There has been a lot of uncertainty with regard to withholding taxes imposed by the South African Revenue Service (SARS) on cross-border payments made by South Africans to offshore recipients, and the ambiguous administrative and compliance procedures relating thereto. Based on the information available directly from SARS, any amounts received… – Continue reading
It has never been easier for Americans to start businesses while living outside the U.S. If you are an American entrepreneur operating abroad, however, be aware of U.S. tax reporting obligations on non-U.S. businesses operated by Americans and make sure you are leveraging the value of U.S qualified retirement accounts… – Continue reading
Law360, New York (April 06, 2015, 3:10 PM ET) — A draft report released Friday by the Organization for Economic Cooperation and Development on strengthening controlled foreign-company rules to crack down on tax evasion said there are substantial disagreements among member states about how to best define CFC income. The… – Continue reading
National tax laws are struggling to keep pace with the rise of the digital economy and the progress of multinational companies. These factors leave gaps that are susceptible to misuse and lead to cases of double non-taxation, which undermine the integrity and fairness of tax systems around the world. The… – Continue reading
Russia’s Finance Minister, Anton Siluanov, announced that the deadline to report on CFCs will be postponed from 1 April to 15 June 2015. As such, failing to file before 15 June 2015 will not result in any penalties. Submissions of notifications on participation in CFCs must have actual information as… – Continue reading
Russia’s Parliament, the Duma, has approved a draft law to allow taxpayers to regularize previously undeclared assets held offshore. The Russian Government said on March 27, 2015, that the law, “On the Voluntary Declaration of Property and Bank Accounts (Deposits) by Individuals,” will allow taxpayers to repatriate assets taken out… – Continue reading
U.S. Court of Appeals Rejects IRS Attempt to Apply Closing Agreement Retroactively to Support an Unrelated Proposed Adjustment to Tax SUMMARY From 2003 to 2006, U.S. corporations were entitled, in certain circumstances, to elect a one-time dividends-received deduction for dividends from controlled foreign corporations. BMC Software, Inc. made this election… – Continue reading
Transactional work varies from jurisdiction-to-jurisdiction with the ebb and flow of various economic cycles, but a prevailing theme across the EMEA region has been that more and more advisory firms are urging taxpayers to prepare for the impact of the OECD’s base erosion and profit shifting (BEPS) action plan. Joe… – Continue reading
New Zealand has a broad-based tax system consisting principally of: income tax fringe benefit tax resident and non-resident withholding tax (RWT and NRWT) goods and services tax (GST) Accident Compensation levies import tariffs and miscellaneous excise duties, and local authority rates on property. Stamp duty, gift duty and death duties… – Continue reading
Introduction In the autumn statement the Chancellor of the Exchequer announced the introduction of a new Diverted Profits Tax (DPT). Against the context of international co-operation in the OECD led consultation on ways to ensure profits are taxed where they are generated (the Base Erosion and Profit Shifting project (BEPS),… – Continue reading
On December 2, 2014, the State Administration of Taxation (SAT), China’s highest tax authority, issued the Administrative Measures for the General Anti-Avoidance Rules (Trial) (GAAR), which went into effect on February 1, 2015. Prior to this legislation, China had no specific GAAR, only a few general anti-avoidance principles in various… – Continue reading
On February 25, South Africa’s Minister of Finance, Nhlanhla Nene, presented a 2015 Budget that was said to be constrained by a slowing economy and lower-than-expected tax revenues. Nene indicated that the Government now has to rebalance its fiscal policy to reduce the “structural gap” that exists between spending on… – Continue reading
Amid global efforts to combat profit shifting. PRETORIA – In line with international efforts to combat tax avoidance, National Treasury on Wednesday said it is taking further steps to curb financial leakage. With government under pressure to collect more revenue amidst dwindling economic growth, Finance Minister Nhlanhla Nene on Wednesday… – Continue reading
Within the framework of the BEPS (Base Erosion and Profit Shifting) action plan, adopted in July 2013, on last September 16, the OECD published its first recommendations in the form of reports on 7 of the 15 points of the action plan: Address the tax challenges of the digital economy… – Continue reading
As the Organisation for Economic Co-operation and Development (OECD) passes the halfway point in its joint project with the G20 to address base erosion and profit shifting (BEPS) concerns, it is worth pausing to examine what the consequences of some of the proposed changes may be. Much of the focus… – Continue reading
“These measures were taken in line with the policy announced by President Vladimir Putin for the Russian economy’s de-offshorization,” USM Holdings owned by billionaire Alisher Usmanov said MOSCOW, December 19. /TASS/. USM Holdings owned by billionaire Alisher Usmanov is transferring key assets to Russian holding companies, USM said in a… – Continue reading
IN TAX, the latest global buzzword is “BEPS” or base erosion and profit shifting. BEPS refers to the practice of multinational corporations (MNCs) of shifting profits from high tax jurisdictions to low tax jurisdictions as a tax mitigation strategy. In February 2013, the Organization for Economic Co-operation and Development (OECD)… – Continue reading
While the dust is still settling from the mid-term elections and the pundits are trying to figure out what it all means, the American people have made their collective voices heard and delivered a message that they do not like the country’s direction. Exit polling data from Election Day showed… – Continue reading
The Financial Accountability and Corporate Transparency (FACT) Coalition is calling on Congress to reject the tax extenders package that includes two wasteful offshore loopholes that allow U.S. companies to dodge billions worth of taxes. The tax extenders are a set of 54 temporary tax breaks, which are ostensibly designed to… – Continue reading
On November 18, 2014, the Lower House of Russia’s Parliament, the State Duma, approved at second and third readings Bill No. 630365-6, which would introduce a new controlled foreign corporation (CFC) regime in the country. The new CFC regime contained in the Bill has an anti-offshore orientation and would give… – Continue reading
MOSCOW, Nov. 25 (Xinhua) — Russian entrepreneurs must report to tax authorities about their ownership of shares in the off- shore jurisdictions, according to the law signed by President Vladimir Putin on Tuesday. The new law introduces an amendment to the Russian Tax Code that will force Russian owners of… – Continue reading
The law introduces amendments to the country’s tax code that will oblige Russian owners of companies registered in offshore tax havens to pay taxes in Russia MOSCOW, November 25. /TASS/. Russian President Vladimir Putin signed on Tuesday a new tax law intended to return Russian capital and assets from foreign… – Continue reading
Transfer pricing can be identified as an area of tax law that continues to attract the attention of both tax authorities and businesses worldwide. The growing importance of transfer pricing can be observed in the Slovak Republic as well, as it has become one of the dominant tax issues addressed… – Continue reading
The UK’s Public Accounts Committee (PAC) has criticized what it says has been “unacceptably slow” action from HM Revenue and Customs (HMRC) against tax avoidance and has recommended that the Department be more transparent about its compliance yield estimates. In a new report, PAC said tax revenues are being placed… – Continue reading
MOSCOW, November 19. /TASS/. The Federation Council, the upper house of Russia’s parliament, approved a new tax law on Wednesday as part of President Vladimir Putin’s “deoffshorization” initiative designed to return Russian capital and assets from foreign jurisdictions. The law introduces amendments to the country’s tax code that will oblige… – Continue reading
MPs have attacked the taxman for being too slow to crack down on controversial avoidance schemes used by celebrities and other high earners, resulting in millions of pounds being lost to the public purse. As much as £10 million may never be recoverable because of delays by Her Majesty’s Revenue… – Continue reading
The European Union’s 28 member states are seeking agreement on the proposed introduction of a common anti-abuse clause in the Parent-Subsidy Directive (2011/96/EU). The plans were discussed at a meeting of the EU’s Economic and Financial Affairs Council (ECOFIN) on November 7, 2014. The proposed anti-abuse clause would allow member… – Continue reading
In March 2014 the Russian Ministry of Finance published a draft anti-offshore law which is currently submitted for consideration by The State Duma (parliament) with the decision expected to be made by the end of 2014. Russia is aiming to clamp down on the use of foreign offshore tax shelters… – Continue reading
Subsidiary funds companies within Irish multinational, says spokesman RH did not feature in the leaked files, but accounts for one of its Luxembourg subsidiaries show it had multibillion-euro intra-group loans going in and out of the state. Photograph: Brenda Fitzsimons Ireland’s largest indigenous multinational, building materials group CRH, has a… – Continue reading
The National Tax Service (NTS) said Thursday that it will help foreign companies in Korea reduce potential tax uncertainty regarding their cross-border transactions with parent firms. From 2015, the NTS will allow foreign firms that earn less than 50 billion won ($46 million) a year in sales to focus on… – Continue reading
Tax avoidance, or the use of legal arrangements to reduce tax, is rife. According to the Australian Tax Office (ATO), Australian companies in 2012 sent almost A$60 billion to related parties in tax havens. Singapore and Ireland topped the list of countries where businesses send their money. A recent report… – Continue reading
An overhaul of the Grand Duchy’s corporate tax law and administration is required Occupying a damp 1,000 square miles where the French, German and Belgian borders meet, the Grand Duchy of Luxembourg is a far cry from the palm-fringed tropical island tax haven of popular imagination. In fact the country… – Continue reading
The taxation of a person is based on two principles: Source and Residence. A person for tax purposes includes an individual, trust, company, partnership and any form of business arrangement one chooses to take on. It should be noted that with globalisation, there is a constant mix of these two… – Continue reading
Ireland’s role in Apple’s affairs means the sums involved are material to Ireland Ireland has done extraordinarily well at attracting foreign direct investment, and the politicians and public servants involved must be hoping that when the current fuss over global tax competition subsides, that will continue to be the case…. – Continue reading
Hopes are rising that multinational companies operating in New Zealand may soon be paying a fairer share of tax. The French official leading the global clampdown on multinational tax rorts says the scrapping of the notorious “double Irish” tax loophole shows aggressive tax planning is on the way out. Organisation… – Continue reading
(Reuters) – Russia’s government has approved a new tax law to clamp down on Russian companies and individuals using offshore tax shelters. The law is part of a range of measures initiated by President Vladimir Putin, and collectively known as “deoffshorisation”, which are aimed at bringing Russian businesses and money… – Continue reading
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
On 29 July 2014, the China State Administration of Taxation (SAT) released an internal notice to the China tax authorities at the provincial levels, in the name of “Notice on Antiavoidance Investigation against Large Amount Outbound Payments” (Circular Shui Zong Ban Fa [2014] No. 146, Notice 146), urging a nationwide… – Continue reading
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
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
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
Vodafone has emerged victorious against the Indian taxman in the latest bout of litigation between the two. The important point for the rest of us being what it tells us about those endless claims of tax avoidance and tax evasion by large companies. It’s not just that large amounts of… – Continue reading
Eight of the top 200 companies publicly listed on the Australian stock exchange (ASX200) paid no taxes on profits averaging $50 million to more than half a billion dollars over the decade to 2013! More than 20 (10 percent) corporations paid an average tax rate of five percent or less…. – Continue reading
The Italian tax authorities have been intensifying their focus on transfer prices involving financial intercompany transactions such as loans. Multinational corporations frequently resort to such transactions to optimise and rationalise the financial management of the entire group. In certain cases, the said optimisation tools pertaining to intercompany financial resources may… – Continue reading
The reputation of Italian family businesses will escape unscathed despite news of yet another high-profile family being hit by allegations of tax avoidance, according to a family business academic. This week, family-owned Prada announced that its two chief executives, Miuccia Prada and Patrizio Bertelli, are under investigation for inconsistent tax… – Continue reading
Troubled Italian fashion giant Prada stonewalled questions over its tax affairs on Monday after it emerged that its top two executives are being investigated for allegedly not disclosing many millions in overseas earnings to Italian authorities. Chinese fashion titans look to Italy for value (29 Sep 14) Global fashion circus… – Continue reading
eBay accused of tax avoidance, but insists it complies with letter of the law By Emma Woollacott, Sep 29, 2014Updated: September 30, 2014 7:24 AM Online auction site eBay got away with paying just £620,000 in tax on sales of over £1.3 billion last year, its latest accounts reveal. The… – Continue reading
George Osborne, the Chancellor of the Exchequer over here in the UK, has just announced at the Conservative party conference that he’ll be changing the tax laws to make sure that Google GOOGL +0.16% and other tech multinationals (Facebook, Microsoft MSFT -0.17%, possibly Apple AAPL +0.64%, among them) end up… – Continue reading
The European Commission’s crackdown on the deal between Irish tax authorities and Apple Inc. marks an expansion in the growing global war on tax avoidance by multinational companies. Governments that enable it are now a target. Tuesday, the European Commission said the Irish tax authorities failed to conform to international… – Continue reading
Troubled Italian fashion giant Prada stonewalled questions over its tax affairs on Monday after it emerged that its top two executives are being investigated for allegedly not disclosing many millions in overseas earnings to Italian authorities. Chinese fashion titans look to Italy for value (29 Sep 14) Global fashion circus… – Continue reading
