UK: Consultation on secondary adjustments in transfer pricing legislation
On 26 May 2016 the UK has published a consultation document on the possible introduction of secondary adjustments into the UK transfer pricing legislation. This would in the opinion of the UK government help to ensure taxpayer compliance with the
See MoreCanada: First reading of federal budget bill 2016 received
Federal budget bill 2016, Bill C-15, has received first reading on 20th April 2016 that contains some of the proposals announced by the 2016 federal budget. It also includes several measures, such as changes affecting the inter-corporate dividend
See MoreOECD: JITSIC to discuss tax avoidance risks
A meeting of the Joint International Tax Shelter Information and Collaboration (JITSIC) network is to take place on 13 April 2016 to discuss further options for cooperation following the publicity surrounding the documents referred to as the Panama
See MoreOECD: Consultation document on treaty access for non-CIV funds
The OECD has issued a consultation document inviting comments on issues arising from the tax treaty entitlement of non-CIV vehicles. This consultation follows on from the final report on action 6 of the project on base erosion and profit shifting
See MoreUK: Responses to call for evidence on cash and noncompliance
On 24 March 2016 HMRC published a summary of responses to the call for evidence on cash, tax evasion and the hidden economy. The call for evidence had asked for views on the relative decline in the use of cash and its impact on tax compliance, the
See MoreUK: HMRC Clarifies Approach to Taxing Multinationals
The UK Parliament’s Public Accounts Committee is taking evidence on 11 February 2016 in relation to the tax affairs of multinational enterprises. In advance of the parliamentary hearing the UK tax authority HMRC has published a factsheet on its
See MoreEuropean Commission publishes Anti Tax Avoidance Package
The European Commission published its Anti Tax Avoidance Package on 28 January 2016. This package consists of the following main elements: Anti Tax Avoidance Directive The provisions of a proposed Anti Tax Avoidance Directive have been published
See MoreOECD: Multilateral Competent Authority Agreement for exchange of CbC reports
On 27 January 2016 thirty-one countries signed a Multilateral Competent Authority Agreement for the automatic exchange of Country by Country (CbC) reports. The Agreement will facilitate speedy implementation of the CbC reporting requirement as set
See MoreAustralia: Multinational anti tax avoidance bill receives Royal Assent
On 11 December 2015, Further to its passing by Parliament on 3 December 2015 the Tax Laws Amendment (Combating Multinational Tax Avoidance) Bill 2015 received Royal Assent. The Bill implements a new anti avoidance rule designed to counter the
See MoreAustralian Senate passes Government’s multinational anti tax avoidance measures
The Turnbull Government has secured the passage of the Tax Laws Amendment (Combating Multinational Tax Avoidance) Bill, a critical piece of legislation, which will ensure major international companies operating in Australia but booking profits
See MoreUK: Autumn Statement Includes Measures Effective from 25 November 2015
The Chancellor of the Exchequer delivered his Autumn Statement to Parliament on 25 November 2015. The measures with immediate effect from 25 November 2015 are as follows: Loans to participators, trustees of charitable trusts: This measure affects
See MoreUK: Corporation tax and large companies
A report published by a UK accounting firm indicates that 85 of the companies in the FTSE 350 index paid corporation tax at a rate of less than 5% on their accounting profits; a further 8 companies paid less than 10% of their profits in corporation
See MoreEuropean Union: Anti abuse clause added to parent subsidiary directive
On 27 January 2015 the Council of the European Union (EU) amended the parent subsidiary directive to add a binding anti-abuse clause. This is designed to prevent tax avoidance and aggressive tax planning, and to ensure more consistency in the
See MoreNew Russian CFC and anti-avoidance legislation
The amended draft law regarding controlled foreign companies and other anti-offshore measures has done most valuable changes in the field of foreign tax structures and tax avoidance. This law has publicly available on 27 May, 2014. It highlights
See MoreUnited Kingdom – HMRC report on offshore tax evasion
The United Kingdom government is continuing to take action against artificial tax avoidance and tax evasion. In this connection the tax administration (HMRC) has issued a "corporate report," which sets out how HMRC addresses offshore tax evasion and
See MoreCanada – Evaluation of GST/HST information
The Canadian Revenue Agency has began to judge the “hefty penalties” regarding the GST/HST annual information return that many large businesses and financial institutions in Canada are needed to report. The penalties (which can be as high as
See MoreNew Zealand: Taking Tough Stance on Tax Avoidance
A former businessman has been punished recently over a total of 87 tax-related charges, and the Inland Revenue Department of New Zealand has warned that it will continue with its “zero tolerance” approach to tax evasion. This approach to
See MoreUK: HMRC issues revised GAAR guidance
HMRC’s latest guidance on the application of the General Anti-Abuse Rule (GAAR) was approved by the GAAR Advisory Panel on 15 April 2013. This guidance summarizes what the GAAR is intended to achieve and how it operates to arrive at this
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