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Tag Archive for BEPS

Transfer Pricing Summit—Register Today!!

K J 6.7

The issue of transfer pricing has never been a bigger issue than now. With news of the IRS auditing U.S. corporations who operate outside of the country, the Organization for Economic Cooperation and Development (OECD) latest action plans under the Base Erosion Profit Sharing (BEPS) project, and the U.K. voting to leave the European Union (Brexit), the effects with be seen by U.S. multinationals. You have the opportunity to learn from top tax experts who will discuss and analyze the transfer pricing market.

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Transfer Pricing Moves Ahead: OECD and G20 Broaden Intra-Group Services Provisions

Ronald Marini

Transfer pricing methodologies are beginning to spread far beyond the narrow confines of section 482. Consider two very recent examples:

• Argentina had enacted revenue raising measures designed to penalize companies that would shift profits from Argentina to a tax haven. Argentina used an OECD BEPS transfer pricing rationale in enacting these anti-tax-haven provisions. Most Argentinian enterprises that make use of tax havens use Panama for that tax haven purpose, in part because of the commonality of language. Panama sued Argentina, arguing that the Argentinian tax restrictions are an artificial trade constraint. Panama brought suit at the World Trade Organization (WTO). Other countries are now involved. Panama won the initial round at the WTO, but Panama has joined the OECD’s Global Forum, a measure that would ultimately bring the country into compliance with the OECD’s Transfer Pricing Guidelines. Panama’s attack is similar to the attack on DISC before GATT three decades ago

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IRS Issues Proposed Country-by-Country Reporting Rules!

Ronald Marini

The OECD in October released its final recommendations under its project to combat tax base erosion and profit shifting, which included a plan for having companies file reports in their home jurisdictions detailing their business activities such as taxes accrued, profits and number of employees.

The IRS has now proposed rules requiring large companies to report information for each country of operation including the amount of revenue, profit or loss, capital and accumulated earnings, consistent with OECD recommendations designed to combat base erosion and profit shifting. The rules (REG-109822-15) would apply to U.S. parent companies with at least $850 million in annual revenue for the preceding annual accounting period, for the taxable year beginning on or after the rules are made final, ensuring that, for most companies, they won’t take effect before Jan. 1, 2017.

The proposed regulations affect U.S. persons that are the parent of a MultiNational Enterprise (MNE) group, with annual revenue for the preceding annual accounting period of $850 million or more. Read more

TEI-SJSU High Tech Tax Institute – 11/9-11/10, 2015 in Palo Alto, California

World_Connections

As a Reminder, the 31st Annual TEI-SJSU High Tech Tax Institute will be held on November 9 and 10 at the Crowne Plaza Cabana in Palo Alto, California.  Topics include practical consequences of BEPS, EU hot topics, Sections 41 and 199 applied to cloud computing transactions, repatriation strategies, and IRS developments.  Speakers include Heather Maloy, Joe Mikrut, Larry Langdon, Jim Fuller, Eli Dicker and Ivan Humphreys.  The agenda includes speakers from China, Ireland and the UK.

For the complete agenda and speaker list, as well as online registration, please visit http://www.tax-institute.com.

A discount is offered for TEI members. Read more

TEI-SJSU High Tech Tax Institute – November 9 & 10, 2015 in Palo Alto

TaxConnections Picture - Announcement - 10-26-15 - square

The 31st Annual TEI-SJSU High Tech Tax Institute will be held on November 9 and 10 at the Crowne Plaza Cabana in Palo Alto, California.  Topics include practical consequences of BEPS, EU hot topics, Sections 41 and 199 applied to cloud computing transactions, repatriation strategies, and IRS developments.  Speakers include Heather Maloy, Joe Mikrut, Larry Langdon, Jim Fuller, Eli Dicker and Ivan Humphreys.  The agenda includes speakers from China, Ireland and the UK.

For the complete agenda and speaker list, as well as online registration, please visit http://www.tax-institute.com.

A discount is offered for TEI members. Read more

OECD To Release BEPS Package To Stop Tax Avoidance!

Ronald Marini picture13

The OECD will release the final package of measures for a coordinated international approach to reform the international tax system under the OECD/G20 Base Erosion and Profit Shifting (BEPS) strategy to tackle tax avoidance by multinational companies on Monday October 5, 2015.

The final outcomes of the BEPS Project will be presented by Pascal Saint-Amans, Director of the OECD Centre for Tax Policy and Administration, during a webcast news conference at 2:00 p.m. (CET).

A technical briefing via webcast on the BEPS deliverables will follow, at 4:00 p.m. (CET).

The OECD/G20 BEPS Project provides governments with clear international solutions to Read more

Cloud Computing and Other High Tech Tax Issues

Annette Nellen3

Cutting edge activities challenge tax rules written with different business methods and products in mind. For example, cloud computing raises issues as to how longstanding tax provisions, such as the research tax credit and Section 199 manufacturing deduction apply. This and other current tax topics relevant to high tech companies and their tax advisers are on the agenda for the 31st Annual TEI-SJSU High Tech Tax Institute, November 9 & 10, 2015 in Palo Alto. Additional topics include BEPS Relevance, M&A activities, state tax haven activities, European Union hot topics and how these topics also affect the income tax provision on financial statements.

For the complete agenda and list of speakers, as well as to register, please visit Read more

BEPS – The View From Around the World

Annette Nellen2

We hear a lot about the OECD’s BEPS project (base erosion and profit shifting) and its action items. What is the relevance of “country-by-country” reporting for transfer pricing documentation? Does the statement on harmful tax practices mean that the US should adopt a patent box? The 31st Annual TEI-SJSU High Tech Tax Institute, scheduled for November 9 and 10, 2015 in Palo Alto, will address these questions and more. A BEPS panel will include attorneys from China, Ireland and the U.S. to share how other countries are responding the BEPS project and what it means for your company or clients.  Another panel with practitioners from the UK and Ireland will explore hot topics in the EU. Heather Maloy, (former) Commissioner for the IRS Large Business & International Division will also be speaking, along with numerous other experts on hot tax topics for high tech Read more

Structuring Investment in India – Does Mauritius Holdco Work?

Pallav Acharya2

Tax authorities worldwide distaste the word “treaty shopping” as such. In recent times, OECD has worked out guidelines for BEPS and most U.S. tax treaties have “Limitation of Benefit” clause that prevents abusive tax planning. However, there may still be some opportunities available to U.S. investors in India; one such avenue is investing via Mauritius Holdco structures.

A lot of foreign investors prefer to route their investment through Mauritius in India. Since the India- Mauritius double tax avoidance agreement offers exemption from capital gains tax to Mauritian residents. It has been the key incentive provided by the Indo-Mauritius tax treaty where by tax on capital gains is exempted for investors from Mauritius. As per the last finance bill almost 42% of the foreign direct investment into India is routed through Read more

How Are You Preparing For BEPS?

Tax Blog

International Tax Review / TPWeek interviewed 180 leading in-house tax professionals to discover their opinions on the Base Erosion and Profit Shifting (BEPS) project and what shape their transfer pricing strategies are taking as final BEPS guidance draws near. As the Infographic shows below, the approach of these tax executives proved to be very interesting.

Where do you and your tax organization stand on being prepared for BEPS? Are you being proactive in your approach for responding to BEPS? Are you doing nothing at all until the project is finalized?

See Infographic below: Read more

BEPS And Planet Mars

TaxConnections Picture - Alien - 8-24-15 - square

NASA recently announced that your name can be put on the planet Mars. This is incredibly great news for the people with good fortunes who are thrilled by the opportunity to gain their foothold in the universe and enhance their fame. However, in another space mission, scientists are attempting to find out if any life exists in other planets.

Think about it. If they indeed were able to find the life on Mars and if the inhabitants there happen to be much more advanced than the humans on earth, they are likely to have a tax law that can tax such inbound activities. Beware and think before you make that tempting decision.

Putting your name on a planet may have its other side. If “cross planet” law applies and Read more

Industry Tax And Transfer Pricing Leaders To Discuss BEPS Integration of Technology

International Tax Review - 7-21-15

Corporate Heads of Tax and Transfer Pricing will meet to discuss how best to approach the issue of integrating technology systems in light of pending BEPS guidance.

The leaders will meet in Washington DC on September 24 and 25 at the Park Hyatt hotel as part of TPWeek and International tax Review’s Global transfer Pricing Forum.

The forum opens with a panel discussion on technology responses to BEPS and will look at operational TP, data analytics and country-by-country reporting.

As the BEPS process continues to evolve, one thing that is clear is that taxpayers will face a need for more information and greater reporting to various tax authorities. Read more

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