BRUSSELS (Alliance News) – The EU stepped up the fight against corporate tax avoidance Thursday, unveiling proposals including an EU-wide blacklist of international tax havens, as part of a wider clampdown on firms using loopholes to reduce their tax bills. The EU’s executive estimates that member states are deprived of… – Continue reading
In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting out the parameters for automatic exchange of country-by-country reports on large multinational corporations. The agreement — the Multilateral Competent Authority Agreement on… – Continue reading
Despite EU intentions to crack down on tax avoidance, the European Commission’s Anti-Tax Avoidance Package does not do what it says on the tin, warns Oxfam, and developing countries will feel the EU’s failure most. The package comes a week after the international NGO revealed that just 62 people own… – Continue reading
Tech company’s 2015 earnings will be announced next week as governments aim to crack down on Google’s controversial tax avoidance arrangements Google is poised to confirm next week that controversial tax structures in Ireland, the Netherlands and Bermuda have boosted its offshore cash mountain to more than $43bn (£30bn), figures… – Continue reading
Directive follows a series of high-profile tax cases involving Google, Apple and others. Rampant corporate tax dodging and sweetheart deals that cheat governments and skew markets, have prompted the European Commission to unveil a new directive Thursday. The proposed legislation follows a quick succession of tax rulings, settlements and investigations… – Continue reading
On 5th October 2015, the OECD released its final reports setting out the action plan on Base Erosion and Profit Shifting (BEPS) project, thus concluding the two year project which started at the behest of G20 countries in 2013. The reports are aimed at suggesting the measures to reform the… – Continue reading
GE division makes millions in sales to health service, and is net beneficiary from UK Exchequer One of the biggest suppliers of equipment and testing services to the NHS pays barely any corporate tax in the UK, despite receiving hundreds of millions of pounds a year from medical sales to… – Continue reading
A group of businesses in the Welsh town of Crickhowell have gone offshore as part of a campaign to try and get HMRC to change tax laws. The Welsh town of Crickhowell is spearheading a unique campaign to get HM Revenue & Customs (HMRC) to change the laws so companies… – Continue reading
India’s biggest source of FDI is India itself, money departing on a short holiday to a tax haven and then routed back as FDI. Will the government muster up the political will to clamp down on the tax-allergic business elite? This could be a bumper year for the ever-lucrative tax… – Continue reading
As from 1 January 2016, new rules have become effective in the Netherlands that require multinational enterprises (“MNEs“) to comply with new transfer pricing documentation requirements, including the obligation to prepare a Country-by-Country Report (“CbC Report“), a Master File and a Local File. These rules essentially implement Action 13 of… – Continue reading
The proceeds from illegal tax breaks brokered between an EU state and a multinational company, known as clawbacks, should be returned either to the EU budget or to the coffer of other states unfairly deprived of the money, according to MEPs. The idea was endorsed by the European parliament in… – Continue reading
Switzerland took an important step toward becoming a renminbi trading hub on Thursday with its inauguration of a new branch of the China Construction Bank, (CCB), one of the biggest financial institutions in the world. The Zurich branch of the CCB has been authorised by China’s central bank to operate… – Continue reading
The Netherlands will be at the forefront of efforts to combat multinationals’ tax avoidance, its finance minister has said. The comments come amid a dispute with the European Commission over his country’s tax treatment of Starbucks. The Commission, the EU’s executive arm, will propose a new set of binding rules… – Continue reading
The Netherlands will prioritize action against corporate tax avoidance during its Presidency of the Council of the European Union, from now until the end of June. In a report detailing its plans for its six-month term, the Dutch Government said: “The Netherlands Presidency will prioritize action against tax evasion and… – Continue reading
Documentary Evidence European Union lawmakers sitting on the TAXE committee investigating corporate tax evasion in Europe say they have become frustrated at changes to their mandate and the unwillingness of the European Commission to hand over documents for their investigation. The matter is all the more personal as Commission President… – Continue reading
Federal Supreme Court of Switzerland denies treaty benefits in case of dividend paid on shares acquired for hedging derivative contracts. Court stated that due to the fully hedged nature of ownership, there was economic nexus and interdependency between two independent transactions and therefore, the “intermediary” bank did not have beneficial… – Continue reading
AB InBev says it’s `disappointed’ and is assessing its options Vestager lashes out at `double non-taxation’ schemes BRUSSELS – The European Union ordered Belgium to recover about 700 million euros ($763 million) in illegal tax breaks given to at least 35 companies, including Anheuser-Busch InBev and BP, as regulators continued… – Continue reading
The European Union ordered Belgium to recover about 700 million euros ($762 million) in illegal tax breaks given to at least 35 companies, including Anheuser-Busch InBev NVand BP Plc, as regulators continued a crackdown on overly generous tax schemes throughout the 28-nation bloc. The European Commission told Belgium to recoup… – Continue reading
January 2016 You will find below a summary of some of the most important tax developments that have happened since the release of our last newsletter, at OECD, EU or country level, in the area of tax transparency and the fight against tax avoidance. EU – Tax transparency and anti-BEPS… – Continue reading
Dutch holding companies have been again included on the Brazilian government’s list of “privileged tax regimes.” Accordingly, this action has implications for purposes of the transfer pricing, thin capitalization, and tax deductibility rules. Background Under Brazilian tax law, the concept of “privileged tax regimes” is relevant for determining: Whether Brazil’s… – Continue reading
Viacom Inc. was accused by one of its former executives of plotting to hide revenue from “Teenage Mutant Ninja Turtles” in a Netherlands entity to avoid taxes. The ex-vice president for financial planning at Viacom claims she was fired after opposing what she believed was an illegal tax dodge. Nataki… – Continue reading
On January 6, 2016 the text of the Memorandum of Understanding with respect to the Exchange of Information for Tax Matters as concluded between the Competent Authorities of the Netherlands and Georgia (Hereafter: the MoU) was published in the Dutch Staatscourant. The MoU was signed by the Dutch competent authorities… – Continue reading
A Viacom whistleblower claims she was sacked by the media company for opposing its alleged plan to illegally avoid paying U.S. taxes on the international licensing rights to Teenage Mutant Ninja Turtles. In a complaint filed in Manhattan federal court on Tuesday, former vice president Nataki Williams said she was… – Continue reading
Legislation amending the rules governing transfer pricing documentation—to include country-by-country reporting, as well as master file and local file provisions—has been enacted and has an effective date of 1 January 2016. The Dutch Upper House (Eerste Kamer) on 22 December 2015 passed the legislation (the bill is referred to in… – 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
The Minister of Finance has announced a decision on international information exchange based on the FATCA agreement. This decision contains a publication of the concluded in November 2015 between the competent authorities of the Netherlands and the US administrative arrangements for the practical application of the FATCA agreement EN-US 2013… – Continue reading
On December 30, 2015 on the website of the Dutch Staatscourant the text of the Competent Authority Arrangement between the Competent Authorities of the United States of America and the Kingdom of theNetherlands was published. The Competent Authority Arrangement between the Competent Authorities of theUnited States of America and the… – Continue reading
At the House of the approval bill filed from between the Kingdom of the Netherlands, on behalf of Curaçao, and the United States of America Convention concluded improve international tax compliance and implementing FATCA (hereinafter Cur IGA). The Convention is published in Trb. 2015, 11 and 144. The approval is… – Continue reading
On 15 September 2015, the Dutch government released its budget for 2016, containing the Tax Plan 2016, which includes certain amendments to Dutch tax law. One of the proposed amendments was the inclusion of an anti-hybrid rule in the Dutch participation exemption regime (“PER”). On 22 December 2015, the amendments… – 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
Fertilizer maker CF Industries and Dutch rival OCI NV, which agreed to merge in August, said they would move the tax residency of the combined company to the Netherlands from the U.K., in a move to satisfy inversion rules put in place by the U.S. Treasury. When the deal was… – Continue reading
CF Industries (CF – Analyst Report) and Netherlands-based fertilizers and industrial chemicals producer – OCI N.V. – said that they have amended their merger agreement originally announced in Aug 2015. Under the modified agreement, the jurisdiction of incorporation and tax residency of the new combined company has been changed to… – 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
Group companies, irrespective of the jurisdiction, will have to conform to common standards The Organization for Economic Cooperation and Development (OECD) recently released 15 action-plans to address the issue of “Base Erosion & Profit Shifting” or BEPS, which has led to misalignment between where taxes are paid and where value… – Continue reading
Tax disputes are to no longer form a part of a Bilateral Investment Treaty (BIT) signed by the government with another country, the Union Cabinet decided on Wednesday, clearing a revised model text The idea is that foreign companies finding themselves in a tax row with the government will not… – Continue reading
On December 8, there was a brief note in the media about the fact that Malta had managed to include a reference to flexibility into a European Council communiqué on taxation. You would be forgiven for overlooking it, assuming it was just a pedantic attempt to score political points. Think… – 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
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
Why would anyone object to Uber, the user-friendly online drive-share service? Uber’s many riders obviously love it, but it seems civic officials are having conniptions. Their main complaint is that Uber drivers are unlicensed to carry passengers and might not have adequate insurance. In addition, officials are genuinely concerned that… – Continue reading
Coffee chain Starbucks said it paid £8 million in corporation tax last year after posting record UK profits. The UK arm of the US-based chain said pre-tax profits jumped to £34.2 million in the year to September 27, compared with less than £2 million a year ago – as it… – 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
The European Commission asked the Netherlands on 19 November to amend the limitation on benefits (LOB) provision in the existing Dutch-Japanese tax treaty. The LOB provision may be detrimental to Dutch companies held by residents of certain EU/EEA countries when they receive interest, royalties and dividends from Japan. They may… – Continue reading
Tax evasion costs the EU €1 trillion a year in lost tax revenue, according to the European Commission. The Lux leaks scandal showed that EU countries sometimes court multinationals with advantageous tax schemes. These practices were investigated by the Parliament’s special committee on tax rulings. MEPs adopted its report last… – 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
After the LuxLeaks affair in November 2014, the European Parliament established a special committee “on tax rulings and other measures similar in nature or effect” (TAXE) in February 2015. The committee’s report was adopted in a plenary session of the European Parliament on 25 November 2015. The Conference of Presidents… – 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
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
The European Commission today announced its decision to launch a “state aid” investigation into tax rulings granted by the tax authorities in Luxembourg to a company that is a member of a U.S.-based multinational taxpayer group. Background According to a February 2015 report, in 2008-2009, the group transferred its European… – Continue reading
