International Tax


Taxpayer Woes Over Taxation Of The Digital Economy Simmer

So far the only agreement on taxation of the digital economy is that it should be decided upon on an international level. While OECD and EU proposals are still in their consultation stages, taxpayers are hoping for more emphasis on dispute resolution mechanisms and safeguards against double taxation.



Reduction of the Duration of the 30%-ruling for Expats in the Netherlands

The maximum duration of the 30%-ruling for expats in the Netherlands will be reduced from eight to five years, from 1 January 2019. To assist multinational businesses, Baker Tilly Berk (the Netherlands) has recorded a webinar for employers, to explain and discuss the consequences of the change.

US Mid-terms Spell Gridlock for Taxpayers

The Republicans have lost their stranglehold on the House of Representatives, with the Democrats now holding the majority of seats as a result of the mid-term elections that took place across the US on November 6. Although the Democrats have not managed to capture the US Senate, House Ways and Means Committee Chairman Kevin Brady has lost his post. Massachusetts representative Richard Neal is set to take his place, potentially changing the tax roadmap.

The New Italian Tax Amnesty In Summary

On October 23, 2018 the Decree n. 119 (hereinafter the «Decree») concerning “urgent tax and financial measures” has been approved. The Decree entered temporary in force on October 24, 2018, i.e. the day after its publication on the Italian Official Gazette and, is at time under the scrutiny of the Parliament for being eventually be converted into law (the conversion shall take place within 60 days).

Highlights Of The 2019 Budget Proposals - Malaysia

The 2019 Malaysian Budget was presented by the (new) Government of Malaysia on 2nd November 2018. The theme of Budget 2019 was ‘A Resurgent Malaysia, A Dynamic Economy, A Prosperous Society’. This was a highly anticipated maiden Budget by the Finance Minister, the Honourable Mr Lim Guan Eng, and was presented amidst an extremely challenging fiscal situation in the country, and with burgeoning global economic risk of trade wars, a cooling Chinese economy, strife and tensions in many areas of the world. On the domestic front, alarmingly high Government debt levels, financial scandals and ever-increasing earnings disparity faced by the people of Malaysia.

Legislative Changes October 2018 - Moldova

This month there have been significant changes entering into force related to tax legislation and other normative acts regulating economic activities. Earlier, at the beginning of the second half of the fiscal year, the Government has announced their initiative to decrease the tax burden in order to establish a better business climate.

The Application of Anti-abuse Rules: Follow The Footsteps of Cadbury Schweppes!

In its decision of 13 June 2018 (I R 94/15), the Federal Financial Court (‘Bun-desfinanzhof’) decided on the application of the German Controlled Foreign Corpo-rate (“CFC”) rules to a company in Cyprus.

New Model of Co-operation With Taxpayers

During the last 6 years State Revenue Service of Latvia (SRS) had a special VIP service line for so called “white-listed” companies. As from 1 January 2019 this is going to be changed by broadening of taxpayers' base and modernising/automated the current system.

Baker Tilly International UK Member Firm Discusses New Digital Services Tax

Chris Denning, a Corporate and International Tax Partner with MHA, the UK member firm of Baker Tilly International, talks about the new 2% Digital Services Tax, which was announced in the recent budget. This would tax sales of large digital firms, linked to UK users.


Chief Strategic Officer: A New World

Multinational organisations typically have the roles of chief operating officer, general counsel, chief information officer, human relations officer, chief tax officer, chief financial officer, and perhaps a chief compliance officer supporting the business strategy and the chief executive officer. However, in light of recent tax developments, there may now be the opportunity to sculpt a formal position of chief strategic officer.

Authorised Economic Operator (AEO) Status

MHA MacIntyre Hudson, the UK member firm of Baker Tilly International have written an article focused on Authorised Economic Operator (AEO) Status. The EU (European Union) AEO Scheme is a voluntary system, introduced to safe and legitimate international suppliers. The article discusses types of certification, mutual recognition agreements, benefits and of course, the effects of Brexit.

Brexit Toolkit – A To Do List

MHA MacIntyre Hudson, the UK member firm of Baker Tilly International, has published a To Do List to help businesses avoid any customs issues. Their experts Alison Horner, Indirect Tax Partner, and Lucy Sutcliffe, Senior Customs Duty Manager, provide all the information you need to develop your Brexit Plan.

China to Introduce More Measures to Facilitate Foreign Investment / Trade

On 26 September 2018, a string of measures were rolled out at the State Council executive meeting (hereafter as the “Meeting”) presided over by Premier Mr. Li Keqiang, as to facilitate the delivery of major foreign invested projects, lower tariffs on certain goods and streamline customs clearance procedures at a faster pace.

UK Tax Laws After Brexit

It is a very significant piece of legislation for the future direction of the tax law in the UK as it defines how the split from EU Laws, which have determined large parts of UK law for decades, is to be exercised. The following article describes the "divorce" mechanisms, outlines what tax-related EU law the UK will adopt after Brexit, and analyses the retained tax law’s likely efficacy in a post-Brexit legal environment.

Ireland's Budget: Baker Tilly Hughes Blake Share Their Views On Key International Announcements

On October 9th, 2018, Ireland’s Minister for Finance and Public Expenditure and Reform, Mr. Paschal Donohoe, announced Ireland’s budget for 2019. The budget included minor changes to personal tax rates and bands and also set out increases in public expenditure. Baker Tilly Hughes Blake have produced a summary document which highlights the key changes that were introduced.

David Kemp Acknowledged As One Of The “World’s Leading Tax Controversy Advisors”

David Kemp, Tax Partner at Collins Barrow, a member firm of the Baker Tilly International in Canada, and executive member of Baker Tilly International's Global Transfer Pricing Committee has been acknowledged by International Tax Review Tax Controversy Leaders Guide as one of the "World's leading Tax Controversy Advisors". He has also been acknowledged repeatedly by Euromoney Legal Media Group Expert Guides as one of the "World's leading Transfer Pricing Advisors".

China Amends its Individual Income Law – Expectably a Far-reaching Reform on the Way

On August 31, 2018, the National People's Congress of People's Republic of China (“PRC” or “China”) has passed the Decision on Amending the Individual Income Tax (“IIT”) Law of the People's Republic of China, effective from January 1, 2019. This is the one of the most significant amendment made to China's IIT Law since its implementation in 1980 and is expected to exert profound and far-reaching impact on the IIT practice in China. We expect the publicizing of detailed implementation rules and other relevant regulations in the following months.

Baker Tilly Tax Clinic Section In October’s Issue Of “The Tax Adviser”

On an annual basis, Baker Tilly Virchow Krause has been the October contributing editor of the American Institute of Certified Public Accountants (AICPA) The Tax Adviser’s Tax Clinic section. The Tax Clinic is a unique forum that lets tax professionals demonstrate the techniques and procedures applied to the work that is provided to clients.


Tax Encroaches On Retail Sector On Multiple Fronts

The in-house tax leaders at International Tax Review’s Taxation of the Digital Economy Summit in London said tax authorities are coming up with new applications of value creation and establishment principles in the EU and US to extract more taxation from their companies

The Dangers Of Moving Away From The Arm's-length Principle

Vodafone’s Glenn Price told TP Week that the outcome of the OECD’s consultation on transfer pricing for financial transactions could jeopardise a fundamental TP convention if MNEs don’t participate in the discussion.

Corporate Tax Rate Reduction

Allan Mortel, Partner at Baker Tilly Pitchers Partners, the Australian member firm of Baker Tilly International, has released a bulletin discussing the recently passed Base Rate Entity Bill, which ensures a 30% company tax rate is applied to companies with mostly passive income, rather than the 27.5% rate.


The Tax Cuts and Jobs Act (TCJA)

Baker Tilly, one of the US member firms of Baker Tilly International, have released an Insight in which they discuss The Tax Cuts and Jobs Act (TCJA). Looking at how federal income taxes are computed will be transformed, eliminating a state and local tax deduction, depreciation changes, accounting method changes for small business taxpayers, federal payroll withholding and hardship distributions.

Annual Tax Act 2018: The Most Relevant Changes At A Glance

The government has set itself the task of summarising changes in tax law once a year within the framework of an Annual Tax Act so that entrepreneurs can prepare for them better. The Annual Tax Act 2018 (Jahressteuergesetz 2018) was passed in July 2018. We will summarise the main changes for you.

Brexit: A New Horizon

Experts at MHA MacIntyre Hudson, Baker Tilly International's UK member firm, has put together a business planning guide that will highlight the long term strategic opportunities in a post-Brexit business world.

Sales and Service Tax Bills in Malaysia

Sandra Saw, Associate Director at Baker Tilly in Malaysia, has written an article for Focus Malaysia, which discusses the resurrection of the Sales and Service Tax, also known as SST.

IRS and Treasury Department Release New Regulations

Baker Tilly, one of Baker Tilly Internationa's US member firms, has written an Insight which covers the proposed section 965 regulations that have been released by the IRS and Treasury Department. The new regulation requires US shareholders to pay a one time repatriation tax on previously untaxed foreign earnings.

Baker Tilly in the USA Release Tax Alert

Baker Tilly, one of Baker Tilly International’s US member firms, has sent out a tax alert addressing new bonus depreciation proposed regulations. The alert discusses the Tax Cuts and Jobs Act amendments, to help small business taxpayers.

Tax Alert from the US on Bonus Depreciation Regulations

One of Baker Tilly International’s US member firms, Baker Tilly, has released a tax alert which talks about the bonus depreciation proposed regulations having been released. The proposed regulations, which were released on 3 August 2018, provide guidance on the changes made by the Tax Cuts and Jobs Act to bonus depreciation.

UK Could Take Unilateral Action On Digital Tax In 2018 Budget

With Italy and India already having their own digital economy taxes, and some countries doubting the OECD’s ability to find a global solution on taxing online businesses by 2020, the UK government is once again looking to establish its own approach.

The Real-time Risks Of Tax Technology

Cybersecurity will only become more important as the rise of real-time reporting technologies revolutionise compliance methods. Malware can spread through corrupted updates on accounting software just as it can on any other network.

Transfer Pricing Changes In Poland

TPA, the Baker Tilly International member firm in Poland, have produced a summary of changes to transfer pricing in the country. A draft bill aimed to abolish current legislations and amend the Corporate Income Tax Act and the Personal Income Tax Act was published on 16th July 2018. The key change is to adapt Polish regulations to the OECD guidelines and change provisions on transfer pricing. Should these draft changes go through parliament, there may be a unification of terms and definition which will allow to avoid potential disagreements over interpretations currently.


Baker Tilly (Mauritius) Tax Brief on Finance Bill

Baker Tilly (Mauritius) has produced a Tax Brief to cover the key tax measures of The Finance Bill (Miscellaneous Provisions, No. XI of 2018), which was present to the National Assembly on 13 July 2018. This will cover the implementation process detailed in the Budget Speech 2018-19 by the Prime Minister, Minister of Home Affairs, External Communications and National Development Unit, Minister of Finance and Economic Development in his budget speech of 14 June 2018.

Baker Tilly In the US Discuss Tax Reform 2.0

The House Ways and Means Committee has announced the next phase of tax reform. Baker Tilly, the Baker Tilly International member firm in the US has released a new Insight, which provides a progress report on tax reform.

Blockchain Technology Laws Approved In Malta

The Maltese Parliament has recently approved bills which regulate Blockchain and Distributed Ledger Technolody (DLT) which helps to push Malta to the forefront of blockchain technology. Three bills were passed on 4 July, including Initial Coin Offerings (ICOs).

The 'Harry Kane Theory Of Value' And The Flaws In The EU's Digital Tax Plans

The international debate on how to tax the online economy is based on key assumptions about tax and value creation. The idea of basing a tax regime on value creation was laid down as part of the OECD’s BEPS project, and the EU has since taken it up in its efforts to find a short-term fix to the problem of digital tax. Yet the idea of value creation has not been the basis of international tax law in the past.

One In 10 Multinationals To Restructure 'Soon' Due To BEPS And ATAD

The BEPS Project and the EU Anti-Tax Avoidance Directive (ATAD) are forcing some companies into restructuring, according to a new survey. But many are still waiting for more clarity before they decide their next move.

ATAD To Hike Intra-group Financing Costs For Unprepared MNEs

The EU’s Anti-Tax Avoidance Directive (ATAD), which will be implemented in most member states’ domestic legislation by January 2019, includes a new regime on interest deductibility which is expected to impact the costs of intra-group financing. The rules are based on BEPS Action 4 on limiting base erosion involving interest deductions and other financial payments, but are more pressing for companies than Action 4, say advisers.

OECD Releases The Largest Source Of Comparable Tax Revenue Data

The Organisation for Economic Cooperation and Development (OECD) announced on 28th June 2018, the launch of a new database providing detailed and comparable tax revenue information for 80 countries around the world.

International Tax Survey 2018 Report

Baker Tilly International conducted an International Tax Survey to assess the impact of BEPS, the fast changing international tax arena, tax uncertainties and other topics


Baker Tilly In The US Discuss The South Dakota v. Wayfair Result And What It Means

Baker Tilly, the US member firm of Baker Tilly International, has released an Insight, talking about the result of South Dakota v Wayfair, what this means and the implications this will have. 

China Has Released Special Administrative Measures For Access of Foreign Investment (Negative List) To Further Open Up To Foreign Capital

On 28 June 2018, the National Development and Reform Commission and the Ministry of Commerce have jointly released the Special Administrative Measures for Access of Foreign Investment (Negative List) (Version 2018) (“the 2018 Negative List”) to lift the restrictions on foreign capital in 22 industries. The 2018 Negative List is an amendment to the Industry Category Guide for Foreign Investment (Version 2017) and shall take effect from 28 July 2018.

Germany And France Forge EU Corporate Tax Pact

The German Ministry of Finance released a working paper on tax harmonisation on June 20, pledging a joint effort with France to take the agenda to the Eurogroup and the Economic Financial Affairs Council (ECOFIN). These meetings could make or break the CCCTB.

BREAKING: Tax Chaos Looms As US Supreme Court Rules In Favour Of South Dakota In Wayfair Case

The ruling means that states will be able to collect sales tax from retailers outside of their borders, which has previously been prohibited by the decades-old Quill decision. Given the rise of e-commerce, today’s retail landscape looks very different to 1992’s.

Australia and Singapore Free Trade Golden Era

Australia and Singapore already enjoy a free trade agreement, but the recent signing of the Trans-Pacific Partnership in January has further strengthened this relationship. Darryl Daisley from Baker Tilly Pitcher Partners talks about what will change and the benefits of the deal.

Mauritius Budget 2018-2019 Main Measures

The Prime Minister and Minister of Finance presented the National Budget 2018 - 19 centred around economic growth. Here, Baker Tilly Mauritius present the key points in a Tax Flash.

Baker Tilly Pitcher Partners Look At The Biggest Tax Risks When Selling Your Home

The trend thus far has been neighbours band together to sell their combined lots to a developer for driving up the value to get a better price. However, how these are treated by the Australian Tax Office can be complex. Scott McGill, from Baker Tilly Pitcher Partners, Baker Tilly International's Australian member firm, talks about the risks of Capital Gains or Goods and Services Tax on selling your home when working with neighbours.

Wall Street Waits For US Tax Reform 2.0

US lawmakers are considering their options for a second tax bill, while American and foreign banks are still weighing up the full impact of the Tax Cuts and Jobs Act (TCJA). Among the top concerns are the base erosion anti-abuse tax (BEAT), the global intangible low-taxed income (GILTI) rules, the problems of inflexible rules on deductions and the threat of double taxation.

Baker Tilly Pitcher Partners on The Business Relationship Between China and Australia

Darryl Daisley, of Baker Tilly International’s Australian member firm Baker Tilly Pitcher Partners, discusses in this article for Australia China Business Review the relationship, and its future, between the two countries.

OECD Conference Debates Value Creation In Taxation Of The Digital Economy

Differing opinions on what value creation is, and how value is created, are some of the main obstacles to achieving consensus, speakers said at the conference's panel on tax challenges arising from digitalisation. Data and user participation continue to give rise to disagreements between countries and value creation is still an unclear concept, often interpreted differently by jurisdictions.

Navigating Global Immigration Investment Services

Baker Tilly International is pleased to publish it’s 2018 Immigration Investment Services Publication, which allows readers to efficiently analyse, at a high level, immigration investment programs available - key for investors and developers before, during and after transactions.

Carbon Taxation Revenue Rose By 50% In 2017 – Or Did It?

The report, said that 45 national jurisdictions and 25 sub-national jurisdictions have adopted carbon pricing initiatives, raising $33 billion in 2017 – 50% up from the $22 billion raised in 2016. China is set to enact its emissions trading scheme (ETS) in 2018, which will make a big difference to the numbers, and this could contribute to the total annual value (not revenue) of carbon pricing initiatives rising 58% from $52 billion to $82 billion in 2018.

MHA MacIntyre Hudson Discuss HMRC Overseas VAT

The huge rise and rapid growth in online marketplaces has led to a similar growth in overseas sellers using online marketplaces to sell goods to customers in the U.K. without registering for VAT. Sue Rathmell, of Baker Tilly International's UK member firm, MHA MacIntyre Hudson, has written an article for Bloomberg Tax discussing the issues HM Revenue & Customs (HMRC) has when it comes to enforcing VAT measures on overseas based online sellers.

Is GDPR Putting Companies Off The UK's Anti-VAT Fraud Scheme?

The strength of the online marketplace agreement is the level of data access it gives to HMRC. Unfortunately for the UK revenue authority, the agreement coincided with the EU’s general data protection regulation (GDPR) coming into effect.

Baker Tilly Albania Release New Tax Insight

Baker Tilly International's Albananian member firm, Baker Tilly Albania, has released a new Tax Insight which provides useful information on a new law on accounting and financial reporting, law No. 25.

Big Data Will Make Or Break Use Of The Cloud For Tax Reporting

The rise of real-time reporting technologies may promise to revolutionise VAT compliance, but its success will come down to data quality, as well as the agreement in place with the service provider. This is no minor issue as corporations like Coca-Cola and Uber increasingly rely on reporting technology to manage their tax affairs.


Will The UK Be Taxing Robots In The Not Too Distant Future?

The UK’s Business, Energy and Industrial Strategy Committee recently launched a review into the automation and future of work, which includes reference to a ‘robot tax’ designed to support workers impacted by automation.

China Is On The Path To Create The World's Largest Economic Stand

The road has influenced the development of the entire region for hundreds of years from creating a network of railways, roads and pipelines, to forming utility grids that would link China and Central Asia, West Asia and parts of South Asia. This initiative, One Belt and One Road (OBOR), is aimed to create the world’s largest platform for economic co-operation, trade and financing collaboration and social and cultural co-operation.

Quarterly Update on Regional Tax Developments

Baker Tilly in South East Europe has produced a Quarterly Update on key tax developments in Cyprus, Greece, Romania and Bulgaria for Spring.

Asia-Pacific: Managing change and finding substance

One of the biggest challenges for taxpayers is planning appropriately for constantly changing tax rules, greater scrutiny and transparency. Recent tax scandals have revealed the extent of tax avoidance, tarnishing the brand image of some multinationals – in some cases unfairly.


EU's Digital Sales Tax Could Prompt New MLI

The European Commission (EC) set out two proposals for taxing the digital economy on March 21. The first proposal, a long-term solution, would enable member states to tax profits generated in their territory and is based on the concept of a virtual permanent establishment (PE). The second proposal is an interim tax on revenues created from certain digital activities.

BEPS awareness becomes embedded in boardrooms

Corporate heads of tax and Philip Green, the former CFO of Deliveroo and Groupon, share their perspectives on why tax and transfer pricing are taking up an increasing amount of C-suite time. With the rollout of BEPS, transfer pricing and controversy management have become crucial for boardrooms.

Tax Technology Roundtable: German MNEs eye AI dividends

TP Week hosts a roundtable with German multinationals AUDI AG and Henkel and consultancy WTS to discuss progress in implementing artificial intelligence and automation in tax departments. The clear message is that machine learning is happening now and will amplify tax capabilities exponentially in the future, much beyond our current purview.

Q&A: Ex-Microsoft Tax Adviser Mike Bernard On Data And The Digital Economy

Mike Bernard, former Microsoft tax counsel, talks to ITR about his experience at Microsoft, how the tax department functioned, and how he will help MNEs use data to be audit-ready in his new role at Vertex.


Multilateral Convention To Implement Tax Treaty - Enter Into Force 1 July 2018

Following the fifth instrument of ratification by Slovenia received in March 2018, the OECD has announced that the Multilateral Convention to implement Tax Treaty related measures to prevent Base Erosion and Profit Shifting will enter into force on 1 July 2018.

UK and Cyprus Sign Double Tax Treaty

Cyprus and the UK today signed a new double tax treaty to replace that which was signed between the countries in 1974 which, once ratified, will be become effective as from 1 January 2019. The new treaty is a modified version of the OECD Model Tax Convention framework and applies to taxes on income as well as on gains from alienation of moveable or immovable property. The treaty covers income tax, in the UK’s case, as well as corporation tax and capital gains tax, whilst it covers corporate and personal income tax, the defense tax and capital gains tax in Cyprus’ case.

A One Stop Shop for Corporate Income Tax Moves One Step Closer

Herm Nieste from Baker Tilly Berk in the Netherlands confirms “Members of the European Parliament have voted with a significant majority to implement two EU Directives: the Common Corporate Tax Base (CCTB) and the Common Consolidated Corporate Tax Base (CCCTB). These Directives were introduced shortly after the two Anti-Tax Avoidance Directives (ATAD I and ATAD II). Introductions of all these major tax plans were received with a lot of scepticism however, ATAD I and ATAD II are here to stay and will be implemented in phases with a target completion year of 2021, immediately followed by CCTB and CCCTB.

Q&A: Achim Pross On New OECD Mandatory Disclosure Rules For CRS

The OECD has released new rules requiring lawyers, financial advisers, accountants, banks and other service providers to let tax authorities know about any schemes that help clients avoid reporting under the common reporting standard (CRS).

EU Consultation Discloses Views on Digital Economy Taxation

The European Commission has now published the outcome of its public consultation on fair taxation of the digital economy. The survey shows the majority of stakeholders favours an international discussion and believes short-term solutions should be adopted until long-term measures are agreed upon.


Singapore budget to focus on GST and digital sales

A new e-commerce tax, tax hikes, and changes to the goods and services tax (GST) regime that may affect MNEs are all highly likely in Singapore’s 2018 budget next week.

Thai Revenue Department Audits and Reviews

Baker Tilly Thailand has published an article on Thai Revenue Department Audits and Reviews.

Quarterly Update on Regional Tax Developments

Baker Tilly in South East Europe has produced a Quarterly Update on key tax developments bulletin in Cyprus, Greece, Romania and Bulgaria. 

The EU's Digital Tax Framework Threatened By Conflicting Political Agendas

Last week, the German coalition talks laid out an agreement that included proposals for the "fair taxation of large companies". The document singled out Google, Apple, Facebook and Amazon (sometimes called 'GAFA’ for short) as examples. These brands have all come under fire in the past over allegations of tax avoidance, and they have denied claims they don’t pay what they owe in taxes.

January 2018

Baker Tilly in the USA Helping to Untangle Tax Reform Webinars

Baker Tilly, our member firm in the USA, has produced a number of webinars to help you untangle the new US tax reforms. The webinars cover state and local tax, accounting methods and tax credits, international taxation and multinationals, and finally individual and estate planning.

US Tax Reform Focus: Ireland's Good Fortunes

As Ireland has long been a prime destination for US investment, the US tax reform has raised questions for the Irish tax model and how it will stand its own following the Tax Cuts and Jobs Act was passed. Companies like Facebook and Apple have recently overhauled their tax arrangements, and Ireland faces several other external threats to its tax system. Donal Leahy from Baker Tilly Hughes Blake talks about

Q&A: EC's Stephen Quest Talks About The EU's Digital Tax Future

The European Commission’s Director General for Taxation and Customs Union tells International Tax Review about how the European Commission is pushing ahead with its plans for a digital tax framework, how it will work with OECD initiatives, and the emerging industries and technologies making their mark.

US Tax Reform Set To Increase Number Of CFCs And Transparency Risk

The US tax reform introduces changes to Subpart F stock attribution rules that are expected to result in the formation of many new controlled foreign corporations. However, the amendments leave room for interpretation with tax professionals mooting whether the new repatriation and GILTI taxes could also be triggered.

Baker Tilly Thailand Transfer Pricing Update

On 3 January 2018, the Thai Cabinet approved the draft specific transfer pricing legislative provisions after public consultation during 2017. Taxpayers with international and domestic related party transactions should consider whether to expedite any transfer pricing analysis, comparable search and transfer pricing documentation in view of the mandatory reporting.

More Tax Guides from Baker Tilly in Cyprus

After the recent guides released by Baker Tilly in Cyprus, they have followed up with several more. They cover a range of topics including: Double Tax Treaty between Cyprus and Saudi Arabia, Cyprus taxation of property for VAT purposes and Extension for settlement of tax liabilities.

New U.S. Form 5472 disclosure rules for foreign-owned, single-member LLCs due in early 2018

Foreign-owned domestic companies, including U.S. LLCs, that are disregarded as separate entities for federal tax purposes (disregarded entities) are subject to a new disclosure obligation. Treasury regulations promulgated back in 2016 require such entities to file Form 5472 - Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business, disclosing certain transactions between the reporting entity and its foreign owner and other affiliates. The new reporting requirement administered by the Internal Revenue Service (IRS) is due for the first time in early 2018 and is subject to substantial non-compliance penalties.

Tax Guides from Baker Tilly in Cyprus

Baker Tilly in Cyprus has produced two tax guides to help provide you with up to date tax information and legislation. The first is a VAT Tax Flash, which talks about VAT treatment of holding companies and the the second is Baker Tilly in Cyprus' guide to the Cypriot tax system.

The Immediate Data Provision Obligation Regarding Electronic Invoices Commences On 1st July

The TPA Group, an independant member of the Baker Tilly Europe Alliance discuss the main rules of the online data provision becoming mandatory from July this year.

Technical Issues Give Rise To CbCR Deadline Extensions

Despite the vast majority of multinationals being ready to file their country-by-country reports by the end of the year, several countries chose to defer the filing deadline for a variety of reasons, including difficulties with the XML format. In more than 40 countries, multinationals with income greater than around €750 million ($904.5 million) had to file a country-by-country report (CbCR) at the end of December 2017.

Baker Tilly in the USA Helping to Untangle Tax Reform

Baker Tilly, our member firm in the USA, has written a number of articles to help you untangle the new US tax reforms. The articles cover the new 20 percent qualified business income deduction, bonus depreciation, recovery periods for real property and expanded section 179 expensing, business interest limitation and business losses and NOLs for corporate and noncorporate taxpayer

VAT Implementation in Saudi Arabia And UAE Has Teething Problems

Teething problems are common when tax systems are first introduced, but a number of factors have made matters more difficult in the Middle East. The tax authorities are struggling to answer all of the questions they are being asked, the legislation is imperfect and has already been tweaked in Saudi Arabia, not all companies are registered and a lack of low-denomination coins is proving problematic.

Year End Tax Planning Guide 2017/18

MHA, the UK member firm of Baker Tilly International, has produced a tax planning guide. The guide, which summarises some key tax and financial planning tips, covers a variety of topics, including income tax, capital gains tax, property investment and much more.

US Tax Reform: The Tax Cuts and Jobs Act Passes 

United States Congress has passed the Tax Cuts and Jobs Act and sent it to the President for his signature. The Act dramatically reduces the corporate income tax rate to 21%, transitions the US to a territorial tax system, provides for a one-time repatriation of foreign earnings and makes extensive changes to individual taxation rules. Most individual changes will expire after 2025.

Prepaying Taxes: Tax Cuts and Jobs Act

Paul Dillon, at Baker Tilly, the US member firm of Baker Tilly International, discusses prepaying taxes and the Tax Cuts and Jobs Act in this article.

Russia Extends 'Google Tax' As Part Of Tax Code Changes

The Russian government is preparing to extend the so-called ‘Google tax’ as part of changes to its tax code after President Vladimir Putin signed off on the proposals in December 2017. The government has also announced several other changes.

US Treasury Department and Internal Revenue Service Issue First Major Guidance Under Tax Cuts and Jobs Act

Jim Alajbegu, from Baker Tilly, a Baker Tilly International member firm in the US, has written an article which talks about repatriation tax and guidance on the Tax Cuts and Jobs Act.

December 2017

Planning for the US Tax changes

As the House and Senate reconcile their versions of the tax reform bill, taxpayers cannot afford to wait and see what happens; they need to act this month before certain opportunities go away. MBAF, a member firm of Baker Tilly International based in the United States, discusses how to plan for the changes to come.

The Israeli VAT Law

Baker Tilly, our member firm in Israel, talk about Israeli VAT law in a recent article

Investment in buildings in Israel

Baker Tilly, a member firm of Baker Tilly International in Israel, talk about how the Israeli encouragement of Capital Investments Law encourages investment in buildings designated for residential rental in Israel.

German Tax Risk: Offshore Companies can be Classified as Foreign Base Companies

Company structures involving companies from certain offshore jurisdictions are subject to strict scrutiny by German tax authorities.

Navigating Global Research and Development Incentives

We are pleased to publish our 2017 Global Research and Development Incentives Publication, which allows readers to efficiently analyse, at a high level, the tax benefits available in more than 50 key countries worldwide - key when embarking on a project to locate qualifying research and development activities.

Q&A: European Tax Commissioner Pierre Moscovici Talks Tax Havens and the Digital Single Market

European Commissioner for Economic and Financial Affairs, Taxation and Customs Pierre Moscovici speaks to International Tax Review about the EU’s blacklist of tax havens, the struggle to tackle tax avoidance and how to tax the digital economy.

Tax Reform: The Senate Bill Passes

Last week, the Senate passed its own version of the Tax Cuts and Jobs Act (TCJA), its tax reform bill with the same name as the House’s version. The Senate significantly modified the bill approved by the Senate Finance Committee prior to Thanksgiving. This alert will focus on the key changes.

Grey is the new black in EU’s tax haven blacklist

The EU has released its first ever blacklist of 17 tax havens, including South Korea, United Arab Emirates and Panama, as well as a grey list of 47 other jurisdictions, but has received criticism for going easy on notorious tax havens.

UAE And Saudi Arabia Ready For VAT: Are You Prepared?

The United Arab Emirates and Saudi Arabia have published their final VAT laws, but questions remain over just how ready the GCC and its taxpayers are for VAT with only a month to go.

UK proposes stop-gap measures to tax digital companies

The EU and the UK have threatened unilateral action on tax reforms for the digital economy ahead of the OECD’s 2018 interim report on the issue. Proposals so far indicate a paradigm shift towards taxing the functional areas of the digital economy.

November 2017

Who Will Be On The EU’s Tax Haven Blacklist?

The European Union is about to release a blacklist of uncooperative tax jurisdictions as part of the international effort to crackdown on tax avoidance. The blacklist has sparked speculation over which countries are most under threat.

Affordable Care Act reporting update

Employers are actively preparing for the Affordable Care Act (ACA) reportable year 2017 forms release. No, the IRS has not adjusted the deadlines for the 2017 reporting that is due in early 2018. What the IRS has done recently, however, is update its guidance on how it intends to assess 2015 employer shared responsibility mandate penalties. Since this process is new for everyone, we are taking this opportunity to review what we know about it as of today.

Why Does Capital Investments Law Encourage Tourism

Baker Tilly, a member firm of Baker Tilly International in Israel, talk about how capital investments law encourages tourism and has other benefits.

CbCR may bring upswing in corporate tax revenues

Corporate tax revenue collections remain at low levels around the globe, the OECD’s annual tax revenue statistics show, but advisers believe increased transparency and potential audits drawing on country-by-country reports could turn this around.

A Britain Fit For The Future

Following on from today's Budget, tax partner Nigel May, tax manager Katriona McEwan and tax development manager Androulla Soteri from our UK member firm MHA MacIntyre Hudson, discuss the key points from the Chancellor's speech.

Implementation of the EU Anti-Tax Avoidance Directive in Cyprus

The Tax Department has presented a discussion draft of a bill to amend the Cypriot tax laws for the purposes of introducing in these laws with the provisions of the EU Anti - Tax Avoidance Directive ("ATAD"), which was approved by the EU Commission in 2016. The Tax Department invited comments from interested parties in order to finalise these changes. 

Taxation of Trusts in Israel – Types of Trust

A simple guide to four key types of Trust in Israel.

Will UK's VAT threshold fall?

In its review of VAT, the OTS recommended that the UK government examine the registration threshold for VAT because the current level of £85,000 ($111,300) is unsuitable. The UK has the highest VAT threshold in the European Union, where the minimum threshold is €10,000 ($11,800) but the average is €22,000. The high threshold means that there is a “cliff-edge” for businesses, which offers an incentive to find creative ways to lower turnover in order to avoid paying VAT.

Switzerland: Partial amendment VAT Act from 1 January 2018 and 1 January 2019

As a result of the referendum on 24 September 2017 the VAT rates will be adjusted as of 1 January 2018.

The Senate releases its version of tax reform

On Thursday, the Senate released a detailed description of its initial tax reform bill, the Senate Tax Cuts and Jobs Act (STCJA). The STCJA now heads to markup by the Senate Finance Committee the week of Nov. 13. Majority Leader Mitch McConnell indicated he expects the Senate to hold a vote on the bill before Thanksgiving. If it passes, it would then go to a conference committee to negotiate differences between it and the House version.

Lebanese Government Approved New Tax Changes

The Lebanese Government has approved new tax changes introduced by Law No. 64 dated 20 October 2017, published in the official Gazette on 26 October 2017, deemed essential to fund the additional cost of the salary scale. The new law has introduced new taxes, as well as an increase of rates on existing taxes.

Year-end tax planning letter 2017

2017 has yet to produce any meaningful enacted federal tax legislation. While the House has introduced its tax reform bill, numerous questions remain. As this letter is published, the Senate has yet to weigh in. Although the process continues, how to pay for the proposals and what deductions will be eliminated or modified remain fiercely debated.

House Releases Tax Reform Bill

he House of Representatives released the initial draft of its tax reform bill, the Tax Cuts and Jobs Act (TCJA), on Thursday. The bill now heads to markup by the Ways and Means Committee next week. Speaker Paul Ryan indicated he expects the full House to hold a vote on the bill the week of 13 November.

Harmful tax incentives critically curtailed: BEPS Action 5 in action

BEPS Action 5 – Countering harmful tax practices more effectively by taking into account transparency and substance is one of the four BEPS minimum standards. To date, 102 jurisdictions have committed to its implementation, and 2017 is a decisive year in translating that commitment into action. Achim Pross, Kevin Shoom and Melissa Dejong of the OECD, discuss the first results of the work under BEPS Action 5, and its significance in achieving the goals of the BEPS project.

Highlights of the 2018 Malaysian Budget Proposals

The 2018 Malaysian Budget was presented by the Government of Malaysia on 27 October 2017. The theme of Budget 2018 was ‘Prospering an Inclusive Economy, Balancing between Worldly and hereafter, for the Wellbeing of Rakyat (people of Malaysia) and towards the TN50 Aspiration.

October 2017

GOP Tax Reform Framework and its Impact on International Tax

The GOP released the much-awaited installment of the tax reform guidelines a few days ago, dubbed as the unified framework to overhaul and simplify the Internal Revenue Code.

Amazon and eBay profiting from foreign traders avoiding UK VAT

The UK is losing billions of pounds in revenues each year from online VAT fraud committed by foreign traders. But with Amazon and eBay profiting from the fraudsters, and HMRC not doing enough to tackle the problem, is collaboration or conviction the better solution?

Austria’s Hans Jörg Schelling eyes EU digital tax rules

Austrian Federal Minister of Finance Hans Jörg Schelling has not held back on his views of how to tax multinational corporations so they pay their fair share. He talks to Anjana Haines about what he has planned over the coming year.

Finnish court issues landmark TP ruling involving ERP

The Finnish Administrative Supreme Court on September 13 issued two rulings, korkein hallinto-oikeus (KHO) 2017:145 and KHO 2017:146. Both rulings have been welcomed by Finnish TP professionals as potential trendsetters for future transfer pricing rulings as these are generally scarce in the country.

Q&A: Tomas Balco rolls out busy BEPS agenda as new head of OECD’s TP unit

Tomas Balco brings to the table work experience from the public and private sector, and is known as a consensus builder on both the national and regional level. Prior to taking up the position at the OECD, Balco was the general state counsel and head of international taxation at the Slovak Republic’s Ministry of Finance between 2014 and 2017.

News on Withholding Taxes in 2018 and 2019 in the Netherlands

On 19 September 2017, the Dutch Secretary of State published proposed legislation for the Dutch Dividend Withholding Tax (DWT) Act. The legislation contains significant changes for Dutch Co-operatives (Co-ops) as well as a new general exemption from DWT. It will be brought to Dutch congress during the autumn of 2017 and is likely to take effect on 1 January 2018.

UK and Ireland Brace for Customs Chaos as ‘no-deal’ Brexit Looms

The UK has released a white paper examining possibilities for its post-Brexit customs system once it leaves the EU’s customs union, and a more revealing report by Ireland’s Revenue has added further detail.

Amazon slapped with €250 million bill for illegal state aid

Luxembourg will have to reclaim €250 million ($294 million), plus interest, from Amazon for “undue tax benefits” after the European Commission announced its state aid decision in the case. But the amount is surprisingly small and many say the decision doesn’t tackle the real issue.

September 2017

EU to Redesign Tax Net to Catch Online Giants 

The European Commission (EC) will set out a “strong and ambitious” vision on how to tax the digital economy in early 2018, targeting companies such as Google, Amazon, Microsoft and Apple.

ECOFIN to Consider Virtual PE Rules to Tax Digital MNEs 

Multinational technology giants like Google, Amazon, Apple, Microsoft and Facebook could face higher tax bills under EU plans to introduce virtual permanent establishment rules. However, such rules could be difficult for governments to administer.

Our UK Member Firm MHA MacIntyre Hudson has Published a Corporate Criminal Offences - Business Planning Guide

Our UK member firm has published a guide which sets out the scope of the new offence. It explains the practical steps that businesses should consider taking to protect themselves against criminal liability.

Switzerland: Partial Amendment to the VAT Act from 1 January 2018 and 1 January 2019

VAT law in Switzerland will be subject to partial amendments from 1 January 2018. These amendments could have major impacts for foreign companies.

France Tries to use PE Rules to Make MNEs pay a ‘Fair Share of Tax’

The French permanent establishment rules are the country’s biggest hurdle in taxing Google, Amazon, Facebook and Apple (GAFA) in the way it wants. But it is determined to use these rules to make such digital companies pay what it believes to be their ‘fair share of tax’.

August 2017 

Trump's Tax Reform: Economic Growth Tool or Tax Break for Corporates?

President Donald Trump on Wednesday delivered a new round of promises of a “pro-growth, pro-jobs and pro-American” tax reform, including a 15% corporate tax rate. However, sceptics say his proposals do not match the rhetoric, and that they may be impossible to implement all at once.

The Status of Tax Reform

As the Senate struggled with the repeal and replacement of the Affordable Care Act (ACA), Congress has been working behind the scenes on tax reform. Leadership from both the House and the Senate has been holding discussions with their committees of relevant jurisdiction as well as the White House (this group has informally become known as the “Big Six”). 

OECD’s Base Erosion Profit Shifting (BEPS) and Thailand: Tax Structuring in Thailand Under International Tax Law Changes

Baker Tilly Thailand review specific issues that may need to be reviewed under the Thai and international tax law. 

Brazil Looks to Introduce VAT to Ease Compliance for Corporates

Brazil is seeking to become the latest major economy to introduce a national VAT system to end the torturous system of multiple state taxes that is causing headaches for companies.

Q&A: Maltese Finance Minister Edward Scicluna Surveys a Changing EU Tax Landscape

Scicluna has returned to his role as the Maltese finance minister after the country’s presidency of the EU Council ended in June. When Malta began its six-month presidency, many were sceptical about how the leaders of the small Mediterranean island could achieve their ambitious objectives – particularly the tax measures.


July 2017

Trump Set to Axe US Anti-tax Avoidance Measures

A new notice from the IRS reveals President Donald Trump’s plans to revoke Obama-era anti-tax avoidance measures including earnings stripping rules, which could cause an upsurge of inversions.

Q&A: Cypriot Finance Minister Harris Georgiades Wants a More Transparent and Attractive hub for Corporates

Harris Georgiades, Cyprus’ minister of finance, talks to Natalie Leonidou about tax reform and why his country is an attractive investment hub despite the drive for transparency in the wake of BEPS.

Transatlantic ties Smoulder as Ireland set to Collect €15 Billion from Apple

Tax community members on both sides of the Atlantic are holding their breath for a reaction from the US government as the European Commission picks up its investigations into cross-border tax strategies and alleged state aid cases of US tech companies.

New International Tax Treaty in Israel

As part of the effort to reduce the usage of black capital and tax evasion by taking advantage of the international system, the Israeli Tax Authorities recently signed agreements with various countries for the exchange of financial information. 

GST Payable on Supplies of Digital Downloads and Other Intangibles from Offshore 

In 2016, Baker Tilly Pitcher Partners issued an alert to highlight that the Australian Government has enacted measures commonly referred to as the ‘Netflix Tax’ to bring supplies of intangibles made by non-resident suppliers to Australian consumers within Australia’s GST net.

US Income Tax Authorities Targeting Foreign Companies on Non-compliance 

Over the next several weeks, the Internal Revenue Service (IRS) will be sending letters to foreign businesses active in the US to inquire about their compliance with US federal income tax laws. The initiative targets large multinationals importing goods into the US as well as middle-market global companies with US customers. 

Q&A: Pascal Saint-Amans Comes out Fighting for the OECD’s Blacklist and CbCR Standard

The OECD has found itself at odds with both the EU and the Tax Justice Network in the past week over divergent transparency standards. Pascal Saint-Amans, the organisation’s head of tax policy and administration, explains to Salman Shaheen why he believes its blacklist and non-public CbCR standard are the right approach.

Q&A: Nissan Motor’s Soichiro Matsuo and Inga Kondrataite Gain Pole Position on BEPS Implementation

Soichiro Matsuo, global head of TP, and Inga Kondrataite, regional head of tax for Asia Pacific, talk to TP Week from Nissan Motor’s headquarters in Japan about working through the challenges of implementing BEPS measures and CbCR. Their work on documentation, APAs and the management of TP globally has earned Nissan the International Tax Review Asia In-House Transfer Pricing Team of the Year award.

Google not out of the Woods After Landmark $1.25 Billion French Court Victory

After a six-year tussle, Google has emerged victorious after the Paris administrative court found in its favour over a PE dispute. But the French authorities have announced their intention to appeal.

Tax Treatment of Intra-Group Back-to-Back Financial Arrangements

On 30 June 2017, Baker Tilly in Cyprus issued a document stating the Cypriot tax department had issued an interpretative circular relating to the revised tax treatment of intra-group back-to-back financing arrangements.


June 2017

Companies Across Germany Could Face State Aid Clawback

German companies could be hit with an unexpected tax bill if the European Court of Justice (ECJ) rules that a commonly used clause in the country’s Real Estate Transfer Tax (RETT) Act constitutes state aid.

GST on Supplies of Low Goods to Australian Consumers: Delayed Until 1 July 2018

Baker Tilly Pitcher Partners recently prepared a tax bulletin in respect of the delay regarding the proposed changes to GST in Australia.

New Cyprus Legislation: Payment of Overdue Taxes by Monthly Instalments  

The House of Representatives approved unanimously the bill proposed by the parliamentary parties, which regulates the issue of payment of overdue taxes by monthly instalments.

Ground-breaking Multilateral BEPS Convention Signed at OECD will Close Loopholes in Thousands of Tax Treaties Worldwide

Taken from the Organisation for Economic Co-operation and Development (OECS) press statement published on 7 June 2017.


May 2017

EU Council Adopts Directive to Crack Down on Hybrid Mismatches

The Directive, which is also known as the Anti-Tax Avoidance Directive 2 (ATAD 2), will amend the existing ATAD 1. The rules are designed to stop companies exploiting the differences between the tax systems of EU member states and non-EU countries to avoid paying tax, or to gain a double tax deduction, known as hybrid mismatches.

Litigation, Litigation, Litigation? - How the OECD’s BEPS Guidelines are Affecting Brazil, Mexico and Argentina

The impact of the base erosion and profit shifting (BEPS) guidelines has been manifold in Latin America. Despite the certainty these guidelines have generated in some tax markets, their implementation has seen an increase in court litigation in Brazil, Mexico and Argentina.

Macron’s Victory Puts Corporate Tax Cuts on the Agenda

After 66-34 victory in the French election, Emmanuel Macron faces the difficult task of fighting the legislative elections and building a government to deliver his reform agenda: cutting taxes and public spending. The outcome was a significant relief for European leaders in particular.

Technology Solutions in a Post-BEPS World

There has been a complete paradigm shift in global taxation with the rise in audit risks caused by new global initiatives like the Organisation for Economic Co-operation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) Project. 

Australia: More Regulation, Less Innovation in the Federal Budget

Baker Tilly Pitcher Partners welcomes the Turnbull Government’s efforts to back small business and invest in infrastructure to grow the Australian economy.


April 2017

White House Announces Tax Plan
The Trump administration announced its tax plan on 26 April 2017, labelling it the largest corporate tax cut in history.

OECD Releases Further Guidance on Country-by-country Reporting
Multinationals will have an easier time understanding the requirements of country-by-country reporting due to the release of the Inclusive Framework on base erosion and profit shifting, which contains further guidance on the subject.

GST to Become Payable on Sales of Low Value Goods into Australia From 1 July
In November 2016 the Australian Government announced its intention to impose goods and services tax (GST) on supplies made by offshore suppliers of ‘low value goods’ to Australian consumers. The government has now introduced a Bill into Parliament to enact these changes. The changes are due to commence on 1 July 2017.

Cyprus – Iran and Jersey: Double Tax Treaties Which Have now Entered into Force
The double tax treaties with Iran and Jersey have now entered into force and will come into effect as from 1 January 2018.

Businesses Prepare for GST After Parliament Passes Laws
India’s goods and services tax (GST) regime is set to begin on 1 July after the lower house of parliament passed four GST-related laws and the upper house prepares to do the same.


March 2017

Apple Challenges EC’s Use of Arm’s Length in State Aid Case
Apple released its grounds for appealing the €13 billion (US$14 billion) tax bill from the European Commission earlier this week, arguing that the Commission’s arm’s-length test did not comply with EU laws for determining state aid in tax assessments.

India’s GST Almost set for 1 July Implementation 
Businesses have less than two months to complete their preparation for India’s GST regime after the GST Council passed a major landmark in its latest meeting.

A Brief Timeline on the Developments of the LuxLeaks Case 
International Tax Review breaks down the developments that led to the conviction of former PwC employees Antoine Deltour and Raphaël Halet, who exposed more than 300 multinational enterprises benefiting from sweetheart tax deals with the Luxembourg authorities to avoid taxes in Europe. 


February 2017

US Tax Reform
The new US Presidential administration and Congress have created much speculation and anxiety about how tax reform will proceed and who will be most affected by the result. Baker Tilly in the US is dedicated to keeping you abreast of significant tax reform proposals and enacted legislation.


January 2017

UK Prime Minister Set Out Government’s 12 Negotiating Objectives for Brexit
On 17 January 2017 UK Prime Minister, Theresa May, set out the Government’s 12 negotiating objectives for leaving the European Union (EU). Below is the extract from her speech.