Category: Profit Shifting

Capital gains / Capital Gains Tax / Dividends / Framework / G20 / Profit Shifting / Revenue / Royalties / Withholding Tax

Ireland: Aviation Finance & Leasing 2022

Published by: Mondaq - June 13, 2022

Financing structures involving Irish entities often employ the use of a special-purpose vehicle ("SPV"), which is a company established specifically to hold title to the aircraft subject to the financing and to lease those aircraft to the operators. Ireland is a popular jurisdiction for the establishment of SPVs due to the numerous double-tax treaties in place between Ireland and other countries, many of which specifically refer to aviation in their text. Ireland is also attractive due to the confidence in the legal and court system (which is broadly based on English common law) and the number of aviation experts and leasing companies based in Ireland. ... - Continue reading

Advance Pricing Agreement / Capital gains / Corporate Tax / Permanent establishment / Poland / Profit Shifting / Royalties / Tax Deductibility / Tax Deductions

Polish Deal introduces new minimum tax for corporations

Published by: MNE Tax - September 10, 2021

On 8 September, Poland’s government accepted a new tax bill called the “Polish Deal,” announcing after the public consultation on the bill a significant amendment to include a special anti-avoidance measure referred to as a minimum income tax for corporations. ... - Continue reading

Europe / Profit Shifting / Tax treaties

European Union: Interpretation And Application Of The General Anti-Abuse Rule Of The Parent-Subsidiary Directive

Published by: Mondaq - December 14, 2020

''Overview of EU Member States and Switzerland'', which gives you a comprehensive overview of the current state of play on the interpretation and application of the EU Parent Subsidiary Directive general anti-abuse rule (Directive 2015/121/EU) in the EU member states and how Switzerland deals with it. ... - Continue reading

Advance Pricing Agreement / Automatic Exchange of Information / Beneficial Ownership / Cyprus / G20 / OECD / Profit Shifting / Regulatory / Tax Avoidance / Tax Laws / Tax Planning / Tax Transparency / Tax treaties / Transfer pricing

Cyprus: European Mandatory Disclosure Regime (EU MDR) – A New Reality For Cypriot Intermediaries, Another Burden On Cypriot Taxpayers?

Published by: Mondaq - October 12, 2020

Mandatory disclosure rules are not something new for European Member States ("EU MS"). In fact, with the United Kingdom leading the race (from 2004), Ireland (in 2008) and then Portugal (in 2011) were the first -and only- EU MS to introduce mandatory disclosure rules in their local legislation. ... - Continue reading

Business / Jurisdiction / Multinationals / OECD / Philippines / Profit Shifting / Related party Transactions / Tax Collection / Transfer pricing

Enhanced transfer pricing regime amidst the pandemic

Posted On: August 31, 2020

Globally, the coronavirus disease 2019 (Covid-19) pandemic is requiring governments to design and implement strategies to cope with the deepening impact of the virus. They are introducing measures to cushion the blow from the economic downturn, such as drawing from reserves and intensifying tax collection efforts. As entire countries and… – Continue reading

Business / Cyprus / Double Tax Treaty / Double Taxation / Mutual Agreement Procedure / OECD / Permanent establishment / Profit Shifting

Cyprus: Cyprus And Switzerland Agree Updated Double Tax Treaty

Published by: Mondaq - August 17, 2020

On 20 July 2020 Cyprus agreed an updated double tax treaty (DTT) with Switzerland. The signatory for Cyprus was Foreign Minister Constantinos Petrides, while his counterpart, Pierre-Yves Fux, signed on behalf of the Swiss Federal Council. The revised protocol will update the existing agreement, which has been in force since July 2014. Details of the protocol were published in the Official Gazette on the 24 July 2020 and are now undergoing the ratification process. ... - Continue reading

Canada / Dividends / Infrastructure / Investments / Lease / Legislation / Profit Shifting / Revenue / Royalties / Tax Authority / Tax treaties / Treating Shopping / Treaty Abuse

Canada: Treaty Shopping: MIL, MLI And ALTA Things In Between

Published by: Mondaq - February 19, 2020

On February 12, the Federal Court of Appeal (FCA) released its decision in The Queen v. Alta Energy Luxembourg S.a.r.l.1 (Alta Energy), a case that represents an attempt by the Canadian tax authority to relitigate the issue of whether Canada’s domestic general anti-avoidance rule (GAAR) can apply to curtail so-called “treaty shopping”.2   ... - Continue reading

Business / Corporate Tax / Digital Services / Facebook / Ghana / Jurisdiction / Nigeria / Profit Shifting / Residence / Tax Haven / Tax Laws / World Trade Organisation

How major tech companies exploit tax laws: A focus on Ghana and Nigeria

Posted On: December 11, 2019

When World Trade Organisation (WTO) officials designed the territorial taxing rights back in the 1920s, not many people imagined that a century later; these guidelines would still underpin the international tax system. Today, highly digitalised companies such as Facebook and Google are able to operate internationally from their tax havens,… – Continue reading

Capital gains / Capital Gains Tax / Corporate Tax / Interest / Ireland / Profit Shifting / Real Estate / Tax Avoidance / Transfer pricing

Ireland Budget 2020 released

Published by: MNE Tax - October 10, 2019

On 8 October, the Irish government announced its Budget 2020 measures. Brexit and climate change are core themes of new revenue measures and expenditure commitments. Brexit remains the foremost immediate concern for the Irish economy, whereas tackling climate change requires long-term commitments to tax and spending policies. ... - Continue reading

Arbitration / Dividends / Double Taxation / G20 / Mutual Agreement Procedure / OECD / Profit Shifting / Tax Avoidance / Tax Credit / Tax Laws / Tax Planning / Treaty Abuse

Canada: Canada Ratifies The Multilateral Instrument

Published by: Mondaq - September 6, 2019

On June 7, 2017, Canada along with numerous other jurisdictions signed the Organisation for Economic Co-operation and Development’s (“OECD”) Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “MLI” or “multilateral instrument”). The multilateral instrument is the culmination of work undertaken as part of the OECD/G20 BEPS Project to equip governments with domestic and international instruments to address tax avoidance.   ... - Continue reading

Canada / Double Taxation / Income Tax / Income Tax Act / Mutual Agreement Procedure / Profit Shifting / Tax Planning / Tax Refunds / Transfer pricing

Canada: Transfer Pricing: What’s New In Canada (Part II)

Published by: mondaq - September 4, 2019

Transfer pricing disputes in Canada have, predominately, been resolved through either a request for competent authority assistance under the Mutual Agreement Procedure ("MAP") of a treaty, or, to a much lesser extent, through the notice of objection process with CRA Appeals.  Regardless of the recent increase in transfer pricing cases being brought before the Courts, the MAP will likely continue to be the dispute resolution process most often utilized by a Canadian corporation in transfer pricing cases because, in the absence of a 100% reversal of a transfer pricing adjustment by either CRA Appeals or a Canadian court, economic double taxation may still exist as a consequence of the CRA upward transfer pricing adjustment. The correlative relief provided by the treaty partner under a MAP settlement resolves that double taxation. ... - Continue reading

HMRC / OECD / Pakistan / Profit Shifting / Transfer pricing

Transfer pricing: DGIT starts analysing potential cases of MNCs

Posted On: August 25, 2019

The Directorate General of International Taxes of the Federal Board of Revenue (FBR) has started analysing a few potential multinational companies’ cases of transfer pricing where companies are directly involved in shifting their profits outside the country without payment of any taxes. In this regard, Directorate General of International Taxes… – Continue reading

Multinational Enterprises ("MNEs") / Offshore Tax Haven / Profit Shifting / Tax Laws / Tax Reform / Transfer pricing

CIAT’s transfer pricing “Cocktail” provides solutions for transactional net margin method overuse

Published by: MNE Tax - August 20, 2019

In recent years there has been a major public outcry for governments to take action to force multinational groups to pay a fair share of tax in the jurisdictions where their economic activities take place and to stop shifting profits to offshore tax havens. ... - Continue reading

Corruption / Individuals / Investments / Jurisdiction / Law Firm / Mauritius / Profit Shifting / Revenue / Tax Avoidance / Tax Dodging / Tax Haven

Mauritius leaks latest reminder of how much we lose to tax havens

Posted On: August 6, 2019

Mauritius leaks latest reminder of how much we lose to tax havensA report by Canadians for Tax Fairness Bay Street and Tax Havens revealed how over 90% of Canada’s largest corporations have subsidiaries in tax havens. Ottawa (06 Aug. 2019) — Last month Canadians for Tax Fairness reported that, while… – Continue reading

Advance Pricing Agreement / Europe / European Commission / G20 / Mutual Agreement Procedure / OECD / Profit Shifting / Tax Authority / Transfer pricing

The latest APA and MAP figures in Europe: what are the implications for multinational group taxpayers?

Published by: MNE Tax - August 2, 2019

Statistics published earlier this week by the European Commission on member state advance pricing agreement (APA) and mutual agreement procedure (MAP) programs suggest that the OECD/G20 base erosion profit shifting (BEPS) project has increased the scope for differences of opinion between tax authorities of different countries. ... - Continue reading

Corporate Tax / Country-by-Country (CbyC) Reporting / Government Bodies / Kenya / Legislation / Multinationals / Offshore / Profit Shifting / Revenue / Tax Authority / Tax Avoidance / Tax Evasion / Tax evasion investigations

Government Should Investigate BAT’s Tax Evasion

Posted On: May 29, 2019

Kenya  Tobacco Control Alliance KETCA has today called upon the government to prioritize regulations that enable the  maximization of corporate tax revenue from British American Tobacco (BAT) Company. The  KETCA  Chairman, Joel  Gitali  said that  BAT avoids paying full corporate taxes which would have been used for public  services like… – Continue reading

Income Tax / Indonesia / Multinationals / Profit Shifting / Tax Avoidance / Tax Haven / United Kingdom

British American Tobacco shifts nearly $1bn out of developing countries into one UK office

Posted On: April 30, 2019

For every dollar British American Tobacco (BAT) paid in tax in the countries it operates in, the giant multinational shifted more than half a dollar that would have been taxed locally to a UK subsidiary where BAT paid almost no tax. New analysis by the Tax Justice Network estimates Bangladesh,… – Continue reading

Amazon / Beneficial Ownership / Canada / Canada Revenue Agency / Google / Netflix / OECD / Offshore / Profit Shifting / Tax Avoidance / Tax Haven / Uber

Tax Netflix and other e-commerce companies, say Canadians and CRA professionals

Posted On: February 21, 2019

OTTAWA, Feb. 21, 2019 (GLOBE NEWSWIRE) — The federal government needn’t worry about a consumer backlash to a sales tax on Canadians’ Netflix accounts, if newly released results from an Environics Research poll and a separate survey of Canada Revenue Agency (CRA) tax professionals are any indication, says the Professional… – Continue reading

Multinationals / Non Compliant / Profit Shifting / Revenue / Tax Laws / Tax Transparency / United Kingdom / USA

One in nine US multinationals ‘fail to comply with tax transparency law’

Posted On: February 6, 2019

Analysis of more than 600 US multinational corporations has revealed that 12 per cent failed to comply with UK law requiring them to publish their tax strategies. With the UK estimated to lose £25 billion in corporate tax revenue each year due to multinational corporations shifting profits out of the… – Continue reading

Base Erosion & Profit Shifting / Investments / Profit Shifting / Tax Evasion / Tax Fraud / Tax Laws / Tax Reform / Vietnam

Ministry to mull over measures against profit shifting

Posted On: January 14, 2019

The Ministry of Finance will scrutinize amendments to tax law policy in 2019, centred on some measures aimed at preventing base erosion and profit shifting (BEPS) and restructure tax revenue sources. The information was released at a conference reviewing the finance sector’s performance throughout 2018 and setting forth targets for… – Continue reading

Banking / Base Erosion & Profit Shifting / Business / Donald Trump / Ernst & Young / Internal Revenue Service (IRS) / Jurisdiction / Multinationals / Profit Shifting / Royalties / Tax Laws / USA

IRS gives foreign banks a break in Trump tax law’s new levy

Posted On: December 17, 2018

The Internal Revenue Service is giving foreign-based banks with U.S. operations some leeway when calculating a major new international tax aimed at preventing global companies from shifting profits abroad. Multinationals often transfer payments, such as interest or royalties, to their affiliates in low-tax jurisdictions to maximize deductions and minimize tax… – Continue reading

Legislation / Offshore / Profit Shifting / Revenue / South Africa / Tax Authority / Tax Collection

Trade misinvoicing costs South Africa $7.4bn in tax a year

Posted On: November 19, 2018

While SARS is scrambling to meet collection targets, a new report estimates the country lost $37-billion in revenue to trade misinvoicing in five years. Trade misinvoicing is thought to be the largest component of illicit financial flows, draining developing countries of much-needed finances. In a new report, Global Financial Integrity… – Continue reading

Americans / Apple / Corporate Tax / Donald Trump / EU / Google / Multinationals / Oil / Profit Shifting / Tax Collection / Tax Dodging / Tax Evasion / Tax Haven / Tax Laws / USA

US multinationals dodge $180 billion in taxes on foreign profits per year

Posted On: November 10, 2018

US multinational corporations are plundering the populations of the United States and the world to the tune of trillions of dollars by driving down and evading taxes on profits booked overseas. This is the conclusion that emerges from a recent study by University of California at Berkeley economist Gabriel Zucman… – Continue reading

Base Erosion & Profit Shifting / Multinationals / OECD / Papua New Guinea / Profit Shifting / Tax Authority / Tax Dodging / Tax Evasion

OECD comes to PNG’s aid to chase tax dodgers

Posted On: October 22, 2018

Internal Revenue Commission is now in partnership with an international auditing organisation to help tackle multinationals that are avoiding paying taxes, Deputy Prime Minister and Treasurer Charles Abel, pictured, says. He said that Organisation for Economic Cooperation and Development (OECD), under its ‘tax inspectors without borders’ programme, would help IRC… – Continue reading

Africa / IMF / Indonesia / Nigeria / Profit Shifting / Tax Collection / Tax Evasion / Tax Reform / Transfer pricing

Nigeria seeks IMF’s support on tax collection

Posted On: October 13, 2018

The Federal Government is seeking assistance from the International Monetary Fund (IMF) on modalities for improving tax collection, especially from the International Oil Companies (IOCs), Finance Minister Zainab Ahmed, has said. She told reporters on the sidelines of the ongoing 2018 International Monetary Fund (IMF)/World Bank Group Meetings, in Bali,… – Continue reading

Africa / Business / Corporate Tax / Corruption / MTN / Multinational Corporations / Multinationals / Nigeria / Politically Exposed Persons / Profit Shifting / Tax Evasion

PACAC Explains Why FG Turned Spotlight on Multinationals

Posted On: September 9, 2018

The Presidential Advisory Committee against Corruption (PACAC) has explained why it is shifting the war against corruption in the country from politically exposed persons to multinationals. According to the Executive Secretary of PACAC, Prof. Bolaji Owasanoye, Africa and indeed Nigeria losses more from Illicit Financial Flows (IFF) perpetrated by multinational… – Continue reading

Business / Intragroup Services / Jurisdiction / Legislation / Multinational Corporations / Profit Shifting / Tax Authority / Tax Avoidance / Transfer pricing

Intra-group Service Fee Treatment in China

Posted On: August 7, 2018

Most multinational corporations (MNCs) charge their subsidiaries for services like human resources (HR) or information technology support. The subsidiary’s payment for these services is classed as intra-group service fees when they are made within same enterprise group. Because some businesses use this method to avoid tax and shift profits, tax… – Continue reading

Automatic Exchange of Information / Banking Secrecy / Base Erosion & Profit Shifting / Common Reporting Standard / Multinationals / Profit Shifting / Tax Authority / Tax Planning / Tax Reform / Tax Transparency

Profit shifting a regional issue: Palaso

Posted On: July 25, 2018

Profit shifting by large companies is a regional issue that can be addressed through improved information sharing between tax authorities of economies, says Internal Revenue Commission commissioner-general Betty Palaso. She said this at the opening of the Advancing Base Erosion and Profit Sharing (BEPS) and Automatic Exchange of Information (AEOI)… – Continue reading

Deloitte / Foreign Direct Investment (FDI) / Investments / Profit Shifting / Tax Authority / Tax Reform / Transfer pricing / Vietnam

Tax, investment changes concern foreign firms

Posted On: July 11, 2018

Hanoi (VNS/VNA) – The changes in tax policy and investment incentives are the issues of greatest concern for foreign investors in Vietnam, said Bui Ngoc Tuan, Deputy General Director of the Audit and Advisory firm Deloitte Vietnam at a workshop on in Hanoi on July 10. Themed “Investment incentives, related… – Continue reading

Anti-Tax Avoidance Package / Bahamas / Blacklist update / EU / Profit Shifting / Tax Haven / Turks and Caicos

TCI dodges EU tax haven black list

Posted On: June 18, 2018

THE TURKS and Caicos Islands has managed to avoid being placed on the European Union’s tax haven black list. Although the territory was on the anti-corruption watchdog’s grey list in 2017, prudent financial measures including tax transparency and compliance have prevented international sanctions. The EU’s grey list consists of jurisdictions… – Continue reading

Anti money laundering / Canada / Cayman Islands / Legislation / Offshore Tax Haven / Profit Shifting / Tax Laws

Canada’s legal weed sparks Cayman money laundering claims

Posted On: June 18, 2018

(CNS): While the prospect of legal cannabis for recreational use in the Cayman Islands is not expected anytime soon, Canada is just a couple of months away from full legalisation. As that date approaches, legislators have raised concerns that the multi-billion dollar legal weed market could be taken over by… – Continue reading

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