Home to 5,000 plus FDI projects, HCM City has comfortably remained Viet Nam’s growth engine, and it plans to make full use of its position to rise to international standards in many areas, Xuan Huong reports. Despite all the international and regional competition, Viet Nam has remained an attractive destination… – Continue reading
If Illinois small business owners were to collectively offset state and federal revenues lost annually due to corporations using offshore tax havens, they would each have to pay $4,570 in additional taxes a year. That what-if scenario is laid out in a recent report from the Illinois Public Interest Research… – Continue reading
As compared to past federal Budgets, Budget 2015 contained fewer (and arguably less controversial) international tax measures. Nevertheless, Budget 2015 did announce the Government’s intention to address taxpayer concerns relating to (i) the withholding obligations borne by non-resident employers that have non-resident employees that work in Canada, and (ii) the… – Continue reading
Turkey is to host a G20 international tax symposium next month to discuss developments to address Base Erosion and Profit Shifting (BEPS) and the exchange of information between tax administrations The event, organised by Turkish Ministry of Finance, also aims to ensure that developing and low-income countries benefit from the… – Continue reading
According to the most recent estimates, the quantity of goods carried by containers has risen from around 100 million metric tons in 1980 to about 1.5 billion metric tons in 2012. Out of these numbers, one container in every 11 that is engaged in global trade is either bound for… – Continue reading
Last September, the US Treasury Department announced new tax rules designed to crack down on the rising trend of “tax-inversion” deals in the pharmaceutical industry, as an increasing number of US firms had begun to pursue overseas acquisitions in attempts to relocate their legal addresses to non-US based headquarters to… – Continue reading
Section 55 of the Income Tax Act (Canada) (the “Tax Act”) contains an anti-avoidance rule that prevents a corporation from converting what would otherwise be a taxable capital gain into a tax-free intercorporate dividend. Section 55 deems a dividend not to be a dividend, but rather a capital gain, where… – Continue reading
In brief: At the recent G20 meeting in Washington, Treasurer Joe Hockey announced the establishment of a working group between Australia and the UK to develop initiatives to address so-called diverted profits involving multinational enterprises. What are the implications for multinationals doing business in Australia? Partner Martin Fry (view CV)… – Continue reading
BHP Billiton is contesting A$522 million (S$544.8 million) in Australian tax bills on its Singapore marketing operations up to 2010, after having paid almost no tax in Singapore since 2006, the global miner told an Australian Senate panel, reports the Business Times. The figures were released on Monday by a… – Continue reading
An OECD initiative on tax evasion is causing ripples around the world While a host of topics — from the necessity and the proposed scope of corporate tax reform, to corporate rate reduction and corporate inversions — are of major concern to those engaged in international tax, the overriding issue… – Continue reading
The Vietnamese unit of motor maker Honda and the Ministry of Finance still fail to reach an agreement on a preferential tax treatment the company is supposed to enjoy, thanks to which it refuses to pay nearly US$10 million in tax arrears. Honda Vietnam Co. Ltd. has been asked to… – Continue reading
HMRC has increased its scrutiny of potential tax avoidance among high-net-worth individuals following the launch of a specialist team, says law firm Pinsent Masons. The ‘Rising Stars’ team in HMRC, which focuses on high-net-worth individuals with growing assets, increased the number of investigations it carried out and the amount recouped… – Continue reading
April 24 — Pressure is increasing on the Treasury Department to address concerns over language in the anti-inversions Notice 2014-52 that experts say could hurt the ability of foreign insurers to take part in commonplace business combination deals. “This has had an impact not only on foreign insurance companies, but… – Continue reading
TOKYO — Two of the world’s largest manufacturers of the machinery used to produce semiconductors, Applied Materials of the United States and Tokyo Electron of Japan, on Monday dropped plans to merge after the Department of Justice said that combining their businesses would restrict competition. The proposed $10 billion deal… – Continue reading
Pfizer Inc. (NYSE:PFE) went big exactly a year ago when it announced a takeover offer for UK-based AstraZeneca plc (ADR) (NYSE:AZN). The company’s decision to lap up AstraZeneca was seen as opportunistic; it being laced with controversy on many accounts, with some allegations behind the company’s proposition to acquire AstraZeneca… – Continue reading
BHP Billiton is contesting $522 million in Australian tax bills on its Singapore marketing operations up to 2010, after having paid almost no tax in Singapore since 2006, the global miner told an Australian Senate panel. The figures were released on Monday by a Senate committee that is investigating corporate… – Continue reading
On Saturday 25 April, at the second session of the informal meeting of the Economic and Financial Affairs Council (ECOFIN), one of most important issues on the agenda was the further development of the Capital Markets Union concept, which was broadly supported by the ministers and Governors of central banks…. – Continue reading
When Burger King’s owners first announced last summer’s mega-deal to gobble up Tim Hortons, the fast-food firm’s executives downplayed a key reason why they were acquiring the Canadian coffee chain and relocating corporate HQ to Canada: to cut its taxes. “Tax wasn’t really the driver of this,” Daniel Schwartz, the… – Continue reading
KELLY NJOMBO, Lusaka THE Jesuit Centre for Theological Reflection (JCTR) says Government’s discussion to approve changes to the mineral royalty tax regime will result in the increase in primary budget deficit and possible limiting of expenditure. JCTR says the threat of job losses, placing the mines under care and maintenance… – Continue reading
NUMBER OF THE WEEK: 6.5 percent The tax rate at which companies could voluntarily repatriate their foreign earnings under the Invest in Transportation Act of 2015 ( S. 981). Senators Barbara Boxer (D-CA) and Rand Paul (R-KY) introduced the bipartisan proposal, offering ways to save the Highway Trust Fund. Funding… – Continue reading
Trade in today’s global era visualizes significant number of international transactions in form of transfer of goods, services, capital and intangibles. International transfers arise within the Multinational Enterprise group entities and are called intra-group transfer. What is actually paid by one entity to another entity in the intra-group transfer is… – Continue reading
Multinationals play such a large role in many nations’ budgets that effective control is crucial. Business Tax-base erosion cripples Africa 24 Apr 2015 00:00 Lisa Steyn Multinationals play such a large role in many nations’ budgets that effective control is crucial. Finance Minister Nhlanhla Nene says practices such as incorrect… – Continue reading
Arris stock on Thursday rose over 22 percent—leading the Nasdaq Composite index. The gain was due to an announcement that the company would acquire Pace, a U.K.-based telecommunications company. The deal will allow Arris to change its domicile to the United Kingdom, where it will enjoy a 21 percent tax… – Continue reading
The “Hound of Hounslow” day trader accused of helping trigger a Wall Street “flash crash” made more than £30 million profit dealing from his parents’ home in four years, the Evening Standard can reveal. FBI agents are investigating claims that Navinder Sarao, 36, transferred as much as £26 million to… – Continue reading
Arris Group Inc. agreed to buy British set-top box maker Pace Plc for about $2.1 billion and incorporate in the U.K. in a deal designed to save on taxes. Shares in Pace, one of Britain’s few global technology companies, rose as much as 44 percent. The acquisition will combine two… – Continue reading
FATCA 1. New FATCA IGA guidance notes On 3 February 2015, the Jersey Chief Minister’s Department published the latest version of the Guidance Notes on the Taxation (International Tax Compliance) (Jersey) Regulations 2014 in relation to the implementation of obligations arising under the intergovernmental agreements (IGAs) with the US and… – Continue reading
1 General news 1.1 HMRC organisation chart HMRC has published its latest organisation chart showing the names of senior management. One point to note is the number of senior people now in roles such as change management as opposed to being in pure technical roles. This clearly demonstrates the direction… – Continue reading
MPs say transfer pricing, though legal, presents challenges when determining if firms have evaded taxation and they want the practice criminalised. The portfolio committee on trade and industry has heard calls for the criminalisation of transfer pricing – a practice that, when abused, results in large corporations shifting profits offshore… – Continue reading
The Minister of Finance (Canada), the Honourable Joe Oliver, presented the Government of Canada’s 2015 Federal Budget (“Budget 2015”) on April 21, 2015 (“Budget Day”). Budget 2015 contains several significant proposals to amend the Income Tax Act (Canada) (the “ITA”) while also providing updates on previously announced tax measures and… – Continue reading
Finance Minister Joe Oliver faced formidable challenges, both economic and political, in delivering his first Budget. In a time of depressed oil prices, and mere months ahead of the next federal election, it appears he felt it was imperative to follow through with prior commitments to balance the budget, provide… – Continue reading
IF THE South African Revenue Service (SARS) focused on recovering money from transfer pricing abuses‚ Finance Minister Nhlanhla Nene probably wouldn’t have had to raise taxes by 1% in his budget speech‚ Judge Dennis Davis‚ head of the Davis Tax committee, told Parliament on Tuesday. He was briefing the portfolio… – Continue reading
Commissioner Chris Jordan delivers rebuke to multinational tech giants contesting evidence they gave to a Senate inquiry into corporate tax avoidance The tax commissioner, Chris Jordan, has delivered a public rebuke to multinational tech giants Apple, Google and Microsoft, vigorously contesting evidence they gave to a recent Senate inquiry hearing… – Continue reading
1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins The legal system of the Republic of Ireland is a common law system. In order to ensure consistency, a legal principle developed whereby courts were generally required to follow earlier relevant decisions. This doctrine of… – Continue reading
Mylan NV Executive Chairman Robert Coury made $22.7 million, including $1 million for his personal use of the drugmaker’s two corporate jets, in 2012 and 2013. At Israeli rival Teva, shareholders in 2012 balked at raising the chairman’s salary to $900,000 a year. The contrast highlights the sharp differences that… – Continue reading
MUMBAI/NEW DELHI: Markets fell 500 points on Monday. Punters’ worries about current tax disputes between Modi Sarkar and foreign portfolio investors (FPIs) being one reason why the Sensex dived. There has been a battle of phrases between FPIs and North Block. And it looks as if this will be a… – Continue reading
Companies would be forced to reveal any arrangements that are used to avoid tax, and those not paying their fair share of tax would be named and shamed on a “worst offenders” list, under a plan by the Greens. The party has released a discussion paper detailing policies to fight… – Continue reading
The Vietnamese unit of Germany’s Metro Cash & Carry will have to pay almost US$24 million in tax arrears after its wrongdoings have been unearthed in a transfer pricing inspection that concluded Monday. Metro Cash & Carry Vietnam Co. Ltd. began coming under scrutiny on suspicions of transfer pricing in… – Continue reading
NEW DELHI: Tax authorities have issued a fresh notice to UK-based telecom giant Vodafone seeking reassessment of tax returns for two years. The notice has been served under Section 148 of the Income Tax Act which seeks to deal with income that has escaped assessment. Sources said the notice seeks… – Continue reading
Vietnamese tax inspectors have found multiple violations at the local subsidiary of German retail giant Metro, estimating them to be worth VND507 billion (US$23.7 million). Of the total amount, Metro Cash & Carry Vietnam was ordered to immediately pay VND62 billion ($2.8 million) in arrears of income taxes for its… – Continue reading
“The business tax system today is inefficient, overly complex, and too riddled with loopholes,” said Mark Mazur, assistant secretary for tax policy at the U.S. Department of Treasury. So much so, in fact, that it can’t fulfill its function to be a world-class system, he noted. Mazur, speaking Tuesday at… – Continue reading
International plans for gathering and analysing data on the extent to which multinational companies are artificially shifting their profits to low-tax jurisdictions are at a disappointingly early stage, an expert has said. Heather Self of Pinsent Masons, the law firm behind Out-Law.com, also said that the global governments involved in… – Continue reading
In his recent article, “A Cursory Analysis of the Impact of Combined Reporting in the District”, Dr. Eric Cook claims that the District of Columbia’s (D.C. or the District) newly implemented combined reporting tax regime is an effective means of increasing tax revenue from corporate taxpayers, but it will have… – Continue reading
CHINA Tax Free Reorganisations • With circulars 109 and 116 jointly issued in December 2014 by the Ministry of Finance and the State Administration of Taxation, the Chinese authorities have relaxed the conditions for internal reorganisations. • Circular 109 deals with internal reorganisations. Provided the pertinent requirements are met, the… – Continue reading
The Union Finance Minister, Arun Jaitley, expressed concern over transfer pricing and several other measures taken by MNCs to avoid paying tax on international transactions. The Dollar Business Bureau Stressing on the need to keep a check on tax evasion by multi-national companies (MNCs), India has asked the G20 members… – Continue reading
THE xenophobic attacks that have rocked SA over the past two weeks will continue to dominate headlines this week. The crisis at Eskom will also be keenly watched following the appointment of Transnet CEO Brian Molefe as Eskom acting CE. Hopes are high that Mr Molefe — who has had… – Continue reading
Vodafone’s long-standing tax woes in India have hit another hurdle after the country’s income tax department asked the operator to re-file its 2009-10 tax return for re-assessment. An inside source told the Economic Times he didn’t know what triggered the request, but the tax authority is looking to review the… – Continue reading
The Senate inquiry into corporate tax avoidance will unexpectedly return on Wednesday after the Australian Taxation Office requested a supplementary public hearing to refute allegations made in evidence by former ATO executive Martin Lock. Mr Lock told the inquiry earlier this month that the Tax Office gives up “billions of… – Continue reading
Business is braced for a slew of new anti-avoidance measures after the UK general election next month as politicians compete on promises to raise billions of pounds from closing tax loopholes, reports the Financial Times. A cross-party consensus is emerging over the scope for a renewed crackdown. Last week Vince… – Continue reading
Technology companies with international operations are increasingly using global tax avoidance methods, despite growing opposition from the public and politicians in the U.S. and abroad. As this opposition fuels ongoing changes in tax rules, organizations must be able to quickly adapt their corporate structures and tax strategies to maintain a… – Continue reading
NEW DELHI: Tax authorities have issued a fresh notice to UK-based telecom giant Vodafone seeking reassessment of tax returns for two years. The notice has been served under Section 148 of the Income Tax Act which seeks to deal with income that has escaped assessment. Sources said the notice seeks… – Continue reading
