EUROPEAN M&A DOS AND DON’TS FOR NON-EUROPEAN BUYERS Inbound M&A in Europe by non-European buyers increased in 2014 by 68.6% compared to 2013, representing over a third of USD 901.4 billion total European M&A.1 For non-European buyers the basic framework of transactions may be similar, but there are a number… – Continue reading
Bangladesh authorities are working with counterparts abroad to recover proceeds of corruption (‘stolen assets’), in terms of the UN Convention Against Corruption (UNCAC), Bangladesh Bank (BB) Governor Dr. Atiur Rahman has said. The central bank chief disclosed this while speaking at an event title Addressing the Linkage Illicit Flows and… – Continue reading
Even as the government is losing no opportunity to emphasise its commitment to a transparent and predictable tax regime, it’s epic seven year tussle with Vodafone is not showing any signs of losing steam. The income tax department is back in pursuit of the British telecom giant and has issued… – Continue reading
Promising a ‘modern tax system’ with low and globally competitive rates, Finance Minister Arun Jaitley has assured foreign investors against any retrospective action and said taxpayers will be seen as “partners and not as potential hostages or victims”. For domestic taxpayers also, the rates need to be low as taxes… – Continue reading
Nothing is certain in India except death and tax disputes. Ask foreign portfolio investors: they now face demands for past dues of as much as $6.4 billion. The wrangle stems from the Minimum Alternative Tax, or MAT, which officials say leads to a 20 percent levy on capital gains by… – Continue reading
Members of both houses of Congress in Washington D.C. are working to end offshore tax deals corporations are using to cut costs. “These companies, these corporations, want to avoid paying their fair share of taxes in the United States, sometimes billions of dollars and yet they want life to go… – Continue reading
For the majority of the public, including small business owners, Tax Day might not be our favorite time of year. However, it remains an important day because it means paying our dues for the numerous public benefits we receive, from our infrastructure and roads to our education system to our… – Continue reading
Lee Curthoys, corporate tax lead at Radius, looks at Singapore’s changing transfer pricing regulations and tells us what we need to know. For a number of reasons, ranging from public safety to proximity to other Asian markets, Singapore is a popular destination for businesses looking to expand globally. In fact,… – Continue reading
The outlook for uranium, moribund for some time, is looking up. And that means shares of Cameco Corp., the Saskatoon-based miner one analyst calls “the only real blue-chip stock in the sector,” are up, too – about 20 per cent from their 52-week lows. The stock has received a host… – Continue reading
“Tax policy and administration should incentivise compliance. They should be administered fairly, transparently, with minimum discretion, with no harassment of taxpayers but also ensuring that tax evasion is dealt with firmly.” Promising a ‘modern tax system’ with low and globally competitive rates, Finance Minister Arun Jaitley has assured foreign investors… – Continue reading
When Hillary Clinton recently borrowed Elizabeth Warren’s talking points and claimed “the deck is still stacked in favor of those at the top” (in our economic and political system) against regular working people, did she mention reforming the tax code — and then offer any solutions? The simple answer is… – Continue reading
Starwood Hotels & Resorts Worldwide Inc. may need to accommodate activist shareholders with a merger or buyout. Starwood, which owns high-end hotel chains such as W and Westin, has one of the worst stock-return and growth outlooks in the industry. It’s also entering the second month of searching for a… – Continue reading
Last week some of Australia’s biggest and richest companies voluntarily fronted up to a senate inquiry on corporate tax avoidance. Bigwigs from big brands, including Apple, Google, Microsoft, Rio Tinto, BHP Billiton and Fortescue Metals, squirmed under the spotlight as they were grilled about how they (legally) shift profits offshore… – Continue reading
Tax inspectors conducted last year 130 tax inspections which included an analysis of the affiliation relations of the taxpayer and the transfer prices applied as part of the transactions undertaken with the identified related parties, says Transfer Pricing Services (TPS). “Last year were conducted a third of the total number… – Continue reading
Get three tax advisers in the same room and they will come up with at least four definitions of tax avoidance: put in a couple of members of the public and the total will double. There are a few purists who dispute that tax avoidance exists – either something is… – Continue reading
ENERGY giant Woodside Petroleum says its Singapore office was set up for marketing, not tax minimisation. “THE office in Singapore for us is actually not set up at all for tax optimisation, it’s set up because that’s where marketing is done,” chief executive Peter Coleman told Woodside’s annual general meeting…. – Continue reading
Corporate treasury departments will have to start complying with International tax rules and provide documentation for transactions according to recent reports. G20 leaders attempted to reform the international tax system in July 2012 by setting up the Base Erosion and Profit Shifting (BEPS) project. This task was given to the… – Continue reading
Wealthy Americans are running out of ways to hide their money. The IRS has been relentless in prying open the secret Swiss bank account—dozens of Swiss banks are cooperating with the agency. Just last month, a settlement with the private bank BSI revealed bankers used coded language and nameless credit… – Continue reading
Top Democrats in both the House and the Senate are bringing back legislation to crack down on offshore tax deals. Senate Minority Whip Dick Durbin (D-Ill.), Rep. Sandy Levin (D-Mich.) and five other Democratic lawmakers are proposing to ban companies that shift their legal address abroad and score a lower… – Continue reading
A Conservative Government would not raise value-added tax (VAT), income tax, or National Insurance contributions (NICs), the party’s manifesto says. The manifesto confirms several pre-election promises. It includes a commitment that the Conservative Party will raise the personal (tax-exempt) allowance to GBP12,500 (USD18,439) and the threshold for the 40 percent… – Continue reading
Within the current discussion of corporate tax there are a number of terms used to describe the corporate strategies and behaviours involved, such as “tax minimisation” or “tax avoidance”. There are also other terms used in the academic accounting literature on tax. This can result in confusion about what exactly… – Continue reading
Israel joined the OECD in 2010. Background The Organization for Economic Cooperation and Development is spearheading a concerted effort to help governments around the world collect more taxes. The OECD is doing so by issuing a series of recommendations for tightening up corporate and personal tax measures. Individual governments are… – Continue reading
One in three wealthy people who may be dodging tax will get a call or personal visit by the Australian Taxation Office as it moves to ensure the richest Australians and private companies pay their fair share of tax. The ATO wants to beat its 2013-14 rate of raising $1.1… – Continue reading
NEW YORK • When it comes to taxes, corporate America is getting a bit less corporate. And a bit less American. Fueled by a wave of inversions, a record 54 companies in the Standard & Poor’s 500 Index of leading U.S. firms are now at least partially exempt from the… – Continue reading
Tax directors at many organizations anticipate their companies will grow by entering into new domestic and international markets in the years ahead, according to a new survey by BDO USA. In a sign of an improving economy, 50 percent of the 100 tax directors at $1billion-plus public companies surveyed by… – Continue reading
As the above title indicates (it is only a modest exaggeration), the Treasury Greenbook regarding the FY 2016 budget proposes a radical restructuring of the system for U.S. taxation of foreign income of U.S. multinational enterprises (MNEs). Some Congressional players have suggested that these proposals are an opening bid in… – Continue reading
New Delhi, April 15 (IANS): The Supreme Court on Wednesday said that while the tax authorities could move under the law to raise tax claims against Vodafone, in another case involving the de-merger of its towers business, the assets transfer, as such, cannot be blocked. The apex court bench of… – Continue reading
April 14 — When it comes to taxes, corporate America is getting a bit less corporate. And a bit less American. Fueled by a wave of inversions, a record 54 companies in the Standard & Poor’s 500 Index of leading U.S. companies are now at least partially exempt from the… – Continue reading
Increased mergers and acquisitions in the pharmaceuticals space has been a boon for healthcare-heavy Israel exchange traded funds. Year-to-date, the Market Vectors Israel ETF (NYSEArca: ISRA) and the iShares MSCI Israel Capped ETF (NYSEArca: EIS) are up an average of 11.6%, an advantage of 260 basis points over the MSCI… – Continue reading
Increased mergers and acquisitions in the pharmaceuticals space has been a boon for healthcare-heavy Israel exchange traded funds. Year-to-date, the Market Vectors Israel ETF (NYSEArca: ISRA) and the iShares MSCI Israel Capped ETF (NYSEArca: EIS) are up an average of 11.6%, an advantage of 260 basis points over the MSCI… – Continue reading
Everyone’s “favorite” day of the year is less than 24 hours away – Tax Day. And the big question is: Have you filed your return yet? (If you haven’t, stop reading this and go take care of that. This will still be here when you’re done.) By now, most people… – Continue reading
Washington, D.C. – As tax day approaches, it’s important to remember that small businesses end up picking up the tab for offshore tax loopholes used by many large multinational corporations. U.S. PIRG joined Senator Bernie Sanders, Bryan McGannon of the American Sustainable Business Council, and Bob McIntyre of Citizens for… – Continue reading
Sen. Bernie Sanders (I-VT) drops a bomb on corporations who are dodging taxes by hiding money overseas by introducing new legislation that will force tax dodgers to pay their fair share. Here is part of what The Corporate Tax Dodging Prevention Act of 2015 would do: 1. Ending the rule… – Continue reading
Analysts upbeat on the company’s standalone prospects The recent share price performance of Shire Plc (LON:SHP), the London-listed drugmaker left at the altar by US pharma giant AbbVie (NYSE:ABBV) last year, suggests that the company will continue to thrive on its own, a view supported by recent analyst comments on… – Continue reading
When it comes to taxes, corporate America is getting a bit less corporate. And a bit less American. Fueled by a wave of inversions, a record 54 companies in the Standard & Poor’s 500 Index of leading U.S. firms are now at least partially exempt from the corporate income tax…. – Continue reading
– Rising Cost of Compliance Within The Tax And Financial Regulatory Environment Creates Opportunities For Increased Efficiency – CHICAGO–(BUSINESS WIRE)–As the economy continues to accelerate, many organizations plan to grow by entering into new markets in the years ahead, reveals the first ever BDO USA, LLP Tax Outlook Survey. Fifty… – Continue reading
1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins Canada is a federal state, with legislative powers divided between the federal and provincial governments. The federal government has legislative jurisdiction over issues concerning Canada as a whole, including foreign affairs, international trade, banking, telecommunications,… – Continue reading
The European Commission has announced a package of measures aimed at increasing tax transparency between Member States. The central focus of the measures is the automatic exchange of cross-border tax rulings given by tax authorities. Under current rules, Member States are obliged to provide details on their tax rulings to… – Continue reading
In recent years, the State Administration of Taxes (“SAT”) has paid closer attention to fees resident enterprises pay their overseas related parties, concerned that multinational groups have shifted profits away from China through aggressive tax planning and by paying unreasonable service fees and royalties overseas. Following PRC’s active participation in… – Continue reading
Historically taxpayers have faced difficulty overcoming a presumption against a change in domicile to a foreign jurisdiction. Intellectual property generally will be the most valuable asset held by technology companies and, in fact, many other business entities across all sectors of the economy. A recent analysis of S&P 500 companies… – Continue reading
A new watchdog team of the revenue authority is ready to start operation to check transfer mispricing by the multinational companies (MNCs) on their tax returns as such trick is allegedly used in underhand cross-border transactions. The revenue board recently completed appointment of officials for enforcing the measure. It was… – Continue reading
Listed companies in developed market could be avoiding as much as $82b annually London: Listed companies in developed markets are avoiding at least $82 billion (Dh301 billion) of tax a year by using tax havens and other minimisation strategies, according to detailed analysis of more than 1,000 businesses. The revelation… – Continue reading
One of the most financially damaging taxes facing wealthier British families is UK inheritance tax. Living in Malta does not automatically protect you since liability does not rest on residence but on domicile. Domicile is a complex UK common law concept. If claiming a change of domicile, the onus is… – Continue reading
SINGAPORE, April 12 (Reuters) – The Singapore trading hubs of the world’s largest commodity companies are coming under scrutiny from the governments of some resource-producing countries who say they suspect they are using units in the Southeast Asian financial centre to avoid tax. Some of the world’s largest oil, mining… – Continue reading
The key is to arrive at a Goldilocks mean — rolling out tax-friendly policies while being firm with incorrigible offenders A phrase first used by Prime Minister Narendra Modi while addressing a group of businessmen in the run-up to the elections last year has now come back to haunt his… – Continue reading
All eyes will be on former Secretary of State, and now presidential candidate, Hillary Clinton as she sets out a policy agenda during the opening months of her campaign. While in recent years Clinton has not gotten into the nitty-gritty of tax policy, she does have a long voting record… – Continue reading
On 18th March 2015, George Osborne delivered his sixth budget as Chancellor and the last of the current Parliament. Amongst the announcements were a number of developments relevant to tax planning, the key points of which are summarized below: Capital Gains Tax – Entrepreneurs’ Relief Entrepreneurs’ Relief (ER) reduces the… – Continue reading
DTA of Namibia president McHenry Venaani suspects that the majority of fishing and mining companies are involved in transfer pricing because of the lack of capacity in the government to control the dodgy practice. Venaani made the remarks in the National Assembly on Wednesday during his statement on the budget,… – Continue reading
Apple Australia follows Australian transfer pricing law and pays all of its taxes due in the Australian market in accordance with the law, Tony King, the Managing Director of Apple Australia, told the Senate Inquiry on corporate tax avoidance and minimization on April 8, 2015. In his opening remarks before… – Continue reading
The present French Tax Update will focus on (i) several noteworthy French and European Union court decisions issued in the last months of 2014 and in the first months of 2015, and (ii) the recent presentation by the European Commission of a package of tax transparency measures. VALIDITY OF TAX… – Continue reading
