Apple is a major part of why the United States is the world’s leading innovator on new technologies, particularly those involving telecommunications and computers. The company has over 66,000 domestic employees, and a large percentage of its customers are here — at least 40 percent, according to its latest annual… – Continue reading
Apple CEO Tim Cook struck back at critics of the iPhone maker’s strategy to avoid paying U.S. taxes, telling The Washington Post in a wide ranging interview that the company would not bring that money back from abroad unless there was a “fair rate.” Along with other multinational companies, the… – Continue reading
Budget 2016 introduced a new tax called Equalisation Levy (“EL”), aimed at taxing online transactions. EL was originally mooted by the OECD in Base Erosion and Profit Shifting (BEPS) Project Final Report on Action 1 – Addressing the Tax Challenges of the Digital Economy (the “Report”). We will examine Equalisation… – Continue reading
Officials from the Department of Finance and the Revenue Commissioners said they are investigating recent media reports that so-called vulture funds are using a clause in Irish law to pay small amounts of tax here. Minister for Social Protection Leo Varadkar has said that the Government is “very concerned” at… – Continue reading
The world’s major economies need to deepen cooperation on tax collection as companies seek to minimise the amount they pay to governments, finance ministers said Saturday. The issue has become controversial in many countries, with multinational firms from Google to Starbucks facing accusations of not contributing appropriately to the economies… – Continue reading
Slashing rates probably won’t be the U.K.’s magic bullet. As Britain plans its way out of the European Union, politicians have been looking for ways for the country to maintain its dominance as a center for global capital. One idea: turning the post-Brexit U.K. into a tax haven. In the… – Continue reading
The Irish Revenue has released guidance on how it will exchange information on the tax rulings it grants. Revenue eBrief No.65/16, which was released on July 5, 2016, sets out Revenue’s arrangements for implementing Council Directive (EU) 2015/2376; and the OECD’s framework for the compulsory spontaneous exchange of information in… – Continue reading
The U.S. Internal Revenue Service (IRS) said Facebook Inc. may have understated the value of intellectual property it transferred to Ireland by “billions of dollars,” unfairly cutting its tax bill in the process, according to court papers. The U.S. Justice Department filed a lawsuit on Wednesday in federal court in… – Continue reading
The United Kingdom is unlikely to try to lure international investment by becoming a tax haven after it leaves the European Union, according to an internal memo prepared by the body responsible for the drafting international tax rules. The head of tax at the Organization for Economic Co-operation and Development,… – Continue reading
Tax authorities in Spain have raided Google’s offices in Madrid as part of an investigation into tax evasion and fraud, TechCrunch understands. Local press and the Reuters news agency are also reporting the raids. The raid on Google’s Madrid headquarters and its Google Campus workspace are related to VAT payments… – Continue reading
Regardless of whether you were surprised, overjoyed, dismayed or showed any other emotion (perhaps anger as you saw world markets tank), Brexit is here. Yes, we’re talking about the British exit from the European Union. We are not sure why the media coined the term “Brexit,” when it’s not only… – Continue reading
British multinational companies face new withholding taxes that may cost hundreds of billions of euros a year if U.K. voters decide to leave the European Union, international tax specialists say. A so-called Brexit “would have a major impact” on British corporations that have subsidiaries in the EU, said Daniel Gutmann,… – Continue reading
The European Commission is on the brink of agreeing its far-reaching anti-tax avoidance directive, but is waiting on approval of some elements of the package by the Belgian and Czech governments, before it introduces new rules at midnight on Monday 20 June At the end of last week the Commission’s… – Continue reading
With just days remaining until Britain decides on its EU membership, the UK is at a crossroads. It has a historical choice to make, with various consequences attached to the decision on the 23rd of June on whether it becomes the first ever country to leave the EU. Those consequences… – Continue reading
Sydney-A new report by Oxfam said Australia’s federal government lost an estimated 5 billion US dollars in revenue in 2014 as a consequence of tax avoidance by multinational corporations with Australian operations. The non-governmental organization said in its report that investments from Australian-based big companies in tax havens globally grew… – Continue reading
Sinn Fein’s Matt Carthy has launched a stinging attack on Ireland’s corporate tax regime, arguing that Ireland’s reputation as an “enabler of massive tax avoidance for large corporations” is justified. Addressing the European Parliament in Strasbourg on Tuesday, the Midlands-North West MEP criticised the last government’s move to abolish the… – Continue reading
New U.S. Treasury regulations aimed at curbing tax inversions, where U.S. companies acquire foreign counterparts and headquarter abroad, seem to be working. But their broader goal – to keep American corporate capital at home – has failed. Consider the recent mergers-and-acquisitions activity. Chicago-based CF Industrial Holdings and Netherlands-based OCI called… – Continue reading
The EU’s Economic and Financial Affairs Council (ECOFIN) has been unable to reach agreement on the European Commission’s proposed anti tax avoidance directive. The issue has therefore been postponed until the next ECOFIN meeting in June. The European Commission announced its proposed anti-tax avoidance directive (ATAD) in January. The proposed… – Continue reading
BRUSSELS – EU state aid regulators aim to rule on Amazon’s (AMZN.O) tax deal with Luxembourg by July, two people familiar with the matter said on Thursday, and it may order the country’s tax authorities to recover about 400 million euros ($448 million) in back taxes. The European Commission’s decision… – Continue reading
The European Union, locked in a tax battle with the likes of Apple Inc. and McDonald’s Corp., laid down the law in its bid to rein in governments that woo multinationals with special fiscal deals allowing them to reduce their fiscal liability by booking profits abroad. The European Commission, which… – Continue reading
NEW YORK — U.S. multinational companies are saving $100 billion a year by shifting their profits overseas to lower their tax bills, according to a study released Tuesday that found that corporate tax-dodging is a bigger problem than previously estimated. Most U.S. companies pay far less than the country’s 35… – Continue reading
Tensions between the EU and the US over tax follow investigations into Apple in Ireland The US should be added to a new European blacklist of tax havens being drawn up by the European Commission, according to a report commissioned by the Green group in the European Parliament. The report,… – Continue reading
Bank of Ireland has lost a £27m (€34.2m) tax avoidance case in the UK after an attempt to exploit a loophole that did not exist. HM Revenue and Customs challenged the attempt to avoid corporation tax by Bank of Ireland through a subsidiary, the former building society Bristol and West,… – Continue reading
The Irish Revenue has issued a brief explaining how the implementation of a most favored nation clause in Ireland’s tax treaty with Estonia will affect the tax treatment of royalties. Ireland’s Double Tax Convention (DTC) with Estonia became effective in 1999. It contains a provision whereby the tax treatment of… – Continue reading
Unctad thinktank shows firms funnelled $221bn in 2015 through low-tax jurisdictions such as the Netherlands and tax havens in the Caribbean The UN has urged governments to stem the flow of funds to tax havens after companies funnelled $221bn (£152bn) into countries with low tax rates last year. The Netherlands… – Continue reading
Ireland’s tax treaties with poorer countries are some of the most restrictive in the world, limiting the taxing rights of those countries, an international NGO has claimed. Action Aid said that globally, tax treaties cost developing countries billions every year. In a report released yesterday, the body said it has… – Continue reading
Gibraltar, a tiny British territory at Europe’s southern tip, is famous for its geography — a huge limestone rock — that appears on the Prudential logo. It’s a global center for offshore banking, with the trappings of wealth to prove it: Luxury high-rises tower over super yachts in Gibraltar’s marina. The… – Continue reading
The U.S. Treasury Department is finalising new tax rules aimed at combating the use of shell companies to evade taxes, U.S. Treasury Secretary Jack Lew said on Saturday amid increased pledges by global finance leaders to cooperate on tax issues. In a statement to the International Monetary Fund’s steering committee,… – Continue reading
US President Barack Obama has warned that “tax avoidance is a big global problem” and urged Congress to take action to eliminate tax loopholes. “A lot of it is legal, but that’s exactly the problem,” he said. His comments come a day after the US Treasury Department announced fresh plans… – Continue reading
March 31 — Minnesota Sen. John Marty (DFL) introduced legislation that would require corporations headquartered in 46 tax havens to be subject to the same taxation as domestic companies. While it’s still early in the legislative session—the bill was introduced March 29—a spokeswoman for the Minnesota Chamber of Commerce told… – Continue reading
The number of multinational companies warning investors about the risk of higher taxes doubled in the past year, according to analysis by the Financial Times. Nearly a fifth of the US companies who warned on taxes were technology companies, the Financial Times found in a study of company filings. A… – Continue reading
Investors alerted to risks of higher payments as crackdown closes loopholes A global crackdown on tax avoidance has forced a surge of warnings by multinational companies that higher payments are set to hit their earnings. A Financial Times analysis of company filings revealed that more than twice the number of… – Continue reading
The Association of Tax Technicians (ATT) has expressed its disappointment that the UK Government intends to press ahead with plans to introduce a stamp duty land tax (SDLT) surcharge on purchases of second homes from April 1. Higher rates of SDLT will apply to purchases in England, Wales, and Northern… – Continue reading
Even as more large companies announce plans to take advantage of the inversion loophole to avoid taxes, Congress has refused to move on commonsense legislation that would put an end to inversions. Fortunately, as outlined in a new letter signed by Citizens for Tax Justice and 54 other groups, there… – Continue reading
Ireland recently announced it will introduce a formal advance pricing agreement (APA) programme this year. Ireland has accepted and concluded bilateral APAs for many years although there have been no formal procedures to initiate an APA in Ireland. However, in light of comments made by an Irish Revenue official at… – Continue reading
Ireland’s 12.5 percent corporate tax rate has encouraged several major U.S. companies like Medtronic, Pfizer, Johnson Controls, and Baxalta to move there in tax inversions in recent months, saving them billions of dollars of taxes and protecting themselves from international competition in the process. The U.S. corporate tax rate, on… – Continue reading
Summary The pace of change in international tax is dramatic. Each month brings new initiatives and developments at both national and supra-national levels. In this update, we focus on recent changes which are relevant to our clients. The OECD Base Erosion and Profit Shifting (“BEPS”) reports were finalised in October… – Continue reading
In their latest attempt to try to stamp out tax avoidance by multinationals in the European Union, lawmakers are set to question Apple, Google, IKEA and McDonald’s over their tax affairs as EU member states fail to agree a common tax policy. Lawmakers in the EU have struggled to prevent… – Continue reading
State lawmakers are getting into the act of demonizing corporate inversions even though there is not much they can do to stop them. Corporate inversions, in which U.S. companies merge with or are acquired by an overseas business, are a hot topic on the campaign trail and in the halls… – Continue reading
In the final session of the two day Global Tax Conference at Dublin Castle yesterday, a senior Canadian tax advisor used the analogy of children playing football to describe the relationship between multinationals and government when it comes to tax. In a kids football match, he said, when the ball… – Continue reading
The amount of tax multinational companies pay – and the amount they don’t pay – has become highly controversial, writes RTÉ’s Economics Correspondent Sean Whelan. This is mainly as a result of public outrage over legal tax avoidance schemes that big companies can use to shelter vast amounts of money… – Continue reading
Fortune 500 firms may be avoiding $695 billion in U.S. income taxes on $2.4 trillion held offshore. What do Bernie Sanders and Donald Trump have in common? Both seek an end to the use of offshore tax havens by corporate America. Bernie Sanders’ plan ends the ability of corporations to… – Continue reading
Offshore schemes operated by Swiss bank UBS and Germany’s Deutsche Bank in a bid to avoid paying income tax on bankers’ bonuses are not exempt from tax, the Supreme Court in London ruled Wednesday. British tax authorities, who brought the court action, said the schemes set up by the Swiss… – Continue reading
EU countries will exchange information on the tax affairs of multinational companies under new rules backed by EU finance ministers aimed at stopping big companies avoiding paying their fair share into government coffers. The rules, that should take effect later this year, are a response to growing concerns about corporate… – Continue reading
Governments around the world want more tax income. There is a widely held feeling that many international companies are basing themselves in places like Luxembourg, Ireland, and the Netherlands to avoid tax. The world’s largest countries have a plan and things will change. What will be the effect on Luxembourg,… – Continue reading
France is seeking €1.6 billion in back taxes from Google, criticised for its use of aggressive tax optimisation techniques, a source at the finance ministry has said. “As far as our country is concerned, back taxes concerning this company amount to €1.6bn,” the official, who spoke on condition of anonymity,… – Continue reading
A new report from ActionAid titled ‘Mistreated’ released this week has revealed that Zambia has 13 restrictive tax treaties that dramatically restrict the government’s power to tax global companies doing business on our soil and therefore unfairly limit our country’s potential to collect tax revenue. The report also found that… – Continue reading
Search giant Google – now a subsidy of Alphabet Inc. (NASDAQ:GOOG) – transferred around 11.7 billion euros ($13 billion) from its European operations to its accounts in Bermuda in 2014, in order to limit the tax burden on this income. This tax avoidance practice is often known as “Double Irish… – Continue reading
The decade-old arrangement allowed Alphabet to enjoy an effective tax rate of just 6 per cent on its non-US profits last year Google moved euro 10.7 billion euros ($12 billion) through the Netherlands to Bermuda in 2014, as part of a structure which allows it to earn most of its… – Continue reading
A quiet revolution is taking place across Europe. It isn’t playing out on the streets of capital cities or in the debating chambers of national parliaments. It has been slowly happening with every newspaper headline about how little corporation tax some companies pay relative to their size. It is also… – Continue reading
