On October 14, 2014, the Irish Minister for Finance released proposals as part of the 2015 Irish Budget that would cause Irish incorporated non-resident (“INR”) companies to be treated as tax resident in Ireland beginning January 1, 2015. The goal is to shut down the use of so-called “Double Irish”… – Continue reading
Council leader Jo Lovelock laid down a motion at a meeting on Tuesday saying “aggressive corporate tax avoidance schemes are unfair, unjust and morally wrong” Big name brands like Vodafone, Starbucks, Apple and Facebook were bandied around the council chamber as companies the council did not want to do business… – Continue reading
Plan ‘is to reduce the risk that owners will outlive their retirement funds’ The Finance Bill has changed the tax rules in relation to Approved Retirement Funds (ARFs), the structures into which many people move their defined contribution pensions on retirement. In 2011, the Government increased the “imputed or notional… – Continue reading
Move intended to make Ireland more attractive to firms wanting to bring key decision makers The Government is to relax the rules governing a special tax incentive scheme to attract foreign executives into Ireland after just 31 individuals availed of the scheme last year. The move, contained in the Finance… – Continue reading
The European Union Court of Justice (CJEU), Europe’s highest court in matters of EU law, ruled against the Italian government in a dispute related to the Italian taxation on gambling. According to the CJEU, Italy’s tax legislation operates in conflict with Article 52 and Article 56 of the Treaty on… – Continue reading
Measures to ensure people who are not on social welfare or paying tax get relief on water charges will be brought forward at the committee stage of the Finance Bill, the Finance Minister has said. This follows controversy when it emerged that thousands of people would not be able to… – Continue reading
“The issue of substance and taxation is, and always will be, a core column of the Irish taxation system,” Michael Noonan, Ireland’s Finance Minister, said at his Department’s Tax Policy Conference on October 21, 2014, underscoring that Ireland’s strategy is to play fair but play to win. Beginning by discussing… – Continue reading
Christine Milne says Australian Securities and Investments Commission should target ‘smaller enterprise’ exemption Facebook Australia has not lodged annual accounts since 2009 because it says it is a smaller enterprise and exempt from having to file. Photograph: Jonathan Nackstrand/AFP/Getty Images The Greens are calling on the Australian financial services watchdog… – Continue reading
23/10/14 – After a comprehensive review in October 2012, the OECD Working Group on Bribery asked France, through a series of concrete recommendations, to intensify its actions to fight the bribery of foreign public officials and undertake important reforms. In October 2014, the Working Group welcomed several significant reforms, including:… – Continue reading
Irish Finance Bill 2014: Last Sunday The New York Times in an editorial following the decision in Budget 2015 to eliminate the Double Irish tax dodge from 2021, said “Ireland, which for years used policies like the Double Irish to attract multinational businesses, appears uninterested in true reform. It will… – Continue reading
Business Standard October 23, 2014 Last Updated at 23:20 IST The Bombay High Court recently in the case of Vodafone India Services Private Limited (Vodafone) held that the foreign direct investment (FDI) received by the Indian company in the form of share capital cannot be taxed in India under the… – Continue reading
The number of companies lobbying the U.S. government on tax inversions more than doubled in the quarter ended Sept. 30, as they sought to prevent Congress and the Obama administration from imposing new restrictions. Novartis AG (NOVN), SAP SE, and Eaton Corp Plc (ETN) were among companies that began lobbying… – Continue reading
By insisting, as he did yesterday, that other countries can follow Ireland’s lead in closing corporate tax loopholes, Michael Noonan risks being seen to over-egg the pudding. The Finance Minister rightly shut the door on the so-called ‘Double Irish’ tax loophole favoured by multi-national corporations last week in the Budget…. – Continue reading
Corporate tax “inversion” deals became a prime target this year of President Barack Obama, as part of his running theme that many U.S. corporations are stealing from Americans by not paying their fair share. After the August announcement of Burger King’s plans to merge with Canada-based Tim Hortons, the administration… – Continue reading
LUXEMBOURG — On the first floor of a rust-colored building near the main railway station, Marius Kohl spent years engineering this country’s most valuable export: tax relief. As head of a federal agency called Societes 6, Mr. Kohl approved thousands of tax arrangements for multinational corporations, sometimes helping them save… – Continue reading
The “blanket assumption” of tax avoidance that HM Revenue & Customs makes when it approaches Personal Service Companies has been left in tatters by its own research. Stephen Herring, head of tax at the Institute of Directors, revealed this tendency of HMRC to regard PSCs as “automatic evidence of some… – Continue reading
Democratic House and Senate candidates seem likely to lose the votes of a large constituency they rarely think about over a law that most Americans have never heard of. The issue is FATCA — the Foreign Account Tax Compliance Act — passed by Congress and signed into law in 2010…. – Continue reading
The Organisation for Economic Cooperation and Development (OECD) has recommended a number of direct tax reforms to build on the French Government’s efforts to improve the nation’s competitiveness in Europe. The report points out that the tax wedge (the cumulative burden of taxes on workers) in France is among the… – Continue reading
For now, while the benefit for American corporations to buy or merge and move overseas may be over, as evidenced by AbbVie cancelling its merger with Shire Pharmaceutical, that doesn’t mean that consolidation within the industry is through. A new research report from Merrill Lynch features three top companies, dubbed… – Continue reading
BERN/NEW DELHI: To comply with global norms, Switzerland today began consultation process for unilaterally amending bilateral tax treaties to allow exchange of information when there is a request from another country. Amid rising international pressure, including from India, Switzerland has been taking steps to share tax information as well as… – Continue reading
The lower house of Parliament has approved legislation that allows the exchange of information about banking accounts with other countries. The bill is a prerequisite for the implementation of the FATCA agreement with the United States which will require Czech financial institutions to inform US authorities about account owned by… – Continue reading
On October 15th, 2014 the Minister for Finance announced the Luxembourg Budget 2015. The announcement followed the presentation made the day before by the Prime Minister Xavier Bettel who presented a policy statement entitled “Package for the Future” which provides some overall public finances policy statements for the period 2015… – Continue reading
A new survey by E&Y released at its 33rd Annual International Tax Conference, titled “Connecting the dots” uncovered the issues of navigating multiple challenges, led by increased scrutiny and the effects of the Organisation for Economic Co-operation and Development’s (OECD) base erosion and profit shifting (BEPS) project. “Tax directors need… – Continue reading
Mark Davies is not happy that accidents are going to cost you as much as intentions Recently, the government issued a consultation document on new legislation to extend HM Revenue & Customs’ powers of retribution for undeclared income and gains hidden offshore. It believes that offshore tax evasion is difficult… – Continue reading
High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Email ftsales.support@ft.com to buy additional rights. http://www.ft.com/cms/s/0/dd154b40-5866-11e4-a31b-00144feab7de.html#ixzz3GxohXLDx ig, bad companies are firmly in the sights of politicians. Last week UK Labour… – Continue reading
Madhya Pradesh : Chief Minister Shri Shivraj Singh Chouhan has directed for strict action in cases of tax evasion. He said that a scheme should be chalked out to reward people giving tip-off regarding tax evasion. Shri Chouhan was reviewing fiscal management of the state here today. Finance Minister Shri… – Continue reading
There may some benefits to the closed-down loopholes Unbearable pressure was exerted on this State by our neighbours in Europe to take action unilaterally to close down corporate tax avoidance loopholes such as the Double Irish, upon which time was called in last week’s budget. The pressure and the Irish… – Continue reading
Around 33,000 Britons are likely to receive letters from the taxman telling them they owe the government, on average, £155,000 as the HMRC starts cracking down on tax avoidance in line with new powers granted under the Finance Act 2014. According to law firm Winckworth Sherwood, the first batch of… – Continue reading
There is a common misunderstanding in the charity world that tax avoidance, and its ugly sister – tax abuse, cannot be regarded as applying to charities except where charities are ‘hijacked’ to line the pockets of wealthy ostensible donors. But that is simply not the case. A charity which seeks… – Continue reading
As Indian tax authorities have been slapping foreign firms with billions of dollars in unexpected tax bills, hundreds of global companies are now negotiating with the taxman here to clarify ahead of time what they will owe in the future, hoping to avoid surprises. In the past five years there… – Continue reading
Senate Finance Committee Chairman Ron Wyden has indicated that, as companies appear to be reconsidering inversions following the administrative measures put forward by the Treasury Department last month, he is focused on reforming the US tax code, rather than pressing for immediate anti-inversion legislation. “While it looks like the rush… – Continue reading
AbbVie Inc. (ABBV) and Shire Plc agreed to terminate what would have been the biggest U.S. tax inversion after AbbVie pulled its support for the deal in the wake of proposed changes to U.S. rules governing such transactions. AbbVie, based in North Chicago, Illinois, planned to buy Shire for an… – Continue reading
Lump sum taxation, the tailor-made measure tax regime designed to attract wealthy foreigners to Switzerland, is facing a crucial test as voters head to the polls on November 30 to decide whether or not to abolish the system for good. Proponents of the initiative say lump sum taxation is unfair… – Continue reading
Bombay High Court holds that shares issued at a premium by a resident entity to a non-resident entity is a capital account transaction and does not give rise to any income; Income arising from an International Transaction between AEs must satisfy the test of ‘income; as provided under the ITA… – Continue reading
Climate Change Law Practice Group Blog, Environmental, Energy and Resources Law The BC Government tabled Bill 6, the Liquefied Natural Gas Income Tax Act, on October 2, 2014. Bill 6 sets out the features of the new LNG tax regime. The LNG taxation proposals have been the subject of great… – Continue reading
On 16 October, the Saeima (Parliament), in its final reading, passed the “Public Persons Enterprises and Capital Shares Governance Law” in order to promote more effective governance of companies owned by the state and local governments. The Secretary-General of the Organisation for Economic Cooperation and Development (OECD), Angel Gurría, has… – Continue reading
European Union finance ministers have reached a breakthrough agreement that will make it more difficult for tax cheats to hide their money. The new legislation, which had been blocked for years by countries with a reputation as tax havens, was approved last week after Luxembourg and Austria agreed to lift… – Continue reading
On July 15th 2014, the OECD published its 2014 update of the Model Tax Convention (“2014 OECD Update”). This update is the outcome of the work accomplished between 2010 and the end of 2013. It does not however take into account the OECD conclusions of the “Action Plan on Base… – Continue reading
The revenue implications for South Africa of ‘base erosion and profit shifting’ by corporate taxpayers are firmly in the crosshairs of the Davis Tax Committee (DTC) and Judge Dennis Davis hinted on Monday that recommendations were being considered to “detect and deter” tax-avoiding financial flows. Speaking at a G20 study… – Continue reading
The Council agreed last tuesday, at a meeting of the Economic and Financial Affairs Council , on a draft directive extending the scope for the mandatory automatic exchange of information between tax administrations, enabling them to better combat tax evasion and to improve the efficiency of tax collection. The proposal… – Continue reading
Representation of foreign individuals who wish to purchase US residential property should include careful attention to the manner in which the income and gain from the property will be taxed in addition to the other aspects of ownership. In addition, it is important to be aware of the manner in… – Continue reading
Devolving further tax powers to Scotland would be “more complex than many might anticipate”, Scotland’s accountancy body has said. The Institute of Chartered Accountants of Scotland (ICAS) highlighted factors such as tax competition within the UK and the need to reduce tax avoidance. A commission is considering proposals for more… – Continue reading
In recent years, the United States has increased initiatives to counter tax evasion committed by U.S. persons who are not reporting and paying U.S. income tax on earnings derived from foreign financial assets. The Foreign Account Tax Compliance Act (“FATCA”) represents the latest major initiative in this regard, having been… – Continue reading
PANAMA CITY – Panama and Colombia said they will talk uninterruptedly to resolve a dispute that erupted after Bogota included the Central American nation on its list of tax havens. Panama’s vice president and foreign minister, Isabel De Saint Malo de Alvarado, and Colombia’s foreign minister, María Angela Holguín, delivered… – Continue reading
The tax gap has increased to £34bn in the past year according to the latest figure from HM Revenue and Customs (HMRC), but Baker Tilly’s George Bull has said that HMRC are nonetheless “winning the battle” against tax avoidance. The tax gap in the UK jumped from 6.6% in 2011-12… – Continue reading
Senate Finance Chairman Ron Wyden (D-Ore.) said Friday that he hopes to build on the pharmaceutical company AbbVie’s move away from a tax inversion. AbbVie’s board advised shareholders to vote against the proposed merger with the Irish competitor Shire, which Wyden said showed the company saw “the strategic business value… – Continue reading
17/10/2014 – Full implementation of the structural reforms adopted and announced in France would boost potential annual economic growth by one third, or 0.4 percentage points per year over ten years, according to the OECD. In a report entitled Structural reforms in France: Impact on growth and options for the… – Continue reading
Our Reaction The Irish Minister for Finance delivered his Budget 2015 (the “Budget”) speech this week. There was considerable domestic and international anticipation in advance of the Budget against a backdrop of significant recovery in the Irish economy and also international focus (including, in particular, under the OECD BEPS project)… – Continue reading
High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Emailftsales.support@ft.com to buy additional rights. Trustees of private family trusts are being urged to register with the US tax… – Continue reading
The reservation or grant of certain powers by settlors has always been possible under Bermuda’s trust law but, historically, there was some uncertainty about exactly how far settlors could go without calling the validity of the trust structure into question. The recently passed Trusts (Special Provisions) Amendment Act 2014 (TAA… – Continue reading
