The regulatory environment surrounding the banking industry already constrains the behavior of banking groups in ways which obviate base erosion and profit shifting (BEPS) risks, the International Banking Federation (IBFed) said in a paper released on August 7. Entitled Base Erosion and Profit Shifting (BEPS): Why International Banks Are Different,… – Continue reading
With the UK announcing new tax rules for foreigners living in the country, the government has been careful not to damage the country’s appeal to wealthy foreigners. The “non-dom” tax status “plays an important role in allowing those from abroad to contribute to our economy”, says George Osborne, the UK’s… – Continue reading
A “legislative requirement” for large businesses to publish their tax strategy could create commercial confidentiality risks IN an age where large corporates continue to engage in tax avoidance or aggressive tax planning, compelling businesses to disclose their tax strategies is, at heart, a good idea. There is a risk, however,… – Continue reading
The Australia government on 6 August 2015 released two exposure drafts in relation to its multinational tax integrity measures. In the 2015 budget, the government announced a package of measures to address multinational tax avoidance. As part of these measures, the two exposure drafts would: (1) introduce the new OECD… – Continue reading
The latest estimate of the tax potentially underpaid by the UK’s biggest businesses suggests that “the era of billion-pound tax settlements might be over” with HM Revenue and Customs (HMRC) increasingly focusing on mid-tier firms, an expert has said. Heather Self of Pinsent Masons, the law firm behind Out-Law.com, was… – Continue reading
Only 23 percent of business leaders feel that recommendations from the OECD on base erosion and profit shifting will be successfully implemented, according to the findings of a new survey by Grant Thornton. Three quarters of business leaders would pay more taxes in exchange for greater clarity from authorities on… – Continue reading
The Barbados Government has taken key steps to meet the requirements of the Foreign Account Tax Compliance Act Intergovernmental Agreement (FATCA IGA) with the United States, Minister of Finance Christopher Sinckler said during a public consultation. Sinckler said: “With respect to legislative requirements, I am pleased to inform you that… – Continue reading
Surprising as it may seem, most of the advantages of the Cypriot Tax Regime were, up until recently, mostly directed to non- Cypriot Tax residents. This effectively meant that in order to enjoy the full benefits of the Regime one had to be a non-resident. The idea behind this was… – Continue reading
NAIROBI: The civil society in Kenya wants Parliament to join them in the push to end tax evasion through enactment of laws that enhance compliance from international trade. This, they argue, will boost revenue collection by the State. They say tougher laws will criminalise tax avoidance and spell harsher penalties… – Continue reading
Would businesses really be willing to pay more tax if they had more certainty on what is acceptable for cross-border tax planning? According to a recent Grant Thornton International Business Report, three quarters of business leaders would in fact be ready to pony up more taxes in exchange for greater… – Continue reading
On July 29, 2015, Charles Boustany (R-LA) and Richard Neal (D-MA) released a bipartisan discussion draft of proposed Internal Revenue Code (the “Code”) amendments that would cut the United States income tax rate on corporate profits generated from patents and certain other intellectual property to approximately 10% (the “Tax Rate… – Continue reading
Ukraine’s President, Petro Poroshenko, has ratified three acts containing changes to tax law in the areas of transfer pricing, the obligations of taxpayers, and tax rules for non-profit organizations. The first, “On Amendments to the Tax Code of Ukraine Concerning Transfer Pricing,” increases the thresholds for companies’ transactions that will… – Continue reading
For the third year on the trot, Shell service stations generated billions of dollars and revenue but not a cent in company tax. In fact the owners of the sunny yellow servos reported tax benefits in all three years despite total sales which may be in excess of $60 billion…. – Continue reading
Prime Minister Narendra Modi needs to offer much more than just his best intentions to clean up India’s whimsical tax regime to help convince insurers. Companies from Allianz SE to American International Group Inc. are avoiding offering tax-liability coverage in India’s cross-border mergers and acquisitions market because of a relatively… – Continue reading
Australian Taxation Office New or updated materials on ATO website, including: Reminder: Taxable payments annual report due 28 August Remission of penalties: information about remission of penalties following a tax dispute In focus: Procurement hubs of Australian multinational enterprises: the ATO is reviewing arrangements involving offshore entities that are being used… – Continue reading
Shire, the giant pharmaceutical company that relocated its head office from the UK to Ireland for tax reasons a number of years ago has surprised investors by launching a US$30bn hostile bid to acquire the American company, Baxalta, which is also involved in the manufacture of drugs to combat rare… – Continue reading
LONDON–(BUSINESS WIRE)–Three quarters of business leaders would pay more taxes in exchange for greater clarity from authorities on what is acceptable, according to the Grant Thornton International Business Report (IBR), a global survey of 2,580 businesses in 35 economies. And while few expect a global agreement any time soon, the… – Continue reading
MONTRÉAL, Aug. 5, 2015 /CNW Telbec/ – Three quarters of business leaders would pay more taxes in exchange for greater clarity from authorities on what is acceptable for tax planning, according to the Grant Thornton International Business Report (IBR), a global survey of 2,580 businesses in 35 economies. And while… – Continue reading
Microsoft Corp.’s stockpile of offshore profits rose to $108 billion, with a 17 percent increase over the past year as the company continues reaping profits in low-tax foreign jurisdictions. The company crossed the $100 billion mark, making it just the second U.S. corporation — after General Electric Co. — to… – Continue reading
On May 20, 2015, the U.S. Treasury Department (“Treasury”) released five sets of proposed revisions to the U.S. Model Income Tax Convention (“Model Treaty”) for public comment. The Model Treaty was last updated in 2006. The purpose of the proposed revisions is to ensure that the United States maintains the… – Continue reading
The Davis Tax Committee’s First Interim Report on Estate Duty (“DTC Report”) was released for public comment on 13 July 2015. In essence, the DTC Report proposes that “a highly progressive tax that patches loopholes, helps provide equality of opportunity and reduces the concentration of wealth, must be implemented”. The… – Continue reading
Romanian prosecutors have completed its investigations into the alleged fraud committed at a local Lukoil refinery and on August 4 indicted the Russian-owned Petrotel refinery, its Russian director-general and five other officials. Prosecutors estimate the losses to the state at RON 7.6bn (€1.76bn), and have seized shares and bank accounts… – Continue reading
Axa Wealth International saw its funds under management grow by 3% to reach £9.1bn over the first half of 2015, despite a changing distribution landscape creating “unsettled” conditions. Following the release of Axa Wealth’s H1 2015 results, Mike Foy, managing director at the company’s international division, said increasingly fluid distribution… – Continue reading
On 11 July 2015 a new Corporate Income Tax Regulation (CITR) was approved in Spain, introducing, amongst other things, amendments to the Spanish transfer pricing reporting requirements. The new requirements largely reflect the recommendations made by the OECD with respect to Action 13 of the OECD Base Erosion and Profit… – Continue reading
New Delhi, Aug 3: India has signed its first unilateral roll back Advance Pricing Agreement (APA), bringing certainty to tax liability of a US-headquartered multinational company for a nine year period. This is significant as this agreement between the central board of direct taxes (CBDT) and the taxpayer comes within… – Continue reading
The tax and in particular the transfer pricing arrangements of multinationals is currently under the spotlight both internationally, through the OECD/G20 BEPS project, and domestically in Australia, by way of the Senate inquiry into corporate tax avoidance. This has resulted in new legal measures being adopted (such as the DPT… – Continue reading
This article is the third in our current three part series discussing various impacts of the Organisation for Economic Co-operation and Development’s (OECD’s) efforts to address the perceived global tax problem of base erosion and profit shifting (BEPS). The first article provided an overview of the key aspects of the… – Continue reading
Documents filed in the Federal Court on an unrelated matter have highlighted how little profit Jeep has made despite turning over almost $5 billion in six years. US car giant Jeep and its associated brands may not be paying enough tax in Australia, a document filed in the Federal Court… – Continue reading
On July 27, 2015, the U.S. Tax Court issued a stunning rebuke to the IRS by invalidating the part of the Internal Revenue Services’ (IRS) cost-sharing regulations under code section 482 that says taxpayers have to take into account, among other costs, the costs of stock-based compensation. The Altera decision… – Continue reading
First it was three years, now it’s three months. The Senate’s attempt to pass a multiyear highway bill ran off the road this week after House Republicans announced they will adjourn one day early for the month-long August recess. The House’s early departure forced the Senate to acquiesce to a… – Continue reading
Finland’s print media carries a mixed bag of headlines this Thursday, from former business bosses moving to tax-soft Portugal to studio apartment rents rising fast outside Helsinki. Neutral zone Åland is also under scrutiny, and the boat industry, at least, is doing well. Top tabloid Iltalehti splashes its front page… – Continue reading
Donald Trump did not like the tax reform Ronald Reagan signed into law in 1986. In an op-ed in The Wall Street Journal, he called it “one of the worst ideas in recent history.” The reason for his dislike was that the reform put the kibosh on real estate tax… – Continue reading
While preparing its bid for Tim Hortons Inc. last year, Burger King Worldwide Inc. initially wanted to set up the new parent company of Canada’s iconic supplier of double-doubles and maple-glazed doughnuts across the Atlantic in Britain, to avoid taxes. Miami-based Burger King’s first offer to buy the doughnut chain… – Continue reading
On July 17, 2015, the Internal Revenue Service (IRS) released three new “practice units,” each examining a particular type of transaction involving a controlled foreign corporation (CFC). The IRS develops practice units internally for use both as training materials and as job aids for examiners. Practice units are not formal… – Continue reading
Companies and govts have been playing the cat-and-mouse game for several decades on transfer pricing Only a naivete would think of Hilary Clinton’s proposal last week to scale up the rate of capital gains tax as a mere concept to streamline America’s tax rate structure. It is being perceived as… – Continue reading
Governments that dole out tax subsidies to big companies shouldn’t be allowed to reap multibillion-euro windfalls if the European Union orders them to claw back the aid, lawmakers probing tax loopholes said. Instead, the EU should consider changing the law so that money is shared among neighboring nations that played… – Continue reading
Tax savings drove the acquisition strategy of Valeant Pharmaceuticals International Inc. and led to Burger King’s move to Canada, according to a U.S. Senate committee report. Taxes appear to be much more important to the deals than the companies say, according to an advance copy of the report and testimony… – Continue reading
MUMBAI: The identity of taxpayers who opt for an advance pricing agreement (APA) in the field of transfer pricing will continue to remain confidential. Such information cannot be made available under the provisions of the Right to Information Act (RTI), according to the Central However, responding to a second appeal… – Continue reading
If former Fiat Chrysler Australia boss Clyde Campbell goes down over allegations he misused tens of millions dollars of company money, he might just threaten to take the entire Australian operation of the global automaker and several executives with him. Mr Campbell on Wednesday opened the door for a tax… – Continue reading
Consultation on the ATO’s practical guide for offshore marketing hub arrangements is kicking off in August. The guide may also assist taxpayers with offshore intellectual property (IP) hubs. Here is what you need to know if you market Australian produced goods offshore or have centralised your IP offshore. Do you… – Continue reading
On 25 July 2015 the Cabinet of Ministers of Ukraine published an order on the conclusion of advance pricing agreements (“APA”) in respect of controlled transactions for transfer pricing purposes* (“the APA Order”). The APA Order replaces the former procedure for the conclusion of APAs which became outdated due to… – Continue reading
These proposals can be implemented individually or as part of other reforms that may be in the pipeline PKF wishes to contribute its part towards the next budget implementation and for this purpose it has researched new areas which in its opinion warrant attention by the government during the public… – Continue reading
An investor, who purchased shares of Silver Wheaton Corp. (USA) (NYSE:SLW), filed a lawsuit in the U.S. against Silver Wheaton Corp. in connection with certain allegedly false and misleading statements made between March 30, 2011 and July 6, 2015. Investors who purchased a significant amount of shares of Silver Wheaton… – Continue reading
There is a rising trend that many start-ups incorporate their ultimate holding companies abroad, especially in Singapore for various reasons with tax being one of the top 3 factors for such decisions. Some of them have restructured the holding structures after few months of direct Indian holding to accommodate requests… – Continue reading
Kenya collected 1.001 trillion shillings ($10 billion) in the fiscal year to end-June, a 3.86 percent increase from the previous year, the Treasury said on Wednesday. Officials in East Africa’s biggest economy are aiming at increasing tax collections to fund several infrastructure projects, including a new railway, and pay for… – Continue reading
GOMA, DEMOCRATIC REPUBLIC OF CONGO—The Democratic Republic of Congo’s biggest-ever corruption probe was called off without an official explanation, according to both a Congolese lawmaker and a government spokesman. Investigators were looking into fraud that may have cost the government more than $3 billion. It was an investigation of alleged… – Continue reading
There has been much recent focus on tax structures employed by multi-national corporations. This has led to an initiative, spearheaded by the OECD, to combat “base erosion and profit shifting”, or BEPS. The shipping industry is likely to be affected both directly and indirectly by the BEPS initiative – directly,… – Continue reading
Introduction The Cyprus Government has announced a number of proposed tax incentives aimed at encouraging economic activity and attracting inward direct investment. It has also submitted a number of draft laws to the House of Representatives to implement the new provisions of the EU Parent-Subsidiary Directive, to simplify the tax… – Continue reading
Blaming foreigners for homegrown economic woes is a tradition of sorts in Washington. In recent years, the favored scapegoat has been China and its folkloric trade indiscretions. But, lately, some have taken to demonizing foreign companies for the sins of a broken U.S. corporate tax system. Given the importance of… – Continue reading
A U.S. Senate investigative subcommittee, which has used its power for more than a decade to scrutinize corporations and financial institutions for wrongdoing, is shifting its focus to keeping tabs on the government. The U.S. Senate Permanent Subcommittee on Investigations is slated to hold its first hearing under new leadership… – Continue reading
