14

Julio

2016

IRELAND: Apple EU tax probe decision coming in the autumn

Apple’s European headquarters are in Ireland and, like many multinationals, it transfers its profits from one country to another in order to pay as little tax as possible. This is not illegal, but according to the commission: “Tax rulings may involve state aid within the meaning of EU rules if they are used to provide selective advantages to a specific company or group of companies.”

29

Junio

2016

Countries to meet in Japan to discuss BEPS project

Representatives of countries across the world will gather Thursday to participate in a special meeting of the OECD Committee on Fiscal Affairs on the base erosion and profit shifting (BEPS) project.

27

Junio

2016

IRELAND Explains New Bilateral APA Program

The Government is introducing a formal bilateral APA program to implement the proposals contained in Action 14 of the base erosion and profit shifting project and to provide greater certainty in relation to the taxation of cross-border transactions entered into by multinational corporations. Until now, Ireland accepted requests for bilateral APAs on an ad hoc basis in situations where a tax treaty partner agreed to enter into a bilateral APA negotiation.

25

Mayo

2016

GRUPO CONSULTOR EFE™ WINS AWARD AS 2016 MEXICO AND LATAM TRANSFER PRICING FIRM OF THE YEAR

In the ACQ Global Awards 2016 edition, more than 160,000 votes were registered and with that, Grupo Consultor EFE™ has been selected as winner in three different categories: • MEXICO – TRANSFER PRICING FIRM OF THE YEAR. • LATAM – TRANSFER PRICING FIRM OF THE YEAR. • MEXICO – AUDIT AND ASSURANCE FIRM OF THE YEAR.

12

Mayo

2016

VIETNAM: Big C scrutinized for suspected transfer pricing: taxman

With a tax inspection into all Vietnamese outlets of retailer Big C set for completion later this month, local tax authorities are also considering the possibility that transfer pricing activities have taken place.

13

Abril

2016

CHILE: SII strengthens focus on transfer pricing and prepares circular fines of up to 300 %

Chile's Internal Revenue Service (SII) is preparing a circular with instructions on the fines to take for late , incomplete or maliciously false presentation of the affidavit of transfer pricing, each taxpayer who perform transactions with related parties abroad must submit no later than last business day of June.

12

Abril

2016

JAMAICA: Transfer Pricing expert on week-long official visit

Jamaica is continuing to receive overseas technical assistance on Transfer Pricing. Ian Wood, an Advance Pricing Agreement (APA) expert affiliated to the Organisation for Economic Co-operation and Development (OECD), is currently in the island for a five day official visit from April 11 to the 15, 2016.

04

Abril

2016

Ireland needs to start facing down the ‘tax haven’ taunts

At 35%, the US has the highest corporate tax rate in the OECD. However, the US tax code is incredibly complex and has numerous peculiarities. One of these is the concept of ‘deferral’ for corporate income taxes, which means US multinationals can delay certain tax payments until the profits are transferred to US-incorporated entities in their corporate structure. The primary objective of many tax strategies used by US multinationals is to engineer such a deferral, sometimes permanently.

28

Marzo

2016

Opinion: Double tax treaties are the toughest nut to crack

The prime minister admits that he doesn't think the current situation with New Zealand tax on multinationals is fair. It has been suggested that 20 multinational companies operating in New Zealand pay just $1.8 million of tax on revenue of $10 billion.

23

Marzo

2016

Canadian Budget Focuses On Tax Evasion And Avoidance

The first Budget tabled by Canada's new Liberal Government provides for a major crackdown on tax evasion and avoidance, and streamlines the domestic tax credits system. The Budget was delivered by Finance Minister Bill Morneau on March 22, 2016. He told Parliament: "Today, we begin to restore hope for the middle class. Today, we begin to revitalize the economy. Today, we begin a long-term plan that will use smart investments and an unwavering belief that progress is possible to ensure that Canada's best days lie ahead."

16

Marzo

2016

Google, Apple, IKEA and McDonalds probed by Tax Rulings II Committee

Google, Apple, Inter-IKEA Group and McDonald's would welcome more clarity and certainty about their tax liabilities in the EU, but they are concerned about the administrative compliance costs and reluctant to see tax data being made public. So said their representatives at a public hearing, held by Parliament's Special Committee on Tax Rulings II on Tuesday, to elicit their views on recent and upcoming proposed legislation on corporate tax.

14

Marzo

2016

INDIA: Audit Findings On Transfer Pricing Orders

Transfer pricing officers made an incorrect calculation of the arm’s length price in ten high-value transactions, according to the report of the Comptroller and Auditor General of India.

11

Marzo

2016

New Delhi: CBDT issues transfer pricing normsCBDT issues transfer pricing norms

In a guidance note issued to income tax officers, Central Board of Direct Taxes guided against manual picking of cases and underlined that that the cases be picked up for scrutiny only through computer-assisted selection process (CASS). Besides, the note suggested that a tax officer should refer cases to a transfer-pricing officer only in three defined circumstances and where there is income or potential income arising from international transactions.

09

Marzo

2016

EU sharpens focus on tax of multinationals

EU countries will exchange information on the tax affairs of multinational companies under new rules backed by EU finance ministers aimed at stopping big companies avoiding paying their fair share into government coffers.

07

Marzo

2016

UK updates Transfer Pricing guide

This briefing explains how the UK is working with other countries to change the international tax rules and ensure multinationals pay the right amount of Corporation Tax on their UK profits.

07

Marzo

2016

Mumbai: Companies face country-wise rules for transfer pricing

Professionals obtaining any sum of money under a non-compete agreement will now be subject to tax with the government having plugged a loophole in the Budget.

07

Marzo

2016

Nigeria: Transfer Pricing Comparable Data Constraints - Implications and Recommendations

Since Nigeria Transfer Pricing Regulations (the Regulations) came into force in September 2012, with 2, August 2012 commencement date, transfer pricing has become one of the hottest tax issues in Nigeria.

01

Marzo

2016

Countries Adopting BEPS Proposals, OECD Tells G-20

In a report submitted to the G-20 Finance Ministers and Central Bank Governors on February 26-27, 2016, the OECD's Secretary General, Angel Gurría, said that a number of countries have already adopted legislative changes to implement a number of the BEPS measures, including proposals contained under BEPS Action 2 (on neutralizing the effects the hybrid mismatch arrangements) and BEPS Action 13 (on transfer pricing documentation and country-by-country reporting).

29

Febrero

2016

FINLAND: Implements the OECD's Country-by-Country reporting

The Ministry of Finance released a draft of a government bill for public comments in December 2015. According to the draft, Finland will implement Action 13 of the 2015 Final Report of the OECD PEBS project by adding requirements to prepare a master file and provide Country-by-Country (CbC) Reporting. In addition, the penalty provision will be extended to cover the new requirements.

24

Febrero

2016

UK: In Google tax deal, MPs criticise secretive settlement

Public accounts committee says £130m deal seems ‘disproportionately small’ compared with size of UK business

22

Febrero

2016

Google Cut Taxes by $2.4 Billion Using European Subsidiaries

Google saved $2.4 billion in worldwide taxes in 2014 by shifting 10.7 billion euros ($12 billion) in international revenue to a Bermuda shell company, according to regulatory filings.

17

Febrero

2016

EU party says Ikea avoids at least US$1.1b taxes

The EU accuses the furniture giant of funneling money through Lichtenstein and the Netherlands between 2009 and 2014.

16

Febrero

2016

AFRICA: African countries discuss transfer pricing in Dakar

Tax administration experts from 22 African countries were brought together on Monday in Dakar in a seminar to discuss transfer pricing, upon the initiative of the Exchange and studies center on tax administrations (CREDAF), in partnership with OECD.Transfer pricing refer to the internal transfer of prices between companies of the same group established in different tax jurisdictions.

15

Febrero

2016

BEPS: Multinationals face trouble meeting the action plan

According to a study by Thomson Reuters, 1 in 4 multinational can not meet the deadline for compliance with the Plan of Action BEPS ( acronym for Base Erosion and Profit Sharing) of the OECD. European companies are more prepared than those of America and Asia

15

Febrero

2016

AUSTRALIA: More taxing times loom for hi-tech dodgers

Transfer pricing is one technique. A product made for, say $200, in China can be sold for $600 to another international subsidiary in a low tax country, which can then sell the product in Australia for $620, netting a taxable profit of just $20 in Australia.

10

Febrero

2016

KENYA enacts a new tax law

Kenya enacted a new law targeting units of foreign companies that escape remitting most of their domestic taxes by allocating income to tax havens while attributing expenses to the East African nation, a practice known as transfer pricing.

27

Enero

2016

South Africa: Greater tax transparency for multi-nationals a step closer

The South African Revenue Service (Sars) has published additional record-keeping requirements for large multi-national companies which they will have to comply with in future.

27

Enero

2016

IRS Destroys Hard Drive of Tax Compliance Microsoft Case

The disagreement between the IRS and the software giant centered on compliance with the federal tax code, specifically, the agency was looking into the company’s transfer pricing practices. A major concern in establishing the tax liability of multinational corporations, transfer pricing refers to the sale of goods and services between entities that are part of the same corporate structure.

26

Enero

2016

SPAIN: Tecnicas Reunidas faces Hacienda by 164 million

Discrepancies between the Treasury and the engineering group headed by José Lladó obey the tax transfer pricing model used in international projects.

26

Enero

2016

The European Parliament demands an end to unfair tax competition

As concrete measures , the document proposes the introduction of a common consolidated base of corporate tax , the VAT revisision and imposing multinational to communicate their sales and profits country by country.

21

Enero

2016

Argentina: AFIP changes the list of " cooperating countries " and modifies how investments are taxed

With the categorization of " cooperating country ," taxpayers can " usufruct preferential tax regimes , without penalties applied to them to investments or business conducted in these countries "

06

Enero

2016

Mexico: 74% of companies are ready for BEPS

European companies are mostly focused on the BEPS the rest of their peers in the world planning. Most companies headquartered in Europe (59%) are preparing for the BEPS, compared with 48% of companies in the Americas and Asia-Pacific.

04

Enero

2016

USA: Audit reveals Microsoft's tax shaving

A court fight this year between Microsoft and the Internal Revenue Service brought to light new documents outlining the deals that set up the company's structure. Additional court papers, corporate filings and tax records from four continents offer a rare, detailed look at the business of avoiding taxes.

04

Enero

2016

Opinion: Transfer Pricing in Venezuela under BEPS

How could these changes in transfer pricing documentation take effect in Venezuela? . One possibility could be based on an amendment to Chapter III of the Law on Income Tax ( LISLR )

04

Enero

2016

Cayman: Tax dodgers beware

Financial Services Minister Hon Wayne Panton says Cayman National’s US $6million settlement following a US tax evasion probe should serve as a lesson that tax evasion will not be allowed to flourish here.

04

Enero

2016

Opinion: Tax avoidance hits the poorest hardest

The news that Apple will pay £234m to settle an Italian tax dispute (Report, 31 December) is a powerful reminder of the scale of the challenge when it comes to making sure companies pay a fair amount of tax.

04

Enero

2016

Apple to pay Italy 318 million euros, sign tax deal

Apple will pay Italy’s tax office 318 million euros to settle a dispute over allegations it failed to pay taxes for six years, a source with direct knowledge of the matter said on December 30.

21

Diciembre

2015

Spin Master Reaches Agreement With Canada Revenue Agency to Resolve Previously Disclosed Transfer Pricing Matter

Spin Master Corp. announced today that it has reached a settlement agreement with the Canada Revenue Agency ("CRA"), which resolves a previously disclosed transfer pricing matter arising from the CRA's audit of the cost sharing arrangements between Spin Master Ltd. and a foreign affiliate during the 2004 – 2013 taxation years. The amount of the settlement is below the mid-point of the range stated in the Company's Initial Public Offering ("IPO") prospectus.

18

Diciembre

2015

Australia: More than a third of big companies paid no tax

Of 1539 corporate entities operating in Australia, 38 per cent did not pay tax in 2014, the tax transparency report released on Thursday by the Australian Taxation Office shows.

16

Diciembre

2015

Zero tax: Half of Australia's 1300 public companies have been under ATO review

About half the nation's 1300 public companies that will have their tax details publicly revealed have been under review by the Australian Taxation Office. Tax Commissioner Chris Jordan will on Thursday release the tax details of 1539 corporate entities – 985 of which are foreign-owned, and 554 of which are Australian foreign entities. There are some companies on the list – both tax paying and non-tax paying that we will be looking at more closely

15

Diciembre

2015

Coca-Cola Fights $9.4 Billion Transfer Pricing Adjustment

The Coca-Cola Co. filed a petition in U.S. Tax Court challenging a proposed $9.4 billion income adjustment related to the company's transfer pricing for tax years 2007-09

14

Diciembre

2015

Australia to unveil large business hit list, clamps down on Singapore hubs

The ATO has issued a warning to multinationals to come forward immediately to discuss their overseas hub arrangements, if they have not done so already. The warning comes as Tax Commissioner Chris Jordan will begin publishing the tax details of the nation's largest public companies later this week, and the ATO outlines its specific areas of "compliance focus" for large businesses in 2015-16.

11

Diciembre

2015

India set to finalise 40 advance pricing agreements by fiscal-end

In a move aimed at providing greater stability and transparency in its tax policy, India is set to finalise about 40 Advance Pricing Agreements by the end of the fiscal.

10

Diciembre

2015

Italy says international tax dodger amnesty is bringing in billions

The Italian government said on Wednesday it was set to rake in at least €3.8bn euros (£2.75bn/US$4bn) after tax dodgers took advantage of an amnesty deal to declare money and assets hidden abroad.

09

Diciembre

2015

India and South Korea sign taxation treaty MoU

India and Korea have inked a new memorandum of understanding on suspension of collection of taxes during pendency of mutual agreement procedure.

08

Diciembre

2015

EU adopts new transparency rules

The EU Council has adopted a new transparency directive aimed at preventing corporate tax avoidance The directive, which was proposed by the European Commission (EC), is aimed at improving transparency on tax rulings given by member states to companies about how their taxes are calculated. Under the new directive, member states will be required to automatically exchange information on advance cross-border tax rulings as well as advance pricing arrangements. This means any so-called sweetheart deals that member states have agreed to with multinationals will be revealed.

07

Diciembre

2015

JAMAICA: Private sector opposes retroactive tax measure

THE Private Sector Organisation of Jamaica (PSOJ) is not happy with amendments to the Income Tax Act that will see the implementation of a transfer pricing regime retroactive to April 1 this year.

07

Diciembre

2015

Vietnam: Coca-Cola on target for anti-transfer pricing

Is Coca Cola is a typical case of transfer pricing? The answer will depend on the inspection results. However, it is a big question for the public as a big firm like Coca-Cola has been reporting losses for years so as to not have to pay corporate income tax.

07

Diciembre

2015

Opinion: Behind the European Raid on McDonald’s

On Thursday the European Commission announced an investigation of McDonald’s for allegedly illegal behavior. This follows decisions in late October that FiatChrysler and Starbucks would each be assessed 20 million-30 million euros ($21.2 million-$31.8 million). The EC (the European Union’s executive arm) has announced similar investigations of Amazon and Apple, which are expected to result in much larger assessments.

04

Diciembre

2015

EU fights corporate goliaths on tax avoidance

A small team of European Union officials is spearheading an investigation that could force some of the world’s biggest companies to pay billions of euros in avoided taxes.

03

Diciembre

2015

Australian multinational tax avoidance laws to come into effect next year

From the start of 2016, multinational companies found to be avoiding tax will have pay back the tax owed, plus a 100 percent penalty.

02

Diciembre

2015

Thailand’s New Transfer Pricing Guidelines

Thailand’s vote this past May to implement a new transfer pricing law is expected to come into effect in the early part of the new year. Transfer pricing refers to the sale of goods or services between branches of a company or subsidiary companies to a parent enterprise, and most countries instate some form of transfer pricing regulations in order to ensure that sales between divisions of a company roughly mirror the cost of the same sale between separate enterprises.

01

Diciembre

2015

USA: Govt inks 11 pacts to sort transfer-pricing issues

The government has concluded 11 agreements to tax multi-national companies via the transfer-pricing mode. Of these, one advance pricing agreement (APA) has a 'rollback provision', which means those relating to previous years.

01

Diciembre

2015

Jamaica: Senate Passes Bill to Prevent Tax Leakage through Transfer Pricing

The Senate, on Friday (November 27), passed amendments to the Income Tax Act, which will empower the Government to prevent tax leakage through the transfer pricing system.

23

Octubre

2015

After transfer pricing scandal, Coca-Cola VN pays $20 million in taxes

According to the report, thanks to the new investment of $300 million in October 2012, Coca Cola developed strongly and achieved positive business results in Vietnam. In 2014 alone, the taxable profit of Coca Cola Vietnam was more than $16.6 million, doubling that of 2013 ($7 million).

12

Octubre

2015

Facebook paid less tax in 2014 than the average worker

Facebook is the latest large American corporation to be facing awkward questions about its UK tax bill. The tech giant paid a mere £4,327 in corporation tax in 2014 – less than the average British worker.

09

Octubre

2015

G20 Finance Ministers approve final standards for global tax reforms

Finance Ministers from India and other G20 countries today endorsed the final detailed action plan for putting in place a coherent and transparent global tax regime to curb artificial profit-shifting ways.

08

Octubre

2015

INDIA: Vodafone gets a reprieve in ₹8,500-cr transfer pricing case

The Bombay High Court on Thursday gave a favourable ruling to Vodafone in the transfer pricing case related to the sale of the company’s call-centre business to Hutchison and assignment of call options to Vodafone International.

07

Octubre

2015

Apple is still No. 1 at avoiding US taxes

US multinationals in the Fortune 500 doubled the assets they hold in foreign subsidiaries between 2008 and 2014, taking advantage of loopholes in US and foreign laws to keep $2.1 trillion out of sight of tax authorities, a new analysis shows.

06

Octubre

2015

Singapore’s tax jurisdiction largely in line with OECD’s tax proposals: Experts

Tax experts said Singapore's tax jurisdiction is already largely in line with the recommendations, and that sufficient measures have been taken to ensure tax incentives are appropriately extended to multinational firms.

05

Octubre

2015

Ireland could collect more corporation tax under new plan

The new global template for taxing multinationals could lead to more corporation tax being collected by Ireland, according to the head of the team behind the new plan. Pascal Saint-Amans, director of the Centre for Tax Policy and Administration at the Organisation for Economic Co-operation and Development, was speaking as the OECD said that up to $240 billion (€213 billion) is being lost annually to exchequers around the world because of aggressive tax planning by multinationals.

02

Octubre

2015

Denmark Legislates For CbC Reporting

The Danish Ministry of Taxation published draft legislation to introduce a new country-by-country reporting obligation for multinational corporations.

01

Octubre

2015

China Pushes Ahead with Localisation of BEPS Actions

China's State Administration of Taxation (SAT) has been busy during recent months pushing ahead with its own plans to update/revise a series of domestic tax laws and regulations as well as Sino-foreign tax treaties. The most prominent of these changes is the so-called “Master Guide” to Chinese transfer pricing. The SAT has just released a discussion draft of "Implementation Measures of Special Tax Adjustment", which makes direct reference to various draft recommendations proposed in the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plans.

30

Septiembre

2015

US Lags Behind Most OECD Countries in Tax Competitiveness

The United States ranks 32nd among the 34 member countries in the Organization for Economic Cooperation and Development (OECD), according to the Tax Foundation’s 2015 International Tax Competitiveness Index. The index is based on an analysis of more than 40 variables spanning five categories.

29

Septiembre

2015

Austria to send business mission to Ukraine

Fischer praised the decision of Ukraine to remove Austria from the list of countries subject to transfer pricing controls.

28

Septiembre

2015

The Canada Revenue Agency charges $265m on penalties to Silver Wheaton Corp.

Silver Wheaton receives notices of reassessment from the Canada Income Agency relating to its 2005 to 2010 taxation years. In issuing the reassessments, the CRA is looking for to raise Silver Wheaton’s income subject to tax in Canada for the Relevant Taxation Years by about $536 million which would result in federal and provincial tax of $151 million.

25

Septiembre

2015

Volkswagen's 'leakage'

When it comes to tax , like most multinationals operating here, the pattern is one of a contribution which has gone backwards over the past decade. Despite rising sales, their reported profits have stayed flat and so therefore has the amount of tax they pay.

25

Septiembre

2015

Bureau van Dijk Adds Document Management to Its Transfer Pricing Solution

Bureau van Dijk (BvD), one of our partners in PPI™, and the leading provider of company information, has created a new documentation workflow tool to streamline report-preparation, management and compliance in relation to the new BEPS and country-by-country (CbC) reporting requirements. This new solution is called Document Manager and is in addition to BvD’s existing TP Catalyst Benchmarking offering. It was launched at the Global Transfer Pricing Forum yesterday in Washington, DC.

24

Septiembre

2015

Myanmar: More tax laws planned

The IRD has plans to draw up additional laws, including a law dedicated to commercial tax, said the director. “We have found evaders everywhere. The most popular method is transfer pricing, but there are many other methods that we still need to identify.” Transfer pricing is price-fixing between different companies within the same group, so that prices can be set artificially low to avoid taxes.

22

Septiembre

2015

Australians grill Chevron over Bermuda links

Oil and gas multinational Chevron has come under fire in Australia for using Bermuda for tax avoidance. The oil company is one of seven facing a probe by the Australian federal government into corporate tax avoidance.

21

Septiembre

2015

US Urges India To Improve Tax Regime

The Indian Government must assure investors that it is committed to improving its legal framework, including the tax code, if it is to meet its economic objectives, a senior US State Department official has said.

21

Septiembre

2015

Coca-Cola owes $3.3 billion in taxes over transfer pricing

An audit found the company’s reported U.S. income from 2007 to 2009 should have been higher

18

Septiembre

2015

India: likely to resolve a bagful of tax disputes with MNC's

With Prime Minister Narendra Modi slated to visit the US later this month, Finance Minister Arun Jaitley has rekindled hopes of finding a resolution to tax disputes like Vodafone and Cairn.

17

Septiembre

2015

Netherlands Confirms CbC Reporting From 2016

Through Wetsvoorstel Overige Fiscale Maatregelen 2016, released on September 15, the Netherlands has confirmed the introduction of a new country-by-country (CbC) reporting obligation for multinational corporations.

15

Septiembre

2015

FINLAND: Minister on board of tax haven firm

Anne Berner, who serves as Minister of Transport and Communications, serves on the board of a Luxembourg firm involved in tax planning. This is the first time a Finnish minister has been known to have been involved in such a company.

14

Septiembre

2015

Australia: BHP Billiton, Rio Tinto 'ethically bankrupt' on tax

The former treasurer said that "virtually every industry has its share of tax avoiders, from pharmaceuticals, to media and technology, to oil and gas companies", but he focused particularly on BHP Billiton and Rio Tinto.

13

Septiembre

2015

VIETNAM: Double taxation avoidance with US will bring more gains than losses

With the agreement with the US, Vietnam has now signed the double taxation avoidance agreements with 70 out of 170 countries and territories with which Vietnam has trade and investment relations.

10

Septiembre

2015

CHILE: Increase in trials for transfer pricing issues.

The Internal Revenue Service (SII) has increased its powers and its oversight role over the years, and this will continue growing with the Tax Reform. But there is a change that was implemented with the previous tax reform prepared by Sebastian Piñera on transfer pricing.

09

Septiembre

2015

Johannesburg: South African economy affected by Capital Flight

The South African economy has been crippled by decades of transfer pricing and other forms of illegal capital flight by multinational companies, especially in the mining sector.

07

Septiembre

2015

Transfer pricing remains thorny issue for international trade

Key tax experts in the US, UK and SA have warned that the lack of tax certainty and the aggressive behaviour of tax authorities, especially on transfer pricing policies, may affect real investments.

04

Septiembre

2015

Ireland: European Commission to find against Ireland in Apple tax probe

The European Commission is to find against Ireland following the probe into its tax arrangements with Apple, according to financial newswire Bloomberg.

03

Septiembre

2015

INDIA: Illicit outflow of funds from developing countries a matter of concern

Minister of State for Finance Jayant Sinha has estimated that over $300-600 billion illicit fund moves out from developing countries including India to developed countries through money laundering and other ways.

02

Septiembre

2015

Member states stonewall EP tax probe

A probe by the European Parliament into tax abuse by big firms is being obstructed by member states

31

Agosto

2015

Denmark reveals €800m tax fraud – the country's biggest

Tax authority alerts police amid suspicion that foreign companies have defrauded its system over past three years

28

Agosto

2015

Bombay HC : Apply transfer pricing on Associate Enterprise only

In a breather to famed jewellery designer Nirav Modi promoted Firestone International, the Bombay High Court ruled that the transfer pricing addition should be considered only on international transactions with Associated Enterprise (AE) and not on entire turnover of the company.

26

Agosto

2015

YOUR TAXES: OECD tightens the ratchet

ISRAEL: Western governments asked the OECD to recommend ways of preventing offshore tax evasion committed by corporations and individuals. Over the last year the OECD has duly issued a string of reports addressing BEPS – base erosion and profit shifting.

26

Agosto

2015

Tax News Editorial: Country-By-Country Reporting

Taken together, these three documents will require taxpayers to articulate consistent transfer pricing positions, will provide tax administrations with information to assess transfer pricing risks, make determinations about where audit resources can most effectively be deployed, and, in the event audits are called for, provide information to commence and target audit inquiries.

21

Agosto

2015

India: Proposal to make arbitration mandatory under MAP dropped

India opposed the proposal saying it impinges on the sovereign rights of developing countries in taxation

20

Agosto

2015

Australia toughens its stance on tax havens

Joe Hockey, the Liberal party treasurer in the ruling coalition government, pledged to bring new legislation to go after companies that use offshore jurisdictions to cut their tax bills.

19

Agosto

2015

Cayman Islands: BEPS pivotal in fight over tax competition

There has been no decline in corporate tax revenues in recent years, and nations already possess a variety of tools to respond to erosion when needed. BEPS is thus drawing an inordinate amount of global attention and resources for apparently low expected returns. The only way to thus explain the project is to recognize that it represents a new front in the OECD’s long running war on tax competition.

18

Agosto

2015

Name and shame tax dodgers: report

Australia: An interim report from the Senate standing committee on economics, titled "You cannot tax what you cannot see", makes 17 recommendations, including that the government work with other countries with "marketing hub" activity to improve transparency.

18

Agosto

2015

Finance ministry proposes removing limit for transactions under control in transfer pricing

The Finance Ministry of Ukraine has proposed that the limit for transactions subject to control under transfer pricing rules should removed and will provide a simulation in the short presentation on tax reform that will be prepared by September.

14

Agosto

2015

Banks Should Fall Outside BEPS Work: IBFed

The regulatory environment surrounding the banking industry already constrains the behavior of banking groups in ways which obviate base erosion and profit shifting (BEPS) risks, the International Banking Federation (IBFed) said in a paper released on August 7.

14

Agosto

2015

Redefining tax residence of companies: a lever to tax more

As a consequence of POEM, certain potentially undesirable transfer pricing consequences may also ensue. Currently, different thresholds are set for international and domestic transfer pricing compliances. Regarding a foreign company as a tax resident in India (owing to it having a POEM in India) could lead to a greater or lower threshold or number of transactions being subject to Indian transfer pricing.

14

Agosto

2015

OECD publishes guidance on international standard for automatic exchange of tax information

A 'handbook' giving guidance on the new global standard for automatic exchange of financial account information and a guide to designing an offshore tax disclosure programme have been publishedby the Organisation for Economic Cooperation and Development (OECD). Look for it on our resources list.

14

Agosto

2015

Opinion: A defeat for international tax cooperation

An opinion by José Antonio Ocampo, a professor at Columbia University and Chair of the Independent Commission for the Reform of International Corporate Taxation that suggests that the momentum toward strengthening international tax cooperation came to an abrupt halt in the third International Conference on Financing for Development, held in Addis Ababa last month.

13

Agosto

2015

Civil society groups in Kenya push for laws to criminalise tax evasion

The civil society in Kenya wants Parliament to join them in the push to end tax evasion through enactment of laws that enhance compliance from international trade.

10

Agosto

2015

Laws on Tax Code Amendments signed in Ukraine

President of Ukraine Petro Poroshenko has signed laws on amendments to the Tax Code of Ukraine on transfer pricing (bill No. 1861), on reducing the tax burden on taxpayers, and on the taxation of non-profit organizations (No. 2049), Deputy Head of the Presidential Administration Dmytro Shymkiv said at a briefing in Kyiv.

10

Agosto

2015

Shell pumped $20 billion a year from motorists but paid no company tax

August 9, 2015 For the third year on the trot, Shell service stations generated billions of dollars and revenue but not a cent in company tax. In fact the owners of the sunny yellow servos reported tax benefits in all three years despite total sales which may be in excess of $60 billion.

10

Agosto

2015

India and the US have resolved 35 transfer pricing disputes in different segments of the information technology industry

A framework agreement was recently signed with the US under the Mutual Agreement Procedure (MAP) provision of the India-US Double Taxation Avoidance Convention (DTAC).

10

Agosto

2015

India has signed its first unilateral roll back Advance Pricing Agreement

India has signed its first unilateral roll back Advance Pricing Agreement (APA), bringing certainty to tax liability of a US-headquartered multinational company for a nine year period.

30

Julio

2015

Fiat accused of tax evasion by former CEO

The newest accusation in Australia about tax-avoidance is against the former head of Fiat Chrysler in that country, who is having to respond to allegations of misusing $30 million of company funds by engaging in illegal tax-avoidance. This claim will likely attract the attention of the ATO, which is trying to clamp down on tax avoidance by multinational companies.

30

Julio

2015

Fiat accused of tax evasion by former CEO

The newest accusation in Australia about tax-avoidance is against the former head of Fiat Chrysler in that country, who is having to respond to allegations of misusing $30 million of company funds by engaging in illegal tax-avoidance. This claim will likely attract the attention of the ATO, which is trying to clamp down on tax avoidance by multinational companies.

30

Julio

2015

Fiat accused of tax evasion by former CEO

The newest accusation in Australia about tax-avoidance is against the former head of Fiat Chrysler in that country, who is having to respond to allegations of misusing $30 million of company funds by engaging in illegal tax-avoidance. This claim will likely attract the attention of the ATO, which is trying to clamp down on tax avoidance by multinational companies.

30

Julio

2015

Taxpayer info to remain confidential: CIC

MUMBAI: The identity of taxpayers who opt for an advance pricing agreement (APA) in the field of transfer pricing will continue to remain confidential.

29

Julio

2015

Kenya's tax revenues rise to Sh1 trillion in 2014/15 fiscal year

Kenya collected 1.001 trillion shillings ($10 billion) in the fiscal year to end-June, a 3.86 percent increase from the previous year, the Treasury said on Wednesday.

28

Julio

2015

Transfer pricing is truly well regulated in SA (Opinion)

THERE has been a great deal of public commentary in SA over the past 18 months on the question of transfer pricing and illicit financial flows. This is not surprising. In the past several years, this challenge, which faces many countries, has been rigorously addressed by the United Nations (UN), the Organisation for Economic Co-operation and Development (OECD) and the Group of 20.

28

Julio

2015

Pharmaceutical companies accused of profit shifting not being taken to court

None of the pharmaceutical companies that are accused of profit shifting have been taken to court, the Australian Taxation Office has said in written responses to the Senate inquiry into corporate tax avoidance. Earlier in July executives from the largest global pharmaceutical companies operating in Australia were hauled before the inquiry.

27

Julio

2015

A revolving door between the regulators and the biggest firms in the business has caught the eyes of those calling for reform.

A revolving door between the regulators and the biggest firms in the business has caught the eyes of those calling for reform, including former Commonwealth Bank boss David Murray in his sweeping review of the financial system. The government's response to that review is due any day.

24

Julio

2015

U.S. Tax Avoidance Trumps Greek Tax Evasion

While the country struggles more than others to get its people to pay taxes, this isn’t a major contributing factor to the debt crisis. As is the case in most countries, in Greece, the majority of tax is collected from a minority of taxpayers – the very wealthy.

23

Julio

2015

Opinions of the Financing for Development conference in Addis Ababa

Some of the opinions of what happened in the Financing for Development conference in Addis Ababa point out that no significant measures were taken in the outcome document.

13

Julio

2015

Australia Warns MNCs Against Using Offshore Marketing Hubs To Reduce Tax Burden

The Australian Tax Authority warned multinational corporations they will deal seriously with profit-shifting. The ATO is concerned that the amount charged by some hubs (The ATO has identified them to be operating in Singapore and Switzerland) to the Australian companies is not what arm’s length or independent parties would pay.

25

Junio

2015

ICC welcomes new WCO Guide to Customs Valuation and Transfer Pricing

ICC has welcomed a new World Customs Organization’s (WCO) Guide to Customs Valuation and Transfer Pricing which includes ICC proposals for more coherent tax and customs revenue collection.

19

Junio

2015

EU to advance proposal for mandatory CCCTB, consults on public release of country-by-country data

The European Commission on June 17 said it is readying a proposal for an EU-wide common consolidated corporate tax base (CCCTB) that would be mandatory for multinationals.

18

Junio

2015

Shell warns on fallout from tax crackdown

Royal Dutch Shell has waded in on the avoidance debate and warned that tensions arising over a crackdown will have serious repercussions for industry

15

Junio

2015

Big Pharma's secret pricing tactics keep staff and ATO in the dark

Andrew Nicholl had a 25 year career as an executive in the pharmaceutical industry. He held senior leadership roles in Australia and overseas where he worked as a managing director in Taiwan, Venezuela and Hong Kong for three of the top five global pharmaceutical companies.

08

Junio

2015

OECD releases CbC Reporting Implementation Package

Pushing forward efforts to boost transparency in international tax matters, the OECD today released a package of measures for the implementation of a new Country-by-Country Reporting plan developed under the OECD/G20 BEPS Project.

06

Junio

2015

Mexican Tax Administration Service (SAT) has a new instrument for electronic audits

The new instrument the SAT relies on, the ONESOURCE platform, will be used to facilitate the audit of enterprises with foreign transactions and the agreement for its use is for the next five years.

02

Junio

2015

Pharmaceutical companies called on to explain tiny tax contribution

The five biggest suppliers of publicly subsidised medicines in Australia recorded sales of nearly $5 billion last year but paid an average of just $10 million each in company tax.

02

Junio

2015

BEPS Rears Its Head In Amazon European Tax Policy Shift

Amazon announced that it would change the way it accounts for revenue from retail sales in Europe. Under the new arrangement, Amazon will book all revenue from retail sales in individual countries in those countries, rather than routing the profits through Luxembourg, which has the lowest corporate tax rate in the European Union.