Strategizing International Tax Best Practices – by Keith Brockman

Archive for the ‘Transfer Pricing’ Category

Singapore’s (expanded) TP Guidelines

The Inland Revenue Authority of Singapore (IRAS) has published an expanded Transfer Pricing (TP) e-Tax Guide (linked herein for reference) that consolidates the four previous TP guides.  The Guidance adheres to the TP arm’s length principle, while expanding required disclosures in alignment with the OECD BEPS objectives.

Click to access etaxguide_Transfer_Pricing_Guidelines_(Second_Edition)_2015_01_06.pdf

Key observations:

  • IRAS will adjust profits upwards for understated profits, although no mention is made of downward adjustments.
  • IRAS welcomes discussions to discuss difficulties in applying the arm’s length principle.
  • Contemporaneous TP documentation = on or before the tax return due date.
  • Group level TP documentation includes an organization chart of all related parties transacting with the Singapore taxpayer, the group’s business models and strategies, profit drivers including a list of intangibles and legal owners, business activities and functions of each group member with relevant supply chains, business relationships among related parties and group financial statements for the lines of business involving the Singapore taxpayer.
  • Entity level documentation includes a list of related parties to whom the local management reports for its operations, number of employees in each department, business models and strategies, contracts/agreements apart from detailed functional and benchmark analyses.
  • TP documentation exceptions include in-country related party transactions, routine services charged at cost + 5%, APA agreements or de-minimis stated thresholds for transactions and services between related parties.
  • Collaborative engagement methodologies are outlined for the Transfer Pricing Consultation program, by which TP methods and documentation of selected taxpayers will be reviewed.  Examples of high risk transactions are included in Section 7.5
  • Unilateral APAs are not accepted.
  • APA rollback years are acceptable, generally limited to 2 years.
  • MAP and APA methodologies are stated, including factors when IRAS will discontinue the MAP or APA process.
  • Section 16 summarizes updates and amendments of the TP Guidelines.

These guidelines should be reviewed, especially the new TP documentation guidelines as other countries in the APAC region and elsewhere will monitor and possibly adopt similar guidelines.

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Transfer Pricing

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UK Diverted Profits Tax: Parliamentary debate

The UK Diverted Profits Tax proposal (refer to 12 December 2014 post) will become effective in April, 2015.  The Parliament debate sheds light on the intentions for such tax, as well as the assumptions (true or false) underlying this initiative.

The debate clarifies that such “tax” is not meant to be a tax that meets the definition of a tax for double tax treaty purposes, therefore it is subject to domestic legislation and not overridden by its treaty network.  This rationale therefore leads to the premise that it may not qualify as a tax subject to a US Foreign Tax Credit, resulting in a double “tax” situation regardless of the nomenclature.  Additionally, the Mutual Agreement Procedure (MAP) provided for in a double tax treaty would not be available for recourse.

The tax is aggressive in its timing, ahead of the final OECD proposals and in contrast to other initiatives for which the UK is awaiting final BEPS guidance.  The debate highlights the cynicism about the OECD process, thus providing a rationale for unilateral legislation sooner vs. later.  Additionally, this proposal was discussed as a Targeted Anti-Avoidance Rule (TAAR), which is in addition to the EU and UK General Anti-Avoidance Rules (GAAR).

Most importantly, a diverted profit tax situation involves an initial recharacterization assessment by HMRC, requiring payment by the taxpayer, with appeals to follow later – a “Pay Now, Talk Later” approach.

The clock is ticking and time is winding down with alot of questions remaining unanswered.  The debate is provided for reference:

http://www.publications.parliament.uk/pa/cm201415/cmhansrd/cm150107/halltext/150107h0001.htm

It is very useful to review the Intent of new laws to form a better understanding for the formation of such initiatives, as well as comprehension into the foresight of drafters re: possible appeals by the European Commission and/or European Court of Justice.

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Transfer Pricing

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BEPS Action 7 / PE: TEI’s comments

Tax Executives Institute, Inc. (TEI) has provided comments in response to OECD’s BEPS Action 7: Preventing the Artificial Avoidance of PE Status.

Click to access TEI%20Comments%20-%20OECD%20BEPS%20Action%207%20PE%20-%20FINAL%20to%20OECD%2023%20December%202014.pdf

Key observations:

  • Changes to the definition of a Permanent Establishment (PE) are more welcome in the Model Convention, as recommended, rather than modifying the official commentary.
  • Continued focus on physical presence in the general definition of a PE is commended.
  • “The Discussion Draft generally views commissionaires as structured “primarily” to permit MNEs to erode the tax base of the State of sale.” However, there is no mention of the legitimate arrangements for which they are used.
  • Four amendments are proposed, each of which would likely eliminate the commissionnaire arrangement and increase uncertainty.
  • The new paragraph 6, broadening the definition of an independent agent, is vague and problematic.  This change may result in a subsidiary being a dependent agent of the parent in a limited risk distributor situation, resulting in PE of the parent.
  • The proposed anti-fragmentation rules for a PE exception are subjective and increase uncertainty.
  • The Authorized OECD Approach (AOA) for determining a PE’s profits are complex and uncertain.
  • There are no transition periods or grandfathering provisions for implementation of the new PE definition.

TEI’s commentary is well written and poses practical arguments that should be considered by the OECD.  Accordingly, it is a document that should be required reading for all tax practitioners involved in transfer pricing.  The proposed changes will also affect other aspects of transfer pricing and BEPS Actions that will be finalized this year.

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OECD / UN, PE, Transfer Pricing

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Denmark: (Super) GAAR?

The General Anti-Avoidance Rule (GAAR) has received a status of prominence during 2014, and continues its subjective and complex override provisions in domestic law that are interwoven with treaty provisions.

Denmark has proposed a (Super) GAAR, trumping the EU Parent-Subsidiary Directive, EU Interest-Royalty Directive, EU Merger Directive and Danish double tax treaties.  Notwithstanding its current status as a “proposal,” Denmark’s intent is clearly shown to provide an umbrella rule, evidently overriding the respective treaties, providing that a “main purpose” rule which achieves tax advantages would be used to disallow respective tax benefits of the transaction(s).  The proposed rule would be effective by 01 May, 2015.

PwC’s Insight has provided a brief summary of the proposal:

Click to access pwc-denmark-introduce-gaar-double-tax-treaties-directives.pdf

GAAR continues to be “the elephant in the room,” highly visible although the rules and appeal avenues are distinct and arbitrary for every country.  Some countries have GAAR rules, along with specific / targeted anti-avoidance rules (SAAR / TAAR).  Thereby, tax uncertainty and the risk of double taxation increases, dispute resolution (if available) avenues are further stressed, and arbitration measures may not be available.

With respect to arbitration, it should be adopted by every country to achieve mutuality with taxpayers, however some countries have expressly stated that they do not want to give up their control / sovereignty.  Unfortunately, OECD has not aggressively pursued this remedy for multilateral agreement.

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OECD / UN, Tax Risk Management, Transfer Pricing

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Korea: Accumulated earnings tax/reforms

EY’s latest Tax Alert has summarized the effect of Korea’s new tax proposals, provided herein for reference.

Key observations:

The accumulated earnings tax will require a review of Korean entities for which equity capital exceeds the KRW 50 billion threshold, as well as recognizing the revised 2:1 debt to equity ratio and the deadline for filing the report for international transactions. 

On 2 December 2014, Korea’s National Assembly passed 2015 tax reform proposals, 1 which were enacted into law on 23 December 2014. A new proposal regarding capital gains tax on income from trading financial derivatives was introduced in a separate package and is also now enacted. This Alert summarizes key features of the new laws.

Corporate accumulated earnings tax
A new corporate accumulated earnings tax will be imposed on excess cash accumulated by large corporations whose equity capital exceeds KRW 50 billion (US$49 million) and corporations that are members of an enterprise group with restrictions on mutual investment.2

The corporation may apply one of the two methods in calculating the accumulated earnings tax. Method A computes a 10% tax on 80% of adjusted taxable income3 reduced by amounts spent on investment on tangible and intangible assets, salary increases, dividends and certain qualified capital redemptions. Method B calculates the 10% tax on 30% of adjusted taxable income reduced by amounts spent on salary, dividends and certain qualified capital redemptions.

The new law will be effective for taxable years beginning on or after 1 January 2015 and before 31 December 2017.

Increase in the debt to equity ratio
Under the new law, the debt to equity ratio is revised to 2:1. This change will become effective for fiscal years beginning on or after 1 January 2015. However, the debt to equity ratio applicable to financial institutions will remain unchanged from the current 6:1.

Capital gains tax on income from trading financial derivatives
The new law, as part of the Individual Income Tax Law, imposes a 20% tax on gross capital gain reduced by KRW 2.5 million (US$2,300). The Enforcement Decree however has reduced the rate to 10%. Financial institutions such as brokerage firms are required to report details of financial derivative transactions on a quarterly basis to a tax office. This law will be effective as of 1 January 2016.

Tax refund claim period extended from three to five years
Under the new law, the current three-year refund claim period is extended to five years from the date of the statutory filing due date.

Failure to submit data on international transactions with foreign related parties
The new law imposes a penalty not to exceed KRW 100 million (US$95,000) on the failure to timely file a report of international transactions with foreign related parties.

Extended statute of limitation period on tax evasion involving cross-border transactions
The statute of limitation period is extended to 15 years for cross-border tax evasion matters. The amendment becomes effective for the first tax assessment made after enactment of the law.

Increased penalties on tax evasion involving cross-border transactions
Under the new law, a new penalty is imposed on non-filers or the underreporting of income derived by cross-border transactions. The rate is 60% of the amount of the tax evasion and it becomes effective for taxable years beginning on or after 1 January 2015.

Endnotes
1. See EY Global Tax Alert, Korea announces 2015 tax reform proposals, dated 28 August 2014.

2. A Korean conglomerate with assets of more than KRW 5 trillion (US$5 billion).

3. Adjusted taxable income means taxable income plus additions such as dividend received deduction, interest on tax refund, depreciation expense on current year fixed asset acquisition minus corporate income tax, reserves, net operating loss, excess donation expense over a deduction limitation.

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Transfer Pricing

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EU ruling request: 2010-2013

In the context of State Aid, aggressive tax planning, tax avoidance and competition for a country’s fair share of tax, the European Commission has broadened its earlier request for taxpayer rulings to include all tax rulings of all Member States from 2010 to 2013.  This initiative introduces additional transparency into the ruling practice of Member States.

Most importantly, the tax cost for denial of tax benefits for previously issued rulings is incurred by the respective companies, not the Member States.  MNE’s can participate, directly and/or indirectly, into the process if such rulings are formally investigated.  A link to the press release is attached for reference:

http://europa.eu/rapid/press-release_IP-14-2742_bg.htm?locale=FR

This initiative should be monitored by all MNE’s, supplemented by coordinating a list of all such rulings that would be requested for additional review and reference.

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Transfer Pricing

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China GAAR: New rules

China’s State Administration of Taxation (SAT) has established rules for implementing its General Anti-Avoidance Rule (GAAR), effective 1 February 2015.  A PwC summary and details of the rule, as translated into English, are attached for reference:

Click to access 635539923624544645_chinatax_news_dec2014_33.pdf

Click to access 635540044774352869_chinatax_news_dec2014_33_article.pdf

Note, as in most GAAR provisions, the definition is subjective in nature.  Additionally, these rules would be applied after the Specific Anti-Avoidance Rules (SAAR) are applied, resulting in a tiering of potential disallowance avenues.  However, the MAP rules could be employed to minimize double taxation consequences.

As the GAAR provisions are being enacted into domestic law, as well as treaties, in addition to existing rules for SAAR, these rules are critical for new arrangements / transactions, as well as preparing relevant documentation for future reference and defense.

 

 

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Transfer Pricing

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UK: Diverted Profits Tax & CbC reporting

HMRC is taking a unilateral proactive lead in devising measures based on OECD BEPS initiatives that introduce a diverted profits tax, as well as country by country (CbC) reporting for UK headquartered MNE’s.  A Tax Journal summary provides a summary of the diverted profits tax, which is linked herein, in addition to the HMRC source articles for application of the diverted profits tax and CbC reporting.

http://www.taxjournal.com/tj/articles/google-tax-sends-clear-message-multinationals-divert-profits-10122014

Click to access Diverted_Profits_Tax.pdf

Click to access TIIN_2150.pdf

Diverted Profits Tax:

This measure will introduce a new 25% tax (regular tax rate plus a punitive component) on diverted profits. The diverted profits tax will operate through two basic rules. The first rule counteracts arrangements by which foreign companies exploit the permanent establishment rules. The second rule prevents companies from creating tax advantages by using transactions or entities that lack economic substance.  The proposal will be effective as of 01 April 2015.

The main objective of the diverted profits tax is to counteract contrived arrangements used by large groups (typically multinational enterprises) that result in the erosion of the UK tax base.

CbC reporting:

The publication allows regulations to be issued re: CbC reporting for UK-based companies after the OECD publishes guidance on how the reports should be filed and how the information in them may be shared between relevant countries, and after a period of consultation in the UK.

After issuance of the hybrid mismatch rules (post of 7 December 2014) that patiently await the final OECD guidelines for consensus in its guidelines, the diverted profits tax mechanism will be in effect next year prior to final OECD guidelines and subject to other countries following a similar early unilateral lead as incentivized by the BEPS initiatives.

The CbC reporting is addressed at UK-based MNE’s, while presumably non-UK based MNE guidance for such reporting will be also be issued in the near future.

These initiatives may target legal mechanisms that the taxpayer will need to defend aggressively, while advancing preparation for timely compliance for CbC reporting.  Additionally, other countries may use this information via automatic exchange of information to assist in transfer pricing risk assessment.  The initiatives should be reviewed in detail to better understand the rules, and trends, for these proposals.

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Transfer Pricing

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UK: “Aggressive tax planning” consultation paper

HMRC has published draft rules, entitled “Tackling aggressive tax planning,” to give effect to OECD’s BEPS Action 2 item, Neutralising the Effect of Hybrid Mismatch Arrangements.

The legislation will be effective as of 1/1/2017, preceded by this consultation paper, a summary of responses in summer 2015 and a second consultation on proposed draft legislation prior to its introduction in a future finance bill.  Interested parties have until 11 February 2015 to provide comments for this consultation.

The draft legislation is envisioned to follow the OECD guidelines, and commentary, that are due to be completed by September 2015.  A copy of the consultation paper is provided for reference:

Click to access tackling_aggressive_tax_planning_hybrids_mismatch_arrangements_consultation_final.pdf

Key observations:

  • The primary and defensive rules, as provided by the OECD BEPS Guidelines will be followed.  The primary rule will be used to deny the payer’s deduction for a deduction/no income inclusion arrangement of a hybrid financial instrument or disregarded payment made by a hybrid entity, while the defensive rule would include taxing the income by the payee.  For a double deduction arrangement of a deductible payment made to a hybrid entity, the deduction by the investor’s parent jurisdiction is denied using the primary rule, while the defensive rule would deny the payer deduction.
  • Rules will be considered to restrict the tax transparency of reverse hybrids.
  • The UK anti-arbitrage rules will not likely be retained.
  • The definition of an “arrangement” will not be the OECD version, as the existing UK definition would be used to achieve the same result.
  • Timing differences are not included, unless it appears that they will not unwind within a reasonable (5 years) time period.
  • The mismatch rules will apply for intra-UK and cross border situations.
  • For mismatches as a result of both a hybrid financial instrument and a hybrid entity, the hybrid financial instrument rule applies first.
  • Amended corporation tax returns and/or MAP procedures are permissible if the original mismatch no longer exists.
  • Tax treaties will not prevent the application of the recommended domestic laws to neutralise the effect of hybrid mismatch arrangements, thus no treaty amendments are necessary to apply the mismatch rules.
  • No grandfathering rules are envisioned, as the advance announcement of the UK rules will provide a transitional period to unwind structures.
  • The hybrid mismatch rules will operate within the UK’s self-assessment regime.

As stated in the Foreword of the consultation document, the UK’s strategy is to create the most competitive tax environment in the G20 and has led the way, driving the international tax, transparency and trade agenda forward.

The consultation paper is comprehensive, with numerous examples provided to illustrate, and visualize, the impact of the proposed rules.  This proactive measure should be monitored to see how other countries follow the UK’s lead for taxing mismatch arrangements, including the timing and incorporation of the final guidelines by the OECD in 2015.

 

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Transfer Pricing

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Russia: New CFC & Beneficial Ownership rules

Russia has introduced legislation defining a “beneficial owner” and the introduction of CFC rules, expected to be effective 1/1/2015.  PwC has provided a summary of the changes, referenced herein.

Click to access pwc-russian-anti-offshore-law-changes-russian-treaties.pdf

Key observations:

  • Treaty benefits will not apply if the foreign person has limited powers to dispose of the income or fulfill intermediary functions and do not perform any other duties or undertake any risks, or the income is subsequently transferred to another person who would not be entitled to treaty benefits if they had directly received the income.
  • Foreign corporations, trusts, partnerships and funds which hold property subject to Russian property tax are required to notify the Russian tax authorities of their shareholders and founders, beneficiaries and managers.  A 100% penalty tax may apply for noncompliance.
  • A legal entity may now be a Russian tax resident based on its place of management.
  • Russian tax individuals and legal entities must pay Russian tax on a CFC’s retained earnings if the CFC has not paid a dividend, subject to thresholds.  No penalty is applicable for 2015-2107.

Persons with Russian property and legal interests should review this important legislation to understand the new reporting rules and regime for CFC’s and beneficial ownership.  The law follows the intent of the OECD’s BEPS provisions to prevent tax avoidance via tax havens and low-tax jurisdictions.

 

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Transfer Pricing

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Beneficial Ownership: Guiding Principles

The G20 has provided a set of guiding principles re: definition of “beneficial owner” in its efforts to improve transparency and address abuse.  A link to the principles is provided:

Click to access g20_high-level_principles_beneficial_ownership_transparency.pdf

The principles are a proactive effort by the G20 to identify the ultimate ownership / control of legal entities, provide such information in a mechanism that allows sharing by tax authorities and competent authorities, as well as  assessing risk of legal structures and designing actions to fight abuse.

The principles should be compared to the new definition and guidance re: “beneficial owner” provided for the update to the 2014 OECD Model Convention (refer to 22 July 2014 post), which conveyed that the term should be understood in its context and in light of the object and purposes of the Convention including avoiding double taxation and  prevention of fiscal evasion and avoidance.

The focus on “Beneficial Ownership” is increasing, thereby increased diligence re: documentation to address transparency and benefits of current legal structures should be a top priority for MNE’s.

 

 

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Transfer Pricing

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Bangladesh TP Reg’s 2014: Effective July 2014

Bangladesh has introduced new transfer pricing (TP) regulations, effective from July 2014.

Key observations:

  • Definition of: associated enterprise, international transaction and arm’s length methodologies
  • No APAs or safer harbor rules
  • Key documentation requirements include:
    • Business relationships between each member of the MNE group
    • Consolidated financial statements of the MNE group
    • Record of any financial estimates
    • De minims requirements for international transactions less than approx. USD 390,000
    • New statement of international transactions required in addition to the income statement
    • Chartered Accountant’s report
    • 1% of value TP penalties

These rules, similar to Singapore’s recent comments for its proposed update for TP legislation, request broad and complex documentation requirements for the MNE group.  Accordingly, all MNE’s need to modify global transfer pricing documentation methodologies in response to unilateral legislation of various countries.

Most importantly, the global TP requirements will require attendees in all future audits to be familiar with these global methodologies and information that the tax authorities will have had the chance to review.  

A Financial Express summary is included for reference:

http://www.thefinancialexpress-bd.com/2014/06/17/39946

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Transfer Pricing

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TEI’s comments: Singapore’s TP documentation – Marching to a different drummer

Tax Executives Institute, Inc. (TEI) has provided excellent comments to the transfer pricing documentation paper by the Inland Revenue Authority of Singapore (IRAS).  TEI responds to five questions of the Consultation Paper.  A link to their comments, and the Singapore Consultation Paper,  are included for reference:

Click to access TEI%20submission%20re%20IRAS%20TP%20Documentation.pdf

Click to access pconsult_IT_Transfer%20Pricing%20Documentation_2014-09-01.pdf

Key observations:

  • The proposed rules for documentation by December elevate Singapore’s transfer pricing documentation requirements to a higher level than the current OECD guidelines, prior to its final recommendations, including how the Master File should be filed and transition thereto.
  • The Consultation sets forth guidelines for non-related Singapore entities including the provision of a functional analysis for contributions to value creation by each related group member, consolidated financial statements of the group, and transfer pricing policies re: all types of transactions between group members.  
  • Confidentiality concerns arise with respect to the proposed rules, accordingly appeals for exemption should be appropriately provided.
  • Adverse consequences for not providing “adequate documentation” (term not defined), including withdrawal of MAP support set forth in the relevant treaty.
  • TEI has proposed de minims thresholds to exclude immaterial transactions and excluding documentation for intra-country transactions.
  • TEI has suggested an approach to implementing new documentation guidance tracking OECD BEPS developments, with lead time to adjust processes accordingly.

TEI has provided a valuable contribution in their well-written and thoughtful comments to significant issues posed by countries unilaterally adopting new transfer pricing documentation rules prior to finalization of the OECD BEPS initiatives.

Most importantly, Singapore has suggested using domestic legislation to override the MAP process in treaties as well as introducing overly comprehensive documentation that has no relevance to the domestic entity and its intercompany transactions or transfer pricing methodologies.

This initiative by IRAS is indicative of a parade with an OECD banner, although each member has  a different drummer and leader with distinct initiatives and its concept for application of the “arm’s-length principle” to determine its fiscal fair share of tax to be collected from multinationals that will be determined prior to official OECD guidelines.  It is imperative that all interested parties follow this initiative by Singapore, in addition to correlative initiatives by other countries.

 

Category:

OECD / UN, Transfer Pricing

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TP Risk: Audit discussion = Framework for Ways of Working

As the OECD is developing new guidelines to address transfer pricing (TP) risk, including the Country-by-Country (CbC) template, a lack of emphasis resides in the idea that every tax audit involving cross-border issues should require an opening discussion between the taxpayer and the tax authorities of the business, its relevance in that jurisdiction apart from its global business, the functions, assets and risks for that jurisdiction upon which the arm’s length principle is based, and the rationale for the level of income/loss generated during the audit years.

Transfer pricing documentation reports, including a local country report, may be available for review.  However, such reports may not simply convey the business rationale easily to form an accurate understanding prior to embarking upon a leap into technicalities and assumptions to initiate data requests and move forward on assumptions prematurely.  For example, a company investing in a less developed country seeking long-term growth based on the domestic opportunity may have start-up losses, although such losses may be significantly offset by potential future income.

The open audit discussion should be developed into a Best Practice Ways of Working framework which is discussed and signed by the taxpayer and tax authorities.  This framework should be a simple and practical document addressing open dialogue, preliminary discussion of issues designed to produce the relevant documentation, timelines for requesting and providing information and a continuing dialogue discussing the status of open issues and requests, with a mutual effort to resolve issues efficiently.

To the extent this simple idea could be integrated consistently and uniformly around the world, it is a challenge worth addressing.

The Best Practice Ways of Working Framework could be a very effective and practical tool, supplementing the technical and legal requirements for transfer pricing.

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Transfer Pricing

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Substance vs. Form: “Directive Shopping”

Today’s tax climate, OECD Base Erosion & Profit Shifting (BEPS) Action Plans, 2014 changes to the OECD Model Tax Convention re: “Beneficial Ownership” (refer to 22 July 2014 post), and General Anti-Abuse Rules (GAAR) all focus on increased substance of activities in an entity, versus pure legal form, to derive relevant treaty benefits.

A recent Austrian Administrative High Court decision (VwGH 26/6/2014, 2011/15/0080-13) focused on the EU Parent-Subsidiary Directive (PSD) re: “directive shopping.”  There were dividend distributions from an Austrian company to a pure holding company in Cyprus with no people or physical assets. Withholding tax was paid by the Austrian company, with a refund claimed by the Cypriot company in accordance with the EU PSD.  (Note the Cypriot company had a Russian shareholder, for which direct distributions from Austria to Russia would not have the benefit of the EU PSD.)

The High Court, confirming the tax authority’s view, stated the Cypriot company structure was abusive.  Accordingly, the withholding tax refund application of the Cypriot company was denied.

The substance vs. form application of the case highlights the potential withholding tax issues for a pure holding company located in a tax favorable jurisdiction.  Thus, all holding company structures should be reviewed under current law, and most importantly with respect to future international tax changes focusing on the proper substance to receive treaty benefits.

Category:

Tax Risk Management, Transfer Pricing

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