Category: Q-Z

IRS urges Americans living in Canada to come clean after courts allow CRA to share account information with U.S.

The Internal Revenue Service is encouraging all non-compliant U.S. citizens, including those among the 1 million Americans who are resident in Canada, to take advantage of its voluntary disclosure programs initiated in 2009 and 2012. The move comes just a few weeks after Canadian courts refused to issue injunctions prohibiting… – Continue reading

Tax panel compels companies to testify

HSBC, Google, Facebook are among firms that will now appear after threat from MEPs on access to Parliament. Several multinational companies have now dropped their opposition to appearing before a special European Parliament panel investigating allegations of tax avoidance in Europe. HSBC said Tuesday it would participate in a hearing… – Continue reading

Chevron tax dodge busted for $322 million

Profit-shifting has not paid off for petroleum multinational Chevron, slugged with a tax bill for $322 million thanks to a Supreme Court decision on Friday. Chevron has been under close scrutiny this year, particularly since a senate inquiry into tax-avoidance in April which also put mining giants BHP, Rio Tinto,… – Continue reading

McNerney introduces anti-outsourcing bills

Citing the need to boost job growth locally and around the United States, Rep. Jerry McNerney, D-Stockton, has introduced legislation that would close tax loopholes that encourage companies to send jobs overseas and that would make companies reveal their outsourcing. The idea behind the legislative package is to provide greater… – Continue reading

EU Lawmakers Set to Vote on Tax Avoidance in Split Europe

Lawmakers at the European Parliament are set to vote on a controversial series of proposals to harmonize the corporate tax system in Europe in a move that will put them on a collision course with some member states which favor sovereignty over taxation. The EU lawmakers on the TAXE committee… – Continue reading

European Union: Tax Advantages For Fiat In Luxembourg And Starbucks In The Netherlands Deemed Unlawful Under EU State Aid Rules

The European Commission (“Commission”) ruled on 21 October that tax advantages granted by Luxembourg to Fiat and by the Netherlands to Starbucks by means of advance tax rulings were unlawful under the EU State aid rules. The two Member States will be required to recover the aid, in each case… – Continue reading

Is Europe Honest Enough To Deal With Tax-Dodgers?

The EU tax rulings against Starbucks and Fiat Chrysler are but trifles compared to the ones extant against Apple and Amazon. Everyone lies about tax. Holland said it followed international tax standards when everyone knows it’s a corporate tax haven. That’s why ST has its HQ there. Ireland and Luxembourg… – Continue reading

Procurement Services by Chinese Company Taxable as Fees for Technical Services under India-China Tax Treaty: AAR

• There can be no straight jacket formula to determine what is meant by “provision of service,” which may include where services are i) provided; ii) rendered; or iii) utilized. • The expression ‘provision of services’ is much wider than ‘provision of rendering of services,’ and covers the services even… – Continue reading

INVESTIGATION: How MTN ships billions abroad, paying less tax in Nigeria

MTN has consistently prided itself as the foremost telephone company that is getting Nigerians talking the most. Now the South African company is about to set tongues wagging across networks with revelations that it has routinely been shipping billions of naira overseas to avoid paying its fair share of tax… – Continue reading

Relaxed tax residency rules to help MNCs

Foreign companies with Indian shareholders won’t have to pay taxes here for their worldwide income unless they are managed from India on an everyday basis. If these foreign companies are managed from outside India, whether or not they are promoted by resident Indians, they will have to pay taxes in… – Continue reading

Europe wants to get to the core of our Apple issue

The European Commission looks highly likely to make a finding against Ireland in relation to its tax arrangements with Apple, following two similar findings during the week involving Starbucks and Fiat. It is perplexing that the EC doesn’t just come out and make the announcement. The delay is leading to… – Continue reading

Commentary: Multinationals put poor countries in fix

The African Union Advisory Board on Corruption (AUABC) recently requested major multinationals operating in Africa to be more open about the taxes and royalties they pay governments to improve transparency and accountability. Although a reasonable request, this is a tall order when you consider that often it is the governments… – Continue reading

Shops, care homes and cinema among buildings owned by firms based in offshore tax havens

DOZENS of Winchester properties worth more than £100 million are owned by firms based in offshore tax havens. High street shops, restaurants, care homes, a health clinic and even a single parking space are owned by companies benefitting from low tax regimes overseas. Burma Road student village, sold by the… – Continue reading

UK: Data, Privacy And Taxation – A Very Modern Conflict

Since the revelations on government surveillance and data capture by Edward Snowden, journalists have rightfully raised concerns about governments’ insatiable appetite for data collection and the resulting encroachment on citizens’ civil liberties. In the EU an individual’s right to privacy is regarded as a human right in accordance with Art…. – Continue reading

Challenges for family offices in emerging markets

Leading family offices in Latin America and the Caribbean are going through a transitional period, says Steven Cantor, managing partner of Cantor & Webb, a Miami-based law firm, reports the Financial Times. “As the world moves to tax transparency, with a crackdown on undisclosed tax savings in Swiss bank accounts,… – Continue reading

As Maruti and HUL show, royalty is a small price to pay

While stocks such as Hindustan Unilever (HUL) and Maruti Suzuki have outperformed the markets by a wide margin in the last couple of years, the stocks have sustained the performance even over longer periods. Despite the hue and cry over royalty payments by Indian subsidiaries of multinational companies, these companies… – Continue reading

How a company worth billions pays pennies on a million for tax

The company that is not a taxi company, which has drivers that are not taxi drivers, who carry people around that are not clients, Uber, is not only killing the taxi business, it is also avoiding paying taxes. The company uses a trick known as “the double-Dutch.” It is perfectly… – Continue reading

Satori launches Hong Kong offshore pension plan aimed at employees

Global fund distribution company, Satori Consultancy, has launched a Hong Kong registered offshore pension plan structured by Legacy Trust Company (LTC) as an occupational scheme. The International Pension Plan, which has five risk graded investment portfolios run by Marathon Capital & Apollo Multi Asset Management, is a Hong Kong-based exempt… – Continue reading

Corporate Pressure For US International Tax Reform

Major US investor Carl C. Icahn and the Chief Executive Officer of TechNet, Linda Moore, have both recently written letters to leading lawmakers pointing out that the passage of international tax reform by Congress has become a matter of extreme urgency. In his letter, Icahn announced that “the time has… – Continue reading

European Commission adopts first two decisions in EU tax probe in push for corporate tax reform

On 21 October, the European Commission (“EC”) adopted its first decisions in its investigation into Member States’ tax rulings. The investigation, which began in June 2013, has also targeted tax rulings given to Apple and Amazon as well as Belgium’s so-called “excess profits regime”. Although the investigation is conducted under… – Continue reading

Chevron ordered to pay millions in Auz taxes

Chevron lost an appeal in Australian federal court that will see the US supermajor pay more than US$232 million (A$322 million) in back taxes, in addition to fines, after losing a case with the Australian Tax Office (ATO). The Aussie federal court ruled against Chevron, stating the company wrongly shifted… – Continue reading

India: Foreign Tax Credits Available For Exempt Indian Income: Karnataka High Court

Foreign tax credit available to taxpayers even on a portion of exempt income. Exempt income (under section 10A) is chargeable to tax under section 4 and 5 of the ITA although no tax may actually be payable. Actual payment of the tax is not necessary for claiming foreign tax credits…. – Continue reading

Facebook, HSBC, Coca-Cola blacklisted by Socialist MEPs

Center-left MEPs turn up the heat on multinationals refusing to exchange views on tax policy. Google, Facebook, HSBC and AB Inbev are among a group of multinationals that have been “banned” from meeting MEPs from the European Parliament’s center-left grouping unless the companies agree to appear before a special committee… – Continue reading

Travelers CEO says U.S. tax policy sends insurers offshore

Congress needs to lower the corporate tax rate from its current 35% to discourage U.S. insurers from moving offshore, according to the head of Travelers Cos. Inc. “Reducing this rate would end a self-defeating policy that distorts corporate behavior, weakens domestic companies and ultimately harms the U.S. economy,” wrote Travelers… – Continue reading

After Blow to Europe Tax Havens, Some Promise More Staying Power

Luxembourg and the Netherlands lost a bit of luster as tax havens for some of the world’s biggest companies this week, as the European Union fired its latest salvo aimed at multinational tax dodging. Yet the Netherlands is on pace to maintain its attractiveness as a tax-friendly address for multinationals,… – Continue reading

Markets retain early gains amid a range bound trade

Indian equity markets retaining their early gains were trading in a range in early noon session, on value buying activities by market-participants. Sentiment got boost with the statement of finance ministry that the country will grow by 7.5 per cent in the current fiscal, slightly higher than international rating agency… – Continue reading

Apple Stakes Raised as EU Orders Starbucks, Fiat Tax Repayments

Apple Inc. and Amazon.com Inc. got a preview of what the European Union may have in store for them after regulators ordered Starbucks Corp. and a Fiat Chrysler Automobiles NV unit to repay millions of euros in back taxes. The EU said the coffee company and the Italian carmaker were… – Continue reading

OECD crack down on corporate tax shelters is a risky double edged sword

Companies who have been accused of shifting profits to low-tax jurisdictions or those seeking tax shelters need to beware—these practices are coming under fire, and could possibly come to an end. The Organization for Economic Cooperation and Development (OECD) just released details of their far-reaching plan that would require companies… – Continue reading

TP Disputes Trends Report 2015

Since 2002, there has been a steep escalation in transfer pricing disputes in the country, the ‘Taxsutra’s TP Trends Report’, is a perfect compendium which encompasses this escalation. The Chapter under which Transfer Pricing provisions were introduced was with the intent to ensure that there is no avoidance of tax…. – Continue reading

Fiat Chrysler reiterates did not receive state aid

“FCF did not receive any state aid and … any finding in this matter would be immaterial to the FCA Group’s reported results,” FCA said in a statement. MILAN: Fiat Chrysler Automobiles (FCA) denied again on Tuesday having received state aid from Luxembourg in a tax-related case, adding any findings… – Continue reading

Record View: Amazon morally obliged to pay up their share of tax

WHEN public spending is being slashed in a way that punishes the poor, every firm have a moral obligation to pay their fair share. AMAZON are taking an ever bigger share of the shopping market. Technological advances mean you can order something from their website late at night from your… – Continue reading

Chinese bond investors move offshore

Beijing’s monetary easing has sent onshore yields to multiyear lows, reports the Wall Street Journal. China’s booming domestic debt market is pushing investors to seek higher yields offshore, just as its banks start to expand yuan lending world-wide. The shift comes as China’s central bank is selling its first yuan… – Continue reading

London Wants to Become the Center of Chinese Currency Trading

Three years ago, Chinese officials said U.K. Prime Minister David Cameron had “seriously damaged” relations by meeting with the Dalai Lama, the exiled Tibetan leader. As planned talks between the two countries were canceled or failed to take place, worries emerged that Britain would miss out on building deeper economic… – Continue reading

United States: Tax Policy Update – October 13, 2015

NUMBER OF THE WEEK: 0 The number of House Republicans who want to be speaker and can actually secure the necessary 218 votes as of today. After Majority Leader Kevin McCarthy’s dramatic exit from the race last week, the House GOP conference is taking the week-long Columbus Day recess to… – Continue reading

Four things to watch in the Medium-Term Budget

What economists and tax practitioners expect to see. JOHANNESBURG – Finance minister Nhlanhla Nene (pictured) will once again be between a rock and a hard place when he presents his Medium-Term Budget Policy Statement (MTBPS) on Wednesday. With the economy under pressure and concerns about how government will balance its… – Continue reading

Sevan’s agent implicated in Petrobras bribery scandal

An agent who brokered offshore contracts between Sevan Marine and Petrobras in Brazil has come under scrutiny after receiving up to $40m of Sevan’s money into its offshore bank account, Norwegian reports say. The agent’s company is now part of the investigation into whether ex-Sevan Marine employees made bribes to… – Continue reading

Starbucks and Fiat Chrysler’s tax avoidance deals to be ruled illegal

Companies face multimillion-euro repayment bills after EC’s 15-month investigation. Rulings on Amazon and Apple will follow Starbucks and Fiat Chrysler are expected to be billed for tens of millions of euros in additional taxes as the European commission prepares to rule that they had unlawful deals with the Netherlands and… – Continue reading

Turnbull Government welcomes Labor’s support on laws targeted at MNCs tax evasion

The Turnbull government has welcomed the support of the Labor party for the new laws that will add more teeth to the government’s crackdown on multinational tax dodgers. The government also offered to consider the suggestions of the opposition in improving the scope of the legislation. Labor formally announced its… – Continue reading

Tony Wickenden: Net is closing in on offshore tax avoidance

Evading and avoiding tax through the use of offshore structures and arrangements is the source of much tax loss, according to HM Revenue & Customs. No surprise then that the current Government (and the coalition before it) has been relentless in its crackdown on it, with a special focus on… – Continue reading

Facebook accused of ‘insulting British taxpayers’ as London staff are lined up for a £250million shares jackpot

Facebook was last night accused of insulting British taxpayers as it emerged staff in London have been lined up for a £250million shares jackpot. The huge windfall will be paid out over the next three years if the US social media firm, which paid just £4,000 in corporation tax last… – Continue reading

China central bank hires banks for its debut dim sum bond in London-term sheet

[HONG KONG] China’s central bank has hired banks to arrange its debut offshore yuan bond issuance in London, according to a term sheet seen by Reuters on Monday. The so-called dim sum bond sale comes as Chinese President Xi Jinping prepares for a state visit to Britain this week. Sources… – Continue reading

IRS Offshore Account Penalties Go Up, More Banks Sign U.S. Disclosure Deal

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

EU tax: Brussels set for multinational crackdown

Margrethe Vestager, the EU’s competition commissioner, looks set to launch the international community’s most punitive attack on corporate tax avoidance as early as next Wednesday, with rulings that could impose heavy costs on multinationals, reports the Financial Times. Ms Vestager is understood to have postponed her first trip to China… – Continue reading