Where do things stand with the government’s efforts to combat corporate tax avoidance and evasion, one of its priorities as G20 chair in 2014? The headlines suggest a contradictory stance. The latest headline is that Treasurer Hockey ‘backflips on tax laws to target multinational profit-shifters’. This refers to the announcement… – Continue reading
When the commission unveiled its work program this week, it pledged to drop a stalled energy-tax proposal and resume consultations on a common corporate consolidated tax base. The program also promises an “action plan on efforts to combat tax evasion and tax fraud, including a communication on a renewed approach… – Continue reading
The United States Council for International Business (USCIB) has warned that the United Kingdom’s proposal to impose a new tax on so-called “diverted profits” (DPT) would, if implemented, have a major impact on US-based multinational companies. The rules, contained in UK Government’s recent Autumn Statement, propose a 25 percent DPT… – Continue reading
High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. Brussels has widened a probe into corporate tax rulings to include all 28 member states amid heightened scrutiny of sweetheart tax deals granted to businesses by national… – Continue reading
While the Foreign Account Tax Compliance Act (FATCA) has focused worldwide attention on U.S. efforts to create a mandatory cross-border exchange of tax information, the enactment of FATCA was not an isolated occurrence. For more than a decade, the Organisation for Economic Co-operation and Development (OECD) has been trying to… – Continue reading
An investigation into tax rulings provided by certain EU member states is to be widened to cover all member states, according to a press release from the European Commission.17 Dec 2014 Tax Disputes and Investigations EU & Competition Tax Public procurement and state aid Corporate tax International tax UK Europe… – Continue reading
A tax based on turnover penalises companies that hang on to their profits ro reinvest in the business One week it is Starbucks. The week afterwards it is Amazon. And the week after that it is Apple or Vodafone. The names in the headlines might change from time to time…. – Continue reading
HM Revenue and Customs (HMRC) has secured almost all of the disputed tax due from the first group of tax avoidance scheme users to receive the controversial Accelerated Payment notices. About 30 scheme users were told in late August they had 90 days to pay a total of around £29… – Continue reading
(CNS Business): The British government has published draft legislation for a new Diverted Profits Tax (DPT), dubbed the “Google tax”, by which it intends to sidestep Britain’s existing tax treaties with low-tax jurisdictions by levying a charge that would fall outside the corporate tax system. The government hopes to raise… – Continue reading
* EU to examine tax arrangements across bloc * Several deals with multinationals already under scrutiny * Questions asked of new Commission President Juncker (Adds Luxembourg reaction, background) By Foo Yun Chee BRUSSELS, Dec 17 (Reuters) – European Union competition regulators have asked all 28 member countries for details of… – Continue reading
Think tank targets key aspects of Republic’s role in multinationals’ tax affairs Key features of Ireland’s role in the tax affairs of major technology companies such as Google and Microsoft are being targeted by the OECD’s base-erosion and profit-shifting (Beps) project, it has emerged. Ideas being worked on by the… – Continue reading
Bermuda’s Minister of Finance, Bob Richards, has snubbed the UK Prime Minister David Cameron’s plan to create public registers of beneficial owners of companies incorporated in Bermuda. His reasoning behind this update was that this move would be damaging to the economy as Bermuda would lose it’s competitive advantage. He… – Continue reading
Proposals which would introduce automatic criminal penalties for those who fail to declare taxable offshore income may “quietly disappear” following their omission from draft clauses for the 2015 Finance Bill published for consultation, an expert has said.15 Dec 2014 Tax Disputes and Investigations Tax Corporate tax Private wealth tax UK… – Continue reading
Something strange happened in 2014 — Americans became very interested in corporate tax policy. It started in the spring, when U.S.-based pharmaceutical giant Pfizer, which produces blockbuster drugs like Lipitor and Viagra, floated a possible merger with its British-based rival AstraZeneca. Normally a merger of that size would make a… – Continue reading
HM Revenue and Customs (HMRC) has pocketed £32 million after demanding early payments of disputed tax from investors in suspected avoidance schemes. The taxman says this equates to 99% of disputed tax from the first tax avoidance scheme users to be issued with accelerated payment notices. HMRC said that 30… – Continue reading
A new standard that would help stamp out tax evasion by forcing multinationals to give governments details about their tax affairs has been uncosted by Treasury, the latest budget update shows. Under a plan agreed to at the G20 finance ministers meeting in Cairns held earlier this year and then… – Continue reading
The government’s plans to implement a Diverted Profits Tax (DPT) have been questioned by the Association of Chartered Certified Accountants (ACCA). Chas Roy-Chowdhury, head of taxation at the body, said nobody wants profits that should be subject to UK tax “escape the net”. As a result, he believes it is… – Continue reading
Background On 15 December, 2014, the OECD hosted a webcast to update the global tax community on progress under the Base Erosion and Profit Shifting (“BEPS”) Plan. This year, the OECD produced 10 different reports (“BEPS Reports”) covering several actions specific to transfer pricing. This latest OECD webcast summarised efforts… – Continue reading
Given the publicity surrounding the practices of multinationals in structuring their affairs to minimise their tax liabilities, it is not completely surprising that the UK Government has chosen to act by introducing a new tax, called the Diverted Profits Tax (“DPT”), which applies at the rate of 25% (rather than… – Continue reading
Some of the best tax minds in the country agree on one thing: Corporate tax reform will be a very, very heavy lift. Sure, the White House and top lawmakers who will be in charge of writing tax law next year have signaled their openness to the idea. And, yes,… – Continue reading
1. The traditional attitude to tax avoidance is encapsulated in the judgment of Lord Tomlin in the English case of IRC v Duke of Westminster (1936): “Every man is entitled if he can to arrange his affairs so that the tax attaching under the appropriate Acts is less than it… – Continue reading
Around the world, countries are desperately seeking ways to stop multinational companies from earning profits within their borders without paying taxes on them, while stashing trillions in tax havens like the Cayman Islands. The British government, after a search, says it knows how to tax the profits Google earns in… – Continue reading
As multinationals are forced to reveal more about themselves, where should the limits of transparency lie? HOWARD SCHULTZ, the head of Starbucks, said last year that “the currency of leadership is transparency.” If so, bosses should be feeling ever more qualified to command their troops. Business is being forced to… – Continue reading
It seems that reports of Ferrari’s relocation to London have been somewhat exaggerated. The past few days have seen more than a few stories on the legendary Italian brand’s decision to move its tax base out of Italy, and now Fiat Chrysler is speaking out against the scuttlebutt. “These rumors… – Continue reading
Last week’s Autumn Statement was another step in the right direction for the British economy. The economic news it contained continues to warrant cautious optimism. Growth for this year has been revised up to 3 per cent, making us the fastest growing major advanced economy. Unemployment is predicted to fall… – Continue reading
There’s big news from across the pond. The U.K. government’s Autumn Statement (formerly known as the pre-Budget report), released December 3, promises to change how multinational corporations will be taxed – and offers a cautionary tale for would-be U.S. tax reformers. Britain will introduce a “diverted profits” tax, targeting corporations… – Continue reading
HM Revenue & Customs’ (HMRC) plan to make undeclared taxable offshore income a criminal offence has suffered a blow as it has been omitted from draft legislation. The draft Financial Bill, published earlier this week, extended the scope of civil penalties for tax evasion but there was no reference to… – Continue reading
HM Revenue and Customs (HMRC) has issued a new factsheet for users of tax avoidance schemes, explaining how its follower notices and accelerated payments regimes operate. The factsheet defines a tax avoidance scheme as “a set of arrangements that try to use the law to gain a tax advantage that… – Continue reading
There’s big news from across the pond. The U.K. government’s Autumn Statement (formerly known as the pre-Budget report), released December 3, promises to change how multinational corporations will be taxed – and offers a cautionary tale for would-be U.S. tax reformers. Britain will introduce a “diverted profits” tax, targeting corporations… – Continue reading
Jeb Bush, a front-runner to become the Republican Party’s next presidential nominee, has used Britain to set up a private equity fund that could possibly allow it to avoid paying tax in America. The potentially damaging revelation was uncovered by the financial news wire Bloomberg and could pose a serious… – Continue reading
This Alert provides more details on the most significant measures contained in the draft Finance Bill. Draft clauses of the UK Finance Bill 2015 were published on 10 December 2014. They will now be the subject of consultation until 4 February 2015. This Alert provides more details on the most… – Continue reading
The new EU Competition Commissioner has said there is reasonable doubt about whether Apple’s tax arrangements with Ireland were legal. In her first comments on the investigation into the US tech giant’s tax affairs in Ireland, the Danish Commissioner Margrethe Vestager said the case remained open. This is despite Minister… – Continue reading
HM Revenue and Customs (HMRC) has issued a new factsheet for users of tax avoidance schemes, explaining how its follower notices and accelerated payments regimes operate. The factsheet defines a tax avoidance scheme as “a set of arrangements that try to use the law to gain a tax advantage that… – Continue reading
Maples and Calder Michael Gagie, Richard Grasby, Tim Clipstone, Christopher Capewell, Jon Fowler and Tim Frawley Do trustees need to register with the US Internal Revenue Service (the “IRS”) before 1 January 2015? Does registration need to be made in respect of a trust? These questions need to be given… – Continue reading
Scots could end up being “overtaxed” under plans to hand sweeping new powers to Holyrood as part of the Smith Agreement, MSPs have been told. Leading economists warned that big accountancy firms could start selling schemes to “avoid Scottish residence” in order to escape higher tax rates. Holyrood’s devolution committee… – Continue reading
Ferrari SpA is considering moving its fiscal residence outside Italy to save on corporate taxes as the supercar maker prepares for its spinoff from Fiat Chrysler Automobiles NV (FCAU), people familiar with the matter said. The manufacturer, which uses the colors of the Italian flag in its logo, may follow… – Continue reading
A new UK tax on the ‘diverted profits’ of multinationals operating in the UK “is probably not needed, will be hard to apply and will raise little money” according to one expert. 10 Dec 2014 Corporate tax Tax International tax UK Europe Heather Self of Pinsent Masons, the law firm… – Continue reading
Rudolf Elmer, the former employee of Julius Baer Group Ltd. accused of revealing details of client accounts via WikiLeaks, collapsed at the start of his trial, forcing the court to postpone the case. It was not clear when the trial in Zurich District Court would continue. Proceedings had been under… – Continue reading
Hutchison Whampoa had profit of €429.6m but paid just €65,067 tax in Luxembourg A Luxembourg company that provides indirect financial support to 3 Ireland, is among the latest batch of entities found to be availing of secret tax deals in Luxembourg. Hutchison Whampoa Europe Investments Sarl (HWEI) – part of… – Continue reading
Minister of state stresses taxation rates remains a matter for member states Ireland has “nothing to fear” from European proposals to tackle multinational tax avoidance, the Minister of State at the Department of Finance Simon Harris said on Tuesday as EU finance ministers rubber-stamped new rules on the automatic exchange… – Continue reading
The European Investment Bank, which gives loans and grants using taxpayers’ money, acted wrongly when it refused to disclose details of alleged tax evasion by mining giant Glencore, the EU’s watchdog has ruled. The EIB failed to disclose the results of its own investigation into the allegations surrounding a mining… – Continue reading
This publication provides a brief overview of the expected impact on entities established in Bermuda of (a) the foreign account tax compliance provisions (“FATCA”) of the Hiring Incentives to Restore Employment Act, 2010 of the United States of America (the “US”); and (b) equivalent rules implemented in relation to United… – Continue reading
Some statistics rank London as the fourth largest ‘French’ city by population, and the number of French individuals moving to the UK is growing. This is not surprising – the UK offers a highly favourable tax regime for ‘non-domiciled’ individuals moving to the UK, while entrepreneurs, professionals and high net… – Continue reading
Grand Duchy accused of allowing multinational firms to pay virtually no tax Leaked documents reveal more firms used Luxembourg to lower tax There is no suggestion that the tax schemes used by firms are illegal But scandal has dragged in Luxembourg’s former PM Mr Juncker Giant US businesses Disney and… – Continue reading
Rudolf Elmer, the former employee of Julius Baer Group Ltd. accused of revealing details of client accounts via WikiLeaks, collapsed at the start of his trial, forcing the court to postpone the case. It was not clear when the trial in Zurich District Court would continue. Proceedings had been under… – Continue reading
In advance of the UK Chancellor’s Autumn Statement, Geoff Cook, CEO of Jersey Finance said: “The Chancellor has shown a strong commitment to tackling tax evasion and I look forward to hearing more detail behind his future plans in this regard in the Autumn Statement. It is vital that the… – Continue reading
The House of Commons Public Accounts Committee on Monday held a hearing on the role of accountancy firms in tax avoidance and PwC (PricewaterhouseCoopers), the Big 4 accounting firm, was represented by Kevin Nicholson, PwC head of tax in the UK and former HMRC (HM Revenue & Customs) tax inspector,… – Continue reading
The Australian Tax Office is auditing 10 multinational corporations and the government will consider introducing new laws aimed at targeting tax avoidance, Joe Hockey has said. The treasurer said on Tuesday the ATO was “embedded in the offices” of multinationals operating in Australia to closely scrutinise whether those companies were… – Continue reading
Australia may follow the UK in implementing a “diverted profits” tax on multinationals to crack down on tax avoidance. Joe Hockey, Australia’s treasurer, said on Tuesday that his office is exchanging information with London on its “Google tax”, which was announced last week, writes Jamie Smyth in Sydney. I am… – Continue reading
In advance of the UK Chancellor’s Autumn Statement, Geoff Cook, CEO of Jersey Finance said: “The Chancellor has shown a strong commitment to tackling tax evasion and I look forward to hearing more detail behind his future plans in this regard in the Autumn Statement. It is vital that the… – Continue reading
