بعد أن أقر قادة مجموعة العشرين رسميا الحد الأدنى لضريبة الشركات العالمية الذي أقرته منظمة التعاون الاقتصادي والتنمية بنسبة 15 بالمئة، يثار تساؤل مهم وهو كيف سيتم تطبيق الضرائب على الاقتصاد الرقمي ومدى استعداد النظام الضريبي في دول المنطقة العربية، ومنها مصر، لهذه التغيرات؟
عرض العناصر حسب علامة : الاقتصاد العالمي
تعديلات قانون الضريبة على الدخل لرفع حد الإعفاء الضريبي الشخصي من ٩ إلى ١٥ ألف جنيه ليصل حد الإعفاء الضريبي الإجمالي إلى ٣٠ ألف جنيه سنويًا
تعديلات الضريبة على الدخل تستهدف التخفيف عن المواطنين وتحفيز الاستثمار فى ظل التحديات الاقتصادية العالمية
مقالات .. معركة معايير الاستدامة 1 من 2
بعد إقرار ضريبة الشركات العالمية.. كيف تستفيد الدول العربية؟
الثقة الاقتصادية العالمية تنتعش بين المحاسبين
أظهر المحاسبون ثقة أكبر في الاقتصاد خلال الربع الأول من العام الحالي مقارنة بالعام الماضي، خاصة في أمريكا الشمالية، بحسب مسح جديد.
معلومات إضافية
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المحتوى بالإنجليزية
Accountants expressed much higher confidence in the economy during the first quarter of this year compared to last year, especially in North America, according to a new survey.
The survey, by the Association of Chartered Certified Accountants and the Institute of Management Accountants, polled more than 1,000 senior accountants and finance professionals around the world, and found the biggest quarterly jump in confidence in a decade, thanks to increasing supplies of vaccines and continuing fiscal stimulus from many governments. The ACCA and IMA’s Global Economic Conditions Survey saw a nearly 30-point jump in the confidence index globally and more than 40 points for North America in the first quarter of 2021, compared to the fourth quarter of 2020. However, the two “fear” indices in the survey, which measure concern that customers and suppliers could go out of business, offered contrasting messages. Fear that customers would go out of business declined significantly while fear that suppliers would do so rose slightly higher. But both factors remain at relatively high levels, underscoring the high level of uncertainty that remains in the world economy.
The rollout of COVID-19 vaccines in recent months have helped improve economic confidence in many parts of the world. However, the growing number of COVID-19 variants that seem to spread more easily has also led to uncertainty and some European countries have been forced to retreat on their reopening plans. In many parts of the world, access to vaccines remains severely limited. Accountants in Western Europe, Africa and the Middle East did not register as much of an increase in economic confidence as those in North America and Asia.
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“This crisis is different as its root cause is health and not economic,” said IMA vice president of research and policy Raef Lawson in a statement Monday. “For now, global COVID-19 infections are high relative to the vaccination rate, so risks remain significant. But the huge government support provided to both households and companies over the last year leaves both well-placed to resume spending once the health crisis is over. There are likely to be permanent changes in the pattern of spending and other long-term economic consequences of the COVID crisis.”
Economic activity indicators for orders, capital spending and employment all increased to some extent in the first quarter of this year, according to the survey, echoing the level of confidence in the fourth quarter of 2019 before the spread of the COVID-19 pandemic.
“Having suffered the biggest recession for several decades in 2020, the global economy is on course for a relatively quick rebound,” said ACCA chief economist Michael Taylor in a statement. “The good news is that vaccination plans with continued policy support are on course to lift the global economy out of the COVID abyss this year.”
The report acknowledged that vaccination rates vary significantly across different countries, and vaccination can replace lockdown measures as a way to control COVID-19, allowing economic conditions to return to normal. But government policy is also crucial. A major fiscal stimulus in the U.S. is likely to have a positive spill-over impact on other economies around the world this year. Particularly in advanced economies, a large pile of savings accumulated during the periods last year when spending was severely limited, and those funds can provide a source of extra demand once economic conditions improve. Based on those criteria, the U.S. and the U.K. seem to have better growth prospects than the Eurozone, while China is likely to continue to experience strong growth. Emerging markets may also benefit from increased global demand, but vaccination rates will probably remain low in many countries through the rest of this year.
الاتفاقيات الدولية تحفز الانتقال إلى الحد الأدنى العالمي من الضرائب
ما بدأ كإدراك للمشهد الضريبي المتغير الذي أحدثته الشركات الكبيرة التي تحقق إيرادات كبيرة في الأماكن التي لم يكن لها وجود فعلي -وبالتالي لا توجد فيها مسؤولية ضريبية -يتجه نحو حل على المسرح الدولي.
معلومات إضافية
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المحتوى بالإنجليزية
Int’l agreements spur move to global minimum tax
By Roger Russell
August 09, 2021, 12:10 p.m. EDT
7 Min Read
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What began as an awareness of the changing landscape in tax brought about by large companies earning significant revenue in places where they had no physical presence — and therefore no tax responsibility — is heading for a resolution on the international stage.
After years of discussions, position papers, proposals, negotiations, and re-proposals, both the G7 and G20 met in June 2021 and gave approval to the OECD’s proposals as outlined in its Pillars 1 and 2.
“Years ago, the OECD recognized that there were issues related to digitalization of the global economy, “ said Laurie Dicker, transfer pricing technical tax leader at Top Eight Firm BDO USA. “It was based on the fact that the global tax system is built on the premise of countries having taxing rights where companies have physical presence, and as the economy digitalizes there is the notion that companies are now earning income in places where they do not necessarily have a traditional taxing presence. For example, an entity that sells a digital service, whether entertainment or educational or anything else you can access digitally. Someone can buy that in a country in which they don’t have physical presence. The servers can be anywhere, so the companies generate income from someone buying the service but the county does not get taxing rights. That’s the backdrop.”
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A long time coming
The OECD has been discussing this for years, beginning in 2013 with its identifying “Base Erosion and Profit Shifting,” or BEPS, as an issue that needed to be addressed.
“They finally started introducing proposals on how to address this,” said Dicker. “The proposals have been refined over time.”
The BEPS project was initiated in 2013; BEPS final reports were issued in October 2015; BEPS 2.0 interim reports came out in 2019; blueprints for a new global tax framework came out in October 2020; and the G7 meeting in June 2021 agreed to the OECD framework.
“There’s been an enormous amount of activity this year,” said Dicker. “What caught everyone’s attention was the G7 meeting in early June this year, when they met in person and issued a statement in support of what the OECD proposed. That was a huge opening.”
Weeks later, the G20 met and also agreed to the proposals.
“What has been proposed is a two-pillar approach,” said Dicker.
Pillar 1 involves reallocation of profit and revised nexus rules, and is concerned with what portion of profits should be taxed in the jurisdictions where clients or users are located. Pillar Two contains an anti-base erosion mechanism in order to ensure that multinational enterprises pay a minimum level of tax.
“Pillar 2 will expand the taxable revenue collected globally from corporations by implementing a global minimum tax,” said Dicker. “They’re talking about a minimum rate of 15%. The exact rate has not been decided yet. If a country where the effective tax rate is below 15%, then the home country where the company is located can tax on the difference. For example, if a U.S. multinational is taxed in Ireland at 12%, then the U.S. can impose a tax to bring that company up to the global rate. For any country that has a rate below15 %, the choice is to raise their rate or forgo the tax revenue and hand it over to the parent to the parent country. Companies will be paying the same rate; it’s just a question of where they will pay it.”
“Prominent low-tax countries are against this and countries continue to negotiate,” said Dicker. Among the countries that have not yet agreed are Ireland, Hungary, Estonia, Kenya, Nigeria, Sri Lanka and Barbados. “They each have their own reasons for not agreeing,” said Dicker.
Pillar 1 is far more complicated, according to Dicker. “It redefines taxing rights and proposes a new allocation methodology. If you develop a product in one country, manufacture it in another country, market it in another country and have customer service and warehouses in other countries, it determines what part of revenue is allocated to each of those activities.”
Randy Buchanan, a partner at law firm Eversheds Sutherland, agreed.
“Pillar 1 is a much more difficult exercise — it’s a bigger departure from how international tax has been handled in the past, when you always needed some type of physical connection to a country to be taxed in that country. Pillar 1 is going in the direction of saying that if you sell goods or services into a country then you’re subject to tax in that country even if you have no physical presence there. It would shift the right to tax profits away from source countries and into destination countries, and that’s a lot easier said than done. To make it work you really need an agreed formulary apportionment mechanism to determine who ends up taxing how much of the profit. The details of how to accomplish that are pretty murky, and even assuming you could get everyone on the same page, actually implementing it is not going to be easy.”
It will be particularly difficult to implement in the U.S., Buchanan observed. “It will take some type of multilateral treaty among the various countries,” he said. “To get two-thirds of the Senate to ratify that kind of multilateral treaty seems like a steep uphill climb, given the lack of Republican support. You could try to implement some aspects of this through legislation, but it’s not clear to me how you would implement it without a treaty.”
”One way to think about it is that it’s taking the global tax system and trying to make outlook more like the state and local system here in the U.S., where states apply similar apportionment factors to determine which state has the right to tax income,” he explained. “It’s easier to do in a country where you have a unified central government, but it’s harder in the international stage where there’s no central government. The OECD in essence is trying to perform that kind of centralized function to get countries together, but it doesn’t have any real authority. Every country is doing it on a voluntary basis, with no external constraints around implementing it such as the U.S. Constitution.”
Pillar 1 generally would apply disproportionally to U.S.-based multinationals, Buchanan observed. “It goes beyond digital and high-tech entities,” he noted. “Most of the companies that would be impacted by Pillar 1 are large U.S. multinationals, which is another reason I don’t see bipartisan support developing in the U.S.”
Treasury Secretary Janet Yellen during the G20 finance ministers and central bankers meeting in Venice.Andreas Solaro/AFP/Getty Images
Local opposition
Kevin Brady, R-Texas, the top Republican on the House Ways and Means Committee, stated on July 1, 2021, “In negotiations with the OECD, the Biden administration has a already given up significant U.S. ground by opening the door to not grandfathering GILTI and agreeing to a global minimum tax structure that favors foreign-headquartered companies and workers over American ones. This is a dangerous economic surrender that sends U.S. jobs overseas, undermines our economy, and strips away our U.S. tax base.”
“Politics makes strange bedfellows,” Buchanan observed, noting that the large companies in the crosshairs of Pillars 1 and 2 are primarily supporters of Democrats. “Not all Democrats think it’s a great idea, but the administration is supporting it so at least they have a higher comfort level,” he said.
Loren Ponds, a member at law firm Miller & Chevalier, agreed. “Certainly this administration has been active in the negotiation process,” she said. “The Treasury Department was able to work with the Inclusive Framework members [the group of countries working to solve BEPS issues] so now there is a proposed 15% rate, which is lower than the proposed rate for GILTI.”
The fact that individual countries were going ahead and enacting their own Digital Services Tax spurred the push to move the OECD agreement ahead, Ponds indicated: “They knew they were working against the clock.”
Things will start moving quickly now, predicted BDO’s Dicker. “Nothing was going to happen unless the U.S. came on board. Then Treasury Secretary Yellen came out in support, but with a simplified method of what would be in scope. There will be a meeting of G20 principals in October, and the OECD will release its final blueprint of Pillars 1 and 2. It’s possible that changes will need to be implemented at three levels — regulatory, legislative, and by treaty. Each country will have a different process, but the OECD is hoping that it can be implemented globally and take effect in 2023, but experts view this as overly optimistic. To the extent it happens, it will be the largest change to the global tax landscape in 100 years.”
معيار جديد لمراجعات المنشآت الأقل تعقيدًا
تقدم المنشآت الأصغر والأقل تعقيدًا (LCEs) مساهمات حاسمة في الاقتصاد العالمي وتمثل الغالبية العظمى من المنشآت على مستوى العالم. في الوقت نفسه، هناك حاجة إلى معالجة الهياكل والمعاملات المتزايدة التعقيد في المعايير الدولية للتدقيق (ISAs). يمكن أن يشكل هذا التعقيد في معايير التدقيق الدولية تحديات أمام عمليات تدقيق المنشآت الأقل تعقيدًا.
معلومات إضافية
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المحتوى بالإنجليزية
Smaller, less complex entities (LCEs) make crucial contributions to the world economy and account for the great majority of entities globally. At the same time, increasingly complex structures and transactions need to be addressed in the International Standards on Auditing (ISAs). This complexity in the ISAs can pose challenges for audits of less complex entities.
Based on the feedback from a discussion paper and outreach, the IAASB has developed a draft standard that is proportionate to the typical nature and circumstance of an audit of a less complex entity and is responsive to those stakeholders challenges and is a global solution.
The public consultation on this draft new standard is open until January 31, 2022. When final, the standard will meet the growing global need while reducing the emerging risk of jurisdictional divergence. This landmark new draft standard represents a new era for the IAASB and stakeholder feedback is now needed.
The Exposure Draft will also be available in French and Spanish in September 2021.
The Proposed Supplement Guide: Auditor Reporting will be available in August 2021.
The Mapping Documents, ISAs to Proposed ISA for LCE, will be available in August 2021.
The IAASB will also publish an outreach plan in August 2021.
The New Proposed Standard
The new stand-alone standard for audits of less complex entities:
Is designed specifically for audits of a less complex entities
Is based on the underlying concepts from International Standards on Auditing
Was developed to be understandable, clear and concise
Reduces the risk of jurisdictional divergence by driving consistency and comparability globally
Will achieve a quality audit engagement
توصيات مجموعة الأعمال السعودية B20 إلى مجموعة العشرين G20
المضي قدمًا معًا: دعوة مجموعة العشرين إلى العمل في 2020
دراسة ماجستير: التعدين المالي للبيانات لدعم الممارسات الرقابية بهدف رفع كفاءة النظم المحاسبية الرقمية
تعرف على توصيات رئيس مجلس معايير المحاسبة الدولية للقطاع العام لمواجهة كورونا
معلومات إضافية
- المحتوى بالإنجليزية We at IPSASB are committed to doing our part in supporting a strong global response to the challenges posed by COVID-19.
في المحاسبين العرب، نتجاوز الأرقام لتقديم آخر الأخبار والتحليلات والمواد العلمية وفرص العمل للمحاسبين في الوطن العربي، وتعزيز مجتمع مستنير ومشارك في قطاع المحاسبة والمراجعة والضرائب.