25th, 2016
The OECD announced that Brazil, Guernsey, Jersey, the Isle of Man and Latvia signed the Multilateral Competent Authority Agreement (MCAA) for the automatic exchange of Country-by-Country reports. At the same time, Brazil also signed the CRS Multilateral Competent Authority Agreement‎ (CRS MCAA).
South Korea’s IMM Private Equity Closed its Third Investment Fund
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October 25th, 2016
IMM Private Equity has closed its third investment fund focused on Korean market on KRW1.25trn ($1.
OECD Releases Document on MAP (Action 14)
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October 21st, 2016
On October 20, the OECD released key document that will form the basis of the Mutual Agreement Procedure (MAP) peer review and monitoring process under Action 14 of the BEPS Action Plan. The document was approved by the Inclusive Framework on BEPS and OECD will be seeking taxpayer input in the coming weeks.
Japan And Austria Agree In Principle On a New DTA
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October 21st, 2016
On October 20, the Government of Japan and the Government of the Republic of Austria have agreed in principle on the New Tax Convention for the Avoidance of Double Taxation with respect to Taxes on Income.
New Convention
TPA Global Event 2016 - "Value Chain Analysis - the BEPS generation of functional analysis"
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October 21st, 2016
TPA Global conference topic is:
"Value Chain Analysis - the BEPS generation of functional analysis"
How to fight State Aid cases through a full "value chain analysis" - the Starbucks and Apple cases? (2)
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October 21st, 2016
In the public version of the “Starbucks decision” of the European Commission, quite often reference is made to the transfer pricing report of Starbucks. Although no public version of this transfer pricing report is made available, it seems reasonable to conclude that the report did not include a proper value chain analysis.
US and Mexico Revise Unilateral APA Applications Involving Maquiladoras
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October 18th, 2016
On October 14, the Internal Revenue Service (IRS) announced that US taxpayers with maquiladora operations in Mexico will not be exposed to double taxation if they enter into a unilateral advance pricing agreement (APA) with the Large Taxpayer Division of Mexico’s Servicio de Administración Tributaria (SAT) under a new agreement.
Background: Maquiladoras
September Shift in Hedge Funds
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October 18th, 2016
Following a year of criticism over high fees and the disappointing performance of the global hedge fund industry, September has brought hope for change with outperforming equity hedge and event-driven strategies.
Background: Last Year in Hedge Fund Industry
BRICS Countries Target Tax Avoidance
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October 18th, 2016
On October 16 at the BRICS summit, the BRICS countries stressed the need for a mutually acceptable mechanism among BRICS nations to fight tax avoidance. The countries also agreed to set up an independent rating agency based on market-oriented principles to further strengthen global financial architecture.
Singapore Issues e-Tax Guide for Country-by-Country Reporting
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October 13th, 2016
The Inland Revenue Authority of Singapore (IRAS) issued an e-Tax Guide on Country-by-Country Reporting. Singapore-headquartered MNEs meeting certain conditions are required to prepare and file CbC Reports to the IRAS for financial years beginning on or after January 1, 2017.
European Council - Conclusions on Tax Transparency
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October 13th, 2016
During the European Council meeting on October 11, the Council adopted conclusions on tax transparency in response to a Commission communication on tax transparency following the April 2016 Panama Papers revelations.
Large-Scale Concealment of Funds
UN Tax Committee Suggest Changes in its TP Documents
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October 12th, 2016
The UN Committee of Experts on International Cooperation in Tax Matters has released several reports that suggest changes to the UN’s transfer pricing manual for developing countries. Other reports addressing issues such as model tax treaty or mutual agreement procedure were released in advance of UNs annual meeting taking place in Geneva on October 11-14.
EU: Agreement Reached on Financial Transaction Tax
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October 12th, 2016
On October 10, the finance ministers of the 10 EU member states that work on developing financial transaction tax (FTT) held a meeting in Luxembourg. The ministers had agreed on some important measures that form "the core engine" of FTT, but further details have to be agreed on in the coming weeks.
Commissioner Vestager Discusses State Aid with Irish MEPs
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October 12th, 2016
During the European Commission's structured Dialogue with EU's Competition Commissioner Margrethe Vestager held on October 10, the Commissioner defended the position of the Commission on the Apple Ireland case.
Problem
BEPS and Transfer Pricing in MNCs: Policy Considerations and Practices
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October 11th, 2016
The changes proposed by the OECD BEPS Action Plan in October 2015 have the potential to substantially challenge the whole tax and transfer pricing landscape for many taxpayers. More specifically, with a radical attack on preferential regimes and tax avoidance schemes and enhanced transparency through, for example, for example, Country-by-Country (“CbC”) reporting, tax authorities and other governmental units will be able to understand and where appropriate challenge how MNEs allocate their profits and taxes globally.
UK Will not Cut Corporate Tax Rate to 15 Percent
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October 7th, 2016
During the Conservative Party conference in Birmingham held on October 3, the new Chancellor Philip Hammond said the government will follow its plans to lower Britain's corporation tax rate to 17 percent by 2020, instead of 15 percent as suggested by his predecessor George Osborne.
Background: Rate of 15 percent
Four Updates on Japanese DTAs
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October 7th, 2016
The Japanese Ministry of Finance announced that the country will begin negotiations for Tax Convention with Austria. The Ministry also informed that it signed DTA with Slovenia and that Protocol Amending Tax Convention with India and new tax agreement with Germany will enter into force by the end of October 2016.
DTA between Hong Kong and Korea Enters into Force
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October 7th, 2016
Hong Kong’s tax authority announced that the agreement between Hong Kong and Korea for the avoidance of double taxation and prevention of income tax evasion came into force.
The agreement was initially signed in July 2014, which was followed by the ratification procedures in Hong Kong and Korea.
Irish Finance Minister Elaborates on Apple Case
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October 7th, 2016
On October 4, Irish Minister for Finance Michael Noonan published an opening statement to the Irish Senate regarding the European Commission’s decision that Ireland provided unlawful state aid to Apple. The minister provides wide background information and elaborates on the flaws in the Commission's argumentation.
Foreign Banks Targeted in Germany
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October 7th, 2016
German state prosecutors are investigating 57 foreign banks for tax evasion using information obtained from self-declared tax evaders. According to the media, the voluntary disclosures provide very valuable information and became a favorite method of tax prosecutors to track down the evasions.
Switzerland Ratifies Multilateral Agreement on Tax Transparency
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September 29th, 2016
Switzerland deposited the instruments of ratification for the Multilateral Convention on Mutual Administrative Assistance in Tax Matters (Administrative Assistance Convention) with the OECD in Paris.
To Enter into Force
Draft Guidance on Northern Ireland Corporate Tax Regime
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September 29th, 2016
The HMRC has released a 120 pages draft guidance on the operation of Northern Ireland’s corporation tax regime and invites interested parties for comments. The guidance covers calculations of 'profits or losses', corporate tax rate of 12.
Thailand Will Amend its Tax Collection Rules for Internet and Tech Firms
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September 28th, 2016
Thailand’s Revenue Department head, Prasong Poontaneat said in the interview that Thailand is planning to toughen tax collection rules for internet and technology firms to update the country's tax laws.
Background
Switzerland: Consultation on Amending the Withholding Tax Ordinance
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September 28th, 2016
The Swiss Federal Council issued a press release announcing that it has initiated the consultation procedure on an amendment to the Withholding Tax Ordinance. The aim of the proposed amendments is to strengthen financing activities of groups in Switzerland.
Canada: Too Late for Voluntary Disclosure Program
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September 28th, 2016
On September 26, the Canada Revenue Agency (CRA) announced in a statement that those taxpayers that have been identified in the Panama Papers and are being reviewed or audited cannot qualify for the Voluntary Disclosure Program anymore.
Background
Value Chain Analysis - The BEPS Generation of Functional Analysis (2)
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September 26th, 2016
The value chain for any firm links value-creating processes and activities. It refers to the entire performance process of a company, which begins with the research and development and ends with the delivery to the end consumer.
Singapore and the UK Sign Agreement for AEOI
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September 25th, 2016
On September 16, the Inland Revenue Authority of Singapore (IRAS) and Her Majesty’s Revenue and Customs (HMRC) signed a Competent Authority Agreement on the automatic exchange of financial account information (AEOI) based on the Common Reporting Standard.
Exchange of Information
Revitalizing Your Digital Strategy | Tax scandles and strategic challenges faced by Apple in 2016!
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September 22nd, 2016
A 13 billion tax penalty for Apple, yet who’s to blame? Apple had sweet-heart deals paying less than 1% tax since 2004.
According to Apple, no laws were broken, the tax breaks were permitted by the Irish government.
Tax Risk Management & Transfer Pricing for Life Sciences
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September 22nd, 2016
As regulations around the world become both more numerous and stringent, and enforcement and penalties increase in the highly regulated life sciences sector, companies may benefit from taking a risk-based approach to tax planning compliance, execution, and tracking.
The conference agenda will focus on the most problematic areas in tax risk management such as tax compliance and governance, transfer-pricing and country-by-country reporting issues management and others:
Tech Giant Receives Another Tax Bill
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September 22nd, 2016
Japan's Tokyo tax authorities ordered a Apple iTunes unit in Japan to pay $118 million in penalty taxes for failing to properly pay withholding tax on usage rights for software allowing online music and video distribution. Following the series of Apple's tax bills, the EU Competition Commissioner Margrethe Vestager defended the EU's Apple Ireland case during her visit in Washington on September 19.
ATO Warns Multinationals Over Two Avoidance Schemes
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September 22nd, 2016
On September 20, the Australian Taxation Office (ATO) has cautioned multinationals against international profit shifting by multinational companies. In two alerts, ATO addressed 'Cross-Border Round Robin Financing Arrangements' and 'Restructures in response to the Multinational Anti Avoidance Law (MAAL) involving foreign partnerships'.
Indonesia Investigates Internet Search Giant Over $400m Tax Bill
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September 22nd, 2016
The Indonesian Tax office launched investigation on Google over suspicion of tax avoidance over last five years. If found guilty, Google would have to pay $400m (€358m) back in taxes with an $18 million fine.
EU Launches Work On EU's Tax Haven Blacklist
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September 22nd, 2016
The European Commission has launched its work to create first common EU list of non-cooperative tax jurisdictions by presenting a pre-assessment ('scoreboard of indicators') of all third countries according to key indicators.
Member States Select Non-cooperative Jurisdictions
How through a proper Value Chain Analysis the tax payer takes in control of the new generation of TP documentation requirements (BEPS Action 13)
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September 19th, 2016
How through a proper Value Chain Analysis the tax payer takes in control of the new generation of TP documentation requirements (BEPS Action 13).
A Value Chain Analysis (‘VCA’) considers an end to end view of a company’s activities, enabling a better perspective on the way a business works and how each component contributes and creates value.
European Parliament Supports Decision On Irish State Aid
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September 15th, 2016
During the debate on September 13, the European Parliament has strongly supported the European Commission’s conclusion that Ireland granted Apple illegal tax benefits, which enabling the company to pay substantially less tax than other businesses over many years.
Background
Pakistan Signs OECD's Convention on Tax Assistance
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September 15th, 2016
Pakistan signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters and became the 104th jurisdiction to join the Convention.
Background
New Course: Transfer Pricing – BEPS for Beginners
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September 14th, 2016
e-Bright and TPA Global have launched the 4th course of the Transfer Pricing courses
‘BEPS for Beginners’
Indonesia - Shell Companies Not Allowed Under Tax Amnesty
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September 14th, 2016
The Indonesian government is requiring individuals or entities that want to take part in its new tax amnesty program to dissolve any shell companies they own overseas.
Background
India & Mauritius: Foreign Investors Surprised by Aggressive Stance
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September 14th, 2016
The Indian tax office has started questioning foreign direct investors using Mauritius to bet on Indian stocks regarding special purpose vehicles and their establishments in Mauritius.
Background
US-Korean FATCA Entered Into Force
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September 14th, 2016
On September 8, a Model 1 intergovernmental agreement (IGA) signed by the US and South Korea entered into force.
Background
HMRC Opens the Worldwide Disclosure Facility
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September 8th, 2016
On September 5, HMRC opened the Worldwide Disclosure Facility allowing multinationals to disclose a UK tax liability that relates wholly or in part to an offshore issue. On September 6, HMRC followed with a guidance to tax avoidance elaborating on how to get help to settle the tax affairs.
Impact of Apple Case On Singaporean Companies In Question
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September 8th, 2016
Local media in Singapore have questioned the situation in the EU after the Apple case. Singapore firms could be targeted by the EC if these companies enter into anti-competitive agreements that distort competition within the EU.
G20 Leaders Push For Tax Transparency
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September 7th, 2016
G20 leaders have met during the summit in Hangzhou, China, held September 4–5, where they shared their views on current international tax environment. The countries endorsed a proposal on the objective criteria to identify non-cooperative jurisdictions with respect to tax transparency.
Singapore And Australia To Share Data
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September 7th, 2016
On September 6, the Inland Revenue Authority of Singapore has informed that Singapore and Australia have entered into a Competent Authority Agreement on the automatic exchange of financial account information (AEIO) based on the Common Reporting Standard (CRS).
Background: Singaporean Hubs
European Commission Criticized Over Apple Case
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September 7th, 2016
Following the EU's decision on Apple Ireland case, several US politicians including treasury secretary Jack Lew have strongly criticized the European Commission over its conclusion. The International Chamber of Commerce have expressed strong disagreements and warned against possible negative outcomes of the decision.
OECD to Hold First 'Inclusive Framework for BEPS Implementation' Meeting
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September 7th, 2016
On June 30 and July 1, representatives of countries and jurisdictions worldwide will gather in Kyoto, Japan, for a first meeting of the inclusive framework organized to take forward the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project.
Governance, Structure and Work Program
TPA Global Launches New Global Portal
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September 2nd, 2016
TPA Global is proud to announce that it has launched a completely redesigned and enhanced web site.
"Moving forward, we will be updating and improving the web site on a continual basis, but it should be clear today that TPA Global and its professionals are committed to doing a better job communicating with the information demanding corporate transfer pricing market and using technology to operate more efficiently," said managing partner Steef Huibregtse.
Dutch-Ethiopian DTA Entered into Force
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September 1st, 2016
On August 30, the Dutch Government announced that the convention between the Kingdom of the Netherlands and the Federal Democratic Republic of Ethiopia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes and income entered into force on September 1, 2016.
Background
US Tech Giants Warn the Netherlands over Changing Its Tax Regime
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September 1st, 2016
The Silicon Valley Tax Directors Group (SVTDG), which unties 85 biggest US technology companies, have sent a letter addressed to the Dutch prime minister, State Secretary of Finance and to the ministers of Finance, Economic Affairs and Trade, warning the country not to change its favorable tax regime and to resist the pressure from the EU.
Background
Brazil Expected to Push Against Tax Havens
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September 1st, 2016
At the upcoming G20 Summit in Hangzhou, China, Brazilian officials will join several non-governmental agencies that focus on fiscal havens and tax evasion. Brazil also plans to expand cooperation in trade and services with China and schedule a seminar for Chinese investors during the summit.
China Policy in the Lead – A Full Value Chain Analysis for FY 2016 required
; posted on
September 1st, 2016
The China State Administration of Taxation ("SAT"), on June 29, 2016 issued "the Public Notice on Matters Regarding Refining the Filing of Related Party Transactions and Administration of Contemporaneous Transfer Pricing (“TP”) Documentation Public Notice of the State Administration of Taxation [2016] 42” ("Notice 42"), which replaced certain sections laid down in “Guoshuifa [2008] Circular 114 in relation to annual filing of related party transactions and certain sections laid down in the “Guoshuifa [2009] (“Circular 2”) in relation to contemporaneous TP documentation.
Notice 42 mainly reflects the Chinese tax authority’s position in responding the international standard set out in the OECD/G20 BEPS Action 13~~ (“Action 13”) in relation to TP documentation and country-by-country (“CbC”) reporting
Corporate ‘Tax’ Governance: A Necessary Addition to Best Practices for Businesses?
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September 1st, 2016
Management of an entity’s tax strategy has historically been down to finance directors and has received little attention from boards. However, the growing reputational risk attached to strategies that incur a notably low tax bite and the ensuing BEPS project has forced boards to focus on their taxes as much as they do other areas of corporate governance.
Exchange of Information on Tax Rulings and APA’s
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August 30th, 2016
In reference to the rules issued by OECD/G20 and EU, the Dutch tax authority (‘DTA’) is asking taxpayers to provide the required information on the tax ruling they agreed with the DTA. The rules are aimed at improving transparency on tax rulings granted by jurisdictions and are driven by the outcomes of Action 5 of the OECD/G20 BEPS Project and by the amendments of EU Directive 2011/16/EU provide for the mandatory spontaneous exchange of information between Member States.
Japan and Panama Sign a Tax Information Exchange Agreement
; posted on
August 30th, 2016
On August 26, the Japanese ministry of finance announced that the government of Japan has signed a Tax Information Exchange Agreement (TIEA) with the government of the Republic of Panama.
Effective Exchange
EU: Ireland Granted Illegal Tax Benefits to Apple Worth of €13 Billion
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August 30th, 2016
On August 30, the European Commission concluded that Ireland gave Apple illegal tax benefits of €13 billion between the years 2003 to 2014. The Irish government has been ordered to recover the funds plus interest.
OECD Publishes Comments On Amendments To Chapter IX TP Guidelines
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August 26th, 2016
On August 24, The OECD published the comments it received on the conforming amendments to Chapter IX of the OECD Transfer Pricing Guidelines, "Transfer Pricing Aspects of Business Restructurings."
Background
Singapore Signs DTA With Ethiopia and BIT with Mozambique
; posted on
August 26th, 2016
On August 24, the Singaporean Ministry of Finance informed that it signed an Avoidance of Double Taxation Agreement (DTA) with Ethiopia and a Bilateral Investment Treaty (BIT) with Mozambique.
DTA with Ethiopia
OECD Publishes Comments On Amendments To Chapter IX TP Guidelines
; posted on
August 26th, 2016
On August 24, The OECD published the comments it received on the conforming amendments to Chapter IX of the OECD Transfer Pricing Guidelines, "Transfer Pricing Aspects of Business Restructurings."
Background
OECD Releases Discussion Draft On Branch Mismatch (Action 2)
; posted on
August 24th, 2016
The OECD invited interested parties to provide comments on branch mismatch structures under Action 2 (Neutralizing the Effects of Hybrid Mismatch Arrangements) of the BEPS Action Plan.
Background
Sweden Warns UK Against Corporate Tax Cuts
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August 24th, 2016
During an interview on August 21, Swedish Prime Minister Stefan Loefven warned the UK against cutting corporate taxes or implementing similar competitive measures. He said that such moves would damage the relations with the EU states and make Brexit talks 'more difficult'.
Trinidad and Tobago Signs IGA With US
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August 24th, 2016
On August 19, Trinidad and Tobago and the United States have signed an Inter-Governmental Agreement (IGA) as part of the implementation of the Foreign Account Tax Compliance Act (FATCA).
Background
OECD Releases Discussion Draft On Branch Mismatch (Action 2)
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August 24th, 2016
The OECD invited interested parties to provide comments on branch mismatch structures under Action 2 (Neutralizing the Effects of Hybrid Mismatch Arrangements) of the BEPS Action Plan.
Background
Irish - Ethiopian DTA Entered Into Force
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August 16th, 2016
The Irish Revenue announced that the Convention between Ireland and Ethiopia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income entered into force on August 12, 2016.
Background
Mauritius and Korea Sign Tax Information Exchange Agreement
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August 16th, 2016
On August 11, Mauritius and the Republic of Korea signed a Tax Information Exchange Agreement (TIEA). Finance Minister of Mauritius, Pravind Jugnauth, reaffirmed the intention to initiate negotiations on a Double Taxation Avoidance Agreement with Korea.
ATO Warns about Specific Tax Avoidance Arrangements
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August 12th, 2016
On August 10, the Australian Taxation Office (ATO) issued 3 Taxpayer Alerts cautioning large companies and multinationals seeking to avoid tax. The Taxpayer Alerts regard the arrangements involving offshore permanent establishments, GST implications in response to the Multinational Anti-Avoidance Law (MAAL) and Thin capitalization.
Intergovernmental Agreement Curacao-USA Is Now In Force
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August 12th, 2016
The intergovernmental agreement (IGA) between Curacao and the United States that implements FATCA Model 1 is now in force, Curacao Chronicle informed.
Background
Indonesia to Cut Corporate Tax Rate to Stay Competitive
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August 12th, 2016
Indonesia's President Joko Widodo informed that he is considering cutting the corporate tax rate to 17 percent from 25 percent in order to match Singapore's corporate tax rate.
Tax Rate Cut
New Zealand - Simplified Tax Processes and Tighter Foreign Trust Rules
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August 11th, 2016
Revenue Minister Michael Woodhouse informed that New Zealand has introduced a tax bill to simplify tax processes, reduce compliance costs for smaller businesses, and tighten foreign trust disclosure rules. The bill includes the necessary measures to implement the G20/OECD standard for the Automatic Exchange of Information for financial institutions.
BEPS implemented into the LATAM countries: what is happening in that region?
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August 4th, 2016
In the case of LATAM countries the majority are not OECD members and their contribution to BEPS measurements has been limited. Nevertheless, some LATAM countries already have or have announced to implicitly or explicitly implement regulations that are anti-BEPS.
OECD - Discussion Draft on Action 4 in the Banking and Insurance Sectors
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August 3rd, 2016
The OECD invited interested parties to provide comments on a discussion draft which deals with approaches to address BEPS involving interest in the banking and insurance sectors under Action 4 (Interest deductions and other financial payments) of the BEPS Action Plan.
Action 4 - Background
IRS seeks $3-5bn from Social Media Giant over Transfer Pricing
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August 2nd, 2016
Facebook has informed that the US Internal Revenue Service delivered a "notice of deficiency" seeking $3bn (€2.68bn) to $5bn, plus interest and penalties, based on the agency's audit of Facebook's transfer pricing.
OECD - Discussion Draft on Action 4 in the Banking and Insurance Sectors
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August 2nd, 2016
The OECD invited interested parties to provide comments on a discussion draft which deals with approaches to address BEPS involving interest in the banking and insurance sectors under Action 4 (Interest deductions and other financial payments) of the BEPS Action Plan.
Action 4 - Background
IRS - Jurisdictions Need To Have IGA Implementation Plan In Place
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August 2nd, 2016
The US Treasury has announced that it will begin updating the Intergovernmental Agreement (IGA) List and will stop treating a country as if it has the Foreign Account Tax Compliance Act (FATCA) IGA “in effect” if the country does not prove that it has a plan to bring the IGA into force.
Background
New Zealand Not Afraid of EU's Blacklist
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August 2nd, 2016
New Zealand is not likely to end up on EU's blacklist despite the local media’s claim that New Zealand has been put on the EU's radar especially due to many links revealed by the Panama Papers, for which the European Union set up a special investigation committee.
Background: EU Blacklist
South African Treasury To Curb Tax Avoidance Through Trusts
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August 2nd, 2016
The National Treasury informed its plans to introduce a new section into the Income Tax Act that will address the avoidance of estate duty by moving assets to a trust. The National Treasury is concerned abut the interest free loans or loans with interest below market rates without being subject to either donations tax or estate duty, which is a common approach in South Africa.
Investors and Private Equity Associations Are Concerned About India-Singapore Tax Treaty
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August 1st, 2016
Foreign portfolio investors and private equity associations are concerned about the India-Singapore tax treaty, which is expected to be signed later this year. In the last month, the associations have written to the government requesting several changes on the tax treaty.
Egypt Joins the Global Forum on Exchange of Information
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July 28th, 2016
The OECD announced that Egypt has joined the Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum), bringing its membership to 135. The last members to join the Global Forum were Lebanon and Paraguay in May.
Insights into BEPS Implementation By MNEs
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July 22nd, 2016
A new 2016 Global BEPS Readiness Survey examined how multinational enterprises are reacting to and preparing for the BEPS, revealing problems multinationals have adjusting to the new rules. The findings uncovered trends, revealed risks and exposed pain points on a global scale.
Insights into BEPS Implementation By MNEs
; posted on
July 21st, 2016
A new 2016 Global BEPS Readiness Survey examined how multinational enterprises are reacting to and preparing for the BEPS, revealing problems multinationals have adjusting to the new rules. The findings uncovered trends, revealed risks and exposed pain points on a global scale.
Jamaica Joins Inclusive Framework on BEPS Implementation
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July 21st, 2016
The OECD announced that Jamaica has become the 85th member of the Inclusive Framework on BEPS Implementation. The OECD informed that more countries that attended the Kyoto meeting on June 30, are expected to join the Framework.
OECD Releases Discussion Draft on Group Ratio Rule (Action 4)
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July 11th, 2016
On July 11, the OECD invited interested parties to provide comments on a discussion draft which deals with elements of the design and operation of the group ratio rule under Action 4 (Interest deductions and other financial payments) of the BEPS Action Plan.
Fixed Ratio Rule
Hong Kong Ready for Automatic Exchange of Information
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July 6th, 2016
On June 30, The Inland Revenue (Amendment) (No. 3) Ordinance 2016 (the Amendment Ordinance) came into effect, the Hong Kong Inland Revenue Department has informed.
OECD Releases Two Discussion Drafts on BEPS Actions 7 and 8 - 10
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July 6th, 2016
The OECD has released BEPS discussion drafts on attribution of profits to permanent establishments, which deals with work in relation to BEPS Action 7, and revised guidance on profit splits, which deals with work in relation to BEPS Actions 8-10.
Discussion Draft - Action 7
OECD Releases Guidance on the Implementation of CbC Reporting
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July 1st, 2016
The OECD has released guidance on implementing country-by-country (CbC) reporting, as set out in Action 13 Report “Transfer Pricing Documentation and Country-by-Country Reporting” of the base erosion and profit shifting (BEPS) project.
Country-by-Country Reporting
European Parliament Adopts Anti-Tax Avoidance Directive
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June 10th, 2016
The European Parliament voted overwhelmingly in favor of the Anti-Tax Avoidance Directive, proposed by the European Commission in January 2016, which aims at tightening rules against tax avoidance. At the same time, the parliament has also set up a “Panama Papers” inquiry committee to investigate alleged contraventions and maladministration.
EU Investigate Members' TP Rulings under State Aid
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June 7th, 2016
The EU Commission released a working paper identifying problematic areas in profit allocations and arm’s length standard across Member States’ transfer pricing rulings. The working paper investigates whether certain rulings would be prohibited under EU's state aid rules.
EU: Multinationals Grilled at TAXE Meeting
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March 19th, 2016
Representatives from Apple, Google, Ikea and McDonald’s were questioned on their tax structures in Europe at a special hearing of the European Parliament’s special committee on tax on Tuesday, March 15, in Brussels. The MEPs also asked on feedback on specific areas of BEPS project.
How to make intercompany loans BEPS proof
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March 17th, 2016
In this article we provide four “true or false” statements on how the intercompany debt financing has become vulnerable and how to resolve the transfer pricing issues around that.
Debt as intercompany financing with excessive interest deductions has come under greater scrutiny of the tax authorities after the OECD published its final work on Action Points relating to intercompany financing in October last year.
How To Make Intercompany Loans BEPS Proof
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March 17th, 2016
Authors: Steef Huibregtse, Virender Sharma and Maria Grigoryeva (consultants at TPA Global)
Debt as intercompany financing with excessive interest deductions has come under greater scrutiny of the tax authorities after the OECD published its final work on Action Points relating to intercompany financing in October last year. In the light of the aforementioned, and the current practice of MNEs on intercompany loans, this article delves into 4 “true or false” statements which are relevant for various stakeholders including MNEs to ponder over.
Standardize Your Transfer Pricing Documentation System in light of OECD project on BEPS Action 13 report
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February 18th, 2016
In order to standardize, simplify and streamline multinational enterprises’ (MNEs) transfer pricing (“TP”) documentation and to improve global consistency, but still complying with local TP requirement, especially in the light of the OECD project on BEPS Action 13 report 1, TPA has designed this project to provide global TP documentation on a standardized approach through building up the following TP framework:
Master File template
TAXe | Countries that Granted State Aid Should not Be Recovered
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January 20th, 2016
On January 19, the European Parliament agreed that money that a member state should recover from a company due to infringements of tax-related state aid rules should be returned either to the EU budget or to member states that have suffered an erosion of their tax bases.
The Report
USA - New regulations on Country-by-Country Reporting by MNEs
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December 23rd, 2015
On 21 December, The US Treasury Department released a proposal on regulations that would require annual country-by-country reporting by US companies that are the ultimate parent entity of a multinational enterprise (MNE) group.
International Context
TPA German BRICS+ Desk
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December 22nd, 2015
What the BRICS countries do for German Multinationals has a significant economic relevance – at least 1,800 German corporates already have a presence in India, and in Russia one may find 6,000 active corporates with a German origin. Next to these countries, some important markets for the German business community exist, such as Mexico, Turkey, Singapore or Indonesia.
ATAF to Reduce Double Taxation across Africa
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December 15th, 2015
The African Tax Administration Forum (ATAF) has come up with a draft document on avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income in Africa.
Model Agreement
Curaçao Malta DTA Available
; posted on
November 24th, 2015
The English version of DTA with respect to Taxes on Income between the Republic of Malta and the Kingdom of the Netherlands in respect of Curaçao has been published on the website of the Malta Financial Services Authority (MFSA).
Convention
Multinationals Endorse Patent Box in US
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November 19th, 2015
A collection of some of America’s leading companies working under American Innovation Matters (AIM) released a statement pushing for the introduction of a US patent box, or an "innovation box" as it is known in the United States.
American Innovation Matters
European Commission Aims to Deal with Corporate Tax Regimes that Favor Debt Over Equity
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October 1st, 2015
The European Commission will propose a draft law aimed at eliminating tax regimes that favor raising corporate debt over equity, as it tries to reduce the amount of company loans on banks' books and to cut companies' leverage, the Commission announced on 30 September in its Capital Markets Union Action Plan.
Tackling the Debt-Equity Tax Bias
China is Expected to Progress Its Global Corporate Tax Rules
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August 4th, 2015
On 30 September 2015, China Daily has reported that China will be at the forefront of embracing the emerging international tax rules to combat base erosion and profit shifting, known as BEPS, as it shifts toward becoming a "capital-export" country.
Modernization
China is introducing BEPS legislation
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April 15th, 2015
On March 18, 2015, the State Administration of Taxation in China (SAT) released the ‘Public Notice Regarding Certain Corporate Income Tax Matters on Outbound Payments to Related Parties Abroad’ (SAT Public Notice [2015] No.16, hereinafter referred to as “Notice 16”).
Criticism on OECD’s Modified Nexus Approach
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March 17th, 2015
In a joint statement, two business organizations from the Netherlands and Germany have stated their concerns about the development of the proposals under the OECD’s work on Action 5 of its BEPS project. This Action focusses on tackling harmful tax practices and patent box regimes regarding the IP income.
Italy Improves New Patent Box Regime
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March 14th, 2015
The Italian Government has passed improvements to its new patent box preferential tax regime, even though it was only introduced this month, after approval of the 2015 Budget Law in December.
As a means of encouraging the development of intellectual property (IP) in Italy, the patent box regime was introduced along similar lines to the incentives granted in other European Union countries, covering income deriving from the use or licensing of qualifying intangible assets.
Dissecting BEPS Action Plan 6 Preventing The Granting Of Treaty Benefits In Inappropriate Circumstances
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December 10th, 2014
Action Plan 6 of the BEPS Action Plan identified treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns.
The most important aspects of the report are :
Release of discussion draft on the transfer pricing aspects of cross-border commodity transactions
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December 7th, 2014
Public comments are invited on this discussion draft which deals with work in relation to Action 10 (“Assure that transfer pricing outcomes are in line with value creation” in relation to “other high risk transactions”) of the Action Plan on Base Erosion and Profit Shifting (BEPS).
The OECD Action Plan on Base Erosion and Profit Shifting, published in July 2013, identifies 15 actions to address BEPS in a comprehensive manner and sets deadlines to implement these actions.
UK Patent Box – a pre-Action Plan recipe?
; posted on
April 28th, 2014
The UK’s Patent Box system is becoming rather controversial. The scheme is scheduled to provide a predicted amount of £367M (€446M) in tax breaks and was introduced in April 2013.
India to audit transfer pricing based on risk assessments
; posted on
April 28th, 2014
A proposal has been set forward for the transfer pricing audit threshold in India to be removed in favour of a risk management, finger-picking approach. Currently, firms engaging in transactions above INR 15 crore (€1.
UK expecting no changes to Patent Box regime
; posted on
December 12th, 2013
HMRC, the British tax authority, has no current intention of making changes to the UK’s Patent Box system. The Patent Box has been under investigation by the European Commission, but the UK is confident that the arrangement is consistent with international guidelines and therefore will not require further tweaking.
Panama taxpayers must now document transactions with all foreign related parties
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September 1st, 2012
Recent amendments to Chapter IX of the Fiscal Code “Standard of Adaptation of Treaties to Avoid the Double International Taxation” will now reach any operation that a taxpayer in Panama has with its foreign related parties. Prior to the introduction of these amendments, transfer pricing documentation requirements in Panama only applied to cases where a tax resident in Panama had operations with a related party located in a country with which Panama has a double tax treaty in place.
Australia – ATO risk assessments
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February 1st, 2012
The Australian Taxation Office (“ATO”) has announced that it is currently writing to large businesses about the ATO’s assessment of their level of tax risk and that it is looking to meet with the senior executives of those taxpayers to explain their assessment. These tax risk assessments address issues relating to income tax, goods and services tax and excise.
News
; posted on
April 26th, 2016
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