The much-awaited decision of the Bombay High Court was pronounced on October 10. Transfer pricing adjustment carried out in Shell/Vodafone case has been at the centrestage of every public discussion on Indian transfer pricing legislation. The incredulous stand taken by the tax authorities has evoked a strong response from investors… – Continue reading
The European Commission has published a new report detailing key tax reforms implemented by European Union member states during 2014 and identifies the main policy challenges they are said to face. The report notes that the tax burden on labor in the EU is relatively high. It suggests that member… – Continue reading
Budget measures including new foreign direct investment incentives discussed State agencies and Government Ministers and officials have launched a co-ordinated campaign of letters and phone calls to senior executives of foreign multinationals, to reassure them that Ireland remains a top destination for investment following the budget, Minister for Enterprise Richard… – Continue reading
n this second part of our overview of current transfer pricing regulations on the African continent, we focus on relevant provisions in, amongst others, Ghana, Nigeria and Uganda. The Ghanaian Transfer Pricing Regulations, 2012 (L.I.2188) (the Ghanaian Regulations) were introduced by the Ghana Revenue Authority (GRA) on 27 July 2012,… – Continue reading
Ireland has this week moved to change its tax law, closing the “double Irish” tax avoidance technique widely used by multinational enterprises including Google and Microsoft. Picture: Getty Images In very broad terms, the current Irish tax law allows a company incorporated in Ireland to be a tax resident of… – Continue reading
AMONG several proposals for tax reform, the director-general of the Revenue Department has said the agency would propose an amendment to the Revenue Code concerning transfer pricing, aiming to provide greater clarity on the determination of fair transfer prices. The director-general has indicated that in past years many multinational companies,… – Continue reading
The IRS has issued FAQs relating to the new streamlined procedures for offshore compliance, and for Delinquent International Information Return Submission Procedures. The FAQs for the streamlined program provide more detailed guidance on how the 5% penalty will be computed, how 100% owners of an incorporated business will be treated,… – Continue reading
As the Irish government considers closing an infamous tax loophole for corporations, Wall Street has been scrambling to gauge the effect on the pharmaceutical industry. So far, the prognosis seems that damage will largely be minimal. Known as the ‘Double Irish,’ the loophole allows companies to send royalty payments for… – Continue reading
What is FATCA? The Foreign Account Tax Compliance Act (“FATCA”) is a complex reporting and withholding regime enacted by the U.S. government in March, 2010 that is expected to become operational on July 1, 2014. FATCA was designed to combat tax evasion by U.S. taxpayers holding assets through non-U.S. financial… – Continue reading
AbbVie Inc. (ABBV) may scrap its planned 32.4-billion-pound ($51.5 billion) deal for Dublin-based drugmaker Shire Plc (SHP), in what would be the biggest casualty of the U.S. crackdown on so-called tax inversions. Shire stock plunged the most in 12 years after North Chicago, Illinois-based AbbVie said its board will meet… – Continue reading
Taxi service Uber’s tax affairs have been referred to HMRC by London’s taxi and minicab regulator Transport for London (TfL). The move follows a complaint from senior Labour MP Margaret Hodge that Uber was “opting out of the UK tax regime”. London mayor and TfL chair Boris Johnson said TfL… – Continue reading
There are lots of headlines out of Dublin today about the end of the “double Irish,” a notorious tax break used by multinational companies to avoid paying government levies around the world. Don’t be fooled: The Emerald Isle isn’t giving up on its race to the bottom of the tax… – Continue reading
Taxes on fuel and corporate benefit need to rise significantly, says agency The Organisation for Economic Co-operation and Development (OECD) has launched a war of words on diesel fuel and company cars, claiming that the taxation levels on both are costing governments billions and seriously harming the environment. “The cost… – Continue reading
INTRODUCTION In a recent publication1, the LMA have announced a change of approach to the allocation of FATCA withholding risk in certain of their precedent facility agreements. Previously, the LMA had not adopted a definitive stance in this area, recognising that borrowers and lenders may wish to allocate the risk… – Continue reading
LUXEMBOURG, Oct. 14 (Xinhua) — EU finance minister meeting concluded on Tuesday with breakthrough in taxation exchange information to fight against tax avoidance. Italian finance minister Pietro Carlo Padoan, whose country holds the presidency of the EU, told press after the meeting that the EU has planned to build a… – Continue reading
On May 9, 2014, the Tokyo District Court reversed a large tax that had been imposed on a large U.S. multinational’s Japanese holding company (“Japan HoldCo”). Under the Japanese Corporate Tax Law, if a shareholder returns shares to an issuing company (i.e., the issuing company acquires treasury shares), a portion… – Continue reading
Forty of Australia’s biggest companies will be asked to explain their tax affairs to a Senate committee investigating corporate tax avoidance. Companies shown, in a recent report, to have the lowest “effective tax rate” over the past decade and to operate the most subsidiaries in tax havens have been given… – Continue reading
Malta, like Cyprus, has been obliged to dismantle its old ‘offshore’ companies regime as a trade-off for joining the European Union. EU membership has, however, brought about certain benefits for Maltese companies trading across borders, and, coupled with investment-friendly government policies and some interesting tax planning opportunities, Malta remains one… – Continue reading
TORONTO , Oct. 2, 2014 /CNW/ – Aggressive international corporate tax avoidance by multinational corporations has become the subject of intense political scrutiny. U.S. politicians have called out some American multinationals, including Apple, Amazon, Starbucks and Google, for relocating profits abroad to avoid U.S. taxes. More recently, politicians accused Burger… – Continue reading
It appears as if Irish eyes won’t be smiling on U.S. corporations soon. The government of Ireland is set to change its tax code tomorrow to eliminate some of those loopholes that American companies have come to love. Among the targets– the so-called “double Irish” tax break. Both the U.S…. – Continue reading
Reuters) – Ireland’s plan to close a “Double Irish” tax loophole could cost U.S. companies including Apple and Google billions of dollars, although a new break and pressure to tackle tax avoidance elsewhere means they are unlikely to decamp. Analysts and tax advisers predict that corporations which need access to… – Continue reading
* Ireland to end tax regime that saved multinationals billions * Swift upturn ushers in tax cuts rather than austerity * Government faces backlash over uneven nature of recovery (Adds finance minister interview, Google comment) By Padraic Halpin and Conor Humphries DUBLIN, Oct 14 (Reuters) – Ireland will phase out… – Continue reading
The Swiss finance minister, Eveline Widmer-Schlumpf, and her counterparts from European Union member states have signed a joint statement aimed at ending a controversy over corporate taxes. The declaration, signed in Luxembourg on Tuesday, includes the Swiss government’s plans to push ahead with abolishing certain preferential tax regimes for foreign… – Continue reading
Hitech firms are being warned that they should take advantage of tax relief on patent related profits now before a threatened clamp down by the European Union according to Richard Hopes, Partner at Alliotts accountants based in Surrey and London. Richard Hopes, Partner at Alliotts accountants and a specialist in… – Continue reading
It is said that Argentina faces an economic and political crisis every 10 years. Whenever a crisis arises, Argentinians’ right of ownership is at risk. Devaluation, asymmetric pesification and the current foreign exchange restrictions are a few examples of the challenges we face. What’s more, according to a recent OECD… – Continue reading
How your listed property holding will be taxed. CAPE TOWN – By the middle of this year, most of South Africa’s listed property companies had converted themselves into real estate investment trusts (REITs) under legislation adopted in 2013. This brings the sector in line with global standards. One of the… – Continue reading
The IRS updated its streamlined offshore compliance program to provide procedures taxpayers residing both inside and outside the United States should use to participate in the program. The streamlined offshore compliance program is for taxpayers whose failure to comply with requirements to report offshore assets is nonwillful. It is designed… – Continue reading
(Reuters) – Portugal’s government will maintain its budget deficit goal of 2.5 percent of gross domestic product next year and any income tax cuts would depend on clamping down on tax evasion and would only be made after the end of the year, two sources said. Portugal’s center-right government approved… – Continue reading
(Reuters) – Italian Prime Minister Matteo Renzi on Monday promised sweeping tax and spending cuts to help boost growth and jobs next year, as the European Commission considers whether to reject his budget plan for reducing debt too slowly. Speaking to a conference of business leaders, Renzi said he would… – Continue reading
Inter vivos and testamentary trusts are used frequently in Canada to implement a variety of estate and tax planning strategies. Over the past few years, however, amendments to Canada’s Income Tax Act (the ITA), and case law have altered the effectiveness of the use of trusts in certain circumstances. In… – Continue reading
Tax authority set a target of 1,165 people a year by 2014/15, but analysis of the last tax year shows it prosecuted just 795 £119.4bn of UK tax went unpaid, avoided or evaded in the financial year 2013/14, with evasion totalling £82.1bn, according to campaigner Richard Murphy. Photograph: Daniel Lynch… – Continue reading
Americans for Tax Reform is one of 20 taxpayer and free market groups from 15 countries which have signed a letter to world leaders to outline their opposition to transnational tax initiatives and any increase or harmonization of excise taxes. In 2012, the World Health Organization proposed to raise certain… – Continue reading
Compliance is China’s latest Hot Topic. Until recently, many Western managers accepted that some flexibility on legal issues was needed to thrive in the complex Chinese legal environment. Practices to strengthen relationships such as luxurious dinners and karaoke evenings, sponsored travel, red-pocket money and the like, have often been regarded… – Continue reading
Moshe Asher is seeking information about accounts in Switzerland belonging to Israelis. The Israel Tax Authority is stepping up it efforts to combat overseas tax shelters for Israelis. Sources inform “Globes” that Israel Tax Authority director Moshe Asher is expected to travel to Switzerland next week in order to meet… – Continue reading
It is time for an inquiry into HMRC’s competence, policy, decision-making processes and duty to provide transparency Thomas Paine’s observation that what first was plunder later assumed the name of revenue is well-understood by those who have chosen to make their living abroad. Individuals move for various reasons: career development,… – Continue reading
Ireland’s finance ministry officials are weighing phasing out a tax device used by multinational companies including Google Inc., according to a person with knowledge of the matter, as the European Union looks into the practice. Ireland is considering whether to eliminate a technique known as the “Double Irish,” which allows… – Continue reading
* Dublin set to change tax residency rules in Oct. 14 budget * Companies already in Ireland to be given time to adjust * Measures due to be signed off by cabinet next Tuesday By Padraic Halpin DUBLIN, Oct 10 (Reuters) – Ireland is set to announce legal changes next… – Continue reading
Introduction Action 1: the digital economy Action 2: hybrid mismatch arrangements Action 5: harmful tax competition Action 6: preventing tax treaty abuse Action 8: guidance on transfer pricing and intangible assets Action 13: transfer pricing documentation and country-by-country reporting Action 15: developing a multilateral legal instrument Next steps Introduction On… – Continue reading
This week brings a wealth of news in the FATCA arena, which we summarize in today’s post. First, former acting IRS Commissioner Steven Miller speaks out against FATCA and suggests that the benefits of the new information reporting regime imposed by FATCA may not outweigh its costs. An article published… – Continue reading
For a large majority of the ever-increasing number of British expatriates with pensions which remain in the UK, a Qualifying Recognised Overseas Pension Scheme (QROPS) provides a viable and sometimes integral role in retirement planning. This counts for those now residing in Europe, Asia and the Middle East, however arguments… – Continue reading
Both the Securities Industry and Financial Markets Association (SIFMA) and Mindtree, a global technology services company, have pointed out the immense global compliance costs and issues posed by the Foreign Account Tax Compliance Act (FATCA) to the financial services industry. Enacted by the US Congress in 2010, and effective from… – Continue reading
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/ba95cff0-4fcd-11e4-a0a4-00144feab7de.html#ixzz3G77zeNBz Brussels is challenging the “double Irish” tax avoidance measure prized by big US tech… – Continue reading
There are reportedly about to be major moves in the fight against tax evasion within the European Union. The region’s finance ministers are said to be close to an agreement on automatic sharing of bank data so that the authorities could spot tax dodging or illicit money flows more easily…. – Continue reading
The UK Finance Act 2014, enacted in July 2014, contains new legislation to deal with cases of purported tax avoidance, which marks a radical departure from previous policy in this area. Until Finance Act 2014, it was generally the case that where a taxpayer contested a direct tax assessment made… – Continue reading
The Internal Revenue Department has fined or warned scores of businesses for failing to pay taxes but has yet to file criminal charges against a single tax evader, said Min Htut, its director-general. Fines for tax evasion range from 10-150 per cent of taxes owed, he said, adding that the… – Continue reading
MOSCOW, October 8. /TASS/. The Russian Finance Ministry has drafted a decree that will exclude Malta from the black list of offshore jurisdictions. The decision followed the enactment of the convention between the governments of Russia and Malta of May 22, 2014 on the avoidance of dual taxation and prevention… – Continue reading
OPINION: How often do you hear governments say ‘we’re not sure if it will work, but we’ll give it a shot’? Not a lot, Chalkie would say. Lack of evidence that a policy will produce the desired effect is generally its death knell, particularly if said government was not keen… – Continue reading
MOSCOW, October 8. /TASS/. The Russian Finance Ministry has drafted a decree that will exclude Malta from the black list of offshore jurisdictions. The decision followed the enactment of the convention between the governments of Russia and Malta of May 22, 2014 on the avoidance of dual taxation and prevention… – Continue reading
Simon Carter Prime Minister David Cameron pledged at Tory party conference to make tax cuts to assist 30 million “hardworking families”. However, according to tax experts, the main beneficiaries won’t be the claimed 30 million but only the rich. According to the Institute of Fiscal Studies only 15% of the gains from increasing… – Continue reading
HM Revenue and Customs (HMRC) is consulting on draft regulations that will exclude two types of persons from the definition of “promoter” for the purposes of the Promoters of Tax Avoidance legislation. The regulations are intended to meet concerns raised during the development of the primary legislation. They are relieving… – Continue reading
