European Union lawmakers have called 13 multinational companies to a meeting next week to talk about the low-tax deals they have struck with EU jurisdictions, reports CBC News. Among the companies to be questioned on Nov. 16 will be Amazon.com, Disney, Coca-Cola Co, Anheuser-Busch InBev NV, HSBC Holdings, Ikea Group… – Continue reading
Following the October 2015 release of the OECD’s base erosion and profit shifting (BEPS) deliverables, some consultations in the UK have already been opened—including one on the UK’s rules concerning the deductibility of corporate interest expense and how this treatment would be affected by BEPS Action 4 (which seeks to… – Continue reading
THE South African Revenue Service (SARS) is planning to pay more attention to ensuring that medium and smaller companies, and those in the “cash economy”, pay their taxes. This comes after several years in which the focus has been mainly on tackling non-compliance in the large business sector. SARS group… – Continue reading
‘Special purpose’ approach by accountants hides corporate secrets Amid the maelstrom over the GST, the Senate last night passed what may be the most useful piece of legislation yet to combat multinational tax avoidance. The new law was not carried by the government, whose track record on tackling big tax… – Continue reading
A Chris Christie administration would likely make shareholders at some major U.S. companies very happy. The two-term New Jersey Governor has called for an array of pro-growth, business-friendly reforms as he bids for the Republican nomination. Christie is in favor of lowering corporate taxes so companies earn more profits, raising… – Continue reading
At a very high level, it’s a simple concept: a multinational borrows money from a related company overseas, and then uses the interest bill and the repayment methods to reduce tax exposure in Australia. If the loans – and the interest rates – are big enough, the tax savings can… – Continue reading
Article by Patrick W Martin and Ashley Fife With a net worth of USD77.1 billion, Mexican telecoms businessman Carlos Slim Helú was ranked the second richest person in the world in a 2015 survey.1 At the end of 2014, 16 of Mexico’s citizens were on Forbes’ billionaires list.2 As for… – Continue reading
Tax-driven “inversion” deals that let companies flee the U.S. tax system by relocating abroad, if only on paper, would be curbed under legislation introduced in Congress, as Pfizer Inc (PFE.N) pursues such a deal with rival Allergan Plc (AGN.N). Wisconsin Democratic Representative Mark Pocan’s bills likely have little chance of… – Continue reading
In a time of fiscal austerity, it is breathtaking to learn that Congress has allowed Fortune 500 companies to avoid an estimated $620 billion in federal taxes on earnings they are holding offshore. While the inaction by lawmakers on this issue may create the impression that there is nothing to… – Continue reading
FRANKFURT (The Street) — Europe’s allure as a tax haven for U.S. multinationals may be coming to an end. That’s because European Union regulators are closing up tax loopholes that U.S. companies have been enjoying for years. The first two to feel the heat are Starbucks (SBUX – Get Report)… – Continue reading
Leave.EU, supported by Ukip and financed by a multimillionaire, vies to lead Britain’s exit from Europe A leading campaign group seeking to take Britain out of the European Union was set up by an offshore company that offers tax avoidance services to “high net worth individuals”, the Observer can reveal…. – Continue reading
The recent corporation tax controversy highlighted by US presidential hopefuls Hillary Clinton and Donald Trump is not damaging Ireland’s reputation as a place to do business, said the former chief executive of Apple, John Sculley. According to Mr Sculley, the controversy is simply part of US election fever. Known as… – Continue reading
The Redmond tech company and the Internal Revenue Service tangled in court Friday over the government’s audit of Microsoft’s software sales through offshore subsidiaries. Microsoft and the Internal Revenue Service sparred in court Friday over the agency’s power to investigate taxpayers. Microsoft, seeking a court order to overturn a portion… – Continue reading
Exclusive More than 100 victims of notorious conman Peter Foster have moved to freeze funds held in offshore tax havens after more than $10 million was siphoned from his online gambling company Sports Trading Club. Fairfax Media can reveal Foster and at least eight associates have been served with freezing… – Continue reading
Croatia’s National Bank announced a reduction in the bank discount rate, from 7% per annum to 3% per annum, effective 31 October 2015. This rate reduction has tax implications. Accordingly, for Croatian corporate profit tax law purposes: (1) the maximum amount of deductible interest on loans from a Croatian tax… – Continue reading
The finance ministry is streamlining safe harbour rules and advance agreements, two mechanisms to determine the price of services rendered by a multinational to its subsidiary in India. Safe harbour rules – directives on margins the tax authorities should accept for the transfer price declared by an assessee – have… – Continue reading
One year after the announced closing off of the Double Irish tax arrangement, U.S. multinationals once again turned their attention to Dublin as Ireland announced details of the Knowledge Development Box, or KDB. This new component to its corporate tax regime will allow companies to pay a reduced corporate tax… – Continue reading
As procurement organizations evolve, they commonly adopt a different procurement operating model (POMs) at different stages of their development. A global KPMG survey of chief procurement officers (CPOs) found that 83% of organizations changed their POM within the last 5 years and just over half of them over the previous… – Continue reading
Today the EU and Andorra initialled the text of a new tax transparency agreement, marking another important step forward in the fight against tax evasion. Under the new agreement, Andorra and EU Member States will automatically exchange information on the financial accounts of each other’s residents from 2018. Pierre Moscovici,… – Continue reading
Speed read Europe’s highest court has turned the US into a privacy pariah, and the fallout could have a major impact on New Zealand businesses. Tech companies and cloud computing providers, big and small alike, are staring down the barrel of increasingly uncertain privacy compliance challenges, as are their customers…. – Continue reading
Payments made to Luxembourg, Cyprus, and the Seychelles during the current tax period are no longer required to be reported, according to the findings of a 29-30 October 2015 meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes. The conclusion of the October 2015 meeting… – Continue reading
Pharmaceutical giant Shire, which is headquartered in Ireland for tax purposes, has agreed to buy US rare disease specialist Dyax Corp for about $5.9bn (€5.35bn), and potentially up to $6.5bn, while still pursuing a five- times larger unsolicited bid for biopharma firm Baxalta Inc. The Dyax deal, the latest in… – Continue reading
The Department of Justice announced today that Banque Bonhôte & Cie SA (Banque Bonhôte) has reached a resolution under the department’s Swiss Bank Program. The Swiss Bank Program, which was announced on Aug. 29, 2013, provides a path for Swiss banks to resolve potential criminal liabilities in the United States…. – Continue reading
The government has been accused of opening a loophole that allows super rich individuals and multinational companies to avoid taxes. The Tax Justice Network (TJN), a lobby group, has sued the government over agreements, which it says are robbing Kenya of the ability to raise revenues domestically, driving the country… – Continue reading
The Republican front-runner says high corporate tax rates are the real villain. Donald Trump isn’t blaming Pfizer Inc. for the problem of corporate inversions. The Republican front-runner said Pfizer’s planned merger with Allergan Plc was understandable since it would allow the company to relocate its headquarters to Ireland, where taxes… – Continue reading
Buying a property overseas is an exciting venture, but also one that requires careful financial consideration. To help ease the process, Chris White, Founding Director of boutique estate agency Ideal Homes Portugal, has compiled his top tax tips for buying property in Portugal. Portugal has been called ‘Europe’s best kept… – Continue reading
Video game publisher Activision Blizzard (NASDAQ:ATVI) is satisfying its sweet tooth for acquisitions by buying mobile game maker King Digital Entertainment (NYSE:KING), best known for “Candy Crush Saga.” Activision announced late Monday that it has agreed to pay $18 in cash per share for London-based King, in a deal worth… – Continue reading
The founder of a Singapore-based trust company that came under fire in 2013 for data breaches and allegations of aiding tax evasion said it is “time to move on”. Mr David Chong said his Portcullis TrustNet, which has since been renamed Portcullis Group, is busy planning for the future after… – Continue reading
The Internal Revenue Service says some of America’s most successful companies have been shuttling money to avoid paying their share of federal income taxes. Microsoft is fighting IRS attempts to collect more than $2 billion from profit the software giant transferred between foreign affiliates. Amazon.com is fighting to keep $1.5… – Continue reading
Pfizer’s bid for $113bn Dublin-based drug maker Allergan is the biggest merger of the year, anywhere. It’s potentially good news for the Irish exchequer, which may gain a massive new taxpayer, and for businesses here like Arthur Cox, Allergan’s adviser on Irish corporate law. But a deal that may well… – Continue reading
A spate of so-called “tax inversion” deals involving companies based in Ireland appears to be distorting the country’s foreign direct investment (FDI) numbers, The Irish Times reports. An OECD report suggests investment by Irish firms abroad more than doubled to US$75 billion in the first half of 2015. The study… – Continue reading
How analytics will nab cheaters. Tomorrow is the Australian Taxation Office’s official cutoff for 2014-15 personal tax returns. Will you be tempted to tell fibs about your income? How will the tax man ever know? Take note: it may already know – or at least can find out – a… – Continue reading
Pfizer Inc. may be getting closer to breaking up and moving out. The largest U.S. drugmaker and Allergan Plc are considering combining operations, according to the Wall Street Journal. A deal would give Pfizer a way to move to a low-tax legal address abroad and gain valuable specialty drugs like… – Continue reading
The Department of Justice announced today that Luzerner Kantonalbank AG (Luzerner), Habib Bank AG Zurich (HBZ), Banque Heritage S.A. and Hyposwiss Private Bank Genève S.A. (Hyposwiss Geneva) have reached resolutions under the department’s Swiss Bank Program. These banks will collectively pay penalties totaling more than $25 million and continue to… – Continue reading
Gold Fields and Sasol have clinched the top awards in PwC’s Building Public Trust Awards: Excellence in the field of tax reporting in 2015. Gold Fields was the overall winner in the category for tax reporting for multinational companies, while Sasol was announced the overall winner in the category tax… – Continue reading
Opinion is divided on the extent to which corporates are ready for the country-by-country reporting requirements of the OECD’s base erosion and profit shifting project, as well as the work required to ensure compliance. Earlier this month the OECD presented the final package of measures for reform of international tax… – Continue reading
Most double tax avoidance treaties between two countries attempt to repel probable abuse of benefits under the pacts. Incorporating a clause for limitation of benefits (LOB) in the treaty is the usual practice adopted for checking such abuses. LOB provisions are for denying benefits of the tax treaty to those… – Continue reading
The declining trend in the income tax department’s estimates of alleged income suppression by multinational companies would get buttressed, thanks to the new set of transfer pricing (TP) rules issued earlier this week. Currently, transfer pricing adjustments become necessary when the transaction price with related parties abroad reported by a… – Continue reading
Barcelona defender Javier Mascherano has reportedly pleaded guilty to a charge of tax evasion after appearing in court on Thursday. AS says that the Argentine was accused of using tax havens to funnel money from image rights and defrauding the Spanish authorities of around €1.5m in 2011 and 2012. Mascherano… – Continue reading
RIO DE JANEIRO, Oct. 28 (Xinhua) — Brazil’s Secretariat of Federal Revenue is carrying out an official investigation of Eduardo Cunha, head of House of Representatives, for tax evasion and other fiscal crimes, local daily O Globo said on Wednesday. Started in August, the investigation was based on information which… – Continue reading
An income tax treaty between Italy and Hong Kong has entered into force, with the exchange of instruments of ratification. The official communication of the Italian Ministry of Foreign Affairs announcing this exchange was published in the official journal on 26 October 2015. BLACK LIST, WHITE LIST Italy’s “black list”… – Continue reading
Australia’s corporate tax rate is higher than the global average, according to KPMG’s 2015 global tax rate survey, SmartCompany reports. While Australia’s corporate tax rate currently sits at 30 per cent, the global average sits at 23.68 per cent. The United States has the highest corporate tax rate at 40… – Continue reading
Under the new agreement, Liechtenstein and EU Member States will automatically exchange information on the financial accounts of each other’s residents from 2017. Pierre Moscovici, Commissioner for Economic and Financial Affairs, Taxation and Customs, said: “Today the EU and Liechtenstein are sending out a clear message: we are partners in… – Continue reading
The finance ministry on Tuesday set up a 10-member committee to review the Income-Tax Act to avoid litigation and improve ease of doing business, after solving past minimum alternate tax (MAT) cases and easing transfer pricing norms. The announcement came on a day when a World Bank report showed only… – Continue reading
JAKARTA, Oct 28 (Reuters) – Indonesian conglomerate Lippo Group plans to shift two real estate investment trusts (REITs) with 35 trillion rupiah ($2.6 billion) in assets from Singapore to Indonesia next year in order to benefit from new tax breaks offered by Jakarta. Lippo’s move could be followed by at… – Continue reading
National Bank of Abu Dhabi (NBAD), the largest lender by assets in the United Arab Emirates, bought Royal Bank of Scotland’s offshore loan book in India for 3 billion dirhams ($816.8 million) in October, the bank’s chief executive Alex Thursby said in a conference call on Wednesday. The bank is… – Continue reading
Come November 1, mutual fund investors will have to provide details and declaration pertaining to Foreign Account Tax Compliance Act (FATCA) and common reporting standards (CRS) for all new accounts opened, failing which fund houses are likely to reject their applications. While some fund houses have already started this process… – Continue reading
Action 13 of the final package of reports issued by the Organisation for Economic Cooperation and Development (OECD) under the base erosion and profit shifting (BEPS) project focuses on a company group’s global value chain and transfer pricing policy, and introduces a standardized three-tiered approach to transfer pricing documentation—core documentation… – Continue reading
The European Commission recently published new rulings, the OECD published its base erosion and profit shifting (BEPS) final reports, and many countries are reviewing and reinforcing their transfer pricing rules—and France is no exception. Tax professionals in France have observed certain recent trends with regards to transfer pricing. The current… – Continue reading
The Netherlands has completed its ratification procedures for the entry into force of a new income tax treaty between the Netherlands and Germany. Therefore, the treaty will be effective beginning 1 January 2016. The Netherlands-Germany income tax treaty was signed in April 2012. The ratification process in the Netherlands took… – Continue reading
