Category: Corporates

OPP union mess reveals a ‘toxic’ work culture amid allegations of theft and fraud

Two reviews into the Ontario Provincial Police Association reveal that “tyrannical” leaders led to a complete breakdown of governance. There were harassing, expletive-filled emails, including one telling a staffer to “hurry the f— up” and another threatening to “rip off” a board member’s head. There were employees brought to tears… – Continue reading

Undisclosed foreign bank accounts: CBDT issues guidelines for compounding of offences

NEW DELHI: The Central Board of Direct Taxes (CBDT) has issued guidelines for compounding of offences under Income Tax Act, 1961/Wealth Tax Act, 1957, in cases of persons holding undisclosed foreign bank accounts/assets. The CBDT on Friday issued directions to all field formations, including principal chief commissioners, chief commissioners and… – Continue reading

New Swiss Banking Norms May Not Help India’s Hunt for Black Money

Switzerland will allow stolen data acquired through official means to form the basis for a request for assistance but will help India only for post-2011 bank accounts, that too as long as Swiss courts don’t interfere Geneva: Switzerland’s proposed changes on treating stolen information have generated much optimism in India… – Continue reading

Big UK companies halve provisions for disputed tax bills

The amount big companies set aside to cover disputed tax bills has more than halved over the past three years to £1.7bn this year, reports the Financial Times. Even though businesses fear more disputes as tax authorities become increasingly tough, they are showing reluctance to be drawn into conflicts that… – Continue reading

Israeli banks named in Australian tax evasion affair

Former Nudie Juice CEO Andrew Binetter allegedly sought the destruction of incriminating files at Bank Hapoalim. The names of Israeli banks Bank Hapoalim (TASE: POLI) and Israel Discount Bank (TASE: DSCT) have been mentioned in the Australian press as involved in alleged tax fraud in the millions of dollars by… – Continue reading

Govt to tax collectors: give foreign companies a break | Reuters

MUMBAI India’s tax officials, long the scourge of foreign investors, are under government pressure to avoid aggressive claims against overseas funds and companies, as the country seeks to repair an image dented by high-profile tax battles. The latest dust-up was over a largely overlooked minimum alternate tax (MAT), which had… – Continue reading

Black money law: Beneficiaries in overseas discretionary trusts may face enquiry

MUMBAI: Indian tax authorities will ignore conventions to pierce trust structures used by most people to stash black money abroad. Persons who are named as beneficiaries in overseas discretionary trusts are likely to face enquiry even if they do not receive any money from such trusts. The taxman will look… – Continue reading

Funding for businesses facing APNs

A funding line has been launched to help business taxpayers facing payment deadlines arising from Accelerated Payment Notices (APNs) APNs, introduced in 2014, enable HMRC to request full upfront payment of disputed tax within 90 days. They are issued to individuals and companies suspected of partaking in aggressive avoidance schemes…. – Continue reading

Last minute funding to help SMEs pay tax bills

Commercial finance provider LDF has launched a funding line to help taxpayers facing payment deadlines arising from accelerated payment notices issued by HMRC. Accelerated payment notices, otherwise known as APNs, were first introduced in 2014. Designed to change the economics of avoidance, the notice enables HMRC to request full upfront… – Continue reading

Tax scandal probe hit by setback as EU refuses to hand over documents to MEPs

The European Commission is refusing to hand over documents to MEPs investigating whether EU member states are using special tax regimes that favour large multinational corporations such as Facebook and Amazon. EU economics commissioner Pierre Moscovici wrote to the European Parliament’s special committee on tax rulings (TAXE) this week claiming… – Continue reading

Fortune 500 Corporations Are Likely Avoiding $600 Billion in Corporate Tax Using Offshore Tax Havens

As Labor Day weekend approaches, a tanned and rested Congress is poised to return to Washington to hash out corporate tax changes. Much of the debate over corporate tax reform in Washington sensibly focuses on how to encourage Fortune 500 corporations to repatriate and pay U.S. taxes on the $2.1… – Continue reading

IRS Offshore Account Penalties Increase, Hunt Continues

The number of Swiss banks that have entered deferred prosecution agreements with the U.S. government keeps growing. The subject is tax evasion involving American account holders. Today, banks everywhere want to know if you are compliant with the IRS. Under FATCA, the entire world is lending the IRS a hand…. – Continue reading

Glenmark down 3%; Credit Suisse says Venezuela may hurt PAT

Moneycontrol Bureau Credit Suisse has maintained its underperform rating on Glenmark Pharma as it feels potential currency devaluation in Venezuela could hurt profit meaningfully. The stock lost more than 3 percent intraday Wednesday. The brokerage expects a 20 percent degrowth in company’s FY17 earnings per share as it continued to… – Continue reading

Argentina Tells HSBC to Remove CEO in Tax Evasion Dispute

HSBC’s Argentine unit told to remove CEO and one director HSBC accused of helping capital flight by wealthy Argentines Argentina’s central bank revoked the licenses of two top executives at HSBC Holdings Plc’s local unit, including the chief executive officer, arguing they had failed to prevent clients from laundering funds… – Continue reading

Etsy facing renewed pressure over Irish tax strategy

Call to strip company of transparency standards certification A leading tax policy advocacy group has called for online retailer Etsy to be stripped of a certification awarded to companies that adhere to strict standards for transparency and social accountability unless it dismantles its offshore tax cutting structure. Last month, Bloomberg… – Continue reading

Tax-dodger hunt neutralises Swiss bank secrecy, U.S. envoy says

Swiss banking secrecy is no longer viable as the U.S. Justice Department closes in on agreements with most of the institutions that may have helped Americans evade taxes, according to the top American diplomat in Switzerland. Negotiations with about one-third of Swiss lenders, known as Category 2 banks, to finalise… – Continue reading

Mexico used a ‘strong-arm’ tactic to coax multinational corporations into paying more taxes

Mexico’s government withheld hundreds of millions of dollars in tax refunds owed to Procter & Gamble, Unilever, and Colgate combined as it sought to coax them and other multinationals to pay more income tax locally, according to people close to the talks. After luring foreign companies with corporate tax breaks… – Continue reading

Mexico: International Transactions And Cost-Sharing Limitations In Mexico

International worldwide transactions in Mexico face a weakness as a result of an old and outdated provision which disallows for income tax purposes, the deduction of payments made abroad on a prorated basis with other parties that are not subject to Mexican income tax, such as foreign residents with no… – Continue reading

Indian Court Allows Mauritius Treaty Benefits For Appellant

Rejecting “treaty shopping” claims, India’s High Court of Punjab and Haryana has ruled that India should not tax capital gains from the sale by Mauritian entities of shares held in an Indian company if they are proven resident in Mauritius. The ruling was given in Serco BPO Private Limited v…. – Continue reading

Transfer pricing audits: flipping the tested party

Introduction Transfer pricing methods and tested parties Troubling trend Tools for taxpayers Introduction In some recent transfer pricing audits the Internal Revenue Service (IRS) has ‘flipped the tested party’ after examining transactions between related US and foreign companies. Typically, this practice results in the attribution of a larger portion of… – Continue reading

Leumi Asked to Consider Bonus Clawbacks After U.S. Tax Fine

The Bank of Israel asked Bank Leumi Le-Israel Ltd. to set up an independent committee to examine management performance and bonuses after the lender agreed in December to pay a fine to U.S. authorities in a tax probe. Leumi, Israel’s second-largest lender, agreed the $400 million fine after a seven-year… – Continue reading

Foreign companies with no permanent base may get Minimum Alternate Tax relief

Three-member AP Shah Committee has recommended extending minimum alternate tax (MAT) relief to foreign companies which do not have permanent establishment or public business in India. In an earlier version, the committee had sought to restrict MAT to foreign institutional investors and foreign portfolio investors. The committee had also not… – Continue reading

Israel Banking Watchdog Says Leumi Execs May Have to Return Bonuses

Regulator demands Bank Leumi investigate top management in wake of U.S. tax-evasion settlement. Bank Leumi should take back bonuses it paid three former senior executives after the lender was forced to pay a huge penalty to the United States for tax violations that occurred under their watch, Banks Supervisor David… – Continue reading

No MAT for ‘Foreign Companies’ – Shah Panel suggested in revised report

Three-member AP Shah Committee has recommended extending minimum alternate tax (MAT) relief to foreign companies which do not have permanent establishment or public business in India. In an earlier version, the committee had sought to restrict MAT to foreign institutional investors and foreign portfolio investors. The committee had also not… – Continue reading

Transfer pricing: Encouraging developments on APA and MAP

A recent Central Board of Direct Taxes (‘CBDT’) press release of August 6, 2015 announced signing of 2 unilateral APAs, including one with a rollback provision, and this has raised hopes of many MNCs, that hope to witness expeditious and reasonable closures. n July 2012, with a view to providing… – Continue reading

Barclays Pressing Swiss Private Bankers to Double Client Assets

The new head of Barclays Plc’s Swiss unit is pushing private bankers in Geneva and Zurich to double client assets in four years as international competitors exit the world’s largest hub for offshore wealth. James Buchanan-Michaelson, who joined from Coutts International in June, aims to increase Swiss assets, including loans,… – Continue reading

Country-By-Country Reporting: The Transfer Pricing Game-Changer

This month’s feature examines proposals for new tax information reporting requirements for large multinational businesses as part of wider and ongoing changes to the international tax system – proposals which have been described by international tax experts as the most significant development in the field of transfer pricing since TP… – Continue reading

HSBC spills details on 400 Indian accounts in Singapore; half are from Mumbai

After the leak of two major secret documents from HSBC’s Swiss private banking arm that revealed names of roughly 2,000 Indian account holders, the global bank itself has done it now. For the first time ever, HSBC Singapore shared a new list of 1,200 individuals all across the globe of… – Continue reading

UK: In The Spotlight – Summer 2015

WINDS OF CHANGE – GEORGE OSBORNE’S FIRST BUDGET AS THE CHANCELLOR OF A CONSERVATIVE GOVERNMENT BROUGHT SEVERAL SIGNIFICANT ANNOUNCEMENTS. By Mark Wingate Taking a leaf from the Labour Party’s election manifesto, there will be a further tightening of the rules for non-doms. In an attempt to provide a more level… – Continue reading

Will Etsy’s Brazen Tax Avoidance Cost the Company Its “B Corporation” Status?

The online craft website Etsy is facing new scrutiny for its recent decision to shift some of its intellectual property into a secretive Irish subsidiary. As Bloomberg reported last week, the company’s Irish subsidiary has been made into an “unlimited liability corporation,” a form that exists primarily to avoid disclosure… – Continue reading

CHINA: MANAGING IP TAX CHALLENGES IN BEPS ENVIRONMENT

Multinational enterprises (MNEs) producing or selling their products in China have had to contend with the commercial, legal, and tax challenges of managing how their intellectual property (IP) is used in relation to their Chinese operations. Regulatory approvals for joint ventures operating in China have often required that IP rights… – Continue reading

UK sets sights on large-scale tax dodgers

The UK is preparing to triple the number of prosecutions of “serious and complex” tax evaders using an arsenal of proposed new powers, reports the Financial Times. A unit combining the civil and criminal investigations teams at HM Revenue & Customs will spearhead a crackdown that George Osborne, the chancellor,… – Continue reading