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April 26th, 2016
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The latest news

Amazon Wins $1.5 Billion Dispute With IRS
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March 25th, 2017
On March 23, Amazon won more than $1.5 billion tax dispute with the Internal Revenue Service (IRS) over transactions involving a Luxembourg unit.
Israel Investigates Local Activities of Tech Giants
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March 25th, 2017
The Israel Tax Authority is undertaking an assessment of the activity of Facebook and Google in Israel by collecting information from media companies and customers that work with the Tech Giants. The Tax Authority aims to obtain better understanding of the economic activity and operational methods of Facebook and Google in Israel.
OECD Publishes Report On Tax Certainty And Other Subjects
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March 21st, 2017
The OECD published an OECD Secretary-General Report to G20 Finance Ministers that consists of the latest developments in the international tax agenda and an IMF/OECD report for G20 finance ministers on tax certainty. The report also includes a Progress Report to the G20 by the Global Forum on Transparency and Exchange of Information for Tax Purposes.
G20 Finance Ministers Address Digitalization And Tax Certainty
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March 21st, 2017
G20 finance ministers and central bank governors met in Baden-Baden (Germany) and called on OECD and the IMF to assess progress in enhancing tax certainty in 2018 and to produce an interim report on the implications of digitalization for taxation by spring 2018. The ministers further addressed developments in the areas of BEPS and Beneficial Ownership Information.
Australian Treasurer Says Tech Giants Are Forced to Pay Tax
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March 21st, 2017
On March 21, Treasurer of Australia Scott Morrison told Parliament that the Australian Taxation Office managed to get Facebook, Google and other multinational companies to pay tax in Australia based on their Australian profits as ATO could use "the power, the resources and the penalties to get the job done."
Facebook And Google Changed Their Tax Arrangements
ATO Expects Seven Major Multinational Audits Soon
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March 17th, 2017
The Commissioner of Taxation, Chris Jordan, has delivered a speech reflecting on ATO's achievements. He informed that ATO observed positive changes in behavior from taxpayers and advisors, while notifying that at least seven major multinational audits are expected before July.
OECD Announces Further Developments
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March 17th, 2017
OECD announced further developments in international tax co-operation informing about six treaty partners of Hong Kong signing a competent authority agreement, the Global Forum monitoring the implementation of tax transparency standards and Panama depositing its instrument of ratification for the Convention on Mutual Administrative Assistance.
Hong Kong to Exchange Information
Views On UK Spring Budget
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March 15th, 2017
On March 8, Chancellor Philip Hammond delivered the Spring Budget addressing long-term economic stability, fiscal responsibility, lowering corporate tax rate and fair tax system, among other subjects. Various industry leaders have provided their view on the new measures.
Swiss Federal Council Approved Withholding Tax Changes
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March 15th, 2017
On 10 March, The Federal Council approved the changes to the Withholding Tax Ordinance in order to strengthen the financing activities of groups in Switzerland. The reforms will affect groups in which a Swiss group company provides a guarantee for a bond of a foreign group company.
Singapore To Exchange Information with Belgium and Luxembourg
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March 15th, 2017
On March 10, the Government of Singapore signed Agreements on the Automatic Exchange of Financial Account Information with Belgium and Luxembourg. Luxembourg's Finance Minister Pierre Gramegna pointed out "green finance", alternative investment funds and fintech as the areas to deepen the cooperation with Singapore, and stressed the importance of open financial centers.
EU Report: "The US Emerging as Tax and Secrecy Haven Leader"
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March 13th, 2017
The European Parliament’s Inquiry Committee into Money Laundering, Tax Evasion and Tax Avoidance (PANA) published in-depth analysis on EU-US trade and investment relations and their impact on tax evasion, money laundering and tax transparency. One day earlier, the PANA Committee also held its third and last public hearing on “the role of intermediaries in the Panama Papers”.
The Netherlands Informs About Information Exchange With Iceland
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March 13th, 2017
The Ministry of Finance in the Netherlands published the text of Memorandum of Understanding (MoU) between Iceland and the Netherlands regarding the exchange of information in tax matters.
Information Content
Save The Date - TPA Global VCA Workshop for Corporates
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March 9th, 2017
“Value Chain Analysis Workshop for Corporates in Amsterdam, Singapore and New York - The Bridge to Align the Operating Model, Corporate Governance Framework and the Tax/Transfer Pricing Structure of a MNE”
Due to globalization and increasing business complexities, management boards are experiencing difficulties in being in control of their operating model and transfer pricing model simultaneously. The key decision makers in an organization in practice appear sometimes wearing multiple hats in the decision-making process, making the organization not being in control.
OECD Global Forum on VAT Meets in April
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March 8th, 2017
The OECD released a draft agenda on the 4th meeting of the OECD Global Forum on VAT, which will take place on April 12-14. The meeting will focus on the policy and operational challenges faced by tax authorities and on the efficient and the effective implementation of the International VAT/GST Guidelines.
Malaysia Joins BEPS Inclusive Framework
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March 8th, 2017
The OECD announced that Malaysia has joined the “Inclusive Framework on BEPS." Malaysia commits to the BEPS Project to participate as a BEPS Associate of the OECD's Committee on Fiscal Affairs.
India - Advance Pricing Agreements Help Resolving TP Issues
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March 8th, 2017
For the first time, the government may end up resolving about 100 transfer pricing issues by signing advance pricing agreements (APAs) with multinationals this fiscal, people in the know said according to The Economic Times.
Background: APA Program
EU Collects Information On Member State Practices
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March 5th, 2017
The European Parliament's Committee on money laundering, tax avoidance and tax evasion (PANA) has updated the latest responses obtained from Member States on national definition, practices and methods related to tax evasion, tax avoidance and money laundering. The Parliament obtained 27 responses, awaiting the last reply from Malta.
The Australian Treasury Published Submission From DPT Consultation
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March 5th, 2017
The Australian Treasury published 21 submissions received on the exposure draft legislation for a Diverted Profits Tax (DPT), which was launched by the Australian Government on November 29.
Background: DPT
"UK Corporate Tax Cuts Likely To Fail"
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February 28th, 2017
Following the suggestions of Prime Minister Theresa May and Chancellor Philip Hammond to lower UK corporation tax, concerns were raised by JPMorgan saying that lowering corporate tax rate "would not come close to offsetting the shock of a very hard Brexit," and would only lower UK's corporate tax revenues.
Background
Singapore DTAs with India and Uruguay Enter Into Force
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February 28th, 2017
On February 27, the Inland Revenue Authority of Singapore informed that the Third Protocol amending DTA with India entered into force on February 27. The new DTA between Singapore and Uruguay will enter into force on March 14.
IRS Released Draft Instructions for Filing CbC Reports
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February 28th, 2017
The IRS published instructions for filing Form 8975 and accompanying the draft Schedule A (Country-by-Country Report) that apply to US multinational companies with more than $850 million in annual consolidated gross income.
Background: IRS Reports
BEPS Action 4: Policy Considerations and Implementation Status
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February 27th, 2017
This article addresses BEPS Action 4. The authors provide a historical perspective of the relevant BEPS and EU measures, explain the highlights of BEPS Action 4, discuss the overlap between the different Actions, update readers on countryspecific implementation of BEPS Action 4, summarize existing case law in the area, present practical examples dealing with the impact of Action 4 on certain structures and, finally, provide concluding remarks.
TPA Global Top-10 Solutions: "Are You 'In-Control' of Tax and Transfer Pricing?"
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February 27th, 2017
As G20 countries have become increasingly aggressive in their aim to combat corporate tax avoidance, full tax transparency is the new norm. The global tax and transfer pricing (“TP”) compliance has become more strict and complex due to new documentation requirements.
Adoption of the CUP Method for Commodity Transactions in new Colombian Tax Law
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February 24th, 2017
The recent tax reform -issued by Law 1819 of December 29/2016- introduced some changes in international tax law and transfer pricing rules. Relevant changes were adopted to introduce CbC report, adopt CFC legislation and define a legal framework regarding preferential tax regimes and beneficial owner to control base erosion and prevent tax deferral (see BEPS Action 5).
Irish Department of Finance Seeks Feedback On Corporate Tax Code
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February 24th, 2017
The Irish Department of Finance released public consultation paper seeking public feedback in connection with a review of Ireland’s Corporation Tax Code. The Government appointed an independent expert, University College Cork economist Seamus Coffey, to review Ireland's corporate tax code using the information collected during the public consultation.
ATO Publishes Simplified TP Record Keeping Options
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February 24th, 2017
On February 22, the Australian Taxation Office (ATO) released Practical Compliance Guideline outlining simplified transfer pricing record-keeping options intended to minimize the record-keeping for eligible taxpayers.
Purpose of the Guidelines
Meet us at the International Job Fair Maastricht, the Netherlands
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February 22nd, 2017
Work @ TPA Global will be represented at The International Job Fair on Thursday the 23rd of February at Castle Vaeshartelt, Maastricht, The Netherlands.
During this day we will be giving various presentations, which would be the perfect opportunity to get to know us better.
The EU Commission Agrees on Hybrid Mismatch Rules
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February 22nd, 2017
On February 21, the European Commission welcomed the agreement reached on hybrid mismatches with regard to non-EU countries. A day earlier, the Council of the European Union has released two documents addressing the general approach and presidency compromise with respect to hybrid mismatches with third countries.
UAE: DTA With Lichtenstein And TIEA With Norway Enter Into Force
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February 22nd, 2017
The Agreement between the United Arab Emirates (UAE) and Liechtenstein for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital enters into force on February 24, 2017. The agreement between the UAE and Norway for the exchange of information relating to tax matters (TIEA) entered into force on February 15, 2017.
"EU made fundamental errors in State Aid Decision"
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February 22nd, 2017
On February 20, the EU published arguments of Apple’s appeal against the EU Commission’s State Aid Decision of August 30, 2016, in which the Commission concluded that Ireland gave illegal tax benefits to Apple worth 13 billion Euro. The tech giant says EU made fundamental errors in interpreting the way in which Apple generated its profits.
“We Talk Business” - TPA Global Announces New Global Service
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February 21st, 2017
Quick and professional advice is now just one click away!
Tired of going through pages after pages of regulations without knowing how they affect your company in practice? Spending hours trying to figure out which of the multitude of services offered by consultancy firms are best suited to your needs? Then book an hour of face-to-face communication with a TPA Global professional and receive an immediate answer to your question(s) today!
EU's Financial Transaction Tax under Siege
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February 17th, 2017
Responding to recent news suggesting that the Financial Transaction Tax (FTT) has lost the support of Belgium and Slovakia (who are concerned over its impact on pension funds), Deputy Laurent Mosar of Luxembourg’s Christian Social People's Party (CSV) called on Luxembourg Finance Minister Pierre Gramegna to clarify the situation.
Background: FTT
Irish Minister of Finance Addresses Corporate Tax
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February 17th, 2017
During the Plenary Session on February 16, Irish Minister for Finance Michael Noonan addressed the recent development of international taxation and problems with aggressive tax practices. Minister praised OECD BEPS project, but warned against the EU efforts that deviate from BEPS recommendations.
TPA Global Forms Alliance With SILC Global, The Netherlands
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February 16th, 2017
TPA Global, leading independent provider of global transfer pricing and valuation services, is pleased to announce that it has entered into an alliance with SILC Global, an independent consultancy firm based in Amsterdam, the Netherlands.
SILC Global is recognized as a leading independent consultancy firm in Europe, based in Amsterdam.
Transfer Pricing On Mining With A Focus On Africa - A Reference Guide For Practitioners
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February 16th, 2017
Amsterdam, 16 February 2017
This book presents the results of a study on transfer pricing (TP) with specific focus on mining in Africa commissioned in 2014 by the World Bank Group (WBG) in partnership with the International Mining for Development Centre (IM4DC). It sets a standard of reference for all tax practitioners in the mining industry dealing with transfer pricing.
Sharing Ideas And Experiences with Cross-border Dispute Settlement
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February 15th, 2017
Many tax treaties offer the possibility of resolving tax disputes through a Mutual Agreement Procedure (MAP). An increasing number of cross-border tax disputes and new international initiatives, however, ask for considering alternative ways of dispute settlement such as arbitration.
Swiss Voters Reject Corporate Tax Reform In Referendum
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February 15th, 2017
On February 12, Swiss voters blocked the government’s attempts to reform its corporate tax regime by abolishing ultra-low tax rates for multinational companies. Almost 60 percent of voters refused the plans that political and business elite embraced under international pressure.
EU PANA Committee Meets Lawyers, Accountants and Bankers
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February 15th, 2017
During the PANA meeting held on February 9, the committee held a second session on "The role of lawyers, accountants and bankers in Panama Papers", addressing the Scandinavian and German practice. In addition, insights from EU Member States regarding their country specific tax-related crime practices were published.
Australian Government Opens Consultation on Beneficial Ownership Register
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February 15th, 2017
The Australian Government invited interested stakeholders to share their views on the government's plan to establish the Beneficial Ownership Register. The government is seeking views on the details, scope and implementation of a beneficial ownership register for companies.
TPA Global Forms Alliance With GAW Consultancy, The Netherlands
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February 14th, 2017
GAW Consultancy is an innovative and leading independent Customs & Trade Compliance firm located in the EU. Having successfully managed and implemented projects for various different customers throughout the past five years, it is through this acquired diversified level of expertise which allows us to fully understand and meet the customer’s requirements from both a strategic and operational level.
A Simplified Guide to Increasing your Chances of Survival in Battles with Tax Authorities
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February 14th, 2017
Multinational enterprises (MNEs) have been facing disputes on tax and/or transfer pricing with tax authorities since their very inception. In light of the Base Erosion and Profit Shifting (BEPS) Action Plan of the OECD and the many UN initiatives to set new norms for tax and transfer pricing, many tax authorities around the globe will use the grey areas in these plans to challenge as many tax structures as they can, sometimes leading to nothing more than pure aggressive behavior.
Mining Industry Solutions
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February 13th, 2017
The mining industry is facing unprecedented pressures due to lack of market stability and major developments in regulations. At the same time G20 countries have become increasingly aggressive in their aim to combat corporate tax avoidance, imposing much more strict global tax compliance and new complex documentation requirements.
Introducing TPA Global's Greater China Practice
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February 13th, 2017
As a means to best serve our multinational clients operating in China as well as Chinese outbound “Go Out” companies to overseas, we are sending this email to inform you that TPA Global has recently reorganized its Greater China practice.
The new Greater China practice orchestrates all service areas of TPA Global through an experienced and multilingual team of professionals that possess the know-how and resources needed to perform engagements of all sizes.
EU Council Releases Presidency Draft Roadmap on BEPS
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February 11th, 2017
The European Council released a Draft EU-BEPS Roadmap by the Maltese Presidency of the Council setting out future work in the coming months. The roadmap addresses subjects such as hybrid mismatches, dispute resolution mechanism, the list of non-cooperative jurisdictions, renewed CCCTB, Patent Boxes, Code of Conduct (Business Taxation) and the Mandatory Disclosure rules.
Australian Proposal Diverted Profits Tax Bill 2017
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February 11th, 2017
The Australian Government introduced a proposal into the Australian Parliament for legislation to implement a new Diverted Profits Tax (DPT). This measure will apply in relation to tax benefits for an income year that starts on or after July 1, 2017.
Value Chain Analysis – the bridge between operating, governance and tax/TP models of an MNE
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February 9th, 2017
Value Chain Analysis has become a burning topic for discussion for many after the publication of the final report on BEPS Action Plan 13 and subsequent notifications by governments (especially the Chinese government) on the extent of information to be included in such analysis. Due to lack of consistent and clear guidance on what triggers the need for a value chain analysis, what a value chain analysis should entail, how the value chain analysis will be used by tax authorities around the globe etc.
TP Alert in Indonesia
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February 7th, 2017
As tax administrations and international economic organizations reach consensus for implementing international measures that will promote tax transparency amongst the business community, uncertainties rise around the scope and extent of some of the action points proposed to drive tax transparency between jurisdictions. For example, the implementation of Action plan 13.
Ireland's Appeal In The Apple State Aid Case Is Published
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February 7th, 2017
On February 6, the Irish government’s summary of legal proceedings was published in the Official Journal of the European Union. Just one week earlier, Irish Finance Minister Michael Noonan criticized the European Commission's decision at an EU meeting.
Britain’s Overseas Territories Meet To Discuss Brexit
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February 7th, 2017
On February 7, ministers of Britain’s overseas territories met with U.K.
India And Austria Amend DTA
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February 7th, 2017
On February 6, India and Austria signed the protocol for avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Background
Japan and Austria Sign New DTA
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February 3rd, 2017
The Japan and Austria signed the Convention for the Elimination of Double Taxation with respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance.
Background
EU To Contact US Administration Over Tax Haven Blacklist
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February 3rd, 2017
The United States appeared on the EU draft list of countries perceived as potential tax havens according to the list obtained by Handelsblatt Global. To make the final list of non-cooperative jurisdictions by the end of 2017, American and other tax authorities will be contacted this week by the European Union to clarify certain taxation policy.
A Career @ TPA Global
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February 3rd, 2017
TPA Global provides international businesses with integrated and value-added solutions in improving financial performance, operational efficiency, strategic development, talent coaching and tax / transfer. TPA Global identifies the right solutions for customers and targets; efficient and streamlined advisory and implementation processes which cut through operational complexities across functions and borders.
OECD Invites Multinationals For Feedback On MAP Peer Reviews
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January 31st, 2017
On January 30, OECD invited multinationals to provide input on the Mutual Agreement Procedure (MAP) peer review and monitoring process, which was launched in December 2016 under Action 14 of the BEPS Action Plan. At this stage, OECD gathers input on Austria, France, Germany, Italy, Liechtenstein, Luxembourg and Sweden.
USA - GAO Analyzed Potential Impact of BEPS
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January 31st, 2017
On January 27, the Government Accountability Office published a report that examines the potential impact of the OECD BEPS initiative’s revised international transfer pricing guidance on both the IRS and U.S.
ATO Publishes Tax Risk Governance Review Guide
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January 31st, 2017
The Australian Taxation Office (ATO) published a tax risk management and governance review guide that sets out principles for board-level and managerial-level responsibilities and provides examples of design and operational effectiveness of control framework for tax risk.
Background
Financial Services Industry Solutions
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January 31st, 2017
The financial services industry is facing unprecedented pressures due to lack of market stability and extensive development of new technologies. At the same time G20 countries have become increasingly aggressive in their aim to combat corporate tax avoidance, imposing much more strict global tax compliance and new complex documentation requirements.
Pharmaceutical Industry Solutions
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January 31st, 2017
The pharmaceutical industry is facing unprecedented pressures due to lack of market stability and major developments in regulations. At the same time G20 countries have become increasingly aggressive in their aim to combat corporate tax avoidance, imposing much more strict global tax compliance and new complex documentation requirements.
TPA Global Forms Alliance With CrossTax, The Netherlands
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January 30th, 2017
TPA Global, leading independent provider of global transfer pricing and valuation services, is pleased to announce that it has entered into an alliance with CrossTax, an independent tax advisory firm in the Netherlands.
CrossTax is recognized as a leading independent professional service firm dedicated to serving companies and individuals, both Dutch and foreign based, in optimising their cross-border transactions and activities from a tax and legal point of view.
Seven More Jurisdictions Join The Automatic Sharing of CbC Reporting
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January 27th, 2017
On January 27, the OECD informed that Gabon, Hungary, Indonesia, Lithuania, Malta, Mauritius and the Russian Federation have now signed the Multilateral Competent Authority Agreement for Country-by-Country Reporting (CbC MCAA), bringing the total number of signatories to 57.
Background: CbC Reporting for Tax Transparency
Panama Papers - EU PANA Committee Meets to Discuss Tax Avoidance and Evasion
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January 27th, 2017
On January 24 and 26, the Inquiry Committee on the Panama Papers (PANA) held meetings addressing "The role of lawyers, accountants and bankers in Panama Papers" and the "Report on the inquiry into Money Laundering, Tax Avoidance and Tax Evasion". The recordings of the meetings have been published for the public.
Draft Toolkit On The Lack Of Comparables Released For Comments
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January 27th, 2017
On January 24, 2017 the so-called Platform for Collaboration on Tax (a joint initiative of the IMF, OECD, UN and World Bank Group) published a Discussion Draft on the Toolkit for Addressing Difficulties in Accessing Comparables Data for Transfer Pricing Analyses, which addresses the ways developing countries can overcome a lack of data on "comparables."
Background
Valuation Services after BEPS
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January 24th, 2017
Apart from being a crucial tool for businesses for placing a value on their business to be used in case of sale of a business, partnership dissolution, mergers and acquisitions, loan/financing arrangements, the importance and need for valuation has been further strengthened by the OECD under BEPS Action Plans 8 – 10 by stating that valuation techniques may be used as a part of one of the five OECD approved transfer pricing methods. In situations where reliable comparable uncontrolled transactions for a transfer of one or more intangibles cannot be identified, it may also be possible to use valuation techniques to estimate the arm’s length price for intangibles transferred between associated enterprises.
VCA – A Bridge To Align Operating And Governance Models With Tax/TP Set-up
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January 24th, 2017
The value chain 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. While a functional and risk analysis is geared to individual group companies, a value chain analysis applies on crosscompany processes within the Group.
Representation before tax authorities and Courts
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January 24th, 2017
Multinational enterprises (MNEs) have been facing disputes on tax and/or transfer pricing with tax authorities since their very inception. Over the course of time, a wide variety of instruments have been developed in order to address these disputes.
Oil & Gas Industry Solutions
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January 24th, 2017
The oil & gas industry is facing unprecedented pressures due to lack of market stability and major developments in regulations. At the same time G20 countries have become increasingly aggressive in their aim to combat corporate tax avoidance, imposing much more strict global tax compliance and new complex documentation requirements.
IRS Released A New Withholding Agreement And CbC Filing Guidance
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January 23rd, 2017
US IRS released an updated withholding foreign partnership agreement (WP agreement) and a withholding foreign trust agreement (WT agreement). The IRS also published an advance version of the Revenue Procedure 2017-23 addressing the process for filing the Country-by-Country (CbC) Report and other related documentation by ultimate parent entities of U.
EFTA Provides Guidelines On State Aid
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January 23rd, 2017
The EFTA Surveillance Authority (ESA) has adopted new guidelines on when a public measure does or does not involve state aid. The guidelines correspond to similar guidance adopted by the European Commission.
Britain to Leave EU Single Market
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January 20th, 2017
British Prime Minister Theresa confirmed that Britain will leave the EU single market, but will seek to establish a favorable free trade agreement. She stressed that the government is ready to take tax breaks to stay competitive if the EU would insist on punitive tariffs.
ATO Publishes TP Guidelines for Offshore Hubs
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January 20th, 2017
ATO published Practical Compliance Guideline PCG 2017/1 that addresses transfer pricing issues related to centralized operating models involving procurement, marketing, sales and distribution functions.
Centralized Operating Models
US IRS Issue Tax Regulations On Disregarded Stock In Inversions
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January 18th, 2017
On January 18, the IRS has published final tax regulations and guidance on disregarded stock in inversions designed to fight tax avoidance associated with the inversion. The IRS also requests comments on proposed rulemaking by cross-reference to temporary regulations on Inversions and Related Transactions.
Trump Refuses Republican Border Adjustment Tax Reform
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January 18th, 2017
US President-elect Donald Trump has criticized the border adjustment provision, a feature of the House Republicans' corporate-tax plan, during an interview on January 16.
Border Adjustment
Belarus and Hong Kong Conclude DTA
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January 18th, 2017
On January 16, Hong Kong and Belarus signed a comprehensive agreement for the avoidance of double taxation (CDTA) to eliminate double taxation with respect to taxes on income and on capital.
Allocation of taxing rights
Juncker Blocked Secretly EU's Anti Tax Avoidance Efforts
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January 11th, 2017
European Commission President Jean-Claude Juncker faces renewed pressure as the leaked documents show he secretly blocked EU efforts to tackle tax avoidance by multinational companies during his time as Luxembourg's Prime Minister.
Background
India - Portfolio Investors Shifting Base to Europe
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January 11th, 2017
Due to amended tax treaties with Singapore, Mauritius and Cyprus, Foreign Portfolio Investors (FPIs) are looking to shift their base to European jurisdictions such as France, Spain and the Netherlands, the Economic Times reported.
Tax Treaties
HMRC Releases Criminal Case Highlights of 2016
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January 11th, 2017
On January 7, the HM Revenue and Customs revealed its top ten most significant fraud and organized crime cases of the last year, together with other statistics from 2016.
2016 Overview
Argentina Succeeds With Tax Amnesty Programme
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January 11th, 2017
Argentinean Government announced that the country declared $97.842 billion in assets by the completion of a second phase of a broad tax amnesty programme that ended on December 31, 2016.
Global Tax Compliance Solutions For MNEs
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January 9th, 2017
With the increasing regulatory requirements, the globalization has brought its own challenges with respect to global tax compliance to multinational enterprises (“MNEs”). The answer to ‘growing tax related complexities’ in today’s world is the implementation of automated software solutions, in order to tackle the increased tax compliance burden in a timely, cost effective and efficient manner.
Colombia's New Anti Tax Evasion Law Not Enough
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January 9th, 2017
Colombia's newly approved tax reform law that imposes higher penalties for tax evasion will still fail to tackle tax evasion according to chief prosecutor. Néstor Humberto Martínez wrote a letter to the Minister of Finance earlier in January, criticizing the insufficient measures.
US Signs FATCA With Belgium And Taiwan
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January 6th, 2017
US Treasury Department informed that it has signed Model 1 FATCA intergovernmental agreement (IGA) with Belgium and a Model 2 FATCA intergovernmental agreement (IGA) with Taiwan.
Background: FATCA
India and Kazakhstan Amend Existing DTA
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January 6th, 2017
On January 6, The Central Board of Direct Taxation (CBDT) announced that India and Kazakhstan have signed a protocol to amend the existing Double Taxation Avoidance Agreement.
Amended DTA in line with BEPS
EU Commission Publishes New State Aid Investigation
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January 6th, 2017
On January 5, the EU Commission published the non-confidential version of the decision to open an in-depth investigation into Luxembourg's tax treatment of GDF Suez (now Engie) that is believed to be in breach of EU state aid rules.
Opening an In-Depth Investigation
Cyprus calls for notification from MNEs with regards to Country-by-Country reporting
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January 6th, 2017
On December 30, 2016, the Ministry of Finance in Cyprus published a Decree regarding country-by-country reporting for multinational enterprises.
Country-by-Country Reporting
Application Of New Rules Regarding The Mandatory Exchange Of Information On Cross-Border Rulings
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January 4th, 2017
As of 1 January 2017 EU Member States are required to apply the automatic exchange of information on all new cross-border tax rulings that they release.
Application of Council Directive
Peru - "Sixth Method" provisions are being replaced by other approach that seems more in line with Arm´s Length Principles
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January 3rd, 2017
On Saturday, December 31, 2016 Government published Legislative Decree 1312, in the Official Gazette Decree that modifying parts of the Income Tax, particularly related to Transfer Pricing:
Amends in paragraph 1 of point e) article 32-A of the Income Tax Law. Basically most of the "Sixth Method" provisions are being replaced by other approach that seems more in line with Arm´s Length Principles.
German Federal Council Adopts BEPS Legislation
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December 20th, 2016
The German Federal Council approved Country-by-Country Reporting and other BEPS related measures. These were approved by the Federal Parliament earlier on December 2 after several months of discussions on the approval of specific measures.
EU Commission Publishes The Apple Case Decision
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December 20th, 2016
The EU Commission has published the non-confidential version of the final negative decision adopted on 30 August 2016 concluding that Ireland gave illegal tax benefits to Apple, worth up to €13 billion.
Background
IRS And Treasury Officials Meet at International Tax Conference
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December 19th, 2016
At the 29th Annual Institute on Current Issues in International Taxation, held on December 15-16, IRS and Treasury officials discussed recently released regulations on outbound transfers of goodwill, pending EU State aid cases and other related subjects.
Recently Released Documents
Malta Issues Guidance On Mutual Agreement Procedure
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December 19th, 2016
The Commissioner for Revenue has published guidance issued under the provisions of Article 96(2) of the Income Tax Act on the use of Mutual Agreement Procedure (MAP).
Mutual Agreement Procedure (MAP)
US Tax - President-Elect Trump Meets Top US Multinationals
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December 16th, 2016
On December 14, top executives of US Multinationals including Amazon, Facebook, Google, IBM, Apple and Tesla met with president-elect Donald Trump at Trump Tower in Manhattan to discuss country's taxation system and tax cuts among other topics such as creation of jobs or country's global competitiveness.
Invited Executives
New Zealand To Update TP And Permanent Establishment Measures
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December 16th, 2016
On December 14, the Minister of Revenue Michael Woodhouse has released information on BEPS measures being considered by the Government that would strengthen the transfer pricing and permanent establishment rules to address base erosion and profit shifting (BEPS).
Background
The Netherlands - Tax Treaty 2017 Update
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December 14th, 2016
On December 12, the Dutch Ministry of Finance issued a press release informing about its 2017 tax treaty negotiations agenda. The country will start tax treaty negotiations with with Andorra, Liechtenstein and Panama, and continue with other already initiated negotiations.
UK Publishes Draft Guidance on Hybrid Mismatch
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December 14th, 2016
On December 9, The HM Revenue & Customs published draft tax guidance to assist understanding of the application of the hybrids mismatch legislation that comes into effect on January 1, 2017. The HMRC seeks comments on the draft guidance on the hybrids mismatch legislation.
France Rejects Public Country-by-Country Reporting
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December 14th, 2016
On December 9, France’s Constitutional Council rejected public country-by-country reporting as it violated the freedom of enterprise guaranteed under the French Constitution.
Background: CbC Reporting in France
EU Council Adopts New Directives At ECOFIN Meeting
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December 8th, 2016
On December 6, during the ECOFIN meeting the Council of the EU adopted directive granting access for tax authorities to beneficial ownership information. The Council also achieved consensus on a 'hybrid mismatches' draft directive with regards to third countries.
BRICS Countries Enhance Tax Cooperation
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December 8th, 2016
On December 5-6, BRICS Heads of Revenue and Experts on Tax Matters held a meeting in Mumbai during which they enhanced their mutual cooperation in international taxation and their efforts to combat BEPS. The countries reaffirmed their support for the automatic exchange of information and will begin exchanging by 2018 at the latest.
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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'
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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)
; posted on
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
; posted on
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"
; posted on
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)
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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)
; posted on
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
; posted on
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!
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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)
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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?
; posted on
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
; posted on
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
; posted on
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
; 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
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
; posted on
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
; posted on
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)
; 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
Irish - Ethiopian DTA Entered Into Force
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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?
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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)
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
The latest news

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