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
In the overview of tax treaties as published on the website of the Irish Revenue, the Irish Revenue has published a statement announcing that the Convention between the Government of Ireland and the Government of Ukraine for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect… – Continue reading
Greece has repealed a 26 percent withholding tax on business transactions with Cyprus following pressure from the European Commission. The tax, which was introduced by Greece in March, applied to transactions with Bulgaria, Cyprus, and Ireland – territories that were targeted due to their low corporate tax rates. The European… – Continue reading
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
Ireland has made “little or no” effort over the past four years to create a corruption-free playing field for global trade, violating its “obligation to combat cross-border bribery”, reports the Irish Times. The Transparency International Exporting Corruption report, released on Thursday, found that Ireland, along with countries such as Russia,… – Continue reading
Improvement of the e-management system for value added tax The Law of Ukraine “On Amending the Tax Code of Ukraine on improving the management of value added tax” No. 643 was adopted by the Verkhovna Rada of Ukraine on 16 July 2015. The law in its main part came into… – Continue reading
Subsidiaries in Luxembourg of food group had no staff and assets at year’s end of €1.3bn In its 2014 accounts Glanbia Luxfin, a subsidiary of Irish food group Glanbia, reported profits of $14.2 million and tax of $4,175, while Glanbia Luxinvest reported profits of €2.9 million and tax of €38,863…. – Continue reading
Whatever one thinks of Europe’s ruling class, one thing is undeniable: it has chutzpah. Like a gambler who has lost his savings on roulette and decides to bet his house in hope that his luck will turn, the EU leadership is upping the ante in the destructive pursuit of an… – Continue reading
Luxembourg currently has 76 income tax treaties in force, and there are 29 treaties under negotiation. Tax treaties can provide a legal framework not only for the avoidance of double taxation and fiscal evasion, but also for international administrative cooperation between Luxembourg and its treaty partners in terms of mutual… – Continue reading
The Organisation for Economic Cooperation and Development (OECD) said in a recent report that improving taxpayer services, while making non-compliance harder, is helping revenue bodies increase their efficiency and allowing governments to finance important programs that will further benefit their citizens. According to Tax Administration 2015, which looks at 56… – Continue reading
Introduction In 1934 distinguished US jurist Judge Learned Hand famously opined that “one may so arrange his affairs so that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to… – Continue reading
Artisan goods marketplace Etsy Inc., which promised to be a beacon for transparency as a public company, recently implemented a strategy that shrouds its offshore tax-cutting arrangements in secrecy. Because of a change in how its Irish subsidiary is registered, Etsy no longer needs to publicly disclose basic financial information… – Continue reading
With the UK announcing new tax rules for foreigners living in the country, the government has been careful not to damage the country’s appeal to wealthy foreigners. The “non-dom” tax status “plays an important role in allowing those from abroad to contribute to our economy”, says George Osborne, the UK’s… – Continue reading
On August 11, 2015, the Organisation for Economic Co-operation and Development (OECD) released its annual report addressing global tax administration. The OECD’s stated mission is to “promote policies that will improve the economic and social well-being of people around the world.” The OECD describes its annual report as follows: Tax… – Continue reading
The first reporting cycle for the United States Foreign Account Tax Compliance Act (FATCA) kicked off with the 31 March deadline set by the US Internal Revenue Service’s (IRS) for countries and territories such as Hong Kong that have a Model 2 Intergovernmental Agreement (IGA). Although the IRS has granted… – Continue reading
Accommodation company Airbnb has held a meeting in Dublin, for people in Ireland who may owe tax on income earned by renting rooms and properties through the website. However, Airbnb hosts said there was no tax or legal expert to answer their questions and the meeting did not provide clarity… – Continue reading
Only 23 percent of business leaders feel that recommendations from the OECD on base erosion and profit shifting will be successfully implemented, according to the findings of a new survey by Grant Thornton. Three quarters of business leaders would pay more taxes in exchange for greater clarity from authorities on… – Continue reading
Shire, the giant pharmaceutical company that relocated its head office from the UK to Ireland for tax reasons a number of years ago has surprised investors by launching a US$30bn hostile bid to acquire the American company, Baxalta, which is also involved in the manufacture of drugs to combat rare… – Continue reading
LONDON–(BUSINESS WIRE)–Three quarters of business leaders would pay more taxes in exchange for greater clarity from authorities on what is acceptable, according to the Grant Thornton International Business Report (IBR), a global survey of 2,580 businesses in 35 economies. And while few expect a global agreement any time soon, the… – Continue reading
Microsoft Corp.’s stockpile of offshore profits rose to $108 billion, with a 17 percent increase over the past year as the company continues reaping profits in low-tax foreign jurisdictions. The company crossed the $100 billion mark, making it just the second U.S. corporation — after General Electric Co. — to… – Continue reading
Governments that offer multi-national firms sweetheart tax deals should not be allowed to benefit if the European Union orders them to claw back the aid, according to a new report by the European Parliament’s special committee on tax rulings. Instead, the proceeds should be “returned to the member states which… – Continue reading
Governments that dole out tax subsidies to big companies shouldn’t be allowed to reap multibillion-euro windfalls if the European Union orders them to claw back the aid, lawmakers probing tax loopholes said. Instead, the EU should consider changing the law so that money is shared among neighboring nations that played… – Continue reading
Multinationals should pay a withholding tax before moving their profits out of EU countries to ensure they are being taxed somewhere, according to a draft report from the European Parliament. The report, seen by the Irish Examiner, deals with the fallout from the Lux Leaks and follows the European Commission’s… – Continue reading
Blatant corporate and personal tax evasion contributed to Greece’s debt crisis, but it’s dwarfed by the tax avoidance of U.S. multinationals operating in countries like Australia. There’s a popular misconception that Greece’s debt crisis was self-inflicted. ‘The Greeks are a bunch of tax evaders! They should never have been allowed… – Continue reading
July 22: The Irish Revenue Commissioners updated a list of “frequently asked questions” (FAQs) concerning FATCA reporting obligations of Irish reporting financial institutions. A list of FAQs concerning the Common Reporting Standard (CRS) was also released. Read the FATCA and CRS FAQs (21 July 2015) from the Irish Revenue Commissioners…. – Continue reading
London (July 21st 2015):- His Excellency Dr Kevin Isaac signed an Agreement on the Exchange of Information Relating to Tax Matters with the Republic of Ireland on behalf of the Federation this afternoon July 21st 2015 at the Embassy of Ireland in London. Ireland’s ambassador for Britain Dun Mulhall signed… – Continue reading
THE HAUGE, July 20 (Xinhua) — The Dutch-German agreement to enhance the exchange of information on tax rulings was “an important step” towards greater transparency, but there is still a long way to go before reaching common ground on harmonized corporate tax policies within the European Union (EU), according to… – Continue reading
Irish people investing in other countries often lose up to a fifth of dividends Irish tax refund specialists Taxback. com have introduced an online service to help people recover tax withheld on share dividends in other countries. *Irish people investing abroad often lose up to a fifth of their dividends… – Continue reading
The IRS’ investigation into Microsoft books centers on how the company uses its overseas subsidiaries for tax purposes. The company says the IRS audit has gone on long enough and the federal agency improperly hired an outside law firm to help in the investigation. Microsoft and the federal government have… – Continue reading
The rising exchange of information between countries is also leading to the disclosure of more details about these taxpayers’ affairs. Along with other countries, SA is paying closer attention to its residents’ cross-border activities. But while compliance is necessary, industry experts warn that overly aggressive tax enforcement in SA could… – Continue reading
Whether or not the point-of-consumption tax (POC) enacted by the United Kingdom in 2014 is a barrier to the free trade of services across the European Union is a question that will now head to the Court of Justice of the EU, following a ruling in a UK case yesterday…. – Continue reading
A seismic change in the international private wealth arena is under way. Over 90 jurisdictions have committed to automatically exchange comprehensive financial information on an annual basis under the OECD’s Common Reporting Standard (CRS). The CRS will start in 2016 in over 55 jurisdictions. This article comments on the CRS… – Continue reading
European Commission to issue decisions on four test cases, including Apple in Ireland, Until a few months ago, the medieval town of Athenry in County Galway owed its fame mainly to a song. Irish rugby and football fans often burst into stirring renditions of “The Fields of Athenry”, a ballad… – Continue reading
Portugal is an increasingly desirable destination, thanks to its tax-friendly stance. Portugal may not be top of everyone’s list in terms of tax-friendliness, particularly given the recent backdrop of the recession and bail-out, but it does have a history of running successful tax-friendly programmes, for example the Madeira and Azores… – Continue reading
KUWAIT, July 13 (KUNA) ¬¬ The cabinet, under the chairmanship of His Highness the Prime Minister Sheikh Jaber Al¬Mubarak Al¬Hamad Al¬Sabah, approved Monday a number of agreements to boost cooperation with several friendly countries. The endorsed agreements included a memorandum of understanding for cooperation in social insurance with Bahraini government,… – Continue reading
Multinationals were probably waiting for result of British referendum on EU before deciding where to locate, says head of Irish investment authority Global corporations will think twice about investing in the UK while uncertainty reigns over Britain’s European Union membership, according to the head of the Irish state body that… – Continue reading
10/07/2015 – The OECD set out a clear path for Lithuania’s accession to the Organisation, reinforcing the OECD’s commitment to further extend its global membership. On 8 July 2015 the 34 OECD Members adopted the Roadmap for the Accession of Lithuania to the OECD Convention setting out the terms, conditions… – Continue reading
Ireland’s Horizon Pharma has launched a hostile takeover bid for Depomed of the US after being frustrated in its efforts to enter negotiations about combining the two companies. Horizon was a US company until September 2014 when it closed a $660m takeover of Irish company Vidara Therapeutics just days before… – Continue reading
Five days after the emergence of the most serious allegations of large-scale corruption in recent memory, the PSNI has still not opened a criminal investigation. The TUV leader Jim Allister said that, after days of continued revelations about the irregular nature of the sale of NAMA’s – the Republic’s ‘bad… – Continue reading
Apple is most valuable company in the world – worth an estimated £500bn But it funnels sales though Ireland to whittle down its tax bills in the UK Company made £1.9bn profit in UK last year worth £400m incorporation tax But they paid just £11.8million – only £400,000 more than… – Continue reading
ARBADOS’ CONTROVERSIAL BLACKLISTING by a group of European Union (EU) countries is “hypocritical” and “grossly discriminatory”, says outgoing Barbados International Business Association (BIBA) president Connie Smith. But Smith also thinks the time is right for “engaging in bilateral discussions which could hopefully conclude in double taxation agreements and bilateral investment… – Continue reading
Thousands of retirees living abroad face the prospect of high tax charges, following an HMRC crackdown on offshore pension transfers. The Financial Times reported that HM Revenue & Customs is now investigating whether offshore pension schemes that accepted transfers from the UK meet new requirements. Offshore pension funds must comply… – Continue reading
Ireland’s attractively low rate of corporate taxation is once again under pressure with the recent release of the European Commission’s new action plan to tackle tax avoidance. The commission has been prompted into this politically ambitious move by public outcry over big, usually American, companies avoiding tax in the EU…. – Continue reading
The next step for all Irish entities which are classified as Financial Institutions (“FIs”) for FATCA purposes is to submit a return (the “FATCA Return”) to Irish Revenue setting out details of any US reportable accounts they may have maintained during the 2014 calendar year, or to confirm by way… – Continue reading
A new HMRC taskforce has been launched to go after wealthy tax cheats in Northern Ireland. Investigators from HM Revenue and Customs will use Land Registry and Merchant Acquirer data to identify those with “badges of wealth” such as large houses, aeroplanes, boats and undeclared offshore bank accounts, which are… – Continue reading
“THE decision by a group of European Union (EU) Member States to blacklist Barbados as being non-cooperative and further claim that Barbados and 29 other countries, mostly small islands, do not meet its standards of transparency, exchange of information and fair tax competition, is hypocritical and on the face of… – Continue reading
Ahead of Dublin visit, health expert discusses fighting poverty and sharing prosperity. “The Koreans have a saying that you bury your spouse in the ground but you bury your children in your heart,” said Dr Jim Yong Kim. The Korean-born health expert is speaking to The Irish Times at his… – Continue reading
The Irish Revenue has again reminded taxpayers that the Tax Avoidance Settlement Opportunity deadline is June 30. Revenue said over EUR33m (USD36.9m) has either been paid, or commitments to pay have been received, in respect of more than 90 cases. The settlement opportunity was contained in the 2014 Finance Act…. – Continue reading
The Irish Government announced that the FATCA reporting deadline has been extended to 31 July 2015 (from 30 June 2015) for reporting Irish financial institutions to file a FATCA return with respect to 2014. FATCA seeks to obtain information on accounts held by U.S. taxpayers in other countries. It requires… – Continue reading
Conor Hynes and Ronan Connaughton of Deloitte Ireland explore the impending changes arising from BEPS Action 7 and the Skandia case and provide insight on the potential tax impact for the insurance industry. The Greek philosopher Heraclitus is attributed with the saying, “the only thing that is constant is change”…. – Continue reading
