The first stage of an un-precedented worldwide crackdown on tax evasion and banking secrecy has got under way, with Irish banks this week starting to collect details of non-resident bank account holders. The collection of information follows on from the agreements brokered by the Organisation for Economic Co-operation and Development… – Continue reading
More than €45.6bn raised for exchequer last year, up from €41.2bn in 2014 The Revenue Commissioners secured 27 criminal convictions for serious tax evasion and fraud in 2015, according to figures released today. Those prosecutions were on top of 2,063 summary convictions, or lesser charges, for the non-filling of tax… – Continue reading
Billionaire JP McManus is refusing to back down in a row with the US government over a tax bill of $5.2m (€4.8m). The racehorse owner has renewed efforts to secure a tax refund for the sum, court papers seen by the Irish Independent reveal. The disputed cash was part of… – Continue reading
Official Irish statistics are being fattened up by massive tax inversions and the re-registering of companies, warns Dan White The ESRI estimates that the Irish economy grew by 6.7pc in 2015 and is forecasting GDP growth of 4.8pc for this year. GNP, which is generally regarded as a better measurement… – Continue reading
Italy has already brought several cases against global technology companies that have headquarters in low-tax nations like Ireland to avoid paying higher taxes in other countries, like Italy. Tax officials won’t say what Apple has agreed to pay, but citing local reports, the Times reports it may be around $350… – Continue reading
SEATTLE — When someone in Seattle buys a copy of Office at a Microsoft Store, that cash doesn’t take the short route to the company’s area headquarters. Instead, after accounting for state taxes, the profit goes to a Microsoft sales subsidiary in Nevada. From there, much of that money begins… – Continue reading
Bermuda has “long been a popular tax haven” according to a story by gobankingrates.com, which ranked the island as one of the “top 10 best tax havens in the world.” The story said “Bermuda has long been a popular tax haven, said Ravi Ramnarain, an independent certified public accountant. “Wealthy… – Continue reading
Multinational companies have enjoyed a sustained period of falling corporate tax rates around the world. However, with the conclusion of the OECD’s base erosion and profit shifting project earlier this year marking the start of fundamental changes to the international tax system, and with governments more determined than ever to… – Continue reading
On 18 December 2015, the Regulations implementing the OECD Common Reporting Standard (“CRS“) in Ireland were approved by the Irish Parliament. This update follows on from previous updates published by Maples and Calder Dublin on CRS and US FATCA and outlines the practical next steps for Irish investment funds and… – Continue reading
The Irish Revenue has released a new brief detailing the impact on Irish paying agents of the European Union’s decision to replace the Savings Tax Directive with legislation providing for the automatic exchange of tax information. On November 10, the European Council repealed Directive 2003/48/EC on the taxation of savings… – Continue reading
Measure tries to keep firms from exploiting tax law variations Foreign and local businesses with annual sales of 100 billion won ($85 million) or more, and over 50 billion won in transactions with overseas entities must report international transactions to the tax authority starting next year. Known as the “Google… – Continue reading
On September 17, 2015, the IRS issued a statutory notice of deficiency to the Coca-Cola Company, increasing its federal income taxes for 2007-2009 by $3.3 billion, based primarily on transfer pricing adjustments exceeding $9 billion. On December 14, 2015, Coca-Cola petitioned the U.S. Tax Court to overturn the adjustments. This… – Continue reading
Mary-Lou McDonald is one of the more eloquent Dáil performers and she rarely pulls her punches. But consistency has not always been the most remarkable attribute of her contributions. She can be devastating while excoriating the misdeeds of others – but strangely reticent when it comes to matters close to… – Continue reading
The Irish Revenue Commissioners have confirmed that the necessary statutory instrument to bring the final common reporting standard (CRS) regulations into Irish domestic law was signed 17 December 2015 and is effective 31 December 2015. Other recent developments concerning the automatic exchange of information (AEOI) regimes, include the publication of… – Continue reading
The president of Ireland on 22 December 2015 signed into law Finance Act 2015 that includes rules following the OECD’s recommended country-by-country (CbyC) reporting requirements. The Finance Act provision closely mirrors the OECD’s suggested model legislation. For fiscal years beginning on or after 1 January 2016, multinational groups whose ultimate… – Continue reading
A BALANCING ACT in London, folly and redemption in America’s District of Columbia and sheer hypocrisy in Brussels. And in every case, Barbados and many of its Caribbean neighbours were placed in the negative international spotlight at a time when some of the world’s major financial centres are casting about… – Continue reading
The Markets Supervision Directorate of the Central Bank published its programme of themed-inspections for 2016. These inspections reflect a number of supervisory priorities for 2016 and anticipate areas of emerging risk. This programme builds on the successful supervisory work undertaken in 2015 in the areas of Cyber Security, Operational Risk… – Continue reading
Apple CEO says the company pays ‘every tax dollar we owe’ amid debate in the US over corporations avoiding tax by using offshore units Apple’s chief executive Tim Cook has dismissed as “total political crap” the notion that the technology giant was avoiding taxes. Cook’s remarks, made on CBS’ 60… – Continue reading
A list of tax paid by Australia’s biggest companies, released by Tax Commissioner Chris Jordan on Thursday, may have raised more questions than it answered. Nevertheless, we needed it. This is just the beginning of a long journey towards tax transparency. The Australian Taxation Office (ATO) released the data for… – Continue reading
The Australian Government’s efforts to improve tax collections are more urgent amid falling revenue from weak commodity prices, the Wall Street Journal reports Malcolm Turnbull’s government took the rare step of making public the tax affairs of scores of multinationals, highlighting that many big names—including Apple Inc. and Volkswagen AG… – Continue reading
The Cayman Islands (along with the United Kingdom, Ireland, Jersey, Guernsey, the British Virgin Islands and over 70 other countries) has committed to implementing the OECD Common Reporting Standard (“CRS”), which will require investment funds to collect tax identification and tax residency information from all new subscribers and transferees (including… – Continue reading
Fifty-three jurisdictions have agreed to automatic exchange of tax information beginning in 2017, under the OECD’s Common Reporting Standard. Over 40 others have committed to exchange information by 2018. Another wave of global tax information is about to take place, and financial institutions everywhere are in a race to prepare… – Continue reading
The common reporting standard framework was first released by the Organisation for Economic Co-operation and Development (the “OECD”) in February 2014 as a result of significant political will demonstrated by the G20 members to endorse a global model of automatic exchange of information and increase international tax transparency. On 21… – Continue reading
The European Commission has extended its investigation into a tax ruling provided by the Irish Government to Apple. The Commission has asked the Irish authorities for additional information on the case. Irish media reports that the Government does not anticipate a decision until 2016. In late November, Finance Minister Michael… – Continue reading
Action on tax avoidance could see €600m go from the pharma sector, says report International moves on multinational tax could threaten Ireland, with a potential annual loss of corporate tax revenue of €600 million or more from the pharma sector alone, according to a new report from Chartered Accountants Ireland…. – Continue reading
India and Korea on December 9 agreed to suspend collection of taxes during the pendency of Mutual Agreement Procedure (MAP). This MoU will relieve the burden of double taxation for the taxpayer in both the countries. Two days later, India and Japan signed a protocol for amending the existing convention,… – Continue reading
On 22 December 2014, the Italian Parliament approved the Budget for 2015.40 Among other measures, the Law introduces the possibility of an exemption from corporate income tax (IRES, generally levied at 27,5%) and local tax (IRAP, generally levied at 3,9%) on income derived from qualifying intangible assets (such as patents,… – Continue reading
The $160bn (€146.5bn) merger of US pharmaceutical giant Pfizer with Dublin-based Allergan is an “opportunity” for Ireland, according to IDA chief executive Martin Shanahan. Last month Pfizer, the world’s largest pharmaceutical company, announced plans to merge with Botox manufacturer Allergan in a deal that will create the world’s biggest drug… – Continue reading
According to Baroness Neville-Rolfe, Parliamentary Under Secretary of State at the Department for Business, Innovation and Skills, the United Kingdom “is at the forefront of a dramatic increase in transparency about company ownership” in developed countries. However, it is the UK which is going to provide the testing ground for… – Continue reading
Something unusual is happening with the Irish corporation tax in 2015 — so unusual that Ireland’s top tax man felt obliged to write to the parliament to explain what is going on. But the explanation left a lot to be desired. According to government data, Ireland received 57.7 percent more… – Continue reading
A European Union investigation into whether Apple’s bespoke tax arrangement with the Irish government amounts to illegal state aid has been delayed again, as officials in Brussels continue to gather more information. “We do not expect any decision until after the new year,” a spokesperson for the European Commission told… – Continue reading
Dec. 14 — The Coca-Cola Co. filed a petition in U.S. Tax Court challenging a proposed $9.4 billion income adjustment related to the company’s transfer pricing for tax years 2007-09 (Coca-Cola Co. v. Commissioner, T.C., petition filed, 12/14/15). If the adjustment is sustained, the company could face a tax bill… – Continue reading
Cash doesn’t flow directly from buyers’ pockets to Microsoft’s headquarters in Redmond, Wash. Instead, the company operates through three regional sales units, centered in Ireland, Singapore and Puerto Rico. These groups control the rights to profit from Microsoft products around the world. By conducting sales from places with small populations… – Continue reading
Patent Boxes, Innovation Boxes, Intangible Property Boxes, Knowledge Development Boxes (IP Regimes) – countries may use different names, but all of these regimes are designed to allow a preferential rate of tax to be applied to income generated from intangible property (IP). There are a number of these regimes in… – Continue reading
There are a variety of benefits to moving offshore, yet few would argue the assertion that tax neutrality is paramount among them. As anyone familiar with the phrase “tax haven” would surely recognize, many countries offer strongly favorable tax terms as an incentive to draw new business. Written by CT… – Continue reading
Publican pays €3m in tax, interest, and penalties Two of the four largest published tax settlements in the last quarter were made by businesses in the Cork region. Revenue’s latest tax defaulters’ list for the three months to the end of September shows that a total of €13.99m was recouped,… – Continue reading
Global corporation tax reform proving good for country As things stand, it would appear that matters are going Ireland’s way insofar as global corporation tax reform is concerned. The country-by-country reporting rules that have been proposed under the OECD’s Beps programme, and that commentators had been focused on in relation… – Continue reading
The EU Council has adopted a new transparency directive aimed at preventing corporate tax avoidance The directive, which was proposed by the European Commission (EC), is aimed at improving transparency on tax rulings given by member states to companies about how their taxes are calculated. Under the new directive, member… – Continue reading
Finance Minister Edward Scicluna pushes for ‘flexibility’ during today’s meeting of EU finance ministers in Brussels Malta has come out strongly against applying “rigid rules”, urging the European Commission to adopt a more flexible approach as it drafts legislation on taxation. Corporate tax was high on the agenda of EU… – Continue reading
Ministers due to adopt conclusions on future of EU’s code of conduct on business taxation Corporate tax will top today’s meeting of EU finance ministers in Brussels, as ministers discuss the latest state of play regarding the common consolidated corporate tax base (CCCTB) and cross-border tax rulings. In particular, finance… – Continue reading
The Internal Revenue Service (IRS) continues its focus on perceived abuses in corporate inversion transactions. On November 19, the IRS released Notice 2015-79, which places new limitations on the ability of a U.S. multinational corporation to reduce its U.S. tax burden by inverting its corporate structure. U.S.-based multinationals are subject… – Continue reading
Michael Noonan, Ireland’s Finance Minister, underlined Ireland’s position on key international tax issues that were scheduled for discussion at a meeting of the EU’s Economic and Financial Affairs Council (ECOFIN), reports Tax News. Noonan was addressing the Joint Committee on Finance, Public Expenditure, and Reform on December 1, 2015, in… – Continue reading
WASHINGTON — Hillary Clinton on Wednesday will unveil a proposal for a new “exit tax” aimed at cracking down on corporate inversions, a practice that permits U.S. companies to merge with corporations overseas to lower their tax bill. The new tax would be part of a broader effort to target… – Continue reading
The taxman has appointed a chief analytics officer to lead its mining of taxpayer data. Daniel Sinnott has joined the Revenue Commissioners in the newly created role of chief analytics officer, having previously held a variety of private sector consulting and analytics roles. Because of the nature of its activities,… – Continue reading
Employees at Allergan have been told a proposed merger with Pfizer is about changing healthcare – not skirting tax law. Allergan’s global chief executive Brent Saunders has written directly to the company’s employees – including around 1,000 in Ireland, telling them the controversial deal is not just about tax savings…. – Continue reading
Company changed tax address from U.S. to Ireland this year CEO says 40 percent of cash still located outside U.S. Medtronic Plc’s decision to move its tax address out of the U.S. is already starting to pay dividends. The medical device company used a deal with Covidien Plc this year… – Continue reading
A bill approved by New Jersey’s Assembly would strike back against “corporate inversions,” when a U.S. company buys a smaller company abroad, then changes its address to slash its tax bill. Under the measure approved Thursday, New Jersey would stop offering contracts and development subsidies to these artful tax dodgers… – Continue reading
The Financial Services Council has urged the Government to broaden the range of collective investment vehicles (CIV) available for foreign investors in order for Australia to reach its full potential as a financial services exporter. The FSC said offshore investors were not always familiar with the nuts and bolts of… – Continue reading
Developments driven by Base Erosion and Profit Shifting (Beps) boost Irish tax The closing down by Irish multinationals of tax planning arrangements involving offshore or foreign subsidiaries is part of the reason for Ireland’s increased corporation tax receipts, according to an informed source. Under country-by-country reporting rules, Irish companies with… – Continue reading
Corporate taxes continued to flood into the exchequer’s coffers last month, compounding a mystery about their source and raising doubts about whether a future government can rely on the company receipts after the election. The Revenue Commissioners and the Department of Finance have moved in recent weeks to dampen down… – Continue reading
