Category: Europe

France, Luxembourg amend tax treaty, affecting investment structures of Luxembourg vehicles holding French real estate

The French and Luxembourg governments have signed a new amendment to the French-Luxembourg tax treaty that will significantly impact the investment structures involving Luxembourg vehicles holding French real estate assets. This amendment, signed early in September, will come into force once the ratification process by the respective parliaments of both… – Continue reading

Lack of fairness with overseas tax evasion: Canadians pay the price

The Government of Canada has been moving ahead with its plans to solve the deficit by cutting services to Canadians and yet, there are billions of dollars in taxable assets illegally hidden by some Canadians in overseas tax havens. Overseas tax evasion is a serious problem requiring assertive action not… – Continue reading

Minecraft, Nokia, Skype: How Microsoft Buys Overseas Companies To Avoid US Taxes

Nokia, Skype and Minecraft-maker Mojang have more in common than just the fact that they are among Microsoft’s biggest acquisition targets in recent years. They are all also based outside the U.S., and that’s no coincidence. As the debate over so-called inversions heats up and critics — from President Obama… – Continue reading

Treasury’s Inversion Rules Create Uncertain Environment For US Multinational Companies

The Obama administration’s new rules intended to stem the tide of inversions, in which U.S. companies reincorporate abroad to dodge taxes at home, won’t be completely effective because they don’t address the high corporate tax rate in the U.S. that compels such behavior, say tax experts and analysts. The rules announced… – Continue reading

Obama Treasury’s Corporate Inversion Regulations Simply Won’t Work

The Treasury Department today came out with a series of arcane new tax regulations in the hopes of stemming corporate inversions. Inversions happen when U.S. companies merge with a foreign company while usually retaining U.S. operations. Their purpose is to avoid punitive U.S. double taxation on income earned overseas. The… – Continue reading

Twitter accounts point to UK sales heading offshore

Twitter is funnelling much of the revenue it generates in Britain through an offshore sales structure, newly published annual accounts suggested today. Twitter UK has filed abbreviated 2013 accounts for a small company under Companies House rules, which are usually applicable to a business with an annual turnover of less… – Continue reading

New US Tax Rules Chill ‘Inversion’ Deal-Making

WASHINGTON/NEW YORK, Sept 23, (Agencies): Tough new US rules on corporate “inversions” on Tuesday sent a chill through the market for the tax-avoidance deals, both pending and potential, with share prices falling sharply in nearly a dozen companies on both sides of the Atlantic. As investors sold stocks involved in inversions,… – Continue reading

Alibaba’s $21.8 Billion Inversion

Inversions are technically a financial transaction where a corporation from one country, say the United States, merges with a company in a foreign country, say Ireland. Nothing changes in the United States from a business point of view, except that the value and financial sustainability of the corporation goes up significantly. Why… – Continue reading

British Virgin Islands: BVI US And UK FATCA Implementation – Entity Classification And Registration

On 30 June 2014, the British Virgin Islands (“BVI“) government signed a Model 1B (i.e. non-reciprocal) intergovernmental agreement with the United States (the “US IGA“).  The US IGA provides a framework for the implementation of the US Foreign Account Tax Compliance Act (“FATCA“) in the BVI.  The BVI government had,… – Continue reading

B2B: Transfer Pricing

Three years ago, Russia adopted new transfer pricing legislation. The new rules became effective on  Jan. 1, 2012. They are in line with international standards (OECD Guidelines on Transfer Pricing), but their concept was, and still is, quite new for the Russian tax authorities. Thus the rules provide for a transition period until 2017: For the years 2012… – Continue reading

Everything That’s Wrong with the US Tax System in One Chart

Last week the Tax Foundation released its annual International Tax Competitiveness Index for 2014. The United States ranked 32 out of 34 OECD countries surveyed. Only Portugal and France got lower competitiveness scores, and not by much. As if that were not bad enough, the competitiveness score is only half… – Continue reading

B2B: Bilateral Advance Pricing Agreements Are a Useful Tool for Attracting Foreign Investors

In recent years, Russian tax legislation has adopted many modern international tax concepts and practices. Most notably, transfer pricing rules, consolidated groups of taxpayers, easy electronic communications between taxpayers and tax authorities have all become part of standard working practice. However, there is always room for improvement. The current global economic and political situation dictates that new initiatives… – Continue reading

Lonmin denies evading tax

Reports that Lonmin was evading tax were denied by a spokeswoman on Monday, after calls that the company should be investigated. “It is completely false, we are busy preparing a statement,” spokeswoman Sue Vey said. Vey said she was not sure when the statement would be released. Earlier, Sars spokesman… – Continue reading

UK Tax Evasion Widens on HMRC Cuts and Lack of Avoidance Law

A lack of anti-avoidance tax law and cuts to public services are contributing to the UK’s yawning tax gap. New research by Tax Research LLP, on behalf of the Public and Commercial Services Union, shows that the tax gap – defined as “the difference between the tax that should be paid in the UK if the taxsystem worked as parliament and… – Continue reading

Labour Could Ban Uber App Over Tax Avoidance Fears

Labour could stop controversial cab-on-demand app Uber from operating in Britain over concerns about its tax arrangements. Shadow transport secretary Mary Creagh warned that Labour would not tolerate “tax avoidance on a large scale”, describing Uber’s tax arrangements, being based offshore, as “interesting”. She also seized on the fact that… – Continue reading

The Obama administration just took action to curb corporate inversions. It’s the right move against tax avoiders.

The beautiful part is the administration did it without Congress. Jared Bernstein, a former chief economist to Vice President Biden, is a senior fellow at the Center on Budget and Policy Priorities and author of “Crunch: Why Do I Feel So Squeezed?” among other books. Well, would you look at… – Continue reading

U.S. Treasury moves against tax-avoidance ‘inversion’ deals

(Reuters) – Moving against tax avoidance by corporations, the Obama administration took several actions on Monday to curb “inversion” deals that allow companies to escape high U.S. taxes by reincorporating abroad. The Treasury Department announced new rules, effective immediately, that will reduce the tax benefits available to companies that have… – Continue reading

Pressure rises to close tax loopholes

Plans to curb tax avoidance will hit Ireland. Most countries are set to force multinationals to pay more tax and as the political controversy grows, our own role in these activities will come under ever increasing scrutiny On Tuesday the OECD, the Paris-based club of the world’s richest economies, published… – Continue reading

From today, a new beginning to end global bank secrecy: G20

CAIRNS/AUSTRALIA: India may have scored a big win in its efforts to receive information on black money stashed away overseas as the G20 grouping of nations is set to endorse on Sunday a framework for automatic exchange of information on bank accounts, putting an end to global bank secrecy. A… – Continue reading

Big economies take aim at the firms running circles around their taxmen

POLITICIANS in the rich world like to splutter about the ever more elaborate dodges that big multinational firms undertake to minimise their tax bills. But doing something about them is trickier. America’s Congress is struggling to agree on ways to stop companies “inverting”—switching domicile to reduce tax bills (see article)…. – Continue reading

Dar rules out easy access to billions in Swiss banks

ISLAMABAD: Finance Minister Ishaq Dar on Thursday ruled out possibility of the recovery of billions of dollars stashed in Swiss banks any time soon. ISLAMABAD: Finance Minister Ishaq Dar on Thursday ruled out possibility of the recovery of billions of dollars stashed in Swiss banks any time soon. The minister… – Continue reading

Mail & Guardian NEWS OPINION BUSINESS ARTS & CULTURE EDUCATION SCI-TECH MULTIMEDIA SPECIAL REPORTS IN THE PAPER ZAPIRO PARTNERS NEWS NATIONAL AFRICA WORLD ENVIRONMENT SPORT HEALTH DATA AMABHUNGANE National Cyril Ramaphosa’s Lonmin tax-dodge headache

Having recently blasted corporate tax evaders, the deputy president now has egg on his face after Lonmin’s Bermuda tax avoidance tactics surfaced. Evidence before the Marikana commission that Lonmin moved millions in platinum revenue from South Africa to tax-free Bermuda is likely to prove embarrassing for ANC deputy president Cyril… – Continue reading

UBS Clients Lead Canada Surge in Admitting Hidden Income

Clients of UBS AG (UBSN), Switzerland’s largest bank, have led a five-fold surge in the number of Canadian residents reporting hidden offshore income over the past eight years. Almost 6,000 taxpayers came forward in the past 12 months as part of the Canada Revenue Agency’s voluntary disclosure program to report… – Continue reading

International Tax Alert: OECD Releases BEPS Papers

Yesterday saw the release of the first set of deliverables under the OECD’s project on base erosion and profit shifting (BEPS).  These constitute the “building blocks” for an internationally agreed and co-ordinated response to government and media concerns in recent years about the perceived way in which shortcomings in relevant… – Continue reading

‘Deoffshorisation’ of the Russian Economy: Updated version of the Draft Law on Controlled Foreign Company legislation and other measures

The Russian Ministry of Finance has published an updated version of the draft controlled foreign company rules (hereinafter – “CFC”) on the 2nd of September (hereinafter – ‘the new Draft’). The previous drafts were covered in detail in our press releases of 24 March and 5 June. The new Draft… – Continue reading

Google, Apple and Amazon under fire in OECD war on tax evasion

The OECD wants to force businesses to declare their turnover and number of employees in each country where they are active. Among the multinationals targeted are digital giants Google, Apple and Amazon. The Organisation for Economic Co-operation and Development (OECD) has announced an international action plan called “Project BEPS”, to target… – Continue reading

UBS in $1.4 Billion Test of French Tax-Evasion Crackdown

UBS AG, the world’s biggest manager of money for the rich, has become the test case for French President Francois Hollande’s tax-evasion crackdown. The Swiss bank is set to learn from a Paris appeals court on Sept. 22 if it must post a 1.1 billion-euro ($1.4 billion) bond to cover… – Continue reading

OECD outlines anti-tax avoidance plan

THE CLAMPDOWN on tax avoidance by multinational corporations has been bolstered by a series of recommendations made by the OECD. Companies including Google, Amazon and Starbucks have been in the firing line for their use of offshore jurisdictions to drive down their UK tax liabilities. In particular, the companies have… – Continue reading

How Italian jewellery giant Bulgari struck tax gold

Luxury brand came under investigation after routing €680m through its Irish unit Apple and Google are names regularly cited when it comes to using Ireland for aggressive tax planning, but the practice is open to a much wider range of businesses. Bulgari, the Italian jewellery giant whose products were made… – Continue reading

Tax information: Cyprus accepts India’s condition

Cyprus has accepted a key condition put forward by India on effective exchange of information on tax avoiders Cyprus has accepted a key condition put forward by India on effective exchange of information on tax avoiders, hoping its move, which comes amid continuing talks on amending their mutual tax treaty,… – Continue reading

Swiss banks at crossroads as secrecy goes up in smoke

As Switzerland’s long-cherished banking secrecy practices evaporate, the institutions in the world’s largest offshore tax haven are dramatically rethinking their business models in a bid to survive. Already reeling from the painful process of making amends for allowing foreign nationals to hide assets from the taxman back home, the secretive… – Continue reading

Cyprus: Implications Of Anti-Avoidance Amendments To EU Parent-Subsidiary Directive

Cyprus transposed the EU Parent-Subsidiary Directive1 into domestic legislation when it updated its tax laws in preparation for EU membership in 2004. The Income Tax Law and the Special Contribution for the Defence of the Republic Law provide a liberal system of double taxation avoidance, which also extends to non-EU countries,… – Continue reading

FIFA panel member is stood down during Cayman Islands corruption probe

A member of FIFA’s financial watchdog panel has been temporarily suspended while implicated in the Cayman Islands corruption investigation. Canover Watson was questioned last month by police anti-corruption and financial crime units in his native Cayman Islands on suspicion of corruption and money-laundering. He denies wrongdoing. FIFA said audit committee chairman… – Continue reading

ICBC to clear RMB business in Luxembourg

BEIJING, Sept. 16 (Xinhua) — The Luxembourg branch of China’s largest lender, ICBC, has been appointed as a clearing bank for renminbi business in the European country, the Chinese central bank said on Tuesday. The People’s Bank of China (PBOC) made the decision in accordance with a memorandum of understanding… – Continue reading

Inverting corporations should pay what they owe when they go

If the all-American fast food chain Burger King, with its thousands of restaurants in the United States, can claim to be a foreign company for tax purposes, our corporate tax system is in real trouble. The crisis of corporate inversions is now apparent even to those who aren’t connected to… – Continue reading

India Continues Tax Dispute With Cyprus and Mauritius

India has seemingly reached an impasse with both Cyprus and Mauritius over the re-negotiation of their respective double taxation avoidance agreements (DTAA). For the former, the disagreement relates to Cyprus’s status as a notified jurisdictional area (NJA) in India, whilst for the latter, it pertains to the update of their… – Continue reading

Forget Zimbabwe, U.S. Tax System Ranks At Bottom, Just Better Than Portugal

Remember the study last year that ranked our tax code right below Zimbabwe? Now, a new study by the Tax Foundation still ranks us near last. Zimbabwe wasn’t a part of this contest, since the new study looked only at the 34 countries making up the OECD. Still, we have… – Continue reading

British Virgin Islands suffers amid push against money laundering

High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Email ftsales.support@ft.com to buy additional rights. http://www.ft.com/cms/s/0/3fbed922-3d51-11e4-871d-00144feabdc0.html#ixzz3Eo63WbfR The British Virgin Islands has long attracted Chinese companies looking to… – Continue reading