Category: A-E

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

Transfer (mis)pricing

TRANSFER pricing — the pricing of commodities traded between or within multinational enterprises — is a legal practice and a key feature of cross-border and intra-firm transactions. The United Nations prefers to use the broader phrase ‘trade pricing’ in addressing this practice and defines it as a ‘normal incident of… – Continue reading

Bank of Singapore’s Hong Kong CEO on Developing a Greater China Proposition

As Bank of Singapore’s Global Market Head for Greater China and North Asia, and since March 2018 also Hong Kong CEO, Derrick Tan has plenty of challenges in front of him. But he can draw on from his multi-faceted background – he spent five years as an investigating officer with… – Continue reading

British overseas territories top corporate tax loophole index

Governments are stepping up efforts to recoup more tax from multinationals, with the European Commission forcing iPhone maker Apple to repay 13 billion euros after it used Ireland to cut its tax on European profits to almost zero. The Tax Justice Network, a group campaigning for transparency, said its study… – Continue reading

Tax authorities mount raids on 19 German banks and houses

Investigation is linked to Panama Papers and part of money laundering allegations Eleven banks and eight private homes and offices across Germany have been raided by police and tax investigators as part of a wide-ranging investigation into tax evasion. The raids, which began at dawn on Wednesday and went on… – Continue reading

Kamal says fully foreign-owned cos no more to be allowed

Finance minister AHM Mustafa Kamal has said that the foreign companies will be required to have local partners for doing business in Bangladesh as the government wants to bring them under the tax net. ‘No foreign company can do business alone here any longer,’ he told reporters on Thursday after… – Continue reading

Africa’s problem with tax avoidance

Every year African countries lose at least $50 million in taxes — more than the amount of foreign development aid. So where is it all going and how can multinational companies be held to account? NGOs continue to raise the alarm. African countries are being cheated out of billions in… – Continue reading

Swedbank hires EY to conduct forensics into money laundering

Swedbank, one of the largest banks in Sweden, has hired professionals services firm EY to investigate the bank’s possible involvement in large scale money laundering. According to media reports in Sweden, over the period of nearly ten years the bank facilitated approximately $5.8 billion worth of suspicious transactions. The transactions… – Continue reading

Tax Netflix and other e-commerce companies, say Canadians and CRA professionals

OTTAWA, Feb. 21, 2019 (GLOBE NEWSWIRE) — The federal government needn’t worry about a consumer backlash to a sales tax on Canadians’ Netflix accounts, if newly released results from an Environics Research poll and a separate survey of Canada Revenue Agency (CRA) tax professionals are any indication, says the Professional… – Continue reading

OECD moves toward consensus on taxing multinational tech companies

The Organization for Economic Cooperation and Development is making progress on dealing with the tax challenges of the digital economy with a goal of arriving at a new consensus-based long-term solution in 2020. The OECD announced last week that the countries and jurisdictions participating in the OECD/G20 Inclusive Framework on… – Continue reading

Apple settles 10-year tax battle with France, paying a reported €500M ($570M)

Apple has settled a ten-year tax battle with France, agreeing to pay a reported half a billion Euros ($570M) in back tax. The French government had accused Apple of evading or avoiding tax due on sales made in France. The line between tax evasion, which is illegal, and aggressive tax-avoidance,… – Continue reading

Chile May Tax eCommerce Companies 19 Pct

Chile is considering a 19 percent tax on multinational eCommerce companies like Amazon, Netflix and Uber. Finance Minister Felipe Larrain made the announcement on Thursday (Jan. 10), and if it comes to fruition, the rate would be almost double what was originally proposed, Reuters reported. The Chilean Chamber of Commerce,… – Continue reading

Austria to Introduce Tax on Tech Giants With Annual Revenues Over $864Mln – Kurz

VIENNA (Sputnik) – The Austrian government will introduce a 3-percent tax on international tech giants with an annual turnover exceeding 750 million euros ($864 million), Austrian Chancellor Sebastian Kurz said on Thursday. “Europe currently does not have taxation of digital Internet giants and Austria intends to become a pioneer in… – Continue reading

IRS gives foreign banks a break in Trump tax law’s new levy

The Internal Revenue Service is giving foreign-based banks with U.S. operations some leeway when calculating a major new international tax aimed at preventing global companies from shifting profits abroad. Multinationals often transfer payments, such as interest or royalties, to their affiliates in low-tax jurisdictions to maximize deductions and minimize tax… – Continue reading

Australian corporate tax takes up 20 percent: data

CANBERRA, Dec. 13 (Xinhua) — The amount of tax paid by Australia’s biggest companies has risen 20 percent in a single year, data has revealed. According to the Australian Taxation Office (ATO) ‘s corporate tax data for financial year 2016-17, which was released on Thursday, the nation’s 1,470 biggest companies… – Continue reading

EU finance ministers need to deliver: Digital companies must pay tax

When European finance ministers meet on Tuesday (4 December), they should swiftly adopt the digital service tax: a levy on turnover for very large digital firms such as Google, Apple, Facebook, Amazon, Booking and Spotify, write Udo Bullmann and Paul Tang. Udo Bullmann is president of the Socialist and Democrats… – Continue reading

A tax ruling just opened the Pandora’s box for India’s back offices

MUMBAI: Are India-based back offices of multinationals merely brokers? And, are Indian companies providing services to foreign firms just commission agents? Going by the tax department’s definition, it appears that they are so — and not exporters. Several back offices at multinationals now face 18% Goods and Services Tax (GST)… – Continue reading

US multinationals dodge $180 billion in taxes on foreign profits per year

US multinational corporations are plundering the populations of the United States and the world to the tune of trillions of dollars by driving down and evading taxes on profits booked overseas. This is the conclusion that emerges from a recent study by University of California at Berkeley economist Gabriel Zucman… – Continue reading

Britain to start taxing big internet companies

LONDON — Britain’s Treasury chief unveiled Monday a new tax on big internet companies’ revenues, insisting it is time that the global tech giants with profitable business in the United Kingdom pay their fair share for public services. Philip Hammond made the announcement as he outlined his budget, explaining that… – Continue reading

Germany urges global minimum tax for digital giants

FRANKFURT AM MAIN: German Finance Minister Olaf Scholz in an interview said he backed a global minimum fiscal regime for multinationals as Europe looks to levy tax notably on US tech giants. “We need a minumum tax rate valid globally which no state can get out of (applying),” Scholz, a… – Continue reading

New Zealand Law Foundation Report suggests accepting cryptocurrency

A recent report published by the New Zealand Law Foundation on regulating cryptocurrencies in New Zealand suggests the regulators of the country to start taking tax in crypto and trial a CBDC. The report, that is commissioned by the New Zealand Law Foundation and written by the University of Auckland… – Continue reading

McDonald’s Luxembourg tax deal not illegal

BRUSSELS (Reuters) – McDonald’s tax deal with Luxembourg did not breach EU state aid rules, EU antitrust regulators ruled on Wednesday, saying the reason the US fast food chain did not pay some taxes was due to the mismatch between US and Luxembourg laws. The decision by the European Commission… – Continue reading

EU Should Challenge Google, Apple, Facebook, Amazon Payment Systems, ECB Says

A European Union board member gave a speech criticizing the weak presence of European fintech businesses in the continent’s own market. The leader’s comments come in response to several major clashes with American multinationals over their unscrupulous practices. Yves Mersch, European Central Bank (ECB) member of the Executive Board, addressed… – Continue reading

The best-known transfer pricing cases in Vietnam

VietNamNet Bridge – Nearly 38 percent of foreign invested enterprises (FIEs) reported losses in 2017, a significant decrease from the 50 percent seen in previous years. However, transfer pricing by FIEs remains a headache for management agencies. Do Thien Anh Tuan of Fulbright University said that enterprises that most regularly… – Continue reading

Facebook, Coke could face tax hit after ruling against Medtronic

Last week, Medtronic Plc suffered a legal setback in its bid to avoid a $1.4 billion U.S. tax bill — a ruling that may have costly implications for other multinationals battling the Internal Revenue Service over the use of overseas payments to lower their taxes. Companies including Facebook Inc. and… – Continue reading

Booksellers urge government to ‘act quickly’ on ‘Amazon tax’

News that the government may bring in an ‘Amazon tax’ to help “rebalance the playing field” between physical and online retailers has been welcomed by booksellers. After department store retailer House of Fraser became the latest high street chain to go into administration on Friday (10th August) Philip Hammond said… – Continue reading

Ensure foreign taxpayers have NBR certificates before allowing DTAA benefits

Bangladesh Bank on Monday asked all banks to ensure that foreigners have clearance certificates from the National Board of Revenue before allowing them tax benefits under double taxation avoidance agreement. Foreign Currency Policy Department of the central bank in a letter to the head offices of approved dealer banks suggested… – Continue reading

European Leaders Press for New Digital Tax at G20 Meeting

European finance officials just wrapped up a G20 summit in Argentina where they pressed for new global rules to better collect tax on digital giants like Google (NASDAQ:GOOGL 1258.15 0.04%), Facebook (NASDAQ:FB 214.67 0.02%), and Amazon (NASDAQ:AMZN 1829.24 0.02%), among others. The European Commision is the executive (read: tasked with… – Continue reading

Tax, investment changes concern foreign firms

Hanoi (VNS/VNA) – The changes in tax policy and investment incentives are the issues of greatest concern for foreign investors in Vietnam, said Bui Ngoc Tuan, Deputy General Director of the Audit and Advisory firm Deloitte Vietnam at a workshop on in Hanoi on July 10. Themed “Investment incentives, related… – Continue reading

Australian Government planning on digitally taxing Google and Facebook

The Australian federal government has proposed a tax on digital advertising that could raise up to $200 million each year but could have serious consequences for corporate Australia. Scott Morrison, Australia treasurer, mentioned in his budget speech that the $7 billion in sales from Australians to United States owned media… – Continue reading

Deloitte: Romania faces growing fiscal competition as 8 EU member states cut corporate tax rates since 2017

Romania will be able to count less on the low taxation advantage in order to attract investments due to growing competition, after eight EU member states have reduced their corporate tax rates since 2017, according to a study released by Deloitte Romania. “Even in the new context, the Romanian corporate… – Continue reading

Apple Will Start Paying Back Taxes to Irish Government Next Month Amid Legal Battle With European Regulators

Apple will start paying 13 billion euros in back taxes to the Irish government from May, according to the Financial Times, nearly two years after the European Commission ruled that the company received illegal aid from the country that saw its tax bill significantly reduced over the past few decades…. – Continue reading

Opportunity Zone Program turns blight sites into tax havens for asset-rich investors

The rich are getting richer in America but that prosperity is not trickling down the economic food chain, with investment capital pooling up in thriving portions of big cities. One reason for this, experts believe, is the amount of wealth tied up in assets—real estate holdings and stock portfolios, primarily—that… – Continue reading

Activists stage ‘die-ins’ at French Apple stores to protest impact of tax avoidance on social services

The Association for the Taxation of Financial Transactions and Citizen’s Action —or Attac for short —staged “die-in” protests at two French Apple stores on Saturday, once again charging the company with exploiting loopholes to avoid paying its fair share of taxes. Around 70 members participated in an action at the… – Continue reading

TAX TALK: BEPS & ATAD RESHAPING INT’L TAX LANDSCAPE

Speakers corner: Delano asked Raymond Krawczykowski, partner and tax leader at Deloitte Luxembourg, “In your view, what have been the key changes in EU & Luxembourg tax rules in 2017, and what major shifts could be in store for 2018-19?” His response was clear: Beps and Atad. The Base Erosion… – Continue reading