Amazon’s Luxembourg-located tax affairs are under the scrutiny of the EU’s Competition Commission as regulators and lawmakers in the bloc widen an investigation into tax avoidance strategies carried on at the European headquarters of big companies. Amazon looks likely to join Apple, Starbucks and Fiat Finance and Trade, all of… – Continue reading
Should investors pay much heed to domicile when investing in an investment trust IPO? The first half of 2014 has very much mirrored what we saw last year, certainly from a new issues perspective. The investment trust sector is going full throttle, with the sector raising £1.8bn so far this… – Continue reading
With regard to business operations, a resident of one country (e.g., Panamanian company) may be taxed in the other country (e.g., Israel) if it has a “permanent establishment” (PE) in the other country. Panama is famous for its canal, colorful history and cool offshore tax regime. To that we can… – Continue reading
Not only do Indians manage global investors’ money that is invested in India, Indian nationals often hold positions of responsibility in funds that have nothing to do with India. Now, given the rapid advances that have been made in technology, why aren’t these Indian nationals residing in India? Clearly, some… – Continue reading
Going offshore means registering any intellectual property (IP) in an offshore company and delegating R&D and marketing to onshore companies. Money doesn’t grow on trees, and taking your business international is no picnic. On June 12, the International Business Structuring Association (IBSA) held a seminar to discuss ways of growing… – Continue reading
The organisations making the payments are required to withhold tax from such payments and pay over the withheld amounts to their respective relevant Tax Authorities within 30days of receipt of payment or credit by the person or entity suffering the Tax. The relevant tax authorities to receive the WHT tax… – Continue reading
New agreement The new double tax agreement between Cyprus and the United Arab Emirates took effect from January 1 2014. For the most part, the agreement reproduces the corresponding provisions of the latest Organisation for Economic Cooperation and Development (OECD) Model Tax Convention verbatim. The principal departures from the OECD… – 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
Following the recent offer by U.S drugmaker Pfizer to acquire British pharmaceutical firm AstraZeneca, congressional Democrats are proposing new limits on the ability of U.S.-based firms to establish foreign residence and thus cut their U.S. corporate tax bill. Even before this latest flap, the Obama Administration proposed curbs on this… – 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
First Minister Alex Salmond has refused to back calls for a boycott of Amazon after reports the company is engaging in large-scale tax avoidance. During First Minister’s Questions on Thursday afternoon, Scottish Green MSP Patrick Harvie cited concern over “further revelations about the scale of the scandal of tax avoidance… – 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
You’ve seen a recurring headline at the top of the business section this year: “ABC Corp. buys XYZ Inc. in multibillion merger.” When one company buys another, it’s typically done because there’s a fundamental belief that the sum is greater than the parts (Apple for Dr. Dre’s Beats Music, for… – Continue reading
The Decree Law No. 145 of December 23, 2013 (ratified by Law No. 9 of February 21, 2014) broadens the scope of the international ruling procedure. The main area of application is transfer pricing, in particular advance pricing agreements, but it may also apply to (i) the attribution of income… – Continue reading
Margaret Hodge, the chair of the public accounts committee, has called on shoppers to boycott Amazon after it was revealed that the online store paid just 0.1% tax last year. Drawing on the indignation provoked earlier by Starbucks, Hodge advised shoppers to shun Amazon, noting that it paid just £4.2m… – Continue reading
Wout Moelands, Hamir Khatau and Richard Collier, PwC UK Until the work of the OECD is completed, we can expect more frequent and assertive PE challenges, including the international origination arrangements conducted by travelling bankers or representative offices of banks. l. Introduction The PE rules provide tax authorities with a… – Continue reading
The OECD has been prolific in its publication of discussion documents since the start of the year. OECD discussion draft documents have been released in respect of: Action 13: Transfer pricing documentation and country by country reporting – 30 January 2014 The BEPS Action Plan issued on 19 July 2013… – Continue reading
A call to tax technology companies such as Apple and Google in the countries where they have substantial activities has re-ignited concerns companies may be taxed twice and stop business altogether. The Organisation for Economic Co-operation and Development, which is working on a global plan to prevent companies from avoiding paying… – Continue reading
The U.S. and Indian competent authorities are famously at loggerheads over the principles to be applied in transfer-pricing double-tax cases. Some of the important issues involved are: the appropriate markup on costs for services; when and how to reward location savings; and whether marketing intangibles exist. Virtually all of these… – Continue reading
Look before you leap out of Israeli residence. Israel now has tax rates below the OECD average and no estate or inheritance tax. Israeli residents relocate abroad for a variety of reasons, sometimes business, sometimes personal. If the relocation is for a short period, they will typically claim various expense… – Continue reading
Changes to Ireland’s residency rules, designed to eliminate mismatches between tax treaty partners, have not yet affected the residency status of any company, Finance Minister Michael Noonan has confirmed. The reforms were introduced in Noonan’s 2014 Budget and included in this year’s Finance Bill. They are intended to prevent companies… – Continue reading
Not a single company has contacted the tax authorities to say they have been affected by changes announced in the budget as part of Finance Minister Michael Noonan’s clampdown on international tax avoidance. In October’s budget, Mr Noonan included a measure that required any company incorporated in Ireland to be… – Continue reading
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
The online bookseller Amazon might suddenly find that the UK is more taxing than it would like. A UK judge ruled earlier this month that Amazon had infringed the trademark of soap maker Lush by posting advertisements on Google mentioning “Lush soap” and by offering customers who searched for “Lush soap”… – Continue reading
