Industry lobby groups are calling on lawmakers to bolster business innovation as they debate corporate tax reforms aimed at retaining Switzerland’s status as a location for multinationals, reports Swiss Info. Parliament is currently looking at a government recommendation to replace Switzerland’s current, and controversial, cantonal corporate tax system – that… – Continue reading
The decree to implement Italy’s “patent box” has been signed by Minister of the Economy and Finance Pier Carlo Padoan and Minister of Economic Development Federica Guidi and should be gazetted shortly. The patent box will offer a preferential tax regime in 2015 for income derived from the use or… – Continue reading
In May 2012, Cyprus introduced a package of incentives and tax exemptions relating to investment in intellectual property rights, commonly known as an “IP box.” Intellectual property projects are particularly susceptible to cross-border planning by reason of the mobility of intellectual property rights, which do not consist of physical assets… – Continue reading
The UK Government’s goal is to make the UK the best place in the world to locate an international business; it has one of the most open economies globally, a highly skilled workforce, access to capital markets, a first-class infrastructure, and a highly competitive corporate tax system. UK tax policy… – Continue reading
Copycat China is notorious . Many Western companies hesitate to enter China or to bring in technology, because of valid concerns about loss of intellectual property. This concern is even greater when it comes to innovating or conducting R&D in China. But there is encouraging news: the framework for IP… – Continue reading
The European Commission has released a working paper that looks at how significant the introduction of the modified nexus approach will be for the tax affairs of multinational companies that use patent box regimes Entitled Patent Boxes Design, Patents Location, and Local R&D, the paper suggests “that in the majority… – Continue reading
Companies registering their intellectual property in Israel will be charged only 5% tax on dividends. The committee considering changes in the Law for the Encouragement of Capital Investments, headed by former Ministry of Finance director general Yael Andorn, is recommending extension of the tax break granted under the law to… – Continue reading
The Swiss Federal Council has adopted a dispatch on the Corporate Tax Reform Act III (CTR III), a package of reforms it said will strengthen the country as a business location and ensure companies make an appropriate tax contribution. The Council agreed on the parameters of the CTR III on… – Continue reading
The five biggest suppliers of publicly subsidised medicines in Australia recorded sales of nearly $5 billion last year but paid an average of just $10 million each in company tax. Research by the Parliamentary Library, obtained by Fairfax Media, has disclosed the tax contribution of multinational pharmaceutical companies, including Pfizer… – Continue reading
Following our article at the end of last year on the potential changes to the UK patent box regime further details have been released on the new regime, timings and additional work to be done. On 6 February 2015, the Organisation for Economic Co-operation and Development (OECD) published a paper… – Continue reading
The Swedish Tax Agency (STA) bears the burden of proof that pricing between associated companies differs from what would have been agreed between independent companies but this burden has proved difficult for it to meet. New approaches used by the STA in its investigations suggest it puts more effort in… – Continue reading
The UK’s introduction of the diverted profits tax (DPT) has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) and in effect as of April 1, the DPT seemed intended to appease public anger at multinationals failing to pay their ”fair… – Continue reading
Canada’s health-care stocks are sizzling, as Concordia Healthcare Corp. and Valeant Pharmaceuticals International Inc.’s buy-and-streamline strategy has pushed the industry’s earnings and margins ahead of U.S. peers. The drugmakers are the two top-performing stocks in the Canadian equity benchmark this year, boosting total returns for the members of the Standard… – Continue reading
The Australian Taxation Office is probing Commonwealth Bank over a nine-figure sum arising from tax breaks claimed by the nation’s largest company for research and development. In a hostile environment for tax minimisation by large corporates, CBA and the ATO are wrangling over an amount ¬believed to be in excess… – Continue reading
If you are moving or trading goods across borders, this topic should be of primary importance from both a Transfer Pricing and Customs perspective. There is potential for you to have Transfer Pricing and Customs exposures in your supply and value chains as a result of the OECD/G20 initiative on… – Continue reading
The American Chamber of Commerce has warned that new Irish tax incentives may fail because they do not match the needs of multinationals, reports the Irish News. The chamber, which represents 700 US companies, has said the forthcoming Knowledge Development Box – which will replace the discredited Double Irish structure… – Continue reading
The patent box regime, adopted at the end of 2014 with Italy’s Stability Law, was recently modified by the Investment Compact Decree and implemented into law at the end of March 2015. A distinctive feature of the Italian regime is that the measure now also covers trademarks and designs. A… – Continue reading
In October 2013 Minister Michael Noonan presented Budget 2014. The Minister’s budget speech indicated that one of the primary aims of that Budget was to bring Ireland back to a position where it could fund itself fully through the international markets in a sustainable way, at competitive interest rates. It… – Continue reading
Tax breaks for research and development should be targeted to smaller technology start-ups, rather than big companies that will most likely make the investments regardless of incentives, Google Australia will tell the senate inquiry into corporate tax avoidance. Google Australia’s managing director, Maile Carnegie, will be appearing before the inquiry… – Continue reading
HMRC’s reporting of tax reliefs does not enable Parliament to scrutinise them effectively to determine whether they are providing value for money and the complexity of tax law and the constraints on HMRC’s resources mean that it is fighting an uphill battle against those who are determined to cheat the… – Continue reading
The recent release of Ireland’s major strategy paper, ‘IFS2020 – A strategy for Ireland’s financial services sector 2015-2020’ addresses Ireland’s five year strategy in further developing the country as a global leader in the financial services sector. Over the past 25 years, Ireland’s international financial services sector has grown dramatically,… – Continue reading
The Abbott Government will shortly release a discussion paper on the Australian tax system. It will be the first step towards the much anticipated tax white paper. International factors should figure prominently in the white paper — specifically, how to ensure that Australia has a resilient tax system given the… – Continue reading
Two important developments last week in the transfer pricing domain have the potential of completely transforming the way this critical and controversial tax area has been handled by the income-tax department. One is the Delhi High Court judgment on tackling the AMP (advertisement, marketing and sales promotion) expenses involving a… – Continue reading
Earlier today the UK government delivered its last budget before the UK general election in May. Many of the measures were, as one might expect so close to an election, focused on personal rather than corporate taxation. However, below is a summary of some of the business related announcements: Diverted… – Continue reading
1.GENERAL QUESTIONS 1.1 Why is the Commission presenting a Tax Transparency Package? The Commission has made the fight against tax evasion and corporate tax avoidance a political priority, with a view to creating a socially and economically more efficient Single Market. While much has been done to advance this agenda… – Continue reading
Irish Prime Minister Enda Kenny has reiterated his “rock-solid” commitment to the country’s 12.5 percent corporate tax rate. In a speech to the Irish Chamber of Commerce, Atlanta, Kenny said that his Government is “fully committed to pursuing policies that create the ideal conditions for enterprise and investment.” He pointed… – Continue reading
KARACHI: The customs authorities have referred the case of importer Paramount Corporation to the Engineering Development Board (EDB) for seeking technical view point into the case. The sources informed Customs Today that the authorities concerned of Customs Adjudication-II have forwarded the case of Paramount Corporation to the EDB for seeking… – Continue reading
Two business federations from the Netherlands and Germany have urged the Organisation for Economic Co-operation and Development to ensure that there is a level playing field under new international rules proposed for preferential regimes for intellectual property (IP) income, reports Tax News. The two organizations’ statement concerns the development of… – Continue reading
Corporate tax reform has emerged as an area of potential bipartisan action in the United States Congress over the next few months. But fundamental questions about the right approach remain. There is widespread agreement that the US corporate tax system is deeply flawed. The rate is too high; the base… – Continue reading
Pharmaceutical companies want the finance minister to increase tax concessions across the board as also bring in more clarity on amendment to the rollback of advance pricing agreements (APA), applicability of roll back benefit, impact on on-going assessment, applicability of roll back provisions on bilateral APAs etc. In a pre-budget… – Continue reading
The breathless conundrum for IP companies is four-fold: not only should royalties be taxed at a low rate in order to maximise profits; but also research and development (R&D) or acquisition costs should be considered as allowable expenses to the maximum possible effect, whilst also the jurisdiction where the IP… – Continue reading
Thanks in part to past concerns that globalization could lead to double taxation, corporations have numerous techniques at their disposal to reduce their tax bills, including the placement of subsidiaries and spinoff holding companies in low-tax jurisdictions. The Group of 20 wants to change that. The Organisation for Economic Cooperation… – Continue reading
NUMBER OF THE WEEK: 3,415. The number of people who renounced their citizenship in 2014 according to IRS data. This is one of the five highest totals on record since the U.S. Congress passed the Foreign Account Tax Compliance Act in 2010. In the past five years, more than 10,000… – Continue reading
More than 100 tax disputes involving Indian associates of US companies such as IBM and Microsoft are set to be settled out of court by April this year with the income tax department and the US Internal Revenue Service identifying disputes in the contract research, IT and software sectors for… – Continue reading
THE European Union (EU) will not pursue a probe of national programmes that create tax breaks for research and development, giving a boost to drug and technology companies that generate revenue from patents. The EU’s hands were tied by a 2008 decision to approve a “patent box” tax break in… – Continue reading
Department of Finance officials expressed concern that changes to tax breaks in budget 2015 would cost at least €50 million in foregone taxes annually and reward a relatively small number of companies. On budget day last October, Minister for Finance Michael Noonan announced improved tax incentives for research and development… – Continue reading
On 11 November 2014, the UK and German governments issued a joint statement on proposals for new rules for preferential intellectual property (IP) regimes within the G20/OECD base erosion and profit shifting (BEPS) project. Germany currently does not have a special regime for Patent Boxes, but suffers from structures that… – Continue reading
Both the OECD and the EU are exploring options to change how digital businesses are taxed, while NGOs are stepping up their pressure on tax authorities to challenge large companies’ transfer pricing arrangements. No matter how robust your digital business’s transfer pricing arrangements appear to have been in the past,… – Continue reading
Midlands businesses can still benefit from the Patent Box, according to international accountancy firm Mazars. It follows plans to amend it – resulting in a narrower focus on UK R&D. That is the verdict from Birmingham professionals Peter Jelfs, senior tax manager at international accountancy firm Mazars, and Nicholas Braddon,… – Continue reading
The Department of Finance is understood to be “open-minded” over what rate should be applied to its proposed ‘knowledge box’ tax regime for patents and intellectual property assets developed here. The department yesterday formally launched its planned consultation process for the programme, which was announced in October’s Budget. There has… – Continue reading
The Government has unveiled a three-month public consultation on the proposed Knowledge Development Box, with submissions invited from businesses and the wider public. The proposed scheme, also known as a patent box, was announced in the Budget and is due to come into force next year. It will provide for… – Continue reading
As a means of encouraging the development of intellectual property (IP) in Italy, rather than elsewhere, a “patent box” preferential tax regime has been introduced with effect from January 1, 2015, at the same time as a restructuring of the country’s research and development (R&D) tax credit system. Following the… – Continue reading
December 3: Budget bill 2015—which would provide a tax credit for research and development (R&D) and would introduce a patent box regime—was passed by the Italian lower house on 30 November 2014. The budget bill is pending consideration by the Italian Senate. Changes to the legislation are possible during this… – Continue reading
YORKSHIRE businesses that invest in research and development could face higher tax bills if Chancellor George Osborne uses his Autumn Statement to water down tax breaks following complaints by Germany. One of Mr Osborne’s flagship policies is set to be reformed on Wednesday following the resolution of a dispute with… – Continue reading
Passage by the French assembly on 18 November 2014 of a draft Finance Bill for 2015 (which now will be presented to the Senate) Introduction by the French government on 12 November 2014 of a second draft amended Finance Bill for 2014 In general, the draft Finance Bill for 2015… – Continue reading
The latest work by the OECD tax policy team to review global tax rules is beginning to have an impact, particularly in Europe where Switzerland and Ireland are reforming their current tax rules, says Bill Dodwell, head of tax policy at Deloitte One unsurprising outcome of the OECD’s Base Erosion… – Continue reading
Meredith McBride in Hong Kong Though base erosion and profit shifting (BEPS) took the front seat during meetings between global leaders on November 15 and 16 at the G20 forum, country leaders also expressed concern over the taxation of intellectual property (IP). Patent box regimes in particular were mentioned as… – Continue reading
George Osborne is not going to want to do anything too controversial given the forthcoming General Election in May 2015, but does need to address some clear issues relating to public finances. According to the Institute for Fiscal Studies, the current budget deficit is estimated at just under £100bn and… – Continue reading
One of George Osborne’s flagship policies is set to be reformed in next week’s Autumn Statement following the resolution of a protracted spat with Germany over the controversial tax break. The so-called Patent Box took effect last year and allowed companies to pay lower tax bills on profits derived from… – Continue reading
The Finance Bill 2014 (the “Bill”), which was published 23 October 2014, proposes a package of measures which focuses on Ireland’s tax rate, regime and reputation. The changes seek to reinforce Ireland’s position as a top destination for multinational companies and emphasise the importance of real and substantive foreign direct… – Continue reading
