Category: Royalties

Cayman Islands / Intellectual Property / Ireland / Legislation / Royalties / Tax Planning / USA

Ireland’s tax regime nurtures innovation in avoidance

Posted On: October 7, 2014

A tax-based industrial policy will not produce an innovative economy, writes James Stewart High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Email ftsales.support@ft.com to buy additional rights. http://www.ft.com/cms/s/0/bde702e4-4d5e-11e4-bf60-00144feab7de.html#ixzz3HKJXRQha Irish… – Continue reading

EU / Gibraltar / Ireland / Offshore Companies / Royalties / Spain / State Aid / Tax competition / United Kingdom

European Commission extends probe into Gibraltar’s corporate tax regime

Posted On: October 1, 2014

The European Commission has extended the scope of its investigation into whether Gibraltar’s corporate tax regime favors certain companies, in breach of EU state aid rules. Related Stories Brussels to accuse Apple over illegal Irish tax deals: FT Reuters EU says Ireland swapped Apple tax deal for jobs Reuters EU watchdog to… – Continue reading

Brazil / Legislation / Offshore Investments / Royalties / Withholding tax rules

Brazil: Cross-Border Payments For The Use Of Offshore Data Centers – Taxation In Brazil

Posted On: September 23, 2014

Interpretative Act (Ato Declaratório Interpretativo) No. 7, of August 15, 2014, issued by the Brazilian Internal Revenue Service (Receita Federal do Brasil – RFB), hereinafter referred to simply as IA 7/2014, deals with the taxation of cross-border payments for the use of data centers located abroad (i.e. based outside Brazil), known… – Continue reading

Apple / Base Erosion & Profit Shifting / EU / G20 / Google / Ireland / Loans / Royalties / Tax competition / Transfer pricing / Treaty Abuse

Big economies take aim at the firms running circles around their taxmen

Posted On: September 20, 2014

POLITICIANS in the rich world like to splutter about the ever more elaborate dodges that big multinational firms undertake to minimise their tax bills. But doing something about them is trickier. America’s Congress is struggling to agree on ways to stop companies “inverting”—switching domicile to reduce tax bills (see article)…. – Continue reading

Base Erosion & Profit Shifting / EU / G20 / Hybrids / Legislation / Luxembourg / OECD / Permanent establishment / Royalties / Tax competition / Transfer pricing / Treaty Abuse / USA

International Tax Alert: OECD Releases BEPS Papers

Posted On: September 18, 2014

Yesterday saw the release of the first set of deliverables under the OECD’s project on base erosion and profit shifting (BEPS).  These constitute the “building blocks” for an internationally agreed and co-ordinated response to government and media concerns in recent years about the perceived way in which shortcomings in relevant… – Continue reading

Australia / Canada / Court cases / Double Tax Treaty / Intellectual Property / Royalties / Withholding tax rules

Federal Court hands down software tax decision

Posted On: September 10, 2014

The Federal Court has handed down its decision in the case of Task Technology v Commissioner of Taxation in relation to the tax treatment of specific software payments. The case related to payments made by Task to CaseWare International Inc (CWI) for the right to market and distribute CWI software to end users… – Continue reading

Banking Secrecy / India / Offshore Banking / Offshore Investments / Royalties / Switzerland / Tax Laws / Transfer pricing

PA accord between India and Switzerland to usher in new era of tax cooperation between the nations

Posted On: September 5, 2014

(India and Switzerland are…) NEW DELHI: India and Switzerland are finding it difficult to break a deadlock over sharing information on secret bank accounts held in the European nation but both sides are close to finalising the first accord on a bilateral advance pricing agreement that will allow taxpayers to… – Continue reading

China / Controlled Foreign Companies / Royalties / Tax evasion investigations / Transfer pricing

China’s SAT Investigates Transfer Pricing

Posted On: August 28, 2014

In its ongoing efforts to control tax evasion, China’s State Administration of Taxation (SAT) has recently published an instruction (Tax Office General Fa [2014] No 146), calling on national and local tax bureaus to investigate transfer pricing practices of Chinese enterprises. Under scrutiny by the SAT are all transactions involving… – Continue reading

AbbVie / Covidien / Dividends / Intellectual Property / Inversion / Ireland / Japan / Legislation / Royalties / Tax competition / USA

Broken levy: How U.S. tax law encourages inversions

Posted On: August 26, 2014

An innocuously named species of transaction has inspired a political furor this summer. After a number of U.S. companies announced plans to move overseas in so-called inversion deals, Sen. Carl Levin proposed banning them outright. President Barack Obama called the companies unpatriotic. Because of the controversy, Walgreen Co. backed away… – Continue reading

Dividends / Residence / Royalties / Tax treaties / Withholding tax rules

Local Law Shopping Through “Derivative Benefits” re: Tax on Foreign Income

Posted On: August 9, 2014

Unlike U.S. persons who are subject to U.S. federal income tax on their worldwide income, foreign persons generally are subject to U.S. taxation on two categories of income: (i) certain types of passive U.S.-source income (e.g., interest, dividends, royalties and other types of “fixed or determinable annual or periodical income,”… – Continue reading

Canada / Dividends / Loans / Royalties / Tax Information Exchange Agreements / United Kingdom / Withholding tax rules

Canada, UK Revise Double Tax Agreement

Posted On: July 23, 2014

Canada and the UK on July 21, 2014, signed a protocol to their Double Tax Agreement that amends its withholding tax and information exchange provisions. The Protocol includes an exemption from withholding tax for payments of interest made in respect of loans between persons at arm’s length. The headline withholding… – Continue reading

Dividends / Iceland / Royalties / Switzerland / Tax treaties / Withholding tax rules

Switzerland, Iceland Sign Double Tax Pact

Posted On: July 17, 2014

Switzerland and Iceland have signed a new double taxation agreement (DTA) which lowers withholding tax rates and provides for the exchange of information in line with international standards. It will replace the existing DTA, signed in 1998. The treaty sets a withholding tax exemption for dividend payments from significant holdings… – Continue reading

Dividends / Israel / Legislation / Offshore Trusts / Panama / Permanent establishment / Real Estate / Residence / Royalties / Tax treaties / Withholding tax rules

Your Taxes: Israel to sign tax treaty with Panama

Posted On: June 25, 2014

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

Intellectual Property / Offshore Companies / Offshore Morality / Permanent establishment / Royalties / Tax Planning

Your Taxes: Going International

Posted On: June 18, 2014

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

Dividends / Nigeria / Permanent establishment / Residence / Romania / Royalties / Tax treaties / Withholding tax rules

Administration of withholding tax (2)

Posted On: June 17, 2014

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

Cyprus / Dividends / OECD / Permanent establishment / Residence / Royalties / Tax treaties / United Arab Emirates

Cyprus: New Cyprus-UAE Double Tax Agreement Takes Effect

Posted On: June 10, 2014

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

Base Erosion & Profit Shifting / Finland / India / Microsoft / Nokia / Price Waterhouse Coopers / Royalties / Tax evasion investigations / Tax Planning Failures

Nokia India, Finnish parent discuss tax evasion in emails

Posted On: April 6, 2014

The department had slapped a tax demand of Rs 2,080 crore on the company last year while re-opening the assessment for AY 2006-07 and 2007-08. As Finnish phone-maker Nokia strives to meet the April 30 deadline for sealing the $7.2 billion deal with Microsoft, its tussle with the Indian tax… – Continue reading

Base Erosion & Profit Shifting / Bermuda / Ireland / Netherlands / OECD / Offshore Companies / Royalties / Tax competition / Tax treaties

Corporate Tax: OECD’s Saint-Amans says “Double Irish Dutch” sandwich tax scheme will be axed

Posted On: April 6, 2014

Corporate Tax Reform: The Organisation for Economic Co-operation and Development (OECD) held a briefing and webcast at its Paris headquarters Wednesday on its Base Erosion and Profit Shifting (BEPS) project and Pascal Saint-Amans, the director of the OECD’s tax centre confirmed that “Double Irish Dutch” sandwich tax schemes, which involve… – Continue reading

Apple / Base Erosion & Profit Shifting / EU / Google / Ireland / Microsoft / OECD / Royalties / Tax treaties

Multinationals face new rules on aggressive tax avoidance

Posted On: March 27, 2014

OECD plan to make practice of shifting locations ineffective New rules aimed at preventing the type of aggressive tax avoidance schemes run by some of the largest multinational employers here will begin to be introduced in September, according to a draft report seen by The Irish Times . Structures that artificially shift… – Continue reading

Andorra / Argentina / Automatic Exchange of Information / Dividends / Guernsey / Isle of Man / Jersey / Royalties / Switzerland / Tax Information Exchange Agreements

Switzerland Revives DTA With Argentina

Posted On: March 24, 2014

Switzerland and Argentina have recently signed a new agreement for the avoidance of double taxation with respect to taxes on income and on capital. The treaty replaces the provisional agreement of 1997 and provides for the exchange of information upon request, in line with the current international standard. This is… – Continue reading

Base Erosion & Profit Shifting / Corruption / Intellectual Property / Legislation / OECD / Royalties / South Africa

Developing countries ‘lose taxes to profit shifting’

Posted On: March 24, 2014

STUDIES show multinationals shift profits of $365bn a year from developing to developed countries through transfer pricing mechanisms, the South African Revenue Service (SARS) said on Tuesday. Over three years South Africa has seen “hundreds of billions of rand” leaving in royalties, management and service fees and intellectual property payments,… – Continue reading

Base Erosion & Profit Shifting / China / Dividends / India / Italy / Loans / Malaysia / Offshore Companies / Philippines / Royalties / Singapore / Thailand / USA / Vietnam / Withholding tax rules

How to Get Your Profits Out of China

Posted On: March 11, 2014

BEIJING – Wholly Foreign Owned Enterprises (WFOEs) are able to repatriate funds out of China in a variety of forms, for which tax implications vary according to the form of repatriation used and the Double Taxation Agreement (DTA) in place between China and the recipient country. The four most commonly… – Continue reading

Base Erosion & Profit Shifting / India / Royalties / Tax treaties

Aligning tax with the times

Posted On: March 10, 2014

The aggressive approach of Indian tax authorities on transfer pricing and international tax matters underlines the government’s intention of taking strong action to defend its tax base. When it comes to taxation of cross-border transactions, India’s inclination to widen the source-based tax rules is clearly demonstrated by the retrospective amendments,… – Continue reading

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