International transactions

- eg, tax havens; withholding taxes; transfer pricing; taxes on non-residents

- see also Concessions; Corporations

G20 Leader's Declaration
Russia G20 (September 2013).  Read the G20 Leader's Declaration for the latest statement on international tax and transparency.

OECD Secretary-General Report to the G20 Finance Ministers and Central Bank Governors
OECD (July 2013). 

Action Plan on Base Erosion and Profit Shifting
OECD (July 2013). 

Automatic Exchange of Information: The Next Step - Information Brief
OECD (June 2013). 

A Step Change In Tax Transparency, Delivering a standardised, secure and cost effective model of bilateral automatic exchange for the multilateral context
OECD Report for the G8 Summit (June 2013).  A new OECD report, A Step Change in Tax Transparency, prepared at the request of the G8 for the Lough Erne Summit, outlines four concrete steps needed to put in place a global, secure and cost effective model of automatic exchange of information. The report follows the G20 Finance Minister's endorsement in April 2013 of automatic exchange of information for tax purposes as the expected new standard. It says because tax evasion is a global issue, the model needs to have worldwide reach to avoid merely relocating the problem elsewhere. The process also needs to be standardised to minimise costs for businesses and governments and to improve effectiveness.

Apple Is Not Alone
Citizens for Tax Justice (June 2013).  Recent Congressional hearings on the international tax-avoidance strategies pursued by the Apple corporation documented the company's strategy of shifting U.S. profits to offshore tax havens. But Apple is hardly the only major corporation that appears to be engaging in offshore-tax sheltering: seventeen other Fortune 500 corporations disclose information, in their financial reports, that strongly suggests they have paid little or no tax on their offshore holdings.

Submission to Issues Paper on Implications of the Modern Global Economy for the Taxation of Multinational Enterprises
Tax Justice Network Australia (May 2013).  The TJN-Aus agrees with the OECD that tax dodging by multinational companies can "produce unintended and distortive effects on cross-border trade and investments" and that "it distorts competition and investment within each country by disadvantaging domestic players".

Secrecy Jurisdictions, the ASX100 and Public Transparency
Dr Mark Zirnsak, Justice & International Mission Unit, United Church in Australia (May 2013).  Tax, not aid, is the most sustainable source of finance for development. Tax can help make governments accountable to their citizens, while aid can make them accountable to the interests of foreign donors. As put by South Africa's Finance Minister, Trevor Manuel, "It is a contradiction to support increased development assistance yet turn a blind eye to actions by multinationals and others that undermine the tax base of a developing country".

Apple Holds Billions of Dollars in Foreign Tax Havens: virtually none of its $102 billion offshore stash has been taxes by any government
Citizens for Tax Justice (May 2013). 

Revised Section E on Safe Harbours in Chapter IV of the Transfer Pricing Guidelines
OECD (May 2013). 

Forum on Tax Administration Final Communique
OECD (16-17 May 2013, Moscow).  Tax Commissioners from 45 countries gathered in Moscow commit to co-ordinated action to tackle transnational fraud, evasion and aggressive tax planning. In their final communiqué, they warned evaders that “however hard they try to hide, they will be found”.

Africa Progress Report 2013
Africa Progress Panel (May 2013).  Africa is standing on the edge of enormous opportunity, this year’s Africa Progress Report finds, and African policy makers have critical choices to make. They can either invest their natural resource revenue in people to generate jobs and opportunities for millions in present and future generations. Or they can squander this opportunity, allowing jobless growth and inequality to take root. In many African countries, natural resource revenues are widening the gap between rich and poor. Although much has been achieved, a decade of highly impressive growth has not brought comparable improvements in health, education and nutrition. The Africa Progress Panel is convinced that Africa can better manage its vast natural resource wealth to improve the lives of the region’s people by setting out bold national agendas for strengthening transparency and accountability. However, international tax avoidance and evasion, corruption, and weak governance represent major challenges. The report therefore welcomes the commitment from the current G8 presidency, the United Kingdom, and other governments to put tax and transparency at the heart of this year’s dialogue. It urges all OECD countries to recognize the cost of inaction in this vital area. Africa loses twice as much in illicit financial outflows as it receives in international aid. The Africa Progress Panel finds it unconscionable that some companies, often supported by dishonest officials, are using unethical tax avoidance, transfer pricing and anonymous company ownership to maximize their profits, while millions of Africans go without adequate nutrition, health and education.

OECD Secretary-General Report to the G20 Finance Ministers
OECD (April 2012).  OECD Secretary-General Angel Gurría has presented a report to G20 Finance Ministers and Central Bank Governors that highlights measures to ensure that all taxpayers pay their fair share. The report covers three strategic initiatives: 1) Progress reported by the Global Forum on Transparency and Exchange of Information for Tax Purposes including the upcoming ratings of jurisdictions' compliance with the Global Forum's standards on exchange of information on request; 2) Efforts by OECD to strengthen automatic exchange of information; 3) Latest developments to address tax base erosion and profit shifting, a practice that can give multinational corporations an unfair tax advantage over domestic companies and citizens.

Implications of the Modern Global Economy for the Taxation of Multinational Enterprises Issues Paper
Australian Government Treasury (May 2013).  There is growing concern – in Australia and globally – that many of the key rules of international taxation may not have kept pace with the evolution of the global economy. International tax reform is increasingly on the agenda of G20 Finance Ministers and Leaders. Last year the Government asked the Treasury to develop a Scoping Paper to examine the risks to the sustainability of Australia's corporate tax base from the way current international tax rules are able to be used to minimise or escape taxation. This analysis is being informed by a specialist reference group, made up of business representatives, tax professionals, academics and the community sector. The purpose of this Issues Paper is to seek views of stakeholders and the community more broadly to ensure the analysis in the Scoping paper captures and addresses the key issues. The Issues Paper outlines the challenges that changes in the global economy pose to the international tax system.

Global Forum on Transparency and Exchange of Information for Tax Purposes Progress Report to the G20 Finance Ministers and Central Bank Governors: Global Forum Update on Effectiveness and Ongoing Monitoring
OECD (April 2013).  The report covers three strategic initiatives: 1. Progress reported by the Global Forum on Transparency and Exchange of Information for Tax Purposes including the upcoming ratings of jurisdictions' compliance with the Global Forum's standards on exchange of information on request; 2. Efforts by OECD to strengthen automatic exchange of information; 3. Latest developments to address tax base erosion and profit shifting, a practice that can give multinational corporations an unfair tax advantage over domestic companies and citizens.

No More Shifty Business: A response to the OECD's Base Erosion and Profit Shifting report on tax published in February 2013
Jointly produced by a large number of civil society organisations (March 2013). 

Submission on Tax Laws Amendment (Cross-Border Transfer Pricing) Bill 2013 Modernisation of transfer pricing rules
Tax Justice Network Australia (December 2012). 

Tax Activists and the Global Movement for Development through Transparency
Allison Christians (2012).  Activists around the world seek to expose a global system that fails to tax multinationals adequately and thus deprives governments of needed revenues, with profound effects for development in the world’s poorest nations. These tax activists have sparked a global movement, with groups all over the world seeking progress for development in poor countries by demanding greater transparency about how and how much multinational companies pay taxes.

Towards Unitary Taxation of Transnational Corporations
Sol Picciotto, Tax Justice Network (9 December 2012).  It has become clear that we need to take a fresh look at how transnational corporations (TNCs) are taxed. This paper, building on long experience and analysis of the actual practice of tax administrations around the world, proposes a thorough reform of the system towards a fresh approach: Unitary Taxation. This would help place the international tax system on a foundation fit for the 21st century.

Addressing Base Erosion and Profit Shifting
OECD (February 2013) .  The project, quickly known as BEPS (Base Erosion and Profit Shifting) is looking at whether, and if so why, the current rules allow for the allocation of taxable profits to locations different from those where the actual business activity takes place. The aim is to provide comprehensive, balanced and effective strategies for countries concerned with base erosion and profit shifting.

The Economist: Special Report on Tax Havens
Professor Jason Sharman and Matthew Vallencia (February 2013).  The Economist published a special report on Storm Survivors Offshore financial centres have taken a battering recently, but they have shown remarkable resilience.

IMF Working Paper - Taxing Financial Transactions: An Assessment of Administrative Feasibility
John D. Brondolo - IMF (1 August 2011).  The IMF's fiscal affairs department has posted a working paper titled "Taxing Financial Transactions: An Assessment of Administrative Feasibility", which examines the practical issues countries should deal with in the introduction and application of a financial transactions tax (FTT).

Multilateral Convention on Mutual Administrative Assistance in Tax Matters
OECD (1 Jun 2011).  New amendments to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters open the Convention to all countries, allowing them to benefit from cross border tax co-operation and information sharing.

Tax treaty issues related to the trading of emissions permits (discussion draft)
OECD (31 May 2011).  The OECD Committee on Fiscal Affairs (CFA) has released a preliminary analysis of the tax treaty issues related to the trading of emissions permits for public comment. This analysis addresses the application of the provisions of the OECD Model Tax Convention to the cross-border trading of emissions permits.

Consultation Paper: Reform of the Controlled Foreign Company Rules
Australian Commonwealth Treasury (Jan 2010).  Consultation paper prepared by Treasury regarding the reform and modernisation of the controlled foreign company (CFC) rules.