Category: Activity

Apple Inc. (AAPL), Alphabet Inc (GOOG) Agree on This Strategy

Data from the Organization for Economic Cooperation and Development shows that at 39%, the U.S. has the highest corporate tax rate among the 20 most developed economies. Yet, the average rate of taxation imposed on the 100 biggest S&P corporations was 28.4% in 2014. Apple and Alphabet paid even lower… – Continue reading

After Blow to Europe Tax Havens, Some Promise More Staying Power

Luxembourg and the Netherlands lost a bit of luster as tax havens for some of the world’s biggest companies this week, as the European Union fired its latest salvo aimed at multinational tax dodging. Yet the Netherlands is on pace to maintain its attractiveness as a tax-friendly address for multinationals,… – Continue reading

Asset Managers To Take Centrestage In Business: PwC Report

Foretelling significant changes in tax structures around the world, newly released PricewaterhouseCooper (PwC) report reveals that the future of businesses is dependent on how well their asset managers deal with this emergent tax risk. Titled, ‘Asset Management 2020 and beyond: Transforming your business for a new global tax world’, the… – Continue reading

Offshore Yuan Rises on Stability Bets as Xi Pushes Global Usage

The yuan rose the most in almost a week in offshore trading on speculation Chinese authorities will prevent depreciation as President Xi Jinping promotes the currency’s use in global trade and finance during a trip to the U.K. this week. The People’s Bank of China sold debt overseas for the… – Continue reading

Markets retain early gains amid a range bound trade

Indian equity markets retaining their early gains were trading in a range in early noon session, on value buying activities by market-participants. Sentiment got boost with the statement of finance ministry that the country will grow by 7.5 per cent in the current fiscal, slightly higher than international rating agency… – Continue reading

Tunisia: Belhassen Trabelsi Has Diverted Millions of Dinars Through Offshore and Shell Companies

Tunis, — The process of returning Tunisian property and assets frozen in a number of foreign banks in general and in Switzerland, in particular, has not moved an inch. More than four years have elapsed since the fall of former President Ben Ali without any hope of progress on the… – Continue reading

Apple Stakes Raised as EU Orders Starbucks, Fiat Tax Repayments

Apple Inc. and Amazon.com Inc. got a preview of what the European Union may have in store for them after regulators ordered Starbucks Corp. and a Fiat Chrysler Automobiles NV unit to repay millions of euros in back taxes. The EU said the coffee company and the Italian carmaker were… – Continue reading

Mandatory disclosure rules: OECD releases final paper on BEPS 12

What has happened? On 5 October 2015 the OECD issued its final paper on BEPS Action 12 Mandatory Disclosure Rules, Action 12 – 2015 Final Report (Paper). In this Alert we highlight the main issues and recommendations for taxation reform raised in the Paper. The Australian Treasurer’s BEPS Press Release… – Continue reading

EU: “TAX RULINGS” IN LUXEMBOURG, NETHERLANDS DEEMED ILLEGAL STATE AID

The European Commission today announced a decision that Luxembourg and the Netherlands granted selective tax advantages to two multinational corporate entities, and as such, these “tax advantages” are illegal under EU state aid rules. The EC concluded that the tax rulings granted by the tax authorities in Luxembourg and in… – Continue reading

OECD crack down on corporate tax shelters is a risky double edged sword

Companies who have been accused of shifting profits to low-tax jurisdictions or those seeking tax shelters need to beware—these practices are coming under fire, and could possibly come to an end. The Organization for Economic Cooperation and Development (OECD) just released details of their far-reaching plan that would require companies… – Continue reading

Illicit flows worry ZRA

Zambia Revenue Authority-ZRA- Commissioner General Berlin Msiska says Africa needs to work together to address illegal Financial Flows. Mr Msiska says international cooperation is required because illegal financial flows affect all regions of the continent. He says African Tax administrations can achieve a more effective and efficient relationship through initiatives… – Continue reading

Cayman Islands: CRS On The Cayman Islands

“He hath founded it upon the seas…” Psalm 24:2 From an ancient decree The motto on the Cayman Islands flag has profound meaning for all residents, whether indigenous or not. At 3:00am on 7 February 1794 the Royal Navy Frigate HMS Convert and its convoy of nine merchant ships were… – Continue reading

Revealed: How foreign buyers have bought £100bn of London property in six years

Wealthy investors have snapped up at least £100 billion of property across London using overseas companies in the past six years, new figures reveal today. Official data seen by the Standard shows that since 2008 there have been 27,989 purchases of homes, buildings and land in the capital by shadowy… – Continue reading

TP Disputes Trends Report 2015

Since 2002, there has been a steep escalation in transfer pricing disputes in the country, the ‘Taxsutra’s TP Trends Report’, is a perfect compendium which encompasses this escalation. The Chapter under which Transfer Pricing provisions were introduced was with the intent to ensure that there is no avoidance of tax…. – Continue reading

Financial product peddler ordered to desist and refrain

On June 16 of this year, the California Department of Business Oversight issued a desist and refrain order to Encinitas’s Lawrence (Larry) Freeman and two of his many now-defunct companies, Yeshilkoy Insurance Services and Structured Marketing. In peddling financial products, Freeman made “an untrue statement of material fact to investors,”… – Continue reading

Ireland reveals Budget and international tax strategy

Ireland’s budget statement for 2016 (Budget) was delivered by the Minister for Finance last week. The Budget’s primary focus was on personal tax matters, which is somewhat unsurprising given the general election early next year. However, the Budget also contained two key announcements on Ireland’s corporation tax system.  In line… – Continue reading

KRA reaches out to former employees

Major tax administration reforms are expected after Kenya Revenue Authority (KRA) Commissioner General John Njiraini was made to cut short the release of quarter one performance on Monday following a call from State House. KRA has already moved to deepen its capacity by inviting former employees to boost its capacity… – Continue reading

Carl Icahn Forms Super PAC Aimed At Tax Reform

Carl Icahn, the iconic activist investor, has shifted, if only for today, his cross-hairs of contempt from the boardrooms of corporate America to the nation’s capital. Icahn sends members of Congress a word of warning Wednesday saw Carl Icahn warn several members of Congress a letter laying out his plans… – Continue reading

Fiat Chrysler reiterates did not receive state aid

“FCF did not receive any state aid and … any finding in this matter would be immaterial to the FCA Group’s reported results,” FCA said in a statement. MILAN: Fiat Chrysler Automobiles (FCA) denied again on Tuesday having received state aid from Luxembourg in a tax-related case, adding any findings… – Continue reading

Margaret Hodge calls for overhaul of UK tax laws

Former chair of the UK public accounts committee Margaret Hodge, who has repeatedly attacked the use of offshore tax avoidance schemes, has called for an overhaul of the British tax system. Speaking during an annual Professional Fee Protection (PFP) tax investigations conference, Hodge said the current tax regime in the… – Continue reading

Ireland: International Aspects Of Ireland’s Budget: 6.25% Knowledge Development Box And Country-By-Country Reporting

Following last week’s publication of the various OECD/G20 reports on the Base Erosion and Profit Shifting (“BEPS”) project, the Irish Budget delivered on 13 October 2015 contains the first Government initiative on implementing some of the recommendations. Key features are the introduction of the first of its kind knowledge development… – Continue reading

CLINTON LIBRARY FUNDED BY OFFSHORE TAX HAVEN

Hillary Clinton is repeating the Democrat trope about “offshore tax havens” that immorally divert profits from workers and the taxman. Closing these is a central plank of her promised agenda as President, she explains in an op-ed laying out her economic agenda. Setting aside the economic merits of her plan,… – Continue reading

25% of Companies Expected to Miss BEPS Deadline, Survey Finds

A recent Thomson Reuters survey report reveals that European companies are outpacing all others in developing their Base Erosion and Profit Shifting (BEPS) action plans by Dec. 31, 2017 – the deadline set by the Organization for Economic Cooperation and Development (OECD). But most respondents voiced several concerns about BEPS… – Continue reading

Hong Kong: The Need To Review Royalty And Technology Transfer Agreements

On October 5, 2015, the Organization for Economic Cooperation and Development (“OECD”) released its final report on the 15 key elements of international tax rules set out in its Base Erosion and Profit Shifting (“BEPS”) Action Plan. The OECD launched the BEPS Action Plan in 2013 at the request of… – Continue reading

China: A Brand-New Reporting Mechanism For Transfer Pricing Contemporaneous Documentation Under Discussion Draft For The Implementation Measures For Special Tax Adjustments

On 17 September, 2015, China State Administration of Taxation (“SAT”) released the Discussion Draft for the Implementation Measures for Special Tax Adjustments (“Discussion Draft”) to overhaul the existing trial version of the Implementation Measures, i.e., Circular 2. In the chapter of “Contemporaneous Documentation” of Discussion Draft, SAT introduces an entirely… – Continue reading

Record View: Amazon morally obliged to pay up their share of tax

WHEN public spending is being slashed in a way that punishes the poor, every firm have a moral obligation to pay their fair share. AMAZON are taking an ever bigger share of the shopping market. Technological advances mean you can order something from their website late at night from your… – Continue reading

The Self-Defeating Corporate Income Tax

For many years, policy makers have criticized the strategies that American corporations use to reduce their taxes by shifting income and capital offshore. The impetus behind these strategies is the U.S. corporate income-tax rate — at 35 percent, the highest of any industrialized nation, easily surpassing countries such as the… – Continue reading

Treasury ignores pleas to retain incentives

National Treasury has decided to scrap a recently introduced incentive to make South Africa’s service sector more competitive, despite an impassioned appeal from multinational companies not to do so. The special foreign tax credit for service fees has protected companies from double taxation where South Africa’s treaty partners levied withholding… – Continue reading

Worldwide: OECD Releases Final BEPS Recommendations – Now What?

On Oct. 5, 2015, the Organization for Economic Cooperation and Development (OECD) released a set of final reports on its 15 point action plan to address Base Erosion and Profit Shifting (BEPS). In an accompanying explanatory statement, the OECD also included plans for additional work on technical matters and a… – Continue reading

Ireland: Ireland’s Budget Statement 2016 – Key Points For Multinational Companies

Most of yesterday’s pre-election budget statement for 2016 (the “Budget“) by Ireland’s Minister for Finance (the “Minister“) focused on personal taxation. In the portion of his statement covering corporation tax, two key announcements were made in line with expectations following on from the publication of the final reports under the… – Continue reading

Chinese bond investors move offshore

Beijing’s monetary easing has sent onshore yields to multiyear lows, reports the Wall Street Journal. China’s booming domestic debt market is pushing investors to seek higher yields offshore, just as its banks start to expand yuan lending world-wide. The shift comes as China’s central bank is selling its first yuan… – Continue reading

HOUSING A TAX DODGE IN RICHMOND AND VANCOUVER

Some might be surprised to learn that certain areas of Richmond and Vancouver, despite being thoroughly decorated with mcmansions, monster homes, and incessantly rising land prices, are actually inhabited by low income residents that make up a surprising per cent of the population. Conservative Party leader Stephen Harper, during a… – Continue reading

Benefits of UAE-Based Offshore Companies

Offshore companies are established for a variety of reasons including a company’s necessity to restructure, create an international business entity as well as protect the assets of the company. The United Arab Emirates (UAE) is home to three authorities that register International or offshore companies. The three UAE authorities that… – Continue reading

London Wants to Become the Center of Chinese Currency Trading

Three years ago, Chinese officials said U.K. Prime Minister David Cameron had “seriously damaged” relations by meeting with the Dalai Lama, the exiled Tibetan leader. As planned talks between the two countries were canceled or failed to take place, worries emerged that Britain would miss out on building deeper economic… – Continue reading

United States: Tax Policy Update – October 13, 2015

NUMBER OF THE WEEK: 0 The number of House Republicans who want to be speaker and can actually secure the necessary 218 votes as of today. After Majority Leader Kevin McCarthy’s dramatic exit from the race last week, the House GOP conference is taking the week-long Columbus Day recess to… – Continue reading

Execs Weigh Impact of OECD BEPS Impact on U.S. Tax Reform

The impact of the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting action plan is still unclear, but tax executives are planning ahead for changes on the international tax front. Earlier this month, the OECD unveiled its plan for combating tax evasion strategies by multinational corporations (see… – Continue reading

LUXEMBOURG: DRAFT LEGISLATIVE PROPOSALS TO IMPLEMENT BEPS MEASURES

The Luxembourg government submitted draft legislative proposals to Parliament—legislation that, if enacted, would both implement certain provisions of the OECD’s base erosion and profit shifting (BEPS) actions and provide for certain EU-compliant measures. The proposals also would be intended to improve the competitiveness of the Luxembourg tax system. The proposals… – Continue reading

Surge in outbound payments hint at expats’ bid to escape American tax authorities

MUMBAI: There is a sudden, inexplicable surge in money that Indians are sending abroad for ” maintenance of close relatives“. Such fund transfers typically add up to $10-20 million a month. But in July 2015, according to the latest available data, total remittance under this head crossed $124 million. Also,… – Continue reading