Category: Corporates

African authorities strive to reduce tax leakages

African tax bodies will mark the 10th anniversary of their umbrella organization, the African Tax Administration Forum (ATAF), in their efforts to reduce tax leakages. A total of 38 African countries are members of the ATAF, making the organization Africa’s largest body that collectively deals with global tax issues affecting… – Continue reading

‘Who is buying Seattle?’: New report issues warnings on Seattle’s luxury housing boom

Seattle’s luxury housing boom will worsen inequality and affordability in the city, according to a new report, which calls for officials to require more transparency on who is actually buying luxury real estate in the area. The report — “Who is Buying Seattle? The Perils of the Luxury Real Estate… – Continue reading

Nigeria: Unprecedented Global Drive For Tax Transparency – The Nigerian Perspective

In the last few years, the international tax space has experienced an unprecedented drive to achieve increased transparency in the tax practices of Multinational Enterprises (MNEs) and individuals in order to curb tax avoidance and evasion. ... - Continue reading

The Fiat and Starbucks state aid tax cases: an absolute loss for legal certainty.

In late September, the EU General Court released its decisions in two long-awaited state aid appeals: Fiat (cases T-755/15 Luxembourg v Commission and T-759/15 Fiat Chrysler Finance Europe v Commission) and Starbucks (cases T-760/15 Netherlands v. Commission and T-636/16 Starbucks and Starbucks Manufacturing Emea v. Commission). ... - Continue reading

Financial resources hit P31 trillion as of March

The country’s total financial resources reached P31.044 trillion as of end-March 2019, according to the latest survey of the Bangko Sentral ng Pilipinas. Preliminary results of the Other Financial Corporation Survey showed the total assets of depository corporations reached P23.068 trillion while the combined resources of other financial corporations hit… – Continue reading

Worldwide: Financial Institutions And Personal Data

Combating Tax EvasionIn recent years, there have been several high-profile prosecutions for the crime of tax evasion (for example the actor, Wesley Snipes, and the footballer, Lionel Messi). Governments around the world have been making a concerted effort in an attempt to tackle this problem. Their objective is for their respective tax administrations to work together so that taxpayers pay the correct amount of tax in the correct jurisdiction. ... - Continue reading

EU court backs use of arm’s length principle to assess Starbucks, Fiat APAs for state aid violation

The EU General Court today released long-awaited rulings in the Fiat and Starbucks tax state aid cases, concluding in both decisions that it is appropriate for the European Commission to assess whether an advance pricing agreement (APA) confers a selective advantage to a taxpayer for state aid purposes by referring to the arm’s length principle. ... - Continue reading

Canada, Switzerland ratify instrument to tackle tax avoidance

Canada and Switzerland on August 8 deposited with the OECD their instruments of ratification for the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS MLI). The BEPS MLI, negotiated by over 100 countries and jurisdictions, updates the existing network of tax treaties and… – Continue reading

Bermuda Monetary Authority: 50 Years Later

As the Bermuda Monetary Authority [BMA] celebrates 50 years in 2019, we take a look back at the last five decades. From providing sound policy advice to pushing Bermuda forward as a reputable place to conduct business, the BMA has had an incredible impact on Bermuda’s financial landscape. 1990-1999 Exchange… – Continue reading

Australia’s tax office can use Paradise Papers data to pursue multinationals: Court

Australia’s High Court ruled unanimously that giant Glencore could not rely on “legal privilege” to prevent the Australian Tax Office (ATO) from accessing emails, bank records, PowerPoint presentations and other files from the 2017 Paradise Papers investigation. Typically, documents marked “privileged” do not have to be disclosed in court. Companies… – Continue reading

Canadians for Tax Fairness concerned about inaction on Panama Papers

It is estimated that the use of tax havens is costing federal and provincial governments at least $7.8 billion in lost tax revenue. Low and middle income Canadians are the ones paying for that missing $7.8 billion in tax revenue. Ottawa (11 Aug. 2016) — The leak of the Panama… – Continue reading

Gaming Companies Call for Reaching USA-Croatia Double Taxation Avoidance Deal

ZAGREB, August 21, 2019 – Computer gaming is the most propulsive segment of the IT industry worldwide, and this trend is present in Croatia, too, where local gaming companies export all their products, however the biggest challenge in doing business is the absence of a Croatia-USA double taxation avoidance agreement,… – Continue reading

CIAT’s transfer pricing “Cocktail” provides solutions for transactional net margin method overuse

In recent years there has been a major public outcry for governments to take action to force multinational groups to pay a fair share of tax in the jurisdictions where their economic activities take place and to stop shifting profits to offshore tax havens. ... - Continue reading

CBI Dominica: Leading with Transparency

19 August 2019, Since 1993, Dominica has been at the forefront of the citizenship by investment (CBI) industry, setting high standards in due diligence, processing times, and most recently, transparency. Indeed, this month the nation liaised with prominent international professional services firm PricewaterhouseCoopers (PwC) to release a report clarifying the… – Continue reading

US appeals court sides with Amazon in $1.5 billion transfer pricing dispute

A US federal appeals court on Friday affirmed the Tax Court’s decision in Amazon, ruling that cost sharing buy-in payments made by Amazon’s Luxembourg subsidiary in exchange for Amazon’s transfer of intangible property should not include compensation for transferred residual business assets such as workforce in place, goodwill, and going concern value. ... - Continue reading

What happened to the proposed amendments to Bank Secrecy Act?

The news is replete with discussions on the refiling of the proposed bills for the other TRAIN Packages with the 18th Congress. However, there seems to be no discussion yet on any proposed amendment to the Bank Secrecy Act, Republic Act (RA) 1405, as amended, particularly the proposed amendments to… – Continue reading

High Court confirms ATO can use information from data leaks

Today the High Court confirmed that the ATO may use information obtained from data leaks, even if leaked from a law firm. Second Commissioner Jeremy Hirschhorn said today’s decision in Glencore International v. Commissioner of Taxation means the ATO can continue to use the ‘Paradise Papers’ and other similar data… – Continue reading

Mauritius leaks latest reminder of how much we lose to tax havens

Mauritius leaks latest reminder of how much we lose to tax havensA report by Canadians for Tax Fairness Bay Street and Tax Havens revealed how over 90% of Canada’s largest corporations have subsidiaries in tax havens. Ottawa (06 Aug. 2019) — Last month Canadians for Tax Fairness reported that, while… – Continue reading

Taxpayers given six months to challenge Denmark transfer pricing assessments based on insufficient documentation

A Danish tax administration decree, published 12 July in response to the Supreme Court’s decision in the Microsoft case, establishes a new practice for determining whether transfer pricing documentation must be available at the time the taxpayer is required to file its tax return. ... - Continue reading

Journalists publish details of 200+ companies using offshore law firm, conclude Mauritius promotes tax avoidance

Data on more than 200 companies that engaged the Mauritius office of Conyers Dill & Pearman were published on the internet today by the International Consortium of Investigative Journalists (ICIJ) as a result of leak of confidential information. ... - Continue reading

Netherlands draft law requires disclosure of cross-border transactions to tax authorities

On July 12 the Netherlands government published a legislative proposal implementing the EU mandatory disclosure directive. This follows an internet consultation on a draft legislative proposal which ran from December 19, 2018 — February 1, 2019. ... - Continue reading

Portugal: Central bank to disclose public report on large debtors

The Bank of Portugal (BdP) is to publicly disclose aggregated information about large bank debtors by 17 July, announced the chair of the Budget and Finance Committee. On 23 May, the central bank sent parliament an extraordinary report on the problematic loans and other assets that caused banking problems and… – Continue reading