AMSTERDAM: Google shifted nearly €10bn in royalties to the tax haven of Bermuda via the Netherlands in 2013. That is almost €1bn up on 2012, the paper says. It bases its claims on an analysis of the annual reports of Dutch-registered Google Netherlands Holdings BV. Over €9bn came from Google… – Continue reading
Confidential documents obtained from the Tax Office under the Freedom of Information Act show Australia’s corporate tax base is in crisis because of the explosion in tax haven dealings by multinational companies. The alarming data in these internal documents is at odds with the public position of the Australian Tax… – Continue reading
The Australian Taxation Office has identified at least 36 Australian companies with related entities in Switzerland that may have engaged in tax evasion costing billions in possible tax revenue. According to internal communications between the ATO and the Department of Treasury the bulk of companies under investigation are based in… – Continue reading
On February 6, 2015, the Organisation for Economic Co-operation and Development (OECD) announced that it has reached agreement with the Group of Twenty (G-20) Finance Ministers on three key elements of its base erosion and profit shifting project. The three elements, which the OECD said will enable implementation of the… – Continue reading
The Department of Finance recently published the attached public consultation on the ‘Knowledge Development Box’ (“KDB”), inviting submissions before 8 April 2015. This regime was widely publicised in connection with the 2015 Budget and is intended to play a key role in Ireland’s corporate tax regime, as outlined in the… – Continue reading
The OECD will present the latest developments in the OECD/G20 project to combat base erosion and profit shifting (BEPS) by multinational enterprises during a G20 Finance Ministers meeting on early next week (9th/10th February) in Istanbul. OECD and G20 countries have agreed three key elements that will enable implementation of… – Continue reading
G20 finance ministers will hear about the OECD’s three-pronged approach to implementation of the BEPS Action Plan at their meeting in Istanbul on Monday and Tuesday of next week (February 9 and 10). The OECD, which is leading the work, outlined today what has been agreed so far with the… – Continue reading
HONG KONG — China’s tax officials plan to step up efforts to collect taxes from multinational corporations in the latest of a series of moves in the last year, mostly against Western companies. The activities have included police raids on the headquarters of companies’ China operations and heavy fines under… – Continue reading
THE European Union (EU) will not pursue a probe of national programmes that create tax breaks for research and development, giving a boost to drug and technology companies that generate revenue from patents. The EU’s hands were tied by a 2008 decision to approve a “patent box” tax break in… – Continue reading
The United Nations (UN) has plumped for greater cooperation among countries to put in place a set of safeguards and rules for tax reforms the world over in the bleak backdrop of extant rules and conditions, “particularly regarding illicit flows, as well as tax avoidance” often limiting what governments can… – Continue reading
Ireland has been ranked among the least complex business destinations for multinationals, and its appeal has improved as a result of recent international tax policy changes, according to a new study. The study from the TMF Group ranked 81 jurisdictions across Europe, the Middle East, Africa, Asia-Pacific, and the Americas… – Continue reading
In November 2012, a startled TV audience watched coverage of the House of Commons Select Committee questioning Google’s chief executive about why his business, with ostensibly billions of pounds in sales generated in the UK, accounted for UK corporation tax in an amount equivalent to the price of a single… – Continue reading
In November 2012, a startled TV audience watched coverage of the House of Commons Select Committee questioning Google’s chief executive about why his business, with ostensibly billions of pounds in sales generated in the UK, accounted for UK corporation tax in an amount equivalent to the price of a single… – Continue reading
Introduction The taxpayer, Seven Network Limited, has won a recent decision (22 December 2014) in the Australian Federal Court, Seven Network Limited v Federal Commissioner of Taxation (2014) FCA1411, which is significant to all broadcasters, particularly involving the delivery of live sport and other entertainment. Briefly, the key issue raised… – Continue reading
ARLINGTON, Va., Jan. 28, 2015 /PRNewswire-USNewswire/ — Bloomberg BNA today announced that its Global Transfer Pricing Conference: Paris, held in conjunction with Baker & McKenzie and in association with the Tax Management Education Institute, will occur on March 30-31 immediately after the Organisation for Economic Co-operation and Development (OECD) Global… – Continue reading
On 11 November 2014, the UK and German governments issued a joint statement on proposals for new rules for preferential intellectual property (IP) regimes within the G20/OECD base erosion and profit shifting (BEPS) project. Germany currently does not have a special regime for Patent Boxes, but suffers from structures that… – Continue reading
The tech industry is ramping up its lobbying efforts on tax reform, seeking to make sure it doesn’t end up the loser if Washington can finally find a consensus on rewriting U.S. tax laws. The Tax Innovation Equality Coalition, or TIE, a group that counts both technology and pharmaceutical titans… – Continue reading
American internet giant Google shifted nearly €10bn in royalties to the tax haven of Bermuda via the Netherlands in 2013, the Telegraaf says on Saturday. That is almost €1bn up on 2012, the paper says. It bases its claims on an analysis of the annual reports of Dutch-registered Google Netherlands… – Continue reading
The tech industry is ramping up its lobbying efforts on tax reform, seeking to make sure it doesn’t end up the loser if Washington can finally find a consensus on rewriting U.S. tax laws. The Tax Innovation Equality Coalition, or TIE, a group that counts both technology and pharmaceutical titans… – Continue reading
US sanctions on companies in third countries, ease of doing business and intellectual property rights were among a dozen issues that figured at the India-US CEO Forum where US President Barack Obama and Prime Minister Narendra Modi were also present. US sanctions on companies in third countries, ease of doing… – Continue reading
Over the past few years, the European Union has targeted multinational corporations using tax planning strategies to reduce corporate tax burdens. Recently, the EU has launched an investigation into tax deals between Amazon (AMZN) and the country of Luxembourg. With an array of subsidiaries within European countries, Amazon’s European headquarters… – Continue reading
Midlands businesses can still benefit from the Patent Box, according to international accountancy firm Mazars. It follows plans to amend it – resulting in a narrower focus on UK R&D. That is the verdict from Birmingham professionals Peter Jelfs, senior tax manager at international accountancy firm Mazars, and Nicholas Braddon,… – Continue reading
High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. Luxembourg’s unorthodox tax deal with Amazon was laid bare by European Commission investigators on Friday, who believe it artificially lowered and “capped” the online retailer’s tax bill,… – Continue reading
The Department of Finance is understood to be “open-minded” over what rate should be applied to its proposed ‘knowledge box’ tax regime for patents and intellectual property assets developed here. The department yesterday formally launched its planned consultation process for the programme, which was announced in October’s Budget. There has… – Continue reading
The Government has unveiled a three-month public consultation on the proposed Knowledge Development Box, with submissions invited from businesses and the wider public. The proposed scheme, also known as a patent box, was announced in the Budget and is due to come into force next year. It will provide for… – Continue reading
Ireland: The Department of Finance will publish a consultation document Wednesday on the proposed ‘knowledge box’ patent tax regime that will be enacted in replacement of the Double Dutch tax avoidance scheme. Late last year Department officials hinted that a 5% rate was under discussion to match the Dutch rate…. – Continue reading
On October 14 2014, Ireland’s Minister for Finance (the Minister) announced changes to Ireland’s corporate residence rules. Following much speculation, the Minister confirmed that Ireland would change its rules to restrict the ability of Irish incorporated companies to be treated as non-Irish resident. Under existing Irish law, an Irish incorporated… – Continue reading
Official’s notes include minutes from two meetings held on September 29th, 2008, in Government Buildings Bank guarantee notes The Department of Finance is considering whether to give the Oireachtas banking inquiry two notes from the night of the bank guarantee written by a Department official. They include minutes from two… – Continue reading
CDE Op-Ed CommentaryGiven the recent problems American trading companies are having in establishing bank accounts in Hong Kong, viable alternatives need to be found. These issues, which are directly related to the American IRS carrying out extensive investigations in Hong Kong concerning breaches of the new FATCA regulations, have made… – Continue reading
Already on the radar of governments and regulatory bodies around the world, recent developments with respect to the Organization for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) Action Plan are raising further the profile of oil and gas companies globally with both tax authorities and the… – Continue reading
The landmark transfer pricing case involving GlaxoSmithKline has settled on the eve of the second Tax Court of Canada trial in the matter, scheduled to commence on January 12, 2015. “Counsel for Glaxo confirmed the settlement but the details remain confidential,” writes William Innes of Rueter Scargall Bennett in Bill… – Continue reading
New Delhi, Jan. 11: US President Barack Obama’s visit during Republic Day is expected to set the tone for closer engagements with India as the two nations look to boost bilateral trade to a targeted $500 billion. Obama is the first US President to not only attend the 26th January… – Continue reading
Regulators have updated guidelines regarding a little-known area of tax accounting that has become a political hot potato in recent years. Transfer pricing, as the process is called, refers to the price paid by one unit of a company to another for goods, services, intellectual property or financial transactions such… – Continue reading
Countries are competing to lower their tax rates to please the corporate giants, but the result is a massive collective loss of revenue. Only international coordination can wipe out the practice and defeat the negative influence of the Big Four accounting firms. Tax havens have long existed in the popular… – Continue reading
As a means of encouraging the development of intellectual property (IP) in Italy, rather than elsewhere, a “patent box” preferential tax regime has been introduced with effect from January 1, 2015, at the same time as a restructuring of the country’s research and development (R&D) tax credit system. Following the… – Continue reading
As the Organisation for Economic Co-operation and Development (OECD) passes the halfway point in its joint project with the G20 to address base erosion and profit shifting (BEPS) concerns, it is worth pausing to examine what the consequences of some of the proposed changes may be. Much of the focus… – Continue reading
In recent court filings made in various federal district courts in Washington and California, the Internal Revenue Service is seeking to enforce testimonial summonses issued to current or former Microsoft employees, including former CEO Steven A. Ballmer. The summons had been issued earlier this fall. Microsoft’s outside tax counsel responded… – Continue reading
The Luxembourg Government is to provide the European Commission with a list of the tax rulings issued by its tax authorities, along with a list of the beneficiaries of its concessionary tax regime for intellectual property (IP) income. Luxembourg Prime Minister Xavier Bettel announced that the decision had been made… – Continue reading
Transfer pricing has been an area of high importance for years. We are seeing that multinational companies operating in Germany are being increasingly examined by tax auditors. The level of transfer pricing expertise of the tax auditors is also increasing. Therefore, the transfer pricing environment in Germany is getting more… – Continue reading
The European Commission has announced that its ongoing inquiry into advance tax rulings will be expanded to cover all European Union member states. The Commission said on December 17 that it will ask member states to confirm whether they offer tax rulings. If they do, they will be requested to… – Continue reading
(Reuters) – Luxembourg acceded on Thursday to the demand of the European Commission to release data to further EU antitrust regulators’ investigation into whether it allowed multinationals to pay excessively low taxes. The European Commission launched investigations this year into whether U.S. retailer Amazon (AMZN.O) and a unit of Italian… – Continue reading
There has been a recent surge in anti-tax inversion legislation discouraging companies attempting to shift corporate subsidiaries or headquarters to low-tax or tax-free countries. The issue was subjected to a great deal of publicity in April 2014 during the failed hostile takeover by Pfizer (NYSE:PFE) for AstraZeneca (NYSE:AZN) when Pfizer… – Continue reading
Tracking tax evasion has been a global issue for the Group of 20 nations and the Organization for Economic Cooperation and Development, which is developing new standards to avoid base erosion and profit shifting. The EU also has tackled the issue from a variety of angles, such as approving a… – Continue reading
High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. Brussels has widened a probe into corporate tax rulings to include all 28 member states amid heightened scrutiny of sweetheart tax deals granted to businesses by national… – Continue reading
An investigation into tax rulings provided by certain EU member states is to be widened to cover all member states, according to a press release from the European Commission.17 Dec 2014 Tax Disputes and Investigations EU & Competition Tax Public procurement and state aid Corporate tax International tax UK Europe… – Continue reading
(CNS Business): The British government has published draft legislation for a new Diverted Profits Tax (DPT), dubbed the “Google tax”, by which it intends to sidestep Britain’s existing tax treaties with low-tax jurisdictions by levying a charge that would fall outside the corporate tax system. The government hopes to raise… – Continue reading
Think tank targets key aspects of Republic’s role in multinationals’ tax affairs Key features of Ireland’s role in the tax affairs of major technology companies such as Google and Microsoft are being targeted by the OECD’s base-erosion and profit-shifting (Beps) project, it has emerged. Ideas being worked on by the… – Continue reading
NEW DELHI: Bilateral investment treaties that the government will enter into from now on will have a provision preventing foreign investors to drag India to arbitration on any issues that have been settled by a judicial authority. Wiser from being dragged to arbitration in numerous cases, such as the Vodafone… – Continue reading
Something strange happened in 2014 — Americans became very interested in corporate tax policy. It started in the spring, when U.S.-based pharmaceutical giant Pfizer, which produces blockbuster drugs like Lipitor and Viagra, floated a possible merger with its British-based rival AstraZeneca. Normally a merger of that size would make a… – Continue reading
The surge in U.S. companies avoiding taxes by taking a foreign address has been condemned by President Barack Obama and stirred a policy debate in Congress. What’s often overlooked is that these “inversions” are typically a final step in a hopscotch of multinational tax dodging. Many companies invert after years… – Continue reading
