Category: Base Erosion & Profit Shifting

Patent box tax break for innovation “does not facilitate profit shifting”, says UK Treasury

The UK government will continue to defend its ‘patent box’ tax break for income from qualifying intellectual property (IP) during discussions to develop a global corporate tax regime, a Treasury official has said.08 Oct 2014 Intellectual Property Tax Patents Corporate tax Life sciences Advanced Manufacturing & Technology Services UK Europe… – Continue reading

Patent box tax break for innovation “does not facilitate profit shifting”, says UK Treasury

The UK government will continue to defend its ‘patent box’ tax break for income from qualifying intellectual property (IP) during discussions to develop a global corporate tax regime, a Treasury official has said.08 Oct 2014 Intellectual Property Tax Patents Corporate tax Life sciences Advanced Manufacturing & Technology Services UK Europe… – Continue reading

Corporate tax rip-off

Eight of the top 200 companies publicly listed on the Australian stock exchange (ASX200) paid no taxes on profits averaging $50 million to more than half a billion dollars over the decade to 2013! More than 20 (10 percent) corporations paid an average tax rate of five percent or less…. – Continue reading

Amazon faces European Union tax avoidance investigation

Amazon, the online retailer, is to face a formal investigation into its European corporate tax practices, the European Commission has announced. The Commission – the executive division of the 28-member European Union – says it will look at the tax agreement made between Amazon and Luxembourg. It suspects the deal… – Continue reading

The Marzen decision: a typical example of BEPS

On June 10, 2014, the Tax Court of Canada (“TCC”) delivered its most recent decision on transfer pricing, one which involved a Barbados structure. In Marzen Artistic Aluminum Ltd. v. The Queen[1] (“Marzen”), Justice Sheridan upheld the Canada Revenue Agency’s (“CRA”) transfer pricing adjustment as well as the penalty under… – Continue reading

Washington resists Hockey’s tax crackdown on Silicon Valley giants

OHN KEHOE The global tax plan being pursued by Australia as G20 president, to compel low-tax paying multinationals such as Google and Apple to ­contribute more revenue to government coffers, could be derailed by political resistance in the United States. A prominent US senator in congress who would likely become… – Continue reading

UK government promises early consultation on new multinational tax avoidance rules

The UK government will shortly set out how it plans to implement globally agreed rules to prevent multinational companies from using artificial techniques to significantly reduce their tax bills, it has announced.06 Oct 2014 Tax Tax Disputes and Investigations UK Europe It has confirmed that it will consult on the… – Continue reading

Bernard Hickey: War on the high-tech dodgers

We pay our taxes. Why won’t they? It’s the topic every tax official and finance minister in the developed world is talking about and acting on, yet we hear little about it in New Zealand. Cracking down on tax avoidance by the world’s biggest technology companies – among them Google,… – Continue reading

Osborne proposals for anti-abuse tax rules could damage UK competitiveness, expert warns

Plans to tackle UK tax avoidance by international technology companies could damage UK competitiveness if they are brought in before international measures are finalised, a tax law expert has warned.02 Oct 2014 Corporate tax Tax Tax Disputes and Investigations TMT Advanced Manufacturing & Technology Services UK Europe Heather Self of… – Continue reading

Osborne bid to fight tax avoidance ‘may empty, not swell, state coffers’

British chancellor George Osborne’s promise to clamp down on a tax avoidance loophole widely used by multinational technology companies could actually result in a reduction in the amount of money the government takes in, the Chartered Institute of Taxation has warned. Patrick Stevens, the group’s tax policy director, admitted the… – Continue reading

eBay pays just £620,000 tax on £1.3bn sales

eBay accused of tax avoidance, but insists it complies with letter of the law By Emma Woollacott, Sep 29, 2014Updated: September 30, 2014 7:24 AM Online auction site eBay got away with paying just £620,000 in tax on sales of over £1.3 billion last year, its latest accounts reveal. The… – Continue reading

Crackdown on Apple in Ireland Opens Front in Tax Avoidance War

The European Commission’s crackdown on the deal between Irish tax authorities and Apple Inc. marks an expansion in the growing global war on tax avoidance by multinational companies. Governments that enable it are now a target. Tuesday, the European Commission said the Irish tax authorities failed to conform to international… – Continue reading

EU says Ireland swapped Apple tax deal for jobs

The European Union has accused Ireland of swerving international tax rules by letting Apple shelter profits worth tens of billions of dollars from revenue collectors in return for maintaining jobs. European Competition Commissioner Joaquin Almunia told the Dublin government in a letter published on Tuesday that tax deals agreed in… – Continue reading

Taxman targets multinational profit stripping

Inland Revenue has gone shopping for a database to help it fight erosion of the tax base and “profit stripping” by multinational corporations. The database will help the taxman to independently assess the level of profitability companies should be returning for tax purposes by benchmarking the prices multinationals charge their… – Continue reading

Hiding Assets Under Pet Names Looks Willful, Even For Lionel Messi With 400 Goals

There is nothing illegal about tax planning. Yet some things are legal while others are not, and the lines can sometimes get fuzzy. Add to that the fact that some people go to extraordinary lengths to avoid paying taxes, and it can be a recipe for disaster. Increasingly, if you… – Continue reading

OECD: tax avoidance rules must avoid “collateral damage” on fund management industry

The fund management industry could be exempted from new global rules intended to combat tax avoidance by multinational companies if further work finds that they may “hamper legitimate transactions”, according to the Office for Economic Cooperation and Development (OECD).26 Sep 2014 Corporate Tax Corporate tax Tax Disputes and Investigations Investment… – Continue reading

The Skinny on Corporate Inversions

Corporate financial accounting and taxation are complex subjects. For this reason, many people tune out when issues that involve corporate tax practices rise to the level of public debate. Unfortunately, many legislators shy away from these issues for similar reasons. But while corporate taxation can be mind-bogglingly complex, nontax experts… – Continue reading

Tax avoidance under scrutiny

European Union Tax Commissioner Algirdas Šemeta has welcomed a raft of new measures to combat international tax avoidance, in agreement between the finance ministers of the G20 at a meeting in Cairns, Australia. The ministers have agreed on a several recommendations that were made to address key areas which were… – Continue reading

UK government reveals new tax evasion scheme for multinationals

Global corporations based in the UK will now have to report where they make their profits and pay their taxes to HMRC, the UK government has announced. The new country-by-country reporting template was released this week by the OECD and the UK is the first of 44 countries to officially sign… – 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

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

UK Chartered Accountants Welcome BEPS Progress

The Chartered Institute of Taxation’s Tax Policy Director has said the “first wave of reports [from the Organization for Economic Cooperation and Development on base erosion and profit shifting] is a significant step forward in the process of modernizing the international tax system, but the test will be getting international… – 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

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

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

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


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

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

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

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

Hong Kong Signs on to New OECD Global Tax Standards

HONG KONG – The government of Hong Kong has recently announced that it will support the Organization for Economic Cooperation and Development’s (OECD) new global standards on the automatic exchange of information for the purpose of enhancing tax transparency and combating cross-border tax evasion. Earlier this year, the OECD released… – 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

OECD Recommends Approach to Combating Corporate Tax Avoidance

The Organization for Economic Cooperation and Development has released its first set of recommendations for a coordinated international approach to combat tax avoidance by multinational enterprises, under the OECD/G20 Base Erosion and Profit Shifting Project. The OECD and the Group of 20 finance ministers hope to create a single set… – Continue reading

OECD Takes Aim at Improper Profit Shifting

The Organization for Economic Cooperation and Development recommended Tuesday changes to international tax rules that could stop U.S. multinationals from shifting revenues and profits overseas. A total of 44 large economies, including the U.S., China and Japan, agreed with the new guidelines, but each country must change their laws and may not… – Continue reading

OECD to publish first proposals on tax avoidance; Big tech on backfoot

The OECD will today publish its first recommendations for a co-ordinated international approach to combat tax avoidance by multinational enterprises under the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project. Meanwhile there is already evidence in Europe that the confluence of massive tax avoidance and increased concerns about privacy is… – Continue reading

A global tax crackdown gets one step closer

A proposed clampdown on global tax avoidance took a step forward on Tuesday with a leading global think tank releasing key recommendations ahead of a G-20 meeting later this month. The practice of companies shifting their profits to other country’s jurisdictions to avoid paying tax has drawn criticism from governments… – Continue reading

No US Bipartisan Anti-Inversion Legislation In Sight

While Senate Democrats continue to examine specific legislative proposals to deter US multinationals from using corporate inversions to move their tax residence abroad, Republicans remain insistent that any specific anti-inversion legislation should be explicitly linked to comprehensive tax reform. A new bill has been put forward by Charles Schumer (D… – Continue reading

OECD releases 2014 BEPS deliverables

On September 16, 2014, the Organisation for Economic Co-operation and Development (OECD)  released its first seven of 15 deliverables under the OECD/G20 base erosion and profit shifting (BEPS) project (the 2014 BEPS Package). The 2014 BEPS Package arises from the Action Plan on Base Erosion and Profit Shifting (the BEPS Action Plan),… – Continue reading

Since 2010, Burger King Has Reduced Its World Wide Tax Rate by 60%

American taxpayers are being robbed by yet another giant corporation that is deserting the USA after using the country’s advantages to build untold wealth. Burger King’s recent decision to pursue a corporate inversion to Canada is the culmination of years of maneuvering to dodge paying its fair share in corporate… – Continue reading

Heat on Joe Hockey over tax avoidance deal as government prepares to host G20

Labor has accused the government of procrastinating on a key measure to stop multinational companies shifting profits offshore. It comes as the government prepares to chair the G20 finance ministers meeting in Cairns next week. The information-sharing deal, part of the global push to tackle tax avoidance, has been signed… – Continue reading

Transfer-pricing in the world of BEPS

The past few years have seen a quantum leap in globalisation, resulting in free movement of capital and labour, shifting of manufacturing bases from high-cost to low-cost locations, gradual removal of trade barriers, technological and telecommunication developments, etc. These developments have, on one hand, led to increasing sophistication in tax… – Continue reading

Congressman Introduces Legislation to Stop Tax Inversions

Rep. Mark Pocan, D-Wis., has introduced three pieces of legislation to close tax breaks that enable U.S. multinational corporations to use so-called “inversions” in which they merge with a foreign company and move their tax domicile abroad to a low-tax country to reduce corporate taxes. Corporate inversions are used by… – Continue reading

Doubts mount about Valeant Pharmaceuticals’ tax structures

MONTREAL – The disclosure by Valeant Pharmaceuticals International Inc. that it is under audit by the U.S. Internal Revenue Service is raising further doubts among tax specialists about the future of the Quebec-based drug company’s tax strategies. Valeant estimates it has achieved US$2.5-billion in tax and other “corporate structure” savings… – Continue reading