Joe Oliver says Canada brings labour market, tax reforms to international forum Finance ministers from the G20 nations say they will press ahead on tax reform to prevent profit-shifting by companies and new governance measures for banks to prevent future bank failures. At the conclusion of a morning meeting in Washington, Finance Minister… – Continue reading
Wout Moelands, Hamir Khatau and Richard Collier, PwC UK Until the work of the OECD is completed, we can expect more frequent and assertive PE challenges, including the international origination arrangements conducted by travelling bankers or representative offices of banks. l. Introduction The PE rules provide tax authorities with a… – Continue reading
March 31 –A proposed country-by-country reporting template will not require multinational companies to break down financial details by legal entity, an official with the Organization for Economic Cooperation and Development announced March 31. Joseph Andrus, head of the OECD’s transfer pricing unit, said that Working Party No. 6 has tentatively… – Continue reading
India is set to scrap the R15-crore threshold for referring every international transaction between an MNC’s arms for compulsory transfer pricing audit, and about to embrace a more focused approach to zero in on cross-border transactions with potential for tax evasion. The proposed risk-based selection of transactions between MNC arms… – Continue reading
U.S. states are trying to capture corporate income taxes lost to offshore havens, wary of companies exploiting rules that let them channel cash abroad and weary of congressional inaction. Oregon enacted a bill for the 2014 tax year identifying 39 countries and territories as corporate shelters a decade after Montana… – Continue reading
A joint effort by India and the US to amicably decide on their respective shares of taxes from IT and ITeS companies operating in both countries is threatening to unravel, owing to a big, seemingly unresolvable gap between the transfer pricing (TP) margins individually determined by them. While New Delhi… – Continue reading
The OECD has been prolific in its publication of discussion documents since the start of the year. OECD discussion draft documents have been released in respect of: Action 13: Transfer pricing documentation and country by country reporting – 30 January 2014 The BEPS Action Plan issued on 19 July 2013… – Continue reading
IRELAND’s effective rate of corporation tax averaged between 10.7pc and 10.9pc over the last decade, a report by the Department of Finance states. It claims that the tax paid by companies is close to the 12.5pc headline rate, amid controversy over the amount paid by multinationals here. The Department commissioned… – Continue reading
PARIS — Netflix is set to follow iTunes and Google’s footsteps: The service is expected to launch in Gaul in the fall but will be headquartered Luxembourg in order to avoid the heavy French regulations. French newspaper Les Echos reported the move will bring Netflix’s French outpost together with its other European headquarters —… – Continue reading
On January 30, 2014, the Organization for Economic Cooperation and Development (OECD) released a discussion draft for comment on Action 13; the transfer pricing documentation prong of the Base Erosion and Profit Shifting (BEPS) project, which includes country-by-country reporting. As the Committee of Fiscal Affairs believes it is essential to… – Continue reading
Aggressive tax strategies pioneered by Macquarie Group are under scrutiny both internationally and in Australia, putting at risk techniques the company has used to claim more than $1.3 billion in deductions. The Organisation for Economic Cooperation and Development is targeting ”foreign tax credit generators” as part of its battle against… – Continue reading
The department had slapped a tax demand of Rs 2,080 crore on the company last year while re-opening the assessment for AY 2006-07 and 2007-08. As Finnish phone-maker Nokia strives to meet the April 30 deadline for sealing the $7.2 billion deal with Microsoft, its tussle with the Indian tax… – Continue reading
The revised figure of more than £1.1bn now judged to be “at risk” by HMRC is an increase of 12% on 2012 and 65% on 2011, according to figures calculated by law firm Pinsent Masons. A crackdown on intra-group payments was announced in the chancellor’s Budget earlier this month as… – Continue reading
CFOs of multinationals face growing confusion because of mixed message on new tax rules around the world that threaten investment and the global recovery, a new study revealed on Wednesday. A total of 74 percent of finance chiefs polled in the study by Taxand, a global tax adviser, said political… – Continue reading
Canada is clamping down on off-shore tax shelters used by private-equity funds, in a move that may curb investment in the oil and gas industry by KKR & Co. and Blackstone Group LP. (BX) The government has given private-equity firms and other interested parties until April 11 to respond to proposals tucked… – Continue reading
Macquarie Group successfully lobbied the Abbott government to water down and delay moves to tighten laws over which the bank is fighting a tax battle worth hundreds of millions of dollars. Fairfax Media has learnt that Macquarie was among industry players who attended a November 6 meeting with then-assistant treasurer… – Continue reading
Corporate Tax Reform: The Organisation for Economic Co-operation and Development (OECD) held a briefing and webcast at its Paris headquarters Wednesday on its Base Erosion and Profit Shifting (BEPS) project and Pascal Saint-Amans, the director of the OECD’s tax centre confirmed that “Double Irish Dutch” sandwich tax schemes, which involve… – Continue reading
Adds £118m to ‘tax under consideration’ from intra-group transfers • HMRC proposes further crackdown on intra-group transfers in Budget HM Revenue & Customs has increased the amount of tax it estimates has been underpaid by the UK’s largest businesses through transfer pricing arrangements by £118 million to more than £1.1 billion, an… – Continue reading
Caterpillar avoided $2.4 billion in federal taxes between 2000 and 2012 by shifting $8 billion in profits from international parts sales to a tax haven in Switzerland, said Chairman Carl Levin, (D-MI), of the Senate Permanent Subcommittee on Investigations on Monday. Joining Microsoft (MSFT), Hewlett Packard (HPQ) and Apple (AAPL),… – Continue reading
Tax avoidance is a huge economic issue. Although it’s heavily frowned upon by governments, it’s technically a legal practice, as long as you know how to play the tax game right. The Coalition promised to crack down on tax avoidance, but it seems to have decided to focus on the… – Continue reading
A call to tax technology companies such as Apple and Google in the countries where they have substantial activities has re-ignited concerns companies may be taxed twice and stop business altogether. The Organisation for Economic Co-operation and Development, which is working on a global plan to prevent companies from avoiding paying… – Continue reading
Québec Solidaire on Saturday asked Pierre Karl Péladeau, the Parti Québécois candidate for Saint-Jérôme, to confirm or deny the registration of more than 60 Quebecor affiliates in Delaware, a state considered by many to be a popular tax haven. Amir Khadir, Québec Solidaire’s candidate in the Montreal riding of Mercier, described Delaware as a known tax haven for… – Continue reading
ITS SEARCH ENGINE may boast almighty powers to divine our every move, but Google has come under attack from an order of Catholic priests over its tax arrangements. The Missionary Oblates of Mary Immaculate, established in France two centuries ago, has called on Google to hand more of its profits… – Continue reading
NEW DELHI: Seeking to reduce litigations and promote foreign investments, the Income Tax department has signed Advance Pricing Agreements with 5 multinational firms and plans to enter into more such pacts. “We have signed 5 APAs so far. We will be signing more in the coming days. Foreign companies are eager to… – Continue reading
The Anti-Tax Evasion Act and the Finance Act 2014 have introduced an annual transfer pricing documentation filing obligation and new disclosure requirements for large companies. Since 2010, French companies that have an annual turnover or gross asset value exceeding €400 million, are related to a French or foreign entity exceeding one of… – Continue reading
WASHINGTON (Reuters) – Caterpillar Inc’s offshore tax strategies will come under scrutiny on Tuesday at a U.S. Senate hearing expected to examine dealings by the world’s largest mining and construction equipment maker in Switzerland, Bermuda and Luxembourg. With many multinationals being criticized for tax avoidance, veteran tax sleuth Senator Carl Levin… – Continue reading
The U.S. and Indian competent authorities are famously at loggerheads over the principles to be applied in transfer-pricing double-tax cases. Some of the important issues involved are: the appropriate markup on costs for services; when and how to reward location savings; and whether marketing intangibles exist. Virtually all of these… – Continue reading
NEW DELHI, MARCH 25: In what could be a source of comfort to multinational companies, the Income Tax Department is set to ink the first set of advance pricing agreements (APAs) with MNCs on March 31. Seven-eight agreements may be signed by the month end, informed sources said. An advance… – Continue reading
A looming global crackdown on aggressive tax avoidance is set to stop internet companies slashing bills by routing profits to havens. Plans to “restore taxation” in the countries where digital companies make their sales and base their headquarters were set out on Monday in the first international response to the… – Continue reading
OECD plan to make practice of shifting locations ineffective New rules aimed at preventing the type of aggressive tax avoidance schemes run by some of the largest multinational employers here will begin to be introduced in September, according to a draft report seen by The Irish Times . Structures that artificially shift… – Continue reading
Caterpillar (CAT:US) Inc. began defending its international tax maneuvers as a U.S. Senate investigative panel set an April 1 hearing to examine the company’s “offshore tax strategy.” Representatives from Caterpillar and PricewaterhouseCoopers LLP will testify, according to the hearing notice posted today by the Senate’s Permanent Subcommittee on Investigations. The committee, led… – Continue reading
European Union antitrust regulators ordered Luxembourg on Monday to hand over information on its corporate tax practices as part of their investigation into tax loopholes which have allowed companies such as Starbucks and Apple to cut their tax bills. The move by the European Commission came after Luxembourg failed to… – Continue reading
THE challenges developing countries face from tax avoidance and tax evasion are not new, yet developed countries have suddenly woken up to these challenges, mainly due to the global financial crisis. They call it base erosion and profit shifting, or Beps. The Organisation for Economic Co-operation and Development has over… – Continue reading
Given all the publicity about tax avoidance by multinationals over the last year or more, the clamour for action to be taken, and the government’s commitment to do so, Mr Osborne might have been expected to make at least some reference to this subject in his Budget speech. In fact,… – Continue reading
U.S. corporations added at least $206 billion to their stockpiles of offshore profits last year, parking earnings in low-tax countries until Congress gives them a reason not to. They have accumulated $1.95 trillion outside the U.S., up 11.8 percent from a year earlier, according to securities filings from 307 corporations…. – Continue reading
DESPITE George Osborne’s platitudes to last month’s G20 meeting in Australia – “It is not fair if big companies avoid their taxes by shifting their profits around artificially” – the Eye has discovered that the government has signed its most significant PFI deal to date (a new £190m children’s hospital… – Continue reading
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
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
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
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
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: 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
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
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
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
Not a single company has contacted the tax authorities to say they have been affected by changes announced in the budget as part of Finance Minister Michael Noonan’s clampdown on international tax avoidance. In October’s budget, Mr Noonan included a measure that required any company incorporated in Ireland to be… – Continue reading
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
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
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 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
