Category: K-P

HMRC hails success of tax avoidance clampdown on UK banks

HMRC said the amount of money in tax avoidance schemes has fallen from £3.2bn in 2013 to £1bn All but two UK-registered banks have signed up to a Government scheme encouraging lenders to avoid using tax avoidance schemes. Some 303 lenders, including banks and building societies, have now signed up… – Continue reading

2015: Transfer Pricing Round-Up

The year 2015 was arguably a momentous one for transfer pricing (TP). A combination of local and international developments will mark it as a period which defined the future direction of this subject. Key Developments The Organization for Economic Cooperation & Development (OECD) released final reports as part of its… – Continue reading

Multinational conglomerates escape transfer-pricing charge

VietNamNet Bridge – The agreements on double taxation avoidance that Vietnam has signed with other countries is one of the reasons that have made it impossible for state agencies to clarify the suspected cases of multinational conglomerates conducting transfer pricing. A lot of multinational conglomerates such as Coca-Cola, Metro Cash… – Continue reading

Two Swiss Banks Reach Deal to Avoid Possible U.S. Tax-Evasion Charges

Two Swiss banks will pay a total of more than $107 million to the U.S. Department of Justice to avoid possible prosecution for helping Americans evade taxes, the department said on Thursday. Bank Lombard Odier & Co. Ltd, a Geneva-based unit of Lombard Odier Group, will pay $99.8 million in… – Continue reading

Indian companies with foreign units likely to be impacted by POEM guidelines

MUMBAI: Many manufacturing and trading subsidiaries of Indian companies that are currently operating independently outside India may have to pay taxes in India as they could fail the new test set under the Place of Effective Management (POEM) guidelines. Not just that, some of the companies could see complications with… – Continue reading

Gaming authority ‘convinced’ industry will withstand new EU tax laws

MGA executive chairperson Joseph Cuschieri warns organised crime within gaming industry ‘has never been this sophisticated’ Malta Gaming Authority’s executive chairman insisted that the gaming industry will continue to flourish on the island, even if proposed EU legislation to clamp down on tax avoidance goes through. “The threat [of a… – Continue reading

Bid to stamp out corporate tax avoidance unites Westminster parties

Current system viewed as unfair and too easy to circumvent Abolition of corporation tax is to be considered by a new cross-party group of MPs and peers who will subject ministers and business leaders to public interrogations in a bid to secure fairer and more responsible tax policies. The all-party… – Continue reading

UK Tax Haven: Five Big Investment Banks Paid No Corporation Tax in 2014

The British government is facing a credibility crisis over its pledge to ensure multinational corporations pay their fair share of tax, after it was revealed that five of the world’s largest investment banks paid no corporation tax in Britain last year, despite making billions in profits. Analysis of the banks’… – Continue reading

Benchmarks trim losses; trade continues in red

Indian equity markets trimmed their losses and continue to trade weak in late morning session on account of selling in frontline blue chip counters. Sentiments remained down-beat with the repot that the Finance Ministry has cut its ambitious disinvestment revenue target by 57% to Rs 30,000 crore for the current… – Continue reading

CF Industries (CF), OCI N.V. Amend Merger Agreement

CF Industries (CF – Analyst Report) and Netherlands-based fertilizers and industrial chemicals producer – OCI N.V. – said that they have amended their merger agreement originally announced in Aug 2015. Under the modified agreement, the jurisdiction of incorporation and tax residency of the new combined company has been changed to… – Continue reading

Exclusive: Seven big investment banks in UK paid just $30 million tax in 2014

LONDON (Reuters) – Seven of the biggest investment banks operating in London paid little or no tax in Britain last year, despite reporting billions of dollars in profits, a Reuters analysis of corporate filings shows. In recent months, the seven investment and corporate banks operating in London reported figures showing… – Continue reading

Antoine Deltour — The LuxLeaks Whistleblower

Luxembourg’s long-hidden role as a secret tax haven in the very heart of the European Union has been shattered by one man who happened to be in the right place at the right time to do what he thought was the right thing. Antoine Deltour brought to light how the… – Continue reading

Grant Thornton manpower may touch 10,000 by 2020: Vishesh Chandiok

MUMBAI: When Grant Thornton recently appointed India leader Vishesh Chandiok on its global governance board, it reflected the country’s growing importance as a market for the London-headquartered professional services firm. At 41, Chandiok may be the youngest member of the board ever but points out that he doesn’t lack for… – Continue reading

BEHIND THE HEADLINES: Tax haven hypocrisy

A BALANCING ACT in London, folly and redemption in America’s District of Columbia and sheer hypocrisy in Brussels. And in every case, Barbados and many of its Caribbean neighbours were placed in the negative international spotlight at a time when some of the world’s major financial centres are casting about… – Continue reading

From Choppergate to Lara Bingle, spending is the taxing issue

It was Kerry Packer who famously told the nation’s politicians “if anybody in this country doesn’t minimise their tax they want their head read” because “as a government I can tell you you’re not spending it that well that we should be paying extra”. The words have gone down in… – Continue reading

Netflix is latest multi-million-pound global company that does not pay UK corporation tax despite generating £200m of revenue in Britain

Netflix the online movie rental service did not pay any UK corporation tax last year, despite generating an income of £200million in Britain. The world’s biggest internet movie streaming service has five million subscribers in the UK alone and has proved a hit by offering U.S. shows like House of… – Continue reading

Australia: Country-by-country reporting guidelines

The Australian Taxation Office (ATO) on 17 December 2015 released guidelines that address country-by-country reporting. The ATO release—Law Companion Guideline (LCG) 2015/3—discusses Tax Laws Amendment (Combating Multinational Tax Avoidance) Act 2015 that was enacted earlier this month and discusses, in particular, Schedule 4. Background Schedule 4 created Subdivision 815-E of… – Continue reading

Foreign-invested footwear manufacturers show their power

Footwear is one of the industries with high export turnover. However, the profitable industry is being controlled by companies from South Korea and Taiwan. According to the Vietnam Leather & Footwear Association (Lefaso), with 800 enterprises and 1 million workers, FIEs account for one-fourth of total number of footwear makers,… – Continue reading

India: Marketing intangibles by licensed manufacturer, no transfer pricing adjustment

The Delhi High Court held that the taxpayer’s advertising, marketing, and sales promotion expenses were not an “international transaction” under provisions of India’s tax law, and thus, could not be the basis of a transfer pricing adjustment. The court further held that a “bright line test” as applied by the… – Continue reading

EU: Draft “anti-BEPS” directive, addressing corporate tax planning and evasion

The Council of the European Union released details of a possible draft EU directive, addressing certain “anti-base erosion and profit shifting” (anti-BEPS) initiatives. The issues addressed concern certain international aspects of the proposal for an EU “common consolidated corporate tax base” (CCCTB), and reflect issues that are directly related to… – Continue reading

Australia lays bare corporate tax details

The Australian Government’s efforts to improve tax collections are more urgent amid falling revenue from weak commodity prices, the Wall Street Journal reports Malcolm Turnbull’s government took the rare step of making public the tax affairs of scores of multinationals, highlighting that many big names—including Apple Inc. and Volkswagen AG… – Continue reading

UPDATE 1-Australia unmasks 600 firms which paid no tax on big profits in 2014

SYDNEY, Dec 17 (Reuters) – Australia on Thursday identified 600 companies which it said paid no tax last financial year, including Halliburton Co and Hilton Worldwide Holdings Inc, as part of a campaign to challenge “overly aggressive” tax arrangements. The Australian Taxation Office published the income and tax rates of… – Continue reading

Swiss bank hid assets for Jews, then tax evaders

Dreyfus Sons & Co. has operated for two centuries as a private Swiss bank, catering to Jewish clients who wanted to hide assets from the Nazis during the 1930s and World War II. More recently, it helped U.S. clients hide assets from the Internal Revenue Service by concealing their true… – Continue reading

‘Pfizer tie-up ‘opportunity’ for Ireland says IDA boss

The $160bn (€146.5bn) merger of US pharmaceutical giant Pfizer with Dublin-based Allergan is an “opportunity” for Ireland, according to IDA chief executive Martin Shanahan. Last month Pfizer, the world’s largest pharmaceutical company, announced plans to merge with Botox manufacturer Allergan in a deal that will create the world’s biggest drug… – Continue reading

Mexico: Reminder of expanded transfer pricing disclosures for 2016

Provisions under new article 76A of Mexico’s tax law reflect certain items of the OECD’s base erosion and profit shifting (BEPS) project—in particular expanded transfer pricing disclosure requirements that will apply for the 2016 tax year. Background The Mexican government’s 2016 federal budget, presented 8 September 2015, included proposals for… – Continue reading

Foreign Banks Pay To Avoid Tax Evasion Charges As More Americans Disclose Offshore Accounts

Lately, the IRS is warning offshore account holders to disclose before it’s too late. Under FATCA, banks everywhere want to know if you are compliant with the IRS. And the cost of compliance for many people is growing. The IRS updated its list of foreign banks where accounts trigger a… – Continue reading

Nokian Tyres received EUR 87 million additional payable tax in Finland regarding years 2007-2010

the company will make a complaint against the decision Nokian Tyres plc (HEX:NRE1V) has received a renewed reassessment decision from the Tax Administration, according to which the Company is obliged to pay EUR 87 million additional taxes with punitive tax increases and interests concerning tax years 2007-2010. Payment must be… – Continue reading

Icahn Says Stop Corporate Inversions By Giving Tax Break

Billionaire investor Carl Icahn has a strong opinion on almost every subject, especially politics. He’s also quite happy to share that opinion with anyone who will listen to or read what he has to say. Icahn’s comments this week on how to stop future tax-motivated corporate inversions such as the… – Continue reading

Piper Jaffray Sees Renewed Monsanto (MON) Bid for Syngenta (SYT) Near Start of 2016

DuPont and Dow are now officially combining and Piper Jaffray analyst, Brett Wong, thinks further consolidation is coming with Monsanto (NYSE: MON) likely to renew the pursuit of Syngenta (NYSE: SYT) towards the beginning of the year. Piper thinks a renewed bid for Syngenta would be viewed negatively by investors… – Continue reading

ATO to unveil large business hit list, clamps down on Singapore hubs

Hundreds of millions of dollars of revenue could be up for grabs as the Tax Office announces reviews of multinationals using offshore hubs in Singapore to minimise their tax. The ATO has issued a warning to multinationals to come forward immediately to discuss their overseas hub arrangements, if they have… – Continue reading

Company which owns Queen’s jeweller Mappin & Webb ‘has paid no corporation tax for five years despite £66million profits’

The company that owns the Queen‘s jeweller Mappin & Webb has paid no corporation tax for five years – despite profits of £66million. The allegations made against Mappin & Webb owners Aurum Holdings came as the conduct of firms holding royal warrants was scrutinised amid revelations about their tax arrangements…. – Continue reading

How Microsoft moves profits offshore to cut its tax bill

Cash doesn’t flow directly from buyers’ pockets to Microsoft’s headquarters in Redmond, Wash. Instead, the company operates through three regional sales units, centered in Ireland, Singapore and Puerto Rico. These groups control the rights to profit from Microsoft products around the world. By conducting sales from places with small populations… – Continue reading

Royal warrant companies accused of using tax havens and moving their manufacturing out of Britain

Companies like Mappin & Webb have not paid any corporation tax for the past five years, according to the Sunday Times Several companies which hold the much-coveted royal warrant have come under scrutiny after being accused of benefiting from tax havens and moving their manufacturing out of Britain. The warrants… – Continue reading

Germany: Tax treaty with Australia, other countries; stock-for-stock transactions

Germany and Australia signed a new income tax treaty that follows, in some instances, the OECD Model Tax Convention, but not in other instances. For example, the treaty includes definitions for installation permanent establishments (PEs) and agency PEs, with the latter defined with a view to the OECD’s base erosion… – Continue reading

Sweden: “Hybrid rule” implications for dividend income, withholding tax

Changes to the tax law in Sweden reflect additions of anti-avoidance provisions to the EU Parent/Subsidiary Directive and are intended to bring Swedish tax law into compliance with the directive. The new anti-avoidance provisions will be effective 1 January 2016—which is also the timeframe for EU implementation of the directive’s… – Continue reading

Orica profits hit after losing battle with Australian Tax Office

Explosives maker Orica will take a $36 million hit to its bottom line after the Federal Court found it had avoided tax by using “round robin” financing arrangement it put in place a decade ago to boost its profit and ward off takeover bids. BusinessDay revealed Orica’s battle with the… – Continue reading

EU adopts new transparency rules

The EU Council has adopted a new transparency directive aimed at preventing corporate tax avoidance The directive, which was proposed by the European Commission (EC), is aimed at improving transparency on tax rulings given by member states to companies about how their taxes are calculated. Under the new directive, member… – Continue reading

Fighting tax evasion: EU and the Republic of San Marino sign new tax transparency agreement

The new agreement marks the end of bank secrecy between San Marino and the EU. As of 2017, San Marino and EU Member States will automatically exchange information on the financial accounts of one another’s residents. Pierre Moscovici, Commissioner for Economic and Financial Affairs, Taxation and Customs, said: “This agreement… – Continue reading

Finance meeting to be dominated by corporate tax

Ministers due to adopt conclusions on future of EU’s code of conduct on business taxation Corporate tax will top today’s meeting of EU finance ministers in Brussels, as ministers discuss the latest state of play regarding the common consolidated corporate tax base (CCCTB) and cross-border tax rulings. In particular, finance… – Continue reading

IRS continues focus on corporate inversions

The Internal Revenue Service (IRS) continues its focus on perceived abuses in corporate inversion transactions. On November 19, the IRS released Notice 2015-79, which places new limitations on the ability of a U.S. multinational corporation to reduce its U.S. tax burden by inverting its corporate structure. U.S.-based multinationals are subject… – Continue reading

Is SA heading for a tax revolt?

Taxpayers fume about wastage and corruption, but large-scale evasion seems unlikely. JOHANNESBURG – There seems to be increasing concern that South Africa could be heading for a tax revolt. This comes amid an outcry against corruption, wastage of taxpayer money and the fact that the country’s deteriorating fiscal situation will… – Continue reading

Tata Steel to refinance $1.5bn offshore debt

Tata Steel’s Singapore arm T S Global Holdings Pte raised $1.5 billion debt to settle outstanding loans, the company said in a statement. Tata Steel group executive director-finance and corporate Kaushik Chatterjee said, “Tata Steel actively reviews all its financing options and seeks to continuously optimise its debt based on… – Continue reading

Clinton offers new ‘exit tax’ on U.S.-foreign company mergers

WASHINGTON — Hillary Clinton on Wednesday will unveil a proposal for a new “exit tax” aimed at cracking down on corporate inversions, a practice that permits U.S. companies to merge with corporations overseas to lower their tax bill. The new tax would be part of a broader effort to target… – Continue reading

Cadbury owner paid no UK corporation tax last year

Mondelez was able to pay no UK corporation tax as a result of a Channel Islands-based bond, despite Cadbury making £96.5m profit in 2014 Mondelez, which owns Cadbury, is facing controversy over its tax arrangements after it was reported that it had not paid UK corporation tax last year. An… – Continue reading