(CNS Business): The use of Cayman Islands funds as a wealth management tool for high net worth Latin American families was debated last week at the STEP LatAm Conference in Brazil, where kidnapping is a constant worry for the wealthy and demand for outbound investments is fuelled by privacy and… – Continue reading
Action 13 of the final package of reports issued by the Organisation for Economic Cooperation and Development (OECD) under the base erosion and profit shifting (BEPS) project focuses on a company group’s global value chain and transfer pricing policy, and introduces a standardized three-tiered approach to transfer pricing documentation—core documentation… – Continue reading
The European Commission recently published new rulings, the OECD published its base erosion and profit shifting (BEPS) final reports, and many countries are reviewing and reinforcing their transfer pricing rules—and France is no exception. Tax professionals in France have observed certain recent trends with regards to transfer pricing. The current… – Continue reading
Following the recent Irish budget statement (the “Budget”), the Finance Bill 2015 (the “Bill”) has been published and it implements the changes announced by the Irish Minister for Finance (the “Minister”). The Bill includes additional detail on: the new knowledge development box (“KDB”); and Ireland’s implementation of country by country… – Continue reading
On October 27, 2015 the U.S. Treasury Department and Internal Revenue Service published final regulations concerning the treatment of “mixed-use” projects financed with tax-exempt bonds. These new regulations have significant and immediate importance for tax planning and tax compliance of tax-exempt bond issuers and borrowers. A copy of the new… – Continue reading
A decision by the Federal Court of Australia has key implications for transfer pricing of intercompany financing transactions, as well as implication for other broader intercompany arrangements. The case concerns the transfer pricing implications of an intercompany loan agreement between an Australian taxpayer and its U.S. subsidiary (CFC) and whether… – Continue reading
The global climate for international tax is rapidly changing. The OECD, the EU and tax authorities around the world have focused attention on tax planning implemented by leading multinational companies. The OECD believes that tax planning and related structures lead to an annual revenue loss of US$100-240 billion. Since 2013,… – Continue reading
Brazil has reduced from 20 percent to 17 percent the maximum income tax rate required to designate a location that meets the other requirements as a low-tax jurisdiction for transfer pricing and other tax purposes. The change was made via Ordinance 488/2014 of the Ministry of Finance, published in the… – Continue reading
The Ministry of Finance yesterday held a press conference to explain causes on state budget balance that the public currently raise concerns about. Deputy Minister Do Hoang Anh Tuan said that the ministry would focus on collecting tax debts, fighting against transfer pricing and inspecting businesses over their financial obligations,… – Continue reading
Government action against tax avoidance has made the headlines on numerous occasions over the past few years, with significant developments in litigation, legislation and early tax collection, via a combination of follower notices and accelerated payment notices. Add to this the expansion of the disclosure of tax avoidance schemes, hallmarks… – Continue reading
MUMBAI: The government is set to ease a few pre-set conditions for offshore fund managers to allow private equity investors to shift base to India without attracting a tax on capital gains by relaxing safe harbour rules, people familiar with the matter said. The government is likely to allow a… – Continue reading
Profit-shifting has not paid off for petroleum multinational Chevron, slugged with a tax bill for $322 million thanks to a Supreme Court decision on Friday. Chevron has been under close scrutiny this year, particularly since a senate inquiry into tax-avoidance in April which also put mining giants BHP, Rio Tinto,… – Continue reading
Lawmakers at the European Parliament are set to vote on a controversial series of proposals to harmonize the corporate tax system in Europe in a move that will put them on a collision course with some member states which favor sovereignty over taxation. The EU lawmakers on the TAXE committee… – Continue reading
There was a time when, from a tax perspective, South Africa’s “mini budget” used to be a non-event. The main emphasis was on the annual budget speech delivered in February each year when they announced tax policy proposals. However, over the past few years there has been an increasing tax… – Continue reading
Taxation of Profits of Controlled Foreign Companies (CFC): Double Taxation Conventions must prevail over domestic rules The Superior Court of Justice (STJ) has recently decided a case involving the applicability of Brazilian CFC rules in cases in which the controlled company is located in a country with which Brazil has… – Continue reading
More than three quarters of UK companies feel their approach to tax planning conflicts with HMRC’s expectations, a new survey has found, as corporates struggle to strike a balance between the needs of investors and tax authorities Law firm Allen & Overy found that 78% UK corporates believe their approach… – Continue reading
Coca-Cola might owe an additional $3.3 billion in federal income taxes following an audit, says the Internal Revenue Service (IRS). Following a five year audit of the company, the IRS concluded that the company’s strategy of lowering its taxable income through transfer pricing, underestimates the amount the company should’ve been… – Continue reading
The Regulation of the Law Regulating Transfer Pricing was published last month and is based on the principle of free competition (arm’s length) where transactions between related parties should be carried out at market prices, i.e. those used in comparable transactions between independent parties in similar conditions. The regulation determines… – Continue reading
MTN has consistently prided itself as the foremost telephone company that is getting Nigerians talking the most. Now the South African company is about to set tongues wagging across networks with revelations that it has routinely been shipping billions of naira overseas to avoid paying its fair share of tax… – Continue reading
NEWARK, Del. — It may not summon up a sense of international intrigue like Geneva or Luxembourg, but this small city, just off the Interstate and down the road from Wilmington, can now boast that it has joined those more glamorous locales as a tax haven for art collectors. Fritz… – Continue reading
Rwanda has commissioned an audit into recent merger and acquisition deals involving foreign firms in its latest effort to clamp down on tax avoidance among multinational corporations. This comes amid growing concern that multinational companies move profits from the countries where they are generated and, in so doing, reduce national… – Continue reading
THE House of Representatives on Tuesday postponed its vote on the Income Tax (Amendment) (No 2) Act, 2015, which includes provisions for the introduction of transfer pricing rules in Jamaica. Minister of Finance and Planning Dr Peter Phillips agreed to postpone taking a vote on the Bill, also referred to… – Continue reading
According to recent estimates, Chinese investors represented the largest group of foreign investors in U.S. real estate in the second quarter of 2015 with $1.9 billion in acquisitions. In the last 12 months, Chinese investors acquired $5.9 billion in commercial U.S. real estate, and Asia was second overall to Europe… – Continue reading
Leading family offices in Latin America and the Caribbean are going through a transitional period, says Steven Cantor, managing partner of Cantor & Webb, a Miami-based law firm, reports the Financial Times. “As the world moves to tax transparency, with a crackdown on undisclosed tax savings in Swiss bank accounts,… – Continue reading
The New York billionaire is aiming his financial might at members of Congress who aren’t willing to cut deals on corporate tax policy. Sure, Carl Icahn might make money—lots of money—on his $6 billion stake in Apple Inc. if a political campaign he announced Wednesday to cut taxes on companies’… – Continue reading
Multinational oil giant Chevron has been hit with a tax bill of about $300 million after losing a landmark profit-shifting case that could have global implications for the way tax is assessed. The Australian Tax Office’s case in the Federal Court case has been closely watched by the tax and… – Continue reading
MUMBAI: Technologies that are developed in India but their patents registered in tax havens may come under the domestic tax net from the next financial year, when the country is expected to adopt a new world standard aimed at preventing abuse of double taxation avoidance agreements. Many multinational and local… – Continue reading
Introduction The Internal Revenue Service (IRS) recently replaced Revenue Procedure 2006-54 for requesting assistance under the mutual agreement procedure (MAP) article of US tax treaties, and Revenue Procedure 2006-9 for requesting advance pricing agreements (APAs). New Revenue Procedures 2015-40 and 2015-41 largely track draft procedures issued in 2013 (Notices 2013-78… – Continue reading
Oil and gas giant Chevron faces a massive tax bill after losing a long-running battle with the tax office over allegations the company used internal lending to reduce its Australian taxes. The Federal Court this morning ruled against Chevron in a landmark legal case that had argued the US multinational… – Continue reading
Major US investor Carl C. Icahn and the Chief Executive Officer of TechNet, Linda Moore, have both recently written letters to leading lawmakers pointing out that the passage of international tax reform by Congress has become a matter of extreme urgency. In his letter, Icahn announced that “the time has… – Continue reading
Cross-border transactions have always been a challenge to tax authorities India’s transfer pricing rules and the rising number of litigation over transfer pricing assessments have been a concern for the global business for some time. According to estimates by some experts, India has the highest number of transfer pricing litigations…. – Continue reading
On 21 October, the European Commission (“EC”) adopted its first decisions in its investigation into Member States’ tax rulings. The investigation, which began in June 2013, has also targeted tax rulings given to Apple and Amazon as well as Belgium’s so-called “excess profits regime”. Although the investigation is conducted under… – Continue reading
Chevron lost an appeal in Australian federal court that will see the US supermajor pay more than US$232 million (A$322 million) in back taxes, in addition to fines, after losing a case with the Australian Tax Office (ATO). The Aussie federal court ruled against Chevron, stating the company wrongly shifted… – Continue reading
Global assets under management are expected to climb to around $102 trillion by 2020 according to a new report from PwC. The report – Asset Management 2020 and beyond: Transforming your business for a new global tax world – notes that the boom in AUM is due to be caused… – Continue reading
its tax bulletins, the legislation will apply to transactions even between unconnected parties if the non-Jamaican party is in a tax haven. In addition, it will take into account the use of captive insurance companies, that is, insurance companies established by a parent group or groups with the specific objective… – Continue reading
“If we do not achieve growth, revenue will not increase. If revenue does not increase, expenditure cannot be expanded.” It is with this statement that the Minister of Finance set the tone of the Medium Term Budget Policy Statement (MTBPS) which he presented on Wednesday against a fiscal backdrop of… – Continue reading
Luxembourg and the Netherlands lost a bit of luster as tax havens for some of the world’s biggest companies this week, as the European Union fired its latest salvo aimed at multinational tax dodging. Yet the Netherlands is on pace to maintain its attractiveness as a tax-friendly address for multinationals,… – Continue reading
The Vietnamese arm of U.S. soft drink giant Coca-Cola has paid its 2014 corporate tax, worth some US$20 million, for the first time in two decades due to losses, according to a report the firm submitted to Ho Chi Minh City authorities in May. The taxable profit of the company… – Continue reading
Foretelling significant changes in tax structures around the world, newly released PricewaterhouseCooper (PwC) report reveals that the future of businesses is dependent on how well their asset managers deal with this emergent tax risk. Titled, ‘Asset Management 2020 and beyond: Transforming your business for a new global tax world’, the… – Continue reading
Indian equity markets retaining their early gains were trading in a range in early noon session, on value buying activities by market-participants. Sentiment got boost with the statement of finance ministry that the country will grow by 7.5 per cent in the current fiscal, slightly higher than international rating agency… – Continue reading
What has happened? On 5 October 2015 the OECD issued its final paper on BEPS Action 12 Mandatory Disclosure Rules, Action 12 – 2015 Final Report (Paper). In this Alert we highlight the main issues and recommendations for taxation reform raised in the Paper. The Australian Treasurer’s BEPS Press Release… – Continue reading
The European Commission today announced a decision that Luxembourg and the Netherlands granted selective tax advantages to two multinational corporate entities, and as such, these “tax advantages” are illegal under EU state aid rules. The EC concluded that the tax rulings granted by the tax authorities in Luxembourg and in… – Continue reading
Zambia Revenue Authority-ZRA- Commissioner General Berlin Msiska says Africa needs to work together to address illegal Financial Flows. Mr Msiska says international cooperation is required because illegal financial flows affect all regions of the continent. He says African Tax administrations can achieve a more effective and efficient relationship through initiatives… – Continue reading
Since 2002, there has been a steep escalation in transfer pricing disputes in the country, the ‘Taxsutra’s TP Trends Report’, is a perfect compendium which encompasses this escalation. The Chapter under which Transfer Pricing provisions were introduced was with the intent to ensure that there is no avoidance of tax…. – Continue reading
Ireland’s budget statement for 2016 (Budget) was delivered by the Minister for Finance last week. The Budget’s primary focus was on personal tax matters, which is somewhat unsurprising given the general election early next year. However, the Budget also contained two key announcements on Ireland’s corporation tax system. In line… – Continue reading
The new Indian Government, led by Prime Minister Mr. Narendra Modi, assumed office in May 2014 with the election promise to deliver on reviving economic growth, investor confidence and bringing consumer demand back on track. The key stated goal is to move away from a control-and-command economy towards a market… – Continue reading
Major tax administration reforms are expected after Kenya Revenue Authority (KRA) Commissioner General John Njiraini was made to cut short the release of quarter one performance on Monday following a call from State House. KRA has already moved to deepen its capacity by inviting former employees to boost its capacity… – Continue reading
RBI governor Raghuram Rajan has called for a transparent and predictable tax regime. His words are well-timed, coming as they do just before the Budget exercise starts. Investors want certainty and stability in the tax system. Recently, the government dropped all past demands of minimum alternate tax on foreign portfolio… – Continue reading
Carl Icahn, the iconic activist investor, has shifted, if only for today, his cross-hairs of contempt from the boardrooms of corporate America to the nation’s capital. Icahn sends members of Congress a word of warning Wednesday saw Carl Icahn warn several members of Congress a letter laying out his plans… – Continue reading
“FCF did not receive any state aid and … any finding in this matter would be immaterial to the FCA Group’s reported results,” FCA said in a statement. MILAN: Fiat Chrysler Automobiles (FCA) denied again on Tuesday having received state aid from Luxembourg in a tax-related case, adding any findings… – Continue reading
