Global Minimum Tax and the Future of International Taxation

KnowledgeGlobal Minimum Tax and the Future of International Taxation

Global Minimum Tax and the Future of International Taxation.


This article will speculate on the future of international taxation in light of global minimum tax policies, including potential trends and challenges that may arise. 

The recent OECD/G20 agreement on global minimum tax rules has marked a significant milestone in international taxation. The agreement, which aims to ensure that multinational corporations (MNCs) pay their fair share of taxes, has far-reaching implications for the future of international taxation.


In this article, we will speculate on the future of international taxation in light of global minimum tax policies, including potential trends and challenges that may arise.



Conclusion:

In conclusion, the future of international taxation is likely to be shaped by global minimum tax policies. While these policies represent a major step towards creating a more fair and transparent tax system, there are still many challenges ahead. It will be important for governments, businesses, and international organizations to work together to address these challenges and ensure that the global tax system is fit for purpose in the 21st century.

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21 Sep '15

The New Global Standard on Transfer Pricing Documentation

On September 16 the OECD released guidance on transfer pricing topics as part of the Base Erosion and Profit Shifting (BEPS) Action Plan announced in July 2013. These topics include guidance on Action 13 on transfer pricing documentation and country-by-country reporting.


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15 Sep '15

Transfer pricing documentation for intercompany loans – More than just the price?

Intercompany loans continue to be a hot topic and focus point for the Tax Authorities around the world as this type of transactions are considered high risk from a transfer pricing prospective. If your company has entered into intercompany loans it is critical to assess any transfer pricing risk related with the transaction and to have evidence of compliance with the arm’s length principle.


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31 Aug '15

Australia: Second Country to Incorporate into the legislation BEPS Action plan 13 on Transfer Pricing Documentation

The Australian Treasury has released exposure draft legislation (Subdivision 815-E) to implement new OECD standards on transfer pricing documentation (Master File and Local File) and Country-by-Country (CbC) reporting. The new draft legislation makes Australia the second country (after Spain) to release legislation on this issue as a direct result of the recent guidance set by the OECD as part of its base erosion and profit shifting (BEPS) initiative with respect to Action Plan 13: Guidance on the Implementation of Transfer Pricing Documentation and Country-by-Country Reporting.


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24 Aug '15

Double Penalties for Tax Avoidance and Transfer Pricing Schemes

The Australian Treasury released an exposure draft bill to impose stronger penalties to combat tax avoidance and profit shifting. The draft legislation will apply to companies with annual global revenue exceeding AU$1 billion that are obliged to comply with the Country by Country (CbC) reporting.


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12 Aug '15

Aust Accounting Awards 2015_PARTNER OF THE YEAR


31 Jul '15

New Process for Obtaining Advanced Pricing Arrangements (APAs) in Australia

The Australian Taxation Office (ATO) has released a new process for advance pricing arrangement (APA) negotiations (Practice Statement, PS LA 2015/4). The new process will apply to all ongoing APA negotiations and future APA requests (both new APAs and renewals). The APA program has been updated to ensure it reflects changes in global economy and the ATO’s anti-profit shifting work.

The new process includes three key steps as follows:

  1. Early Engagement
  2. APA Application
  3. Monitoring Compliance.

Key changes:

  • A ‘Triage panel’ during the early engagement phase, a bit like ‘triage’ at the hospital! This panel will assess the taxpayer’ case in order to decide whether the APA application is accepted or not.
  • Taxpayers will need to undertake a significant amount of technical work during the early engagement phase to present their case to the Triage panel
  • Taxpayers will have to disclose more information, particularly in relation to taxpayers’ global value chain, during the early engagement phase before being accepted into the program
  • The ATO will aim to determine up front any ‘tax complexities’ that may prevent the ATO from entering into the APA program with the taxpayer. These ‘tax complexities’ include presence of aggressive tax minimization structures in the multinational corporation global value chain, arrangements that appear to lack commerciality,  value of the cross-border dealing being not material or taxpayers that are not sufficiently cooperative with the ATO
  • The timelines are expected to be longer than in previous process, stage 1 maximum of 6 months and stage 2 maximum of 18 months.

What do we recommend you do now?



If your company is interested in entering into an APA with the ATO, you should carefully assess your resources and effort required, particularly during stage 1, taking into account that there is no guarantee the ATO will accept you into the APA program.

It will be critical to engage specialist consultants from the beginning of the process to manage the relationship with the ATO and to assist with the technical documentation.

For more information please contact Transfer Pricing Solutions on 03 5911 7001 or email admin@transferpricingsolutions.com.au.


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6 Jun '15

The New Global Standard on Transfer Pricing Documentation

The OECD Releases the New Global Standard on Transfer Pricing Documentation- What do you need to do today? On September 16 the OECD released guidance on transfer pricing topics as part of the Base Erosion and Profit Shifting (BEPS) Action Plan announced in July 2013. These topics include guidance on Action 13 on transfer pricing


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19 Aug '14

Aust Accounting Awards BOUTIQUE FIRM OF THE YEAR 2014


22 Jul '14

Thompson Routers 2015


3 Jun '14

Thompson Routers_TP TEAM OF THE YEAR_ 2014 FINALIST


1 Aug '13

Thompson Routers 2013