Category: Activity

Swiss Said to Send Data on UBS French Client Accounts

UBS AG (UBSN), the Swiss bank facing French allegations of helping clients evade taxes, has handed over details on about 100 accounts, according to a person with knowledge of the matter. Swiss authorities at the start of the year notified UBS of a request from France for information on 300… – Continue reading

Amazon Luxembourg Tax Deals Investigated by E.U. Watchdog

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

When FATCA Meets FIRPTA: Some Preliminary Comments

In view of the frenzy in the profession over compliance with the new FATCA rules, it seems appropriate to take an overview of how FATCA applies to a major source of inbound investment by foreign individuals – “FIRPTA” investments in U.S. real property. This commentary considers the extent to which… – Continue reading

Manny Pacquiao Ordered To Explain His Taxes In Court: Is Pacman Now Taxman?

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

Amazon faces European Union tax avoidance investigation

Amazon, the online retailer, is to face a formal investigation into its European corporate tax practices, the European Commission has announced. The Commission – the executive division of the 28-member European Union – says it will look at the tax agreement made between Amazon and Luxembourg. It suspects the deal… – Continue reading

Canada: Tax Court Of Canada Allows Foreign Tax Credit Generator Arrangement

Major changes have occurred with respect to foreign tax credit (FTC). The Department of Finance announced in the federal budget of March 4, 2010, a proposed legislation regarding FTC generators (FTCG) and released modified draft legislation on August 27, 2010. These new FTCG rules target the FTC per subsections 126(4.11)-(4.13)… – Continue reading

Manny Pacquiao Ordered To Explain His Taxes In Court: Is Pacman Now Taxman?

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

Amazon Probed by EU, Following Charges Over Apple’s “Double Irish” Tax Evasion

Amazon is believed to have exploited a slightly different tax loophole in Luxemborg to wash away most local taxes The European Union (EU) made waves late last month when its antitrust regulators — a part of the trade-regulating body known as the European Commission (EC) — issued a preliminary finding… – Continue reading

State aid: Commission investigates transfer pricing arrangements on corporate taxation of Amazon in Luxembourg

The European Commission has opened an in-depth investigation to examine whether the decision by Luxembourg’s tax authorities with regard to the corporate income tax to be paid by Amazon in Luxembourg comply with the EU rules on state aid. The opening of an in-depth investigation gives interested third parties and… – Continue reading

The Marzen decision: a typical example of BEPS

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

Ireland’s tax regime nurtures innovation in avoidance

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

US delegation calls for repeal of FATCA

(CS) As part of a European tour organised by Republicans Overseas, US Senator Mike Lee on Tuesday visited Luxembourg to rally support for the repeal of the Foreign Account Tax Compliance Act, more commonly known as FATCA. Luxembourg and the US signed FATCA as an inter-governmental agreement in March this… – Continue reading

Washington resists Hockey’s tax crackdown on Silicon Valley giants

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

Korindo head probed for alleged tax evasion

By Jung Min-ho Seung Eun-ho Chairman of Korindo Group Prosecutors are investigating allegations that the head of Korindo Group, a Jakarta-based conglomerate, and his sons have evaded taxes. The Seoul Central District Prosecutors’ Office said Monday that the group’s Chairman Seung Eun-ho and his two sons are suspected of evading… – Continue reading

IRS Warns Foreign Banks of a New Online Scam Related to FATCA

Accountingweb.com reported on 24th September, 2014 quoting a fraud alert of the tax agency as “Scammers are posing as IRS and are trying to solicit foreign financial organizations for account-holder identity and financial account details under the Foreign Account Tax Compliance Act (FATCA).” IRS says that these illegal solicitations are… – Continue reading

The Italian approach to intercompany loans

The Italian tax authorities have been intensifying their focus on transfer prices involving financial intercompany transactions such as loans. Multinational corporations frequently resort to such transactions to optimise and rationalise the financial management of the entire group. In certain cases, the said optimisation tools pertaining to intercompany financial resources may… – Continue reading

City’s offshore yuan pool under threat from trade discount

Weak inflows and expanding channels for renminbi outflows are adding to challenges faced by Hong Kong banks in keeping offshore yuan Hong Kong’s offshore yuan pool risks drying up as offshore paper trades at its widest discount in more than two years, prompting mainland importers to avoid coming to Hong… – Continue reading

Asia-Pacific’s developing nations raise low govenment revenue: United Nations

NEW DELHI: Developing countries in Asia Pacific region are less successful in raising government revenue but greater regional cooperation can strengthen resource mobilisation, a report has said. “Countries across the Asia-Pacific region have significant potential for enhancing tax revenues … taxation is primarily a domestic policy issue, there are also… – Continue reading

UK government promises early consultation on new multinational tax avoidance rules

The UK government will shortly set out how it plans to implement globally agreed rules to prevent multinational companies from using artificial techniques to significantly reduce their tax bills, it has announced.06 Oct 2014 Tax Tax Disputes and Investigations UK Europe It has confirmed that it will consult on the… – Continue reading

THE CHATTER: Protests raise fears for Hong Kong banking sector

PEERING down from their gleaming tower blocks at pro-democracy activists on the streets, Hong Kong’s bankers and traders cannot help but worry that the island’s financial community will pay a heavy price if the city further infuriates Beijing. Hong Kong lives with the threat that its crucial role as China’s… – Continue reading

Bernard Hickey: War on the high-tech dodgers

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

How Apple’s Cork HQ became the centre of a bitter global war over corporate tax avoidance

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

United States: International Tax Alert – FATCA – Fund Managers: Be Aware Of Upcoming Deadlines

Fund managers the world over are facing the reality of the U.S. Foreign Account Tax Compliance Act (“FATCA”), encountering requests from U.S. withholding agents for FATCA documentation from funds and inquiries from potential investors regarding the status of FATCA compliance. A fund manager, tasked with assessing the FATCA status and… – Continue reading

Swiss Bank UBS Could Face a Record-Breaking Tax-Evasion Fine

When the U.S. fined Credit Suisse Group (CSGN:VX) $2.6 billion in May, the Justice Department said it was the biggest penalty ever in a criminal tax-evasion case. That record could soon be shattered. France could impose a fine of €4.9 billion ($6.2 billion) on another Swiss bank, UBS (UBSN:VX), for… – Continue reading

The European Commission Opens an Investigation into Transfer Pricing Practices

On Tuesday, September 30, 2014, the European Commission (the Commission) published its decision to open an investigation intoIreland’s transfer pricing practices.  The Commission is also reviewing the transfer pricing practices of other EU Member States, including the Netherlands and Luxembourg.  Any advanced pricing agreement (APA) or other tax ruling within the EU… – Continue reading

Cabinet approves offshore insurance

The Cabinet yesterday approved deregulation plans that would allow domestic life insurers to sell policies to Chinese clients through their offshore units. The Cabinet gave its go-ahead after trimming proposed tax breaks for offshore insurance units (OIU) to 10 years, from 15 years as suggested by the Financial Supervisory Commission… – Continue reading

Barcelona star Lionel Messi to face tax evasion trial

Barcelona and Argentina star Lionel Messi is to face trial for alleged tax evasion, a Spanish judge has ruled. The judge rejected a prosecution recommendation to drop the charges on the grounds the player’s father was responsible for his finances. Messi and his father Jorge are accused of defrauding the… – Continue reading

Osborne proposals for anti-abuse tax rules could damage UK competitiveness, expert warns

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

Fiat says Luxembourg tax deal probe will not significantly impact finances

Fiat-Chrysler (FIA.MI) reiterated on Thursday that a tax agreement granted by Luxembourg to one of its subsidiaries was legitimate and said the potential financial impact of a European Commission probe into the matter would not be significant. A tax concession that Luxembourg authorities granted to Fiat Finance and Trade in… – Continue reading

‘Earnings stripping’: The next tax-dodging strategy in Obama’s crosshairs?

When the Obama administration clamped down last month on companies that reincorporate abroad to escape high U.S. taxes, it did not address a tax-dodging technique known as “earnings stripping,” leaving some to wonder if it is the next target. Earnings stripping is widely practiced and covers a range of financial dealings that… – Continue reading

ITALIAN FAMILY BUSINESS REPUTATIONS LARGELY UNSCATHED BY PRADA TAX PROBE

The reputation of Italian family businesses will escape unscathed despite news of yet another high-profile family being hit by allegations of tax avoidance, according to a family business academic. This week, family-owned Prada announced that its two chief executives, Miuccia Prada and Patrizio Bertelli, are under investigation for inconsistent tax… – Continue reading

Disgorgement Remedy Based on Unpaid Taxes From Wylys’ Securities Trading Profits

Sept. 29 — Samuel Wyly and the estate of Charles Wyly must pay a total of $188 million plus prejudgment interest based on taxes they would have paid on profits from offshore trusts (SEC v. Wyly, S.D.N.Y., No. 1:10-cv-05760, 2014 BL 267268, 9/25/14). Judge Shira A. Scheindlin issued an order… – Continue reading

European Commission extends probe into Gibraltar’s corporate tax regime

The European Commission has extended the scope of its investigation into whether Gibraltar’s corporate tax regime favors certain companies, in breach of EU state aid rules. Related Stories Brussels to accuse Apple over illegal Irish tax deals: FT Reuters EU says Ireland swapped Apple tax deal for jobs Reuters EU watchdog to… – Continue reading

Osborne bid to fight tax avoidance ‘may empty, not swell, state coffers’

British chancellor George Osborne’s promise to clamp down on a tax avoidance loophole widely used by multinational technology companies could actually result in a reduction in the amount of money the government takes in, the Chartered Institute of Taxation has warned. Patrick Stevens, the group’s tax policy director, admitted the… – Continue reading

Gideon Spanier: At last, Europe is targeting the tech giants on tax

American technology companies are suddenly living in fear. European governments are finally standing up to the power of these giants that are happy to talk about the benefits their digital products and services bring to society while being accused of not paying their fair share of corporation tax, not doing… – Continue reading

EU’s investigation into Fiat deal an ‘all-out attack’ on Luxembourg’s tax practices

BRUSSELS : The European Union’s tax investigation of Luxembourg focuses on a single unit of the Italian auto company Fiat. But the implications of the inquiry could in some ways be more far-reaching for multinational companies and their tax accounting than the bloc’s separate Apple-Ireland inquiry, experts said Tuesday. “I… – Continue reading