Category: A-E

EY: Broadening the taxable basis across the GCC and MENA

To increase the scope of income tax laws, GCC countries are pursuing tax determinations with significantly broader interpretations of activities or actions that constitute doing business in-country. New concepts like Virtual Service Permanent Establishment and dependent agents are being used in Saudi Arabia and Kuwait to determine taxable presence or… – 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

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

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

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

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

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

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

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

deVere Group CEO Slams FATCA, “Fiscal Imperialism”

The chief executive of one of the world’s largest independent financial advisory organizations unambiguously condemned the Foreign Account Tax Compliance Act in a recent series of comments. deVere Group CEO Nigel Green likened the act, which went into effect in July 2014, to a “masterclass in fiscal imperialism and the… – Continue reading

How to Curtail Offshore Tax Avoidance

In a time of fiscal austerity, it is breathtaking to learn that Congress has allowed Fortune 500 companies to avoid an estimated $620 billion in federal taxes on earnings they are holding offshore. While the inaction by lawmakers on this issue may create the impression that there is nothing to… – Continue reading

Taka continues to fall against dollar

The taka has continued to fall against the dollar for two weeks now after nearly one year of an unchanged exchange rate, according to data from the Bangladesh Foreign Exchange Dealers’ Association. “Market forces are determining the exchange rate,” said Kazi Sayedur Rahman, general manager of Bangladesh Bank’s foreign exchange… – Continue reading

Former Manchester United and Arsenal stars ‘face ruin’ after failed investments reaching £100m

The company at the centre of the revelations denied any wrongdoing Some of the best-known names in British football face losing millions of pounds after being allegedly advised to invest in “risky” projects that have subsequently failed or were hit with tax bills. Rio Ferdinand and Andy Cole, both former… – Continue reading

Deloitte Poll: US Business Executives Cite Concerns and Priorities for OECD’s Final BEPS Package

NEW YORK, Nov. 9, 2015 /PRNewswire/ — Business executives cited an increased compliance burden as their biggest concern with the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting initiative (37.7 percent), according to an October Deloitte poll. Other concerns included double taxation of income (17 percent) and… – Continue reading

Europe May Not Be a Tax Haven for U.S. Multinationals Much Longer

FRANKFURT (The Street) — Europe’s allure as a tax haven for U.S. multinationals may be coming to an end. That’s because European Union regulators are closing up tax loopholes that U.S. companies have been enjoying for years. The first two to feel the heat are Starbucks (SBUX – Get Report)… – Continue reading

Tax system slow to adapt to digital economy’s rise

LOST REVENUE:A lack of regulations on taxing cross-border Web-based content and services providers puts their local peers at a disadvantage, Ernst & Young said The nation’s tax system is relatively behind developed markets in adapting to the proliferation of the digital economy, which has resulted in lost revenues for the… – Continue reading

Canada: ACB Adjustments For Foreign Affiliate Shares Held Through Partnerships

Recent CRA comments at the May 2014 IFA international tax seminar1 and a subsequently released CRA technical interpretation2 highlight anomalies in the application of subsections 92(4) and (5) of the Income Tax Act (Canada) (the “Act“).3 These provisions address the situation where shares of a foreign affiliate are held by… – Continue reading

US fuss about Irish tax deals just election fever, says ex-Apple CEO

The recent corporation tax controversy highlighted by US presidential hopefuls Hillary Clinton and Donald Trump is not damaging Ireland’s reputation as a place to do business, said the former chief executive of Apple, John Sculley. According to Mr Sculley, the controversy is simply part of US election fever. Known as… – Continue reading

“Cronies and cheating the taxpayer”: MP targets RBS bank tax avoiders in share sell off

Call to halt bank sale in favour of reform rejected by UK Government UK MINISTERS decided to “wash their hands” of a tax evasion scandal in a subsidiary of the government-owned Royal Bank of Scotland, according to damning testimony given by a former treasury official who is now a Labour… – Continue reading

OECD BEPS Heralds Big Changes for Tax Pros and Corporate Treasurers

The Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting action plan is likely to have a major impact on tax planning at multinational corporations by both tax professionals and corporate treasurers. Tom Driscoll, U.S. managing partner for international tax, transfer pricing, and indirect tax at Deloitte Tax… – Continue reading

Seychelles rated ‘largely compliant’ by OECD – continued vigilance and reforms needed to uphold status, says finance minister

(Seychelles News Agency) – Seychelles’ efforts to comply with the widely-recognised Organisation for Economic Co-operation and Development (OECD)’s regulations on the sharing of tax information has led the island nation’s jurisdiction to be rated ‘largely compliant’. This follows a re-assessment of the island nation’s ‘practical implementation’ of its legal and… – Continue reading

LuxLeaks: Little change in tax avoidance loopholes one year on from revelations

British MEP Anneliese Dodds has accused national governments of hampering progress in tackling corporate tax dodging, warning that EU capitals are “far too focussed on their own self-interests”. On the anniversary of the breaking of the LuxLeaks scandal, Dodds said MEPs had made some progress in stamping out aggressive tax… – Continue reading

‘SA is bleeding billions’

JOHANNESBURG – South African has lost R250 billion in the form of service payments over a three-year period, highlighting the significant risk base erosion and profit shifting (BEPS) is posing to the country’s tax base, a South African Revenue Service (Sars) official has said. Almost R80 billion of this were… – Continue reading

Apple’s US returns indicate substantial rise in Irish tax paid

Technology company made the largest profit in its history in year to end of September Apple’s latest annual report indicates a substantial increase in the amount of tax it may be paying in Ireland. The latest annual report from Apple, filed last week in the United States, indicates a substantial… – Continue reading

Secret tax archives: UK joins move to block MEPs’ access

Treasury says making available documents detailing tax policies tailored for multinational firms would jeopardise ‘open and frank discussions’ The UK has joined Luxembourg, the Netherlands and Belgium in blocking attempts by a committee of MEPs to gain access to secret European archives that detail some of most controversial tax policies… – Continue reading

Why Billions of Dollars in Estate Taxes Go Uncollected

They say the only certain things in life are death and taxes, but a large number of non-U.S. citizens may have found a way to avoid at least one of those. Under U.S. tax law, the estates of foreign holders of U.S. assets, such as stocks, real estate and valuables,… – Continue reading

Irish-based Shire buys rival for €5.3bn

Pharmaceutical giant Shire, which is headquartered in Ireland for tax purposes, has agreed to buy US rare disease specialist Dyax Corp for about $5.9bn (€5.35bn), and potentially up to $6.5bn, while still pursuing a five- times larger unsolicited bid for biopharma firm Baxalta Inc. The Dyax deal, the latest in… – Continue reading

German state buys USB said to hold evidence of €600m in tax avoidance

Tax authorities in the German state of North Rhine-Westphalia have purchased a USB stick reported to hold evidence of tax avoidance and illegal deals worth more than €600m (£427m). Investigators are believed to have paid more than €5m for the data, the highest amount handed over for such information, according… – Continue reading

US Justice Department Announces Banque Bonhôte & Cie SA Reaches Resolution Under Swiss Bank Program

The Department of Justice announced today that Banque Bonhôte & Cie SA (Banque Bonhôte) has reached a resolution under the department’s Swiss Bank Program. The Swiss Bank Program, which was announced on Aug. 29, 2013, provides a path for Swiss banks to resolve potential criminal liabilities in the United States…. – Continue reading

Kenya: ‘Kenya Losing Billions to Tax Havens’

The government has been accused of opening a loophole that allows super rich individuals and multinational companies to avoid taxes. The Tax Justice Network (TJN), a lobby group, has sued the government over agreements, which it says are robbing Kenya of the ability to raise revenues domestically, driving the country… – Continue reading

Donald Trump: Don’t Blame Pfizer for Corporate Inversion Problem

The Republican front-runner says high corporate tax rates are the real villain. Donald Trump isn’t blaming Pfizer Inc. for the problem of corporate inversions. The Republican front-runner said Pfizer’s planned merger with Allergan Plc was understandable since it would allow the company to relocate its headquarters to Ireland, where taxes… – Continue reading

Activision buys King with foreign cash

Video game publisher Activision Blizzard (NASDAQ:ATVI) is satisfying its sweet tooth for acquisitions by buying mobile game maker King Digital Entertainment (NYSE:KING), best known for “Candy Crush Saga.” Activision announced late Monday that it has agreed to pay $18 in cash per share for London-based King, in a deal worth… – Continue reading

FATF Declaration on Removing Sudan from its List a Step towards Lifting Sanctions

Khartoum – Ministry of Justice Undersecretary and Chairman of the National Committee of Money Laundering Combating, Ahmed Abbas affirmed that the declaration of the Financial Action Task Force (FATF) according to which Sudan was removed for list of countries whose systems are in neglect of combating money-laundering and financing terrorism… – Continue reading

NORTH RHINE-WESTPHALIA BUYS DATA: NEW TAX DISC CONTAINS DEALS WORTH 70 BILLION EURO

The Düsseldorf Finance Ministry has bought a new CD after mirror information – it is shown that an entire group of banksand financial service providers have deliberately harmed the German Treasury. The land of North Rhine-Westphalia for the so far most expensive record has spent five million euros. A few… – Continue reading

Apple Shifts a Record $50 Billion Overseas, Admits It Has Paid Miniscule to No Tax on Offshore Cash

For the die-hard fans who lined up around the block to purchase Apple’s latest iPhone last month, it’s hardly news that the California-based company still lives up to its reputation for technological innovation. The world’s No. 1 smart phone manufacturer last week released its annual financial report revealing it also… – Continue reading

The European Commission qualified member states’ tax rulings as state aid

On 21 October 2015, the European Commission decided that a tax ruling between Starbucks and the Netherlands should be considered illegal state aid. As a consequence, the European Commission ordered the Dutch State to recover the aid granted to a Dutch Starbucks group company (Starbucks Manufacturing EMEA B.V.), which is… – Continue reading

Amazon Deemed Liable For Online Tax Fraud? Shuts Down Daily-Deals Services

Amazon is reportedly liable for online tax fraud if the company fails to investigate traders who are using their sites to avoid sales tax. According to experts, online marketplaces such as Amazon and eBay could be held liable for all unpaid VAT if action was taken against them. The report… – Continue reading

Reform of the U.S. tax code still needed for the nation’s economy

As the 2016 Presidential campaign heats up with debates and public appearances replete with the candidate’s opinions on the economy, ISIS, and education, among others, few candidates have mentioned the issue of corporate tax reform, especially as it relates to a level playing field between the U.S. and foreign markets,… – Continue reading

The IRS’s intensifying fight over income taxes

The Internal Revenue Service says some of America’s most successful companies have been shuttling money to avoid paying their share of federal income taxes. Microsoft is fighting IRS attempts to collect more than $2 billion from profit the software giant transferred between foreign affiliates. Amazon.com is fighting to keep $1.5… – Continue reading

Pfizer’s Allergan bid defies Obama’s tougher tax rules

Pfizer’s bid for $113bn Dublin-based drug maker Allergan is the biggest merger of the year, anywhere. It’s potentially good news for the Irish exchequer, which may gain a massive new taxpayer, and for businesses here like Arthur Cox, Allergan’s adviser on Irish corporate law. But a deal that may well… – Continue reading

Small EU team leads tax battle against ‘goliaths’

A small team of European Union officials is spearheading an investigation that could force some of the world’s biggest companies to pay billions of euros in avoided taxes, Reuters reports. In an office block in one of Brussels’ less fashionable districts, the 10 Competition Directorate staff from across the bloc… – Continue reading