Australia: ATO cautions taxpayers on schemes avoiding division 7A compliance
The Australian Taxation Office (ATO) has issued a new taxpayer alert (TA2024/2) on 12 December 2024 targeting arrangements designed to bypass Division 7A requirements. The arrangements involve a profitable private company guaranteeing a loan made
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Australia consults expansion of penalty laws for tax exploitation scheme promoters
Australia’s government is requesting feedback on proposals to expand the penalty laws for promoters of tax exploitation schemes. The Treasury released the public consultation document on 4 October 2024, and interested stakeholders are
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OECD: Tax Arbitrage Through Closely Held Businesses
On 7 October 2024 the OECD published a taxation working paper with the title Tax arbitrage through closely held businesses: Implications for OECD tax systems, written by Tom Zawisza, Sarah Perret, Pierce O’Reilly and Antonia Ramm. The working
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EU Commission reviews anti-avoidance tax directive
The European Commission has announced an initiative to evaluate the Anti-Avoidance Tax Directive (ATAD), which will also include a public consultation. The ATAD lays down minimum standard rules to address the most common forms of aggressive tax
See MoreUN: High-Level Dialogue on Financing for Development
On 20 September 2023 the UN held a high-level dialogue on financing for development, including a session on Promoting inclusive and effective international tax cooperation and mobilizing domestic resources. Keynote addresses were given by the
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UK: More Severe Penalties for Promoters of Tax Avoidance
On 27 April 2023 the UK issued a consultation document on more severe penalties for promoters of tax avoidance, inviting comments from interest parties by 22 June 2023. Criminal offence for failure to comply with a Stop Notice The document
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UK: Transfer Pricing and Diverted Profits Tax Statistics
On 7 February 2022 HMRC published the latest set of statistics relating to transfer pricing and the diverted profits tax. The latest release contains data up to end of the 2022/22 tax year. The transfer pricing work is an important part of
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 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 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
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