Category: Regulatory

Spain’s Tax Breaks, TD Bank, Ex-UBS Banker: Compliance

The European Union expanded its crackdown on illegal tax breaks, ordering Spain to recover money from companies that benefited from rules encouraging merger activity outside of the country. The European Commission said the Spanish measures unfairly rewarded companies for buying stakes in foreign competitors. Telefonica SA (TEF) last year lost… – Continue reading

PM: Romania wants to become full-fledged OECD member

Romania wants to become a full-fledged member of the Organization for Economic Co-operation and Development (OECD), according to Romanian officials, Prime Minister Victor Ponta and Foreign Affairs Minister Titus Corlățean. The message has been sent to – and received by –the OECD secretary general William Danvers, who was on a… – Continue reading

Ministers reassuring key foreign firms on closure of ‘Double Irish’

Budget measures including new foreign direct investment incentives discussed State agencies and Government Ministers and officials have launched a co-ordinated campaign of letters and phone calls to senior executives of foreign multinationals, to reassure them that Ireland remains a top destination for investment following the budget, Minister for Enterprise Richard… – Continue reading

Nigeria: Transfer Pricing Africa (Part II)

n this second part of our overview of current transfer pricing regulations on the African continent, we focus on relevant provisions in, amongst others, Ghana, Nigeria and Uganda. The Ghanaian Transfer Pricing Regulations, 2012 (L.I.2188) (the Ghanaian Regulations) were introduced by the Ghana Revenue Authority (GRA) on 27 July 2012,… – Continue reading

Why Apple And Google Won’t Care About Irish Tax Law Changes

Ireland has this week moved to change its tax law, closing the “double Irish” tax avoidance technique widely used by multinational enterprises including Google and Microsoft. Picture: Getty Images In very broad terms, the current Irish tax law allows a company incorporated in Ireland to be a tax resident of… – Continue reading

Private equity owners of Game Group used tax havens for payments

The private equity owners of video games retailer Game used tax havens in the two years they owned it, accounts have revealed. US buyout group Elliott Advisors snapped up Game Group after it collapsed into administration in 2012. It set up Game Digital in April 2012 in a deal masterminded… – Continue reading

Commission’s Tax Drive Unsettles Multinationals

Europe’s antitrust regulator is encroaching on what has been the preserve of national governments. There’s a new tax sheriff in town. Europe’s top antitrust regulator, the Brussels-based European Commission, has launched an unexpected assault on what it suspects are sweetheart tax deals for multinational companies, plowing into an area traditionally… – Continue reading

Profit shifting report false – Lonmin

A report claiming Lonmin is engaging in two transfer pricing arrangements is misleading and false, the company said on Thursday. It was responding to a report titled “The Bermuda connection: Profit shifting and unaffordability at Lonmin 1999-2012″, released by the Alternative Information and Development Centre (AIDC) on Thursday morning. “Lonmin… – Continue reading

Strong rules on transfer pricing on agenda in many countries

AMONG several proposals for tax reform, the director-general of the Revenue Department has said the agency would propose an amendment to the Revenue Code concerning transfer pricing, aiming to provide greater clarity on the determination of fair transfer prices. The director-general has indicated that in past years many multinational companies,… – Continue reading

IRS Modifies Offshore Filing Procedures

The IRS has issued FAQs relating to the new streamlined procedures for offshore compliance, and for Delinquent International Information Return Submission Procedures. The FAQs for the streamlined program provide more detailed guidance on how the 5% penalty will be computed, how 100% owners of an incorporated business will be treated,… – Continue reading

What Does Closing the ‘Double Irish’ Tax Loophole Mean for Pharma?

As the Irish government considers closing an infamous tax loophole for corporations, Wall Street has been scrambling to gauge the effect on the pharmaceutical industry. So far, the prognosis seems that damage will largely be minimal. Known as the ‘Double Irish,’ the loophole allows companies to send royalty payments for… – Continue reading

Bringing back black money: Swiss promise India details in time-bound manner

erne/New Delhi: In a major breakthrough in India’s fight against black money allegedly stashed abroad, Switzerland today said it will examine Indian requests for banking information on a priority basis and provide requested details in a time-bound manner. The Swiss authorities would also “assist in obtaining confirmation on genuineness of… – Continue reading

OECD targets diesel and company cars

Taxes on fuel and corporate benefit need to rise significantly, says agency The Organisation for Economic Co-operation and Development (OECD) has launched a war of words on diesel fuel and company cars, claiming that the taxation levels on both are costing governments billions and seriously harming the environment. “The cost… – Continue reading

Fourth protocol to Canada-UK Treaty eliminates withholding tax on arm’s length interest, but preserves tax exemption for gains on disposition of shares and interests deriving value from Canadian real property

On July 21, 2014, the governments of Canada and the United Kingdom signed the fourth protocol (Protocol) amending the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading

Isle of Man: Crypto-Currencies And The Isle Of Man

The Isle of Man is showing great enthusiasm for crypto-currencies – from the landlord at a popular Douglas drinking hole to the Lieutenant Governor, everyone is talking about digital currency and the potentially huge benefits to the Island. The Isle of Man Financial Supervision Commission (FSC) has announced plans to… – Continue reading

Harper Government Strengthens Tax Collaboration with India

Minister Findlay meets with Indian counterpart during trade mission to India DELHI, INDIA–(Marketwired – Oct. 15, 2014) – Canada Revenue Agency The Honourable Kerry-Lynne D. Findlay, P.C., Q.C., M.P., Minister of National Revenue, met today with Nirmala Sitharaman, India’s Minister of State for Commerce and Industry and Minister of State… – Continue reading

3rd LD Writethru: EU FinMins agree on taxation information exchange

LUXEMBOURG, Oct. 14 (Xinhua) — EU finance minister meeting concluded on Tuesday with breakthrough in taxation exchange information to fight against tax avoidance. Italian finance minister Pietro Carlo Padoan, whose country holds the presidency of the EU, told press after the meeting that the EU has planned to build a… – Continue reading

Tokyo District Court Allows Tax Saving from Share Repurchase

On May 9, 2014, the Tokyo District Court reversed a large tax that had been imposed on a large U.S. multinational’s Japanese holding company (“Japan HoldCo”). Under the Japanese Corporate Tax Law, if a shareholder returns shares to an issuing company (i.e., the issuing company acquires treasury shares), a portion… – Continue reading

Freeman Tax Law Is The Keynote Speaker About FATCA At The American Chamber Of Commerce In Shanghai

The presentation on October 17, 2014 will discuss how FATCA has changed the world and provide perspectives for financial institutions and expatriates  SHANGHAI, China, Oct. 14, 2014 (GLOBE NEWSWIRE) — via PRWEB – As of June 30, 2014 China has signed Model 1 IGA (Intergovernmental Agreement) in cooperation with FATCA… – Continue reading

Malta Holding Companies 2014/15

Malta, like Cyprus, has been obliged to dismantle its old ‘offshore’ companies regime as a trade-off for joining the European Union. EU membership has, however, brought about certain benefits for Maltese companies trading across borders, and, coupled with investment-friendly government policies and some interesting tax planning opportunities, Malta remains one… – Continue reading

Firms Expect Transfer Pricing Policy Impact From BEPS Project

A vast majority of companies headquartered in the United States expect increased scrutiny of their transfer pricing practices in the short-term as a result of the Organisation for Economic Cooperation and Development’s (OECD’s) base erosion and profit shifting (BEPS) project. A recent EY survey, Connecting The Dots, concluded that 30… – Continue reading

Monaco Signs OECD Multilateral Tax Convention

Monaco has become the 84th jurisdiction to commit to strengthen international tax cooperation through its participation in the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. Welcoming the signing by José Badia, Monaco’s Minister for Foreign Affairs and Cooperation, the Organisation for Economic Cooperation and Development’s (OECD’s) Secretary-General, Angel… – Continue reading

International tax avoidance: Is it eroding Canada’s tax base and how should we respond?

TORONTO , Oct. 2, 2014 /CNW/ – Aggressive international corporate tax avoidance by multinational corporations has become the subject of intense political scrutiny. U.S. politicians have called out some American multinationals, including Apple, Amazon, Starbucks and Google, for relocating profits abroad to avoid U.S. taxes. More recently, politicians accused Burger… – Continue reading

Can the EU tame the multi-national tax dodgers? Why Europe wants to turn the screw on the big guns

The screw is being turned on American companies that use complex structures to whittle down their tax bills. But is the latest EU probe a paper tiger or a game changer? It was supposed to be good news. Amazon’s announcement yesterday that it would hire 1,000 staff was dressed up… – Continue reading

UPDATE 3-Ireland calls time on austerity, “Double Irish” tax dodge

* Ireland to end tax regime that saved multinationals billions * Swift upturn ushers in tax cuts rather than austerity * Government faces backlash over uneven nature of recovery (Adds finance minister interview, Google comment) By Padraic Halpin and Conor Humphries DUBLIN, Oct 14 (Reuters) – Ireland will phase out… – Continue reading

Alleged mastermind of UBS tax evasion scheme faces trial

(Reuters) – Former UBS bank executive Raoul Weil was the mastermind of the Swiss bank’s illegal offshore operations that helped thousands of Americans evade taxes, prosecutors said at the start of his federal trial on Tuesday. Weil, 54, was the third-highest ranked executive at the Zurich-based wealth management firm and… – Continue reading

After years of pressure, Luxembourg drops bank secrecy rules

(Reuters) – Luxembourg agreed on Tuesday to end its bank secrecy rules from 2017, yielding to a decade of pressure from Germany and the United States and marking a breakthrough in global efforts to reduce tax evasion. Luxembourg, whose banks hold deposits worth 10 times the nation’s annual economic output,… – Continue reading

Swiss pledge to review business taxation

The Swiss finance minister, Eveline Widmer-Schlumpf, and her counterparts from European Union member states have signed a joint statement aimed at ending a controversy over corporate taxes. The declaration, signed in Luxembourg on Tuesday, includes the Swiss government’s plans to push ahead with abolishing certain preferential tax regimes for foreign… – Continue reading

Tax relief scheme for tech firms under threat from Europe

Hitech firms are being warned that they should take advantage of tax relief on patent related profits now before a threatened clamp down by the European Union according to Richard Hopes, Partner at Alliotts accountants based in Surrey and London. Richard Hopes, Partner at Alliotts accountants and a specialist in… – Continue reading

The Big Picture: Wealth and Estate Planning in Argentina

It is said that Argentina faces an economic and political crisis every 10 years. Whenever a crisis arises, Argentinians’ right of ownership is at risk. Devaluation, asymmetric pesification and the current foreign exchange restrictions are a few examples of the challenges we face. What’s more, according to a recent OECD… – Continue reading