The Double Dividend of a Joint Tariff and VAT Reform: Evidence from Iran
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Analysis of Tax Developments Worldwide
www.pwc.com/its International Tax News Edition 78 August 2019 Welcome Keeping up with the constant flow of Featured articles international tax developments worldwide can be a real challenge for multinational companies. International Tax News is a monthly publication that offers updates and analysis on developments taking place around the world, authored by specialists in PwC’s global international tax network. We hope that you will find this publication helpful, and look forward to your comments. Bernard Moens Global Leader International Tax Services Network T: +1 703 362 7644 E: [email protected] In this issue Legislation Administrative Judicial EU/OECD Treaties Legislation Argentina Argentina approves tax regime for Among others, the following tax benefits knowledge-based activities apply to the extent that taxpayers comply with certain requirements: Law No. 27,506, published on June • 15% reduced corporate income tax rate 10, enacted a new regime promoting applicable to fiscal years beginning on or knowledge-based activities. The regime’s after January 1, 2020 main tax benefits include a reduced • executing tax stability agreements with federal corporate income tax rate of 15% and a tax authorities providing that the federal tax tax stability agreement. The new regime burden on income from Promoted Activities cannot increase until December 31, 2029 replaces the existing regime, which was • ability to claim withholding taxes, VAT limited to the software industry, and withholding exemptions, and reduction in will be effective from January 1, 2020 social security contributions through December 31, 2029. Multinational entities engaged in Promoted Activities should revisit their Argentinian operations in order to The new regime aims to encourage the creation, benefit from the new regime. -
Engagement Guidance on Corporate Tax Responsibility Why and How to Engage with Your Investee Companies
ENGAGEMENT GUIDANCE ON CORPORATE TAX RESPONSIBILITY WHY AND HOW TO ENGAGE WITH YOUR INVESTEE COMPANIES An investor initiative in partnership with UNEP Finance Initiative and UN Global Compact THE SIX PRINCIPLES We will incorporate ESG issues into investment analysis and 1 decision-making processes. We will be active owners and incorporate ESG issues into our 2 ownership policies and practices. We will seek appropriate disclosure on ESG issues by 3 the entities in which we invest. We will promote acceptance and implementation of the Principles 4 within the investment industry. We will work together to enhance our effectiveness in 5 implementing the Principles. We will each report on our activities and progress towards 6 implementing the Principles. CREDITS & ACKNOWLEDGEMENTS Authors: Athanasia Karananou and Anastasia Guha, PRI Editor: Mark Kolmar, PRI Design: Alessandro Boaretto, PRI The PRI is grateful to the investor taskforce on corporate tax responsibility for their contributions to the guidance: ■ Harriet Parker, Investment Analyst, Alliance Trust Investments ■ Steven Bryce, Investment Analyst, Arisaig Partners (Asia) Pte Ltd ■ Francois Meloche, Extra Financial Risks Manager, Bâtirente ■ Adam Kanzer, Managing Director, Domini Social Investments LLC ■ Pauline Lejay, SRI Officer, ERAFP ■ Meryam Omi, Head of Sustainability, Legal & General Investment Management ■ Robert Wilson, Research Analyst, MFS Investment Management ■ Michelle de Cordova, Director, Corporate Engagement & Public Policy, NEI Investments ■ Rosa van den Beemt, ESG Analyst, NEI Investments ■ Kate Elliot, Ethical Researcher, Rathbone Brothers Plc ■ Matthias Müller, Senior SI Analyst, RobecoSAM ■ Rosl Veltmeijer, Head of Research, Triodos Investment Management We would like to warmly thank Sol Picciotto, Emeritus Professor, Lancaster University and Coordinator, BEPS Monitoring Group, and Katherine Ng, PRI, for their contribution to the guidance. -
Transfer Pricing As a Vehicle in Corporate Tax Avoidance
The Journal of Applied Business Research – January/February 2017 Volume 33, Number 1 Transfer Pricing As A Vehicle In Corporate Tax Avoidance Joel Barker, Borough of Manhattan Community College, USA Kwadwo Asare, Bryant University, USA Sharon Brickman, Borough of Manhattan Community College, USA ABSTRACT Using transfer pricing, U.S. Corporations are able to transfer revenues to foreign affiliates with lower corporate tax rates. The Internal Revenue Code requires intercompany transactions to comply with the “Arm’s Length Principle” in order to prevent tax avoidance. We describe and use elaborate examples to explain how U.S. companies exploit flexibility in the tax code to employ transfer pricing and related tax reduction and avoidance methods. We discuss recent responses by regulatory bodies. Keywords: Transfer Pricing; Tax avoidance; Inversion; Tax Evasion; Arm’s Length Principle; R & D for Intangible Assets; Cost Sharing Agreements; Double Irish; Profit Shifting INTRODUCTION ver the last decade U.S. corporations have been increasing their use of Corporate Inversions. In an inversion, corporations move their domestic corporations to foreign jurisdictions in order to be eligible O for much lower corporate tax rates. Furthermore, inversions allow U.S. corporations that have accumulated billions of dollars overseas through transfer pricing to access those funds tax free. With an inversion a U.S. corporation becomes a foreign corporation and would not have to pay tax to the U.S. government to access the funds accumulated abroad as the funds no longer have to be repatriated to be spent. Corporations continue to avoid taxation through Transfer Pricing. This article explains transfer pricing and discusses some of the tax issues that transfer pricing pose including recommendations and proposed legislation to mitigate the practice. -
United States Code: the Tariff Commission, 19 USC §§ 91-107
TITLE 19.-CUSTOM, 1 DUTIES § 123a station to another for duty may be allowed, within tihe discre- 96. Invcstigatios as to customs.-- Supersedecd.l tion and under written orders of the Secretary of the Treasury, This section mast5uperseded by I 1332 (a) of this title. the expenses incurred for packing, crating, freight, and dray- 97. Information to President and Congress.--[ SUplerseded.I age in the transfer of their household effects and other per- This section was superseded sonal property. (Mar. 4, 1923, c. 251, § 5, -12 Stat. 145; June by J 1332 (g) of this tillO. 17, 1930, c. 497, Title IV, § G-15(b), 46 Stat. 701.) 98. Investigating tnmiff relations with foreign countries.-- This section was in part repealed by 1 015 (b) of Act June 17, [Sulerseded. 1 1930, cited thereto, which read its follows: "So much of the Act This section was superseded by 1 1132 (b) of lihs titl. entitied 'An Act to provide the necessary organization of the Customs Service for an udequate administration and enforcement 100. Documents and copies for investigations; teltimony; of the Tariff Act of 1922 and all other customs revenue laws,' ip. compelling production of books or papers; freedom of wit- proved M[arch 4, 1923, as anitided, as limits the amount of house. nesses from prosecution.-[SUlitrsededI. hold effects and other personal property of customs officers nl employees for which expenses may be allowed upon transfer from This section wits suprsedeld hy 111313(a) itn (e) of this tlil, one oflehil station to another, is hereby retlied." and the auendatory set of Selpt. -
Jesus on Tithing 17
www.Tithing.com 1 CHAPTER INDEX PREFACE 3 INTRODUCTION 5 FIRST FRUITS 8 ABRAHAM & JACOB 11 JESUS ON TITHING 17 ETERNAL PRINCIPLE 21 THE MINIMUM STANDARD 29 THE LOCAL STOREHOUSE 33 THE BURDEN OF TITHING 38 GREATER GIVING 43 CLOSING THOUGHTS 51 www.Tithing.com 2 PREFACE The preface may be the most important portion to read in this whole book. This will define some terms and clear up some preconceived notions before we proceed to more controversial issues. If you do not believe the tithe is commanded, and are giving through freewill, Spirit-led giving, this resource is written in support of your view of giving; but if you read this only gaining support for the tithing debate, then you will have missed greater intentions that the Spirit of God has. If you support tithing (a minimum requirement of 10%), this resource is not written in total support of your view, but if you feel that this resource will make attempts to excuse selfishness, greed, and disobedience, then you will have missed the greater intentions of giving written here. The challenge for all is to gain knowledge and experience of the greater call and higher guilt led by the Holy Spirit. Whether you give beyond the tithe with limitless offerings, or you give freely, you already exercise the tool used to define "Spirit-led giving". This book will challenge you to give sacrificially. First, let’s explain and compare two types of givers. 1. Cheerful tither - They follow the examples in scripture about tithing, while cheerfully and willingly committing themselves to give a 10% minimum. -
With Indirect Tax News
InTouch with indirect tax news Caribbean Region – Alert pwc InTouch with indirect tax news Caribbean Region Alert In this issue: PricewaterhouseCoopers Caribbean Region is pleased I Antigua & Barbuda – Budgetary proposals legislated ............................3 to present the August 2010 I Aruba – BBO rate reduced......................................................................5 issue of InTouch, a bulletin I Barbados – Reforms to Barbados VAT ...................................................7 I Curaçao, Bonaire, St. Maarten, Saba, St. Eustatius...............................9 designed to keep our clients I Dominica ...............................................................................................10 up-to-date with regional I Grenada – VAT in Grenada effective February 1, 2010 .........................11 indirect taxation. I Jamaica – Increase in rate of GCT.......................................................12 I St. Kitts and Nevis – VAT proposed implementation ...........................14 I St. Lucia – Proposed introduction of VAT delayed...............................15 I Trinidad & Tobago ................................................................................16 I Contacts................................................................................................17 2 pwc Antigua & Barbuda Updates and developments An overview Rates 2009 saw the rate of Antigua and Barbuda Sales Antigua and Barbuda Sales Tax (“ABST”) is the The following rates of tax are applicable under the Tax (“ABST”) applicable -
New Experimental Electricity Tariff Systems for Household End Use
Panel 2 - ID 54 - p1 Wols i n k New experimental electricity tariff systems for household end Use Ma a r ten Wol s i n k De p a r tment of Environmental Science, University of Amster da m Abstract A significant tool in Demand Side Management is the structure of tariffs. Price incentives can be directed at dif- ferent parts of the efficiency-concept: efficiency in capacity planning, efficiency in total electricity consumption, efficiency in total fossil fuel use, efficiency in total energy demand. The tariff system, which is currently used in the Netherlands, does not give proper price incentives for end-user efficiency. In particular total electricity demand is rather stimulated, which is somewhat dampened by the introduction of the eco-tax. In the Netherlands field experiments with tariff systems directed at influencing household electricity demand were carried out by five utilities. In the experiments differentiated tariff-variants were introduced, replacing the old tariff-system. The experiments included voluntary price differentiation, which introduced a free-rider prob- lem in combination with the chosen price levels. Furthermore remote-monitoring, feedback, special peak-pricing etc. were implemented in the experiments. Some interesting options, in particular those influencing total demand, were not implemented by utilities. The reasons for it should be categorized as ‘strategic’ and part of the utilities’ policy. 1. Reasons for tariff experimentation In 1989 the electricity sector in the Netherlands was reorganized. Part of it was the separation by law of produc- tion companies and distribution utilities. A series of changes in purchase-rates from producers in which flexibility and capacity-cost became more important urged utilities to pay more attention to load patterns. -
Tax Heavens: Methods and Tactics for Corporate Profit Shifting
Tax Heavens: Methods and Tactics for Corporate Profit Shifting By Mark Holtzblatt, Eva K. Jermakowicz and Barry J. Epstein MARK HOLTZBLATT, Ph.D., CPA, is an Associate Professor of Accounting at Cleveland State University in the Monte Ahuja College of Business, teaching In- ternational Accounting and Taxation at the graduate and undergraduate levels. axes paid to governments are among the most significant costs incurred by businesses and individuals. Tax planning evaluates various tax strategies in Torder to determine how to conduct business (and personal transactions) in ways that will reduce or eliminate taxes paid to various governments, with the objective, in the case of multinational corporations, of minimizing the aggregate of taxes paid worldwide. Well-managed entities appropriately attempt to minimize the taxes they pay while making sure they are in full compliance with applicable tax laws. This process—the legitimate lessening of income tax expense—is often EVA K. JERMAKOWICZ, Ph.D., CPA, is a referred to as tax avoidance, thus distinguishing it from tax evasion, which is illegal. Professor of Accounting and Chair of the Although to some listeners’ ears the term tax avoidance may sound pejorative, Accounting Department at Tennessee the practice is fully consistent with the valid, even paramount, goal of financial State University. management, which is to maximize returns to businesses’ ownership interests. Indeed, to do otherwise would represent nonfeasance in office by corporate managers and board members. Multinational corporations make several important decisions in which taxation is a very important factor, such as where to locate a foreign operation, what legal form the operations should assume and how the operations are to be financed. -
More Than 50 Years of Trade Rule Discrimination on Taxation: How Trade with China Is Affected
MORE THAN 50 YEARS OF TRADE RULE DISCRIMINATION ON TAXATION: HOW TRADE WITH CHINA IS AFFECTED Trade Lawyers Advisory Group Terence P. Stewart, Esq. Eric P. Salonen, Esq. Patrick J. McDonough, Esq. Stewart and Stewart August 2007 Copyright © 2007 by The Trade Lawyers Advisory Group LLC This project is funded by a grant from the U.S. Small Business Administration (SBA). SBA’s funding should not be construed as an endorsement of any products, opinions or services. All SBA-funded projects are extended to the public on a nondiscriminatory basis. MORE THAN 50 YEARS OF TRADE RULE DISCRIMINATION ON TAXATION: HOW TRADE WITH CHINA IS AFFECTED TABLE OF CONTENTS PAGE EXECUTIVE SUMMARY.............................................................................................. iv INTRODUCTION ................................................................................................................ 1 I. U.S. EXPORTERS AND PRODUCERS ARE COMPETITIVELY DISADVANTAGED BY THE DIFFERENTIAL TREATMENT OF DIRECT AND INDIRECT TAXES IN INTERNATIONAL TRADE .............................................. 2 II. HISTORICAL BACKGROUND TO THE DIFFERENTIAL TREATMENT OF INDIRECT AND DIRECT TAXES IN INTERNATIONAL TRADE WITH RESPECT TO BORDER ADJUSTABILITY................................................................. 21 A. Border Adjustability of Taxes ................................................................. 21 B. 18th and 19th Century Examples of the Application of Border Tax Adjustments ......................................................................... -
Tanzania the Panama Papers in Africa
Tanzania The Panama Papers in Africa: Tax Avoidance, Money Laundering or Illicit Financial Flows? Olwethu Majola-Kinyunyu LLB, LLM PhD Candidate, Centre of Criminology, University of Cape Town, Cape Town, South Africa Email: [email protected] Abstract Early in 2016 the international community was shaken by the news of the biggest data leak in history. Political figures, prominent business people, sportstars and even criminals were the topic of discussion in news outlets across the globe. Following the release of the Panama Papers, many called for the leaders who were implicated to resign from their positions and for business executives to be investigated. There were reports of offshore accounts and companies operating in tax havens and accusations of money laundering, terrorism financing and tax avoidance. What do the Panama Papers mean for Africa? This paper assesses the effects of the Panama Papers on the African continent and evaluates whether the responses by African states are sufficient. What are the Panama Papers? tax haven jurisdictions in the facilitation of tax evasion, money laundering, organised crime, illicit The ?Panama Papers? is the colloquial term referring to the leak of client documents belonging to financial flows and other issues of grave concern to Panama-based law firm Mossack Fonseca. Details of the the international community. Panama documents were leaked by German newspaper, The Legality of Offshore Accounts and Companies in Süddeutsche Zeitung, in conjunction with the African Jurisdictions International Consortium of Investigative Journalists Holding ownership of a shell company or an offshore (ICIJ), consisting of over 100 media partners in 82 account, in most cases, is not unlawful. -
Potential Retaliation Against the EU Digital Services Tax (DST)
A Service of Leibniz-Informationszentrum econstor Wirtschaft Leibniz Information Centre Make Your Publications Visible. zbw for Economics Lee-Makiyama, Hosuk Research Report The cost of fiscal unilateralism: Potential retaliation against the EU Digital Services Tax (DST) ECIPE Occasional Paper, No. 05/2018 Provided in Cooperation with: European Centre for International Political Economy (ECIPE), Brussels Suggested Citation: Lee-Makiyama, Hosuk (2018) : The cost of fiscal unilateralism: Potential retaliation against the EU Digital Services Tax (DST), ECIPE Occasional Paper, No. 05/2018, European Centre for International Political Economy (ECIPE), Brussels This Version is available at: http://hdl.handle.net/10419/202461 Standard-Nutzungsbedingungen: Terms of use: Die Dokumente auf EconStor dürfen zu eigenen wissenschaftlichen Documents in EconStor may be saved and copied for your Zwecken und zum Privatgebrauch gespeichert und kopiert werden. personal and scholarly purposes. Sie dürfen die Dokumente nicht für öffentliche oder kommerzielle You are not to copy documents for public or commercial Zwecke vervielfältigen, öffentlich ausstellen, öffentlich zugänglich purposes, to exhibit the documents publicly, to make them machen, vertreiben oder anderweitig nutzen. publicly available on the internet, or to distribute or otherwise use the documents in public. Sofern die Verfasser die Dokumente unter Open-Content-Lizenzen (insbesondere CC-Lizenzen) zur Verfügung gestellt haben sollten, If the documents have been made available under an Open gelten abweichend von diesen Nutzungsbedingungen die in der dort Content Licence (especially Creative Commons Licences), you genannten Lizenz gewährten Nutzungsrechte. may exercise further usage rights as specified in the indicated licence. www.econstor.eu ECIPE OCCASIONAL PAPER • 05/2018 The Cost of Fiscal Unilateralism: Potential Retaliation Against the EU Digital Services Tax (DST) By Hosuk Lee-Makiyama Director of ECIPE The author gratefully acknowledges the able research assistance of Cristina Rujan ecipe occasional paper — no. -
Avoiding Penalties and the Tax Gap
Media Relations Office Washington, D.C. Media Contact: 202.622.4000 www.irs.gov/newsroom Public Contact: 800.829.1040 Avoiding Penalties and the Tax Gap FS-2008-19, March 2008 WASHINGTON— The Internal Revenue Code imposes many different kinds of penalties, ranging from civil fines to imprisonment for criminal tax evasion. If you do not file your return and pay your tax by the due date, you may have to pay a penalty. You may also have to pay a penalty if you substantially understate your tax, understate a reportable transaction, file an erroneous claim for refund or credit, or file a frivolous tax submission. If you provide fraudulent information on your return, you may have to pay a civil fraud penalty. Penalties are generally payable upon notice and demand. Penalties are generally assessed, collected and paid in the same manner as taxes. The notice will contain the name of the penalty, the applicable code section, and how the penalty was computed (or information on how to obtain the computation if not included). This fact sheet is the 22nd in the Tax Gap series. It provides additional guidance to taxpayers regarding civil penalties and the consequences for understating income and overstating expenses. Estimated Tax-Related Penalties Employees have taxes withheld from their paychecks by their employer. When you have income that is not subject to withholding you may have to make estimated tax payments during the year. This includes income from self-employment, interest, dividends, alimony, rent, gains from the sale of assets, prizes, and awards. You also may have to pay estimated tax if the amount being withheld from your salary, pension, or other income is not enough to pay your tax liability.