World Bank approves grant to improve domestic revenue mobilization in Liberia
On 16 July 2019 the World Bank approved a grant to its International Development Association (IDA) to improve domestic revenue mobilization systems and strengthen financial control and accountability in public finances. The IDA provides grants and
See MoreNetherlands: Cabinet submits new bill against tax avoidance
The Dutch government published a legislative proposal engaging rules to counter hybrid mismatches into the Dutch corporate income tax act pursuant to the EU Anti-Tax Avoidance Directive as agreed upon in May 2017 (ATAD2). ATAD2 would address tax
See MoreSouth Africa issues draft explanatory memorandum on TLAB
The South African National Treasury has published Draft Explanatory Memorandum on the initial batch of the 2019 draft Taxation Laws Amendment Bill (TLAB) on 10 June 2019 to cover specific provisions that require additional consultation, and is
See MoreNew Zealand: Inland Revenue publishes revised transfer pricing regime
On 29 April 2019, Inland Revenue published the final versions of the special reports on the new rules for base erosion and profit shifting (BEPS). The rules were enacted in the Taxation (Neutralising Base Erosion and Profit Shifting) Act 2018 on 27
See MoreOECD: Consultation on Addressing Tax Challenges of the Digital Economy
On 13 and 14 March 2019 the OECD is to hold a public consultation on the tax challenges of the digitalisation of the economy. This is related to the work on action 1 of the G20/ OECD action plan on base erosion and profit shifting. The consultation
See MoreUK: Summary of responses to consultation on tax abuse and insolvency
On 7 November 2018 the UK government published a summary of responses to the consultation on tax abuse and insolvency held earlier in 2018. In April 2018 the government issued a consultation document exploring ways to combat the deliberate abuse of
See MoreIreland announces Budget for 2019
On 9 October 2018, the Budget for 2019 was presented to Parliament by the Minister of Finance. The summary of 2019 Budget measures are following: Corporate Tax Film Relief The scheme provides relief in the form of a corporation tax credit related to
See MoreNetherlands: Budget Proposals 2019
On 18 September 2018, the government of Netherlands presented the 2019 budget proposals to the House of Representatives. Implementation of ATAD measures The Proposals put forward legislation that introduces various EU Anti-Tax Avoidance Directive
See MoreAustralia: ATO issues draft schedule concerning cross border related party financing arrangements
On 1 August 2018, the Australian Taxation Office (ATO) issued a draft Schedule 2 to PCG 2017/4 for public consultation. This guidance addresses the ATO’s compliance approach to taxation issues associated with cross border related party
See MoreNew Zealand’s taxation act regarding Neutralising Base Erosion and Profit Shifting receives royal assent
New Zealand's Taxation (Neutralising Base Erosion and Profit Shifting) Act received royal assent on 27 June 2018. The main measures of the Act are summarized as follows: CbC reporting requirement: According to the published guidance on
See MoreLuxembourg: Cabinet approves draft law for implementation of EU anti-tax avoidance directive
On 15 June 2018, the Luxembourg Cabinet approved a draft bill providing for measures to implement the EU Anti-Tax Avoidance Directive (ATAD). The draft bill includes the new provisions on the limitation of interest deduction, which limit the
See MoreBelgium issues a draft bill to introduce some tax measures
On 11 June 2018, a draft bill was submitted to the parliament to complete and amend the corporate income tax reform of 2017. The bill contains a new anti-abuse provision for notional interest deduction (NID) and clarifies that the reduction of
See MoreNetherlands: Dutch Council of Ministers approves fiscal policy agenda
The Council of Ministers approved the fiscal policy agenda on a package to combat tax avoidance and tax evasion. The most important changes are summarized below: Corporate Income Tax (CIT) rate: According to the Agenda, the current standard Dutch
See MoreUS Tax Cuts and Jobs Act: Global Intangible Low-Taxed Income
The US Tax Cuts and Jobs Act has introduced various new provisions to counter base erosion and profit shifting by US corporations. These include a base erosion minimum tax, provisions to counter income shifting by intangible property transfers and
See MoreUS Tax Cuts and Jobs Act: Income Shifting by Intangible Property Transfers
A U.S. person transferring intangible property to a foreign corporation in a transaction that would otherwise qualify for non-recognition treatment is generally treated as having sold the intangible property in exchange for payments contingent on
See MoreUS Tax Cuts and Jobs Act: Hybrid Transactions and Hybrid Entities
A group could set up an entity that is treated as fiscally transparent for U.S. federal tax purposes but is treated as an entity in the country in which it is resident or subject to tax. Similarly, an instrument may be treated as debt in one country
See MoreUS Tax Cuts and Jobs Act: Base Erosion Minimum Tax
The Tax Cuts and Jobs Act provides for a participation exemption in the form of a 100% deduction for the foreign-source portion of dividends received from 10%-owned foreign corporations. This deduction for dividends received can eliminate additional
See MoreUK: Consultation on conditionality measures to combat hidden economy
On 8 December 2017 HMRC published a consultation document entitled Tackling the hidden economy: public sector licensing. The document looks at measures that make compliance with tax obligations a condition of obtaining certain licenses and introduce
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