Combatting Tax Crimes More Effectively in APEC Economies

October 15, 2019

Tax evasion and related financial crime threaten the strategic, political, and economic interests of all countries. Recognising the threat that such illicit financial flows pose to the Asia-Pacific region, APEC Finance Ministers developed the Cebu Action Plan, a roadmap for a more sustainable financial future, calling on all APEC Economies to build their capacity to address […]

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Exchange of information: disputes multiply

October 14, 2019

Jonathan Schwarz (Temple Tax Chambers; King’s College London)/October 14, 2019  Some four years ago in this blog, I wrote about problems that would start to emerge as exchange of information between tax administrations became more routine and extensive.  If nothing else, the number of disputes in this area was bound to increase. See also Exchange of Information: bumps in […]

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OECD Pillar One and Two explained

October 14, 2019

The OECD has now two proposals in process:  Pillar One addresses the digital economy and Pillar Two sets forth a global minimum tax system; global anti-base erosion (GloBE) proposal.  The proposals are linked herein for reference.Both proposals may have one or more legal entities of a multinational taxed on more than one approach, whether they have a digital […]

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OECD Consulting on Digital Tax

October 10, 2019

The OECD published for stakeholders’ comments a proposal to advance international negotiations to ensure that multinational enterprises (MNEs), including digital companies, pay tax wherever they have significant consumer-facing activities and where they generate profits. The proposal – Secretariat Proposal for a Unified Approach – would re-allocate some profits and corresponding taxing rights to countries and jurisdictions where […]

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NEW book: Transfer Pricing and Value Creation

October 10, 2019

Recently published:Petruzzi/TavaresTransfer Pricing and Value Creation, Linde-Verlag Dear Colleagues, The Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business), is pleased to inform you about our most recent publication:Petruzzi/Tavares (Eds.) Transfer Pricing and Value Creation Linde Verlag 2019. Series on International Tax Law, vol. nr. 116ISBN: 9783707341232 Value Creation and […]

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Pieterse TRM Erasmus INC win another tax matter against SARS

October 10, 2019

Pieterse TRM Erasmus Inc won another matter yesterday with SARS conceding defeat after the filing of a Rule 32 court response. SARS realised that their procedural steps were fatally flawed. They had provided very scant reasons ( a few words – “insufficient evidence”) on assessment. However, they also effectively conceded the merits of the matter […]

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UN recommends African States update fiscal laws…and Zambia abandons Sales Tax

October 10, 2019

 Africa Business in Brief – 7 OCT 2019ENSafricaThe United Nations urged all African countries to reform their fiscal laws in order to enhance their tax revenues from the Digital Economy… Zambia sales tax abandonedENSafrica The Zambian Minister of Finance in his 2020 Budget Speech of Friday, 27 September 2019, announced that the government is abandoning […]

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Byrnes’ Comments on the OECD’s “Unified Approach” to Allocation of Profits of Digital Business

October 10, 2019

BEPS, DIGITAL SERVICES TAX, DIGITALIZATION, OECD, PERMANENT ESTABLISHMENTS, TRANSFER PRICING William Byrnes (Texas A&M University Law)/October 10, 2019  In my International Taxation class tomorrow (October 10th) we are going to discuss the  OECD’s “Unified Approach” released a day earlier on October 9, 2019.  Given the keen interest generated by digital taxation and the allocation of profits/losses generated therefrom, I thought it of interest […]

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IRS Cryptocurrency guidelines

October 10, 2019

In 2014, the IRS issued Notice 2014-21, 2014-16 I.R.B. 938 (PDF), explaining that virtual currency is treated as property for Federal income tax purposes and providing examples of how longstanding tax principles applicable to transactions involving property apply to virtual currency.  The frequently asked questions (“FAQs”) below expand upon the examples provided in Notice 2014-21 and […]

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Financial fraud concerns that will impact tax fraud against corporates

October 10, 2019

There is a growing concern that accounting practices are bordering on rubber-stamping what could be classified as fraudulent activities. “Fraud” is widely defined as: “a person or thing intended to deceive others, typically by unjustifiably claiming or being credited with accomplishments or qualities.” AND “wrongful … deception intended to result in financial or personal gain…”[which […]

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