Category: Loans

Tax authorities updated their interpretation of certain transfer pricing issues

On 1 July 2014, the Ministry of Revenues and Levies of Ukraine issued Order #368 ‘On amendment of generalised tax consultation on transfer pricing related issues, adopted by Order #699’, which significantly changed the respective tax consultation #699. In particular, the order included additional questions and clarifications and drastically changed… – Continue reading

First time homebuyer state tax credits

The federal first-time homebuyer tax credit programs expired near the end of 2011, but there is still tax help out there depending on the state or county where you live. For example, states such as Delaware, Texas, Kentucky and many more states have local homebuyer tax credit programs that you can take advantage of. Other… – Continue reading

Greenland first with offshore guarantee

The first Chinese company to issue offshore bonds under a more liberal guarantee framework has underlined the premium attached to a simplified security package. In a departure from the keepwell deeds and pledges of support featured on recent offshore financings, last week’s US$1bn issue from Greenland Global Investment came with… – Continue reading

Commissioner Šemeta welcomes Council agreement on measures to fight tax avoidance

“Ladies and Gentlemen, Our campaign against corporate tax avoidance marches on, with further important advances today. I am delighted that Finance Ministers have agreed on a crucial revision to the Parent-Subsidiary Directive, which will block a prevalent form of aggressive tax planning, known as hybrid loan arrangements. No longer will… – Continue reading

LSTA (Loan Syndication and Trading Association) Publishes Revised Documents Effective April 24, 2014

The Loan Syndications and Trading Association (LSTA) has released new forms of its primary trading documents, effective for trades entered into on or after April 24, 2014.[1]   The LSTA’s updated forms are primarily designed to address foreign withholding tax requirements that will become effective July 1, 2014 under the Foreign Account Tax Compliance Act (FATCA). Additionally, the LSTA… – Continue reading

Liverpool children’s hospital goes offshore

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

Argue later but pay NOW says taxman: Shock order means big bills for thousands in avoidance schemes

Celebrities and major companies locked in legal battles over tax-avoidance schemes will be forced to pay up before their cases are resolved, under new rules to be introduced in this week’s Budget. The rules will hit 65,000 companies and individuals in dispute with the taxman over their use of complex… – Continue reading

Taxpayers Pay $163 Billion In Interest To Apple, Cisco, Google, Microsoft In Offshore Accounts

United States taxpayers make large interest payments to the top four technology firmsfor the $163 billion in US government debt the companies own and shelter in tax-freeoffshore accounts. Apple, Cisco Systems, Google, and Microsoft legally hold $124 billion in US Treasury securities and $39 billion in US government agencydebt in accounts overseas, allowing them to avoid the 35… – 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

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

BVI and Canada: down to business — TIEA now effective

The Canada-British Virgin Islands (BVI) tax information exchange agreement (TIEA) came into force on 11 March 2014. The TIEA was signed in May 2013, and the effective date provisions are set out in article 13 of the agreement. The BVI is now party to 25 TIEAs. The BVI-Canada TIEA is… – Continue reading

Russia targets offshore investors

The Russian Finance Ministry will offer companies based offshore but with operations in Russia a choice: either disclose their ultimate beneficiaries and maintain their zero tax rate, or pay taxes at the higher Russian rate. Under Russia’s current corporate tax structure, offshore beneficiaries of Russian companies are treated as de-facto… – Continue reading