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. Brussels has challenged Luxembourg over a tax ruling offering potentially illicit support to a Fiat subsidiary, opening a… – Continue reading
Almost a third of Australia’s largest companies are paying less than 10¢ in the dollar in corporate tax, a report that exposes a gaping hole in government revenues over the past decade shows. As Australia prepares to host world leaders at the G20 summit in Brisbane in November, where a… – Continue reading
Prada shares have also lost 30% of their value this year because of weak investor sentiment Continue reading the main story Related Stories Prada profit hit by fall in sales Prada shares fall on luxury warning The fashion business Prada’s two chief executives are being investigated by Italian authorities for… – Continue reading
The Obama administration’s new rules intended to stem the tide of inversions, in which U.S. companies reincorporate abroad to dodge taxes at home, won’t be completely effective because they don’t address the high corporate tax rate in the U.S. that compels such behavior, say tax experts and analysts. The rules announced… – Continue reading
Three years ago, Russia adopted new transfer pricing legislation. The new rules became effective on Jan. 1, 2012. They are in line with international standards (OECD Guidelines on Transfer Pricing), but their concept was, and still is, quite new for the Russian tax authorities. Thus the rules provide for a transition period until 2017: For the years 2012… – Continue reading
In recent years, Russian tax legislation has adopted many modern international tax concepts and practices. Most notably, transfer pricing rules, consolidated groups of taxpayers, easy electronic communications between taxpayers and tax authorities have all become part of standard working practice. However, there is always room for improvement. The current global economic and political situation dictates that new initiatives… – Continue reading
The Russian Ministry of Finance has published an updated version of the draft controlled foreign company rules (hereinafter – “CFC”) on the 2nd of September (hereinafter – ‘the new Draft’). The previous drafts were covered in detail in our press releases of 24 March and 5 June. The new Draft… – Continue reading
Medical device giant Medtronic Inc. leads all corporate inverters in the amount of offshore cash waiting to be tapped if their tax inversion deals are consummated. Medtronic is buying Covidien and moving to Dublin, and it has $13 billion of cash outside the United States, according to a report from the Financial Times,… – Continue reading
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
Audits may now be based on risk of tax evasion The government has dropped the Rs 15-crore threshold for referring transactions between a multinational company and its Indian subsidiary for compulsory scrutiny by the tax department. It might, instead, move towards a risk-based approach to identify international transactions prone to… – Continue reading
MINNEAPOLIS (WCCO) — A tough new ad from Democratic Sen. Al Franken accuses his Republican opponent’s business of avoiding taxes by headquartering overseas. But Republican Mike McFadden calls the ad “ridiculous” and “full of lies.” The ad marks a new Franken campaign strategy: directly attack McFadden for his business dealings…. – Continue reading
On August 26, Burger King announced that it entered into an agreement to acquire Tim Hortons, Inc., the Canadian coffee-and-doughnut chain, in a transaction that will be structured as an “inversion” (i.e., Burger King will become a subsidiary of a Canadian parent corporation). The deal is expected to close in 2014… – Continue reading
Microsoft is avoiding paying billions in taxes—and it’s not the only one. a subsidiary of a foreign company, so the firm has not technically engaged in the so-called “inversion” scheme that President Obama and Democrats have lately been criticizing. However, according to a 2012 U.S. Senate investigation, the company has… – Continue reading
In its ongoing efforts to control tax evasion, China’s State Administration of Taxation (SAT) has recently published an instruction (Tax Office General Fa [2014] No 146), calling on national and local tax bureaus to investigate transfer pricing practices of Chinese enterprises. Under scrutiny by the SAT are all transactions involving… – Continue reading
I n July, the American pharmaceutical giant AbbVie, maker of the world’s top-selling drug – the arthritis treatment Humira – reached a blockbuster deal to acquire European rival Shire, best known for the attention-deficit medication Adderall. The merger was cheered by Wall Street, not for what the deal will do… – Continue reading
According to Canada’s finance minister, the country’s corporate tax rate has dropped from 20% to 15% since the Conservative government took office in 2006. The U.S. tax rate is 35%, making the tax advantage for Burger King’s move to Canada a central part of the deal. Cutting corporate tax payments… – Continue reading
CFOs of multinationals need to prepare by assessing how much their companies engage in profit shifting to cut their taxes. Do you have responsibility, whether direct or dotted line, for the tax function in your company? Does your company have, or plan to have, operations outside the United States? If… – Continue reading
The Delhi High Court upholds the non-taxability of gains from sale of shares of overseas entities by the Copal Group to the Moody’s Group. Interpretation of the indirect transfer tax provisions in a restrictive manner. 50% threshold for substantiality based on guidance by OECD/ UN material and Shome Committee Report… – Continue reading
A new section 1305A of the UK Corporation Tax Act 2009 (CTA 2009) has been introduced by the UK Finance Act 2014 that applies to payments made from March 19, 2014 under avoidance schemes involving the transfer of corporate profits within a group. This new measure applies if: two companies… – Continue reading
The Canada Revenue Agency is speeding up the frequency of reassessments of Cameco’s tax returns in what may be an attempt to pressure Cameco to settle out of court. Cameco’s cash is being tied up as they are required to remit 50% of each disputed bill. Cameco could ultimately be… – Continue reading
June 30 — Poland’s Sejm, the lower house of parliament, June 26 approved proposals to introduce guidelines to distinguish a foreign-controlled company for tax purposes, and approved Poland’s agreement for the avoidance of double taxation with the United Arab Emirates, as well as its tax information exchange agreements with Bermuda,… – Continue reading
Treasurer Joe Hockey has said that he will improve the structural integrity of Australia’s tax system to address international tax avoidance by multinational enterprises. In particular, the tax law will be tightened to prevent a multinational from shifting profits from Australia by claiming excess interest expense deductions. This tax avoidance technique is… – Continue reading
The authorities are looking to entice Russian-owned offshore firms to repatriate capital. A new law will impose penalties on such companies for tax evasion, but offers 2-year amnesty for those firms which decide to relocate to Russia. The Finance Ministry has decided to grant a 2-year amnesty for offshore companies… – Continue reading
The Finance Ministry is pushing ahead with its program to entice Russian-owned offshore firms to repatriate capital. A new law will impose penalties on such companies for tax evasion, but offers the carrot of a 2-year amnesty for those firms which decide to relocate to Russia. The Finance Ministry has… – Continue reading
The Thai Bankers’ Association (TBA) will soon submit five proposals to the National Council for Peace and Order (NCPO) for its financial sector development plan, says TBA chairman Boontuck Wungcharoen. The proposals include implementation of the Foreign Account Tax Compliance Act (Fatca), an upgrade of Thailand to a financial hub… – Continue reading
As they pile up in cash accounts, undistributed foreign profits are inflating U.S. multinationals’ valuations and making companies appear less leveraged. Undistributed foreign earnings (UFE) — foreign profits earned by overseas subsidiaries that have not, at least not yet, been remitted back to the U.S. parent — are a good… – Continue reading
Vodafone is increasingly using the tax haven of Luxembourg as a base to manage its global spending, in a move that will reignite the controversy about its tax practices. The company’s annual report, which showed the mobile giant is managing spending of €10.2bn (£8.6bn) through Luxembourg, also revealed Vodafone paid… – Continue reading
U.S. corporations have reported to the Internal Revenue Service that 54 percent of their offshore profits are earned in 12 tax haven countries that, combined, only account for 4 percent of economic output among all countries where U.S. corporations do business. A new report by the advocacy group, Citizens for… – Continue reading
It is a figure which Citizens for Tax Justice (CTJ), the US group which authored the report, says highlights Ireland’s popular use as a tax haven among US companies. Matt Gardner, executive director of the Institute on Taxation and Policy in Washington DC, tells IBTimes UK: “It’s a clear indicator… – Continue reading
If any U.S. company seems ripe for moving to an island tax haven, it’s Chiquita. Based in Charlotte, the company’s sale of bananas, grown largely in Central America, accounts for two-thirds of its profits. But Chiquita isn’t bound for the tropics. It’s headed to Ireland, where the climate may be… – Continue reading
Russian business is certainly facing a challenging time. The Russian Government has sights set on the offshore business of Russian entities and individuals, and when they get their way it may have wide-reaching implications not only for Russian business, but for anyone doing business with Russian partners across the globe…. – Continue reading
Caterpillar, industrial and construction equipment manufacturing Goliath, has been avoiding or deferring paying U.S. taxes for at least 13 years to the tune of approximately $2.4 billion, according to a report from the Homeland Security & Government Affairs Permanent Subcommittee on Investigations. “Tax evasion schemes rob the system of billions of… – Continue reading
The UK’s 100 largest public companies have nearly 30,000 subsidiaries, according to new research by Christian Aid Christian Aid has accused many of the largest companies that claim to be driving corporate responsibility of operating behind a veil of secrecy by creating thousands of subsidiaries in tax havens. The UK’s… – Continue reading
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
