Category: Corporates

A global revolution in corporate tax is taking place but it will not be televised

A quiet revolution is taking place across Europe. It isn’t playing out on the streets of capital cities or in the debating chambers of national parliaments. It has been slowly happening with every newspaper headline about how little corporation tax some companies pay relative to their size. It is also… – Continue reading

A New Set of Amendments to the Russian CFC and Beneficial Ownership Rules

On February 15, 2016, the President of the Russian Federation signed Federal Law No. 32-FZ “On Amendments to the First and Second Parts of the Russian Tax Code (with Respect to the Taxation of Controlled Foreign Companies and the Income of Foreign Organizations)”, introducing a new set of amendments to… – Continue reading

The biggest loophole of all

Having launched and led the battle against offshore tax evasion, America is now part of the problem DEVIN NUNES raised eyebrows in 2013 when, as chairman of a congressional working group on tax, he urged reforms that would make America “the largest tax haven in human history”. Though he was… – Continue reading

Buyback Transaction Taxable As Capital Gains

Mumbai Tribunal rules buyback transaction taxable as capital gains, exempt under India-Mauritius Tax Treaty; even if considered as dividend, tax withholding does not apply This EY Tax Alert summarizes a recent ruling of the Mumbai Income Tax Appellate Tribunal (Tribunal) in the case of Goldman Sachs (India) Securities Pvt. Ltd…. – Continue reading

India’s Axis Bank seeks Gulf expansion with branch in Sharjah

Axis Bank, India’s third-largest private bank by assets, is aiming to open branches in Sharjah and Bahrain by March next year as part of plans of increasing its presence in the Arabian Gulf region, a senior executive said. Axis Bank has nine overseas offices: branches at Singapore, Hong Kong, Dubai-DIFC,… – Continue reading

The OECD Action Plan – What’s Next?

The 15 part action plan aims to tackle global inequalities in taxation income, increasing transparency for tax administrators and significantly improving Multinational Enterprises’s compliance. With tax regulations of large corporations at the forefront of all policy makers’ minds, this latest endeavour from the OECD and G20 will address the varying… – Continue reading

EU tax changes vs Singapore’s sovereignty

Last month the European Commission launched its Anti Tax Avoidance Package, propelled by unprecedented political support for the fight against perceived tax avoidance by multinationals. In it the European Union stresses its full support for recent recommendations of the Organisation for Economic Cooperation and Development’s (OECD) BEPS project and it… – Continue reading

Getting to the crux of Ncell buyout deal

CAN NEPAL IMPOSE CAPITAL GAINS TAX ON NCELL BUYOUT DEAL? This question has been making rounds ever since TeliaSonera, the largest shareholder in Nepali telecom operator, Ncell, announced its decision to sell 60.4 per cent of its stake in the telecom company to Malaysian giant, Axiata, for $1.03 billion. Divergent… – Continue reading

States Targeting Snowbirds Fleeing to Tax-Friendlier Climates

Wealthy taxpayers who split time between states should be prepared to prove where their true home lies. You’re lounging by the pool of your second home in Florida, chuckling as you think of your friends back home braving the blizzard in Massachusetts. And you’re musing: Perhaps it’s time to escape… – Continue reading

Apple’s latest tax avoidance ruse: Tech giant issues $12bn in bonds so that it doesn’t have to move money out of low-tax offshore havens to pay dividends

Apple has sold $12billion in bonds as part of another scheme to lower its tax bill. The tech giant got itself further into debt even though it has $215billion in the bank, more than the US Treasury. California-based Apple sold the bonds under a complicated scheme which is reportedly designed… – Continue reading

Consensus on conscience: Are we moving towards a fairer int’l tax system?

In the aftermath of the latest global financial crises, government have sought to recoup lost revenue through tax reform. This has put the spotlight on the issue of gaps in the current international taxation system that created opportunities for Base Erosion and Profit Shifting (BEPS) schemes. Simply put, BEPS are… – Continue reading

HMRC accused of hypocrisy over tax avoidance stance

Pinsent Masons has accused HM Revenue & Customs (HMRC) of hypocrisy over its recent approach to tax planning and avoidance. Fiona Fernie, a partner at the law firm, said many of the government department’s investigations of late had been politically motivated, “concentrating on the best soundbites for ministers”. Tax avoidance… – Continue reading

Poor Tax Policy Sends U.S. Businesses in Search of Friendlier Tax Climates

Pfizer, one of the largest multinational pharmaceutical companies in the world, recently announced plans to merge with Allegran, Plc, a pharmaceutical company based in Ireland. The new merged corporation, worth a total of $160 billion, will move its headquarters to Dublin, Ireland to avoid the U.S. government’s “double taxation” of… – Continue reading

The real value of taking your business offshore

Over the last two decades, an increasing number of companies have set up subsidiaries in offshore financial centres. So why don’t they move the entire business, and establish headquarters there too? While it seems prestigious—and tax-savvy—to be based in the Cayman Islands or Luxembourg, companies that choose to do so… – Continue reading

EU finance ministers wary of anti-tax avoidance proposal

EU finance ministers will attempt to reach agreement by March on a directive requiring EU-wide country-by-country reporting for large multinationals and by July on a directive requiring EU states to adopt six anti-tax avoidance measures for corporations, Jeroen Dijsselbloem Dutch finance minister and president of the Eurogroup announced at an… – Continue reading

Automatic exchange of financial account information

The Government recently introduced into the Legislative Council a bill to provide a legal framework for the implementation of automatic exchange of financial account information in tax matters (“AEOI”). This would have significant implications both for financial institutions and, in a cosmopolitan city like Hong Kong, for many of their… – Continue reading

ADCB launches new private banking proposition

Abu Dhabi Commercial Bank (ADCB), today announced the launch of “ADCB Private” , a new private banking proposition providing globally sophisticated banking and wealth management solutions for high-net-worth customers, delivered from the UAE. Wealthy clients in the region and the UAE have historically had to seek international banking and investment services… – Continue reading

Comment: Privacy v transparency – Withers’ Noseda on incoming OECD tax rules opening a new battle front

In almost every field of legal work, privacy is regarded as a primary and legitimate concern to protect the interests of individuals and organisations. This was confirmed recently when the European Court of Justice (ECJ) struck down the US-EU data exchange agreement amid fears that data transferred to the US… – Continue reading

TTIP could block Governments from cracking down on tax avoidance, study warns

Similar trade agreements have been used to facilitate apparent tax avoidance in the past A controversial new trade deal between the EU and the United States could make it more difficult to fight tax avoidance, a new report has warned. TTIP, the Transatlantic Trade and Investment Partnership, is expected to… – Continue reading

Big corporations will always cheat (yep, I said cheat) on their taxes. Here’s how to deal with it

Let me give you a heads up: First, I’m going to tell you some things that will make you ill. Then I’m going to present a cure. It will make you feel better—until, of course, you realize that knowing the cure brings us as close to implementing it as buying an… – Continue reading

Varner: Taxes and international trade

A while back in Germany, I was driving on the straight as an arrow B-1. That is Bundesstrasse, the equivalent of a U.S. highway, a notch below the Autobahn. Roads tend to curve around farmers’ fields, having been there first. The B-1 from Cologne on the Rhine toward Berlin was… – Continue reading

Tax competition – that would be something to thank the Scots for

A 30% tax bracket. A rise in the standard rate, with a rebate for lower earners. Higher taxes all round to finance more spending. In Scotland, ahead of May’s elections for the devolved parliament, a fascinating debate on tax and spending is under way, with the main parties setting out… – Continue reading

Call to tighten UK’s new property law to crack down on ‘dirty money’

Rules should require foreign owners of prime London homes to come clean about beneficiary owners, say anti-corruption groups Large parts of London’s Baker Street, including the Beatles store, are owned by offshore trusts. New laws that aim to stop the UK being a magnet for money launderers – by forcing… – Continue reading

Ikea avoiding tax liability, report claims

EU countries may have lost out on more than €1 billion in tax revenues between 2009 and 2014 due to aggressive tax strategies by furniture giantIkea, a new report has claimed. The report, commissioned by the Green/EFA group in the European Parliament into the tax affairs of the private company,… – Continue reading

Why Is Monaco A Haven For Tax Defaulters?

If Swiss banking secrecy laws gave Switzerland the world banking capital status, Monaco’s residence policy gives its realtors a thriving business. What is common between the Canadian Raonic who lost in the Australian Open semifinals and the Serbian Djokovic who won it? Well, they are both residents of Monaco, and… – Continue reading

Google tells Parliament it won’t pay ‘Google Tax’ in U.K.

Google’s top global tax executive told U.K. lawmakers that a new U.K. tax provision dubbed “the Google Tax” will not actually apply to the U.S. technology giant. The law, officially the Diverted Profits Tax, was introduced last year amid concerns that Google parent Alphabet Inc. and other global tech companies… – Continue reading

Banksters making the U.S. a tax shelter?

Just when you thought the banksters had done all they could to rig the game against people that bail them out, you hear another tale of industrial-strength greed. This time, the scam is so ironic it’s almost absurd. For almost a decade the U.S. government has been going around the… – Continue reading

UK Chamber Backs Action On MNE Tax Avoidance

Amid ongoing debate in the UK on “corporate tax deals,” the British Chamber of Commerce has said the UK needs to comprehensively simplify business tax rules and eliminate loopholes that are exploited in aggressive tax avoidance schemes. On February 11, on the same day the Public Accounts Committee took evidence… – Continue reading

Beps averts collapse of global tax rules, conference told

OECD’s head of tax policy says protectionist measures by national governments had to be avoided The risk of protectionist tax measures being taken by national governments has abated as a result of the OECD’s Base Erosion and Profit Shifting (Beps) project, a key official has told a conference in Dublin…. – Continue reading

European Union ‘investigating up to 300 Google-style tax deals’

As many as 300 “Google-style” tax deals are under investigation across the European Union , it has been claimed. All 28 EU states are said to be involved in scrutinising a number of agreements struck by countries and multi-national corporations as part of a wider inquiry into unfair tax competition… – Continue reading

Extent of tax fraud unknown – SARS

The South African Revenue Service (SARS) still does not know the full extent of tax evasion, despite its work probing foreign bank accounts held by South African residents. It has been a year since SARS confirmed some account holders had been using their offshore accounts to evade their tax obligations,… – Continue reading

‘Unavoidable’ Netflix Tax enters Parliament

Australian Treasurer Scott Morrison says overseas companies selling digital products to Australians will not be able to avoid paying the GST. The so-called Netflix Tax that would see overseas-based businesses selling digital products to Australians collect 10 percent GST has entered the House of Representatives. Introduced by Treasurer Scott Morrison,… – Continue reading

Canada: Insight – In Search Of Better Tax Outcomes

Taxing decisions With highly efficient labour markets, a solid institutional environment and a strong banking system, Canada has long been considered one of the most competitive nations in the world. In fact, in its most recent rankings in 2014, Bloomberg declared Canada the second best country in the world for… – Continue reading

Canada: Voluntary Disclosure CRA Latest Statistics – Toronto Tax Lawyer Commentary

Voluntary Disclosure & CRA Annual Report to Parliament – General Information CRA has provided the latest statistics about the tax amnesty or voluntary disclosure program (VDP) for the previous fiscal year. CRA provides an annual report to parliament that provides a wealth of information about its activities over the past… – Continue reading

Scrap high-denomination banknotes, urges ex-bank boss

Former Standard Chartered chief says eliminating €500, $100, SFr1,000 and £50 notes would prevent corrupt payments Governments should consider scrapping high denomination banknotes to combat financial crime and tax evasion, including paying tradespeople in cash, a former bank boss has said. Criminals move more than $2tn (£1.4tn) around the world… – Continue reading

Election is the calm in the storm of maintaining a competitive corporate tax regime

When Tim Cook and his two senior Apple colleagues were questioned by a US Senate sub-committee back in May 2013, the headlines generated in the world’s business press were unsettling. Some lawmakers repeatedly characterised Ireland as a tax haven, saying behemoth Apple channelled billions of dollars of global revenues generated… – Continue reading

Special investigation: Why it’s not just planes that vanish in Bermuda

Journalist Steve Topple investigates Bermuda-based big business tax avoidance and its links with UK political parties – and even some charities LAST WEEK saw the news emerge that everyone’s favourite search engine, Google, only had to pay £97m in back-tax (not the “major success” of £130m as was first reported)… – Continue reading

EU Tax Proposal Expected To Target Multinational Corporations

Large multinational corporations such as Amazon.com, Apple, Google and Starbucks with operations in Europe have long been able to keep the tax rate they pay in one country secret, not only from neighboring nations but also from their competitors. Critics say this lack of transparency has allowed companies to unfairly… – Continue reading

Rajan Blames MNCs For Tax Controversies

‘Multinational corporations complain all the time of excessive demand about excessive taxation, but it is also true that MNCs across the world tend to find tax avoidance and sometimes tax evasion as an appropriate technique’ Blaming multinational corporations squarely for tax controversies, Reserve Bank Governor Raghuram Rajan has said their… – Continue reading

The Tax Avoidance Battle: Nations vs. Multinationals

At least this is the goal – member states safeguarding their social models by preventing trans-border operating multinational companies from avoiding “their fair share” of the tax burden. According to the European Commission, small and medium-sized enterprises in the EU pay 30% higher tax burden than large multinational companies. With… – Continue reading

Beazley moves its tax base back to Britain from Ireland

Insurance firm has been domiciled in Ireland since 2009 The insurance group Beazley has said it will move its headquarters back to London more than six years after shifting to Dublin for tax reasons. The FTSE 250 firm will ask shareholders to vote on the move back to the UK… – Continue reading

Kenya: Treasury Defends Controversial Mauritius Tax Agreement

Treasury is still fighting to keep a tax agreement out of parliament after a lobby group sued them over a pact it signed with Mauritius back in 2012. The double taxation avoidance agreement allows firms registered in the two countries to pay taxes in only one country. It also allows… – Continue reading

Cayman’s offshore banking sector shrinking

A major sector of the banking industry in the Caymans could be wiped out by tough regulations designed to fight money-laundering. The number of Class B banks registered with the islands’ regulator has fallen by 14 to 184 over the last year alone. Class B banks generally offer depository services… – Continue reading

Unions Blast Loopholes in New EU Tax Avoidance Proposals

A collective of unions has slammed the latest proposals by the European Commission to stamp out elaborate tax plans used by multinational companies to move vast profits around the EU in an effort to reduce their corporate tax bills in member states. The European Commission last week published a series… – Continue reading

McDonald’s halves its tax bill, back pays $78m

McDonald’s Australia was able to more than halve its tax bill last year after routing payments via the low-tax nation of Singapore. Each year McDonald’s reduces its profit, and thus its local tax bill, by paying McDonald’s Asia Pacific based in Singapore, and registered in Delaware, a “service fee” amounting… – Continue reading

10 biggest multinational offenders evading taxes in the UK

The brands are known worldwide, and even though global companies like Google, Amazon, and Starbucks make billions — they pay little or no taxes at all in the UK and other markets where the firms make a majority of revenue and profits. Companies like Microsoft, Twitter, and Apple don’t set… – Continue reading