Irish lawmakers on Thursday debated new legislation that will close one tax incentive but expand another amid controversy over international corporate tax avoidance following an investigation into deals made by multinationals in Luxembourg. As part of the Finance Bill, Dublin would end the contested “Double Irish” system but a separate… – Continue reading
The hollowing out of tax collected for public purposes by rich and poor nations is not confined to technology and mining companies, according to a major leak of secret tax agreements covering more than 340 companies around the world. The documents, published by the International Consortium of Investigative Journalists, include… – Continue reading
As the Irish government moves to close one door to corporate tax avoidance, it is opening another. Tucked into legislation to eliminate a much criticized tax structure known as the “Double Irish” is a separate provision that would allow companies to pay no corporate tax on profits earned from patents,… – Continue reading
An overhaul of the Grand Duchy’s corporate tax law and administration is required Occupying a damp 1,000 square miles where the French, German and Belgian borders meet, the Grand Duchy of Luxembourg is a far cry from the palm-fringed tropical island tax haven of popular imagination. In fact the country… – Continue reading
The end of the notorious corporate tax loophole known as the ‘Double Irish’ will not deter U.S. technology giants such as Google and Apple from further investment in the country, Ireland’s Prime Minister, Enda Kenny, told CNBC,” Jenny Cosgrave and Seema Mody report for CNBC. “The Taoiseach said the end… – Continue reading
Foreign profits sit on sidelines as companies seek tax reform. WASHINGTON — They are all companies that call Minnesota home: Medtronic, 3M, St. Jude Medical, General Mills and Ecolab. But they also all hold 90 percent or more of their cash outside the United States. Amid a growing national political… – Continue reading
Bruton says new business can be won after end of ‘Double Irish’ with fresh tax proposals More than 1,000 new jobs could be created based on commitments received from US multinationals on a Government trade mission, the Minister for Enterprise, Jobs and Innovation Richard Bruton said. Speaking at the end… – Continue reading
As the OECD’s proposals for global reform of corporate taxation advance, the challenge facing the Government is how best to adapt to major change, while ensuring Ireland remains competitive and continues to attract foreign direct investment. In the budget, Minister for Finance, Michael Noonan took a bold first step by… – Continue reading
66% of Law Firms Work With at Least Some of Their Tax Clients to Identify and Document All Relevant Intangible Assets for Transfer Pricing NEW YORK, Oct. 30, 2014 (GLOBE NEWSWIRE) — As scrutiny by tax authorities mounts, the identification and documentation of intangible assets, such as patents, trademarks and… – Continue reading
Bruton says US multinationals will advise Government on ‘knowledge box’ tax scheme Germany has warned that corporate tax subsidy arrangements known as “patent boxes” are acceptable in the European Union only as a reward for research and investment by companies in member states, not as a new tax-avoidance tool. It… – Continue reading
The OECD’s Action Plan on BEPS was published in July 2013 to reform the international tax system. The Action Plan identified 15 Actions to address BEPS. Seven of the 15 Action Plan items are now moving out of the station. I. Introduction On September 16, 2014 the OECD, together with… – Continue reading
Multinational life sciences companies should review their organizational structures and perform scenario planning to assess the likely impacts of the Organisation for Economic Co-operation and Development’s (OECD’s) Action Plan on Base Erosion and Profit Shifting (BEPS), says a new report from KPMG. “The Post Base Erosion and Profit Shifting World”… – Continue reading
At the 68th Congress of The International Fiscal Association in Mumbai, CBC-TV18’s Payaswini Upadhyay spoke to Sanjay Puri, Director, CBDT on the OECD’s work on Transfer Pricing principle of intangibles and India’s position on it and the kinds of transactions that the Department is looking at in the intangibles space…. – Continue reading
The sovereignty of individual nations is increasingly under threat from international governance bodies that want to force a range of new regional and international taxes on states. The latest attempt to bypass state sovereignty occurred when the World Health Organization (WHO) met behind closed doors in Moscow last week. In… – Continue reading
On October 14, 2014, the Irish Minister for Finance released proposals as part of the 2015 Irish Budget that would cause Irish incorporated non-resident (“INR”) companies to be treated as tax resident in Ireland beginning January 1, 2015. The goal is to shut down the use of so-called “Double Irish”… – Continue reading
Move intended to make Ireland more attractive to firms wanting to bring key decision makers The Government is to relax the rules governing a special tax incentive scheme to attract foreign executives into Ireland after just 31 individuals availed of the scheme last year. The move, contained in the Finance… – Continue reading
“The issue of substance and taxation is, and always will be, a core column of the Irish taxation system,” Michael Noonan, Ireland’s Finance Minister, said at his Department’s Tax Policy Conference on October 21, 2014, underscoring that Ireland’s strategy is to play fair but play to win. Beginning by discussing… – Continue reading
THE OECD has signalled support for the Government’s plan to introduce a so-called “Knowledge Development Box”, but warned that the devil would be in the detail. Pascal Saint-Amans, the director of the Centre for Tax Policy and Administration at the Paris-based Organisation for Economic Cooperation and Development (OECD), told the… – Continue reading
A new survey by E&Y released at its 33rd Annual International Tax Conference, titled “Connecting the dots” uncovered the issues of navigating multiple challenges, led by increased scrutiny and the effects of the Organisation for Economic Co-operation and Development’s (OECD) base erosion and profit shifting (BEPS) project. “Tax directors need… – Continue reading
The Irish government decided last week to get rid of a tax loophole that has helped big multinational companies like Apple and Google avoid paying billions in taxes to any government at all. But hold the champagne: Ireland could well replace one problematic tax policy with another, leaving aggressive tax… – Continue reading
Ireland puts an end to a tax loophole that saved Google, Apple, Microsoft, and Facebook billions in taxes “Double Irish” might sound like a drink that corporate tax lawyers reach for at the prospect of paying higher tax bills, but it’s actually the name of a controversial — albeit legal… – Continue reading
Our Reaction The Irish Minister for Finance delivered his Budget 2015 (the “Budget”) speech this week. There was considerable domestic and international anticipation in advance of the Budget against a backdrop of significant recovery in the Irish economy and also international focus (including, in particular, under the OECD BEPS project)… – Continue reading
Budget measures including new foreign direct investment incentives discussed State agencies and Government Ministers and officials have launched a co-ordinated campaign of letters and phone calls to senior executives of foreign multinationals, to reassure them that Ireland remains a top destination for investment following the budget, Minister for Enterprise Richard… – Continue reading
As the Irish government considers closing an infamous tax loophole for corporations, Wall Street has been scrambling to gauge the effect on the pharmaceutical industry. So far, the prognosis seems that damage will largely be minimal. Known as the ‘Double Irish,’ the loophole allows companies to send royalty payments for… – Continue reading
There are lots of headlines out of Dublin today about the end of the “double Irish,” a notorious tax break used by multinational companies to avoid paying government levies around the world. Don’t be fooled: The Emerald Isle isn’t giving up on its race to the bottom of the tax… – Continue reading
Malta, like Cyprus, has been obliged to dismantle its old ‘offshore’ companies regime as a trade-off for joining the European Union. EU membership has, however, brought about certain benefits for Maltese companies trading across borders, and, coupled with investment-friendly government policies and some interesting tax planning opportunities, Malta remains one… – Continue reading
A vast majority of companies headquartered in the United States expect increased scrutiny of their transfer pricing practices in the short-term as a result of the Organisation for Economic Cooperation and Development’s (OECD’s) base erosion and profit shifting (BEPS) project. A recent EY survey, Connecting The Dots, concluded that 30… – Continue reading
The screw is being turned on American companies that use complex structures to whittle down their tax bills. But is the latest EU probe a paper tiger or a game changer? It was supposed to be good news. Amazon’s announcement yesterday that it would hire 1,000 staff was dressed up… – Continue reading
Reuters) – Ireland’s plan to close a “Double Irish” tax loophole could cost U.S. companies including Apple and Google billions of dollars, although a new break and pressure to tackle tax avoidance elsewhere means they are unlikely to decamp. Analysts and tax advisers predict that corporations which need access to… – Continue reading
* Ireland to end tax regime that saved multinationals billions * Swift upturn ushers in tax cuts rather than austerity * Government faces backlash over uneven nature of recovery (Adds finance minister interview, Google comment) By Padraic Halpin and Conor Humphries DUBLIN, Oct 14 (Reuters) – Ireland will phase out… – Continue reading
Hitech firms are being warned that they should take advantage of tax relief on patent related profits now before a threatened clamp down by the European Union according to Richard Hopes, Partner at Alliotts accountants based in Surrey and London. Richard Hopes, Partner at Alliotts accountants and a specialist in… – Continue reading
Transactions within, rather than between, companies now accounts for about a quarter of Australia’s economic output, the Tax Office says. In a sign of the challenges facing the government’s crackdown on corporate tax erosion, the ATO said related-party dealings now amounted to more than a quarter of a billion dollars… – Continue reading
* Dublin set to change tax residency rules in Oct. 14 budget * Companies already in Ireland to be given time to adjust * Measures due to be signed off by cabinet next Tuesday By Padraic Halpin DUBLIN, Oct 10 (Reuters) – Ireland is set to announce legal changes next… – Continue reading
The European Commission’s recent action to crack down on special deals some European Union governments offer to corporations could be a blow to multinational corporations’ tax-dodging strategies. As we noted in a report earlier this year, three European countries (Ireland, Luxembourg and the Netherlands) are among the top twelve tax… – Continue reading
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. Email ftsales.support@ft.com to buy additional rights. http://www.ft.com/cms/s/0/ba95cff0-4fcd-11e4-a0a4-00144feab7de.html#ixzz3G77zeNBz Brussels is challenging the “double Irish” tax avoidance measure prized by big US tech… – Continue reading
The question has often arisen whether “international law” is an oxymoron – whether “obligations” in income tax treaties and other international agreements are really binding upon the parties, when they are not buttressed by some sort of enforcement mechanism. That question has never been more relevant in the tax world… – Continue reading
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
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
Amazon’s tax arrangements with Luxembourg are being investigated by E.U. regulators, as the online retailer becomes the latest global company to be accused of striking tax-minimising deals with member states that may break bloc rules. Corporate tax avoidance has come under the spotlight on both sides of the Atlantic in… – Continue reading
On top of his many boxing titles, including world championships in eight weight classes, Manny Pacquiao is on tap for a possible Senate seat in 2016. First, he has to get his taxes resolved. The Supreme Court of the Philippines ordered the boxing champ and potential Senator to answer the… – Continue reading
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
A tax-based industrial policy will not produce an innovative economy, writes James Stewart 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. Email ftsales.support@ft.com to buy additional rights. http://www.ft.com/cms/s/0/bde702e4-4d5e-11e4-bf60-00144feab7de.html#ixzz3HKJXRQha Irish… – Continue reading
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
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
The Californian corporation is Cork’s largest private employer, but has not won over all local hearts and minds. Now the city is at the heart of a fight over taxation that involves not just Ireland but also the European commission and the US senate Anger is mounting in Cork. The… – Continue reading
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
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
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. Email ftsales.support@ft.com to buy additional rights. http://www.ft.com/cms/s/0/f0564d62-4803-11e4-b5ad-00144feab7de.html#ixzz3EsBYd5vW Technology companies “that go to extraordinary lengths” to cut their tax… – Continue reading
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
German Finance Minister Wolfgang Schaeuble is working on closing a tax loophole whereby German firms use so-called “patent box” tax breaks available abroad on profits generated from patented research to minimize tax bills, according to a magazine report. Business weekly Wirtschaftwoche said a potential new restriction on the practice, similar to one in… – Continue reading
