It is not a global information reporting network yet, but the US Treasury and Internal Revenue Service’s announcement this week that increases the number of intergovernmental agreements for the Foreign Account Tax Compliance Act (FATCA) from 26 to 48 in one go brings that idea much closer.
The decision of the Delhi Income Tax Appellate Tribunal (ITAT) in the Bharti Airtel case should encourage other Indian taxpayers to apply commercial and transfer pricing principles to agreements concerning corporate guarantees and capital contributions to associated enterprises in India, practitioners have said.
Like other multilateral organisations, such as the IMF and the World Bank, the Asian Development Bank (ADB) has deepened its role in helping to build capacity in tax administrations and to train officials. Satoru Araki, a public management specialist at the ADB, tells International Tax Review how his organisation does it.
The third US Internal Revenue Service (IRS) directive on Information Document Requests (IDR) since June last year has tried to clarify details of the new issuance and enforcement process. Professionals are still worried, however, that it will not deliver the audit efficiencies that the tax authorities want.
Heads of tax and tax administrators should look to expand the G20 / OECD BEPS project and make it more inclusive, the World Bank’s top tax official has said.
