Business ‘to set the pace' in tax rules

By Staff Writer

Business Day, 10 January 2008
 
by Linda Ensor

An internationally renowned tax expert, Owens is in SA to attend the Forum
on Tax Administration, an OECD conference held every 18 months, which is
taking place in Africa for the first time. About 100 delegates, from about
40 countries, will be at the two-day forum - the largest gathering of tax
administrators - which starts in Cape Town today. A number of African tax
commissioners will be attending for the first time, as well as the leaders
of six large enterprises, who will provide input on business trends.

Earlier this week, Owens said in an interview that the "name of the game"
in multinational business restructuring was the centralisation of services.
This had been made possible by greater integration of national economies
and more sophisticated forms of communication.

"For example, in the past, a multinational might have had a financial-
services subsidiary in five or six countries. Now they tend to be
centralised... Also, in the past, multinationals would have had valuable
intangibles: patents and know-how, located in a number of countries,
but today the model is very much to have one location," Owens said.

"This trend is accompanied by the splitting of risks. So, instead of
having your distributors in different countries - bearing the risk of
their activities - the risk is stripped out so effectively that they
become agents, and the risk is centrally located. This clearly has
implications for tax authorities, because ... your tax base tends to
where the risks are.

"Stripping out the risk means stripping out part of your tax base and,
even though tax is generally not the main reason for restructuring,
once a decision has been taken to restructure, the tendency would be
to find a low-tax jurisdiction as the place to locate your intangibles.
"This poses challenges for governments that are losing part of their tax
bases."

Owens said tax administrators needed to understand the global pressures
faced by large multinationals and the new business models to deal with them.
Only then could they investigate the tax implications of these models.With
about 60% of cross-border activities taking place between subsidiaries of
multinationals, tax administrators a re tasked with placing a value on these
transactions.

One of the principal challenges that multinational s pose for tax authorities
is their ability to use transfer pricing to move income from high- to low-tax
jurisdictions, and to move expenses in the opposite direction so they can
minimise their tax obligations.

Owens said tax administrations had to strengthen their co-operation and share
information if they were to tax multinationals effectively . A form of co-
operation was auditing the subsidiaries of multinationals in different
countries simultaneously .

Recent Articles

Featured Rating agencies may come knocking

It is only the middle of February, but the rand has already made two big moves. The first was the rand moving from R14.60 to R 13.20 at the beginning of the year, as emerging markets (EM) became fashionable again. The second was where the rand gave away nearly 90 cents in 2 weeks as the EM rally ran out of steam, and local events started to hit the headlines.

Read more

The cost of sending money home to neighbouring countries

Transferring money home within the Southern African Development Community (SADC) provides vital financial support for many households in neighbouring countries.

Read more

Student bank accounts: Which come out on top?

Being a student signals budgeting and not having a lot of money at your disposal. This means streamlining expenses such as your grocery costs and entertainment budget. But what if your bank account is in fact costing you more than you can afford?

Read more

Can you afford an ambulance in South Africa?

When a loved one is straddling the line between life and death, you won’t hesitate to call an ambulance. This week, Justmoney found out how much an ambulance ride costs in South Africa, whether you can refuse to get into an ambulance, and who pays the bill if you’re unconscious. 

Read more

Sign Up

To our weekly newsletter for advice you can bank on

Deals

President Hotel Easter Special

Price: From R1,500
When: 15 March to 30 April
Where: Cape Town

Kulula-Preskil Island Resort Special

Price: R16,999
When: 11 May -14 September
Where: Mauritius

A Touch Of Madness Tuck In Tuesday Special

Price: R70
When: Tuesdays
Where: Cape Town