Int'l Tax News
Posted on
Brexit: Paving the Way for Greater European Tax Harmonization?
Harmonization lies at the core of many of the European Union's governing principles: could Brexit be the catalyst for greater harmonization among the remaining Member States?
This article explores recent attempts at European harmonization, assessing Franco-German drives for closer cooperation and integration on tax; analyzing the European Commission's latest re-launch of the common consolidated corporate tax base ("CCCTB"); and looking atwhether the U.K.'s decision to leave the European Union ("EU")will be a catalyst for greater EU harmonization among the remaining Member States.
This article explores recent attempts at European harmonization, assessing Franco-German drives for closer cooperation and integration on tax; analyzing the European Commission's latest re-launch of the common consolidated corporate tax base ("CCCTB"); and looking atwhether the U.K.'s decision to leave the European Union ("EU")will be a catalyst for greater EU harmonization among the remaining Member States.
To read more go here
Posted on
Tax Certainty Now on G-20 Radar for Follow-Up Work, OECD Tax Chief Says
G-20 finance ministers have responded favorably to the OECD and IMF's joint report on tax certainty, according to the OECD's tax chief,who added that the OECDwill engagewith countries bilaterally to discuss the results of the business survey onwhich the report is based.
To read more go here Subscription Required
Posted on
European Banks Book $27 Billion Profit in Tax Havens, Oxfam Says
Europe's largest banks routed 25 billion euros ($27 billion) through tax havens in 2015, about a quarter of their profit, amid an international crackdown on corporate tax avoidance, according to a report by Oxfam International.
The 20 biggest lenders paid no tax on 383 million euros of profit posted in seven tax havens that year,while booking 4.9 billion euros of earnings in Luxembourg, more than the U.K., Sweden and Germany combined, Oxfam and the Fair Finance Guide International said Monday. The studywas based on data released under new European Union regulations requiring banks to report earnings on a country-by-country basis.
The 20 biggest lenders paid no tax on 383 million euros of profit posted in seven tax havens that year,while booking 4.9 billion euros of earnings in Luxembourg, more than the U.K., Sweden and Germany combined, Oxfam and the Fair Finance Guide International said Monday. The studywas based on data released under new European Union regulations requiring banks to report earnings on a country-by-country basis.
To read more go here
Posted on
EU Panama Papers Probe Head: U.S. Tax Loopholes Must Be Closed
The European Parliament's special Panama Papers investigative committee concluded its four-day "fact-finding" visit to the U.S.with its chairman calling on the U.S. to close its tax loopholes.
In a March 24 telephone interview at the conclusion of the U.S. visit, the committee's chairman, German lawmakerwerner Langen, told Bloomberg BNA that EU members "have made appeals to the U.S. federal government and Delaware that there needs to be a clampdown on anonymity by introducing beneficial ownership registers."
In a March 24 telephone interview at the conclusion of the U.S. visit, the committee's chairman, German lawmakerwerner Langen, told Bloomberg BNA that EU members "have made appeals to the U.S. federal government and Delaware that there needs to be a clampdown on anonymity by introducing beneficial ownership registers."
To read more go here
Posted on
Special Tax Zones and the WTO
Since the SCM agreementwas enacted in 1995, the global leadership in the field of STZs has shifted from the OECD to thewTO.
ThewTO general agreement includes a broad set of policy goals that goes beyond trade relationships, but its legal framework has been systematically narrowed to the task of assuring market access, non-discrimination, and fairness in trade. Other relevant issues that has impacts on trade, such as for example harmful tax competition or tax base erosion, has not been sufficientlyweighted and has been treated as secondary items.
ThewTO general agreement includes a broad set of policy goals that goes beyond trade relationships, but its legal framework has been systematically narrowed to the task of assuring market access, non-discrimination, and fairness in trade. Other relevant issues that has impacts on trade, such as for example harmful tax competition or tax base erosion, has not been sufficientlyweighted and has been treated as secondary items.
To read more go here
Posted on
A Global Treaty Override? The New OECD Multilateral Tax Instrument and Its Limits
The new OECD Multilateral Instrument to amend tax treaties (MLI) is an important innovation in international law. Hitherto, international economic lawwas built primarily on bilateral treaties (e.g., tax treaties and BITs) or multilateral treaties (thewTO agreements). The problem is that in some areas, like tax and investment, multilateral treaties proved hard to negotiate, but only a multilateral treaty can be amended simultaneously by all its signatories.
To read more go here
Posted on
Analysis of tax developments worldwide - March 2017 edition
International Tax News is designed to help multinational organisations keep upwith the constant flow of international tax developmentsworldwide. Among the topics featured in this month's edition are:
- Israeli budget reduces corporate tax rates and expands corporate tax incentives
- Portugal's 2017 state budget law
- Further increase of the Austrian research premium
- The US IRS Rev. Proc. 2017-23, Process for filing form 8975, country by country report
- Israeli budget reduces corporate tax rates and expands corporate tax incentives
- Portugal's 2017 state budget law
- Further increase of the Austrian research premium
- The US IRS Rev. Proc. 2017-23, Process for filing form 8975, country by country report
To read more go here
Posted on
$500 Billion Lost to Profit Shifting Worldwide, TJN Says
Profit shifting by multinational companies moving funds out of higher-tax jurisdictions is taking $500 billion a year out of tax coffers globally, according to figures released by the Tax Justice Network (TJN) March 22.
The biggest dollar losses are in the United States, but multinationals' tax avoidance strategies have an especially high impact on theworld's poorest countries because their economies are smaller and the revenue lost is a much larger percentage of both the GDP and the total amount of tax revenue, according to the TJN report issued March 22.
The biggest dollar losses are in the United States, but multinationals' tax avoidance strategies have an especially high impact on theworld's poorest countries because their economies are smaller and the revenue lost is a much larger percentage of both the GDP and the total amount of tax revenue, according to the TJN report issued March 22.
To read more go here Subscription Required
Posted on
How to Create a Winning Game Plan for International Taxation
A complex matrix of treaties and multi-country agreements govern international trade. Similarly, there's no single international law governing international taxation.with no global authority to set aworldwide standard, each country is free to set its own standards. The resulting patchwork of national rules and regulations makes international tax planning and compliance more than a little complicated. Companies must carefully structure operations and define a strategy for each country in order to maximize legal tax advantages.
To read more go here
Posted on
EU Lawmakers Visit IRS, Delaware as Tax Haven Concerns Mount
The European Parliament's Panama Papers investigative committee is preparing for a "fact-finding" visitwith counterparts in the U.S. Congress, aswell as officials from the Treasury Department and Internal Revenue Service.
The European Union lawmakers' four-day U.S. trip,which begins March 21,will include a visit to Delaware for meetingswith representatives of the state Legislature and members of the Delaware departments of finance and state, to probe issues such as bank account maintenance and company beneficial ownership rules.
The European Union lawmakers' four-day U.S. trip,which begins March 21,will include a visit to Delaware for meetingswith representatives of the state Legislature and members of the Delaware departments of finance and state, to probe issues such as bank account maintenance and company beneficial ownership rules.
To read more go here
Posted on
Indonesia tax amnesty nets $330 billion - now for reform
Southeast Asia's biggest economy this month iswinding up one ofworld's most successful tax amnesties,with at least 745,000 taxpayers declaring more than $330 billion of assets so far.
President Jokowidodo has cited higher tax revenue as the key to boosting infrastructure spending and growth. But if the amnesty is to avoid being just a one-offwindfall, Indonesia needs to improve a tax collection ratiowell below many of its peers, international agencies and local officials have said.
President Jokowidodo has cited higher tax revenue as the key to boosting infrastructure spending and growth. But if the amnesty is to avoid being just a one-offwindfall, Indonesia needs to improve a tax collection ratiowell below many of its peers, international agencies and local officials have said.
To read more go here
Posted on
EU Council Lawyers Raise Concerns Over Reverse-Charge Mechanism Proposal
The European Commission, during a March 21 meeting of the Economic and Financial Affairs Council, advised member states to suspend technical talks on criteria to allow the application of a general reverse charge mechanism until the lawyers of the EU Council clarify some aspects of the draft plans.
To read more go here Subscription Required
Posted on
OECD/IMF report on tax certainty
This report explores the nature of tax uncertainty, its main sources and effects on business decisions and outlines a set of concrete and practical approaches to help policymakers and tax administrations shape a more certain tax environment.
To read more go here
Posted on
Hammond Says U.K. Spending Cuts Possible to Offset Tax U-Turn
U.K. Chancellor of the Exchequer Philip Hammond suggested he may have to make spending cuts in his autumn budget to fill the gap in public finances createdwhen hewas forced to scrap his plan to raise insurance taxes for the self-employed.
Hammond,whowas lambasted by many in his own party for seeking a tax change viewed as a breach of the Conservative manifesto, told reporters at the G-20 finance ministers meeting in Baden-Baden, Germany, that the money pledged to education reform, social care and business tax reliefwould have be found elsewhere. Taxes covered by the Tory Party's tax lockwould not be touched, he added.
Hammond,whowas lambasted by many in his own party for seeking a tax change viewed as a breach of the Conservative manifesto, told reporters at the G-20 finance ministers meeting in Baden-Baden, Germany, that the money pledged to education reform, social care and business tax reliefwould have be found elsewhere. Taxes covered by the Tory Party's tax lockwould not be touched, he added.
To read more go here
Posted on
Spain's Inditex Sets Retailer Trend in Brushing Off Border Tax
Whetherwith cropped jeans or cropped tops, following global fashion trends is an important part of the business model for Inditex SA, theworld's largest clothing manufacturer and retailer by market capitalization.
On tax matters, however, the Arteixo, Spain-based company has broken the trend of retailerswith U.S. operationswarning about the Republican Party's border-adjustment tax plan.
On tax matters, however, the Arteixo, Spain-based company has broken the trend of retailerswith U.S. operationswarning about the Republican Party's border-adjustment tax plan.
To read more go here Subscription Required
Posted on
Germany Pushes Back on Border-Adjustable Tax Proposal
Germany is pushing back forcefully against a House proposal for a border adjustability tax,with German Federal Finance Ministerwolfgang Schäuble arguing against the proposal.
Speakingwith reporters March 15, Schäuble contended that the U.S. could not "unilaterally" impose a border-adjustable tax. "Iwould not advise it," he said.
Speakingwith reporters March 15, Schäuble contended that the U.S. could not "unilaterally" impose a border-adjustable tax. "Iwould not advise it," he said.
To read more go here Subscription Required
Posted on
OECD Official Previews Upcoming Guidance
Grace Perez-Navarro, deputy director of the OECD Centre for Tax Policy and Administration, hinted March 9 atwhat to expect from upcoming guidance regarding the OECD's base erosion and profit-shifting project -- particularly on profit splits and profit attribution to a permanent establishment.
During a panel discussion of BEPS actions 7-10 at the Pacific Rim Tax Institute in Redwood City, California, Perez-Navarro said thatwhile she doesn't expect dramatic changes in the upcoming draft on profit splits, therewill be further clarification onwhen they are the most appropriate method, and more examples. The new draftwill describe not onlywhen profit splits should be applied, but also how they should be applied, Perez-Navarro said.
During a panel discussion of BEPS actions 7-10 at the Pacific Rim Tax Institute in Redwood City, California, Perez-Navarro said thatwhile she doesn't expect dramatic changes in the upcoming draft on profit splits, therewill be further clarification onwhen they are the most appropriate method, and more examples. The new draftwill describe not onlywhen profit splits should be applied, but also how they should be applied, Perez-Navarro said.
To read more go here Subscription Required
Posted on
U.S. tax reform plan could have currency spillover effect: IMF's Obstfeld
A proposal to overhaul the U.S. tax code that favors exports over imports could have spillover effects to other economies as itwould strengthen the dollar, International Monetary Fund (IMF) chief economist Maurice Obstfeld said on Monday.
"There are significant spill-over effects thatwe are looking into," Obstfeld said, adding that G20 finance ministers and central bankerswill discuss the issue later thisweek at their meeting in Baden-Baden, Germany.
"There are significant spill-over effects thatwe are looking into," Obstfeld said, adding that G20 finance ministers and central bankerswill discuss the issue later thisweek at their meeting in Baden-Baden, Germany.
To read more go here
Posted on
News Analysis: The All-Purpose U.K. Anti-Hybrid Rules
What happenswhen a player puts an elbow in an opponent's face?
Referees' responses to the Argentine elbow, as it is often called, varywith the league. In France, it's no big deal. French matches are so physical -- to use the English euphemism -- that theywould endwith five on a side if every foulwere called. In Italy, an elbow has recently become a yellow card. In England, it's a red card. In America, it's a red card and an inquest. In Spain, there's no need to elbow anyone because players fall downwithout contact.
Referees' responses to the Argentine elbow, as it is often called, varywith the league. In France, it's no big deal. French matches are so physical -- to use the English euphemism -- that theywould endwith five on a side if every foulwere called. In Italy, an elbow has recently become a yellow card. In England, it's a red card. In America, it's a red card and an inquest. In Spain, there's no need to elbow anyone because players fall downwithout contact.
To read more go here Subscription Required
Posted on
U.S. Tax Changes May Spark Retaliation, Merkel to Tell Trump
German Chancellor Angela Merkelwillwarn U.S. President Donald Trump that a proposed tax overhaul could spark retaliatory measures, including higher tariffs for American companies, according to Der Spiegel magazine.
The German government is reviewing its responses to a border-adjustment tax,whichwould only tax U.S. corporations' imports and not their exports. Documents for Merkel's upcoming meetingwith Trump cited by Spiegel label the measure a "protective tariff" and say it violatesworld Trade Organization rules.
The German government is reviewing its responses to a border-adjustment tax,whichwould only tax U.S. corporations' imports and not their exports. Documents for Merkel's upcoming meetingwith Trump cited by Spiegel label the measure a "protective tariff" and say it violatesworld Trade Organization rules.
To read more go here Subscription Required
Posted on
Italy, Switzerland agree to exchange more tax information to fight evasion
Italian and Swiss tax authorities have signed an accord to improve the exchange of information to fight tax evasion, the Italian economy ministry said on Tuesday.
The agreement took effect at the start of this month and aims to further enhance transparency following a previous accordwhichwas introduced last summer, the ministry said in a statement.
It said the latest agreementwill help Italy obtain revenues from a tax amnesty aimed at raising 1.6 billion euros ($1.70 billion) this year, following 4 billion euros cashed in through the measure in 2016.
The agreement took effect at the start of this month and aims to further enhance transparency following a previous accordwhichwas introduced last summer, the ministry said in a statement.
It said the latest agreementwill help Italy obtain revenues from a tax amnesty aimed at raising 1.6 billion euros ($1.70 billion) this year, following 4 billion euros cashed in through the measure in 2016.
To read more go here
Posted on
Sixty Countries Expected to Sign Tax Agreement: OECD Official
The OECD expects at least 60 nations to sign an agreement implementing changes in the global tax system, according to an officialwith the organization.
Grace Perez-Navarro, deputy director for taxes at the Organization for Economic Cooperation and Development, said the total number of participants in the "multilateral instrument"wouldn't be clear until a signing ceremony planned for June 7. The agreementwould adopt several items from the OECD's Action Plan on Base Erosion and Profit Shifting (BEPS)ÔøΩits comprehensive rewrite of the global tax rulesÔøΩby changing aspects of existing double tax treaties. Those changes include new language for preventing abuse of treaties and a new definition for permanent establishments, or the taxable presence of a foreign entity not registered in a jurisdiction.
Grace Perez-Navarro, deputy director for taxes at the Organization for Economic Cooperation and Development, said the total number of participants in the "multilateral instrument"wouldn't be clear until a signing ceremony planned for June 7. The agreementwould adopt several items from the OECD's Action Plan on Base Erosion and Profit Shifting (BEPS)ÔøΩits comprehensive rewrite of the global tax rulesÔøΩby changing aspects of existing double tax treaties. Those changes include new language for preventing abuse of treaties and a new definition for permanent establishments, or the taxable presence of a foreign entity not registered in a jurisdiction.
To read more go here Subscription Required
Posted on
EU to Seek Clarity on U.S. Tax Plans at G-20 Summit
The EU has grown increasinglyworried about the tax reform that the new U.S. administration is preparing behind the scenes.
Experts from France, Germany, and the European Commission met in Brussels on February 28 to define a common line ahead of the G-20 meeting to be held March 17 and 18 in Baden-Baden, Germany.
Experts from France, Germany, and the European Commission met in Brussels on February 28 to define a common line ahead of the G-20 meeting to be held March 17 and 18 in Baden-Baden, Germany.
To read more go here Subscription Required
Posted on
U.K. Tax Rebellion Reminds May Brexit Allies Remain a Threat
The growing revolt over tax increases in the U.K. budget is a reminder for Theresa May that difficult members of her Conservative Party haven't gone away.
Just as she seemed to have tamed party rebels over Brexit, May found herself fighting a mutiny over taxes. And barely a day after the new policywas announced, she signaled there may be room for concessions.
Just as she seemed to have tamed party rebels over Brexit, May found herself fighting a mutiny over taxes. And barely a day after the new policywas announced, she signaled there may be room for concessions.
To read more go here
Posted on
IRS, Business, and OECD Representatives Weigh In on BEPS Progress
Progress on implementation of the OECD's base erosion and profit-shifting project has surpassed expectations, said Theodore Setzer, IRS assistant deputy commissioner (international),who recalled that a year ago, the challenges of the project seemed to loom larger than the opportunities.
Setzer listed reasons for his measured optimism during a panel discussion on the challenges of BEPS at the Pacific Rim Tax Institute in Redwood City, California, on March 9. He citedwork to finalize regulations for country-by-country reporting (T.D. 9773) development of draft instructions,work on a model bilateral CbC competent authority agreement, and progress on terms of reference and methods for the mutual agreement procedure forum.
Setzer listed reasons for his measured optimism during a panel discussion on the challenges of BEPS at the Pacific Rim Tax Institute in Redwood City, California, on March 9. He citedwork to finalize regulations for country-by-country reporting (T.D. 9773) development of draft instructions,work on a model bilateral CbC competent authority agreement, and progress on terms of reference and methods for the mutual agreement procedure forum.
To read more go here Subscription Required
Posted on
OECD To Hold Fourth Meeting On International VAT Reform In April
The OECD has announced the agenda and date for the fourth meeting of the OECD Global Forum on value-added tax (VAT), to be held on April 12-14, 2017.
The fourth meeting of the OECD Global Forum on VATwill focus in particular on the policy and operational challenges faced by tax authorities in the era of digital globalization, and on the efficient and the effective implementation of the standards and mechanisms for addressing these challenges recommended by the International VAT/GST Guidelines.
The fourth meeting of the OECD Global Forum on VATwill focus in particular on the policy and operational challenges faced by tax authorities in the era of digital globalization, and on the efficient and the effective implementation of the standards and mechanisms for addressing these challenges recommended by the International VAT/GST Guidelines.
To read more go here
Posted on
U.S. Emerging as Leading Tax, Secrecy Haven, EU Report Says
The U.S. is emerging as a "leading tax and secrecy haven for rich foreigners" because of its resistance to global tax disclosure standards and the array of tax-free facilities available for non-residents, according to a European Parliament report.
Released March 7ÔøΩtwoweeks before European Union lawmakers visitwashington D.C. and Delaware to probe money laundering and tax evasion issuesÔøΩ the report says U.S. states such as Nevada,wyoming, South Dakota and Delaware are attracting money flows from around theworld because of laws that permit beneficial owners of companies to remain anonymous.
Released March 7ÔøΩtwoweeks before European Union lawmakers visitwashington D.C. and Delaware to probe money laundering and tax evasion issuesÔøΩ the report says U.S. states such as Nevada,wyoming, South Dakota and Delaware are attracting money flows from around theworld because of laws that permit beneficial owners of companies to remain anonymous.
To read more go here
Posted on
The OECD's Multilateral Treaty Instrument and Its Impact on Dispute Resolution
On July 1, 2016, Latvia deposited its instrument of accession to the OECD Convention, thereby becoming the 35th member of the Organization for Economic Cooperation and Development. That modest expansion of membership, however, is dwarfed by the number of countries now participating in the OECD's taxwork "on an equal footing," thereby being treated as full memberswith the right to veto any proposals or reportswithwhich they disagree. More than 60 countrieswere directly involved in the formulation of the final Base Erosion and Profit Shifting reportswhich received approval from the G20 leaders in November 2015. But the BEPS project did not endwith the publication of those reports; soon thereafter, the OECD established an "inclusive framework" on implementation and monitoring of the BEPS measures. Details onwhat that involves are scarce, although the OECD has promised some form of monitoring of compliancewith the four BEPS "minimum standards," aswell as a peer review of implementation of the BEPS measures around theworld to ensure that no country gains an "unfair competitive advantage."
To read more go here
Posted on
U.N. Addresses BEPS Issues for Income From Services in Developing Nations
A country's tax base may be eroded if the country doesn't tax some income from services, or if it allows a deduction for payments for services against its tax base but doesn't tax those services, according to a U.N. portfolio. Erosion may also occur if the tax on the payments is less than the tax savings resulting from the deduction of the payments, the U.N. said.
To read more go here Subscription Required
Posted on
China promises $50bn in fresh corporate tax breaks
Chinese Finance Minister Xiao Jie is promising 350 billion yuan ($50.7 billion) in corporate tax breaks this year, aiming to stimulate the economy and keep companies frustratedwith heavy taxation from seeking greener pastures overseas.
The measures, targeting mainly manufacturers and small businesses, come on top of a tax overhaul that saved companies 570 billion yuan last year. "The goal is to further lighten the burden on companies," Xiao said in his first news conference since his appointment as minister last fall.
The measures, targeting mainly manufacturers and small businesses, come on top of a tax overhaul that saved companies 570 billion yuan last year. "The goal is to further lighten the burden on companies," Xiao said in his first news conference since his appointment as minister last fall.
To read more go here
Posted on
Netanyahu's Deregulation Chief Seeks to Cut Bureaucracy, Taxes
Israel is ratcheting up its deregulation efforts to stimulate economic growth and attract multinational companies, according to the director general of Prime Minister Benjamin Netanyahu's office.
Eli Groner,who coordinates among various government agencies to implement Netanyahu's economic policies, says regulations have been cut in 27 areas of the economy, from cosmetic imports to the hotel industry,with a goal of reaching 60 areas by the end of next year. Efforts to simplify regulationwere presented thisweek to the cabinet as part of awider two-year plan for government ministries.
Eli Groner,who coordinates among various government agencies to implement Netanyahu's economic policies, says regulations have been cut in 27 areas of the economy, from cosmetic imports to the hotel industry,with a goal of reaching 60 areas by the end of next year. Efforts to simplify regulationwere presented thisweek to the cabinet as part of awider two-year plan for government ministries.
To read more go here
Posted on
EU Proposes Willing States Should Harmonize Tax Regimes
The European Commission has outlined possible scenarios inwhich EU member states could cooperate more on tax. The Commission thisweek published itswhite Paper on the future of Europe.
The document presents five scenarios for the potential state of the Union by 2025. One of these scenarios is, "where certain member stateswant to do more in common, one or several 'coalitions of thewilling' [would] emerge towork together in specific policy areas."
To read more go here
Posted on
EU Mulls Tax Sanctions for Countries Branded Tax Havens
Countries that end up on the European Union's list of tax havens could subject companies operatingwithin their borders to tax sanctionsÔøΩsuch aswithholding taxes and denied deductions for royalty paymentsÔøΩdamaging the businesses' ability to offset losses in the jurisdictions.
To read more go here
Posted on
European Commission Launches Consultation on VAT Cooperation, Fraud
The European Commission on March 2 announced a public consultation on administrative cooperation and the fight against VAT fraud, acknowledging thatwhile the topics primarily concern tax administrations, the need for modernization also affects member-state businesses and citizens.
The commission is planning to update rules governing administrative cooperation and cross-border VAT fraud to improve the functioning of the single market and curb losses to EU member states, according to a commission press release. Because the single market guarantees free circulation of goods and services among member states, the correct application of VAT on cross-border transactions is a challenge for tax administrations, the commission said.
The commission is planning to update rules governing administrative cooperation and cross-border VAT fraud to improve the functioning of the single market and curb losses to EU member states, according to a commission press release. Because the single market guarantees free circulation of goods and services among member states, the correct application of VAT on cross-border transactions is a challenge for tax administrations, the commission said.
To read more go here Subscription Required
Posted on
My Big Fatca IRS
Almost since the Foreign Account Tax Compliance Act (Fatca) became law in 2010 to go after fat cats stashing money abroad, these pages have reported that it has led the IRS to treat law-abiding Americans as criminals. Turns outwe have alliesÔøΩat the IRS.
Buriedwithin the most recent report the IRS taxpayer advocate submitted to Congress in January is a section taking issuewith Fatca. "The IRS," says the report, "has adopted an enforcement-oriented regimewith respect to international taxpayers. Its operative assumption appears to be that all such taxpayers should be suspected of fraudulent activity, unless proven otherwise."
Buriedwithin the most recent report the IRS taxpayer advocate submitted to Congress in January is a section taking issuewith Fatca. "The IRS," says the report, "has adopted an enforcement-oriented regimewith respect to international taxpayers. Its operative assumption appears to be that all such taxpayers should be suspected of fraudulent activity, unless proven otherwise."
To read more go here Subscription Required
Posted on
News Analysis: Why the Swiss Referendum Matters for U.S. Tax Reform
On February 12 Swiss voters threw their government's commitments to the EU -- and the stability of many multinationals' European structures -- into disarray. In a referendum, they rejected a package of corporate tax reforms thatwere supposed to fulfill Switzerland's commitments to the EU and its obligations under the OECD's base erosion and profit-shifting project,while also providing sufficient incentives to keep companies that had been attracted to the country because of the favorable tax breaks.
To read more go here Subscription Required
Posted on
US companies would avoid EU state aid rules with Republican tax proposal
A planned reform of the US tax system designed to attract economic activity and jobs to the country could also put US companies beyond the reach of European state aid rules, an EU official told EURACTIV's media partner PaRR.
On 9 February, US President Donald Trump promised to announce a "phenomenal" tax reform in the next two or threeweeks.
On 9 February, US President Donald Trump promised to announce a "phenomenal" tax reform in the next two or threeweeks.
To read more go here
Posted on
Companies Get Draft Instructions for U.S. Global Tax Reports
U.S. multinational companieswith more than $850 million in annual consolidated gross income now have draft instructions for filing IRS reports on their global tax and profits.
The Internal Revenue Service added instructions to the draft Form 8975 and accompanying draft Schedule A it released in December 2016, companies that are the "ultimate parent" of global groups must report information including the amount of revenue, profit or loss, capital and accumulated earnings for each country of operation. The IRS noted that the instructions are a "draft as of February 23, 2017."
The Internal Revenue Service added instructions to the draft Form 8975 and accompanying draft Schedule A it released in December 2016, companies that are the "ultimate parent" of global groups must report information including the amount of revenue, profit or loss, capital and accumulated earnings for each country of operation. The IRS noted that the instructions are a "draft as of February 23, 2017."
To read more go here
Posted on
Brazil Outlines Process for Asking International Tax Questions
Brazil's federal revenue service is continuing to adapt the country's tax rules to OECD recommendations, as shown in recent guidance on how companies should seek help from the government on international tax questions.
Normative Instruction 1689, issued Feb. 21, spells out the requirements for companies to request a consultation on international taxation questions including those dealingwith transfer pricing, a Brazilian program providing tax incentives for the electronics industry and the opening of foreign offices.
Normative Instruction 1689, issued Feb. 21, spells out the requirements for companies to request a consultation on international taxation questions including those dealingwith transfer pricing, a Brazilian program providing tax incentives for the electronics industry and the opening of foreign offices.
To read more go here
Posted on
European Companies Push Back on CCCTB Proposal
The European Commission's revised proposal for a common consolidated corporate tax base (CCCTB) has metwith resistance from European companies,which see the plan as far less business-friendly than the 2011 proposal.
The original proposalwas essentially pro-business, an EU official told Tax Analysts, adding that the only antiabuse provision included in 2011was requiring companies joining the system to commit for at least five years. Not only does the commission's new plan, announced in October 2016, make the common base mandatory for large companies, it also leaves the consolidation aspect for later as part of a separate legislative proposal.
The original proposalwas essentially pro-business, an EU official told Tax Analysts, adding that the only antiabuse provision included in 2011was requiring companies joining the system to commit for at least five years. Not only does the commission's new plan, announced in October 2016, make the common base mandatory for large companies, it also leaves the consolidation aspect for later as part of a separate legislative proposal.
To read more go here Subscription Required
Posted on
New CCCTB Push Faces Early Criticism
EU member states have voiced fresh criticism of the proposal put forward by the European Commission to establish a common consolidated corporate tax base (CCCTB) in the EU. After a first unlucky attempt in 2011, the commission tried to make its plan more attractivewith tax incentives such as a super deduction for research and development costs and the so-called notional interest deduction inspired by Italy's.
To read more go here Subscription Required
Posted on
All Eyes on White House's Border Adjustment Tax Decision
The fate of a controversial import tax in the House tax overhaul plan now restswith thewhite House after pointed criticism from several Republican senators in the pastweek.
House Speaker Paul D. Ryan (R-Wis.),ways and Means Chairman Kevin Brady (R-Texas) and other supporters,who have been backed into a corner about the 20 percent import tax, now have their hopes set on President Donald Trump.
House Speaker Paul D. Ryan (R-Wis.),ways and Means Chairman Kevin Brady (R-Texas) and other supporters,who have been backed into a corner about the 20 percent import tax, now have their hopes set on President Donald Trump.
To read more go here Subscription Required
Posted on
Swiss want Plan B for tax reform by mid-2017
The Swiss government told the finance ministry onwednesday to come upwith a Plan B by mid-year for eliminating ultra-low tax rates for multinationals after voters rejected the original proposal, setting up a clashwith other rich countries.
The Swiss had promised to meet international standards and end by 2019 special low tax rates that benefit about 24,000 companies, a deadline that Finance Minister Ueli Maurer has saidwas dashed by this month's referendum.
The Swiss had promised to meet international standards and end by 2019 special low tax rates that benefit about 24,000 companies, a deadline that Finance Minister Ueli Maurer has saidwas dashed by this month's referendum.
To read more go here
Posted on
Developing Countries Lack Political Will to Adopt AEOI, Says OECD Official
As the OECD strives to help developing countries enhance their tax systems through the automatic exchange of information (AEOI), it has run into several problems, including a lack of awareness and politicalwill to make the necessary changes, according to an OECD official.
Speaking at a February 16 tax fairness conference organized by the Department of Taoiseach in Dublin, Monica Bhatia, head of the Secretariat of the Global Forum on Transparency and Exchange of Information for Tax Purposes, said thatwhile the Global Forum has seen great success in the last five years, it is now facing several challenges in its mission to help get as many countries signed onto AEOI as possible.
Speaking at a February 16 tax fairness conference organized by the Department of Taoiseach in Dublin, Monica Bhatia, head of the Secretariat of the Global Forum on Transparency and Exchange of Information for Tax Purposes, said thatwhile the Global Forum has seen great success in the last five years, it is now facing several challenges in its mission to help get as many countries signed onto AEOI as possible.
To read more go here Subscription Required
Posted on
Uncertainty and concern follow voter rejection of Switzerlands company tax reform
Speaking to Tribune de Genève, Serge Dal Busco, Geneva's minister of finance, voiced his concerns about last Sunday's rejection of Switzerland's planned company tax reform. At the same time he remains optimistic about the chances of a new federal corporate tax reform project.
His biggest concern is that Bern might backtrack on its promise to help the cantons replace the lost tax revenue created by lowering standard tax rates. Switzerland's federal government promised around CHF 1.2 billion to the cantons and communes, had the vote been accepted.
His biggest concern is that Bern might backtrack on its promise to help the cantons replace the lost tax revenue created by lowering standard tax rates. Switzerland's federal government promised around CHF 1.2 billion to the cantons and communes, had the vote been accepted.
To read more go here
Posted on
Linking repatriation to job creation
Householdwords, an expression coined bywilliam Shakespeare, are those familiar to everyone and it seems "tax repatriation" has now joined the club. That is mainly because the president and House GOP members have trumpeted an idea to incentivize multinationals to bring home some $2.5 trillion in cash they have stashed offshore, and their CEOs have enthusiastically joined the chorus.
To read more go here
Posted on
Swiss Seek New Tax Allure as Vote Hurts Pro-Business Image
Switzerland needs to burnish its appeal to multinationals by presenting a simplified plan to lower corporate tax rates after voters rejected proposals they fearedwould squeeze public services and shift the fiscal burden onto individuals.
Voters rejected the reform package by 59 percent to 41 percent on Sunday following more than a decade of pressure on Switzerland from the European Union to scrap tax breaks for multinationals.
Voters rejected the reform package by 59 percent to 41 percent on Sunday following more than a decade of pressure on Switzerland from the European Union to scrap tax breaks for multinationals.
To read more go here
Posted on
Proposed Directive Would Expand EU Arbitration Convention to All Business Tax Disputes
A proposed directive on double taxation dispute resolution mechanismswould simplify the European Union's tax system by expanding the scope of the EU arbitration convention to cover all questions related to business taxes.
To read more go here Subscription Required
Posted on
Border Tax Could Upend Global Markets, but Investors Shy Away From Any Bets
A Republican tax plan has analysts predicting seismic shifts in global markets, from a double-digit surge in U.S. oil prices to the strongest dollar since the 1980s. But so far, few investors arewilling to bet on it.
Markets are struggling to size up the far-reaching impact of the so-called border adjustment,whichwould tax imports at a rate of 20%while exempting exports. The aim is to make the U.S. a more attractive place for businesses to invest,while also raising $1 trillion to offset Republicans' proposed tax-cut plans.
Markets are struggling to size up the far-reaching impact of the so-called border adjustment,whichwould tax imports at a rate of 20%while exempting exports. The aim is to make the U.S. a more attractive place for businesses to invest,while also raising $1 trillion to offset Republicans' proposed tax-cut plans.
To read more go here Subscription Required
Posted on
India Leads Crackdown on Deviant Shell Companies to Curb Tax Evasion
In yet another move to tackle its "black money" economy, India has introduced new measures to discourage shell companies from engaging in money laundering and tax evasion, including the creation of a task force to monitor government action against such companies.
The Indian Ministry of Finance on February 10 announced that senior officials from several government departments met at Prime Minister Narendra Modi's office to examine how shell companies in India function in order "to prevent their misuse for money laundering and tax evasion," especially as the country continues its efforts to find black money, or undeclared assets.
The Indian Ministry of Finance on February 10 announced that senior officials from several government departments met at Prime Minister Narendra Modi's office to examine how shell companies in India function in order "to prevent their misuse for money laundering and tax evasion," especially as the country continues its efforts to find black money, or undeclared assets.
To read more go here Subscription Required
Member Companies
