How to Stop Canadian Multinationals from Dodging Their Taxes And if you thought low rates bought their loyalty, you’re wrong. Tax avoidance has become an accepted part of doing business for corporations the world over. But it isn’t just Google, Starbucks and Amazon working the system. Canadian corporations like Cameco… – Continue reading
The OECD is looking at closing tax loopholes which allow some companies to legally pay little or no tax. The proposed changes to the international tax regime must continue to allow a company to be incorporated in Ireland but not pay tax here if its tax home is covered by… – Continue reading
As reported in Clyde & Co’s 2011 article titled ‘Chinese charterers deducting taxes from hire payments’ (click here to view), foreign vessel owners engaged in business with Chinese charterers have long faced China’s Enterprise Income Tax regime (“EIT”). That regime looks set to extend further into the international transportation sector… – Continue reading
Watching big pharmaceutical companies and other major U.S. corporations line up to make foreign acquisitions that will bring them a low-tax haven as headquarters, a middle market CEO/owner/entrepreneur could easily become jealous. Are you feeling stuck with an effective tax rate of 25%, 30% or even 35%? For the likes… – Continue reading
The International Chamber of Commerce, in a policy statement on July 15, 2014, has advised countries not to adopt exit taxes, to ensure that double taxation is avoided and to promote the free movement of capital. In its statement, entitled “Exit taxes: Serious obstacles for international business restructurings and movements… – Continue reading
28 suspects of evading taxes on fruit and vegetable products are under questioning by prosecutors of the DIICOT. These include two officials from the National Agency for Fiscal Administration (NAFA). Prosecutors of the DIICOT Bucharest, along with officers from the Bucharest Organised Crime Squad, conducted 46 searches on Wednesday in… – Continue reading
NEW DELHI: India and the UK today expressed the determination to work together to tackle the menace of tax evasion even as Britain agreed to support infrastructure projects in the country. UK Export Finance will provide a line of credit of one billion pounds (about Rs 10,000 crore) for the… – Continue reading
Treasurer Joe Hockey has said that he will improve the structural integrity of Australia’s tax system to address international tax avoidance by multinational enterprises. In particular, the tax law will be tightened to prevent a multinational from shifting profits from Australia by claiming excess interest expense deductions. This tax avoidance technique is… – Continue reading
Mining company Glencore has denied reports that it has evaded taxes in Australia for the last three years in spite of earning A$15bn. The company said that it has paid A$8bn in royalties and taxes in the country over the last seven years. An earlier report by the Sunday Morning… – Continue reading
Andrea Bonzano, head of tax at Fiat, discusses the pros and cons of different transfer pricing methods in an interview with TPWeek, and provides his views on BEPS and US inversions. Bonzano has expressed his views on some of the most topical transfer pricing issues, discussing his concerns over BEPS… – Continue reading
Global mining giant Glencore Xstrata has rejected claims it has paid no tax on the $15 billion in income it has earned from coal mining in the last three years. The Swiss-based company, which is Australia’s largest coal producer, was accused of using a sophisticated profit shifting system that might… – Continue reading
Increasing sophistication in combatting base erosion and profit shifting, and the corresponding increase in transfer pricing documentation, have posed a challenge for businesses. The following article considers the tension between the competing demands. Companies are facing a proliferation of transfer pricing documentation demands. While the new requirements set out in… – Continue reading
WELLINGTON, June 23 (Bernama) — New Zealand tax officials are helping the Organisation for Economic Co-operation and Development (OECD) group of developed nations to deliver the first part of a plan to stop base erosion and profit shifting, Revenue Minister Todd McClay said Monday.The first seven “deliverables” of a 15-point… – Continue reading
In an era when many companies seek international solutions that in simpler times might have been openly labeled “tax evasion,” governments around the world are seeking to ensure they are not cheated of legally due taxes by what is now euphemistically called “profit shifting.” Apple Inc. (AAPL) has been keeping… – Continue reading
The Financial Times says today that 14 US tech & pharma groups, including Microsoft, Google and Johnson & Johnson, have cut their average tax rate by a quarter over the past eight years as they parked more cash offshore than all other US companies combined. Almost a half trillion dollars… – Continue reading
Apple Operations International, the principal Irish holding company for foreign subsidiaries, was not always stateless for tax purposes based on the last filed accounts in Ireland. It stopped paying tax in Ireland from 2006, based on US Senate Permanent Subcommittee on Investigations evidence. The most explosive revelation in the May… – Continue reading
Apple Operations International, the principal Irish holding company for foreign subsidiaries, was not always stateless for tax purposes based on the last filed accounts in Ireland. It stopped paying tax in Ireland from 2006, based on US Senate Permanent Subcommittee on Investigations evidence. The most explosive revelation in the May… – Continue reading
WASHINGTON (Reuters) – Cracking down on corporate tax avoidance sounds like a winner, and officials are working on it, but the practical challenges are formidable and they dominated discussion at an Organisation for Economic Co-operation and Development conference on Tuesday. The OECD, a Paris-based club of large economies, has an… – Continue reading
Prime Minister Tony Abbott has given the US notice that he is serious about leading global efforts through the Group of 20 to stop tax evasion through profit shifting by multinationals, which would include some of America’s biggest companies. Mr Abbott said international tax rules should be structured to capture… – Continue reading
The U.S. Internal Revenue Service and manufacturer Illinois Tool Works Inc. are battling in U.S. Tax Court over a $356.8 million dispute that highlights a type of cross-border tax avoidance strategy facing increased scrutiny worldwide. As governments crack down on tax-driven profit-shifting, the IRS is asserting that a loan used… – Continue reading
Having spent the past eighteen months claiming that Ireland does not facilitate international corporate tax avoidance despite overwhelming evidence to the contrary, the Irish Government has done a U-turn and has signalled that it is ready to prepare for the reality of reform. On Tuesday the Department of Finance published… – Continue reading
International tax policy changes being considered by the OECD could shave €1bn off Ireland’s annual multinational tax take, a Dáil Committee has heard. Addressing a joint sub-committee hearing on global taxation matters, yesterday, Brian Keegan — director of taxation at Chartered Accountants Ireland — said the OECD’s base erosion and… – Continue reading
European Union member states should adopt a common position on corporation tax in the current debate on changing global tax rules, according to a high level European Commission report on the digital economy. The report says that the OECD’s Base Erosion and Profit Shifting project (Beps), which is examining how… – Continue reading
Republican tax law writers in the U.S. Congress and multinational businesses on Monday said international talks aimed at preventing companies from moving profits to low-tax countries could hurt the United States. Representative Dave Camp and Senator Orrin Hatch of Utah warned of the effect on U.S. taxpayers from the Organisation… – Continue reading
It is a figure which Citizens for Tax Justice (CTJ), the US group which authored the report, says highlights Ireland’s popular use as a tax haven among US companies. Matt Gardner, executive director of the Institute on Taxation and Policy in Washington DC, tells IBTimes UK: “It’s a clear indicator… – Continue reading
International moves to shut down profit-shifting from high to low tax countries is starting to have an impact on Australian companies doing business offshore. A new EY report says these local companies are feeling the heat of a global trend of “increasingly aggressive” tax authorities. EY’s 2014 Tax Risk and… – Continue reading
THE Department of Finance has launched a public consultation on how Ireland’s tax system might respond to proposed international changes. The Organisation for Economic Cooperation and Development (OECD) is already conducting a public discussion around its Base Erosion and Profit shifting (BEPs) project, which could see tax avoidance loopholes shut… – Continue reading
The internet retail giant Amazon is facing fresh claims of tax avoidance after its latest accounts showed it routed more than £11 billion through its Luxembourg-based subsidiary in 2013 – yet paid only £4 million in UK corporation tax last year. Amazon trades through the Luxembourg subsidiary, Amazon EU SARL,… – Continue reading
Introduction Successive surveys of tax executives and senior finance professionals at multinational companies show that risks associated with transfer pricing have become the number one tax-related concern for businesses operating across several jurisdictions. Ernst and Young’s (EY’s) latest Global Transfer Pricing Survey shows that businesses are taking increasing heed of… – Continue reading
SLOVAK law-enforcement forces known as ‘tax cobra’ have uncovered a tax evasion case concerning the import of mineral oil from Poland, which cost the state at least €9.5 million, head of the Financial Directorate Frantisek Imrecze revealed at a press conference on June 2, as reported by the TASR newswire…. – Continue reading
India’s tax dispute with Vodafone Plc regarding its purchase of Hutch Essar seven years ago is likely to reach the International Court of Justice (ICJ) in the Hague, Netherlands a few weeks from now, sources privy to the matter said, adding this would be an unprecedented development in the history… – Continue reading
If any U.S. company seems ripe for moving to an island tax haven, it’s Chiquita. Based in Charlotte, the company’s sale of bananas, grown largely in Central America, accounts for two-thirds of its profits. But Chiquita isn’t bound for the tropics. It’s headed to Ireland, where the climate may be… – Continue reading
The Liechtenstein Government plans to set up a working group to closely monitor and recommend domestic tax policy responses to the Organisation for Economic Co-operation and Development’s (OECD’s) Base Erosion and Profit Shifting (BEPS) project. The Government anticipates that the OECD’s work will have a significant impact on the territory’s… – Continue reading
When Business Council of Australia chief Jennifer Westacott weighed in on plans for an Australian tax crackdown on multinationals last week, she warned the move could risk competitiveness and lead to companies being double taxed. Last year the Australian government passed new laws to prevent multinational companies shifting their profits to avoid the payment… – Continue reading
On 13 May 2014 the Ukrainian Parliament adopted draft Law of Ukraine No. 4527 On Amending the Tax Code of Ukraine Regarding Improvement of Transfer Pricing (“Bill”). The Bill eases liability of Ukrainian taxpayers for violating transfer pricing rules. In particular, the Bill provides for the following: 1. It extends… – Continue reading
Robert Stack, deputy assistant secretary for international tax affairs with the U.S. Treasury, gave an update on several items in the OECD’s project to combat base erosion and profit shifting at the American Bar Association Section of Taxation’s May meeting. As reported more fully by Transfer Pricing Report’s Kevin Bell, Stack,… – Continue reading
On April 1, the Senate Permanent Subcommittee on Investigations held another hearing on multinational corporations that actively reduce their worldwide tax burdens by shifting profits out of the U.S. Senators and witnesses disagreed as to whether the specific transactions that U.S. corporate taxpayers use to move income to entities outside… – Continue reading
Corporate Tax Avoidance: Last week the news that Apple is considering buying Beats Electronics, a maker of expensive headphones that was founded by record mogul Jimmy Iovine and rap artist Dr Dre, for $3.2bn, got a lot of media attention. Dr Dre must have pissed-off Apple when he bragged on… – Continue reading
Caterpillar, industrial and construction equipment manufacturing Goliath, has been avoiding or deferring paying U.S. taxes for at least 13 years to the tune of approximately $2.4 billion, according to a report from the Homeland Security & Government Affairs Permanent Subcommittee on Investigations. “Tax evasion schemes rob the system of billions of… – Continue reading
Finmin says it decided to propose withdrawal of conciliation offer after Vodafone said it could be resolved only through international arbitration The finance ministry on Monday said it had decided to propose withdrawal of its conciliation offer to Vodafone after the British telecom company said the transfer-pricing issue could be… – Continue reading
African countries are losing up to 12.7% of their national GDP due to shady practices in international trade. Global Financial Integrity, a Washington DC-based think-tank, reports that $542bn (£321bn) worth of capital was lost from Africa in illicit capital flows and estimates that almost 80% of this coming through “trade… – Continue reading
Oil major Cairn India and its former British parent Cairn Energy Plc have moved the Delhi High Court challenging the validity of New Delhi’s controversial 2012 retrospective amendment to law that imposed tax liabilities on several high-profile offshore transactions of Indian assets including Cairn’s. The court will take up the… – Continue reading
There’s a little rumpus building up in my native UK over the coffee chain, Caffe Nero. The argument is that it seems to be making a nice operating profit but not actually paying any corporation tax. There’s also a bit of offshore thrown in here and therefore, undoubtedly, there’s something… – Continue reading
Telecom major Vodafone‘s international arbitration notice in its Rs 24,000-crore tax dispute with the government came after the income tax department decided to withdraw its conciliation offer in the matter without waiting for a tribunal’s decision in the transfer pricing case. Officials said the tax department had prepared a Cabinet note to withdraw conciliation on… – Continue reading
After years of failing efforts to spur the economy through spending and tax hikes, the developed countries tightened their belts against the perceived flaws in the international tax rules. These countries, which earlier supported globalisation, soon echoed the cries, of the developing countries, stemming from Base Erosion and Profit Shifting… – Continue reading
When it comes to tax, things are not always what they seem to be, as the recent news of Starbucks and Amazon shows. In a world where multinational corporations shift taxable profits to favourable jurisdictions, and sovereign nations use tax rates to improve their global competitiveness, things are not always… – Continue reading
Transfer pricing has received a great deal of bad press recently, but it is a useful tool for international businesses, says Lucas Bastin TRANSFER PRICING is the phenomenon by which related corporate entities in different jurisdictions determine the price at which a transfer of goods or services between them should be… – Continue reading
By Nduka Nwosu and Steve Omanufeme in Washington DC Nigeria and other African countries have asked the Bretton Woods institutions, the World Bank and the International Monetary Fund (IMF), to help them arrest the intractable problem of illicit financial outflows from the continent. The Coordinating Minister for the Economy (CME)… – Continue reading
OECD BEPS Project: If new international corporate tax rules take effect from 2016, at least €50bn or half the annual value of services exports will be vapourised. Nevertheless, Ireland should support reform to a) protect the 12.5% corporation tax rate that will continue to give the country an advantage in… – Continue reading
NEW YORK (TheStreet) — The Securities and Exchange Commission is serious about going afterApple’s (AAPL_) off-shore cash. In a letter of comment to Apple’s in-house counsel, SEC accounting branch chief Kathleen Collins challenged the company’s aggressive accounting policies. Apple has about $16 billion of offshore cash exempt from taxation by the Internal… – Continue reading
