Category: Activity

IMDO Launch Report on Irish Tonnage Tax Opportunities for International Shipping Industry

IrishTonnageTax – The Irish Maritime Development Office (IMDO) has released a report Irish Tonnage Tax: Opportunities for the International Shipping Industry. The Irish tonnage tax regime has been established for over 10 years and offers one of the most competitive on-shore corporate tax rates to international shipping companies. The tonnage… – Continue reading

Apple and other tech giants now have to pay their fair share

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

Irish Budget 2015 – Rate, Regime, Reputation

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

Confusion over Fatca deadline for trusts

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. Emailftsales.support@ft.com to buy additional rights. Trustees of private family trusts are being urged to register with the US tax… – Continue reading

Australia: Project Do It: Disclose unpaid tax from offshore income now

“It is the world’s best tax amnesty, “ says Morris Maroon, Head of the National Tax Team of law firm Rockwell Olivier. “There are only months before the best opportunity to turn foreign wealth tax-clean will come to an end. We will then see if the predictions of a particularly… – Continue reading

Bermuda: Super-Powered Settlors

The reservation or grant of certain powers by settlors has always been possible under Bermuda’s trust law but, historically, there was some uncertainty about exactly how far settlors could go without calling the validity of the trust structure into question. The recently passed Trusts (Special Provisions) Amendment Act 2014 (TAA… – Continue reading

Franken’s Attacks on ‘Fat Cat’ Financiers Backfire

Minnesota Democrat invested in opponent’s tax-inverting company as son’s private equity firm opens shop in Caymans Sen. Al Franken (D., Minn.) is hoping to saddle his Republican challenger with Mitt Romney-esque charges of “vulture corporatism,” but his own investment activities, and those of his son, could blunt those attacks with… – Continue reading

Bombay High Court ruling on taxability of share premium in the Vodafone India case

The much-awaited decision of the Bombay High Court was pronounced on October 10. Transfer pricing adjustment carried out in Shell/Vodafone case has been at the centrestage of every public discussion on Indian transfer pricing legislation. The incredulous stand taken by the tax authorities has evoked a strong response from investors… – Continue reading

Taiwan FSC to do stress tests on Chinese banks every quarter

Tseng Ming-chung at a press event in Taipei, Oct. 7. (Photo/Yen Chien-lung) Taiwan’s Financial Supervisory Committee (FSC) plans to conduct stress tests to assess the credit risks of China’s banks every quarter, reports our Chinese-language sister paper China Times. FSC chairman Tseng Ming-chung said the quarterly report will be published… – Continue reading

Spain’s Tax Breaks, TD Bank, Ex-UBS Banker: Compliance

The European Union expanded its crackdown on illegal tax breaks, ordering Spain to recover money from companies that benefited from rules encouraging merger activity outside of the country. The European Commission said the Spanish measures unfairly rewarded companies for buying stakes in foreign competitors. Telefonica SA (TEF) last year lost… – Continue reading

Ministers reassuring key foreign firms on closure of ‘Double Irish’

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

Nigeria: Transfer Pricing Africa (Part II)

n this second part of our overview of current transfer pricing regulations on the African continent, we focus on relevant provisions in, amongst others, Ghana, Nigeria and Uganda. The Ghanaian Transfer Pricing Regulations, 2012 (L.I.2188) (the Ghanaian Regulations) were introduced by the Ghana Revenue Authority (GRA) on 27 July 2012,… – Continue reading

Why Apple And Google Won’t Care About Irish Tax Law Changes

Ireland has this week moved to change its tax law, closing the “double Irish” tax avoidance technique widely used by multinational enterprises including Google and Microsoft. Picture: Getty Images In very broad terms, the current Irish tax law allows a company incorporated in Ireland to be a tax resident of… – Continue reading

Private equity owners of Game Group used tax havens for payments

The private equity owners of video games retailer Game used tax havens in the two years they owned it, accounts have revealed. US buyout group Elliott Advisors snapped up Game Group after it collapsed into administration in 2012. It set up Game Digital in April 2012 in a deal masterminded… – Continue reading

Commission’s Tax Drive Unsettles Multinationals

Europe’s antitrust regulator is encroaching on what has been the preserve of national governments. There’s a new tax sheriff in town. Europe’s top antitrust regulator, the Brussels-based European Commission, has launched an unexpected assault on what it suspects are sweetheart tax deals for multinational companies, plowing into an area traditionally… – Continue reading

Profit shifting report false – Lonmin

A report claiming Lonmin is engaging in two transfer pricing arrangements is misleading and false, the company said on Thursday. It was responding to a report titled “The Bermuda connection: Profit shifting and unaffordability at Lonmin 1999-2012″, released by the Alternative Information and Development Centre (AIDC) on Thursday morning. “Lonmin… – Continue reading

Strong rules on transfer pricing on agenda in many countries

AMONG several proposals for tax reform, the director-general of the Revenue Department has said the agency would propose an amendment to the Revenue Code concerning transfer pricing, aiming to provide greater clarity on the determination of fair transfer prices. The director-general has indicated that in past years many multinational companies,… – Continue reading

IRS Modifies Offshore Filing Procedures

The IRS has issued FAQs relating to the new streamlined procedures for offshore compliance, and for Delinquent International Information Return Submission Procedures. The FAQs for the streamlined program provide more detailed guidance on how the 5% penalty will be computed, how 100% owners of an incorporated business will be treated,… – Continue reading

What Does Closing the ‘Double Irish’ Tax Loophole Mean for Pharma?

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

Bringing back black money: Swiss promise India details in time-bound manner

erne/New Delhi: In a major breakthrough in India’s fight against black money allegedly stashed abroad, Switzerland today said it will examine Indian requests for banking information on a priority basis and provide requested details in a time-bound manner. The Swiss authorities would also “assist in obtaining confirmation on genuineness of… – Continue reading

Fourth protocol to Canada-UK Treaty eliminates withholding tax on arm’s length interest, but preserves tax exemption for gains on disposition of shares and interests deriving value from Canadian real property

On July 21, 2014, the governments of Canada and the United Kingdom signed the fourth protocol (Protocol) amending the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading

Isle of Man: Crypto-Currencies And The Isle Of Man

The Isle of Man is showing great enthusiasm for crypto-currencies – from the landlord at a popular Douglas drinking hole to the Lieutenant Governor, everyone is talking about digital currency and the potentially huge benefits to the Island. The Isle of Man Financial Supervision Commission (FSC) has announced plans to… – Continue reading

Global investment losses from unclaimed withholding tax hits £13.2 billion

UK investors relinquish more than £680 million in rightful returns due to withholding tax Research has revealed that an estimated £13.2bn ($22.4bn) of investors’ rightful returns from foreign shares and bonds were lost in the latest financial year because Witholding Tax (WHT) on dividends and income is not being reclaimed…. – Continue reading

Steris, the latest to renounce U.S. Citizenship, Only Paid a 16.3% Tax Rate Over Three Years

After announcing Ohio-based Steris Co.’s plans to become British for tax purposes on Monday, CEO Walter Rosenbrough later said on a conference call, “We’re not typically users of aggressive tax policies and I don’t think we are here.” That’s his story, and he’s sticking to it. But even a cursory… – Continue reading

Time to Make Corporations Pay Taxes They’re Avoiding

Blue-ribbon corporations are deserting our country “to avoid paying taxes but expect to keep receiving the full array of benefits that being American confers, and that everyone else is paying for,” Fortune magazine reports. That’s right, Fortune wrote it; not Pravda. In a scathing article titled “Positively Un-American” by Allan… – Continue reading

Wealth Inequality Accelerates Worldwide on Inheritance, Tax Avoidance

Wealth inequality is growing worldwide, according to a new report by Credit Suisse. A greater share of wealth is being held by a smaller number of ultra-rich families worldwide as larger inheritances, family trusts, and similar arrangements to avoid taxes help the ultra-wealthy gain a greater portion of total capital… – Continue reading

3rd LD Writethru: EU FinMins agree on taxation information exchange

LUXEMBOURG, Oct. 14 (Xinhua) — EU finance minister meeting concluded on Tuesday with breakthrough in taxation exchange information to fight against tax avoidance. Italian finance minister Pietro Carlo Padoan, whose country holds the presidency of the EU, told press after the meeting that the EU has planned to build a… – Continue reading

Tokyo District Court Allows Tax Saving from Share Repurchase

On May 9, 2014, the Tokyo District Court reversed a large tax that had been imposed on a large U.S. multinational’s Japanese holding company (“Japan HoldCo”). Under the Japanese Corporate Tax Law, if a shareholder returns shares to an issuing company (i.e., the issuing company acquires treasury shares), a portion… – Continue reading