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Archive

  • August 2014

    World Tax Authority: Taking harmonisation to the next level

    August 29, 2014

    Recent attempts at tax harmonisation have struggled to take off. In Europe enhanced cooperation measures are being invoked because of the inability to find consensus. But what fate awaits the notion of a World Tax Authority (WTA)? Would it take tax harmonisation to the next level or, like the Europe-wide language of Esperanto, is this attempt at harmonisation doomed to fail? Matthew Gilleard analyses what has motivated discussion of such a concept and looks at the barriers to implementation.

  • Convergence or divergence: New reporting standards in India

    August 29, 2014

    India has announced the adoption of IFRS converged standards for financial reporting and tax accounting standards for the computation of taxable income. Sai Venkateshwaran, partner and head of the accounting advisory services group at KPMG in India analyses the impact and challenges of these announcements.

  • Going the extra mile - when finance and IT suddenly awoke

    August 29, 2014

    In the July/August issue, Frank Schoeneborn, head of group operational transfer pricing in the finance and accounting division at Merck Group, took a retrapolative look at the country-by-country reporting standard five years into its implementation. In part two, he looks at how different functions within a multinational company are interacting with the tax team to manage reporting obligations.

  • Alternative dispute resolution: Alleviating burdens all round

    August 29, 2014

    The number of tax disputes is increasing rapidly around the world. The trend is encouraging governments to turn to alternative dispute resolution (ADR) in a bid to reduce backlogs in the courts. While ADR is well established in some jurisdictions, in others it is just getting going. Aaran Fronda looks at how ADR has become an increasingly viable solution for resolving tax disputes.

  • NZ Inland Revenue releases draft GAAR guidance

    August 29, 2014

    New Zealand has had a general anti-avoidance rule (GAAR) since income tax was first introduced in 1891. But in the past decade, changes in Inland Revenue practice and judicial attitudes have seen the GAAR, which was previously considered applicable only to highly artificial tax avoidance schemes, become probably the most broadly applied GAAR of any country in the world. Russell McVeagh’s Tim Stewart tracks this trend.

  • Environmental fiscal reform: Windows of opportunity

    August 29, 2014

    Constanze Adolf, of Green Budget Europe, looks at environmental fiscal reform (EFR) in a post-crisis context, assessing the prospects for EFR to raise government revenue and promote the polluter-pays principle.

  • The IMF and international tax

    August 29, 2014

    David Spencer, of the Law Offices of David Spencer in New York, analyses the recent work of the International Monetary Fund (IMF) and assesses its growing influence in the area of international taxation.

  • Osborne figure-fudge highlights UK government’s core conflict on avoidance

    August 29, 2014

    COMMENT: George Osborne used inappropriate figures when boasting of the UK government’s success in clamping down on tax avoidance during the latest Budget, the UK Statistics Authority has found.

  • UN survey calls for more tax cooperation in Asia

    August 29, 2014

    A UN body has highlighted the prospects of tax harmonisation and the elimination of tax competition in Asia-Pacific as methods for helping countries in the region to increase the amount of taxes they raise.

  • Verizon claims IRS arguments are inconsistent in $26 million WorldCom case

    August 29, 2014

    The US Supreme Court is mulling over whether or not to hear WorldCom Inc v. Internal Revenue Service (13-1269), a case that holds the now-obsolete WorldCom (Verizon Communications) liable for millions in excise taxes for its telecommunications services.

  • EU Commission adopts new customs risk management strategy

    August 28, 2014

    A new strategy and action plan aimed at developing better customs risk management has been approved by the EU Commission.

  • Indian High Court provides relief for indirect transfer of Indian assets

    August 28, 2014

    The Delhi High Court’s ruling in the Copal Research Limited, Mauritius case is the first on the taxation of the indirect transfer of Indian assets since the previous government’s much talked about amendment following the Supreme Court’s Vodafone decision.

  • Is it time to scrap the FTT?

    August 28, 2014

    With financial institutions struggling to deal with an abundance of new regulation, a new report urges the new EU Commission and Parliament to focus on growth, rather than implementing a badly designed tax that could spell disaster for the European economy.

  • Tax is key part of Grant Thornton Vietnam merger with Nexia ACPA

    August 28, 2014

  • US political rhetoric continues as latest inversion deal creates third-largest global fast-food business

    August 28, 2014

    The $11 billion Burger King-Tim Hortons deal will see the new company located in Canada. Burger King company executives say it is motivated by growth opportunities rather than by any potential tax savings.

  • Australia unveils tax guidance on digital currencies

    August 26, 2014

    Bitcoin users in Australia will have to report and pay GST on their digital currency transactions, after the Australian Taxation Office (ATO) announced that digital currencies such as Bitcoin are not money or foreign currency under the GST Act.

  • Brazil: Tax benefits of Manaus Free Trade Zone extended until 2073

    August 26, 2014

    Ricardo M Debatin Silveira and Gabriel Caldiron Rezende of Machado Associados have good news for investors in the state of Amazonas in the north of Brazil.

  • New protocol to Canada-UK tax treaty could affect future tax disputes

    August 26, 2014

    Jeffrey Shafer and Ian Caines, of Blake, Cassels & Graydon, explain how the recent protocol to the Canada-UK tax treaty could induce a change in the way taxpayers approach disputes covering the two jurisdictions.

  • Taxand appoints Alain Recoules as new global indirect tax leader

    August 26, 2014

  • Indian taxpayers get more time to file tax audit reports

    August 22, 2014

    The Central Board for Direct Taxes (CBDT) in India has given taxpayers an extra two months to file their Tax Audit Report (TAR) for the Assessment Year 2014-2015 because of changes it made in July to the forms required. However, there is no extension for the filing of income tax returns, which are still required by September 30.

  • Inversions highlight antiquated US tax system

    August 22, 2014

    Comment: Far from representing the lack of economic patriotism of US companies, the trend of inversions out of the US is indicative of just how antiquated the US tax code is.

  • Ukraine clampdown on audits avoids tax

    August 22, 2014

    Tax has escaped a prohibition on audits by Ukrainian state agencies.

  • HMRC to close EBT settlement initiative

    August 21, 2014

    UK taxpayers have until March 2015 to eliminate employee benefit trusts (EBT) from their tax planning. However, the warning does not apply to every company that has used the technique, advisers say. A settlement initiative for employers who used Employee Benefit Trusts (EBT), as a tax avoidance vehicle will close in seven months’ time, HM Revenue and Customs (HMRC) has announced.

  • TEI raises concerns about Chinese GAAR

    August 21, 2014

    The Tax Executives Institute (TEI) submitted comments to China’s State Administration of Taxation (SAT) regarding its draft of administrative measures on general anti-avoidance rules (GAAR). The group, which represents the interests of in-house tax professionals, expressed concern that the new measures inappropriately expand the scope of GAAR and do not provide clarity to taxpayers.

  • Voluntary self-disclosure in Austria: New restrictions ahead

    August 21, 2014

    New tax law amendments in Austria are set to take effect from October 1. The amendments will mean taxpayers have more options to correct instances of negligence without criminal proceedings.

  • Americas Awards nominations released

    August 20, 2014

    The nominations for the Americas Tax Awards, which take place in New York on September 18, have been announced on www.internationaltaxreview.com.

  • Malaysia: Clock is ticking for GST registration

    August 20, 2014

    With the introduction of the goods and services tax (GST) from April 2015, the Malaysian Customs Department has released its GST handbook to help prepare businesses for the new tax, but time is running out.

  • UK sets out questions about implementation of Common Reporting Standard

    August 15, 2014

    HM Revenue & Customs (HMRC) has opened a consultation into how the Common Reporting Standard (CRS) should be incorporated into UK law.

  • India: High Court rules CCDs are exempt under India-Mauritius DTAA

    August 14, 2014

    The Delhi High Court has decided, in Zaheer Mauritius vs Director of Income Tax, that the sale of compulsory convertible debentures (CCDs) should be classified as capital gains and exempt under the India-Mauritius double tax treaty (DTT). The decision will mean most to real-estate taxpayers who use Mauritius to invest in India.

  • Swedish tax official reflects on interest deductibility proposals

    August 14, 2014

    A Swedish committee on corporate taxation has proposed reforms to limit interest deductibility in the country. Borje Noring, tax auditor at the Swedish Tax Agency, Skatteverket, reacts to the proposals, which have drawn criticism from US business representative groups.

  • Japan: Changes to place of supply rules will hurt overseas suppliers of digital services

    August 13, 2014

    The government has proposed changes to Japanese consumption tax (JCT) place of supply rules, so the levy applies equally to foreign and domestic suppliers of digital services.

  • Phase II of AJAC may increase US litigation

    August 13, 2014

    Phase II of the Appeals Judicial Approach and Culture (AJAC) project in the US provides that the Appeals division of the Internal Revenue Service will not accept new cases unless there is at least 365 days remaining on the statute of limitations, but this may lead to more cases heading for litigation.

  • Singapore to fully implement advance export declaration

    August 13, 2014

    From October 2014, Singapore will fully implement advance export declaration (AED), which will require all exporters to submit export declarations to Singapore Customs authorities before the physical export of goods.

  • EY appoints Jay Nibbe as new global head of tax

    August 12, 2014

  • Inversions - special focus

    August 10, 2014

    Between 1983 and 2004 there were 29 inversion transactions out of the US. In the decade following, almost 50 companies restructured using the method. With foreign profits trapped offshore by an outdated, worldwide system which would hit them with a tax on repatriation, as well as a high tax rate, the temptation to consider an inversion is proving too much for US companies, particularly those in the highly-mobile pharmaceuticals sector. Whatever the motivation, inversions are in vogue. ITR’s special report looks at the knock-on impacts of the current wave of inversions, including shareholder pressure to consider an option they see their rivals pursuing and the possible inflammation of the tax morality debate in the US. We also bring you exclusive insight as to why Danaher is not looking to invert.

  • Why Japan is cutting its corporate tax rate

    August 08, 2014

    The corporate income tax rate in Japan is known to be one of the highest worldwide. To encourage foreign companies to do business in Japan and make Japan a more attractive location for investments, Prime Minister Shinzo Abe is considering reducing the corporate income tax rate to a "competitive rate in the global market".

  • Brazil: Tax amnesty programme applied for Rio de Janeiro

    August 07, 2014

    The amnesty programme allows the waiver or reduction of penalties and interest relating to certain outstanding state tax obligations in a bid to increase tax revenue.

  • Brian Birt joins MHA MacIntyre Hudson

    August 07, 2014

  • Amazon struggles to resolve $1.5 billion dispute with IRS

    August 06, 2014

    The international e-commerce company, Amazon, has failed to resolve elements of its transfer pricing dispute with the Internal Revenue Service (IRS). The case revolves around the retailer’s use of a European subsidiary to reduce its tax bill which, if it loses, could cost the company billions.

  • Australia: New GST refund measures remove scope for subjectivity

    August 06, 2014

    The rules that determine the amount a taxpayer can be refunded for payment of excess GST have now changed. The Tax Laws Amendment (2014 Measures No 1) Bill 2014 updates the Taxation Administration Act (TAA) to provide that excess GST shall not be refunded where an entity would obtain a windfall gain.

  • HMRC to get even tougher on tax avoidance

    August 06, 2014

    New proposals by the UK government to enlarge the scope of its Disclosure of Tax Avoidance Schemes (DOTAS) and VAT Avoidance Disclosure Regulations (VADR) regimes, as well as the drafting of a new financial product hallmark, will increase the number of schemes that could fall prey to controversial accelerated payment powers.

  • How Hong Kong is adapting to international fiscal transparency standards

    August 04, 2014

    Hong Kong is an important financial, trading and service hub for China and Asia which is a result of very good infrastructure, highly effective financial markets and a highly competitive tax regime. Hong Kong has always aimed at minimising administrative burdens which results in a very simple and easy-to-handle tax regime that many countries would wish for. Thus, more complicated tax regulations including tax treaties or anti-avoidance regulations including transfer pricing have been kept to a bare minimum, if included at all.

  • Trends in Latin American business restructurings: Spain as a holding jurisdiction

    August 04, 2014

    Its ETVE regime is one of the reasons why Latin America businesses are using Spain as a holding company location, but interested taxpayers should remember the substance requirements.

  • APM Terminals global tax head: Divergent thinking is the way forward

    August 01, 2014

    In part two of International Tax Review’s exclusive interview, Steven Ouwerkerk, global head of tax & treasury at APM Terminals, based in the Netherlands, discusses the transition from adviser to in-house professional, analyses the challenges an in-house tax team faces, and stresses the importance of thinking divergently to find creative solutions.

  • REINTEGRA: Re-establishment of the Brazilian special regime for the reinstatement of taxes for exporters

    August 01, 2014

    Provisional Measure 651/2014, enacted in July 2014 (MP 651/2014), re-established the Brazilian Special Regime for the Reinstatement of Taxes for Exporters (REINTEGRA).

International Tax Review Profile

RT @CBItweets: UK needs a Budget that enables the country to grow its way out of austerity. Here are 5 business priorities https://t.co/CAw

Oct 19 2017 09:19 ·  reply ·  retweet ·  favourite
International Tax Review Profile

This year's World Tax directory is now online. How does your firm stack up? https://t.co/CtRbW1Ub5j

Oct 19 2017 09:13 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @AuroChardon: Let's honour the #memory of a brave #journalist and woman ➡️ vigil tomorrow, 18 Oct, 6pm, in front of Residence Palace #Da…

Oct 18 2017 04:42 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Big Soda scores victory as Chicago-area tax repealed - could this be the beginning of the end of the sugar tax trend?https://t.co/PNuafWHy9K

Oct 12 2017 04:03 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Ebay and Netflix pay total UK tax of less than £1.9m - How long until HMRC investigate their TP practices? https://t.co/VPPsT3aGMZ via @FT

Oct 12 2017 03:59 ·  reply ·  retweet ·  favourite
International Correspondents