Category: Jurisdiction

European Commission releases press material for the upcoming G20 summit in Antalya

On November 10, 2015 the European Commission published a brochure titled “Did you know… Facts and figures about the European Union and the G20 – 2015 Turkey G20 Antalya, 15>16 November 2015”. According to the European Commission, the brochure sets out the European Commission’s aims for the G20 summit. The… – Continue reading

Australia: The transfer pricing Chevron decision – funding, parental support, currency… and the experts

Key Points: The rejection of the Commissioner’s position on the relevance of credit rating agencies and the relevance of implicit support will give rise to uncertainty going forward, as it is unclear how an arm’s length interest rate can be practically determined. The Federal Court’s recent decision in Chevron Australia… – Continue reading

Michael Gray: The UK’s tax avoidance scandal is a sorry tale

DID you hear the story about the Queen, tax evasion, a nationalised British bank for the rich and famous, a whistleblower and a £7bn under sale to ‘reward cronies and cheat the taxpayer’? Sounds like a pretty big deal, right? But last Thursday’s damning testimony from Helen Goodman MP –… – Continue reading

3 Stocks to Buy if Chris Christie Becomes President

A Chris Christie administration would likely make shareholders at some major U.S. companies very happy. The two-term New Jersey Governor has called for an array of pro-growth, business-friendly reforms as he bids for the Republican nomination. Christie is in favor of lowering corporate taxes so companies earn more profits, raising… – Continue reading

Irish PM defends country’s corporation tax arrangements

Irish Prime Minister Enda Kenny has defended his country’s low rate of corporation tax, currently set at 6.25 per cent, and Dublin’s arrangements with global corporations which house subsidiaries in the country, reports Digital Look. Over the last decade, major corporations such as Google and Dell have created corporate subsidiaries… – Continue reading

The Ministry of Finance proposed to soften the terms of the Amnesty

Moscow. November 10. The Finance Ministry has prepared proposals aimed to strengthen Amnesty of capital, which is now actually fails, reports the newspaper “Kommersant”. The law on the voluntary Declaration by individuals of assets and accounts, is known as the law on the legalization or Amnesty of capital, earned from… – Continue reading

Still Broken: major new report on global corporate tax cheating

“In 2013 the OECD, supported by the G20, promised to bring an end to international corporate tax avoidance which costs countries around the world billions in tax revenues each year. However, with the recently announced actions against corporate tax dodging, G20 and OECD countries have failed to live up to… – Continue reading

Vestager Lauds Tax Decisions as She Reviews Apple, Amazon Cases

The European Union’s top antitrust official lauded rulings ordering two companies to repay tens of millions of euros in back taxes as she considers similar decisions involving Apple Inc. and Amazon.com Inc. European Union competition chief Margrethe Vestager told lawmakers Monday that the rulings last month against Starbucks Corp. and… – Continue reading

G20 among biggest losers in large-scale tax abuse – but poor countries relatively hardest hit

Headline: G20 among biggest losers in large-scale tax abuse – but poor countries relatively hardest hit G20 countries are the biggest losers when US multinationals avoid paying taxes where they do business. This is the main finding of a new report on the global tax system, ‘Still Broken,’ released by… – Continue reading

France wants financial transactions tax accord in Brussels

France wants an agreement on a financial transactions tax (FTT) struck on Monday after a meeting of euro zone finance ministers, Finance Minister Michel Sapin said, reports Reuters. “We have done most of the technical work. I think the time has come to make a decision,” Sapin told reporters. “We… – Continue reading

The EC repeals savings taxation directive

The Council of European Union has revoked Directive 2003/48/EC, which has allowed tax administrations better access to information on private savers since 2005. By revoking the directive, which is part of a tax transparency package presented by the Commission in March this year, the Council says it strengthens measures to… – Continue reading

OECD warns of property bubble risk

Think tank says Ireland has ‘robust’ growth and Budget 2016 was ‘reasonable’ The Organisation for Economic Co-operation and Development has warned of big threats to Ireland’s “robust” growth, among them the risk of another property bubble. Amid anxiety in the EU/IMF troika about Government moves to loosen the fiscal stance,… – Continue reading

Paradigm shift in tax landscape through BEPS must also engender tax certainty

A paradigm shift in the way business is conducted is taking place as new base erosion of profit shifting (BEPS) rules are aligned with tax systems, but more tax certainty and rules that suit specific African circumstances are needed, a Deloitte OECD Transfer Pricing Guidelines seminar heard on Wednesday, 04… – Continue reading

United States: Steps Foreign Persons Can Take To Avoid Unnecessary U.S. Estate Tax

A recent CNBC report suggests that several billion dollars of estate tax due from the estates of foreign decedents on investments in U.S. stock and real estate goes uncollected by the IRS every year. The report noted a large discrepancy between the amount of foreign investment in these assets and… – Continue reading

Crickhowell: Welsh town moves ‘offshore’ to avoid tax on local business

The Powys tax rebellion, led by traders including the town’s salmon smokery, local coffee shop, book shop, optician and bakery, could spread nationwide When independent traders in a small Welsh town discovered the loopholes used by multinational giants to avoid paying UK tax, they didn’t just get mad. Now local… – Continue reading

NAM Highlights Concerns with BEPS, Critical Need for International Tax Reform

Dorothy Coleman, the NAM’s Vice President, Tax and Domestic Policy, today joined U.S. Senator Rob Portman (R-OH) and a panel of experts, including representatives from the Organization for Economic Co-Operation and Development (OECD), to discuss key international tax issues, including the Base Erosion and Profit Shifting (BEPS) project recommendations recently… – Continue reading

U.S. missing out to corporate tax havens

U.S. companies moved $500 billion to $700 billion in profits to countries with low or no corporate tax rates in 2012 alone, according to new research published by tax reform campaigners Tuesday. Tax avoidance on such a large scale means the U.S. accounts for about 71% of profits worldwide that… – Continue reading

US corporations avoid an estimated $2 billion tax every year in Australia: report

United States corporations avoid an estimated $US1.45 billion ($2.06b) of tax in Australia each year by shifting their profits to low or no tax countries, research shows. A joint report by advocacy and union groups Tax Justice Network, Oxfam, Global Alliance for Tax Justice and Public Services International says in… – Continue reading

Why Australia’s landmark tax ruling against Chevron is a first battle in a global war on profit shifting

At a very high level, it’s a simple concept: a multinational borrows money from a related company overseas, and then uses the interest bill and the repayment methods to reduce tax exposure in Australia. If the loans – and the interest rates – are big enough, the tax savings can… – Continue reading

EU to rule on Apple tax avoidance by Christmas

Ireland is expecting European Union regulators to issue a decision on the country’s tax deal with Apple before the end of the year. The Irish finance minister said the move could force the iPhone maker to pay substantial back taxes. The European Commission has already ordered Dutch authorities to recover… – Continue reading

Bermuda: Day Of The Deed

Article by Patrick W Martin and Ashley Fife With a net worth of USD77.1 billion, Mexican telecoms businessman Carlos Slim Helú was ranked the second richest person in the world in a 2015 survey.1 At the end of 2014, 16 of Mexico’s citizens were on Forbes’ billionaires list.2 As for… – Continue reading

Senate inquiry backs tax avoidance bill

A Senate inquiry committee has endorsed government measures to crack down on multinational tax avoidance. A Senate committee has recommended the government review proposed multinational tax avoidance measures within three years to ensure they stop companies siphoning profits offshore. An inquiry into a government bill to crack down on companies… – Continue reading

Mexico’s 16% Discount for Paying Cash Shows Tax Evasion’s Allure

On a warm afternoon last month, Mexican central bank Governor Agustin Carstens looked out over sun-drenched piles of dirt and construction equipment near Guadalajara and hailed the groundbreaking of a new currency-printing plant as a sign of a solid economy. There’s one catalyst for rising cash demand that isn’t a… – Continue reading

Governments have taken an important step towards ensuring cross border consumption tax

Governments have taken an important step towards ensuring that consumption taxes on cross-border transactions are effectively paid in the jurisdiction where products are consumed, while minimizing the risks that uncoordinated tax rules distort international trade. The decision by representatives of more than 100 countries and jurisdictions to endorse the new… – Continue reading

Ghana weak laws offer 67% tendency for illicit financial flows

Ghana’s financial secrecy – the tendency to facilitate tax evasion, money laundering and illicit financial transfers – has been rated at a fairly high 67 per cent. The Tax Justice Network, an organisation concerned with tax havens and tax evasion, ranked Ghana 48th out of 92 territories, in its 2015… – Continue reading

Transfer pricing and arm’s length principle

The dramatic expansion of international trade and development of new business strategies due to globalisation, converted the world into a large global market. In connection with that, companies have been using complex networks of subsidiaries and branches (e.g. permanent establishments) in order to continue most of their operations. The Multinational… – Continue reading

Taxing the future

Although Finance Minister Nhlanhla Nene played it very close to his chest regarding the specifics of tax reforms we can expect in the February 2016 Budget, we’ve compiled a snapshot of the possible tax reforms announced in his 2015 Medium Term Budget Policy Statement. Corporate income tax There are great… – Continue reading

NZ welcomes Cook Islands measures to tackle tax avoidance

NZ welcomes Cook Islands measures to tackle tax avoidance Minister of Revenue Todd McClay has welcomed a decision by the Cook Islands government to implement the ‘Automatic Exchange of Financial Account Information in Tax Matters Agreement’ (AEOI) and says the Cooks Islands and New Zealand will play their part to… – Continue reading

FinCEN’s expanding application of the Bank Secrecy Act and anti-money laundering regulations

The Financial Crimes Enforcement Network (FinCEN) is again flexing its regulatory muscles by increasing the breadth and scope of the types of entities regulated by the Bank Secrecy Act (BSA). Among other things, the BSA requires certain types of financial institutions to implement anti-money laundering (AML) programs and file suspicious… – Continue reading

Belgium’s new CFC rule: the ‘Cayman tax’

The Belgian Federal Parliament recently adopted a new controlled foreign corporation provision, known as the “Cayman tax”, that allows Belgian tax authorities to look through low-taxed offshore structures to directly tax their Belgian resident founders and third-party beneficiaries on the structure’s income. Belgium’s introduction of the Cayman tax is in… – Continue reading

Evidence of efforts to help multinationals avoid tax strengthen call for proper EU investigation

Over the weekend, German news magazine, Der Spiegel, reported that over many years EU member states such as Luxembourg and the Netherlands have sabotaged attempts to counter profit shifting to low tax jurisdictions via ‘patent boxes’ under the political leadership of current President of the European Commission, Jean Claude Juncker,… – Continue reading

FRANCE: STATUS OF TRANSFER PRICING DOCUMENTATION, COUNTRY-BY-COUNTRY REPORTING

Legislative proposals being considered in France would require the automatic filing of transfer pricing documentation and, as part of this documentation, country-by-country reporting. STATUS OF PROPOSALS The Finance Committee of the French National Assembly has started its consideration of tax provisions relating to the second part of the Finance Bill… – Continue reading

Implementation problems in connection with the FATCA Agreement

The BMF has application letter sent to the chief financial authorities of the countries associated with the between the Federal Republic of Germany and the United States of America concluded by 31.5.2013 FATCA Agreement. Background Background of extensive, comprehensive 71 pages, application letter from the Federal Ministry of Finance on… – Continue reading

Congressman Introduces Bills to Curb Corporate Tax Inversions and Deferrals

Rep. Mark Pocan, D-Wis., has introduced two pieces of legislation to combat corporate tax inversions and tax deferral. The Corporate Fair Share Tax Act and the Putting America First Corporate Act would prevent corporations from using “tax inversions” to reduce a company’s U.S. tax burden and hide profits overseas. Corporate… – Continue reading

Gov’t approves support for SMEs until 2020

Transportation and other issues also taken up by the Cabinet Prague, Nov 9 (ČTK) —The Czech government today approved the Industry and Trade Ministry’s program Expansion, under which Kč 9.5 billion (€350 million) should be provided in support of small and medium-sized enterprises until 2020, Deputy Prime Minister Pavel Bělobrádek… – Continue reading

Democrat targets corporate tax-avoidance deals in U.S. Congress

Tax-driven “inversion” deals that let companies flee the U.S. tax system by relocating abroad, if only on paper, would be curbed under legislation introduced in Congress, as Pfizer Inc (PFE.N) pursues such a deal with rival Allergan Plc (AGN.N). Wisconsin Democratic Representative Mark Pocan’s bills likely have little chance of… – Continue reading