Category: Tax Planning

Nigeria – Transfer pricing forms, non-resident company tax returns

November 28: Nigeria’s Federal Inland Revenue Service previously indicated that it would no longer accept tax returns filed by non-resident companies on a “deemed profit basis,” but that non-resident companies must  file their tax returns on an “actual profit basis.” These returns are to include audited financial statements as well… – Continue reading

Never talked about bringing black money in 100 days: Government

Even as Finance minister Arun Jaitley on Thursday said a heavy tax regime was responsible for black money, his ministerial colleague M Venkaiah Naidu told parliament amidst uproar that BJP had never promised to bring back black money stashed aboard in first 100 days of power. Reading BJP manifesto, Naidu,… – Continue reading

Proposals to allow Scotland to vary income tax rates could lead to a rise in tax avoidance

Proposals by the Smith Commission to allow Scotland to vary income tax rates could lead to a rise in tax avoidance unless properly managed, according to a tax expert at Pinsent Masons, the international law firm. Karen Davidson, a legal director and tax specialist at Pinsent Masons says that any… – Continue reading

Luxembourg: a tax haven by any other name? Professor on ‘secret’ tax deals

The revelations that global and multinational businesses have been brokering “secret” tax deals with Luxembourg to avoid paying taxes in their home countries, may be the first time an entire country has been implicated in tax avoidance collusion. A cache of leaked agreements uncovered by the International Consortium of Investigative… – Continue reading

G20 gives Africa the will to deal with tax evasion

To prevent cross-border tax evasion, we endorse the global Common Reporting Standard for the automatic exchange of tax information (AEOI) on a reciprocal basis. We will begin to exchange information automatically with each other and with other countries by 2017 or end-2018, subject to completing the necessary legislative procedures,’’ says… – Continue reading

New foreign incentives ‘a positive step’

Recently approved incentives for companies to set up international headquarters and international trading centres in Thailand could have a positive effect on foreign investment, say foreign executives. “After Singapore, I think Thailand could be the next big attraction for [such offices] to open here,” said Stanley Kang, chairman of the… – Continue reading

France – Tax proposals in pending legislation

Passage by the French assembly on 18 November 2014 of a draft Finance Bill for 2015 (which now will be presented to the Senate) Introduction by the French government on 12 November 2014 of a second draft amended Finance Bill for 2014 In general, the draft Finance Bill for 2015… – Continue reading

He’s only in the job 27 days but the EC boss has already survived a motion of no confidence

The new head of the European Commission Jean-Claude Juncker has faced, and survived a motion of no confidence, just weeks after taking up his role. MEPs wanted to censure the Commission, headed by the former Prime Minister of Luxembourg, in the wake of revelations that multinational companies used his country… – Continue reading

Microsoft (NASDAQ:MSFT) Accused of Tax Evasion

Microsoft (NASDAQ:MSFT), once again finds itself deep in controversy and this time, on foreign shores. The company has been hit with a $140 million in taxes and interests presented by the Chinese government. This came to light in a rare incident of cross-border tax invasion. An article was published by… – Continue reading

Jean-Claude Juncker saved from censure over Luxembourg tax schemes

Centrist parties vote down European parliament motion criticising commission president’s role in tax avoidance schemes Jean-Claude Juncker, president of the European commission, has survived a motion of censure in the European parliament brought because of his role in tax avoidance schemes. The motion brought by Britain’s Ukip, France’s Front National,… – Continue reading

Argentina Accuses HSBC of Aiding People in Tax Evasion

BUENOS AIRES — Argentina’s tax agency accused the HSBC bank on Thursday of helping more than 4,000 Argentines evade taxes by placing their money in secret Swiss accounts. The head of country’s AFIP tax agency, Ricardo Echegaray, said Argentine citizens had evaded about $3 billion in taxes that were handled… – Continue reading

Action needed to soften impact from Russia tax law

THE Institute of Certified Public Accountants of Cyprus (ICPAC) said that action is needed to mitigate the impact on the local financial services sector from a recent Russian law cracking down on Russian offshore business. Speaking at a press conference in Nicosia, ICPAC chairman Yiannis Charilaou said however that the… – Continue reading

Tax Inversions Succeed When Government Lawyers Go Private

Hal Hicks cleared his throat and addressed a roomful of peers in a midtown Manhattan auditorium. The topic: the tax-avoidance technique called inversion, in which a U.S. company claims a foreign legal address. Waving his hands back and forth as if tracing a pendulum’s swing, Hicks explained how four government… – Continue reading

Why Are So Many Offshore Companies Winning Lucrative Government Contracts?

Despite the Obama administration’s ongoing efforts to crackdown on American companies moving overseas to avoid U.S. taxes, the Treasury Department is still awarding millions of dollars in federal contracts to these companies. Tyco International for example, moved their firm from the U.S. to Bermuda in 1997 and currently operates out… – Continue reading

MPs summon PwC tax chief to attend Luxembourg tax deal hearing

Public accounts committee will demand intricate details from Kevin Nicholson about tax avoiding schemes in Grand Duchy One of Britain’s top tax advisers at PricewaterhouseCoopers has been summoned to give evidence before MPs in the wake of revelations about controversial tax deals for PwC clients in Luxembourg. Kevin Nicholson, PwC… – Continue reading

Medtronic Acquisition of Covidien Receives U.S. FTC Clearance

WASHINGTON–U. S. authorities on Wednesday approved Medtronic Inc.’s$43 billion merger with fellow medical device maker Covidien PLC after requiring the spinoff of a drug-coated catheter business. The Federal Trade Commission required Minneapolis-based Medtronic to sell off Ireland-based Covidien’s catheter business before completing the acquisition. That $30 million sale, to Colorado-based… – Continue reading

Don Cayo: Proposed tax reforms target growing income inequality (with video)

Strategies: Economists suggest removing easy avoidance VANCOUVER — Never mind that business-friendly tax policies – reforms like the dramatic reductions in federal and provincial corporate taxes over the past decade or so – enhance international competitiveness. This doesn’t impress the electorate when the benefits go mostly to the relative handful… – Continue reading

Dodwell: BEPS reform is forcing Ireland to reform tax rules

The latest work by the OECD tax policy team to review global tax rules is beginning to have an impact, particularly in Europe where Switzerland and Ireland are reforming their current tax rules, says Bill Dodwell, head of tax policy at Deloitte One unsurprising outcome of the OECD’s Base Erosion… – Continue reading

Netherlands responses to interim reports on BEPS project

Introduction On 19 September the Dutch State Secretary for Finance Mr Wiebes responded to the release of the 2014 interim reports on the OECD BEPS project. The Netherlands underlines the importance of the initial results of the BEPS project and is one of the forerunners in the international cooperation against… – Continue reading

Progress reports released on tax avoidance

Progress reports released on tax avoidance Revenue Minister Todd McClay today released two reports from officials relating to tax avoidance by large multinational companies. The reports provide an update on policy work being undertaken in line with the OECD Action Plan and also outline the expected timeline for related policy… – Continue reading

Russia enacts anti-offshore tax legislation

MOSCOW, Nov. 25 (Xinhua) — Russian entrepreneurs must report to tax authorities about their ownership of shares in the off- shore jurisdictions, according to the law signed by President Vladimir Putin on Tuesday. The new law introduces an amendment to the Russian Tax Code that will force Russian owners of… – Continue reading

Switzerland’s wealthy expats braced for vote on tax break

ZURICH (Reuters) – Many of Switzerland’s foreign millionaires will be watching nervously on Sunday as voters decide whether or not to scrap one of the country’s biggest tax perks for expatriates. Switzerland’s system of charging foreign residents with no gainful activity in the country a lump sum based on their… – Continue reading

ATO letting big multinationals get away with it

Martin Lock was formerly the top withholding-tax specialist at the Tax Office, a role that encompassed oversight of profit shifting by multinationals. He is one of many former officers who have voiced their concerns to Fairfax Media about the challenge of arresting the slide in tax receipts from multinational companies… – Continue reading

Putin signs anti-offshore law to return Russian capital from foreign tax shelters

The law introduces amendments to the country’s tax code that will oblige Russian owners of companies registered in offshore tax havens to pay taxes in Russia MOSCOW, November 25. /TASS/. Russian President Vladimir Putin signed on Tuesday a new tax law intended to return Russian capital and assets from foreign… – Continue reading

Analysts support increased transparency to fight tax havens

Responsible corporations paying their taxes and revealing their ownership structure could be a possible solution in the fight of Europe against tax evasion and tax havens which cost billions of euro annually. EurActiv Czech Republic reports. “We should step up our efforts to combat tax evasion and tax fraud”, Jean-Claude… – Continue reading

Microsoft to pay China $140 million for ‘tax evasion’

(Reuters) – China has levied about $140 million in back taxes from Microsoft Corp in the first major case concerning cross-border tax evasion in the country, as regulators ramp up pressure on U.S. corporations doing business there. According to an article published by China’s Xinhua official news agency on Sunday,… – Continue reading

China’s offshore empires go from help to headache

When is a Chinese company not Chinese? When it’s a complex web of offshore vehicles rooted in anonymous tax havens. That description includes some of the People’s Republic’s most successful and innovative companies. It will make the country’s apparent new push on tax evasion hard to enforce. Authorities have extracted… – Continue reading

OECD Considers Availability of Tax Treaty Benefits for Investment Funds, Pension Funds and Private Equity Funds

On November 21, 2014, as part of its Action Plan on Base Erosion and Profit Shifting (BEPS), the OECD released a discussion draft on “Follow-up work on BEPS Action 6: Preventing Treaty Abuse” (the Discussion Draft) for comments. The Discussion Draft deals with a number of issues relating to tax… – Continue reading

Transfer Pricing Compliance in Nigeria: What Next? (2)

TRANSFER pricing (TP) audit is a bit different from normal tax audits.  It primarily focuses on reviewing transfer pricing returns and supporting TP documentation submitted by taxpayers who had engaged in related party transactions in the preceding year of assessment.  This approach is necessary in order for the tax authority… – Continue reading

Kenya: CMA Seeks Lower Tax to Attract Investors

DOUBLE taxation for companies and individual investors at the securities market could be scrapped in 2016, if a plan by the Capital Markets Authority is adopted. In a move to attract and grow investments, the Capital Markets Authority has initiated talks on a transparent tax regime, to eliminate multiple taxes… – Continue reading

$1 Billion: That’s How Much Walmart Avoids Paying in Taxes Each Year Through Loopholes

This Black Friday, legions of shoppers will throng to their local Walmart in frenzied pursuit of holiday deals. But it turns out that Walmart has saved the sweetest deals for itself. In a recent analysis of Walmart’s tax spending, Americans for Tax Fairness (ATF) found that the company “avoids $1… – Continue reading

Transfer Pricing: A Developing Area in Slovak Tax Law

Transfer pricing can be identified as an area of tax law that continues to attract the attention of both tax authorities and businesses worldwide. The growing importance of transfer pricing can be observed in the Slovak Republic as well, as it has become one of the dominant tax issues addressed… – Continue reading

Tougher operating environment calls for a new business model

Rüschlikon is just a 20-minute boat ride from the centre of Zurich, yet a world away from the intense rivalry of the city’s financial powerhouses. Every autumn, the sleepy lakeside settlement hosts the Private Banking Summit, where delegates seek safeguards for their threatened industry. “Swiss private banking is in turmoil,… – Continue reading

Juncker holds ground on tax avoidance before EU confidence vote

Strasbourg, France (dpa) – European Commission President Jean-Claude Juncker urged lawmakers on Monday to trust his determination to tackle tax avoidance, ahead of a parliamentary confidence vote related to a tax scandal in his native Luxembourg. The controversy, known as LuxLeaks, grew out of allegations by a team of investigative… – Continue reading

Shocking tax evasion in the name of a trust!

Mumbai: While the Central Government has expressed its commitment to bring back black money stashed abroad, the Mumbai bench of the Income Tax Appellate Tribunal (ITAT) took a first concrete step towards this direction. It recently passed a crucial order in a case where unaccounted money was stashed in LGT… – Continue reading

Base erosion and profit shifting – a South African perspective

The concept of base erosion and profit shifting (BEPS) has been debated at various international forums following discussions at the G20 Finance Ministers and Central Bank Governors meeting and the G20 Heads of State summit in Russia last year. The Organisation for Economic Co-operation and Development’s (OECD) BEPS Action Plan… – Continue reading

Base erosion and profit shifting – treaty shopping

The concept of base erosion and profit shifting (“BEPS”) has been much discussed at various international forums including the G20 Finance Ministers and Central Bank Governors meeting in July 2013 in Moscow as well as the G20 Heads of State meeting in September 2013. From a South African perspective, the… – Continue reading

There’s $2.1 Trillion Sitting Overseas, How Do We Get It Back on American Soil?

Companies based in the United States now have over $2.1 trillion stashed overseas shielded from U.S. taxes. That’s a sixfold increase in 12 years, NBC News reported citing research provided by Capital Economics. Generally, the U.S. tax policy allows companies based in the country to defer any tax obligation on… – Continue reading

Schaeuble raps German firms for avoiding taxes via Luxembourg -Focus

Nov 22 (Reuters) – German Finance Minister Wolfgang Schaeuble sharply criticised leading German companies for reducing taxes by creating subsidiaries in Luxembourg, where tax rates are lower, according to Focus news magazine. “The list of those that have institutions in Luxembourg with the aim of saving taxes is a Who’s… – Continue reading

Clampdown on tax avoidance

By closing the tax gap, South Africa can reap billions of rands to benefit the economy. A global crackdown on tax avoidance has begun and South Africa is forging ahead in a bid to tackle wealthy individuals and corporates who practise this tactic. The initiative is better poised to succeed… – Continue reading

BEPS – Discussion draft on follow-up work under Action 6 (prevent treaty abuse)

November 21:  The Organisation for Economic Cooperation and Development (OECD) today released a discussion draft [PDF 179 KB] concerning follow-up work as mandated under a report with respect to Action 6 (prevent treaty abuse) under the base erosion and profit shifting (BEPS) action plan. Background The OECD in September 2014… – Continue reading

INTERNET COMPANIES PAY MORE TAX THAN THE EUROPEAN AVERAGE

Sit down before you read this: Internet companies pay more corporation tax than the European average, in some cases many times more. According to the European Commission the average ‘effective’ corporate tax rate in the European Union and EFTA is 12.9%; in 2012 Amazon had a whopping 78% in corporation… – Continue reading