Identifying opportunities for BEPS in the digital economy.
This chapter provides a general discussion of the common features of tax planning structures that raise base erosion and profit shifting (BEPS) concerns. It then provides a detailed description of the core elements of BEPS strategies with respect to both direct and indirect taxation.
A Critical Evaluation of the OECD's BEPS ProjectRamon Tomazela
This document provides a critical analysis of the OECD's BEPS (base erosion and profit shifting) project from the perspective of an international tax law expert. It summarizes key actions and proposals from the BEPS project, and identifies challenges. Action 1 addresses taxing the digital economy, but determining which states can tax and allocating taxable profits will be difficult. Action 2 aims to prevent tax benefits from hybrid financial instruments and entities, but linking tax treatments across countries relies on debatable principles of international tax law. The BEPS project may be insufficient to fully address issues caused by economic changes and requires radical tax law reforms.
The document provides an overview of BEPS (Base Erosion and Profit Shifting) which refers to tax avoidance strategies used by multinational enterprises to artificially shift profits to low or no-tax jurisdictions. It summarizes the key actions and recommendations from the OECD's BEPS project to address this issue, including establishing new minimum standards around preventing treaty abuse, improving transparency through country-by-country reporting, and strengthening transfer pricing rules and controlled foreign company rules. It also discusses some of the changes made in India's tax regime to tackle BEPS concerns related to the digital economy, hybrid mismatches, interest deductions, and harmful tax practices.
The document discusses the OECD's Base Erosion and Profit Shifting (BEPS) Action Plan, which aims to address tax avoidance strategies used by multinational enterprises. The Action Plan was released in 2013 and covers 15 specific actions to be completed by the end of 2015. It focuses on three main pillars: ensuring coherence of corporate tax and the digital economy, improving transparency, and aligning taxation with substance. One of the actions addressed is transfer pricing aspects of intangibles. The guidance in this area aims to prevent BEPS resulting from improper allocation of intangible returns. It provides definitions of intangibles and discusses factors like functions, assets, and risks that determine which entity is entitled to returns from int
Curbing profit shifting in international transaction un oecd model _ JenaChidananda Jena
The document discusses various ways that multinational enterprises shift profits for tax avoidance purposes. It begins by covering the use of tax holidays and incentives, capital allowances, inter-company transactions like royalty payments and management fees, and selling goods through low-tax countries. It then contrasts the challenges facing developing versus developed countries in addressing profit shifting. Finally, it outlines the scope for profit shifting across different types of income like business profits, dividends, interest, royalties, and more to avoid taxation.
International Tax Planning as Viewed through the Eyes of BEPSLewis Rice
Lewis Rice attorney Timothy G. Stewart co-presented to the St. Louis International Tax Group on the OECD's efforts to address Base Erosion and Profit Shifting.
A Critical Evaluation of the OECD's BEPS ProjectRamon Tomazela
This document provides a critical analysis of the OECD's BEPS (base erosion and profit shifting) project from the perspective of an international tax law expert. It summarizes key actions and proposals from the BEPS project, and identifies challenges. Action 1 addresses taxing the digital economy, but determining which states can tax and allocating taxable profits will be difficult. Action 2 aims to prevent tax benefits from hybrid financial instruments and entities, but linking tax treatments across countries relies on debatable principles of international tax law. The BEPS project may be insufficient to fully address issues caused by economic changes and requires radical tax law reforms.
The document provides an overview of BEPS (Base Erosion and Profit Shifting) which refers to tax avoidance strategies used by multinational enterprises to artificially shift profits to low or no-tax jurisdictions. It summarizes the key actions and recommendations from the OECD's BEPS project to address this issue, including establishing new minimum standards around preventing treaty abuse, improving transparency through country-by-country reporting, and strengthening transfer pricing rules and controlled foreign company rules. It also discusses some of the changes made in India's tax regime to tackle BEPS concerns related to the digital economy, hybrid mismatches, interest deductions, and harmful tax practices.
The document discusses the OECD's Base Erosion and Profit Shifting (BEPS) Action Plan, which aims to address tax avoidance strategies used by multinational enterprises. The Action Plan was released in 2013 and covers 15 specific actions to be completed by the end of 2015. It focuses on three main pillars: ensuring coherence of corporate tax and the digital economy, improving transparency, and aligning taxation with substance. One of the actions addressed is transfer pricing aspects of intangibles. The guidance in this area aims to prevent BEPS resulting from improper allocation of intangible returns. It provides definitions of intangibles and discusses factors like functions, assets, and risks that determine which entity is entitled to returns from int
Curbing profit shifting in international transaction un oecd model _ JenaChidananda Jena
The document discusses various ways that multinational enterprises shift profits for tax avoidance purposes. It begins by covering the use of tax holidays and incentives, capital allowances, inter-company transactions like royalty payments and management fees, and selling goods through low-tax countries. It then contrasts the challenges facing developing versus developed countries in addressing profit shifting. Finally, it outlines the scope for profit shifting across different types of income like business profits, dividends, interest, royalties, and more to avoid taxation.
International Tax Planning as Viewed through the Eyes of BEPSLewis Rice
Lewis Rice attorney Timothy G. Stewart co-presented to the St. Louis International Tax Group on the OECD's efforts to address Base Erosion and Profit Shifting.
This document discusses the OECD's BEPS project and its potential impact on small and medium enterprises. It provides an overview of the 15 actions under the BEPS project, including addressing tax challenges in the digital economy, limiting base erosion from interest deductions, and improving transparency through country-by-country reporting. While the changes are aimed at large multinational corporations, the document notes they could still affect SMEs through shifts in public opinion, tax authority stances, and domestic tax laws. The document also examines perspectives and initial responses to BEPS from several countries and regions, including Ireland, Luxembourg, the Netherlands, and the United States.
Panel 10 : Managing Transfer Pricing Risks - By Ms.Marlies de Ruitertaxsutra
The document summarizes guidance from the OECD/G20 BEPS project on aligning transfer pricing and value creation. It provides six sections of guidance: (1) applying the arm's length principle, (2) commodity transactions, (3) transactional profit splits, (4) intangibles, (5) low-value services, and (6) cost contribution arrangements. It also outlines requirements for transfer pricing documentation under Action 13. The guidance establishes frameworks for delineating transactions and evaluating economically relevant characteristics to determine appropriate transfer pricing in intercompany arrangements.
Session by Achim Pross, Head, International Co-operation and Tax Administration Division, OECD Centre for Tax Policy and Administration, Meeting of the OECD Parliamentary Group on Tax, 19 Oct 2015
In July 2013 the OECD unveiled the Action Plan on Base Erosion and Profit Shifting (BEPS), which aims to develop a new set of standards to prevent double non-taxation and ensure that profits are taxed where they are actually generated. By Grace Perez-Navarro, Deputy Director, and Raffaele Russo, Head of the BEPS Project, Centre for Tax Policy and Administration.
Transfer Pricing Forum: Transfer Pricing for the International PractitionerMatheson Law Firm
Tax Partner, Catherine O’Meara, wrote an update for Bloomberg Tax on recent developments in Ireland’s transfer pricing rules. The article provides an update on the type of audit activity we are seeing in Ireland under transfer pricing rules, the incorporation of the revised OECD Transfer Pricing Guidelines into Irish law and Ireland’s transfer pricing documentation requirements.
PwC Global Mobility Insights - Cooperative CompliancePeter Clarke
Cooperative compliance agreements between tax authorities and companies allow companies to streamline tax compliance for mobile employees. These agreements eliminate individual tax filings if the company pays the proper tax amount through payroll withholding. This yields cost savings and efficiency. However, companies must have a robust compensation withholding system to qualify and properly assess any risks of agreements. Examples provided are the UK's real-time information processes and the Netherlands' and Malaysia's approaches.
The document summarizes developments regarding the OECD's Base Erosion and Profit Shifting (BEPS) initiative and actions taken by the European Commission to investigate alleged state aid provided by tax rulings in Luxembourg. Key points include the OECD releasing final reports on various BEPS actions in September 2014, the EC opening investigations into tax rulings for Fiat Finance and Trade and Amazon, and debates around the implications of these investigations and challenges to perceived tax avoidance through state aid rules.
International taxation and transfer pricing for transfer pricing ssuser47f0be
This document discusses international taxation and transfer pricing. It provides an overview of key concepts in international taxation such as double taxation, foreign tax credits, and tax treaties. It also discusses transfer pricing regulations and guidelines from the OECD and IRS that require transactions between related parties to be conducted at arm's length prices comparable to third party transactions. The document outlines methods used to determine appropriate transfer prices such as cost-plus and resale price methods.
The summary provides an overview of the key corporate taxes in Colombia that should be considered for business models, including income tax, VAT, excise taxes, property taxes, and more. It explains how various taxes work at the national, departmental, and municipal levels, such as income tax rates and categories, VAT rates, excise taxes on goods like fuel and carbon, and property taxes. The document also covers special tax regimes for holding companies and foreign-controlled companies.
Presentation delivered by Angie Pulley, Director, Income Tax, Planning and Accounting, Coca Cola Bottling Company at the Tax Officers Summit 2016 in FL
Grant Thornton - Indirect tax in China - a VAT reform programme is introduced...Grant Thornton
The document discusses a VAT reform pilot program introduced in Shanghai on January 1, 2012 to replace business tax with VAT for certain industries and services. This marks the beginning of replacing China's current dual indirect tax system with a unified VAT system applied to all goods and services. The pilot program is expected to generally lower indirect tax rates for affected Shanghai businesses, though not in all cases. It also provides details on the industries now subject to VAT instead of business tax and applicable VAT rates under the new system.
A corporate group exists when there is a relationship of subordination (control) between companies, along with a shared purpose and management determined by the parent company. The controlling company must register the corporate group within 30 business days with the Commercial Registry. Failure to register on time can result in sanctions from the Superintendence of Companies of up to 200 minimum legal monthly salaries. An affiliate is directly controlled by a parent company, while a subsidiary is controlled by subordinated companies of the parent.
Panel 7 : Base Erosion & Profit Shifting (BEPS)taxsutra
The document discusses key issues related to the Base Erosion and Profit Shifting (BEPS) project and its implementation. It summarizes reactions to BEPS and debates around source vs residence taxation. It raises concerns about whether BEPS adequately addresses issues for developing countries. It also examines important technical issues like the impact of changes to permanent establishment standards and transfer pricing rules, as well as challenges around implementing BEPS within countries and achieving a multilateral agreement. Finally, it discusses the overall impact of BEPS on tax structures, compliance costs, and litigation risks.
This document discusses the allocation and apportionment of expenses and how it affects foreign tax credit benefits. It covers key definitions such as class of income, statutory groupings, and residual groupings. It provides examples of how interest, research and experimental, stewardship, and state taxes and charitable deductions are allocated and apportioned. It also discusses adopting a plan to apportion selling, general and administrative expenses. The document examines how expense apportionment impacts the calculation of foreign source taxable income and the foreign tax credit limitation.
The summary provides an overview of the main taxes in Colombia that should be considered for business models, including national taxes like income tax, VAT, national excise tax, and regional taxes. Income tax rates range from 20% to 31%. VAT is generally charged at 19% but some goods and services are exempt. Various other taxes apply to activities like financial transactions, gasoline, vehicles, cigarettes, and alcohol. The document provides brief descriptions of how these different taxes work.
This document discusses corporate tax reform in Albania. It argues that corporate tax reform could improve the country's competitiveness and economic growth while maintaining government revenue. Specifically, it suggests lowering the statutory corporate tax rate from 15% through revenue-neutral options, such as limiting interest expense deductions or reviewing taxes on small and medium enterprises. However, any reform needs to balance competing priorities like economic efficiency, equity across industries, and deficit reduction. Accompanying social security reforms may also be needed to alleviate burdens from corporate tax changes.
The document summarizes the global efforts to reform international corporate taxation of multinational corporations (MNCs). It discusses existing issues like base erosion and profit shifting (BEPS) and measures taken by OECD and countries. It then summarizes the recent agreement by G7 countries to support OECD's two pillar approach for taxing MNCs. Pillar One aims to reallocate some profits to market jurisdictions. Pillar Two proposes a global minimum corporate tax of 15%. The agreement could significantly impact tax havens and boost tax revenues but also faces challenges in implementation.
Key Takeaways:
- Background and Overview of Legal Provision
- Facts of the Case
- Contentions of the Assessee and Revenue
- Supreme Court’s Verdict
- Key Learnings and Way Forward
This document provides an overview of the taxation of foreign taxpayers in the United States. It discusses two types of income subject to tax: income effectively connected to a U.S. business, which is taxed at progressive rates, and fixed or determinable annual or periodic income from U.S. sources, which is generally taxed at a 30% rate. Exceptions include portfolio interest, interest on securities, and gains from the sale of property that are not effectively connected. The Foreign Investment in Real Property Tax Act treats gains from the sale of U.S. real property as effectively connected income. The branch profits tax and earnings stripping rules aim to prevent base erosion through interest payments between related parties.
The document discusses the OECD's proposals under Pillars 1 and 2 of the BEPS 2.0 project. Pillar 1 aims to establish a new nexus rule and profit allocation framework to address tax challenges from the digitalization of the economy. It proposes allocating additional taxing rights to market jurisdictions based on factors like user participation and marketing intangibles. Pillar 2 introduces the Global anti-Base Erosion proposal consisting of an income inclusion rule and undertaxed payments rule to ensure a minimum level of taxation. It seeks to limit profit shifting, but countries have concerns around its economic and political impacts as well as challenges reaching consensus by the 2020 deadline.
This document provides an overview of base erosion and profit shifting (BEPS) and the OECD's BEPS Action Plan. It discusses how MNEs have engaged in tax planning to artificially shift profits to low/no tax locations. In response, the OECD published an Action Plan in 2013 to address BEPS in a comprehensive manner through 15 actions. The actions are structured around reinforcing substance requirements, aligning taxation with economic activity, and improving transparency. The document then summarizes some of the specific actions, including addressing tax challenges of the digital economy and neutralizing the effects of hybrid mismatches.
This document discusses the OECD's BEPS project and its potential impact on small and medium enterprises. It provides an overview of the 15 actions under the BEPS project, including addressing tax challenges in the digital economy, limiting base erosion from interest deductions, and improving transparency through country-by-country reporting. While the changes are aimed at large multinational corporations, the document notes they could still affect SMEs through shifts in public opinion, tax authority stances, and domestic tax laws. The document also examines perspectives and initial responses to BEPS from several countries and regions, including Ireland, Luxembourg, the Netherlands, and the United States.
Panel 10 : Managing Transfer Pricing Risks - By Ms.Marlies de Ruitertaxsutra
The document summarizes guidance from the OECD/G20 BEPS project on aligning transfer pricing and value creation. It provides six sections of guidance: (1) applying the arm's length principle, (2) commodity transactions, (3) transactional profit splits, (4) intangibles, (5) low-value services, and (6) cost contribution arrangements. It also outlines requirements for transfer pricing documentation under Action 13. The guidance establishes frameworks for delineating transactions and evaluating economically relevant characteristics to determine appropriate transfer pricing in intercompany arrangements.
Session by Achim Pross, Head, International Co-operation and Tax Administration Division, OECD Centre for Tax Policy and Administration, Meeting of the OECD Parliamentary Group on Tax, 19 Oct 2015
In July 2013 the OECD unveiled the Action Plan on Base Erosion and Profit Shifting (BEPS), which aims to develop a new set of standards to prevent double non-taxation and ensure that profits are taxed where they are actually generated. By Grace Perez-Navarro, Deputy Director, and Raffaele Russo, Head of the BEPS Project, Centre for Tax Policy and Administration.
Transfer Pricing Forum: Transfer Pricing for the International PractitionerMatheson Law Firm
Tax Partner, Catherine O’Meara, wrote an update for Bloomberg Tax on recent developments in Ireland’s transfer pricing rules. The article provides an update on the type of audit activity we are seeing in Ireland under transfer pricing rules, the incorporation of the revised OECD Transfer Pricing Guidelines into Irish law and Ireland’s transfer pricing documentation requirements.
PwC Global Mobility Insights - Cooperative CompliancePeter Clarke
Cooperative compliance agreements between tax authorities and companies allow companies to streamline tax compliance for mobile employees. These agreements eliminate individual tax filings if the company pays the proper tax amount through payroll withholding. This yields cost savings and efficiency. However, companies must have a robust compensation withholding system to qualify and properly assess any risks of agreements. Examples provided are the UK's real-time information processes and the Netherlands' and Malaysia's approaches.
The document summarizes developments regarding the OECD's Base Erosion and Profit Shifting (BEPS) initiative and actions taken by the European Commission to investigate alleged state aid provided by tax rulings in Luxembourg. Key points include the OECD releasing final reports on various BEPS actions in September 2014, the EC opening investigations into tax rulings for Fiat Finance and Trade and Amazon, and debates around the implications of these investigations and challenges to perceived tax avoidance through state aid rules.
International taxation and transfer pricing for transfer pricing ssuser47f0be
This document discusses international taxation and transfer pricing. It provides an overview of key concepts in international taxation such as double taxation, foreign tax credits, and tax treaties. It also discusses transfer pricing regulations and guidelines from the OECD and IRS that require transactions between related parties to be conducted at arm's length prices comparable to third party transactions. The document outlines methods used to determine appropriate transfer prices such as cost-plus and resale price methods.
The summary provides an overview of the key corporate taxes in Colombia that should be considered for business models, including income tax, VAT, excise taxes, property taxes, and more. It explains how various taxes work at the national, departmental, and municipal levels, such as income tax rates and categories, VAT rates, excise taxes on goods like fuel and carbon, and property taxes. The document also covers special tax regimes for holding companies and foreign-controlled companies.
Presentation delivered by Angie Pulley, Director, Income Tax, Planning and Accounting, Coca Cola Bottling Company at the Tax Officers Summit 2016 in FL
Grant Thornton - Indirect tax in China - a VAT reform programme is introduced...Grant Thornton
The document discusses a VAT reform pilot program introduced in Shanghai on January 1, 2012 to replace business tax with VAT for certain industries and services. This marks the beginning of replacing China's current dual indirect tax system with a unified VAT system applied to all goods and services. The pilot program is expected to generally lower indirect tax rates for affected Shanghai businesses, though not in all cases. It also provides details on the industries now subject to VAT instead of business tax and applicable VAT rates under the new system.
A corporate group exists when there is a relationship of subordination (control) between companies, along with a shared purpose and management determined by the parent company. The controlling company must register the corporate group within 30 business days with the Commercial Registry. Failure to register on time can result in sanctions from the Superintendence of Companies of up to 200 minimum legal monthly salaries. An affiliate is directly controlled by a parent company, while a subsidiary is controlled by subordinated companies of the parent.
Panel 7 : Base Erosion & Profit Shifting (BEPS)taxsutra
The document discusses key issues related to the Base Erosion and Profit Shifting (BEPS) project and its implementation. It summarizes reactions to BEPS and debates around source vs residence taxation. It raises concerns about whether BEPS adequately addresses issues for developing countries. It also examines important technical issues like the impact of changes to permanent establishment standards and transfer pricing rules, as well as challenges around implementing BEPS within countries and achieving a multilateral agreement. Finally, it discusses the overall impact of BEPS on tax structures, compliance costs, and litigation risks.
This document discusses the allocation and apportionment of expenses and how it affects foreign tax credit benefits. It covers key definitions such as class of income, statutory groupings, and residual groupings. It provides examples of how interest, research and experimental, stewardship, and state taxes and charitable deductions are allocated and apportioned. It also discusses adopting a plan to apportion selling, general and administrative expenses. The document examines how expense apportionment impacts the calculation of foreign source taxable income and the foreign tax credit limitation.
The summary provides an overview of the main taxes in Colombia that should be considered for business models, including national taxes like income tax, VAT, national excise tax, and regional taxes. Income tax rates range from 20% to 31%. VAT is generally charged at 19% but some goods and services are exempt. Various other taxes apply to activities like financial transactions, gasoline, vehicles, cigarettes, and alcohol. The document provides brief descriptions of how these different taxes work.
This document discusses corporate tax reform in Albania. It argues that corporate tax reform could improve the country's competitiveness and economic growth while maintaining government revenue. Specifically, it suggests lowering the statutory corporate tax rate from 15% through revenue-neutral options, such as limiting interest expense deductions or reviewing taxes on small and medium enterprises. However, any reform needs to balance competing priorities like economic efficiency, equity across industries, and deficit reduction. Accompanying social security reforms may also be needed to alleviate burdens from corporate tax changes.
The document summarizes the global efforts to reform international corporate taxation of multinational corporations (MNCs). It discusses existing issues like base erosion and profit shifting (BEPS) and measures taken by OECD and countries. It then summarizes the recent agreement by G7 countries to support OECD's two pillar approach for taxing MNCs. Pillar One aims to reallocate some profits to market jurisdictions. Pillar Two proposes a global minimum corporate tax of 15%. The agreement could significantly impact tax havens and boost tax revenues but also faces challenges in implementation.
Key Takeaways:
- Background and Overview of Legal Provision
- Facts of the Case
- Contentions of the Assessee and Revenue
- Supreme Court’s Verdict
- Key Learnings and Way Forward
This document provides an overview of the taxation of foreign taxpayers in the United States. It discusses two types of income subject to tax: income effectively connected to a U.S. business, which is taxed at progressive rates, and fixed or determinable annual or periodic income from U.S. sources, which is generally taxed at a 30% rate. Exceptions include portfolio interest, interest on securities, and gains from the sale of property that are not effectively connected. The Foreign Investment in Real Property Tax Act treats gains from the sale of U.S. real property as effectively connected income. The branch profits tax and earnings stripping rules aim to prevent base erosion through interest payments between related parties.
The document discusses the OECD's proposals under Pillars 1 and 2 of the BEPS 2.0 project. Pillar 1 aims to establish a new nexus rule and profit allocation framework to address tax challenges from the digitalization of the economy. It proposes allocating additional taxing rights to market jurisdictions based on factors like user participation and marketing intangibles. Pillar 2 introduces the Global anti-Base Erosion proposal consisting of an income inclusion rule and undertaxed payments rule to ensure a minimum level of taxation. It seeks to limit profit shifting, but countries have concerns around its economic and political impacts as well as challenges reaching consensus by the 2020 deadline.
This document provides an overview of base erosion and profit shifting (BEPS) and the OECD's BEPS Action Plan. It discusses how MNEs have engaged in tax planning to artificially shift profits to low/no tax locations. In response, the OECD published an Action Plan in 2013 to address BEPS in a comprehensive manner through 15 actions. The actions are structured around reinforcing substance requirements, aligning taxation with economic activity, and improving transparency. The document then summarizes some of the specific actions, including addressing tax challenges of the digital economy and neutralizing the effects of hybrid mismatches.
International Business Transactions has indeed made the world smaller and more developed. However due to the free cross boundary transactions, business entities are now able to generate revenue and not pay the appropriate taxes in their respective countries.
The G20 Countries had assigned OECD to come up with some non tax evasion rules so that the countries of the world may accept the same without any dispute.
This presentation covers the BEPS Rules suggested by OECD and explains the changes in Tax Laws that India has incorporated in order to align with BEPS and to curb Tax Evasion.
This presentation was performed by my GMCS Team during the GMCS 2 Course at Mangalore Branch of SIRC of ICAI.
This document discusses developing a harmonized tax regime to foster small business development in the East African Community (EAC). It analyzes the different tax systems of EAC countries and how they affect small businesses. The informal sector plays a large role in EAC economies and small businesses need support to formalize. Different approaches to taxing small businesses are considered, including presumptive taxation based on indicators like turnover. Harmonizing definitions of small and medium enterprises and tax bases across countries could help, but implementing reforms faces challenges around equity, compliance, and preventing tax evasion.
Tax management within multinational enterprises (MNEs) has never been more challenging. 'Getting to grips with the BEPS Action Plan' is the latest Grant Thornton report exploring the OECD’s planned overhaul of the international tax system, what it means for businesses and how they can prepare.
This document discusses corporate tax avoidance by multinational companies in developing countries. It outlines how companies shift profits to tax havens through interest payments and transfer pricing. Two potential solutions discussed are limiting interest deductions to a percentage of earnings and improving transfer pricing methods. The document also suggests that an alternative minimum tax based on gross revenue could help address both profit shifting through deductions and transfer pricing. More research is needed to assess how alternative minimum taxes have worked in countries that have adopted them.
This document discusses revenue administration reform. It provides rationale for why reform may be needed, including inadequate tax collection, a poor investment climate, high corruption, and an inability to address sophisticated tax evasion. It then lists some key indicators that could point to weaknesses, such as tax revenue as a percentage of GDP, actual revenue collected compared to targets, and tax revenue gaps. Finally, it presents a methodology for diagnosing the root causes of deficiencies by examining a revenue administration system's various components and interactions.
This document discusses revenue administration reform. It provides rationale for why reform may be needed, including inadequate tax collection, a poor investment climate, high corruption, and an inability to address sophisticated tax evasion. It then lists some key indicators that could point to weaknesses, such as the tax to GDP ratio, differences between estimated and actual revenue, and the proportion of voluntary compliance. Finally, it introduces a methodology called the Congruence Model for comprehensively diagnosing the causes of deficiencies in a revenue administration.
Professionals in the tax community are tasked with developing planning strategies under existing statutory schemes that minimize or eliminate their clients’ global tax burden. It is these planning structures that draw the attention of tax authorities as causing the “erosion” of taxable income bases and consequently, the tax revenues for their respective countries.
BEPS: Action #1 - Addressing the tax challenges of the digital economyAlex Baulf
No new taxes or recommendations unique to the digital economy were suggested by the Organisation for Economic Co-operation and Development (OECD) but the door is still open for unilateral safeguard actions.
__Unlocking the Benefits of the VAT Flat Rate Scheme for Small Businesses_.pdfFarihaSaddique
You will find here
"Unlocking the Benefits of the VAT Flat Rate Scheme for Small Businesses". Also VAT flat rate scheme criteria for small businesses , Difference between flat rate scheme vat and main scheme?
This document provides an overview of the OECD/G20 Inclusive Framework agreement on Pillars One and Two of the Base Erosion and Profit Shifting (BEPS) project. Pillar One introduces new profit allocation and nexus rules that re-allocate some taxing rights over large multinational enterprises to market jurisdictions. Pillar Two establishes a global minimum corporate tax rate of 15% through two interlocking rules: the Income Inclusion Rule and Undertaxed Payment Rule. The agreement also outlines scope, thresholds, carve-outs, dispute prevention and resolution processes, and guidance for implementation.
Submission to the International Monetary Fund's Consultation on Economic "Spi...Dr Lendy Spires
This document provides recommendations from ActionAid International to the IMF's consultation on international tax spillovers. Key points include:
1) International tax reforms should consider macroeconomic impacts and inter-nation equity, not just domestic revenue impacts. Broader effects on financial stability, debt management, and development policy coherence should be analyzed.
2) The IMF is well-placed to develop methodologies for quantifying tax spillovers between countries from changes to domestic tax regimes. Baseline measurements of the international distribution of the corporate tax base would aid future assessments.
3) Reforms aimed at preventing base erosion and profit shifting should explicitly protect lower-income countries' tax bases and rights. Measures permitting source-based
Bloomberg Tax - Transfer Pricing Forum - The NetherlandsNavita Parwanda
The Summer 2019 Issue of the Transfer Pricing Forum issue contains country insights on “Taxation and digitalization of the economy” and forms an interesting update on the progress so far from 23 geographically spread out nations. The TP forum was showcased at the IFA London Congress in September 2019.
The Country report from the Netherlands focuses on practical questions posed by guidance and case law, including some practical recommendations.
The document summarizes tax issues in Vietnam discussed by the We Taxation and Transfer Pricing Sector Committee. It addresses five key areas: 1) VAT-related issues regarding VAT rates for export services and non-VAT clawbacks for failed oil and gas projects. 2) Restricted deductibility of advertising and promotional expenses. 3) Issues with tax treaty claims and treatment of capital transfers in real estate companies. 4) Foreign contractor withholding tax treatment related to warranties and distribution rights. 5) Simplifying documentation for foreign tax credits. Recommendations are provided for each area to improve tax regulations and create a more competitive investment environment.
OBJECTIVE
OECD Inclusive Framework released a public consultation document on matters where its members seek input from stakeholders in conducting this 2020 review. This webinar shall touch upon the issues relating to implementation, scope and content of CbC Reporting set out in the document for public consultation.
Multinationals are challenged by changing tax laws, accounting practices, valuation methods and penalties as administrations around the world clamp down on tax avoidance
This document provides an overview of indirect tax rates around the world, broken down by region. It lists the standard VAT/GST rate and any other rates that may apply in each country. For example, in Africa it lists that the standard VAT rate in Botswana is 12% with no other rates, while in Egypt the standard rate is 10% with rates ranging from 5-15%. It also provides brief summaries of customs duty and how it interacts with other indirect taxes. The document aims to give readers a quick reference to indirect tax rates globally.
Anatomy of Intangible Transfer Pricing Scheme, With A Focus on Corporate Rest...taxguru5
"Amidst the OECD's inclusionary efforts, many issues remain unresolved, particularly when it comes to the transfer of intangibles for the specific purpose of bus"
TaxGuru is a platform that provides Updates On Amendments in Income Tax, Wealth Tax, Company Law, Service Tax, RBI, Custom Duty, Corporate Law , Goods and Service Tax etc.
To know more visit https://taxguru.in/income-tax/anatomy-intangible-transfer-pricing-scheme-focus-corporate-restructurings.html
Anatomy of Intangible Transfer Pricing Scheme, With A Focus on Corporate Rest...taxguru5
"Amidst the OECD's inclusionary efforts, many issues remain unresolved, particularly when it comes to the transfer of intangibles for the specific purpose of bus"
TaxGuru is a platform that provides Updates On Amendments in Income Tax, Wealth Tax, Company Law, Service Tax, RBI, Custom Duty, Corporate Law , Goods and Service Tax etc.
To know more visit https://taxguru.in/income-tax/anatomy-intangible-transfer-pricing-scheme-focus-corporate-restructurings.html
Similar to Action 5. identifying the opportunities for beps in the digital economy (20)
This document discusses the Dickey-Fuller test for unit roots, which tests whether a time series is stationary or nonstationary. It presents the three regression equations used in the Dickey-Fuller test and the corresponding critical values. It then provides steps for performing the Dickey-Fuller test in EViews, including specifying the test type, level/difference of the series, regression model, lag length, and interpreting the test results by comparing the test statistic to the critical values.
The document summarizes the Toda-Yamamoto augmented Granger causality test.
[1] The test allows checking for causality between integrated variables of different orders without needing to determine cointegration. It involves estimating a VAR model with maximal order of integration lags added.
[2] The test procedure involves determining the order of integration (d), selecting the optimal lag length (k), setting the null and alternative hypotheses of no causality and causality, and calculating an F-statistic to test for causality.
[3] If the F-statistic exceeds the critical value, the null of no causality is rejected, indicating causality between the variables.
The document describes the standard Granger causality test procedure for determining whether changes in one time series (Xt) can help forecast changes in another (Yt).
[1] The test involves estimating a VAR model with the two time series and their lags, then comparing the restricted and unrestricted models to calculate an F-statistic.
[2] If the F-statistic exceeds the critical value, the null hypothesis that Xt does not help forecast Yt (or vice versa) is rejected, indicating Granger causality between the two time series.
[3] The test results help explain the relationship between the changes in the two time series by determining the direction of causality (if any
The document discusses augmented Dickey-Fuller (ADF) tests for detecting unit roots in time series data. It presents the three possible forms of the ADF test regression and describes how to determine the appropriate model. A procedure is outlined for selecting between models and testing whether time series contain deterministic trends, constants, or unit roots. The document also provides instructions for performing ADF tests in Eviews software, including specifying the test regression, lag length, and interpreting the test results.
The document describes the error correction model (ECM) version of Granger causality testing for determining the causal relationship between two non-stationary time series variables. It involves first testing for cointegration between the variables using the Johansen test or Engle-Granger approach. If cointegrated, the ECM version estimates an error correction model and performs Granger causality tests to examine short-run, long-run, and strong causality. The procedure and hypotheses for each test are provided along with the method for calculating the relevant F-statistics.
The document provides an overview of time series econometrics concepts including:
1) Time series econometrics analyzes the dynamic structure and interrelationships over time in economic data. It examines stationary and non-stationary stochastic processes.
2) A time series is stationary if its mean, variance, and autocovariance remain constant over time. A random walk process is a type of non-stationary process where the variable fluctuates around a stochastic trend.
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This document discusses using the bounds test approach within an autoregressive distributed lag (ARDL) model to test for cointegration and causality between time series variables. The ARDL model estimates error correction models involving the change in one variable (ΔYt or ΔXt) regressed on lags of itself and the other variable. The bounds test involves calculating an F-statistic and comparing it to critical value bounds - if the F-statistic exceeds the upper critical value bounds, then there is cointegration, and if it falls below the lower bounds, then there is no cointegration. The document provides the null and alternative hypotheses for the bounds test when each variable is the dependent variable in the error correction model. It also outlines the
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against which they can evaluate those classes of AI applications that are probably the most relevant for them.
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As an experienced Government Liaison, I have demonstrated expertise in Corporate Governance. My skill set includes senior-level management in Contract Management, Legal Support, and Diplomatic Relations. I have also gained proficiency as a Corporate Liaison, utilizing my strong background in accounting, finance, and legal, with a Bachelor's degree (B.A.) from California State University. My Administrative Skills further strengthen my ability to contribute to the growth and success of any organization.
Business law for the students of undergraduate level. The presentation contains the summary of all the chapters under the syllabus of State University, Contract Act, Sale of Goods Act, Negotiable Instrument Act, Partnership Act, Limited Liability Act, Consumer Protection Act.
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"Lifting the Corporate Veil" is a legal concept that refers to the judicial act of disregarding the separate legal personality of a corporation or limited liability company (LLC). Normally, a corporation is considered a legal entity separate from its shareholders or members, meaning that the personal assets of shareholders or members are protected from the liabilities of the corporation. However, there are certain situations where courts may decide to "pierce" or "lift" the corporate veil, holding shareholders or members personally liable for the debts or actions of the corporation.
Here are some common scenarios in which courts might lift the corporate veil:
Fraud or Illegality: If shareholders or members use the corporate structure to perpetrate fraud, evade legal obligations, or engage in illegal activities, courts may disregard the corporate entity and hold those individuals personally liable.
Undercapitalization: If a corporation is formed with insufficient capital to conduct its intended business and meet its foreseeable liabilities, and this lack of capitalization results in harm to creditors or other parties, courts may lift the corporate veil to hold shareholders or members liable.
Failure to Observe Corporate Formalities: Corporations and LLCs are required to observe certain formalities, such as holding regular meetings, maintaining separate financial records, and avoiding commingling of personal and corporate assets. If these formalities are not observed and the corporate structure is used as a mere façade, courts may disregard the corporate entity.
Alter Ego: If there is such a unity of interest and ownership between the corporation and its shareholders or members that the separate personalities of the corporation and the individuals no longer exist, courts may treat the corporation as the alter ego of its owners and hold them personally liable.
Group Enterprises: In some cases, where multiple corporations are closely related or form part of a single economic unit, courts may pierce the corporate veil to achieve equity, particularly if one corporation's actions harm creditors or other stakeholders and the corporate structure is being used to shield culpable parties from liability.
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12. From:
Addressing the Tax Challenges of the Digital
Economy
Access the complete publication at:
https://doi.org/10.1787/9789264218789-en
Please cite this chapter as:
OECD (2014), “Identifying opportunities for BEPS in the digital economy”, in Addressing the Tax Challenges
of the Digital Economy, OECD Publishing, Paris.
DOI: https://doi.org/10.1787/9789264218789-8-en
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