On the 29th of September of this year, one of the most important and controversial norms of the tax reform: the general anti-avoidance rule came into effect. This norm intends to cutback aggressive tax planning providing new faculties to the Chilean IRS. Indeed, this norm has incorporated what is widely… – Continue reading
Billionaire investor Carl Icahn has a strong opinion on almost every subject, especially politics. He’s also quite happy to share that opinion with anyone who will listen to or read what he has to say. Icahn’s comments this week on how to stop future tax-motivated corporate inversions such as the… – Continue reading
Hundreds of millions of dollars of revenue could be up for grabs as the Tax Office announces reviews of multinationals using offshore hubs in Singapore to minimise their tax. The ATO has issued a warning to multinationals to come forward immediately to discuss their overseas hub arrangements, if they have… – Continue reading
Stricter Tax and documentation requirements for foreign transactions “Amazon, Facebook, Google and Starbucks pay little taxes …” or “Luxembourg attracts international corporations” – headlines like these have 62 states and the OECD called into action. The result was “base erosion and profit shifting” BEPS shortly. Even the German SME sector… – Continue reading
Its approach includes a new “nexus principle”, as agreed by the multinational Organisation for Economic Cooperation and Development (OECD). This is designed to ensure that the benefits of the UK tax regime are only available where the research and development (R&D) expenditure required to develop that innovation also took place… – Continue reading
Meg Hillier has a tough act to follow. This parliament’s Public Accounts Committee chairwoman had a ringside seat watching her predecessor, Margaret Hodge, tear into tax avoiders and the tax man. “It is very exciting – you see all the guts of Whitehall spilled out in front of you,” she… – Continue reading
Transfer pricing is a tax planning method where related companies enter into transactions among each other to shift funds, and thereby profits. For instance, a parent company can extract funds from a subsidiary by having the issue a dividend, but the parent can also provide a service to subsidiary and… – Continue reading
The Queen’s jeweller has not paid corporation tax in five years, it is claimed, despite reported profits of £66million Demands are growing for a review of the royal warrant system after firms supplying the monarchy were criticised for moving profits overseas. The crest is a mark of British craftsmanship and… – Continue reading
Cash doesn’t flow directly from buyers’ pockets to Microsoft’s headquarters in Redmond, Wash. Instead, the company operates through three regional sales units, centered in Ireland, Singapore and Puerto Rico. These groups control the rights to profit from Microsoft products around the world. By conducting sales from places with small populations… – Continue reading
Companies will to scrutinise their R&D activity more closely under proposed changes to patent box regime BUSINESSES will to scrutinise their R&D activity more closely under proposed changes to the design of the UK Patent Box regime outlined by the government The government is making the changes in order to… – Continue reading
In 2013, the 39th G8 summit in Lough Erne committed to reform the international tax system. The G8 Lough Erne Declaration stated that such reforms would benefit developing countries. The G20 declaration in St Petersburg 2013 also stated specifically that “Developing countries should be able to reap the benefits of… – Continue reading
SOUTH Africa ranks seventh among developing countries in terms of illicit financial outflows, a Washington-based research organisation has found. Illicit outflows from the country are of great concern to the Treasury, which has introduced a number of measures to curb it, particularly the outflows achieved through profit shifting by large… – Continue reading
On 8 December 2015, the Council adopted a directive aimed at improving transparency on tax rulings given by member states to companies in specific cases about how taxation will be dealt with. The directive is one of a number of initiatives aimed at preventing corporate tax avoidance. It will require… – Continue reading
MUMBAI: India has been an active participant in the Base Erosion and Profit Sharing (BEPS) action plan, the final package of which was rolled out by the Organisation for Economic Co-operation and Development (OECD) in October. The action points, set down by the OECD, aim at closing loopholes that enable… – Continue reading
Explosives maker Orica will take a $36 million hit to its bottom line after the Federal Court found it had avoided tax by using “round robin” financing arrangement it put in place a decade ago to boost its profit and ward off takeover bids. BusinessDay revealed Orica’s battle with the… – Continue reading
Yahoo has reportedly abandoned its plan to spin off its stake in Alibaba. Yahoo’s proposed spinoff had been driven by tax concerns. In a world without taxes, Yahoo could have simply sold its Alibaba shares and distributed the proceeds to shareholders. Yahoo will now concentrate on other strategic options, including… – Continue reading
Finance Minister Edward Scicluna pushes for ‘flexibility’ during today’s meeting of EU finance ministers in Brussels Malta has come out strongly against applying “rigid rules”, urging the European Commission to adopt a more flexible approach as it drafts legislation on taxation. Corporate tax was high on the agenda of EU… – Continue reading
Taxpayers fume about wastage and corruption, but large-scale evasion seems unlikely. JOHANNESBURG – There seems to be increasing concern that South Africa could be heading for a tax revolt. This comes amid an outcry against corruption, wastage of taxpayer money and the fact that the country’s deteriorating fiscal situation will… – Continue reading
The Base Erosion and Profit Shifting (BEPS) project is an initiative being pursued by the Organization of Economic Cooperation and Development (OECD) to curtail perceived exploitation of international tax rules and loopholes by multinational enterprises (MNEs). The OECD’s BEPS project was initiated in 2013 at the request of the Group… – Continue reading
Campaigners attack offshore centre for support of tax dodging, corruption and terrorist financing, reports the Financial Times. Bermuda has hit back against its critics, claiming that the financial centre is the victim of an “irresistible urge to stereotype” the British overseas territories. Bob Richards, finance minister, mounted a trenchant defence… – Continue reading
WASHINGTON — Hillary Clinton on Wednesday will unveil a proposal for a new “exit tax” aimed at cracking down on corporate inversions, a practice that permits U.S. companies to merge with corporations overseas to lower their tax bill. The new tax would be part of a broader effort to target… – Continue reading
Mondelez was able to pay no UK corporation tax as a result of a Channel Islands-based bond, despite Cadbury making £96.5m profit in 2014 Mondelez, which owns Cadbury, is facing controversy over its tax arrangements after it was reported that it had not paid UK corporation tax last year. An… – Continue reading
Wealthiest 20 Americans, with combined net worth of $732billion, are as wealthy as half of the U.S. population, new study says Study found country’s richest 20 people now own more wealth than bottom half of population which is about 152 million people Wealthiest 20 people includes eight founders of corporations,… – Continue reading
Employees at Allergan have been told a proposed merger with Pfizer is about changing healthcare – not skirting tax law. Allergan’s global chief executive Brent Saunders has written directly to the company’s employees – including around 1,000 in Ireland, telling them the controversial deal is not just about tax savings…. – Continue reading
Deep in the $1.1 trillion dollar spending bill that Congress has to pass by Dec. 11 to avoid a government shutdown are 50 annual “tax extenders” that would provide tens of billions of dollars in tax relief for the private sector. Advocates say these measures, which have been around for… – Continue reading
HM Revenue & Customs (HMRC) updated its diverted profits tax guidance to clarify the tax authority’s interpretation of the legislation and proposed administrative practice. Highlights Some highlights from the revised guidance include: Both the “insufficient economic substance condition” and the “design test” in section 86 FA 2015 (avoidance of UK… – Continue reading
Some of the DTAAs entered into by India with other countries allow taxation of capital gains on shares only in the country of which the taxpayer is a resident. The government on Friday told the Lok Sabha that it has started negotiations with some countries to amend provisions on capital… – Continue reading
Tax authorities around the world could take a “cowboy” attitude towards captive tax rights when following guidance from the Base Erosion and Profit Shifting (BEPS) papers, according to Dr Pierre Olivier Gehriger, partner and certified tax expert at Pestalozzi Attorneys at Law. Speaking on a Captive Review webinar hosted by… – Continue reading
The Government of India is aware of the potential loss of revenue from tax avoidance, and has been taking all necessary measures for preventing it. As a part of these measures, India has actively participated n the Base Erosion and Profit Shifting (BEPS) project undertaken by the OECD and G-20… – Continue reading
The highly significant changes to transfer pricing guidance planned for under the SAT’s public discussion draft on ‘Special Tax Adjustments’ (yet to be finalised at the time of writing), and the impact of these changes in the light of evolving Chinese transfer pricing enforcement practice is the focus of this… – Continue reading
Australians hiding funds and investments offshore to avoid paying tax have been put on notice. The federal government on Thursday introduced to parliament legislation to enable the tax office to crack down on taxpayers hiding funds overseas. It implements an OECD scheme allowing the sharing of information between foreign tax… – Continue reading
A lengthy and yet complex investigation by The Botswana Gazette into financial affairs of the company in the shady tax haven of Bermuda blows the lid off the dealings amounting to P29 million with a mailbox sister company that has no office, employees or any legitimate business activities. Not only… – Continue reading
The Greens have been labelled “tax transparency traitors” by Labor for agreeing to pass the Government’s multinational tax avoidance laws, but the deal is also causing friction within Coalition ranks. Under the deal, multinational companies with a global turnover of $1 billion or more will have to prepare “general purpose”… – Continue reading
Lawmakers seek late deal to scale back ‘Cadillac tax’ Lawmakers are making a late push to repeal or scale back Obamacare’s “Cadillac tax” by the end of the year, eying inclusion of changes in a broader tax package, wrote Peter Sullivan of The Hill. But lawmakers in both parties say… – Continue reading
Inland Revenue is looking at the tax treatment of hybrid debt and equity instruments and the use of related party loans funding local subsidiaries as part of a global clamp-down on tax avoidance. Acting deputy commissioner of policy and strategy David Carrigan told Parliament’s finance and expenditure select committee that… – Continue reading
The European Commission’s use of state aid rules to challenge corporate tax agreements is causing uncertainly for businesses in Europe, Luxembourg finance minister Pierre Gramegna has said. Gramegna told the Financial Times this week that the situation “raises so many issues about predictability and certainty”. The Commission announced in October… – Continue reading
A new international framework is targeting tax avoidance—and it has implications for captive insurers. Jenny Coletta of Ernst & Young explains In recent years, tax authorities around the world have been increasingly scrutinising captive insurance arrangements, focusing on questions relating to commercial purpose, pricing and substance. In what is likely… – Continue reading
Amazon Anonymous van drove through central London emblazoned with the line: ‘Enjoy unlimited instant tax dodging subsidised by government hand-outs. Anywhere, anytime’ Anti-Amazon campaigners drove a van through central London yesterday that was emblazoned with a crowdfunded, fake Amazon advert attacking the online retailer’s alleged tax avoidance. Booksellers have championed… – Continue reading
The 28 nations of the European Union lose up to $1 trillion per year in revenue thanks to multinational corporations that use a spider’s web of completely legal constructs to lower their taxes. Now, Europe’s law enforcers and lawmakers want to wipe away these intricate tax-avoidance systems. If they have… – Continue reading
“It is not the strongest or the most intelligent who will survive but those who can best manage change”-Charles Darwin The Organization for Economic Co-operation and Development (OECD) released its final recommendations on the Base Erosion and Profit Shifting (BEPS) Project on October 5, 2015. The BEPS project consist of… – Continue reading
Pension schemes should review their holdings in infrastructure heading into 2016, with the dual threat of incoming regulation and high prices potentially threatening returns, Kames Capital has said. Infrastructure has been an increasingly popular asset class for many schemes since bond yields tumbled in the wake of the financial crisis,… – Continue reading
The current international tax regime was developed in the last century when the internet was not yet invented. At that time, a foreign company would typically require a substantial physical presence in Australia before it could be in a position to earn significant amount of income from Australian customers. This… – Continue reading
EU committee to vote on plans to curb tax avoidance EU countries should be compelled to inform other member states in advance of plans to introduce tax initiatives that could affect their own or another country’s effective tax rate, according to a report to be considered by the European Parliament’s… – Continue reading
Multinationals operating in Kenya, Tanzania and Uganda will be among the first in Africa to feel the impact of new measures to be adopted in January to curb tax losses caused by manipulation of contracts between related companies. The three countries together with Nigeria, Ghana, Burkina Faso, Senegal, Botswana and… – Continue reading
While the U.S. is plagued by inertia when it comes to tax policy, the rest of the world hasn’t been standing still. The biggest change of late has been the completion of the Organization for Economic Cooperation and Development’s (OECD) Base Erosion and Profit Shifting Project, or BEPS, a multiyear… – Continue reading
Government officials say multinational technology giants are reluctant to pay anything The Korean affiliates of Microsoft (MS) and Oracle are under increasing pressure to pay taxes here, with government officials saying the two multinational technology giants were reluctant to pay anything, although they generated huge a lot of money from… – Continue reading
Action Plan 10 of the Base Erosion and Profit Shifting (BEPS) project of the Organisation for Economic Co-operation and Development (OECD) seeks to align transfer pricing (TP) outcomes with value creation by clarifying the conditions under which transactions between related parties can be re-characterized. It also sheds light on how… – Continue reading
What is the whole point of the 15 actions in the Base Erosion and Profit Shifting (BEPS) code? How will they curb tax dodging and make taxation of multinationals more transparent? Historically, the interaction of different tax policies lead to instances where taxes paid are not commensurate to economic value… – Continue reading
East African countries expect to collect more revenue under a new code drawn, by the world’s richest economies to stop foreign multinationals from dodging taxes in host countries. The new code — Base Erosion and Profit Shifting (BEPS) — adopted by G20 at its meeting in Turkey two weeks ago,… – Continue reading
Tech titans powering the economy shelter money through insane tax-avoidance havens. It’s wrong — and adding up Offshore tax havens enable not only individuals to dodge taxes—they also enable multinational corporations to do so. Often this tax avoidance is done within the letter of the law: multinational groups exploit the… – Continue reading
