Tax-driven “inversion” deals that let companies flee the U.S. tax system by relocating abroad, if only on paper, would be curbed under legislation introduced in Congress, as Pfizer Inc (PFE.N) pursues such a deal with rival Allergan Plc (AGN.N). Wisconsin Democratic Representative Mark Pocan’s bills likely have little chance of… – Continue reading
In a time of fiscal austerity, it is breathtaking to learn that Congress has allowed Fortune 500 companies to avoid an estimated $620 billion in federal taxes on earnings they are holding offshore. While the inaction by lawmakers on this issue may create the impression that there is nothing to… – Continue reading
NEW YORK, Nov. 9, 2015 /PRNewswire/ — Business executives cited an increased compliance burden as their biggest concern with the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting initiative (37.7 percent), according to an October Deloitte poll. Other concerns included double taxation of income (17 percent) and… – Continue reading
Transfer pricing by multinationals has cost South Africa an estimated R250 billion over three years and, with it, lost tax revenue. This is according to Sunia Manik, group executive for the large business centre at the SA Revenue Service (Sars), adding that it was being done through “service payments” made… – Continue reading
The UK is one of several countries to introduce voluntary disclosure schemes. More people are coming forward to regularise their affairs as they realise there is nowhere left to hide in this new world of tax transparency. Tax authorities and financial institutions are gearing up for the new automatic exchange… – Continue reading
The recent corporation tax controversy highlighted by US presidential hopefuls Hillary Clinton and Donald Trump is not damaging Ireland’s reputation as a place to do business, said the former chief executive of Apple, John Sculley. According to Mr Sculley, the controversy is simply part of US election fever. Known as… – Continue reading
First it was the scourge of public sector corruption, until now the mortifying spectacle of South Africa’s post-apartheid transition. Now, with the ground shifting beneath the world’s sclerotic economy – and the past few years have produced more tremors than ever in the 21 years of democracy – it’s a… – Continue reading
MINISTER of finance Calle Schlettwein said yesterday that the solidarity tax will be introduced as an income tax for individuals according to their income scale. He said the tax will also be a flat amount levied from juristic persons (closed corporations, partnerships, trusts and companies), based on the average per… – Continue reading
New law in Poland expands the requirements for transfer pricing documentation, and includes country-by-country (CbC) reporting. The new provisions essentially reflect the recommendations made in Action 13 the OECD’s base erosion and profit shifting (BEPS) project, and provide for CbC, master file and local file reporting. The legislation was passed… – Continue reading
The Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting action plan is likely to have a major impact on tax planning at multinational corporations by both tax professionals and corporate treasurers. Tom Driscoll, U.S. managing partner for international tax, transfer pricing, and indirect tax at Deloitte Tax… – Continue reading
On 5 October 2015 the OECD published the final package of recommendations to reform the international tax system – the “BEPS” Project. Base Erosion and Profit Shifting (BEPS) refers to tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations… – Continue reading
JOHANNESBURG – South African has lost R250 billion in the form of service payments over a three-year period, highlighting the significant risk base erosion and profit shifting (BEPS) is posing to the country’s tax base, a South African Revenue Service (Sars) official has said. Almost R80 billion of this were… – Continue reading
A question being considered in Australia—concerning country-by-country (CbyC) reporting—is whether an investment entity is to be excluded from the “group” for CbyC reporting purposes. A preliminary position being advanced is when an entity is not required to prepare consolidated financial statements for financial reporting purposes, then it would be excluded… – Continue reading
Technology company made the largest profit in its history in year to end of September Apple’s latest annual report indicates a substantial increase in the amount of tax it may be paying in Ireland. The latest annual report from Apple, filed last week in the United States, indicates a substantial… – Continue reading
Barbados and Slovakia signed a double tax agreement on October 28, 2015, to boost investment and trade prospects. The DTA allocates taxing rights to the two territories, to ensure that cross-border income is not taxed twice. It further stipulates that cross-border income from dividends will be subject to a withholding… – Continue reading
The finance ministry is streamlining safe harbour rules and advance agreements, two mechanisms to determine the price of services rendered by a multinational to its subsidiary in India. Safe harbour rules – directives on margins the tax authorities should accept for the transfer price declared by an assessee – have… – Continue reading
The time of gaming the international tax system is over for big business, following the endorsement of the OECD’s Base Erosion and Profit Shifting (BEPS) project Corporations have to realise that “playtime is over, now you have to come back to school and play with the new instruments”, said Pascal… – Continue reading
Treasury says making available documents detailing tax policies tailored for multinational firms would jeopardise ‘open and frank discussions’ The UK has joined Luxembourg, the Netherlands and Belgium in blocking attempts by a committee of MEPs to gain access to secret European archives that detail some of most controversial tax policies… – Continue reading
As procurement organizations evolve, they commonly adopt a different procurement operating model (POMs) at different stages of their development. A global KPMG survey of chief procurement officers (CPOs) found that 83% of organizations changed their POM within the last 5 years and just over half of them over the previous… – Continue reading
Hong Kong is the world’s second least transparent financial center, making it vulnerable to tax evasion, money laundering and other wrongdoing. It is topped only by Switzerland in a global survey by Tax Justice Network, a coalition of researchers and activists focused on tax avoidance issues. The United States ranks… – Continue reading
Pharmaceutical giant Shire, which is headquartered in Ireland for tax purposes, has agreed to buy US rare disease specialist Dyax Corp for about $5.9bn (€5.35bn), and potentially up to $6.5bn, while still pursuing a five- times larger unsolicited bid for biopharma firm Baxalta Inc. The Dyax deal, the latest in… – Continue reading
A number of member states are failing to tackle corporate tax avoidance despite media revelations and EU and national-level moves to close loopholes. “It’s clear that in the EU it is business as usual for multinational corporations who want to dodge the rules to lower their tax bills”, said Tove… – Continue reading
TORONTO (miningweekly.com) – Canada’s largest uranium producer Cameco expects to defend itself in court next year over a tax dispute with the Canadian Revenue Agency (CRA) about taxation years 2003, 2005 and 2006. The CRA was questioning Cameco’s practise of selling uranium at a low fixed price to its European… – Continue reading
On 21 October 2015, the European Commission decided that a tax ruling between Starbucks and the Netherlands should be considered illegal state aid. As a consequence, the European Commission ordered the Dutch State to recover the aid granted to a Dutch Starbucks group company (Starbucks Manufacturing EMEA B.V.), which is… – Continue reading
Suggest Easwar panel on Income Tax Act should also make safe harbour profit margins more realistic The justice R V Easwar committee on the Income Tax Act set up last week would do well to clarify whether payments for software should attract income tax or service tax, and make safe… – Continue reading
The justice R V Easwar committee on the Income Tax Act set up last week would do well to clarify whether payments for software should attract income tax or service tax, and make safe harbour profit margins more realistic, tax experts said. Tax demands based on ‘excessive’ advertising and promotional… – Continue reading
As the 2016 Presidential campaign heats up with debates and public appearances replete with the candidate’s opinions on the economy, ISIS, and education, among others, few candidates have mentioned the issue of corporate tax reform, especially as it relates to a level playing field between the U.S. and foreign markets,… – Continue reading
The Internal Revenue Service says some of America’s most successful companies have been shuttling money to avoid paying their share of federal income taxes. Microsoft is fighting IRS attempts to collect more than $2 billion from profit the software giant transferred between foreign affiliates. Amazon.com is fighting to keep $1.5… – Continue reading
Pfizer’s bid for $113bn Dublin-based drug maker Allergan is the biggest merger of the year, anywhere. It’s potentially good news for the Irish exchequer, which may gain a massive new taxpayer, and for businesses here like Arthur Cox, Allergan’s adviser on Irish corporate law. But a deal that may well… – Continue reading
A small team of European Union officials is spearheading an investigation that could force some of the world’s biggest companies to pay billions of euros in avoided taxes, Reuters reports. In an office block in one of Brussels’ less fashionable districts, the 10 Competition Directorate staff from across the bloc… – Continue reading
A spate of so-called “tax inversion” deals involving companies based in Ireland appears to be distorting the country’s foreign direct investment (FDI) numbers, The Irish Times reports. An OECD report suggests investment by Irish firms abroad more than doubled to US$75 billion in the first half of 2015. The study… – Continue reading
South African Tax Legislation: Proposed Amendments in an International Tax Context[1] This article sets out a brief summary of some of the proposed amendments introduced by recent South African draft Tax Bills. The article focuses on amendments in the context of international taxation. The draft Taxation Laws Amendment Bill, 2015… – Continue reading
The new rules require companies to file a “country-by-country” report as well as creating new specific documentation requirements. CbC report For the fiscal year beginning 1 January 2016, country-by-country (CbC) reporting will be compulsory for corporate groups whose turnover exceeds EUR750 million in the 12 months prior to the information… – Continue reading
Blast waves: smoke billows from the site of an explosion that reduced a parking lot filled with new cars to charred remains at a warehouse in northeastern China’s Tianjin municipality. Most of Bermuda’s major insurers and reinsurers had significant exposures to this disaster. (Photograph by Ng Han Guan/AP Photo) Tianjin… – Continue reading
Pfizer Inc. may be getting closer to breaking up and moving out. The largest U.S. drugmaker and Allergan Plc are considering combining operations, according to the Wall Street Journal. A deal would give Pfizer a way to move to a low-tax legal address abroad and gain valuable specialty drugs like… – Continue reading
The European Commission (Commission) has adopted a decision on 21 October 2015 on the tax rulings – also referred to as “comfort letters” – granted by Luxembourg to Fiat Finance and Trade (FFT) and by The Netherlands to Starbucks. Rejecting the decisions of domestic authorities in Luxembourg and The Netherlands,… – Continue reading
Opinion is divided on the extent to which corporates are ready for the country-by-country reporting requirements of the OECD’s base erosion and profit shifting project, as well as the work required to ensure compliance. Earlier this month the OECD presented the final package of measures for reform of international tax… – Continue reading
Viet Nam’s milk price is more expensive than that of many regional countries. Statistics from the department showed that Viet Nam has 13,000 foreign direct investment companies of which 4,098 transactions having signs of transfer pricing. — File Photo HA NOI (VNS) — The Ministry of Finance yesterday in Ha… – Continue reading
HM Treasury has published a consultation on the tax deductibility of corporate interest expense in the UK. The consultation has been prompted by the recent publication by the Organisation for Economic Co-operation and Development (“OECD”) of its final Base Erosion and Profit Shifting (“BEPS”) reports, in particular BEPS Action 4,… – Continue reading
The tax authorities continue to abide by the principle of “what is not forbidden is allowed”, using contradictory norms of the Russian Tax Code to their advantage. As a result, there is a surge in tax audits by territorial tax authorities during which they check whether prices charged in transactions… – Continue reading
Final recommendations about how multinational companies should be allowed to shift profits among different tax jurisdictions were issued this month, and the U.S. Congress has not yet indicated whether it will consider legislation in response to the proposals. Issued by the Organisation for Economic Cooperation and Development (OECD) on October… – Continue reading
The declining trend in the income tax department’s estimates of alleged income suppression by multinational companies would get buttressed, thanks to the new set of transfer pricing (TP) rules issued earlier this week. Currently, transfer pricing adjustments become necessary when the transaction price with related parties abroad reported by a… – Continue reading
A new report by Allen & Overy has revealed that corporate clients’ tax functions are now more concerned about risk management than tax minimisation. ATO sophistication, combined with heightened media interest, has forced tax directors to focus on compliance instead of dedicating their efforts to achieving the low tax rates… – Continue reading
The Ministry of Finance yesterday announced establishment of Transfer Pricing Inspection Agency under the Inspection Department of the General Taxation Department. This aims to fight against complicating transfer pricing which has resulted in budget revenue’s losses. The agency will act as a counselor for the Taxation General Department to work… – Continue reading
Parliament’s Special Committee on Tax Rulings recommended measures to make corporate taxes in the EU fairer and more transparent, after eight months of fact finding, in a vote Monday evening in Strasbourg, EU News reports. The report – prepared by co-rapporteurs Elisa Ferreira and Michael Theurer – was approved by… – Continue reading
MPs have proposed that the basic rate of profit tax should be reduced to 15% from the current of 18%, and taxation of distributed profit and payments equaled to it should be introduced, according to a draft bill on tax reform registered in the parliament by 114 lawmakers on Monday…. – Continue reading
In a BEPS seminar organised by the Federation of Enterprises in Belgium this week, with a special focus on the practical consequences for Belgian enterprises, a representative of the Belgian Ministry of Finance, Steven Van Elsuwe;, provided more details on the new legislative proposals that have been prepared so far,… – Continue reading
Multinationals have generated big-time revenues with its subsidiaries spread all over the world, which means huge profits and that’s taxable income. In recent years, a number of conglomerates – Amazon, Apple, Google and Starbucks – have engaged in so-called profit-shifting (profit allocation) via transfer pricing methods to pay minuscule taxes…. – Continue reading
Nearly three quarters of companies surveyed by legal practice Allen & Overy said that their approach to tax planning either sometimes or often conflicts with the domestic tax authority’s expectations. 350 senior-level executives operating in a range of jurisdictions were questioned by FT Remark on behalf of Allen & Overy… – Continue reading
The finance ministry on Tuesday set up a 10-member committee to review the Income-Tax Act to avoid litigation and improve ease of doing business, after solving past minimum alternate tax (MAT) cases and easing transfer pricing norms. The announcement came on a day when a World Bank report showed only… – Continue reading
