Apple has sold $12billion in bonds as part of another scheme to lower its tax bill. The tech giant got itself further into debt even though it has $215billion in the bank, more than the US Treasury. California-based Apple sold the bonds under a complicated scheme which is reportedly designed… – Continue reading
In the aftermath of the latest global financial crises, government have sought to recoup lost revenue through tax reform. This has put the spotlight on the issue of gaps in the current international taxation system that created opportunities for Base Erosion and Profit Shifting (BEPS) schemes. Simply put, BEPS are… – Continue reading
ST. GEORGE — The Internal Revenue Service has announced that avoiding taxes by hiding money or assets in unreported offshore accounts remains on its annual list of tax scams known as the “Dirty Dozen.” “Our continued enforcement actions should discourage anyone from trying to illegally hide money and income offshore,”… – Continue reading
Pinsent Masons has accused HM Revenue & Customs (HMRC) of hypocrisy over its recent approach to tax planning and avoidance. Fiona Fernie, a partner at the law firm, said many of the government department’s investigations of late had been politically motivated, “concentrating on the best soundbites for ministers”. Tax avoidance… – Continue reading
Pfizer, one of the largest multinational pharmaceutical companies in the world, recently announced plans to merge with Allegran, Plc, a pharmaceutical company based in Ireland. The new merged corporation, worth a total of $160 billion, will move its headquarters to Dublin, Ireland to avoid the U.S. government’s “double taxation” of… – Continue reading
Over the last two decades, an increasing number of companies have set up subsidiaries in offshore financial centres. So why don’t they move the entire business, and establish headquarters there too? While it seems prestigious—and tax-savvy—to be based in the Cayman Islands or Luxembourg, companies that choose to do so… – Continue reading
EU finance ministers will attempt to reach agreement by March on a directive requiring EU-wide country-by-country reporting for large multinationals and by July on a directive requiring EU states to adopt six anti-tax avoidance measures for corporations, Jeroen Dijsselbloem Dutch finance minister and president of the Eurogroup announced at an… – Continue reading
Proposals to repeal inventory and watercraft taxes or alter their credits have resurfaced a year after similar proposals were squelched following an outcry from industry and local government officials. The taxes that contribute a combined $85 million to Lafourche and Terrebonne government agencies are caught up in the battle of… – Continue reading
(Special) – If you’re planning on leaving Canada soon, don’t give up on contributing to your Registered Retirement Savings Plan (RRSP). If you become a non-resident of Canada, you can still contribute to an RRSP provided you still have accumulated contribution room available. “Your contribution room is determined by your… – Continue reading
The Government recently introduced into the Legislative Council a bill to provide a legal framework for the implementation of automatic exchange of financial account information in tax matters (“AEOI”). This would have significant implications both for financial institutions and, in a cosmopolitan city like Hong Kong, for many of their… – Continue reading
The Chancellor has been pressed to take “urgent action” and cut the headline rate of tax for the struggling North Sea oil industry in his Budget next month. Deputy First Minister John Swinney has written to George Osborne highlighting the “substantial challenges” the sector is facing amid plummeting prices, and… – Continue reading
MANILA, Philippines – Corporations may soon be subject to a transfer pricing audit, a new type of tax audit, from the Bureau of Internal Revenue (BIR). Transfer pricing is used to describe inter-company pricing arrangements relating to transactions between related entities. These can include transfers of intellectual property, tangible goods,… – Continue reading
The Irish Revenue has launched a new webpage that contains guidance on what it considers to be tax avoidance and information on the legislative tools available to detect and tackle avoidance arrangements. Revenue said its policy is “to challenge tax avoidance schemes and [the] unintended use of the legislation which… – Continue reading
Malta’s Minister of Finance, Edward Scicluna, has expressed disappointment that the proposed EU Anti-Tax Avoidance Directive was not accompanied by an impact assessment for member states. Speaking at the ECOFIN meeting of EU Finance Ministers in Brussels, he said that such an impact assessment is necessary, including to measure the… – Continue reading
In almost every field of legal work, privacy is regarded as a primary and legitimate concern to protect the interests of individuals and organisations. This was confirmed recently when the European Court of Justice (ECJ) struck down the US-EU data exchange agreement amid fears that data transferred to the US… – Continue reading
Similar trade agreements have been used to facilitate apparent tax avoidance in the past A controversial new trade deal between the EU and the United States could make it more difficult to fight tax avoidance, a new report has warned. TTIP, the Transatlantic Trade and Investment Partnership, is expected to… – Continue reading
On February 15, 2016 the President of the Russian Federation signed Federal Law No. 32-FZ on Amendments to Parts One and Two of the Russian Federation Tax Code (Regarding Taxation of Profits of Controlled Foreign Corporations and Income of Foreign Entities) (the “Law”). The Law introduces a number of amendments… – Continue reading
Where the United States leads on legislation, foreign jurisdictions slavishly follow Hongkongers will need to declare all their assets abroad by 2025. No, the government has not announced the policy yet. But academics have noticed a trend which strongly suggests Hong Kong will follow the US example in foreign tax… – Continue reading
The 2016 Singapore Transfer Pricing Guidelines on related-party loans The Inland Revenue Authority of Singapore published the 3rd edition of its Transfer Pricing Guidelines on the second working day of the New Year. In this new edition, the IRAS’ expectations concerning related-party loans have been slightly elaborated. The guidelines now… – Continue reading
The push for a tax amnesty has attracted a fair amount of criticism and even rebuke from analysts, the International Monetary Fund, the Organization for Economic Cooperation and Development (OECD), the World Bank and even the Corruption Eradication Commission (KPK). Yustinus Prastowo, a respectable tax analyst, went so far as… – Continue reading
In line with international developments, the Italian Government has been focusing on fighting tax evasion and avoidance in recent years. Studies and in-depth analyses on evasion and aggressive avoidance, conducted under the OECD BEPS project, which was delivered in October 2015, have led to the issuing of a series of… – Continue reading
Let me give you a heads up: First, I’m going to tell you some things that will make you ill. Then I’m going to present a cure. It will make you feel better—until, of course, you realize that knowing the cure brings us as close to implementing it as buying an… – Continue reading
A while back in Germany, I was driving on the straight as an arrow B-1. That is Bundesstrasse, the equivalent of a U.S. highway, a notch below the Autobahn. Roads tend to curve around farmers’ fields, having been there first. The B-1 from Cologne on the Rhine toward Berlin was… – Continue reading
A 30% tax bracket. A rise in the standard rate, with a rebate for lower earners. Higher taxes all round to finance more spending. In Scotland, ahead of May’s elections for the devolved parliament, a fascinating debate on tax and spending is under way, with the main parties setting out… – Continue reading
Action Plan 15 of the Organisation for Economic Co-operation and Development’s (OECD’s) Base Erosion Profit Shifting (BEPS) Project discusses the desirability and technical feasibility of a multilateral instrument to implement the treaty-related measures in the other BEPS Action Plans (discussed in previous articles in this column). Action Plan 15 proposes… – Continue reading
Rules should require foreign owners of prime London homes to come clean about beneficiary owners, say anti-corruption groups Large parts of London’s Baker Street, including the Beatles store, are owned by offshore trusts. New laws that aim to stop the UK being a magnet for money launderers – by forcing… – Continue reading
EU countries may have lost out on more than €1 billion in tax revenues between 2009 and 2014 due to aggressive tax strategies by furniture giantIkea, a new report has claimed. The report, commissioned by the Green/EFA group in the European Parliament into the tax affairs of the private company,… – Continue reading
If the apparent demise of the Coalition’s push to increase the GST shows anything, it’s that Australians are unwilling to accept tax reform unless it is obviously fair. It is right to think that rich people should pay more tax than the poor. Happiness studies show an extra dollar means… – Continue reading
If Swiss banking secrecy laws gave Switzerland the world banking capital status, Monaco’s residence policy gives its realtors a thriving business. What is common between the Canadian Raonic who lost in the Australian Open semifinals and the Serbian Djokovic who won it? Well, they are both residents of Monaco, and… – Continue reading
The Belarusian Tax and Duties Ministry will step up efforts to legalize revenues from international online trade in 2016, BelTA learned from Belarusian First Deputy Tax and Duties Minister Igor Klepcha during a press conference on 12 February. “We will greatly step up efforts to move revenues from international digital… – Continue reading
Google’s top global tax executive told U.K. lawmakers that a new U.K. tax provision dubbed “the Google Tax” will not actually apply to the U.S. technology giant. The law, officially the Diverted Profits Tax, was introduced last year amid concerns that Google parent Alphabet Inc. and other global tech companies… – Continue reading
The Australian Treasury on February 11 opened a consultation on whether Australia should adopt into law final OECD/G20 base erosion profit shifting (BEPS) transfer pricing recommendations. The goverment seeks feedback on the adoption of the BEPS report, Alleging Transfer Pricing Outcomes with Value Creation, which has been approved by G20… – Continue reading
Earlier this week the State Department released its latest statistics for people who have renounced their US citizenship. 2015 was another record year, with 4,279 people divorcing themselves from the US government and heading to greener pastures elsewhere. This was the third year in a row that broke the previous… – Continue reading
Non-competition agreements can be a valuable tool for purchasers who want to protect their investments in new businesses. However, non-competition agreements can have unintended and unexpected tax consequences, particularly to sellers who grant non-competition agreements to purchasers. The Income Tax Act (Canada) (the Act) contains specific provisions regarding the taxation… – Continue reading
China has one of the most archaic corporate tax systems in the world, from which the new value-added tax structure was supposed to provide much-needed relief. China’s tax complexity and inconsistent enforcement has become an efficiency drain on China’s own economy and a roadblock to foreign companies wishing to set… – Continue reading
As if the mental harassment of delayed delivery of a house is not bad enough, you could also be losing 85% of the tax benefit on your home loan, for no fault of yours. A tax deduction of Rs 2 lakh per year is allowed against payment of interest on… – Continue reading
In tax law, the concept of residency is used to determine tax liability based on whether there is a sufficient connection between an individual or legally recognized entity and a jurisdiction such that the jurisdiction is justified in taxing such individual or legally recognized entity on their worldwide income. Generally,… – Continue reading
Amid ongoing debate in the UK on “corporate tax deals,” the British Chamber of Commerce has said the UK needs to comprehensively simplify business tax rules and eliminate loopholes that are exploited in aggressive tax avoidance schemes. On February 11, on the same day the Public Accounts Committee took evidence… – Continue reading
OECD’s head of tax policy says protectionist measures by national governments had to be avoided The risk of protectionist tax measures being taken by national governments has abated as a result of the OECD’s Base Erosion and Profit Shifting (Beps) project, a key official has told a conference in Dublin…. – Continue reading
As many as 300 “Google-style” tax deals are under investigation across the European Union , it has been claimed. All 28 EU states are said to be involved in scrutinising a number of agreements struck by countries and multi-national corporations as part of a wider inquiry into unfair tax competition… – Continue reading
Australian Treasurer Scott Morrison says overseas companies selling digital products to Australians will not be able to avoid paying the GST. The so-called Netflix Tax that would see overseas-based businesses selling digital products to Australians collect 10 percent GST has entered the House of Representatives. Introduced by Treasurer Scott Morrison,… – Continue reading
Taxing decisions With highly efficient labour markets, a solid institutional environment and a strong banking system, Canada has long been considered one of the most competitive nations in the world. In fact, in its most recent rankings in 2014, Bloomberg declared Canada the second best country in the world for… – Continue reading
Cash rewards for dobbing in multinational tax cheats and greater protection for whistleblowers are being considered by the Turnbull government to reduce tax avoidance. In the US, whistleblowers who have provided information that lead authorities to tax cheats have received a cut of the billions of dollars recouped. Assistant Treasurer… – Continue reading
The Eastern Caribbean Central Bank (ECCB) is seeking to expedite the signing of Intergovernmental Agreements (IGA) that will prevent the loss of correspondent banking relationships (CBR) for commercial banks in the Eastern Caribbean Currency Union (ECCU). Towards this end, Governor of the ECCB, Timothy NJ Antoine sought the assistance of… – Continue reading
Voluntary Disclosure & CRA Annual Report to Parliament – General Information CRA has provided the latest statistics about the tax amnesty or voluntary disclosure program (VDP) for the previous fiscal year. CRA provides an annual report to parliament that provides a wealth of information about its activities over the past… – Continue reading
Multinational companies operating in Europe will have to publicly disclose their earnings and the tax paid in each European country if new measures being proposed by the European Commission come into force, The Guardian has reported. The Commission will propose new legislation in April that makes profit and tax information… – Continue reading
Kenya enacted a new law targeting units of foreign companies that escape remitting most of their domestic taxes by allocating income to tax havens while attributing expenses to the East African nation, a practice known as transfer pricing. The Tax Procedures Act gives the Kenya Revenue Authority powers to investigate… – Continue reading
Former Standard Chartered chief says eliminating €500, $100, SFr1,000 and £50 notes would prevent corrupt payments Governments should consider scrapping high denomination banknotes to combat financial crime and tax evasion, including paying tradespeople in cash, a former bank boss has said. Criminals move more than $2tn (£1.4tn) around the world… – Continue reading
When Tim Cook and his two senior Apple colleagues were questioned by a US Senate sub-committee back in May 2013, the headlines generated in the world’s business press were unsettling. Some lawmakers repeatedly characterised Ireland as a tax haven, saying behemoth Apple channelled billions of dollars of global revenues generated… – Continue reading
Journalist Steve Topple investigates Bermuda-based big business tax avoidance and its links with UK political parties – and even some charities LAST WEEK saw the news emerge that everyone’s favourite search engine, Google, only had to pay £97m in back-tax (not the “major success” of £130m as was first reported)… – Continue reading
