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  • May 2015

    Businesses report difficulties in obtaining APAs with China

    May 28, 2015

    Though China has had an advance pricing agreement (APA) programme for nearly a decade, some businesses report that obtaining APAs in China is challenging due to a lack of manpower at the State Administration of Taxation’s (SAT) transfer pricing team.

  • Creditors reject Greek VAT reform

    May 28, 2015

    Plans for sweeping changes to the VAT system, which would cut the rate businesses pay from 23% to 15%, have been rejected by Greece’s creditors.

  • ECJ clarifies German case on investment fund lump-sum taxation

    May 28, 2015

    In its judgment dated May 21 2015 (Wagner-Raith) the European Court of Justice (ECJ) confirmed that the German lump-sum taxation according to section 18 paragraph 3 of the German Foreign Investment Act (GFIA), as effective until the end of 2003, is within the scope of the standstill clause of article 57, EC Treaty.

  • Nokia withdraws asset freeze request as Delhi High Court case begins

    May 28, 2015

    Nokia India’s latest dispute with the Indian tax authorities kicked off on Tuesday [May 26 2015] in the Delhi High Court.

  • The Brockman brief: UK diverted profits tax: The extrapolation effect

    May 27, 2015

    The UK's diverted profits tax (DPT) was developed, and enacted, quickly in the weeks leading to the general election. The legislation was a two-pronged attack: on transactions having insufficient economic substance and the avoidance of permanent establishment (PE). The legislation went into effect April 1 2015 and there have been hints that other countries are looking at similar moves; but exactly what tax doctrines will other countries adopt to achieve similar objectives?

  • BEPS: Improving data, economic analysis and measurement

    May 27, 2015

    It is stating the obvious to say that current international efforts to tackle base erosion and profit shifting (BEPS) have attracted a great deal of global attention. Since the OECD and G20 countries, working together on an equal footing, adopted a 15-point action plan to address BEPS in September 2013, the focus on this issue has steadily grown. David Bradbury, head of the tax policy and statistics division at the OECD Centre for Tax Policy and Administration, and the man overseeing this aspect of the project, provides exclusive insight into an action point that has not always received as much attention as other items in the Action Plan.

  • India: Changing perceptions through administrative evolution

    May 27, 2015

    Ashwani Mehta, former Chief Commissioner of Income Tax at the Indian Revenue Service, who retired in February after more than 35 years at the IRS department, assesses recent developments in Indian income taxation.

  • ETFs - preparing for future tax challenges

    May 27, 2015

    Exchange traded funds (ETFs) have been a huge success growing far beyond their initial function of tracking large liquid indices in developed markets. Global ETFs now hold more than $2.9 trillion of assets in upwards of 5,400 products listed on 60 exchanges. Marie Coady, financial services tax partner at PwC in Ireland, tackles the associated tax and regulatory challenges.

  • Shifting the balance: Asia’s move to indirect tax

    May 27, 2015

    With China poised to complete its VAT roll-out in the second half of this year and India hoping to introduce GST in 2016, the next few years will see 2.5 billion people paying consumption tax more efficiently than ever before on the goods and services they are buying at an ever increasing rate. Meredith McBride tracks the shift from direct to indirect taxation in Asia.

  • Substance-over-form in China's GAAR

    May 27, 2015

    Scott Heidecke and Flora Luo of Nexia International member firm Nexia TS (Shanghai) discuss China's latest attempts to implement countrywide standard practices for application of the general anti-avoidance rules, while bringing clarity to foreign entities which are affected.

  • Swiss court challenges fundamental OECD tax principle

    May 27, 2015

    The OECD has updated the commentaries on the Model Tax Convention (Commentaries) seeking to clarify the concept of beneficial ownership in tax treaties. Charles Hermann, a financial services tax partner at KPMG, explores beneficial ownership issues arising from the ‘Swiss Swap’ case.

  • Implementing the BEPS Action Plan in Mexican domestic law

    May 27, 2015

    One of the concerns that has arisen for governments around the world is the erosion of the national tax base caused by a globalised economy, the progress of technology and the development of telecommunications. Ricardo Rendón and César de la Parra of Chevez, Ruiz, Zamarripa y Cía look at the Mexican perspective on base erosion and profit shifting (BEPS).

  • Collections delayed on transfer pricing bills under India-UK DTAA

    May 25, 2015

    The Indian Ministry of Finance has issued a fresh notice preventing the collection of taxes on transfer pricing cases for Indian subsidiaries of UK resident companies undergoing a mutual agreement procedure (MAP).

  • European Tax Awards 2015 - the winners

    May 22, 2015

    The European Tax Awards 2015 were presented on May 21 at a dinner at the Grosvenor House Hotel in London.

  • Americas Awards 2015: Entry forms are available now

    May 20, 2015

    This year's Americas Tax Awards will take place in New York on September 17. Make sure you are ready to compete.

  • Finance minister: No corporate tax cuts for Indonesia

    May 20, 2015

    The Indonesian Minister of Finance has rejected claims that the country’s corporate tax rate will be cut to less than 18%.

  • Uncertainty remains around tax treatment of Brazilian current account structures

    May 20, 2015

    Current account structures enable companies in the same economic group to make cash available to each other, generating reciprocal obligations of booking the amounts corresponding to withdrawals and disbursements of cash, without one being considered a creditor or debtor of the other.

  • Ansip to propose EU-wide VAT threshold “as soon as possible”

    May 19, 2015

    Andrus Ansip, European Commission vice president for the digital single market, has promised to launch a proposal for an EU-wide VAT threshold on business-to-consumer (B2C) e-services “as soon as possible”.

  • MEPs to discuss important EU VAT vote tonight

    May 18, 2015

    Members of the European Parliament (MEPs) will take part in a plenary debate tonight [May 18 2015] on potential changes to the EU’s 2015 VAT rules.

  • Jaitley orders tax authorities to stop issuing MAT bills

    May 15, 2015

    India’s Finance Minister Arun Jaitley has told the tax authorities not to send out any new bills for minimum alternate tax (MAT) to foreign portfolio investors while a committee he has created enquires into the controversy.

  • OECD tax chief highlights benefits and risks of transparency

    May 15, 2015

    Pascal Saint-Amans has emphasised the urgency of fixing the flaws in the international tax system.

  • Upper house delay means India’s GST may not achieve April 1 deadline

    May 15, 2015

    A Bill necessary for facilitating India’s goods and services tax (GST) has been delayed in the Rajya Sabha, the Upper House of Parliament, until the next parliamentary session this summer.

  • JPMorgan under investigation for tax evasion in France

    May 14, 2015

    France has launched a formal investigation into American bank JPMorgan over allegations that some of its senior managers helped French investment company Wendel to evade tax.

  • Possible corporate tax cut faces hurdles in Indonesia

    May 14, 2015

    President Widodo is considering slashing Indonesia's corporate tax rate from 25% to under 18% to stop multinationals transferring profits out of the country to offshore low tax jurisdictions, Luhut Panjaitan, his chief of staff, has said. However, not everyone is convinced the plan will see fruition.

  • Budget confirms Australian commitment to tougher anti-avoidance measures

    May 13, 2015

    Australian Treasurer Joe Hockey had plenty to say about large companies and their tax arrangements in his annual budget statement on May 12.

  • EC's digital single market strategy aims to reform VAT for B2C online retailers by 2017

    May 13, 2015

    The European Commission‘s ambitious plans to improve the digital single market include changes to the VAT treatment of the cross-border supply of goods and services.

  • Puerto Rico drops VAT plans; higher taxes on multinationals likely to compensate

    May 13, 2015

    Puerto Rico’s parliament has voted down plans to introduce a VAT of 16%, leading to fears that the government could impose higher taxes on large multinationals, defined as those generating more than $600 million in sales, to plug the territory’s budget deficit.

  • Vestager delays verdict on EC state aid investigations in to Apple, Amazon, Starbucks and Fiat

    May 13, 2015

    The European Commission (EC) will miss its June deadline to complete state aid investigations into tax rulings for Amazon, Apple, Fiat and Starbucks, competition commissioner Margrethe Vestager has announced.

  • ‘Netflix tax’ and diverted profits expected to feature in Australian budget

    May 08, 2015

    Though broad-based tax reform will wait until after a white paper is published later this year, tax professionals expect Australia’s May 12 Budget to continue to lay the foundation for furthering the OECD BEPS initiative, including discussions on controversial taxes on diverted profits and e-commerce sales.

  • Ola Nicolai Borge joins Baker & McKenzie Myanmar

    May 08, 2015

    Ola Nicolai Borge leaves Grant Thornton to join Baker & McKenzie in Yangon.

  • Are too many Swiss banks using the US DoJ self-reporting programme?

    May 07, 2015

    The US Department of Justice (DoJ) self-reporting programme for Swiss banks, which was launched in 2013, offers banks the chance to bring US taxpayers’ undeclared assets into the open in return for immunity from prosecution.

  • India’s Lok Sabha passes GST Bill

    May 07, 2015

    India’s lower house of parliament this week passed a goods and services tax (GST) Bill, gaining the two thirds majority needed despite a staged walkout from the opposition Congress party.

  • Lam leaves Goldman Sachs after more than a decade

    May 07, 2015

    Jocelyn Lam is finishing up this week at Goldman Sachs before joining KPMG on July 1.

  • BHP Billiton faces $432 million tax bill in Australia

    May 06, 2015

    The Australian Tax Office has challenged the transfer pricing practices of BHP Billiton, serving the country’s largest taxpayer with a A$522 million ($432 million) tax bill, based on the pricing of goods it sold to a marketing affiliate in Singapore. The company’s Singapore tax bill is also being questioned under Australia’s controlled foreign company (CFC) rules, which require a minimum payment of tax.

  • Investors challenge Indian MAT

    May 04, 2015

    Several foreign portfolio investors have banded together to challenge India's minimum alternate tax (MAT) on capital gains in a case that will have wide-reaching implications for investors who face hefty tax bills between 2009 and 2015.

  • Tax deductibility of recharges by non-resident companies in Nigeria under turnover assessment

    May 03, 2015

    For Nigerian tax purposes recharges can be defined as costs reimbursed by a non-resident company to its Nigerian affiliate in respect of services provided by the affiliate in execution of a joint contract in Nigeria. Generally, this amount includes a profit mark-up for the affiliate, and the non-resident company is allowed the amount as a deduction in its income tax returns.

International Correspondents