Category: K-P

Ackman Says Tax Inversion Rules Could Lead to U.S. Drugmakers Selling to Overseas Buyers

(Bloomberg) — The backlash against acquisitions meant to skirt U.S. tax laws could spur more midsize U.S. drugmakers to sell to overseas buyers, Bill Ackman, the billionaire activist hedge fund manager, said Thursday. Takeover activity in 2014 was highlighted by U.S. companies — including Medtronic Inc. and Pfizer Inc. —… – Continue reading

India, US set to map out way to end transfer pricing cases in court

More than 100 tax disputes involving Indian associates of US companies such as IBM and Microsoft are set to be settled out of court by April this year with the income tax department and the US Internal Revenue Service identifying disputes in the contract research, IT and software sectors for… – Continue reading

U.K. rails against Shire’s tax tricks that suitors extol

Report skewers PwC for creation of Shire tax shelter it calls ‘tax avoidance on an industrial scale’ Shire’s Ireland address has made the specialty drugmaker a prime takeover target. AbbVie was attracted but dumped the $55 billion buyout when the U.S. Treasury Department threw cold water on the deal with… – Continue reading

Big companies need to tell the public how much tax they pay, says business lobby group CTA

The group that represents most of the ASX 200 on tax issues, the Corporate Tax Association, has emerged as a surprise advocate of increasing transparency about the amount of taxes big companies pay. The Corporate Tax Association’s submission to the inquiry into corporate tax avoidance said it had concerns about… – Continue reading

Location savings from low-cost bases are not taxable, says tax tribunal

MUMBAI: The Mumbai bench of the tax tribunal has clarified that additional tax liability cannot be claimed from competitive industries in the name of location savings arising out of the country’s low-cost manufacturing base. The ruling may benefit pharmaceutical, auto, IT and IT-enabled companies, among others, that are engaged in… – Continue reading

China Stepping Up Scrutiny of Tax Evaders

Beijing is going after base erosion and profit shifting, and multinationals could get caught in the crosshairs. China is continuing to step up its efforts to curb what it sees as cross-border tax evasion by foreign-owned companies, announcing it will review how companies move money and allocate costs among their… – Continue reading

Tax Office pushes for biggest corporations to audit themselves

The Australian Tax Office is pushing ahead with a controversial plan to allow the country’s biggest corporations to audit themselves through their own private auditors, despite mounting public anger over corporate tax avoidance. An ATO spokesman said 56 public companies with a turnover of between $100 million and $5 billion… – Continue reading

Obama Wants a New Tax on U.S. Companies’ Overseas Profits

(Bloomberg) — President Barack Obama will propose that U.S.-based companies pay a minimum 19 percent tax on their future foreign earnings, capturing profits that are now often beyond the government’s reach. Obama will also seek a 14 percent mandatory tax on about $2 trillion in stockpiled offshore profits, said two… – Continue reading

Firms prepare for new tax rules as China vows crackdown

Feb 1 (Reuters) – The Chinese government’s vow to increase tax scrutiny of foreign companies has sent firms rushing to tax advisors ahead of the implementation on Sunday of new rules designed to rein in cross-border tax avoidance. Tax professionals and business lobbies alike have welcomed the move as an… – Continue reading

KPMG Suggests Hong Kong Budget Tax Changes

Hong Kong’s Government should use greater-than-expected revenue receipts to implement measures to enhance the city’s international competitiveness in the 2015/16 Budget, according to a KPMG survey of senior Hong Kong-based business executives. It is foreseen that the Government will be in a position of increased fiscal strength at the end… – Continue reading

Government asks I-T department to apply Vodafone principle on similar Transfer Pricing cases

MUMBAI: In what will be widely perceived as a sentiment booster for investors, the government has asked the I-T department to apply the principle behind a tax ruling involving Vodafone Group to all similar transfer pricing cases, an official letter seen by Reuters showed. Reacting to the news, Dinesh Kanabar of KPMG India told ET Now,… – Continue reading

Microsoft NZ ownership transferred from US to Luxembourg

Microsoft denies a transfer of ownership of its New Zealand business from the United States to Luxembourg is related to the tiny European state’s favourable tax policies. Luxembourg, which has a population of less than 600,000, has been accused of facilitating large-scale tax avoidance by multinationals. Microsoft New Zealand was… – Continue reading

Puerto Rico Expands Tax Haven Deal For Americans To Its Own Emigrants

Puerto Rico’s Acts 20 & 22, tax incentive laws aimed at luring wealthy American investors to move there and at reviving the Island’s economy, are celebrating their third anniversary this month. While Puerto Rico’s economic situation remains bleak (it currently has more than $73 billion of “junk” status debt, unemployment… – Continue reading

Mylan, Heinz among U.S. companies using Luxembourg for tax reduction

When Cecil-based generic drug giant Mylan bought Bioniche is 2010, it didn’t simply hand over a check to the owners of the Irish pharmaceutical firm. Instead, Mylan channeled financing through Luxembourg, a small European country that is a magnet for U.S. companies seeking ways to cut their tax bills. The… – Continue reading

Second French suspect charged over ‘Luxleaks’ tax probe

LUXEMBOURG – A second French suspect was charged Friday with theft and money-laundering in ongoing investigations into the leaking of secret tax avoidance deals between Luxembourg and multinational companies, a scandal dubbed “Luxleaks.” The identity of the new suspect was not released, but he is a 38-year-old Frenchman and former… – Continue reading

Luxembourg: Tough times for a favorite tax haven

Luxembourg’s business-friendly tax laws have saved companies billions. The party’s almost over. On a typical day, thousands of passengers pull into Luxembourg’s central train station and traverse the busy shopping street of Rue de la Gare, where everything from pastries to rain boots is on offer. Few, however, step inside… – Continue reading

US tech giants launch fierce fightback against global tax avoidance crackdown

Lobby groups representing Google, Amazon and other powerful US tech multinationals have launched a fierce attack on global plans to stamp out artificial corporate structures used to avoid tax. In responses to the latest stage of a two-year, G20-led programme of international tax reform, lobbyists for the US tech industry… – Continue reading

A Guide to India’s Transfer Pricing Law, Part 2: Should BEPS be on India’s Radar?

In the first of this two part article, we outlined what businesses must do to comply with India’s transfer pricing laws, while stressing the key reforms introduced by the new government to bring certainty to the domestic tax system. Here, we discuss if and how India should respond to the… – Continue reading

Obama in India: India, US finalise framework to resolve transfer pricing cases

NEW DELHI: India and the US have finalised a framework to resolve transfer pricing cases, some of them pending for five years, in what could end tax trauma for more than 50 American MNCs such as Microsoft, IBM and Oracle by the fiscal year-end and send a strong signal to… – Continue reading

US tech giants launch fierce fightback against global tax avoidance crackdown

Lobbyists representing firms including Google, Amazon and Apple claim ‘fundamental flaws’ in G20-led reforms The World Economic Forum in Davos, where Google, Microsoft and Facebook executives will discuss the digital economy on Thursday. Photograph: Fabrice Coffrini/AFP/Getty Images Lobby groups representing Google, Amazon and other powerful US tech multinationals have launched… – Continue reading

New Brief: Representative John Delaney’s New Proposal Lets Corporations Off Easy

On Dec. 12, 2014, Rep. John Delaney (D-MD) proposed a new version of his “repatriation holiday” tax plan. The latest version would require multinational corporations to pay a token amount of taxes on their accumulated offshore profits and exempt those profits from any further U.S. income tax. Delaney’s new plan… – Continue reading

Dems ready new push on offshore tax deals

Congressional Democrats are preparing new efforts to curb the offshore tax deals that drew the ire of President Obama last year. Senate Minority Whip Dick Durbin (D-Ill.), Sen. Jack Reed (D-R.I.), Rep. Sandy Levin (D-Mich.) and Rep. Lloyd Doggett (D-Texas) will introduce legislation on Tuesday seeking to stop the maneuver… – Continue reading

Malta: Taxation Of Private Pensions

Introduction Malta is increasingly becoming a financial services centre of repute looked at by a number of financial services operators as the ideal platform to set up their private pension schemes. Malta’s success is attributable to the flexible and prudent manner in which the industry is regulated, providing the desired… – Continue reading

North York pharmaceutical company gets FedDev boost

North York pharmaceutical company Dalton Pharma Services is expanding its operations with help from Ottawa. The contract manufacturing and drug development research company is receiving more than $2 million from the Federal Economic Development Agency for Southern Ontario (FedDev Ontario). The company itself is putting in an additional $6.3 million… – Continue reading

Wild Parties, Secret Cash Drops, Offshore Accounts: Meet Brazil’s Black-Market Central Banker

He was known to authorities as Brazil’s black-market central banker, a career criminal who smuggled cash for the rich and powerful by private jet and armored car. Now Alberto Youssef — a rum-runner turned money-launderer turned reputed billionaire — has emerged as a principal player in the biggest corruption scandal… – Continue reading

LEGAL ALERT ON KAZAKHSTAN BANKS M&A

Under Kazakhstan law, generally, both resident and non-resident legal entities may own shares in a Kazakhstan bank. National Bank Pre-Transaction Consent.  Generally, there are two thresholds entailing the necessity to obtain the National Bank of Kazakhstan (the ‘NBK’) (financial regulator) pre-transaction consent:  (i) “large participant”, whereby an entity controls ≥10%… – Continue reading

How an Obscure Tax Loophole Brought Down Obama’s Treasury Nominee

(Bloomberg) -– So how did the previously obscure term tax inversions become part of Washington parlance, fodder for the next presidential campaign and the issue that helped derail a U.S. Treasury nominee? Thank, or blame, depending on your perspective, cutting-edge tax lawyers, populist Democrats, a banana seller, a drugmaker, a… – Continue reading

UPDATE 1-China developer Kaisa’s bonds jump but battle ahead for offshore creditors

* Bonds up around seven points * Kaisa missed bond coupon payment last week * Case could be test of China’s bankruptcy law (Adds comments, updates price) By Umesh Desai HONG KONG, Jan 13 (Reuters) – Bonds issued by Kaisa Group rose sharply on Tuesday after the embattled Chinese property… – Continue reading

Kaisa’s bonds rise but offshore creditors face waiting game ahead

Bonds issued by Kaisa Group rose sharply on Tuesday after the embattled Chinese property developer said it had received a waiver from HSBC Holdings on a loan it failed to repay in late December 2014. Kaisa, which is struggling with the sudden departure of senior executives, government officials blocking sales… – Continue reading

Kaisa Group Appears To Default On Offshore Bond Debt After Defaulting On HSBC Loan

A Chinese property developer, which was seemingly in good financial shape until recently, appeared to default on an offshore bond payment Thursday, raising concerns among international investors with an interest in the country’s property market, according to reports. Kaisa Group Holdings Ltd., which is listed on the Hong Kong stock… – Continue reading

Credit Suisse says Milan offices searched by Italian tax police

(Reuters) – Credit Suisse said its offices in Milan were searched by Italian tax police last month, following media reports of an investigation into whether a Bermuda subsidiary of the bank helped wealthy Italians hide undeclared funds. The searches follow a series of investigations against Swiss banks, including Credit Suisse,… – Continue reading

Jim Armitage: PwC whistleblower deserves a medal, not a jail sentence

Outlook PwC’s request the Luxembourg authorities prosecute the whistleblower who lifted the lid on the vast extent of tax avoidance there is ill-judged and unpalatable. Antoine Deltour did the world a service in leaking the details of thousands of PWC-arranged tax deals in the tiny country. The result is likely… – Continue reading

LuxLeaks Scandal Reveals International “Race to the Bottom”

Countries are competing to lower their tax rates to please the corporate giants, but the result is a massive collective loss of revenue. Only international coordination can wipe out the practice and defeat the negative influence of the Big Four accounting firms. Tax havens have long existed in the popular… – Continue reading

Shareholders Approve Medtronic-Covidien Deal

Medtronic Inc. took one step closer to becoming an Irish company when shareholders voted in favor of acquiring Dublin-based medical supply maker Covidien Ltd. Covidien shareholders similarly voted on the deal early today and also approved it. The acquisition now goes before the Irish High Court, which may take several… – Continue reading

Digital tax increase to take effect in Europe

Europe’s tax showdown could be headed straight to people’s wallets. With the new year, a change in fiscal rules in the European Union is increasing the tax on many purchases of digital content like e-books and smartphone applications. Under the new rules, first approved in 2008, the tax rate on… – Continue reading

Minnesota investment board withholds support of Medtronic-Covidien deal

Critics said the deal would allow Medtronic avoid taxes while providing preferential treatment to executives. The promise of 1,000 new Minnesota jobs was not enough to convince the state’s pension board to support a $48 billion corporate transaction that will move Medtronic’s legal headquarters overseas. A four-member subcommittee of the… – Continue reading

Internal Revenue Service Getting Tough on Production of Evidence From Current and Former Microsoft Executives In Connection With Its Transfer Pricing Audit

In recent court filings made in various federal district courts in Washington and California, the Internal Revenue Service is seeking to enforce testimonial summonses issued to current or former Microsoft employees, including former CEO Steven A. Ballmer. The summons had been issued earlier this fall. Microsoft’s outside tax counsel responded… – Continue reading

Canada transparency laws force ASX companies to disclose tax bills

Two Australian mining companies will be forced to disclose how much tax they pay in every country around the world by new transparency laws introduced in Canada. Paladin Energy and OceanaGold, both dual-listed in Australia and Canada, will have to comply with new Canadian laws requiring all oil, gas and… – Continue reading

KPMG responds to transfer pricing ruling

KPMG has responded to the ATO’s recent taxation ruling TR 2014/8 (documentation requirements) and practice statements PSLA 2014/2 (penalties) and PSLA 2014/3 (simplification). Anthony Seve, KPMG transfer pricing partner, said the ruling places increased compliance and documentation obligations on larger companies. This, he said, is reflective of global developments. “Although… – Continue reading

IRS demands Ballmer, other Microsoft leaders testify in corporate tax audit

The Internal Revenue Service has sued former Microsoft CEO Steve Ballmer and a slate of other former and current executives, seeking to compel them to testify in a long-running investigation into how the company’s sales through subsidiaries affected its taxable income. The Internal Revenue Service has sued former Microsoft Chief… – Continue reading