From the formation of the OECD,its work on taxation was driven by the member states,responding to the requirements of industrialised economies.However,during the work on the BEPS action plan leading to the final repor...From the formation of the OECD,its work on taxation was driven by the member states,responding to the requirements of industrialised economies.However,during the work on the BEPS action plan leading to the final reports in 2015,a limited number of developing country representatives participated in the technical working groups,aiming to ensure that the outcomes conformed to the needs of developing countries.Developing countries considered that the OECD procedures were not giving sufficient opportunity for countries to participate in the standard setting process.The countries that were required to implement the stan-dards needed a mechanism for participating in setting up the process of implemen-tation,and this led to the creation of the BEPS Inclusive Framework.Participation of non-OECD countries in decision-making was still limited,and many developing coun-tries were not members of the Inclusive Framework.The African group of nations at the UN considered that inclusive international.tax policy instruments should be developed through a global,transparent forum which can be provided by the UN.The UN Resolution of 22 November 2022 called for discussions on developing an international tax cooperation framework to be agreed through a UN inter-governmental process.The Terms of Reference of 15 Au-gust 2024 clarified that a Framework Convention should establish a system of gover-nance for inclusive international tax cooperation.It should establish an inclusive,fair,and transparent international tax system for sustainable development and strength-.ening of domestic resource mobilisation.展开更多
With the increasing globalisation of production chains,the trade in intermediate goods and associated services is also constantly growing.Trade between related parties within multinational groups is increasing as a pr...With the increasing globalisation of production chains,the trade in intermediate goods and associated services is also constantly growing.Trade between related parties within multinational groups is increasing as a proportion of global trade,and there are growing levels of north/south trade.These factors are leading to changes in the approaches to international taxation and its interaction with global trading rules.The World Trade Organization(WTO)agreements have a potentially significant impact on cross-border tax relationships through concepts such as the non-discrimination principle;the agreement on subsidies and countervailing measures;and the most favoured nation(MFN)principle.Governments will need to work together to ensure that global tax and trade policies are supportive of each other.There willalso be a need for capacity building in Belt and Road Initiative jurisdictions to ensure that they can benefit from tax and trade rules.Countries must be more aware of the risks of tax protectionism,and work to maintain an open global trading system.展开更多
Differences in national accounting standards can make it difficult for users of financial statements,including investors,to correctly assess financial results in each country or compare the business performance from o...Differences in national accounting standards can make it difficult for users of financial statements,including investors,to correctly assess financial results in each country or compare the business performance from one country to another.BRI jurisdictions need to ensure that potential investors have as much information as possible and can make accurate assessments.The best course may be to move to-wards adopting the international accounting standards.The adoption of internation-al standards is considered by the International Accounting Standards Board(IASB)to be a low-cost option for developing countries if they do not have the administrative capacity to develop their own domestic accounting standards.Accounting standards cover the treatment of taxation items,including deferred taxation,in the financial statements.The international accounting standard dealing with income tax is Inter-national Accounting Standards(IAS)12.Using this standard can lead to enhanced tax disclosure,transparency and comparability.In view of the potential impact of the global minimum tax developed under Pillar Two of the OECD proposals,the IASB intends to amend IAS 12 to ensure that tax disclosures in the financial statements re-main comparable.The IASB has proposed a temporary exception to IAS 12 in relation to recognition of deferred tax assets and liabilities relating to Pillar Two taxes.Under the IASB proposals an entity would however be required to disclose information for the current period on Pillar Two legislation enacted in the jurisdictions where it oper-ates.For periods after the global minimum tax comes into effect,an entity would be required to separately disclose the liability to Pillar Two taxes.展开更多
The growing trading links in the modern world have made it more difficult for tax administrations to monitor the activities of multinational enterprises(MNEs)operating on their territory.Advanced technology and commun...The growing trading links in the modern world have made it more difficult for tax administrations to monitor the activities of multinational enterprises(MNEs)operating on their territory.Advanced technology and communications have been used by MNEs to increase the scope of their operations and create global supply chains,while tax administrations try to use limited resources to apply the tax rules.The development of digital technology within government can help tax administrations to implement the latest international tax rules and monitor taxpayer activities more completely,improving domestic resource mobilisation.A benefit of more digitalisation for tax administrations is the ability to manage data and use analytical tools to make the best use of the data acquired.Wider international tax cooperation has provided tax administrations with access to information from country-by-country(CbC)reporting,the common reporting standard(CRS)and the exchange of tax rulings.These give tax administrations access to large volumes of data in relation to cross-border activities to facilitate risk assessment.Digitalisation can also reduce the compliance burden of taxpayers by making it easier to complete their tax obligations,helping them to integrate taxation processes into their routine business systems.Full use of technology combined with adequate governance can boost the efficiency of tax administration.The Belt and Road Initiative Tax Administration Cooperation Mechanism(BRITACOM)can be a platform for cooperation among tax administrations to gain more efficiency.It is important for BRI tax administrations to learn from each other through sharing their knowledge and experience in the introduction of digital technology.展开更多
Trade,investment and tax treaties are concluded for different reasons and with different objectives.The international trade and tax systems are overseen by different global organizations.The overlaps and inconsistenci...Trade,investment and tax treaties are concluded for different reasons and with different objectives.The international trade and tax systems are overseen by different global organizations.The overlaps and inconsistencies between these agreements could be exploited by investors to gain unintended advantages.Therefore,developing countries must ensure that there is greater cooperation and exchange of information in relation to trade,investment and tax policy.The exchange of information between tax administrations is important in the context of the Belt and Road Initiative(BRI),where the tax administration in each jurisdiction needs to know more about the cross-border transactions of multinationals operating in its territory.The most effective way for developing countries to improve the exchange of information is to sign multilateral agreements,in particular the Convention on Mutual Assistance in Tax Matters.The customs and transfer pricing functions within a jurisdiction should collaborate and exchange information to ensure that the pricing of import transactions is consistent across different taxes.Both functions could carry out risk-based compliance audits that would involve comparison of transfer pricing and customs documentation.In the context of coordination between customs and direct tax functions,the comparison of customs and transfer pricing documentation can be established on a routine basis.Closer coordination of transfer pricing and customs would also help taxpayers reduce compliance costs in relation to cross-border transactions.In view of the compliance costs involved in putting together transfer pricing documentation,it would help taxpayers if much of the same documentation could also be used for the purposes of customs valuation.展开更多
Governments around the world have taken urgent measures including both fiscal and monetary policies,to address the severe economic effects of the COVID-19 pandemic.Initially measures were taken to support businesses a...Governments around the world have taken urgent measures including both fiscal and monetary policies,to address the severe economic effects of the COVID-19 pandemic.Initially measures were taken to support businesses and individuals during the pandemic,to support unemployed people and reduce insolvencies resulting from the crisis;however,as the health situation around the world begins to improve,countries affected by the pandemic should take measures to stimulate growth and employment.This article argues that countries should act to promote investment and economic growth,in support of green energy and future technologies.Policy measures could include tax and non-tax incentives.Stimulus measures should be carefully targeted to achieve the intended result and their effects should be monitored through the collection of relevant statistics.The BRITACOM can be a platform to establish standards and exchange experiences.展开更多
As the pandemic begins to ease in some places,the support made available to individuals and businesses should be gradually phased out and replaced by spending to encourage economic growth and employment.While business...As the pandemic begins to ease in some places,the support made available to individuals and businesses should be gradually phased out and replaced by spending to encourage economic growth and employment.While businesses and individuals are recovering from the problems caused by the pandemic,revenue from corporate and individual income taxes may be reduced.Additional tax revenues can however be gained from improved taxation of the digital economy and the opportunities to identify undisclosed income sources arising from agreements for the exchange of tax information.Jurisdictions must modernise tax administration to improve taxpayer compliance and reduce the size of the informal and shadow economies.Modernisation and digitalisation of tax administration can significantly improve tax collection.Using the dialogue process under BRITACOM,the BRI jurisdictions can benefit from the experience of other developing jurisdictions and receive technical support to improve tax administration and collection.Tax incentives could be used to encourage businesses to invest in the digital and green energy sectors.These incentives should be specifically framed and targeted to achieve the maximum effect and monitored to ensure that they continue to achieve the required goals.展开更多
The COVID-19 virus has rapidly escalated from a localized health emergency to a global pandemic at an unprecedented speed,with a global footprint expanding at an exponential rate.This paper focuses on a review of the ...The COVID-19 virus has rapidly escalated from a localized health emergency to a global pandemic at an unprecedented speed,with a global footprint expanding at an exponential rate.This paper focuses on a review of the tax measures taken and seeks to identify the most effective steps.It commences with a brief look at the measures taken in the financial crisis of 2008/09,and then narrows the comparison down to tax policy measures with particular emphasis on China and key BRI jurisdictions.The paper concludes with recommendations for BRI jurisdictions.The most effective tax measures at this stage of the coronavirus crisis are those that can help businesses to improve their cash flow and stay in business.At a later point,it may be necessary to introduce further measures to stimulate the economies.BRITACOM has an important role to play in coordinating the tax policy responses to the crisis in BRI jurisdictions.展开更多
(Continued from the last issue)4.The Role of Double Taxation Treaties 4.1 Advantages of Tax Treaties for Developing Countries Tax treaties are important because they can help to eliminate double taxa-tion,facilitate c...(Continued from the last issue)4.The Role of Double Taxation Treaties 4.1 Advantages of Tax Treaties for Developing Countries Tax treaties are important because they can help to eliminate double taxa-tion,facilitate cooperation and exchange of information between tax administra-tions,and set out a tax dispute resolution mechanism.Double taxation is an ob-stacle to inward investment and by con-cluding tax treaties with the main trading partners developing countries can reduce the risk of double taxation and boost in-vestment.展开更多
文摘From the formation of the OECD,its work on taxation was driven by the member states,responding to the requirements of industrialised economies.However,during the work on the BEPS action plan leading to the final reports in 2015,a limited number of developing country representatives participated in the technical working groups,aiming to ensure that the outcomes conformed to the needs of developing countries.Developing countries considered that the OECD procedures were not giving sufficient opportunity for countries to participate in the standard setting process.The countries that were required to implement the stan-dards needed a mechanism for participating in setting up the process of implemen-tation,and this led to the creation of the BEPS Inclusive Framework.Participation of non-OECD countries in decision-making was still limited,and many developing coun-tries were not members of the Inclusive Framework.The African group of nations at the UN considered that inclusive international.tax policy instruments should be developed through a global,transparent forum which can be provided by the UN.The UN Resolution of 22 November 2022 called for discussions on developing an international tax cooperation framework to be agreed through a UN inter-governmental process.The Terms of Reference of 15 Au-gust 2024 clarified that a Framework Convention should establish a system of gover-nance for inclusive international tax cooperation.It should establish an inclusive,fair,and transparent international tax system for sustainable development and strength-.ening of domestic resource mobilisation.
文摘With the increasing globalisation of production chains,the trade in intermediate goods and associated services is also constantly growing.Trade between related parties within multinational groups is increasing as a proportion of global trade,and there are growing levels of north/south trade.These factors are leading to changes in the approaches to international taxation and its interaction with global trading rules.The World Trade Organization(WTO)agreements have a potentially significant impact on cross-border tax relationships through concepts such as the non-discrimination principle;the agreement on subsidies and countervailing measures;and the most favoured nation(MFN)principle.Governments will need to work together to ensure that global tax and trade policies are supportive of each other.There willalso be a need for capacity building in Belt and Road Initiative jurisdictions to ensure that they can benefit from tax and trade rules.Countries must be more aware of the risks of tax protectionism,and work to maintain an open global trading system.
文摘Differences in national accounting standards can make it difficult for users of financial statements,including investors,to correctly assess financial results in each country or compare the business performance from one country to another.BRI jurisdictions need to ensure that potential investors have as much information as possible and can make accurate assessments.The best course may be to move to-wards adopting the international accounting standards.The adoption of internation-al standards is considered by the International Accounting Standards Board(IASB)to be a low-cost option for developing countries if they do not have the administrative capacity to develop their own domestic accounting standards.Accounting standards cover the treatment of taxation items,including deferred taxation,in the financial statements.The international accounting standard dealing with income tax is Inter-national Accounting Standards(IAS)12.Using this standard can lead to enhanced tax disclosure,transparency and comparability.In view of the potential impact of the global minimum tax developed under Pillar Two of the OECD proposals,the IASB intends to amend IAS 12 to ensure that tax disclosures in the financial statements re-main comparable.The IASB has proposed a temporary exception to IAS 12 in relation to recognition of deferred tax assets and liabilities relating to Pillar Two taxes.Under the IASB proposals an entity would however be required to disclose information for the current period on Pillar Two legislation enacted in the jurisdictions where it oper-ates.For periods after the global minimum tax comes into effect,an entity would be required to separately disclose the liability to Pillar Two taxes.
文摘The growing trading links in the modern world have made it more difficult for tax administrations to monitor the activities of multinational enterprises(MNEs)operating on their territory.Advanced technology and communications have been used by MNEs to increase the scope of their operations and create global supply chains,while tax administrations try to use limited resources to apply the tax rules.The development of digital technology within government can help tax administrations to implement the latest international tax rules and monitor taxpayer activities more completely,improving domestic resource mobilisation.A benefit of more digitalisation for tax administrations is the ability to manage data and use analytical tools to make the best use of the data acquired.Wider international tax cooperation has provided tax administrations with access to information from country-by-country(CbC)reporting,the common reporting standard(CRS)and the exchange of tax rulings.These give tax administrations access to large volumes of data in relation to cross-border activities to facilitate risk assessment.Digitalisation can also reduce the compliance burden of taxpayers by making it easier to complete their tax obligations,helping them to integrate taxation processes into their routine business systems.Full use of technology combined with adequate governance can boost the efficiency of tax administration.The Belt and Road Initiative Tax Administration Cooperation Mechanism(BRITACOM)can be a platform for cooperation among tax administrations to gain more efficiency.It is important for BRI tax administrations to learn from each other through sharing their knowledge and experience in the introduction of digital technology.
文摘Trade,investment and tax treaties are concluded for different reasons and with different objectives.The international trade and tax systems are overseen by different global organizations.The overlaps and inconsistencies between these agreements could be exploited by investors to gain unintended advantages.Therefore,developing countries must ensure that there is greater cooperation and exchange of information in relation to trade,investment and tax policy.The exchange of information between tax administrations is important in the context of the Belt and Road Initiative(BRI),where the tax administration in each jurisdiction needs to know more about the cross-border transactions of multinationals operating in its territory.The most effective way for developing countries to improve the exchange of information is to sign multilateral agreements,in particular the Convention on Mutual Assistance in Tax Matters.The customs and transfer pricing functions within a jurisdiction should collaborate and exchange information to ensure that the pricing of import transactions is consistent across different taxes.Both functions could carry out risk-based compliance audits that would involve comparison of transfer pricing and customs documentation.In the context of coordination between customs and direct tax functions,the comparison of customs and transfer pricing documentation can be established on a routine basis.Closer coordination of transfer pricing and customs would also help taxpayers reduce compliance costs in relation to cross-border transactions.In view of the compliance costs involved in putting together transfer pricing documentation,it would help taxpayers if much of the same documentation could also be used for the purposes of customs valuation.
文摘Governments around the world have taken urgent measures including both fiscal and monetary policies,to address the severe economic effects of the COVID-19 pandemic.Initially measures were taken to support businesses and individuals during the pandemic,to support unemployed people and reduce insolvencies resulting from the crisis;however,as the health situation around the world begins to improve,countries affected by the pandemic should take measures to stimulate growth and employment.This article argues that countries should act to promote investment and economic growth,in support of green energy and future technologies.Policy measures could include tax and non-tax incentives.Stimulus measures should be carefully targeted to achieve the intended result and their effects should be monitored through the collection of relevant statistics.The BRITACOM can be a platform to establish standards and exchange experiences.
文摘As the pandemic begins to ease in some places,the support made available to individuals and businesses should be gradually phased out and replaced by spending to encourage economic growth and employment.While businesses and individuals are recovering from the problems caused by the pandemic,revenue from corporate and individual income taxes may be reduced.Additional tax revenues can however be gained from improved taxation of the digital economy and the opportunities to identify undisclosed income sources arising from agreements for the exchange of tax information.Jurisdictions must modernise tax administration to improve taxpayer compliance and reduce the size of the informal and shadow economies.Modernisation and digitalisation of tax administration can significantly improve tax collection.Using the dialogue process under BRITACOM,the BRI jurisdictions can benefit from the experience of other developing jurisdictions and receive technical support to improve tax administration and collection.Tax incentives could be used to encourage businesses to invest in the digital and green energy sectors.These incentives should be specifically framed and targeted to achieve the maximum effect and monitored to ensure that they continue to achieve the required goals.
文摘The COVID-19 virus has rapidly escalated from a localized health emergency to a global pandemic at an unprecedented speed,with a global footprint expanding at an exponential rate.This paper focuses on a review of the tax measures taken and seeks to identify the most effective steps.It commences with a brief look at the measures taken in the financial crisis of 2008/09,and then narrows the comparison down to tax policy measures with particular emphasis on China and key BRI jurisdictions.The paper concludes with recommendations for BRI jurisdictions.The most effective tax measures at this stage of the coronavirus crisis are those that can help businesses to improve their cash flow and stay in business.At a later point,it may be necessary to introduce further measures to stimulate the economies.BRITACOM has an important role to play in coordinating the tax policy responses to the crisis in BRI jurisdictions.
文摘(Continued from the last issue)4.The Role of Double Taxation Treaties 4.1 Advantages of Tax Treaties for Developing Countries Tax treaties are important because they can help to eliminate double taxa-tion,facilitate cooperation and exchange of information between tax administra-tions,and set out a tax dispute resolution mechanism.Double taxation is an ob-stacle to inward investment and by con-cluding tax treaties with the main trading partners developing countries can reduce the risk of double taxation and boost in-vestment.
