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Archive for OECD

Mauritius Signs The Multilateral BEPS Convention

Mahess Rawoteea of the Ministry of Finance and Economic Development of Mauritius, signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) in the presence of Douglas Frantz, OECD Deputy Secretary-General.

Based on expressed reservations at this point in time, 23 tax treaties would be impacted by this signing. Read more

Seven More Jurisdictions Sign Tax Co-operation Agreement

William Byrnes

As part of continuing efforts to boost transparency by multinational enterprises (MNEs), Gabon, Hungary, Indonesia, Lithuania, Malta, Mauritius and the Russian Federation have now signed the Multilateral Competent Authority Agreement for Country-by-Country Reporting (CbC MCAA), bringing the total number of signatories to 57. Lithuania and Hungary joined the Agreement in October and December 2016 respectively.

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OECD Updates BEPS Financial Payments And Tax Treaties

William Byrnes

The 2015 Report on BEPS Action 4 established a common approach which directly links an entity’s net interest deductions to its level of economic activity, based on taxable EBITDA. Further work on two aspects of the common approach was completed in 2016 and this is included in this update.

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Peru Joins The Inclusive Framework On BEPS

William Byrnes

Following the first meeting of the Inclusive Framework on BEPS in Japan, on 30 June – 1 July, and recent regional meetings, more countries and jurisdictions are joining the framework. The Inclusive Framework on BEPS recently welcomed Peru bringing to 91 the total number of countries and jurisdictions participating on an equal footing in the Project.

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Tax Residency In Canada: Deemed VS. Factual Resident

John Richardson

Tax Residency is becoming an increasingly important topic. Every country has its own rules for determining who is and who is not a “tax resident” of that country. The advent of the OCED CRS (“Common Reporting Standard”) has made the determination of “tax residence” increasingly important.

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More Than 1,000 Relationships Now In Place To Automatically Exchange Information Between Tax Authorities

William Byrnes

As a further step to implement the OECD Common Reporting Standard (CRS), the first series of bilateral automatic exchange relationships were established among the first batch of jurisdictions committed to exchanging information automatically as of 2017.

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IRS Provides Legal Advice When Data Exchange With Foreign Countries is Confidential

Ronald Marini

In Legal Advice Issued by Associate Chief Counsel 2016-004, the IRS has given its opinion on the exact moment when information that it provides to and receives from foreign tax administrations via the Organization for Economic Cooperation and Development’s Common Transmission System becomes protected under the Code’s confidentiality rules. Legal Advice Issued by Associate Chief Counsel 2016-004.

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Tax Policy Reforms Driven By Focus On Boosting Growth

While fiscal consolidation was the key driver of tax reforms in the years following the global economic crisis, the main emphasis of recent tax reforms has shifted back to tax measures aimed at boosting economic growth, according to a new OECD report.

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Pakistan Becomes the 104th Country to Signs OECD Convention on Mutual Administrative Assistance in Tax Matters

Ronald Marini

On August 29, 2016, we posted OECD Adds 5 More Countries To Its CbC Automatic Exchange Agreement where we discussed that on June 30, the Organization for Economic Co-operation and Development (OECD) announced that 5 new countries have signed the Multilateral Competent Authority Agreement for the automatic exchange of tax information.

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Singapore is Now Automatically Sharing Your Account Information!

Ron Marini

On July 25, 2016, we posted Tax Havens Coming Clean and Becoming Transparent where we discussed that the Inland Revenue Authority of Singapore has issued an e-Tax Guide on the territory’s general anti-avoidance rule in Section 33 of the Income Tax Act. The guide, issued on July 11, 2016, explains the three tests to determine whether the GAAR should apply.

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OECD Adds 5 More Countries To Its CbC Automatic Exchange Agreement

Ron Marini

On June 30, the Organization for Economic Co-operation and Development (OECD) announced that 5 new countries have signed the Multilateral Competent Authority Agreement for the automatic exchange of country-by-country (CbC) reports (CbC MCAA), which facilities the exchange of certain confidential transfer pricing information recommended under Action 13 of the G20/OECD project to target base erosion and profit shifting (BEPS). It brings the total number of signatories to 39 countries.

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U.S. Treasury Seeks Comments On Form 8975—CbC Reporting Form

Ron Marini

On May 5, 2016, we posted Possible CbC Optional Reporting for 2016 Under Consideration by US Treasury, which discussed that the Treasury and IRS were working towards a solution that would allow optional country-by-country (CbC) reporting for 2016. Also, more work would be needed to ensure that allowing optional filing for 2016 in the US would be effective in obviating the need for local filing. The Treasury and IRS also requested that U.S. multinational corporations (MNCs) to engage in the global debate to ensure optional CbC reporting will be enough to protect U.S. MNCs from becoming subject to secondary reporting requirements.

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