Search results for

Timothy Lyons QC and Kelly Stricklin-Coutinho of 39 Essex Chambers analyse recent transparency developments across Europe, focusing on the proposed requirement for EU member states to provide a quarterly report on all cross-border tax rulings and advance pricing arrangements.

Tim Stewart

James Newnham After an intense month of tax-related Australian Senate Economics Committee hearings, namely an inquiry taking evidence on corporate tax avoidance, Apple, Google and Microsoft as well as leading Australian mining companies were in the spotlight to answer allegations around international profit shifting. In this context, the Australian tax regime is under increasing public pressure to keep up with the effects of ubiquitous digital disruption. In this regard, Australian Treasurer Joe Hockey has flagged plans for the so-called 'Netflix tax' to extend the reach of the GST to the online purchase of movies, songs, books and streaming services, consistent with the G20/OECD destination principle. The plan would update the GST to include intangible services such as online downloads and could set a precedent which extends to other digital and editorial content. On March 30 2015, the Australian government released its 'Re:think' tax discussion paper, following on from the 2015 Intergenerational Report, contemplating a renewed tax system that supports higher economic growth and living standards, improves international competitiveness and adjusts to a changing economy. In releasing the paper, the Treasurer also said the government "does not support high tax rates to deliver these outcomes. As we have said on numerous occasions, our nation will never be able to tax its way to prosperity.". Hockey said the "challenge then is to reform our tax system so that we can raise necessary revenue without detracting from continued economic growth across the Australian economy". The key points of the paper discuss and consider reforms to the rate and base of the GST, the (high) corporate tax rate and inefficient taxes such as stamp duty.

Partho Shome’s 30-year career as a tax official and adviser to Indian governments and multilateral organisations may be at an end for now, but he will still take a keen interest in tax policy, as this exclusive interview with International Tax Review reveals.

Alvaro Pereira and Mark Conomy (pictured) On April 1 2015, the Brazilian Government issued Decree 8,426/2015, regulating the Social Integration Program (PIS) and the Social Contribution on Billing (COFINS) applied on financial revenues, including financial revenue derived from hedge transactions, with effect from July 1 2015. By way of background, PIS and COFINS under the non-cumulative regime are social contributions levied on gross revenues within Brazil (subject to certain specified exemptions) at the combined rate of 9.25%. Financial revenue has been granted a 0% combined rate since April 2005.

The UK diverted profits tax (DPT) – dubbed the Google tax – has been in effect for almost a month, and Australia is looking at similar action to be included in its May 12 Budget speech, after signalling a desire to move “further and faster” than the OECD-led BEPS project. If other jurisdictions follow suit, this could drastically dilute the impact of multilateral efforts.

The chairman of India’s Tax Administration Reform Commission (TARC), which completed its work earlier this year, has highlighted an increased customer focus, the desirability to combine the country’s direct tax and indirect tax administrations, and the need for impact assessment and revenue forecasting, as examples of the organisation’s most important recommendations.

The Peruvian tax authorities have changed the period within which settlement must take place for income derived from financial derivatives to be considered sourced in Peru.

Lynne Doughtie has been elected as KPMG’s US chairman and CEO, becoming the first woman to hold both positions. Scott Ozanus will continue to serve as US deputy chairman and COO.

June 8 is the date of the next webcast to update stakeholders on the progress of the OECD-led base erosion and profit shifting (BEPS) project.