Category: Corporate Tax

The tide continues to turn for offshore companies.

The case of Development Securities (No. 9) Ltd and other v HMRC [2017] UKFTT 0565 is the latest in a line of cases concerning the UK corporate tax residence of offshore companies. The case once again highlights the difficulties in preserving an offshore company’s non-UK tax resident status, whilst giving… – Continue reading

Ireland, Hungary Unite Against EU Tax Harmonization

The leaders of Hungary and Ireland have both expressed their opposition to the prospect of additional tax harmonization within the EU. Irish Prime Minister Leo Varadkar was in Hungary to visit his counterpart, Viktor Orban. Reuters reported that, during a joint news conference following their meeting, Orban said that his… – Continue reading

There Is a Raging Battle of Tax Codes with China and the US Starting the Race

The GOP tax bill that was signed into law by the white house late last year, significantly reduced corporate taxes which has piled pressure on other significant economies around the world to adjust so as not to lose investors to the United States. Just hours after President Trump signed the… – Continue reading

Bulgarian Presidency Outlines EU Tax Plans

The “fair and efficient” taxation of corporate profits and the fight against tax avoidance and evasion through enhanced administrative cooperation are among the priorities of the new Bulgarian presidency of the European Union, which commenced on January 1, 2018. The recently released program of the Bulgarian presidency states that it… – Continue reading

Singapore Urged To Enhance Tax Offering

Ernst and Young Solutions LLP, Singapore, has released its wish list for the Singapore Budget 2018, calling for reforms to sharpen the territory’s competitiveness. The firm said that Singapore should maintain its 17 percent corporate income tax (CIT) rate, which is one of the lowest in the world, but recommended… – Continue reading

US tax reform breaks global rules, EU says

European finance ministers are worried. They say the United States’ big tax reform bill contains measures that would unfairly disadvantage European business and contravene global fair-taxation rules. Are they right? Last week, the finance ministers of Europe’s five biggest economies — Germany, France, the UK, Spain and Italy — wrote… – Continue reading

Amazon Agrees To A $118 Million Tax Settlement With Italy

Amazon reached a major tax settlement with Italy by agreeing to pay €100 million ($118 million) to the European country in order to put an end to an investigation of potential back taxes it owes that spanned the majority of this year. According to initial reports on the matter, Italian… – Continue reading

Facebook Korea to pay tax here on ad income

Facebook has decided to start paying tax to Korea on advertising revenue earned here, bowing to mounting complaints over multinational online giants’ tax avoidance. The U.S. social media company’s decision will place other global information players such as Apple, Google and Cisco under more pressure to follow suit. They have… – Continue reading

Transfer Pricing and BEPS to Increase Tax Revenues in Georgia

The FINANCIAL — Transfer Pricing Rules were implemented by the Government of Georgia in 2011, based on OECD guidelines. Since the number of international companies in Georgia is increasing steadily, Transfer Pricing Rules have become a point of obvious interest. However, multinational companies operating in Georgia are not sufficiently well-informed… – Continue reading

AmCham EU Speaks Out Against EU Digital Tax Proposals

The American Chamber of Commerce in the European Union has criticized the proposals put forward in the European Commission’s recent consultation on options for new tax rules or a new tax on digital firms. The aim of that consultation is to help the Commission to define an approach to the… – Continue reading

Bahamas ‘Done Everything Possible’ To Avoid Blacklist

THE Deputy Prime Minister believes the Bahamas has “done everything we could possibly do” to escape the European Union (EU) ‘tax haven’ blacklist that will be issued tomorrow. K P Turnquest told Tribune Business that the Minnis administration “has no reason to think” this nation will be deemed a ‘non-cooperative… – Continue reading

France Boasts Second-Highest Taxes In the World

A new study shows that France taxes its population the second-most among developed countries. Which country claimed the first place spot? Denmark. As research from the OECD economic think tank attests, the combination of France’s income and property taxes, social security payments, and goods and services makes up 45.3% of… – Continue reading

Tax Reform Must Level the Playing Field for American Companies

Multinationals have been getting away with not paying their fair share to the U.S. for too long, says this business founder With Washington pushing full-tilt on tax reform, it’s time to tackle the unfair tax advantage enjoyed by multinational enterprises. Addressing this longstanding problem could provide a unique opportunity to… – Continue reading

Senate’s Offshore Tax Ideas Could Be a ‘Goldmine’ for Some Companies

Plan proposes 12.5% tax rate on intellectual-property income Bills ‘upend decades of U.S. tax policy’ on tight deadline U.S. companies that make billions of dollars from patents and other intellectual property held offshore would be eligible for a special 12.5 percent tax rate on those earnings under the Senate tax… – Continue reading

US Senate Presents A Different Take On Tax Reform

The Senate Finance Committee released its tax reform plan on November 9, presenting a draft bill with marked differences to that agreed by the House Ways and Means Committee on the same day. The proposal was drafted by Finance Committee Republicans under the leadership of Senate Finance Committee Chairman Orrin… – Continue reading

CCCTB FAQ

The European Union Common Consolidated Corporate Tax Base (CCCTB) has been talked about recently as a solution to the problem of an imperfect pan-EU corporate tax system, which allows large companies, particularly those with a digital presence, to detach profits from value-creation, and pay tax in low-tax jurisdictions. But what… – Continue reading

Republicans Reveal US Tax Reform Law

On October 2 the US Government released the Tax Cuts and Jobs Act, setting out in legislation its plans for comprehensive reform of the US tax code. For businesses, the bill will bring about a landmark shift to a territorial corporate tax system, replacing the current worldwide tax basis regime… – Continue reading

‘Low Level’ Corporation Tax Studied

The Deputy Prime Minister yesterday revealed the Bahamas “may have to look at” implementing a low-rate corporate income tax, as global regulatory pressures force “hard decisions” upon it. K P Turnquest, while emphasising that such a move was a long way off, agreed that compliance with the OECD’s Base Erosion… – Continue reading

Base Erosion and Profit Shifting Project implementation in Mauritius

Introduction The Organisation for Economic Co-operation and Development (OECD) is an economic organisation made up of 35 member countries, with the aim of encouraging economic progress and world trade. In 2015, the OECD developed the Base Erosion and Profit Shifting (BEPS) Project, made up of reports on 15 action plans,… – Continue reading

Morrison Pushing For Australian Company Tax Cuts

Cutting Australia’s company tax rate is “now an urgent matter,” according to Treasurer Scott Morrison. In a speech to CEDA, Morrison said that with the UK, France, and the US each seeking to lower their corporate tax rate, Australian businesses risk “becoming stranded on an uncompetitive tax island if we… – Continue reading

PANA committee calls for increased focus on virtual currencies, new technologies such as FinTech

The European Parliament’s PANA Committee has approved draft recommendations calling for increased scrutiny and regulation of emerging technologies, including virtual currencies and FinTech. The committee also approved a report delving into the findings of an 18-month probe into breaches of EU law in relation to money laundering, tax avoidance and… – Continue reading

Hong Kong financial chief dashes hopes for wide-ranging tax cuts for corporations

Paul Chan Mo-po says the city must protect against unforeseen market changes at a tax forum that also featured a warning about the city’s international tax compliance There are no plans to cut Hong Kong’s corporate taxes across the board because the government needs to reserve funds to protect the… – Continue reading

Switzerland agrees to share tax information on multinationals

ZURICH (Reuters) – Switzerland said on Wednesday it would start sharing information on the activities of multinationals in its territory with other countries in 2020, joining an international push to fight tax evasion. The new measures will force about 200 large companies in the low-tax haven to prepare country-by-country reports… – Continue reading

Singapore tax incentives meet global standards

Republic has implemented all four agreed standards under OECD’s tax/profit project An international body overseeing global tax practices has said that Singapore’s tax incentives meet the international standards on countering corporate tax avoidance. The Forum on Harmful Tax Practices (FHTP) said in a report yesterday that it had reviewed 164… – Continue reading

ATO’s tax gap figures revealed: $2.5 billion missing from corporates, multinationals

An estimated $3.5 billion in revenue from large corporates and multinationals is at risk to the economy, but through audit activity this will reduce to $2.5 billion, according to the Australian Taxation Office. On Wednesday the agency is releasing the first tranche of its long-awaited highly anticipated “tax gap” figures,… – Continue reading

Small EU countries need tax competition tools to compensate for major disadvantages – Sant

Maltese MEP and former Prime Minister Alfred Sant said that small EU countries and islands use tax competition tools in order to compensate for major competitive disadvantages due to their limited endowments and distance from major markets. Along with Malta, even Ireland and Cyprus have notably expressed their great concerns… – Continue reading

Ireland to be dragged in front of Europe’s highest court for refusing to accept €13billion in Apple back tax

The cash would be enough to fund the entire health service for a year Ireland faces legal action for failing to recover €13billion euros in tax from US tech giant Apple after European competition authorities blasted the country over a sweetheart deal. The European Commission said Ireland had not recouped… – Continue reading

EU Countries Seek Legislative End-Around on Digital Tech Tax

EU nations led by France and Italy reinforced the need for an “equalization tax” or turnover tax on large internet companies such as Facebook Inc. and Amazon.com Inc., and suggested they would use special legislative procedures to impose one in the event all 28 EU-member countries don’t back the levy…. – Continue reading

100 Organizations Urge Congress to Reject Giant Tax Loophole for Offshoring and Tax Avoidance

GOP Leadership’s Proposal for a “Territorial Tax System” Would Encourage Corporations to Send Jobs Offshore and Avoid Paying Taxes. WASHINGTON – Today, 100 organizations sent a letter urging members of Congress to reject a proposal that would allow U.S. multinational corporations to pay little to nothing on their offshore profits…. – Continue reading

Trump’s corporate tax reform plan could neuter Ireland’s advantage

President Trump on Wednesday this week announced a sketchy Republican tax reform plan that covered just 9 pages and he proposed that the headline federal corporate rate should be cut from 35% to 20%. However, there is a risk to Ireland’s low 12.5% corporate tax advantage. The average rate of… – Continue reading

U.S. companies urge EU to refrain from unilateral moves on Web tax

BRUSSELS (Reuters) – The European Union’s plans to increase taxes on digital firms risks undermining the bloc’s growth and stifle global efforts to find common solutions, U.S. companies operating in the EU said on Tuesday. Critics say online firms such as Google (GOOGL.O) or Facebook (FB.O) pay too little tax… – Continue reading

Business Europe Rejects EU Digital Turnover Tax Proposal

Markus J Beyrer, Director General of Business Europe, has expressed concerns about the proposed introduction of a European Union turnover tax on digital businesses. On September 21, the European Commission launched a new agenda to ensure that the digital economy is taxed “in a fair and growth-friendly way.” This could… – Continue reading

The Netherlands – Budget 2018 – Dividend withholding tax and non-resident taxation

On 19 September 2017, the Dutch government released the State’s Budget for the year 2018. The Budget includes a draft bill to expand the dividend withholding tax exemption to tax treaty countries, to introduce a withholding tax obligation for holding cooperatives and to limit the taxation of non-resident investors. If… – Continue reading

US set to lose $12bn in tax take by 2027 if multinationals relocate overseas

Tax inversions by US multinationals attempting to shift profits into lower tax jurisdictions could cost the US up to $12bn (£7.4bn) in lost corporate tax revenues by 2027, according to figures released by the US Congressional Budget Office There were 11 major corporate inversions from 2014-2015, although two significant inversions… – Continue reading

BHP willing to head to court against ATO tax bill

BHP is willing to head to court to fight the Australian Taxation Office on a more than $1 billion tax bill over its Singapore marketing hub. The world’s largest miner has continually defended its Singapore marketing hub, where it is accused of routing profits, and says it is confident of… – Continue reading

Multinationals Fear Japan Reports Could Spur Outside Audits

Japanese multinational companies worry that filing their first country-by-country reports in 2018 will lead to a barrage of transfer pricing audits by developing countries. Companies are currently preparing their first country-by-country reports that must be filed with the National Tax Agency by the end of March 2018. Japan adopted country-by-country… – Continue reading

OECD Criticizes Estonia’s Dividend Tax Measure

The OECD has taken issue with the Estonian Government’s plans to reduce the rate of tax on distributed dividends for established companies, warning that the measure could complicate the tax system and discriminate against small firms. Under recently enacted legislation, tax on distributed dividends will be reduced from 20 percent… – Continue reading