Category: A-E

Brazil’s BTG Open to More Swiss Private-Banking Acquisitions

(Bloomberg) — Grupo BTG Pactual, the only publicly traded investment bank in Brazil, said it’s willing to consider more acquisitions in Switzerland after completing the purchase of BSI, the Swiss private-banking unit of Assicurazioni Generali SpA. “We are looking. We are always looking,” Renato Cohn, a BTG partner and member… – Continue reading

Bank La Roche & Co AG Reaches Resolution Under US Justice Department’s Swiss Bank

The Department of Justice announced today that Bank La Roche & Co AG has reached a resolution under the department’s Swiss Bank Program. “Today’s agreement is yet another example of a foreign financial institution coming forward, acknowledging its criminal conduct, taking the necessary steps to resolve its criminal exposure, cooperating… – Continue reading

IRS Offshore Account Penalties Expand, More Banks Sign

The number of banks with deferred prosecution agreements with the U.S. government keeps growing. The subject is tax evasion involving American account holders. Today, under FATCA, banks everywhere want to know if you are compliant with the IRS. And the IRS keeps updating its list of foreign banks where offshore… – Continue reading

Europe moves towards a more transparent tax regime

Note: This article was published by Bloomberg BNA in Tax Planning International European Tax Service Vol. 17 No. 7 July 2015 Introduction The recent LuxLeaks scandal has once again focused political attention on tax planning practices of multinationals (“MNEs”). It comes in the wake of the European Commission investigation of… – Continue reading

Apple China Ordered To Pay $10 Million Fine For Tax Evasion

Apple’s CEO Tim Cook announced on Wednesday, Sept.9, that the famed brand’s revenue significantly increased in China by up to 75 percent in the past year. However, the country’s finance authorities cut the celebration short. China’s Ministry of Finance demanded Apple to pay 452 million yuan, a price equivalent to… – Continue reading

Tax trouble brews for Starbucks, Apple as Europe takes aim at taxes

Multinationals have come under fire yet again over their tax arrangements in some European countries, as the continent moves closer to a pan-European regime to combat tax avoidance. On Friday, European economy and finance ministers and central bankers (known as an ECOFIN meeting) gathered in Luxembourg to discuss what the… – Continue reading

Vietnam-US double taxation avoidance will bring more gains than losses

With the agreement with the US, Vietnam has now signed the double taxation avoidance agreements with 70 out of 170 countries and territories with which Vietnam has trade and investment relations. Double taxation is considered a barrier to trade and investment. It discourages transnational investments while prompts individuals and businesses… – Continue reading

Malta remains against tax harmonization

Speaking at an informal meeting of the Economic and Financial Affairs (ECOFIN) in Luxembourg, Finance Minister Edward Scicluna once again expressed Malta’s opposition to tax harmonization. “Taxation remains a sensitive area for Malta, not only because of its obvious role in the revenue collection process, but also as an important… – Continue reading

U.S. companies given Export-Import Bank subsidies keep profits offshore, skirt taxes

Budgeting battle But like much of the budgeting in Washington, D.C., it gets complicated. The Congressional Budget Office contends the Ex-Im Bank’s surpluses are the result of the accounting method the bank uses and would disappear — or require a taxpayer subsidy — if the bank used a more appropriate… – Continue reading

Private banking: Singapore, Indonesia in private banking tug-of-war

Indonesians hold $300 billion in Singapore; controversial tax amnesty on the cards. Indonesia’s finance minister Bambang Brodjonegoro told Euromoney earlier this year that tax collection falls way short of targets and must improve to provide funding for infrastructure and other projects It doesn’t take much for Indonesia’s government officials to… – Continue reading

How captive IT offshore centers are driving IT innovation

Companies like Amazon, Tesco and Honeywell are looking to offshore IT subsidiaries to deliver digital transformation. New launches of captive centers offshore continued to increase in the first half of 2015, according to research from outsourcing consultancy Everest Group. Companies in the manufacturing, telecommunications and technology industries, in particular, expanded… – Continue reading

RBS sells corporate loan commitments portfolio

LONDON–Royal Bank of Scotland Group PLC (RBS.LN) has sold a portfolio of corporate-loan commitments related to its banking business in China for 498 million pounds ($755.1 million), as part of the bank’s strategy to focus mainly on U.K. and European customers. RBS said it has reached an agreement with China… – Continue reading

MEPs approve draft report on corporate tax avoidance

This week, MEPs discussed a draft report on tax rulings, with a view to a vote in the next plenary session in Strasbourg. The report proposes a comprehensive overhaul of corporate tax practices as part of the EU’s battle to tackle tax avoidance. Parliament’s special committee on tax rulings (TAXE)… – Continue reading

Big UK companies halve provisions for disputed tax bills

The amount big companies set aside to cover disputed tax bills has more than halved over the past three years to £1.7bn this year, reports the Financial Times. Even though businesses fear more disputes as tax authorities become increasingly tough, they are showing reluctance to be drawn into conflicts that… – Continue reading

Israeli banks named in Australian tax evasion affair

Former Nudie Juice CEO Andrew Binetter allegedly sought the destruction of incriminating files at Bank Hapoalim. The names of Israeli banks Bank Hapoalim (TASE: POLI) and Israel Discount Bank (TASE: DSCT) have been mentioned in the Australian press as involved in alleged tax fraud in the millions of dollars by… – Continue reading

Govt to tax collectors: give foreign companies a break | Reuters

MUMBAI India’s tax officials, long the scourge of foreign investors, are under government pressure to avoid aggressive claims against overseas funds and companies, as the country seeks to repair an image dented by high-profile tax battles. The latest dust-up was over a largely overlooked minimum alternate tax (MAT), which had… – Continue reading

Tax scandal probe hit by setback as EU refuses to hand over documents to MEPs

The European Commission is refusing to hand over documents to MEPs investigating whether EU member states are using special tax regimes that favour large multinational corporations such as Facebook and Amazon. EU economics commissioner Pierre Moscovici wrote to the European Parliament’s special committee on tax rulings (TAXE) this week claiming… – Continue reading

IRS Offshore Account Penalties Increase, Hunt Continues

The number of Swiss banks that have entered deferred prosecution agreements with the U.S. government keeps growing. The subject is tax evasion involving American account holders. Today, banks everywhere want to know if you are compliant with the IRS. Under FATCA, the entire world is lending the IRS a hand…. – Continue reading

Glenmark down 3%; Credit Suisse says Venezuela may hurt PAT

Moneycontrol Bureau Credit Suisse has maintained its underperform rating on Glenmark Pharma as it feels potential currency devaluation in Venezuela could hurt profit meaningfully. The stock lost more than 3 percent intraday Wednesday. The brokerage expects a 20 percent degrowth in company’s FY17 earnings per share as it continued to… – Continue reading

Argentina Tells HSBC to Remove CEO in Tax Evasion Dispute

HSBC’s Argentine unit told to remove CEO and one director HSBC accused of helping capital flight by wealthy Argentines Argentina’s central bank revoked the licenses of two top executives at HSBC Holdings Plc’s local unit, including the chief executive officer, arguing they had failed to prevent clients from laundering funds… – Continue reading

Etsy facing renewed pressure over Irish tax strategy

Call to strip company of transparency standards certification A leading tax policy advocacy group has called for online retailer Etsy to be stripped of a certification awarded to companies that adhere to strict standards for transparency and social accountability unless it dismantles its offshore tax cutting structure. Last month, Bloomberg… – Continue reading

Indian Court Allows Mauritius Treaty Benefits For Appellant

Rejecting “treaty shopping” claims, India’s High Court of Punjab and Haryana has ruled that India should not tax capital gains from the sale by Mauritian entities of shares held in an Indian company if they are proven resident in Mauritius. The ruling was given in Serco BPO Private Limited v…. – Continue reading

Transfer pricing audits: flipping the tested party

Introduction Transfer pricing methods and tested parties Troubling trend Tools for taxpayers Introduction In some recent transfer pricing audits the Internal Revenue Service (IRS) has ‘flipped the tested party’ after examining transactions between related US and foreign companies. Typically, this practice results in the attribution of a larger portion of… – Continue reading

Leumi Asked to Consider Bonus Clawbacks After U.S. Tax Fine

The Bank of Israel asked Bank Leumi Le-Israel Ltd. to set up an independent committee to examine management performance and bonuses after the lender agreed in December to pay a fine to U.S. authorities in a tax probe. Leumi, Israel’s second-largest lender, agreed the $400 million fine after a seven-year… – Continue reading

Israel Banking Watchdog Says Leumi Execs May Have to Return Bonuses

Regulator demands Bank Leumi investigate top management in wake of U.S. tax-evasion settlement. Bank Leumi should take back bonuses it paid three former senior executives after the lender was forced to pay a huge penalty to the United States for tax violations that occurred under their watch, Banks Supervisor David… – Continue reading

Barclays Pressing Swiss Private Bankers to Double Client Assets

The new head of Barclays Plc’s Swiss unit is pushing private bankers in Geneva and Zurich to double client assets in four years as international competitors exit the world’s largest hub for offshore wealth. James Buchanan-Michaelson, who joined from Coutts International in June, aims to increase Swiss assets, including loans,… – Continue reading

Will Etsy’s Brazen Tax Avoidance Cost the Company Its “B Corporation” Status?

The online craft website Etsy is facing new scrutiny for its recent decision to shift some of its intellectual property into a secretive Irish subsidiary. As Bloomberg reported last week, the company’s Irish subsidiary has been made into an “unlimited liability corporation,” a form that exists primarily to avoid disclosure… – Continue reading

Canada Life’s offshore bond market share hits 29% on L&G deal

Canada Life’s acquisition of Legal & General International has resulted in a combined 29% share of the offshore bond market into the UK. Managing director of Canada Life International, Sean Christian, revealed the figure in an interview with international Adviser while discussing the details of the deal and the opportunities… – Continue reading

Proposal to make arbitration mandatory under MAP dropped

India opposed the proposal saying it impinges on the sovereign rights of developing countries in taxation New Delhi: An international proposal to make arbitration mandatory and binding under mutual agreement procedures (MAP) in tax treaties has been dropped after India strongly opposed it. Last year, the Organisation for Economic Co-operation… – Continue reading

Is FATCA chasing a leprechaun and his pot of gold?

FATCA was enacted into law by section 501(a) of the Hiring Incentives to Restore Employments (HIRE) Act 2010 as a revenue offset to help pay for the continuation of unemployment benefits for workers laid off during the 2008-2010 financial crisis. In July 2008, the U.S. Senate Permanent Subcommittee on Investigations… – Continue reading

Bank pays €22 mn for Luxembourg tax evasion activities

(CS) German financial institution HSH Nordbank reportedly reached a 22-million-euro settlement with prosecutors in Cologne over setting up offshore companies through Luxembourg to hide client assets from tax authorities. Newspaper “Süddeutsche Zeitung” and broadcasters NDR and WDR first reported on the deal on Tuesday. Allegedly, HSH Nordbank approached the prosecutor’s… – Continue reading

The critical importance of the Cayman Islands to the U.S. economy

In May of 2012, and soon before Facebook’s IPO, Eduardo Saverin renounced his U.S. citizenship. Saverin was a co-founder of the social-networking site, and the consensus was that he gave up his citizenship to avoid U.S. taxes that would be levied after the offering. Saverin was widely denounced for his… – Continue reading

Singapore bankers rattled by Asian moves to chase hidden wealth

Singapore-based wealth managers, already under pressure from a global move towards tax information sharing, face a more immediate threat as Asian countries including Indonesia and India look to chase undeclared money in the low-tax city state. A global crackdown on tax evasion launched during the 2008 financial crisis has already… – Continue reading

Aircraft overhaul expenses continue to be “fees for technical services” but not taxable absent source in India

In DIT vs. M/s. Lufthansa Cargo India: TS- 299-HC-2015, the Delhi High Court held that payment made by assessee (an Indian company) to German company for carrying out overhaul repairs to aircrafts was fees for technical services (“FTS”) under section 9(1)(vii) of the Income Tax Act, 1961 (“the IT Act”)… – Continue reading

Private equity braced for global tax changes

The private equity industry has long been known for its ability to take advantage of tax rules. But international changes are set to have an impact on their businesses. After a string of multinationals such as Apple, Google and Starbucks came under fire for paying minimal tax on their British… – Continue reading

What we know will be in the Senate inquiry’s interim report on multinational tax avoidance

The Senate inquiry into multinational tax avoidance will table an interim report today detailing some of its findings after holding five public hearings and receiving more than 100 submissions from some of the world’s largest companies including Apple, Microsoft, BHP, Rio Tinto and Google. The final report is due to… – Continue reading