Category: Base Erosion & Profit Shifting

Apple to IBM hoard $206b abroad to avoid US tax

The largest US-based companies added $206 billion to their stockpiles of offshore profits last year, parking earnings in low-tax countries until Congress gives them a reason not to. The multinational companies have accumulated $1.95 trillion outside the US, up 11.8 per cent from a year earlier, according to securities filings… – Continue reading

TAX FREE | US tech giants’ offshore cash piles earn interest from government: report

LONDON — Four of the biggest U.S. technology groups collectively hold an estimated $124 billion in U.S. Treasury debt, much of it offshore, earning them tax-free interest, the UK’s Bureau of Investigative Journalism (BIJ) said on Thursday. The finding means Apple Inc, Microsoft Corp, Google Inc and Cisco Systems Inc… – Continue reading

Documents reveal Kurchenko’s alleged tax evasion schemes

The young Ukrainian ex-billionaire Serhiy Kurchenko, now widely suspected of being a front man for overthrown President Viktor Yanukovych’s family, clearly liked offshore destinations. His companies registered in offshore zones are now accused of trading in oil products using a tax evasion scheme that cost Ukraine’s government an estimated $1… – Continue reading

Apple, IBM and Microsoft Lead U.S. Tax-Avoiding Spree

Apple Inc., IBM Corp. and Microsoft Corp. have been picked out as some of the main culprits of stockpiling profits abroad in order to avoid huge tax bills, according to Bloomberg. Last year, the largest U.S. firms collectively added an extra $206 billion to their offshore profit stockpiles based in low-tax countries. Together the… – Continue reading

United Kingdom: The OECD Base Erosion And Profit Shifting Action Plan

There has been considerable publicity in recent months on the alleged tax avoidance perpetrated by multinationals that has resulted in the Organisation of Economic Cooperation and Development (OECD) publishing its action plan on base erosion and profit shifting (BEPS). The action plan, consisting of 15 proposals to counter the perceived… – Continue reading

Corporate tax avoidance ‘scheme’ hurting Canada, expert says

Country’s corporate tax rate sits at about 25 per cent As Canadians dutifully file personal income tax returns during the coming weeks, consider this: many profitable companies pay little or no tax. In an interview this week on The Sunday Edition, Dennis Howlett, executive director of Canadians for Tax Fairness,… – Continue reading

Finance ministry seeks early disposal of Vodafone transfer pricing case

NEW DELHI: The finance ministry will soon write to British telecom major Vodafone to press the company to seek an early decision from the Income-tax Appellate Tribunal (ITAT) in the Rs 8,500-crore transfer pricing case. The Union Cabinet had, on February 28, directed the finance ministry to wait for the… – Continue reading

Apple iTax: made in Ireland, designed in the US

Apple, famous for its innovative products, is equally creative in its tax structure. From 2009 to 2012, it successfully sheltered US$44 billion from being taxed anywhere in the world, including sales generated in Australia. While there are probably some sound reasons for Apple’s CEO, Tim Cook, to claim in a US congressional… – Continue reading

Brazil tries to grasp online cross-border taxation

The Brazilian government has been trying to catch up on a number of areas of the digital economy, one of them being online cross-border taxation – but not without controversy. During the Mobile World Congress (MWC) last month, the Brazilian communications minister Paulo Bernardo said Brazil is a “tax haven”… – Continue reading

Canada: Businesses Face More Onerous Transfer Pricing Documentation And Country-By-Country Tax Reporting

The OECD proposes to reform transfer pricing documentation for multinational enterprises and to impose onerous country-by-country (CbC) reporting obligations, including disclosure of taxes paid in each country in which a business operates, in a bid to enhance revenue authorities’ abilities to identify high risk transfer pricing situations and to make… – Continue reading

Hunting Lost Revenue in Offshore Tax Havens

Some states are going after multinational corporations which avoid state taxes by stashing some of their earnings in offshore tax havens, an effort aimed at recouping some of the more than $20 billion states lose to such gimmicks each year. Shifting income to subsidiaries in places like the Cayman Islands… – Continue reading

How to Get Your Profits Out of China

BEIJING – Wholly Foreign Owned Enterprises (WFOEs) are able to repatriate funds out of China in a variety of forms, for which tax implications vary according to the form of repatriation used and the Double Taxation Agreement (DTA) in place between China and the recipient country. The four most commonly… – Continue reading

Africa: Tackling Illicit Outflows

As far back as the early stages of the global financial crisis in 2007, Nick Mathiason citing the African Union (AU) reported: “More than $150 billion a year is looted from Africa through tax avoidance by giant corporations and capital flight using ‘a pinstripe infrastructure’ of Western banks, lawyers and accountants.”… – Continue reading

Aligning tax with the times

The aggressive approach of Indian tax authorities on transfer pricing and international tax matters underlines the government’s intention of taking strong action to defend its tax base. When it comes to taxation of cross-border transactions, India’s inclination to widen the source-based tax rules is clearly demonstrated by the retrospective amendments,… – Continue reading

Australia’s Tax Office Is Targeting 86 Multinationals Over Profit-Shifting

In an attempt to stop multinationals shifting profits overseas Australia’s Tax Office is launching a task force to investigate 86 large corporations’ tax activities. The tax office is looking into companies that use complex structures to move profits through tax havens as well as those that are using thin capitalisation,… – Continue reading

New Discussion Launched on Tax Treaty Abuse

PARIS – The OECD is initiating an international discussion into measures to prevent the occurrence of profits shifting and tax evasion through the abuse and misuse of international tax treaties. Late last week the Organization for Economic Cooperation and Development released a public discussion draft “Preventing the Granting Of Treaty Benefits In… – Continue reading

Tax Evasion Threatens Africa’s Socio- Economic Transformation: UN Expert

The quest of African countries to carry out economic stability and transformation is threatened by illicit financial outflows through tax evasion and avoidance, a UN expert observed here on Thursday. He said the draining of tax revenues and scarce foreign exchange resources stifled growth and socio-economic development and weakened governance…. – Continue reading

Australia’s new transfer pricing laws overlap the thin cap rules: new challenges for taxpayers

The overlap of Australia’s new transfer pricing laws with the thin capitalization rules is causing challenges and likely duplication of analysis for taxpayers – particularly for the arm’s length amount-of-debt test. Australia legislated comprehensive new transfer pricing laws in 2012[i] and 2013.[ii]  These laws were passed in two installments: Subdivision 815-A, dealing with… – Continue reading

G20 gives Google, Microsoft, Apple et al tax deadline

G20 finance ministers speak loudly, mention big stick The world’s top 20 finance ministers have signalled once again that they’re sick of their taxes disappearing offshore and have signalled a strong intention to get their cash back. The ministers in question are all members of the Group of Twenty (G20)… – Continue reading

Ortega’s Zara Fashions Tax Avoidance by Shifting Profits to Alps

Zara’s celebrity chic helps make its Spanish parent company, Inditex SA, the world’s biggest fashion retailer. Singer Taylor Swift, reality-television personality Kim Kardashian and Kate Middleton, Prince William’s wife, have all been spotted wearing the stylish, low-cost brand. Another reason for Inditex’s industry-best profit margins of almost 15 percent: the… – Continue reading

Multinationals unfazed by G20 tax crackdown

The G20 finance ministers have once again agreed to cooperate to counter aggressive cross-border tax avoidance by multinationals. Many US firms are using tax avoidance schemes for their non-US earnings while they shamelessly claim they are paying appropriate taxes in the source countries in which they operate. The OECD responded to earlier… – Continue reading

G20 to tackle transfer pricing with new tax exchange scheme

The days of multinational companies being able to use the Double Irish Dutch Sandwich to avoid taxation may soon be coming to an end, with the G20 group of nations looking to create a reporting standard to allow for automatic exchange of tax information. In the official communique coming at the end… – Continue reading

Tony Abbott must achieve ‘concrete results’ or risk losing G20 influence, says Wayne Swan

Former treasurer Wayne Swan has warned that Australia risks losing global influence unless this year’s G20 summit achieves concrete results on issues such as multinational tax avoidance. Ahead of this weekend’s meeting of G20 finance ministers and central bankers in Sydney, Mr Swan also urged the Abbott government not to… – Continue reading

Murdoch’s $880m tax win raises issues of global corporations’ tax liability

An $880 million payout to Rupert Murdoch’s News Corporation has reignited the debate over whether global companies pay their fair share of tax in Australia. News was paid the money after winning a long-running legal battle with the Tax Office relating to a 1989 restructure of the media empire involving… – Continue reading

A Solution for Corporate Tax Avoidance

Some three hundred years ago Sir Walter Scott asked, “Breathes there a man with soul so dead who never to himself hath said, This is my own, my native land.” Well, in America corporations are legally deemed  “persons,” so the answer to Scott’s question is “Yes,” at least when it… – Continue reading

Why world governments may not sign up to the plan against tax avoidance

Multinational tax avoidance in the digital economy has become a hot political topic with public reports of companies such as Google, Apple and Starbucks not paying a “fair share” of tax. The G20 group of rich economies has commissioned the Organisation for Economic Co-operation and Development to tackle corporate profit… – Continue reading

Vodafone’s £1bn Indian tax bill row: peace talks about to break down

India’s finance ministry is preparing to seek the cabinet’s approval to withdraw conciliation proceedings with the UK telecoms firm. Vodafone, the world’s second-largest mobile operator by subscribers, entered India in 2007 by acquiring Hutchison Whampoa’s mobile phone assets. It is contesting a tax bill of about 112bn rupees (£1.1bn) relating… – Continue reading

HMRC now targeting mid-tier firms in its transfer pricing investigations, says expert

HM Revenue and Customs (HMRC) collected more tax from smaller businesses than large multinationals last year as a result of its investigations into firms’ transfer pricing arrangements, according to figures obtained by Pinsent Masons, the law firm behind Out-Law.com. Corporate tax expert Heather Self of Pinsent Masons said that HMRC… – Continue reading

Yahoo’s Irish move may be start of Swiss corporate exodus

Yahoo! Inc is shifting its main European tax base to Ireland from Switzerland, a Reuters examination of company statements and accounts shows, as pressure mounts on the Alpine nation to abolish some corporate tax incentives. The internet search group said the shift reflected a streamlining of its European operations and… – Continue reading