The number of companies lobbying the U.S. government on tax inversions more than doubled in the quarter ended Sept. 30, as they sought to prevent Congress and the Obama administration from imposing new restrictions. Novartis AG (NOVN), SAP SE, and Eaton Corp Plc (ETN) were among companies that began lobbying… – Continue reading
Corporate tax “inversion” deals became a prime target this year of President Barack Obama, as part of his running theme that many U.S. corporations are stealing from Americans by not paying their fair share. After the August announcement of Burger King’s plans to merge with Canada-based Tim Hortons, the administration… – Continue reading
LUXEMBOURG — On the first floor of a rust-colored building near the main railway station, Marius Kohl spent years engineering this country’s most valuable export: tax relief. As head of a federal agency called Societes 6, Mr. Kohl approved thousands of tax arrangements for multinational corporations, sometimes helping them save… – Continue reading
For now, while the benefit for American corporations to buy or merge and move overseas may be over, as evidenced by AbbVie cancelling its merger with Shire Pharmaceutical, that doesn’t mean that consolidation within the industry is through. A new research report from Merrill Lynch features three top companies, dubbed… – Continue reading
Government must deal with tax evasion to help improve service delivery and ensure a bigger fiscus for the country, the EFF said following the mid-term budget speech on Wednesday. “Government should deal more with the issue of base erosion and capital shifting and transfer pricing because that is stealing millions… – Continue reading
On October 15th, 2014 the Minister for Finance announced the Luxembourg Budget 2015. The announcement followed the presentation made the day before by the Prime Minister Xavier Bettel who presented a policy statement entitled “Package for the Future” which provides some overall public finances policy statements for the period 2015… – Continue reading
A new survey by E&Y released at its 33rd Annual International Tax Conference, titled “Connecting the dots” uncovered the issues of navigating multiple challenges, led by increased scrutiny and the effects of the Organisation for Economic Co-operation and Development’s (OECD) base erosion and profit shifting (BEPS) project. “Tax directors need… – Continue reading
ITR Correspondent • • • The G20 and OECD’s Base Erosion and Profit Shifting (BEPS) project has rarely been out of the headlines during 2014. At the heart of the BEPS project is the assumption international tax rules make it possible for profits to be taxed in countries that are… – Continue reading
Mark Davies is not happy that accidents are going to cost you as much as intentions Recently, the government issued a consultation document on new legislation to extend HM Revenue & Customs’ powers of retribution for undeclared income and gains hidden offshore. It believes that offshore tax evasion is difficult… – Continue reading
Internet giant plays down speculation it is considering closing Bermudan arm Google has played down speculation in France that it is considering shutting its Bermudan arm and boosting its operations in Dublin, following the closure of the Double Irish tax loophole in last week’s budget. Le Monde yesterday reported that… – Continue reading
As Indian tax authorities have been slapping foreign firms with billions of dollars in unexpected tax bills, hundreds of global companies are now negotiating with the taxman here to clarify ahead of time what they will owe in the future, hoping to avoid surprises. In the past five years there… – Continue reading
The U.S. government’s move to hamper tax-inversion deals is good for the drug industry because it forces companies to focus on intrinsic business reasons for transactions, Actelion Ltd. Chief Executive Officer Jean-Paul Clozel said. Since the U.S. Treasury said last month that it would tighten tax rules, three of eight… – Continue reading
In determining the optimum gateway for investing into India, reliance on industry data may be the most prudent opening gambit. Data released by India’s Department of Industrial Policy & Promotion peg Mauritius and Singapore as the top two destinations through which foreign direct investment and private equity capital is routed… – Continue reading
Senate Finance Committee Chairman Ron Wyden has indicated that, as companies appear to be reconsidering inversions following the administrative measures put forward by the Treasury Department last month, he is focused on reforming the US tax code, rather than pressing for immediate anti-inversion legislation. “While it looks like the rush… – Continue reading
AbbVie Inc. (ABBV) and Shire Plc agreed to terminate what would have been the biggest U.S. tax inversion after AbbVie pulled its support for the deal in the wake of proposed changes to U.S. rules governing such transactions. AbbVie, based in North Chicago, Illinois, planned to buy Shire for an… – Continue reading
Bombay High Court holds that shares issued at a premium by a resident entity to a non-resident entity is a capital account transaction and does not give rise to any income; Income arising from an International Transaction between AEs must satisfy the test of ‘income; as provided under the ITA… – Continue reading
Foreign structures are tempting targets for governments, says Vanessa Houlder. When governments around the world embarked on a drive to plug tax loopholes in 2012, the urgency of the move was underpinned by rising tensions over austerity and inequality. Widespread public outrage over alleged tax-dodging by wealthy individuals and multinationals… – Continue reading
Climate Change Law Practice Group Blog, Environmental, Energy and Resources Law The BC Government tabled Bill 6, the Liquefied Natural Gas Income Tax Act, on October 2, 2014. Bill 6 sets out the features of the new LNG tax regime. The LNG taxation proposals have been the subject of great… – Continue reading
The Organization for Economic Cooperation and Development’s (OECD) plan for base erosion and profit shifting (BEPS) is already affecting corporations, according to speakers participating in a Captive Insurance Companies Association (CICA) transfer pricing webinar. Polling results during the webinar revealed attendees’ opinions were in line with tax industry surveys indicating… – Continue reading
The tide of tax inversions has started to recede, taking with it a substitute for real growth at some of our biggest companies. AbbVie Inc. just decided to bail out of an acquisition that would have moved its headquarters overseas where corporate tax rates are lower than U.S. rates. AbbVie… – Continue reading
Grant Thornton calls on government to show greater support for mid-sized companies as they drive UK growth GRANT THORNTON has lent its weight to calls for the government to back high-growth, mid-sized firms in the Autumn Statement on 3 December. In a 20-page document submitted to the chancellor, the top-ten… – Continue reading
The revenue implications for South Africa of ‘base erosion and profit shifting’ by corporate taxpayers are firmly in the crosshairs of the Davis Tax Committee (DTC) and Judge Dennis Davis hinted on Monday that recommendations were being considered to “detect and deter” tax-avoiding financial flows. Speaking at a G20 study… – Continue reading
Swiss authorities have confirmed that, if asked, they will assist India in efforts to confirm the genuineness of bank documents and will swiftly provide information on requests relating to non-banking dossiers. The commitment was made in a joint statement following a meeting between the Swiss State Secretary, Jacques de Watteville,… – Continue reading
Representation of foreign individuals who wish to purchase US residential property should include careful attention to the manner in which the income and gain from the property will be taxed in addition to the other aspects of ownership. In addition, it is important to be aware of the manner in… – Continue reading
The Irish government decided last week to get rid of a tax loophole that has helped big multinational companies like Apple and Google avoid paying billions in taxes to any government at all. But hold the champagne: Ireland could well replace one problematic tax policy with another, leaving aggressive tax… – Continue reading
A number of American corporations are making news, and not in a good way. They have announced mergers with foreign companies so they can avoid paying U.S. taxes. They are seeking what is called a “tax inversion” and it allows an American corporation to merge with a foreign corporation, move… – Continue reading
Senate Finance Chairman Ron Wyden (D-Ore.) said Friday that he hopes to build on the pharmaceutical company AbbVie’s move away from a tax inversion. AbbVie’s board advised shareholders to vote against the proposed merger with the Irish competitor Shire, which Wyden said showed the company saw “the strategic business value… – Continue reading
Some 19 British firms are at the center of an investigation into in a mammoth global money-laundering operation. The scheme was allegedly contrived to make $20bn (£12.5bn) worth of ill-gotten gains appear legitimate. The illicit funds are thought to have originated from criminal gangs and corrupt officials across the globe,… – Continue reading
Ireland puts an end to a tax loophole that saved Google, Apple, Microsoft, and Facebook billions in taxes “Double Irish” might sound like a drink that corporate tax lawyers reach for at the prospect of paying higher tax bills, but it’s actually the name of a controversial — albeit legal… – Continue reading
Our Reaction The Irish Minister for Finance delivered his Budget 2015 (the “Budget”) speech this week. There was considerable domestic and international anticipation in advance of the Budget against a backdrop of significant recovery in the Irish economy and also international focus (including, in particular, under the OECD BEPS project)… – Continue reading
Minnesota Democrat invested in opponent’s tax-inverting company as son’s private equity firm opens shop in Caymans Sen. Al Franken (D., Minn.) is hoping to saddle his Republican challenger with Mitt Romney-esque charges of “vulture corporatism,” but his own investment activities, and those of his son, could blunt those attacks with… – Continue reading
The much-awaited decision of the Bombay High Court was pronounced on October 10. Transfer pricing adjustment carried out in Shell/Vodafone case has been at the centrestage of every public discussion on Indian transfer pricing legislation. The incredulous stand taken by the tax authorities has evoked a strong response from investors… – Continue reading
The £32bn takeover of a leading UK pharmaceuticals firm is in danger of collapse because of a tax crackdown announced by the White House. AbbVie said this week that its board would meet on Monday to reconsider the purchase of Basingstoke-based Shire, which is best known for its drugs to… – Continue reading
The collapse of AbbVie’s takeover of Shire shows President Obama has put an end to the tax inversion bonanza for bankers and lawyers but they will find new ways to keep the deal wheels turning In 2010, a group of corporate lawyers went cycling in the French countryside. They whizzed… – Continue reading
n this second part of our overview of current transfer pricing regulations on the African continent, we focus on relevant provisions in, amongst others, Ghana, Nigeria and Uganda. The Ghanaian Transfer Pricing Regulations, 2012 (L.I.2188) (the Ghanaian Regulations) were introduced by the Ghana Revenue Authority (GRA) on 27 July 2012,… – Continue reading
A report claiming Lonmin is engaging in two transfer pricing arrangements is misleading and false, the company said on Thursday. It was responding to a report titled “The Bermuda connection: Profit shifting and unaffordability at Lonmin 1999-2012″, released by the Alternative Information and Development Centre (AIDC) on Thursday morning. “Lonmin… – Continue reading
AMONG several proposals for tax reform, the director-general of the Revenue Department has said the agency would propose an amendment to the Revenue Code concerning transfer pricing, aiming to provide greater clarity on the determination of fair transfer prices. The director-general has indicated that in past years many multinational companies,… – Continue reading
As the Irish government considers closing an infamous tax loophole for corporations, Wall Street has been scrambling to gauge the effect on the pharmaceutical industry. So far, the prognosis seems that damage will largely be minimal. Known as the ‘Double Irish,’ the loophole allows companies to send royalty payments for… – Continue reading
AbbVie Inc. (ABBV) may scrap its planned 32.4-billion-pound ($51.5 billion) deal for Dublin-based drugmaker Shire Plc (SHP), in what would be the biggest casualty of the U.S. crackdown on so-called tax inversions. Shire stock plunged the most in 12 years after North Chicago, Illinois-based AbbVie said its board will meet… – Continue reading
On July 21, 2014, the governments of Canada and the United Kingdom signed the fourth protocol (Protocol) amending the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading
Two Brazilian companies are raising their bid for banana company Chiquita to approximately $658 million. Investment firm Safra Group and juice company Cutrale Group said Wednesday that they are now offering $14 per Chiquita share, up from their previous bid of $13 per share. That’s an approximately 6 percent premium… – Continue reading
After announcing Ohio-based Steris Co.’s plans to become British for tax purposes on Monday, CEO Walter Rosenbrough later said on a conference call, “We’re not typically users of aggressive tax policies and I don’t think we are here.” That’s his story, and he’s sticking to it. But even a cursory… – Continue reading
Blue-ribbon corporations are deserting our country “to avoid paying taxes but expect to keep receiving the full array of benefits that being American confers, and that everyone else is paying for,” Fortune magazine reports. That’s right, Fortune wrote it; not Pravda. In a scathing article titled “Positively Un-American” by Allan… – Continue reading
Wealth inequality is growing worldwide, according to a new report by Credit Suisse. A greater share of wealth is being held by a smaller number of ultra-rich families worldwide as larger inheritances, family trusts, and similar arrangements to avoid taxes help the ultra-wealthy gain a greater portion of total capital… – Continue reading
Oslo : Allaying investors fear, President Pranab Mukherjee today said that the Bombay High Court verdict in the Vodafone taxation case, if it prevails, will help Finnish phone manufacturer Nokia as also 26 others. In his interview to Finnish media ahead of his departure to Helsinki, Mukherjee here said the… – Continue reading
A new initiative to monitor MNCs moving headquarters to evade taxes promises success Largely unnoticed, India has come out strongly supporting an international initiative for plugging tax avoidance by multinational corporations (MNCs). The initiative has been endorsed at the last meeting of G20 finance ministers at Cairns in Australia. Known… – Continue reading
Malta, like Cyprus, has been obliged to dismantle its old ‘offshore’ companies regime as a trade-off for joining the European Union. EU membership has, however, brought about certain benefits for Maltese companies trading across borders, and, coupled with investment-friendly government policies and some interesting tax planning opportunities, Malta remains one… – Continue reading
A vast majority of companies headquartered in the United States expect increased scrutiny of their transfer pricing practices in the short-term as a result of the Organisation for Economic Cooperation and Development’s (OECD’s) base erosion and profit shifting (BEPS) project. A recent EY survey, Connecting The Dots, concluded that 30… – Continue reading
The U.S. government’s attempt to prevent companies from seeking a tax address outside the country hasn’t stopped Steris Corp. (STE) The Mentor, Ohio-based provider of hospital sterilization products and services announced today that it will buy the smaller Synergy Health Plc (SYR) and establish the combined company’s tax address to… – Continue reading
The drugmaker AbbVie said Tuesday it is having second thoughts about its deal to combine with British counterpart Shire after the U.S. government created new limitations on the tax benefits of incorporating overseas. North Chicago, Illinois-based AbbVie said it notified Shire that its board intends to reconsider the recommendation it… – Continue reading
