The Transactional Net Margin Method (‘TNMM’) is a prescribed method for determining the arm’s length price in some cases. It also enjoins the adjustment owing to capacity under-utilization differences. Sizes of entities and level of activities differ, so does the available comparables for the purpose of transfer pricing adjustments. The… – Continue reading
On Thursday, The House Ways and Means Committee will once again contemplate making permanent controversial tax breaks that overwhelmingly benefit big business at a cost of $380 billion over the next 10 years. Known as tax extenders, these giveaways are a package of tax breaks that Congress must vote to… – Continue reading
The night that Uber started offering its ride-hailing service in Costa Rica, vandals – reportedly taxi drivers – smashed the windows of one of the company’s cars in protest. Traffic police impounded two Uber vehicles earlier that same night. Airbnb, however, another staple of the so-called “sharing economy,” has been… – Continue reading
Tax professionals in Australia, in considering how to assess risk and prepare for potential controversy in light of the changing tax landscape, are focusing on a number of key themes. These include the following: The importance of assessing and contrasting positions taken, against positions that the Australian Taxation Office (ATO)… – Continue reading
Former HSBC Bank employee Hervé Falciani gave a USB stick with eight names of alleged tax evaders to the four Greek prosecutors who took his testimony at the Greek Embassy in Paris. According to information from an anonymous source at the Public Prosecutor’s office, the list of names includes two… – Continue reading
‘I’m not going to buy into that’ Joe Hockey refuses to feed speculation that he could be replaced as Treasurer by Scott Morrison under the new Prime Minister Malcolm Turnbull. Malcolm Turnbull’s first full day as PM: Live coverage Joe Hockey signals he’s ready to serve on Malcolm Turnbull’s frontbench… – Continue reading
Exclusive: company faces renewed questions over its fitness as security contractor at Australian detention centres on Manus Island and Nauru Wilson Security faces renewed questions about its fitness as security contractor in Australia’s offshore detention centres in light of its corporate links to a tax haven, a corruption scandal that… – Continue reading
Changing Attitudes to Tax Reputation Risk In recent years, it seems that any discussion of tax includes mention of the moral obligation taxpayers have to “pay their fair share.” Many believe this theme began to get traction in 2011 when Warren Buffett realized that he was paying proportionately less taxes… – Continue reading
Stimulus unleashed by China’s central bank will cushion Chinese companies –the region’s biggest dollar debt issuers — from a potential Federal Reserve interest rate increase, making cheaper yuan funds available. Five interest rate cuts by the People’s Bank of China since November and rules to relax yuan bond issuance onshore… – Continue reading
NEW DELHI: Finance minister Arun Jaitley has promised “fairest and predictable taxation regime” while inviting US businesses to invest in the country. Speaking at the 11th Indo-US Economic Summit organised by the Indo-American Chamber of Commerce ahead of the India-US Strategic and Commercial Dialogue (SACD) in Washington later this month,… – Continue reading
Hewlett-Packard will offshore 60% of its workers at its consulting unit, HP Enterprise Services, CEO Meg Whitman told investors Tuesday during the company’s annual analyst meeting. In 2013, 36% of ES workers were in low-cost offshore locations like Manila, Philippines; Costa Rica; and Bangalore, India. By 2018, 60% of them… – Continue reading
The largest producer of nitrogen-based fertilizer in the United States, CF Industries, is considering merging with a Dutch competitor and moving its headquarters overseas to avoid the “double taxation” of profits earned by overseas subsidiaries going to the domestic company. Curtis Dubay, a tax and economic research fellow with The… – Continue reading
Victoria Seychelles — Promoting cooperation between African countries and increasing trade and industry have been the main focus of diplomatic work of the outgoing Nigerian High Commissioner to Seychelles, Solomon Akintola Oyateru, during his term in office. High Commissioner Oyateru made this statement in an interview with the press at… – Continue reading
(Bloomberg) — Grupo BTG Pactual, the only publicly traded investment bank in Brazil, said it’s willing to consider more acquisitions in Switzerland after completing the purchase of BSI, the Swiss private-banking unit of Assicurazioni Generali SpA. “We are looking. We are always looking,” Renato Cohn, a BTG partner and member… – Continue reading
Google’s CEO may be “proud” of the way his company avoids taxes, but a Canadian tax watchdog group thinks the tech giant’s tax practices should disqualify it from partnering in a Canadian election debate. The Globe and Mail is hosting a leaders’ debate on the economy Thursday night in partnership… – Continue reading
The Department of Justice announced today that Bank La Roche & Co AG has reached a resolution under the department’s Swiss Bank Program. “Today’s agreement is yet another example of a foreign financial institution coming forward, acknowledging its criminal conduct, taking the necessary steps to resolve its criminal exposure, cooperating… – Continue reading
The number of banks with deferred prosecution agreements with the U.S. government keeps growing. The subject is tax evasion involving American account holders. Today, under FATCA, banks everywhere want to know if you are compliant with the IRS. And the IRS keeps updating its list of foreign banks where offshore… – Continue reading
On July 9, 2015, India and the US signed an agreement to implement the Foreign Account Tax Compliance Act (FATCA) that will facilitate exchange of information between the two countries starting on October 1, 2015. FATCA was signed by Revenue Secretary Shaktikanta Das and US Ambassador Richard Verma in New… – Continue reading
An increasing number of Americans renounced their citizenship and cut-off long term residencies during the initial three months of 2015 due to a crackdown in the foreign tax rules. The exit wave went down a little in the second half, but has continued. The Internal Revenue Service and Treasury Department… – Continue reading
Note: This article was published by Bloomberg BNA in Tax Planning International European Tax Service Vol. 17 No. 7 July 2015 Introduction The recent LuxLeaks scandal has once again focused political attention on tax planning practices of multinationals (“MNEs”). It comes in the wake of the European Commission investigation of… – Continue reading
As Big Four accountancy firm PwC publishes its annual report Madeline Ratcliffe talks to chairman Ian Powell. PWC, ONE of the world’s largest financial services companies, will today report their full year profits increased by six per cent, to £818m, reflecting a policy of growth and investment over the last… – Continue reading
A civil society group focused on transparency in the oil and gas sector has criticized the interim Offshore Processing Agreement, OPA, between the Nigerian National Petroleum Corporation, NNPC, and three multinational trading companies to boost the supply of refined petroleum products in the country. The Africa Network for Environment and… – Continue reading
The UK government’s use of ‘accelerated payment notices’ (APNs) to demand up-front payment of disputed tax has enabled it to collect £1 billion in payments from users of tax avoidance schemes, it has announced.14 Sep 2015 HM Revenue and Customs (HMRC) has issued over 25,000 APNs since August 2014 to… – Continue reading
A wave of wealthy Asians is hurriedly moving assets to the United States – to school their children, invest in property or even avoid political uncertainty in China. But few of those immigrants know just how much of their money will eventually end up in the hands of the feds…. – Continue reading
Apple’s CEO Tim Cook announced on Wednesday, Sept.9, that the famed brand’s revenue significantly increased in China by up to 75 percent in the past year. However, the country’s finance authorities cut the celebration short. China’s Ministry of Finance demanded Apple to pay 452 million yuan, a price equivalent to… – Continue reading
EU commissioner urges member states to ensure fair share of tax is paid EU economics commissioner Pierre Moscovici reiterated his commitment to re-launch the Common Consolidated Corporate Tax Base yesterday, urging all EU member states to ensure that companies pay their fair share of tax. Speaking following a meeting of… – Continue reading
Multinationals have come under fire yet again over their tax arrangements in some European countries, as the continent moves closer to a pan-European regime to combat tax avoidance. On Friday, European economy and finance ministers and central bankers (known as an ECOFIN meeting) gathered in Luxembourg to discuss what the… – Continue reading
With the agreement with the US, Vietnam has now signed the double taxation avoidance agreements with 70 out of 170 countries and territories with which Vietnam has trade and investment relations. Double taxation is considered a barrier to trade and investment. It discourages transnational investments while prompts individuals and businesses… – Continue reading
Speaking at an informal meeting of the Economic and Financial Affairs (ECOFIN) in Luxembourg, Finance Minister Edward Scicluna once again expressed Malta’s opposition to tax harmonization. “Taxation remains a sensitive area for Malta, not only because of its obvious role in the revenue collection process, but also as an important… – Continue reading
JOHANNESBURG – An amended estate duty scheme won’t add vast amounts of money to government coffers, but will bring added legitimacy to the system, the chair of the Davis Tax Committee has said. Speaking at the 5th Annual Fiduciary Institute of Southern Africa (Fisa) Conference on Thursday, Judge Dennis Davis… – Continue reading
Budgeting battle But like much of the budgeting in Washington, D.C., it gets complicated. The Congressional Budget Office contends the Ex-Im Bank’s surpluses are the result of the accounting method the bank uses and would disappear — or require a taxpayer subsidy — if the bank used a more appropriate… – Continue reading
All eyes are on how much taxes the British retailer Tesco Group will pay to the South Korean government after its profit of more than 5 trillion won (US$4.21 billion) with the sale of Homeplus. Industry sources say that the company will not have to pay taxes at all, or… – Continue reading
PwC has acquired software company Ellis Financial Systems in a bid to more rapidly meet new tax information reporting required under such regimes as the Foreign Account Tax Compliance Act (FATCA). It has been re-named PwC Tax Information Reporting, and will operate from London. The acquisition represents one of many… – Continue reading
Indonesians hold $300 billion in Singapore; controversial tax amnesty on the cards. Indonesia’s finance minister Bambang Brodjonegoro told Euromoney earlier this year that tax collection falls way short of targets and must improve to provide funding for infrastructure and other projects It doesn’t take much for Indonesia’s government officials to… – Continue reading
Companies like Amazon, Tesco and Honeywell are looking to offshore IT subsidiaries to deliver digital transformation. New launches of captive centers offshore continued to increase in the first half of 2015, according to research from outsourcing consultancy Everest Group. Companies in the manufacturing, telecommunications and technology industries, in particular, expanded… – Continue reading
After reopening investigation into HSBC clients hiding money in Switzerland, HMRC admits it has still only prosecuted one tax cheat, reports The Guardian. HM Revenue and Customs (HMRC) is winding down its inquiries into hundreds of British customers who used HSBC’s Swiss bank to evade tax, a senior official has… – Continue reading
The Department of Justice announced today that Valiant Bank AG has reached a resolution under the department’s Swiss Bank Program. “Offshore enforcement remains a top priority of the department, and banks seeking to avoid prosecution pursuant to the terms of the Swiss Bank Program continue to accept responsibility, provide a… – Continue reading
LONDON–Royal Bank of Scotland Group PLC (RBS.LN) has sold a portfolio of corporate-loan commitments related to its banking business in China for 498 million pounds ($755.1 million), as part of the bank’s strategy to focus mainly on U.K. and European customers. RBS said it has reached an agreement with China… – Continue reading
China appeared to expand efforts Thursday to bolster its currency in what traders said is an attempt to align its exchange rates at home and abroad. The yuan rose a record 1.2 percent in the offshore market amid speculation the People’s Bank of China was again acting to contain the… – Continue reading
This week, MEPs discussed a draft report on tax rulings, with a view to a vote in the next plenary session in Strasbourg. The report proposes a comprehensive overhaul of corporate tax practices as part of the EU’s battle to tackle tax avoidance. Parliament’s special committee on tax rulings (TAXE)… – Continue reading
Superstar-laden FC Barcelona might be among the top teams in the Spanish Liga BBVA this season but the team is making news – again – for a more undesirable reason: tax investigations. As Lionel Messi awaits trial on tax evasion charges, another Barcelona star may be joining him. Spanish news… – Continue reading
In the first meeting between HMRC officials and the new parliament’s Public Accounts Committee (PAC), MPs praised the Revenue’s work but called for urgent improvements to customer service and transparency Labour MP Meg Hillier, who replaced Margaret Hodge as the PAC’s chair, opened proceedings by telling HMRC permanent secretary Lin… – Continue reading
France has handed to Cypriot authorities a controversial list of Cypriots with deposits at HSBC bank in Switzerland, Finance Minister Harris Georgiades said on Tuesday, reports the Famagusta Gazette. Cypriot parliamentarians probing the cause of the near melt-down of the economy in 2013 have repeatedly urged the government to obtain… – Continue reading
The original online payment platform, PayPal, has decided to leave the populous island of Puerto Rico next month. The commonwealth has imposed a 2 percent take on any money transmission, forcing Paypal’s hand. So what does this mean for those who need to send money from Puerto Rico? Puerto Rico… – Continue reading
Neo Corp International hit a lower circuit limit of 5% at Rs 33.45 at 11:25 IST on BSE on reports the Indian authorities are conducting a probe against the company on tax evasion charges. Meanwhile, the BSE Sensex was up 345.75 points, or 1.37%, to 25,663.62. On BSE, so far… – Continue reading
It was an American statesman, Benjamin Franklin, a gentleman of reputedly many talents, who is credited with the widely spoken remark, ‘in this world nothing can be said to be certain, except death and taxes.’ Technically, none of us lives forever and paying taxes is a part of life. Dodging… – Continue reading
Not going to make this easy The amazing Yahoo! / Alibaba / SpinCo tax structure has suffered a blow: America’s Internal Revenue Service has refused to say whether or not it approves or disapproves of Yahoo!’s tax-avoidance chicanery. And that usually spells trouble. Back at the start of the year,… – Continue reading
A wealthy Victoria, B.C., family paid virtually no tax over a span of eight years – and even obtained federal and provincial tax credits – while being involved in an offshore tax “sham” developed by one of the country’s most respected accounting firms, the Canada Revenue Agency alleges. The Canada… – Continue reading
Lawyer Patrick Poulin says he helped clients set up offshore corporations in the Caribbean. And that’s what he was working on when he flew to Miami from the Turks and Caicos last year to meet with two Americans who wanted him to invest $2 million from a real estate deal…. – Continue reading
HMRC’s recovery of tax quicker than projected Recent figures released by HMRC record the progress that they have made in seeking early repayment of tax under the Accelerated Payment Notice (APN) regime. This was introduced by the Finance Act 2014, which gave HMRC the power to serve tax demands where… – Continue reading
