Category: Base Erosion & Profit Shifting

Offshore taxes may slow audits for some U.S. multinationals: IRS

WASHINGTON (Reuters) – Multinational businesses that often fight with the U.S. Internal Revenue Service over their worldwide taxes may be dropped from an IRS program meant to smooth corporate audits, a senior IRS official said on Tuesday. Speaking at a conference, Michael Danilack, a deputy U.S. IRS commissioner, raised concerns… – Continue reading

The ATO Might Be Investigating Google And Apple Right Now

Companies have every right to minimise their own tax burdens, but shrinking your footprint only lasts so long before someone gets annoyed. For Apple Australia and Google Australia, that time might be nigh as the Australian Taxation Office (ATO) reportedly gears up to investigate the pair for tax minimisation. The ABC… – Continue reading

Developing countries ‘lose taxes to profit shifting’

STUDIES show multinationals shift profits of $365bn a year from developing to developed countries through transfer pricing mechanisms, the South African Revenue Service (SARS) said on Tuesday. Over three years South Africa has seen “hundreds of billions of rand” leaving in royalties, management and service fees and intellectual property payments,… – Continue reading

China’s efforts to curb tax evasion net extra HK$59b

The mainland’s efforts to fight tax evasion brought in 46.9 billion yuan (HK$59.2 billion) of additional taxes in 2013, 38 times more than 2008, according to the website of the State Administration of Taxation. Since 2011, China’s transfer pricing agreements with Hong Kong and Macau have saved 34.57 billion yuan… – Continue reading

Ireland’s Noonan Clarifies Corporate Tax Developments

Changes to Ireland’s residency rules, designed to eliminate mismatches between tax treaty partners, have not yet affected the residency status of any company, Finance Minister Michael Noonan has confirmed. The reforms were introduced in Noonan’s 2014 Budget and included in this year’s Finance Bill. They are intended to prevent companies… – Continue reading

Corporate Tax Avoidance: Zara fashion brand owner amasses $10bn property empire

Corporate Tax Avoidance: Inditex, the Spanish owner of Zara, this week announced its first fall in annual profits in five years as the world’s biggest fashion retailer invested in stores while foreign exchange rates moved against it. However, Amancio Ortega Gaona, founding chairman of Inditex, with a stake of 60%… – Continue reading

More multinationals head for tax haven

US companies appear to be thumbing their noses at a global crackdown on tax avoidance, with share registry group Computershare reporting an increase in multinationals re-incorporating in Ireland. In a briefing to investors on its regional outlook last week, Computershare said its Irish division had noticed ”further momentum in US… – Continue reading

Close corporate tax loopholes for large companies

Boeing won’t be paying any taxes this year [“Boeing has big tax refund coming from Uncle Sam — again,” seattletimes.com, March 1]. Instead, by deferring tax payments, it will be getting a $199 million refund. It’s not alone; many corporations are avoiding taxes altogether through loopholes. In the Senate there is… – Continue reading

Amazon, Apple and Google face clampdown over shielding profits made in Britain as Treasury targets global giants on tax avoidance

Global technology giants such as Apple, Google and Amazon could soon be charged a tax on their UK activities in an attempt to stop them sidestepping their responsibilities. Britain is working with nine other countries to draw up shared dossiers on the tax affairs of such groups, it was revealed… – Continue reading

Exporters ‘need transfer pricing clarity’

The benefits of the New Zealand Government’s desire to push export led growth, as part of its overall economic strategy, could be stymied by a lack of clarity over proposed cross-border tax changes. New research from the Grant Thornton International Business Report survey (IBR) reveals that New Zealand business leaders… – Continue reading

U.S. companies add offshore profits to avoid taxes

The largest U.S.-based companies added $206 billion to their offshore profit stockpiles last year in order to put earnings in low-tax countries, Bloomberg reported. Multinational companies accumulated $1.95 trillion outside the U.S., which was up 11.8 percent from a year earlier, according to securities filings from 307 corporations reviewed by Bloomberg. Governments… – Continue reading

OECD urges quick action on multinational tax dodges

OECD tax director Pascal Saint-Amans has played down concerns that the United States might resist plans to make multinational companies such as Apple and Starbucks pay more tax, arguing that governments must move quickly to close multibillion-dollar loopholes or risk ordinary citizens ­losing faith in their taxation systems. Mr Saint-Amans… – Continue reading

Apple to IBM hoard $206b abroad to avoid US tax

The largest US-based companies added $206 billion to their stockpiles of offshore profits last year, parking earnings in low-tax countries until Congress gives them a reason not to. The multinational companies have accumulated $1.95 trillion outside the US, up 11.8 per cent from a year earlier, according to securities filings… – Continue reading

TAX FREE | US tech giants’ offshore cash piles earn interest from government: report

LONDON — Four of the biggest U.S. technology groups collectively hold an estimated $124 billion in U.S. Treasury debt, much of it offshore, earning them tax-free interest, the UK’s Bureau of Investigative Journalism (BIJ) said on Thursday. The finding means Apple Inc, Microsoft Corp, Google Inc and Cisco Systems Inc… – Continue reading

Documents reveal Kurchenko’s alleged tax evasion schemes

The young Ukrainian ex-billionaire Serhiy Kurchenko, now widely suspected of being a front man for overthrown President Viktor Yanukovych’s family, clearly liked offshore destinations. His companies registered in offshore zones are now accused of trading in oil products using a tax evasion scheme that cost Ukraine’s government an estimated $1… – Continue reading

Apple, IBM and Microsoft Lead U.S. Tax-Avoiding Spree

Apple Inc., IBM Corp. and Microsoft Corp. have been picked out as some of the main culprits of stockpiling profits abroad in order to avoid huge tax bills, according to Bloomberg. Last year, the largest U.S. firms collectively added an extra $206 billion to their offshore profit stockpiles based in low-tax countries. Together the… – Continue reading

United Kingdom: The OECD Base Erosion And Profit Shifting Action Plan

There has been considerable publicity in recent months on the alleged tax avoidance perpetrated by multinationals that has resulted in the Organisation of Economic Cooperation and Development (OECD) publishing its action plan on base erosion and profit shifting (BEPS). The action plan, consisting of 15 proposals to counter the perceived… – Continue reading

Corporate tax avoidance ‘scheme’ hurting Canada, expert says

Country’s corporate tax rate sits at about 25 per cent As Canadians dutifully file personal income tax returns during the coming weeks, consider this: many profitable companies pay little or no tax. In an interview this week on The Sunday Edition, Dennis Howlett, executive director of Canadians for Tax Fairness,… – Continue reading

Finance ministry seeks early disposal of Vodafone transfer pricing case

NEW DELHI: The finance ministry will soon write to British telecom major Vodafone to press the company to seek an early decision from the Income-tax Appellate Tribunal (ITAT) in the Rs 8,500-crore transfer pricing case. The Union Cabinet had, on February 28, directed the finance ministry to wait for the… – Continue reading

Apple iTax: made in Ireland, designed in the US

Apple, famous for its innovative products, is equally creative in its tax structure. From 2009 to 2012, it successfully sheltered US$44 billion from being taxed anywhere in the world, including sales generated in Australia. While there are probably some sound reasons for Apple’s CEO, Tim Cook, to claim in a US congressional… – Continue reading

Brazil tries to grasp online cross-border taxation

The Brazilian government has been trying to catch up on a number of areas of the digital economy, one of them being online cross-border taxation – but not without controversy. During the Mobile World Congress (MWC) last month, the Brazilian communications minister Paulo Bernardo said Brazil is a “tax haven”… – Continue reading

Canada: Businesses Face More Onerous Transfer Pricing Documentation And Country-By-Country Tax Reporting

The OECD proposes to reform transfer pricing documentation for multinational enterprises and to impose onerous country-by-country (CbC) reporting obligations, including disclosure of taxes paid in each country in which a business operates, in a bid to enhance revenue authorities’ abilities to identify high risk transfer pricing situations and to make… – Continue reading

Hunting Lost Revenue in Offshore Tax Havens

Some states are going after multinational corporations which avoid state taxes by stashing some of their earnings in offshore tax havens, an effort aimed at recouping some of the more than $20 billion states lose to such gimmicks each year. Shifting income to subsidiaries in places like the Cayman Islands… – Continue reading

How to Get Your Profits Out of China

BEIJING – Wholly Foreign Owned Enterprises (WFOEs) are able to repatriate funds out of China in a variety of forms, for which tax implications vary according to the form of repatriation used and the Double Taxation Agreement (DTA) in place between China and the recipient country. The four most commonly… – Continue reading

Africa: Tackling Illicit Outflows

As far back as the early stages of the global financial crisis in 2007, Nick Mathiason citing the African Union (AU) reported: “More than $150 billion a year is looted from Africa through tax avoidance by giant corporations and capital flight using ‘a pinstripe infrastructure’ of Western banks, lawyers and accountants.”… – Continue reading

Aligning tax with the times

The aggressive approach of Indian tax authorities on transfer pricing and international tax matters underlines the government’s intention of taking strong action to defend its tax base. When it comes to taxation of cross-border transactions, India’s inclination to widen the source-based tax rules is clearly demonstrated by the retrospective amendments,… – Continue reading

Australia’s Tax Office Is Targeting 86 Multinationals Over Profit-Shifting

In an attempt to stop multinationals shifting profits overseas Australia’s Tax Office is launching a task force to investigate 86 large corporations’ tax activities. The tax office is looking into companies that use complex structures to move profits through tax havens as well as those that are using thin capitalisation,… – Continue reading

New Discussion Launched on Tax Treaty Abuse

PARIS – The OECD is initiating an international discussion into measures to prevent the occurrence of profits shifting and tax evasion through the abuse and misuse of international tax treaties. Late last week the Organization for Economic Cooperation and Development released a public discussion draft “Preventing the Granting Of Treaty Benefits In… – Continue reading

Tax Evasion Threatens Africa’s Socio- Economic Transformation: UN Expert

The quest of African countries to carry out economic stability and transformation is threatened by illicit financial outflows through tax evasion and avoidance, a UN expert observed here on Thursday. He said the draining of tax revenues and scarce foreign exchange resources stifled growth and socio-economic development and weakened governance…. – Continue reading

Australia’s new transfer pricing laws overlap the thin cap rules: new challenges for taxpayers

The overlap of Australia’s new transfer pricing laws with the thin capitalization rules is causing challenges and likely duplication of analysis for taxpayers – particularly for the arm’s length amount-of-debt test. Australia legislated comprehensive new transfer pricing laws in 2012[i] and 2013.[ii]  These laws were passed in two installments: Subdivision 815-A, dealing with… – Continue reading

G20 gives Google, Microsoft, Apple et al tax deadline

G20 finance ministers speak loudly, mention big stick The world’s top 20 finance ministers have signalled once again that they’re sick of their taxes disappearing offshore and have signalled a strong intention to get their cash back. The ministers in question are all members of the Group of Twenty (G20)… – Continue reading

Ortega’s Zara Fashions Tax Avoidance by Shifting Profits to Alps

Zara’s celebrity chic helps make its Spanish parent company, Inditex SA, the world’s biggest fashion retailer. Singer Taylor Swift, reality-television personality Kim Kardashian and Kate Middleton, Prince William’s wife, have all been spotted wearing the stylish, low-cost brand. Another reason for Inditex’s industry-best profit margins of almost 15 percent: the… – Continue reading

Multinationals unfazed by G20 tax crackdown

The G20 finance ministers have once again agreed to cooperate to counter aggressive cross-border tax avoidance by multinationals. Many US firms are using tax avoidance schemes for their non-US earnings while they shamelessly claim they are paying appropriate taxes in the source countries in which they operate. The OECD responded to earlier… – Continue reading

G20 to tackle transfer pricing with new tax exchange scheme

The days of multinational companies being able to use the Double Irish Dutch Sandwich to avoid taxation may soon be coming to an end, with the G20 group of nations looking to create a reporting standard to allow for automatic exchange of tax information. In the official communique coming at the end… – Continue reading

Tony Abbott must achieve ‘concrete results’ or risk losing G20 influence, says Wayne Swan

Former treasurer Wayne Swan has warned that Australia risks losing global influence unless this year’s G20 summit achieves concrete results on issues such as multinational tax avoidance. Ahead of this weekend’s meeting of G20 finance ministers and central bankers in Sydney, Mr Swan also urged the Abbott government not to… – Continue reading

Murdoch’s $880m tax win raises issues of global corporations’ tax liability

An $880 million payout to Rupert Murdoch’s News Corporation has reignited the debate over whether global companies pay their fair share of tax in Australia. News was paid the money after winning a long-running legal battle with the Tax Office relating to a 1989 restructure of the media empire involving… – Continue reading

A Solution for Corporate Tax Avoidance

Some three hundred years ago Sir Walter Scott asked, “Breathes there a man with soul so dead who never to himself hath said, This is my own, my native land.” Well, in America corporations are legally deemed  “persons,” so the answer to Scott’s question is “Yes,” at least when it… – Continue reading