Prime Minister Tony Abbott has nominated global tax avoidance as one of the key issues on the agenda for this weekend’s G20 summit in Brisbane. Major companies including Google and Apple have faced strong criticism over their efforts to lower their tax bills by shifting profits to jurisdictions with low… – Continue reading
Treasurer Joe Hockey has called multinational companies who avoid paying tax “thieves” whose actions worsen inequality and make it harder for governments to fix poverty. Mr Hockey told reporters in Brisbane on Thursday that this weekend’s Group of 20 leaders summit would focus on ensuring that “companies pay tax where… – Continue reading
Future Fund chairman Peter Costello has defended the amount of tax the sovereign wealth fund pays, saying it has ‘sovereign immunity’ when it invests overseas. The government-owned Fund was named along with other Australian companies for using Luxembourg as a base in which to lower global taxes in one of… – Continue reading
Members of the European Parliament called for action on tax avoidance in Europe on Wednesday. A report released earlier this month by the International Consortium of Investigative Journalists documented secret deals arranged with multinational corporations, enabling them to avoid paying tax in Luxembourg. Hundreds of major corporations like Pepsi, IKEA… – Continue reading
November 13: Taxation Ruling (TR) 2014/6—issued yesterday by the Australian Taxation Office (ATO)—sets forth the Commissioner’s view on the application of the reconstruction provisions as contained in Australia’s new transfer pricing rules. The significance of these reconstruction provisions is that they authorise the Commissioner to re-price, reconstruct or disregard a… – Continue reading
Ed Balls said Labour will bring in tough penalties to deter people from tax avoidance if they get into power at the next general election. Labour will impose fines of up to 100% of the value of the avoided tax, said the shadow chancellor. As it stands, those who are… – Continue reading
The OECD released today its new Strategy for Deepening Developing Country Engagement in the Base Erosion and Profit Shifting (BEPS) Project, which will strengthen their involvement in the decision-making processes and bring them to the heart of the technical work. The BEPS Project aims to create a coherent set of… – Continue reading
The departure of a multi-national giant from Manx shores will have no effect on our VAT revenue share, Treasury chiefs insist. As an Isle of Man Examiner investigation revealed back in January 2011, Procter & Gamble’s unassuming office at Brewery Court in Castletown was the unlikely hub of a global… – Continue reading
INSTITUTIONAL investors from three countries that are G20 members have called on this week’s summit to ensure transparency and disclosure are part of the G20’s talks on tax avoidance. The investors, including multi-billion dollar companies from the United Kingdom, Canada and France, and non-G20 nation The Netherlands, made the call… – Continue reading
The European Union’s 28 member states are seeking agreement on the proposed introduction of a common anti-abuse clause in the Parent-Subsidy Directive (2011/96/EU). The plans were discussed at a meeting of the EU’s Economic and Financial Affairs Council (ECOFIN) on November 7, 2014. The proposed anti-abuse clause would allow member… – Continue reading
Sears Holdings and Pinnacle Entertainment have become the latest US companies to announce that they are considering establishing real estate investment trusts (REITs), to unlock tax advantages that have been considered by some companies as an alternative to a corporate inversion. REITS do not pay corporate tax as long as… – Continue reading
Spain negotiated the largest rate reductions in its tax treaties with developing countries, out of 15 EU nations scrutinised for their record on international tax-dodging in the wake of the Luxembourg Leaks scandal. Developing countries were missing out on billions of much needed-revenue as a result of the tax rate… – Continue reading
HCMC – Foreign exchange control is a paramount concern of all foreign investors entering into Vietnam, as regulations on capital inflows and outflows have a great influence on operations and profit. Foreign exchange control includes transferring capital into and out of the country, opening and using bank accounts, borrowing foreign… – Continue reading
THERE IS NO single policy or solution that can prevent the occurrence of tax avoidance because there is no single cause for the phenomenon, according to Devereux Tax Chambers barrister Jolyon Maugham. Speaking at the ICAEW’s Hardman Lecture, Maugham told the institute’s members that “plugging holes” in the tax code… – Continue reading
12/11/2014 – The OECD released today its new Strategy for Deepening Developing Country Engagement in the Base Erosion and Profit Shifting (BEPS) Project, which will strengthen their involvement in the decision-making processes and bring them to the heart of the technical work. The BEPS Project aims to create a coherent… – Continue reading
November 12: The Organisation for Economic Co-operation and Development (OECD) today released a report addressing the role of developing countries with respect to the base erosion and profit shifting (BEPS) project. As noted in today’s OECD release [PDF 259 KB], the BEPS project is intended to address tax planning strategies… – Continue reading
With U.S. interest rates remaining at historic lows, yield-starved investors have continued allocating massive amounts of capital to exchange traded products offering exposure to master limited partnerships (MLP). So popular are MLP ETFs and exchange traded notes (ETNs) that the asset class has not endured a month of net outflows… – Continue reading
According to Bill Thompson, tax partner at Minter Ellison, Base Erosion and Profit Shifting (BEPS) — the base erosion referred to as the tax base and its implications for future tax structures — will be a key focus at the G20 Summit in Brisbane, with possible rapid changes to the… – Continue reading
In March 2014 the Russian Ministry of Finance published a draft anti-offshore law which is currently submitted for consideration by The State Duma (parliament) with the decision expected to be made by the end of 2014. Russia is aiming to clamp down on the use of foreign offshore tax shelters… – Continue reading
Australia – Transfer pricing reconstruction not limited to “exceptional circumstances” November 12: The Australian Taxation Office (ATO) today finalised a transfer pricing ruling that sets forth the Commissioner’s position on application of the reconstruction provisions, as outlined in section 815-130 of the Income Tax Assessment Act 1997. The ruling—TR 2014/6—covers… – Continue reading
Patent boxes allow firms to pay much lower taxes on profits from patented inventions, but critics say it gives UK too much of a fiscal advantage George Osborne’s move removes one of the potential flash points between the UK and Germany before this week’s G20 summit in Brisbane. Photograph: Pa… – Continue reading
Northern Ireland is a serious player in the international market to attract more foreign investment. The comprehensive requirement: can Northern Ireland offer a competitive combination of access to markets, favourable domestic costs including employment costs, an adequate infrastructure base, a stable society and taxation policies that help to ensure attractive… – Continue reading
The European Union should complete its four tax probes before it can “decide what to do next,” EU Competition Commissioner Margrethe Vestager said. “Maybe in the beginning of the second quarter of next year we will have results on at least some of those open cases,” Vestager told reporters after… – Continue reading
ovember 10: The Organisation for Economic Co-operation and Development (OECD) last week published a discussion draft on Action 10 (Proposed Modifications to Chapter VII of the Transfer Pricing Guidelines Relating to Low Value-Adding Intra-Group Services) as an additional deliverable under the OECD’s base erosion and profit shifting (BEPS) action plan…. – Continue reading
Those who live in glass houses do well not to throw stones, and Ireland’s predilection for such tax schemes as the “double Irish” probably makes it the last place to cast aspersions at Luxembourg’s creative approach to assisting what is now euphemistically called “tax planning”, once “tax avoidance”. Having sensibly… – Continue reading
On November 3, 2014, the Organisation for Economic Co-operation and Development (OECD) published its discussion draft on the proposed modifications to Chapter VII of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. These proposed modifications have been developed in connection with Action Point 10 of the Action… – Continue reading
The I-T department had said Vodafone India under-priced shares in a rights issue to its parent. The tax demand was for the two financial years ended March 2011 The finance ministry is yet to decide on filing an appeal against the Bombay High Court order of October 10 in favour… – Continue reading
The Financial Transaction Tax (FTT) ensures that we have learnt the lessons from the banking crisis. Unless we accelerate the work on improving the rules so that they are adequate to an environment of globalisation, we will destroy the support for the European integration and that will be the end… – Continue reading
In another bizarre twist to what litigation lawyers have called an “unprecedented” case, counsel for McKesson Canada Corp. are now relying on Tax Court of Canada Justice Patrick Boyle’s recusal from a transfer-pricing case in September as grounds for seeking a new trial. Gavin MacKenzie believes the Court of Appeal… – Continue reading
The tax man is threatening fines of up to £1 million for high-earners shielding their income in tax avoidance schemes. HM Revenue & Customs (HMRC) has published a list of hundreds of schemes and laid out in uncompromising terms the likely penalties for taxpayers who fail to pay up. Around… – Continue reading
High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Email ftsales.support@ft.com to buy additional rights.http://www.ft.com/cms/s/0/8bffa20c-6683-11e4-9c0c-00144feabdc0.html#ixzz3Ijq0jeQ8 The world’s most powerful trade unions have called on their pension funds to fight… – Continue reading
A slew of regulatory changes including Companies Act 2013, GST and Transfer Pricing (TP) are likely to redefine the role of chief financial officers (CFOs) according to a report unveiled by KPMG in India and CII. The report titled ‘Playing to Win in a VUCA Environment’ was unveiled at the… – Continue reading
Subsidiary funds companies within Irish multinational, says spokesman RH did not feature in the leaked files, but accounts for one of its Luxembourg subsidiaries show it had multibillion-euro intra-group loans going in and out of the state. Photograph: Brenda Fitzsimons Ireland’s largest indigenous multinational, building materials group CRH, has a… – Continue reading
Moving overseas, or returning to Australia after a stint abroad, is not just a lifestyle or career decision. It also has far-reaching financial implications that are invariably overlooked until years later. While these often involve what to do with retirement money overseas or the tax implications of selling assets owned… – Continue reading
The hollowing out of tax collected for public purposes by rich and poor nations is not confined to technology and mining companies, according to a major leak of secret tax agreements covering more than 340 companies around the world. The documents, published by the International Consortium of Investigative Journalists, include… – Continue reading
Imagine a scenario in which a Hong Kong-based hedge fund manager establishes and appoints an offshore management company to provide investment management services for its fund. On one hand, the fund’s structure ensures a clear operational base. But at another level, key governance procedures are often neglected. These tasks include… – Continue reading
The Dutch tax rules are attractive to large multinationals. The same is true for countries such as the United Kingdom, Switzerland and Luxembourg. This writes the General Court of Auditors in a report, which was requested by the Second Chamber. The report was published today. Large multinationals search around the… – Continue reading
The global base erosion and profit shifting (BEPS) rules, aimed at collecting a fair share of taxes from multinationals operating in different tax jurisdictions, are likely to be finalised by December 2015, a senior finance ministry official today said. “Work on BEPS is moving very fast. If things go on… – Continue reading
BEPS Action 10: Proposed modifications to Chapter VII of the Transfer Pricing Guidelines relating to low value-adding intra-group services On 3 November 2014, the OECD, as part of its work on the Action Plan to address Base Erosion and Profit Shifting (‘BEPS’), released a Discussion Draft in relation to Action… – Continue reading
Covidien transferred right to $6.9bn loan to new entity Multinational medical supplies group, Covidien, transferred the right to loans totalling $6.9 billion from Luxembourg to a new Irish company as part of an elaborate inter-group tax planning arrangement agreed with the Luxembourg tax authorities in 2009. Under the deal, the… – Continue reading
The tax commissioner has rejected six agreements with multinationals in the past six months after deciding they had misled the Tax Office and engaged in “aggressive tax planning”. Multinationals can enter deals with the Tax Office to lock in the basis for pricing cross-border transactions, under so-called “advanced pricing agreements”,… – Continue reading
From 1970 to 2011, US$2 trillion from Latin America and the Caribbean have been funneled to offshore tax havens. It’s money that moves behind the scenes, in illicit financial flows (IFF). These transnational transfers come from three sources of illegal funds: corruption (bribery), money laundering (contraband, trafficking of drugs, weapons,… – Continue reading
The National Tax Service (NTS) said Thursday that it will help foreign companies in Korea reduce potential tax uncertainty regarding their cross-border transactions with parent firms. From 2015, the NTS will allow foreign firms that earn less than 50 billion won ($46 million) a year in sales to focus on… – Continue reading
Papers show firms used internal loans and interest payments to cut tax bills Leaked tax documents show arrangements were signed off by EU state They are legal, but are predicted to trigger calls to stop firms avoiding taxes British companies using scheme include Dyson and drugs group Shire Some of… – Continue reading
“Judges are expected to decide cases as framed by the parties, then step back and allow the appellate process to unfold. In this case, the trial judge did neither.” – Taxpayer’s Supplemental Memorandum of Fact and Law The transfer pricing case of McKesson v. The Queen has raised procedural issues… – Continue reading
G20 leaders are under pressure to go further in their efforts to crack down on tax avoidance after the revelation that thousands of companies, including several major Australian firms and multinationals operating in Australia, have legally avoided tax with complicated deals negotiated through Luxembourg. The chairman of a Senate inquiry… – Continue reading
BRUSSELS – Dividend, interest and royalty payments that companies let pass through the Netherlands to avoid taxation have increased substantially in the past decade, the Netherlands Court of Audit has found. In a report published on Thursday (6 November), the court writes that tax laws and treaties that originally were… – Continue reading
Government intends to crack down on misuse of Danish companies The minister for business and growth, Henrik Sass Larsen, announced yesterday a new set of law proposals designed to stop Denmark being used as a tax haven. The move comes in the wake of a wave of media attention around… – Continue reading
Ernst & Young Solutions LLP, Singapore* It has been eight years since the Inland Revenue Authority of Singapore (IRAS) first released its Circular on Transfer Pricing Guidelines. During that time, there have been significant changes in the international tax landscape. In Singapore, we have seen supplementary guidance from the IRAS… – Continue reading
For more than a decade, tax gurus at PricewaterhouseCoopers helped Caterpillar Inc., the U.S. heavy equipment maker, move profits produced by its lucrative spare-parts business from the U.S. to a tiny subsidiary in Switzerland. Little changed except the bookkeeping. Parts were still shipped from suppliers to a warehouse in Morton,… – Continue reading
