Category: Business

Canada: For Tax Purposes, Do You Know Where You Live?

In tax law, the concept of residency is used to determine tax liability based on whether there is a sufficient connection between an individual or legally recognized entity and a jurisdiction such that the jurisdiction is justified in taxing such individual or legally recognized entity on their worldwide income. Generally,… – 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

‘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

Commission to propose that country-by-country tax information be made public

Multinational companies operating in Europe will have to publicly disclose their earnings and the tax paid in each European country if new measures being proposed by the European Commission come into force, The Guardian has reported. The Commission will propose new legislation in April that makes profit and tax information… – 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

HMRC issues warning over contractor loan tax avoidance schemes

As part of what it describes as a ‘relentless’ effort to crack down on tax avoidance, HMRC has put out two publications highlighting problems with contractor loan schemes and misleading claims from scheme promoters, in a bid to deter taxpayers from any involvement In its Spotlight 29 document, HMRC says… – 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

Pakistanis welcome tax exemption

ABU DHABI // Pakistani expatriates have been reassured that new taxation laws will not apply to them. Anti-corruption campaign group Transparency International (TI) said Pakistanis residing in the UAE need not worry about double taxation laws. Syed Gilani, former chairman of TI, said that Pakistani laws state that anyone working… – Continue reading

BEPS Action 7: how the OECD’s proposals to redefine a PE could affect multinationals

The OECD’s final reports on the Base Erosion and Profit Shifting (BEPS) Project aim to target aggressive tax planning strategies which have the effect of shifting profits from high tax jurisdictions to low tax jurisdictions. The BEPS Project has been divided into 15 Actions, of which one of the most… – Continue reading

Bank Julius Baer Hit With $547M Criminal Tax Evasion Penalty, Two Bankers Plead Guilty

Bank Julius Baer of Switzerland will pay a $547 million penalty as two bankers individually plead guilty. The bank itself is charged with helping U.S. taxpayers hide billions in offshore accounts and cheating the IRS. The Bank’s deferred prosecution agreement admits that it knowingly assisted U.S. taxpayer-clients in evading taxes…. – 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

Govt criticised for failure to draft framework for jurisdictions of tax authorities

ISLAMABAD: Businessmen and tax experts have criticised the government for its failure to draft framework for jurisdictions of federal and provincial tax authorities. The government has not yet drafted a framework that clearly outlines the federal and provincial tax authorities’ jurisdictions in taxing the services sector. The absence of framework… – 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

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

French Tax Update – Recent Case Law and Other Noteworthy Publications

The present French Tax Update will focus on an overview of several noteworthy publications, including decisions issued during the past few months by the French Administrative Supreme Court (Conseil d’Etat) and French Constitutional Court (Conseil Constitutionnel), as well as the European Commission decision in respect of the Belgian Excess Profit… – Continue reading

Another chance for taxdodgers to come clean

The announcement of another tax and exchange control amnesty in this year’s budget is keenly awaited by some South African taxpayers. The looming implementation of the Common Reporting Standard for the automatic exchange of financial information between more than a hundred countries seems to be fueling the desire for another… – 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

All You Need to Know About Estonia’s E-Residency Program

Estonia has become the first country in the world to offer a transnational digital identity. It’s attracted the attention of entrepreneurs and digital nomads worldwide, but there’s still a huge amount of confusion about the benefits of the E-Residency Program and what e-residency actually means. Let’s take a look. What… – Continue reading

Treaties and treats

In the heyday of strict implementation of tax laws, it is a welcome relief to some taxpayers that a tax treaty relief application (TTRA) is after all, what it is supposed to be, a relief. To begin with, tax treaties are entered into by countries to reconcile their respective fiscal… – Continue reading

Has globalisation made corporation tax redundant?

The debate about corporation tax intensifies. Is the tax on profit no longer viable now that the global nature of modern business is making it ever harder for individual governments to enforce? Director asks two business leaders, has globalisation made corporation tax redundant? Yes, says Stephen Herring, head of taxation… – Continue reading

Brussels’ Corporate Tax Plan Falls Short of Reforms Needed

European Commission’s tax avoidance plan announced last week includes positives, like country-by-country reporting, but doesn’t go far enough to turn the tide against corporate tax dodging; Such reporting should be made public The European Commission last week announced proposals for new laws to tackle tax avoidance and evasion in the… – Continue reading

New EU rules to curb tax avoidance among giant multinational firms, following Google’s £130m “sweetheart” tax deal with HMRC

The European Commission proposed a set of new rules to curb tax avoidance by large companies. This follows Google’s £130m “sweetheart” tax deal with UK’s HM Revenue and Customs to allegedly avoid paying its fair share of corporate tax that spreads across ten years. Euronews reported that one of the… – Continue reading

Industry Expects Relief From Double Taxation For Ease Of Doing Business

While the central government is pursuing its objective to provide a certain and stable tax regime, it is critical that instances of dual levy of VAT and service tax on the same transaction are addressed urgently The levy of service tax as well as Value Added Tax (VAT) on the… – Continue reading

Business taxation may need radical change – think tank

Radical changes to business taxation may be necessary to reduce large multinationals’ ability to avoid levies, a respected economic think tank has indicated. In the wake of the row over Google’s deal with HM Revenue and Customs, the Institute for Fiscal Studies (IFS) suggested a shake-up of the corporation tax… – Continue reading

International Tax Disputes: A Ray of Hope

Despite the anticipated tsunami of tax disputes generated by underlying tensions in international taxation, there is reason for hope that appropriate means are being developed to address them efficiently and effectively. Multinational enterprises (MNEs) should be addressing their existing international taxation planning structures in light of coming changes in international… – Continue reading

EU Moves to Close Profit-Shifting Tax Loophole

The European Parliamentary Research Service has estimated that corporate tax-dodging costs the EU between $54.5 billion and $76.4 billion a year. The European Commission has proposed a package of measures to clamp down on corporate tax avoiders that would close a loophole companies have used to shift profits to low-tax… – Continue reading

Secret accounts overseas urged to be reported

Those who have been hiding their income or wealth overseas had better think again, as Korea will soon be exchanging financial information with multiple countries, including tax havens. They are advised to voluntarily report it to the government before the end of March to be given a grace period, said… – Continue reading

Subsidies will not be eliminated but better targeted, says Modi

Modi promised efficiency in allocation of resources as well as creation of opportunities for citizens to progress. New Delhi: Promising reforms that will transform lives, Prime Minister Narendra Modi on Friday said the government will not eliminate all subsidies but will rationalise and target them to the needy. He said… – Continue reading

MAP-ping tax reform: Good start to resolving transfer pricing row with US

Though the use of the retrospective tax on Vodafone and Cairn tend to grab the headlines, a large part of the ‘tax terror’ in India has really been the contribution of the high-pitched transfer pricing (TP) additions to the income of the MNCs Though the use of the retrospective tax… – Continue reading

India, U.S. clear 100 transfer pricing cases

India and the U.S. have reached an agreement to resolve more than 100 pending transfer pricing cases, one of the biggest deterrents for foreign investors planning an India foray, according to a government statement. Some more are expected to be resolved soon. Transfer pricing refers to the setting of the… – Continue reading

The Italian Patent Box and Its (Non-) Compliance with OECD Recommendations

The Italian Patent Box regime largely complies with the OECD recommendations to prevent base erosion and profit shifting. Its non-compliant features offer a brief window of opportunity for companies able to take swift advantage of its wide range of qualifying intangible assets. Many countries have implemented specific IP regimes through… – Continue reading

Mandatory disclosure of tax bills closer as Australia joins OECD push

Australia is one of 31 countries to sign an agreement in Paris to confidentially share tax information on multinational companies in a bid to stamp out tax avoidance. The deal comes as Apple has taken advantage of accounting rules in its local business that could allow it to pay virtually… – Continue reading

Fair Taxation: Commission presents new measures against corporate tax avoidance

Today’s proposals aim for a coordinated EU wide response to corporate tax avoidance, following global standards developed by the OECD last autumn. New rules are needed to align the tax laws in all 28 EU countries in order to fight aggressive tax practices by large companies efficiently and effectively. The… – Continue reading

Service tax exemption limit to be raised to Rs 25 lakh in Budget

The Ministry of Finance is planning to make the forthcoming general budget people-friendly. According to informed sources, the service tax exemption limit is expected to be increased from Rs 10 lakh at present to Rs 25 lakh. This is being seen as a major step aimed at benefitting traders and… – Continue reading

Seoul preparing to levy ‘Google tax’

x The government plans to exchange financial information on multinational firms doing business here with members of the OECD and G20 countries in order to make them pay appropriate taxes to countries where profits are generated, officials said Thursday. The Ministry of Strategy and Finance said that it will follow… – Continue reading

100 transfer pricing disputes with US resolved, says CBDT

NEW DELHI: The Central Board of Direct Taxes (CBDT) today said it has resolved as many as 100 transfer pricing disputes with the US, which will lead to an environment of “tax certainty and encourage MNCs” to do business in India. The resolution of such issues, CBDT said further, follows… – Continue reading

Canada: Tax Withholding Obligations Of Non-Resident Employers: Further Exemption Details Released

In its 2015 Budget, the Canadian federal government announced its intention to exempt “certified” non-resident employers from the obligation to withhold and remit income tax in respect of certain employees that perform duties in Canada. The Canada Revenue Agency (the “CRA“) recently released the application form that a non-resident employer… – Continue reading

EU Seeks Broader Crackdown On Corporate Tax Loopholes

BRUSSELS (Alliance News) – The EU stepped up the fight against corporate tax avoidance Thursday, unveiling proposals including an EU-wide blacklist of international tax havens, as part of a wider clampdown on firms using loopholes to reduce their tax bills. The EU’s executive estimates that member states are deprived of… – Continue reading

Canada: Taiwan – Canada Tax Arrangement Released

On January 15, 2016, Canada and Taiwan entered into an “Arrangement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income” (the “Arrangement“). The Arrangement will apply to amounts paid or taxation years beginning after January 1 of the year following the… – Continue reading