The government on Tuesday set up a 10-member committee, chaired by former Delhi High Court judge R V Easwar, to identify provisions in the Income Tax Act that “lead to litigation and impact the ease of doing business” for resolution early next year in the Finance Bill, 2016. The government… – 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
After teasing the UK financial community — and the government — with a thinly-veiled threat to decamp from Britain, HSBC has continued to stoke speculation that it’s looking for more hospitable headquarters. Back in April, HSBC announced a review of whether to quit the UK, a somewhat provocative statement, coming,… – Continue reading
Global tax experts KPMG expect taxpayers throughout the world will need to pay more tax in the years ahead as governments repay debt and fund increases in social welfare. In its annual global tax rates survey released on Tuesday it says Australia’s tax mix is out of step with global… – Continue reading
LONDON (Alliance News) – The Renewables Infrastructure Group Ltd on Tuesday said it is planning to raise further funding from its equity placing programme. The company, which invests in renewable energy infrastructure projects, said the fundraising will likely take the form of placing of shares and will be closed in… – Continue reading
The Australian Taxation Office (ATO) recently engaged in the first automatic sharing of financial account information with the tax authority (IRS) in the United States. The details of more than 30,000 Australian financial accounts of individuals with a connection to the United States were provided to the IRS under the… – Continue reading
A decision by the Federal Court of Australia has key implications for transfer pricing of intercompany financing transactions, as well as implication for other broader intercompany arrangements. The case concerns the transfer pricing implications of an intercompany loan agreement between an Australian taxpayer and its U.S. subsidiary (CFC) and whether… – Continue reading
The Internal Revenue Service is encouraging all non-compliant U.S. citizens, including those among the 1 million Americans who are resident in Canada, to take advantage of its voluntary disclosure programs initiated in 2009 and 2012. The move comes just a few weeks after Canadian courts refused to issue injunctions prohibiting… – Continue reading
The Bank of Butterfield has agreed to buy the multibillion dollar private banking trust and investment arm of rivals HSBC Bermuda. The move means Butterfield will acquire the Bermuda Trust Company Ltd as well as the trust and investment business of HSBC. At the end of last year, HSBC’s trust… – Continue reading
Ireland has announced a new 6.25 per cent corporate tax rate for intellectual property research Ireland’s 12.5 per cent corporate tax rate is already one of the lowest in Europe, Economia reports. Now, companies investing in research and development (R&D) will be able to avail of the even lower rate… – Continue reading
For many years, policymakers have criticized the strategies that American corporations use to reduce their taxes by shifting income and capital offshore. The impetus behind these strategies is the U.S. corporate income-tax rate — at 35 percent, the highest of any industrialized nation, easily surpassing countries such as the U.K…. – Continue reading
HSBC, Google, Facebook are among firms that will now appear after threat from MEPs on access to Parliament. Several multinational companies have now dropped their opposition to appearing before a special European Parliament panel investigating allegations of tax avoidance in Europe. HSBC said Tuesday it would participate in a hearing… – Continue reading
Profit-shifting has not paid off for petroleum multinational Chevron, slugged with a tax bill for $322 million thanks to a Supreme Court decision on Friday. Chevron has been under close scrutiny this year, particularly since a senate inquiry into tax-avoidance in April which also put mining giants BHP, Rio Tinto,… – Continue reading
Citing the need to boost job growth locally and around the United States, Rep. Jerry McNerney, D-Stockton, has introduced legislation that would close tax loopholes that encourage companies to send jobs overseas and that would make companies reveal their outsourcing. The idea behind the legislative package is to provide greater… – Continue reading
Credit Suisse Group AG, the Swiss Bank that unveiled a major shift in strategy last week to focus on wealth management over investment banking, plans to make acquisitions and invest about $400 million in Switzerland in the next few years, Chief Executive Officer Tidjane Thiam and Chairman Urs Rohner said… – Continue reading
The offshore yuan market faced a rocky patch following Beijing’s shock devaluation in August, but the push to internationalise the currency has lost little momentum, according to The Strait Times. Similarly, Singapore’s role in the growth of the yuan is likely to continue unabated. The general manager of ICBC Singapore,… – Continue reading
Lawmakers at the European Parliament are set to vote on a controversial series of proposals to harmonize the corporate tax system in Europe in a move that will put them on a collision course with some member states which favor sovereignty over taxation. The EU lawmakers on the TAXE committee… – Continue reading
The South African Revenue Service (SARS) has issued a revised guide to inform foreigners working in South Africa and their employers about their income tax commitments. The guide points out that, under the South African income tax system, amounts received by or accrued to persons other than residents (non-residents or… – Continue reading
Those thinking about a job or retirement abroad should consult their foreign counterparts, who believe they’re getting a better deal stateside. According to a new survey from HSBC, foreign expats living in the United States do so for the long haul. Nearly two-thirds (65%) live here for more than five… – Continue reading
A company controlled by Mayor of Belgrade Sinisa Mali and his family obtained more than 10 hectares of agricultural land worth anywhere from €123,000 to € 250,000 (US$140,000 to US$290,000) for free from a privatized state company. Problem is, the land wasn’t the company’s to give, but was still owned… – Continue reading
The European Commission (“Commission”) ruled on 21 October that tax advantages granted by Luxembourg to Fiat and by the Netherlands to Starbucks by means of advance tax rulings were unlawful under the EU State aid rules. The two Member States will be required to recover the aid, in each case… – Continue reading
The Bank of Japan need not boost its massive monetary stimulus this week as the labor market remains tight, a key economic adviser to Prime Minister Shinzo Abe said on Monday. Koichi Hamada, an emeritus professor of economics at Yale University, also told Reuters that the central bank does not… – Continue reading
Coca-Cola might owe an additional $3.3 billion in federal income taxes following an audit, says the Internal Revenue Service (IRS). Following a five year audit of the company, the IRS concluded that the company’s strategy of lowering its taxable income through transfer pricing, underestimates the amount the company should’ve been… – Continue reading
The EU tax rulings against Starbucks and Fiat Chrysler are but trifles compared to the ones extant against Apple and Amazon. Everyone lies about tax. Holland said it followed international tax standards when everyone knows it’s a corporate tax haven. That’s why ST has its HQ there. Ireland and Luxembourg… – Continue reading
• There can be no straight jacket formula to determine what is meant by “provision of service,” which may include where services are i) provided; ii) rendered; or iii) utilized. • The expression ‘provision of services’ is much wider than ‘provision of rendering of services,’ and covers the services even… – Continue reading
MTN has consistently prided itself as the foremost telephone company that is getting Nigerians talking the most. Now the South African company is about to set tongues wagging across networks with revelations that it has routinely been shipping billions of naira overseas to avoid paying its fair share of tax… – Continue reading
Foreign companies with Indian shareholders won’t have to pay taxes here for their worldwide income unless they are managed from India on an everyday basis. If these foreign companies are managed from outside India, whether or not they are promoted by resident Indians, they will have to pay taxes in… – Continue reading
India has told the International Court of Justice that it will soon appoint an arbitrator to resolve the Rs 10,247-crore tax dispute with British oil explorer Cairn Energy Plc. Cairn on March 10 sought arbitration under the India-UK Bilateral Investment Protection Agreement against the tax demand raised on a 2006… – Continue reading
The European Commission looks highly likely to make a finding against Ireland in relation to its tax arrangements with Apple, following two similar findings during the week involving Starbucks and Fiat. It is perplexing that the EC doesn’t just come out and make the announcement. The delay is leading to… – Continue reading
The African Union Advisory Board on Corruption (AUABC) recently requested major multinationals operating in Africa to be more open about the taxes and royalties they pay governments to improve transparency and accountability. Although a reasonable request, this is a tall order when you consider that often it is the governments… – Continue reading
Rwanda has commissioned an audit into recent merger and acquisition deals involving foreign firms in its latest effort to clamp down on tax avoidance among multinational corporations. This comes amid growing concern that multinational companies move profits from the countries where they are generated and, in so doing, reduce national… – Continue reading
DOZENS of Winchester properties worth more than £100 million are owned by firms based in offshore tax havens. High street shops, restaurants, care homes, a health clinic and even a single parking space are owned by companies benefitting from low tax regimes overseas. Burma Road student village, sold by the… – Continue reading
Since the revelations on government surveillance and data capture by Edward Snowden, journalists have rightfully raised concerns about governments’ insatiable appetite for data collection and the resulting encroachment on citizens’ civil liberties. In the EU an individual’s right to privacy is regarded as a human right in accordance with Art…. – Continue reading
The key corporate tax measures in the Finance Bill show clear signs of the international scrutiny now surrounding multinational tax. The main new measure, the knowledge development box offering a lower tax rate on profits earned as a result of research and development, has been strictly drawn up to comply… – Continue reading
Leading family offices in Latin America and the Caribbean are going through a transitional period, says Steven Cantor, managing partner of Cantor & Webb, a Miami-based law firm, reports the Financial Times. “As the world moves to tax transparency, with a crackdown on undisclosed tax savings in Swiss bank accounts,… – Continue reading
While stocks such as Hindustan Unilever (HUL) and Maruti Suzuki have outperformed the markets by a wide margin in the last couple of years, the stocks have sustained the performance even over longer periods. Despite the hue and cry over royalty payments by Indian subsidiaries of multinational companies, these companies… – Continue reading
The New York billionaire is aiming his financial might at members of Congress who aren’t willing to cut deals on corporate tax policy. Sure, Carl Icahn might make money—lots of money—on his $6 billion stake in Apple Inc. if a political campaign he announced Wednesday to cut taxes on companies’… – Continue reading
Pending draft regulatory measures in Jersey would give effect to the Common Reporting Standard (CRS). In general, the draft regulations would impose an obligation on “reporting financial institutions” in Jersey to identify, review, and report on “financial accounts” maintained by these institutions of accounts held by residents for tax purposes… – Continue reading
Multinational oil giant Chevron has been hit with a tax bill of about $300 million after losing a landmark profit-shifting case that could have global implications for the way tax is assessed. The Australian Tax Office’s case in the Federal Court case has been closely watched by the tax and… – Continue reading
The company that is not a taxi company, which has drivers that are not taxi drivers, who carry people around that are not clients, Uber, is not only killing the taxi business, it is also avoiding paying taxes. The company uses a trick known as “the double-Dutch.” It is perfectly… – Continue reading
Global fund distribution company, Satori Consultancy, has launched a Hong Kong registered offshore pension plan structured by Legacy Trust Company (LTC) as an occupational scheme. The International Pension Plan, which has five risk graded investment portfolios run by Marathon Capital & Apollo Multi Asset Management, is a Hong Kong-based exempt… – Continue reading
MUMBAI: Technologies that are developed in India but their patents registered in tax havens may come under the domestic tax net from the next financial year, when the country is expected to adopt a new world standard aimed at preventing abuse of double taxation avoidance agreements. Many multinational and local… – Continue reading
The “Evasion in the financial system” film is a documentary directed by former minister of Culture Jorge Coscia. It is based on the information leaked in the media by Hervé Falciani, an ex-employee of HSBC’s Swiss private bank, on clients and their tax situation. The C5N news channel aired this… – Continue reading
Oil and gas giant Chevron faces a massive tax bill after losing a long-running battle with the tax office over allegations the company used internal lending to reduce its Australian taxes. The Federal Court this morning ruled against Chevron in a landmark legal case that had argued the US multinational… – Continue reading
Major US investor Carl C. Icahn and the Chief Executive Officer of TechNet, Linda Moore, have both recently written letters to leading lawmakers pointing out that the passage of international tax reform by Congress has become a matter of extreme urgency. In his letter, Icahn announced that “the time has… – Continue reading
On 21 October, the European Commission (“EC”) adopted its first decisions in its investigation into Member States’ tax rulings. The investigation, which began in June 2013, has also targeted tax rulings given to Apple and Amazon as well as Belgium’s so-called “excess profits regime”. Although the investigation is conducted under… – Continue reading
Expats living in the United States enjoy greater financial comfort than U.S. expats living abroad, according to a recent HSBC survey. Financial findings from the report, “Expat Explorer: Balancing Life Abroad,” revealed key differences between expats living in the U.S. and U.S. citizens living abroad. According to the report, expats… – Continue reading
