Category: Activity

UK: The Use Of UK Holding Companies In International Group Structures

The location of a holding company is a significant consideration in any international corporate structure. Choice of jurisdiction for a group holding company (‘Holdco’) is relevant both from the point of view of tax optimisation (maximising withholding tax free dividend, interest and royalty flow up through the group and minimising… – Continue reading

ECOFIN Council reaches agreement on the automatic exchange of information on tax rulings and APAs

On 6 October 2015, the Council of the European Union reached agreement on a proposal for a Council Directive (‘the New Directive’) amending Directive 2011/16/EU (Directive on administrative cooperation between Member States) and requiring automatic exchange of information on ‘advance tax rulings’ (‘Tax Rulings’) and ‘advance pricing arrangements’ (‘APAs’) between… – Continue reading

Russian Federation: Russian 2015 Tax Revolution

For many years international tax planning for Russian inbound and outbound investments, and wealth planning for Russian resident individuals, was rather straightforward. That was primarily due to relatively simple domestic tax rules and a degree of inexperience amongst the Russian tax and other interested authorities in relation to international tax… – Continue reading

OECD proposals could save countries US$240bn in lost taxes

With the bulk of the OECD’s work on the BEPS project complete, attention will now turn to the implementation of the recommendations by member countries and others. Minister for Finance, Michael Noonan said that he welcomed the Base Erosion and Profit Shifting (Beps) report, and that the OECD’s proposals would… – Continue reading

EU: AUTOMATIC EXCHANGE OF INFORMATION, CROSS-BORDER TAX RULINGS AND APAS

EU finance ministers today agreed to introduce provisions for the automatic exchange of information on cross-border tax rulings—the latest development concerning the European Commission’s initiative to address tax avoidance and harmful tax competition. Detailed provisions to be included in a directive are expected to be finalized before the end of… – Continue reading

72% of Fortune 500 Used Foreign Tax Havens

Nearly three-quarters of Fortune 500 companies booked their profits to tax havens last year, with just 30 companies accounting for 62 percent of earnings stashed offshore, according to a new report. The report, “Offshore Shell Games,” released Tuesday by the U.S. PIRG Education Fund and Citizens for Tax Justice, found… – Continue reading

CORRECT: NZ’s biggest companies may face ‘enormous compliance burden’ from OECD tax dragnet

Oct. 6 (BusinessDesk) – Fonterra Cooperative Group is likely to be among some 20 New Zealand companies left dealing with increased red tape to comply with wide-ranging reforms to corporate tax rules proposed by the Organisation for Economic Cooperation and Development and expected to be endorsed by the world’s 20… – Continue reading

BEPS plan puts companies in the firing line, say experts

The OECD-G20 plan to stop multinational tax avoidance could put companies in the middle of border disputes between revenue authorities, tax experts have warned. But civil society groups say the plan has not gone far enough and could make it easier for some multinationals to dodge tax. Treasurer Scott Morrison… – Continue reading

The CRA complied with the September 30 FATCA deadline after the IRS advised that Notice 2015-66 did not apply to Canada

In an affidavit that was filed with the Federal Court of Appeal on September 25, 2015 in support of the government’s response to block a motion for injunctive relief that had been brought by the plaintiffs, Sue Murray, Director of the Canada Revenue Agency’s Competent Authority Services Division, International and… – Continue reading

25% of Global Companies Say They Won’t Meet BEPS Deadline

One-quarter of corporate tax and transfer pricing directors surveyed say their companies will fail to meet the first deadline proposed by the Organisation for Economic Co-operation and Development (OECD) in its Base Erosion and Profit Shifting (BEPS) Action Plan. Finance ministers for the G20 countries called on the OECD to… – Continue reading

OECD: countries commit to minimum standards on international tax dispute resolution

Countries should commit to minimum standards on the resolution of international tax disputes, the Organisation for Economic Co-operation and Development (OECD) said in a report published as part of its base erosion and profit shifting (BEPS) project.06 Oct 2015 The standards would include a commitment to “seek to resolve” cases… – Continue reading

CAB requests the removal of named Caribbean territories on US “Tax-haven” list

PRESS RELEASE – The Caribbean Association of Banks Inc. (CAB) is once more forced to express its deep concern over yet another “tax-haven” list which includes 15 Commonwealth Caribbean countries. The referred list appears within the District of Columbia’s 2015 Budget Support Act which expands the definition of “tax haven”… – Continue reading

US firms pan international tax proposal

The architects of a sweeping set of recommendations to battle offshore tax avoidance insist their project won’t allow foreign countries to simply grab cash from U.S. companies. The business community isn’t convinced. Senior officials at the Organization for Economic Co-operation and Development (OECD), a Paris-based research group sponsored by almost… – Continue reading

Turkey: Council Of Ministers Approves Agreement Between Turkey And Kosovo To Prevent Tax Evasion And Double Taxation

The Council of Ministers has approved an agreement between the Republic of Turkey and Republic of Kosovo (“State” or collectively “States”) to prevent tax evasion and double income taxation for residents of the two countries (“Agreement”). On 19 August 2015, the Council of Ministers approved the Agreement and its annexed… – Continue reading

EU ministers agree measures to curb multinationals’ tax avoidance

LUXEMBOURG: European Union finance ministers agreed on Tuesday to automatically exchange information on deals struck with multinational companies from 2017 in a bid to reduce tax avoidance, officials said. “We have a political deal on this issue,” Luxembourg’s finance minister Pierre Gramegna told his EU counterparts in a public session… – Continue reading

Singapore: Singapore Tax Treaties: The End Of Limitation Of Relief?

What is limitation of relief? Here is an actual illustration: A client in Singapore has loans to a Spanish SOCIMI, a real estate investment company equivalent to a REIT. Spain requires tax to be deducted at source when interest becomes payable even if in fact the interest is not actually… – Continue reading

Ireland tweaks tax regime to divert avoidance criticism

The Irish government is set to make further changes to the country’s corporate tax regime as it seeks to align itself with a global initiative to clamp down on corporate tax avoidance, reports the Financial Times. The change being considered will oblige companies that have global headquarters in Ireland to… – Continue reading

Isle of Man: US FATCA Information Exchange Put Back A Year

In a move which is likely to be of interest to those organisations who put systems and procedures in place to comply, the US has recently announced (September 2015) that information on US persons does not now need to be exchanged for certain jurisdictions until September 2016. In Notice 2015-66… – Continue reading

Gaming the System: Underlying Problems of the U.S. Tax Code Must be Addressed

Last year at this time, news about “tax inversions” was grabbing headlines – cases where large U.S. multinationals would buy a foreign company in a tax-friendly jurisdiction, and then relocate its headquarters to reap the tax arbitrage benefits. The Obama administration responded to the rash of high-profile inversions with new… – Continue reading

OECD poised to release new tax dodge rules

Senior EY partners Andy Archer and David Snell look at some looming changes to international tax rules. In what will be the biggest change to the international tax rule book since it was put in place before World War 2, the OECD will tomorrow (4 am Tuesday 6 October) release… – Continue reading

Internal Revenue Service Begins Reciprocal Automatic Exchange of Tax Information Under FATCA IGAs

On October 2, 2015, the Internal Revenue Service announced that it had achieved a key milestone in implementation of the Foreign Account Tax Compliance Act (FATCA), a critical anti-tax evasion law passed by Congress in 2010 but not fully implemented until July 2014. The milestone announced by the IRS was… – Continue reading

Horizon Pharma relocates U.S. headquarters to Lake Forest

Daily Herald Reports Specialty drug manufacturer Horizon Pharma, which moved its corporate headquarters from Deerfield to Ireland in 2014, announced it is relocating its U.S. headquarters from Deerfield to Lake Forest as part of a company expansion. The Dublin-based company reported it signed a long-term sublease on a 160,000-square-foot building… – Continue reading

It’s Here; The Automatic Exchange of Information Under FATCA Began September 30th

The IRS has announced that as of September 30, 2015 it will implement the automatic exchange of tax information as set forth in the Foreign Account Tax Compliance Act, (FATCA). The IRS Commissioner in announcing the implementation of the automatic exchange of information stated: “This information exchange is part of… – Continue reading

Foreign governments ready cash grab on U.S. earnings

Opposition to foreign taxes on American investment and hard work has been coded into our national DNA for almost 240 years. Yet almost two and a half centuries after resolving that we would not stand idle while others decide how to tax us, Americans once again must take decisive action… – Continue reading

Plans to overhaul global tax system to be published

A plan for overhauling the global system for the taxation of multinationals, to be published on Monday in Paris, will contain major challenges and opportunities for Ireland’s vital foreign direct investment (FDI) sector, according to tax experts, reports the Irish Times. The culmination of two years’ work, the report by… – Continue reading

Some of Plymouth’s most well-known landmarks are owned by offshore companies

SOME of Plymouth best-known landmarks are owned by secretive offshore companies based in tax havens, it has been revealed. Swathes of land all over the city belongs to faceless firms based in places like Luxembourg and the Cayman Islands, The Herald can reveal. They include everything from historic former military… – Continue reading

FM warns of action against those hiding assets abroad

Finance Minister Arun Jaitley on Sunday said that people who had not declared their undisclosed assets in the 90-day compliance window offered by the government will now face the law including penalty and sentence upto 10 years while 638 people who had made the declaration can “now sleep well.” In… – Continue reading

Why landmark OECD tax reform is doomed before it starts

The OECD’s final package of proposals for reforming the international system for taxing companies brings to an end the two-year BEPS project led by the OECD and other G20 countries which also included participation by representatives of developing countries, business, academia and NGOs. Developing the BEPS, or Base Erosion and… – Continue reading

DUTCH DODGE €10 BILLION IN TAXES WITH OFFSHORE SCHEME

Wealthy Dutch people are abusing tax havens abroad to prevent from being taxed on 129 billion euros in deposits, a former tax inspector told television show Nieuwsuur. The money is held in the accounts of shell companies based in the Cayman Islands, Seychelles and Virgin Islands, among other locations, the… – Continue reading

S. Korea, China, Japan finance ministers to hold talks in Lima

SEJONG, Oct. 5 (Yonhap) — Finance ministers of South Korea, China and Japan will hold talks to coordinate policies on the sidelines of the Group of 20, International Monetary Fund (IMF) and World Bank meetings in Peru this week, the government said Monday. The finance ministry said the meeting, scheduled… – Continue reading

KPMG Statement On OECD’s Final Recommendations On Base Erosion And Profit Shifting (BEPS) Initiative

NEW YORK, Oct. 5, 2015 /PRNewswire/ — The following statement is being issued today by KPMG LLP on the final recommendations released on Oct. 5 by the Organisation for Economic Co-operation and Development (OECD) on its coordinated Action Plan on Base Erosion and Profit Shifting (BEPS): “The OECD’s final recommendations… – Continue reading

Bye bye Mauritius? With BEPS, tax havens will be viewed differently

With the final draft of the OECD’s BEPS initiative – Base Erosion and Profit Shifting – out later today, the taxman’s ability to tax international transactions as well as those of foreign firms operating in India will go up dramatically; the idea behind the initiative is to treat all cross-border… – Continue reading

Political & Economic week ahead: will TPP deal close?

Two big offshore deals kick off the week. The first is the Trans-Pacific Partnership Agreement. The long-awaited deal is a bit like the Jabberwocky poem in Alice in Wonderland – the alarmism means the political atmosphere is full of strange and threatening noises which only leave a general impression that… – Continue reading

Global Tech Firms Brace for Tax Rules Which Could Create New Disputes

PARIS–Global tech firms such as Amazon.com Inc. are already preparing for new tax rules that could force them to pay corporate taxes in more countries where they operate, but are also girding for what some say will be more fights with–and between–national tax authorities. The Organization for Economic Cooperation and… – Continue reading

A Tax Revolution in the Making in EU

Europe’s stiff-neckedness is difficult to cure. To come to an agreement for supranational treatment of a certain issue there needs to be a large cataclysm or at least a large scandal. In the case of taxation policy the problem begins to gain urgent and most importantly European status after the… – Continue reading

The value of dual citizenship for African’s wishing to take advantage of opportunities within the continent and abroad

It is estimated that only around 1% of the world’s population have two or more passports, making dual citizenship an exclusive privilege JOHANNESBURG – “No man is an island” is the theme of this year’s upcoming Investment Agenda, being held in Johannesburg on the 20th of October. Leading investors, asset… – Continue reading

The cost of tax evasion

Tax evasion is a massive global industry. Of every hundred dollars people put in bank accounts and investments, eight are socked away in tax havens such as Switzerland and Singapore, according to work by the UC-Berkeley economist Gabriel Zucman. While only the very wealthy can afford to play this international… – Continue reading

Revealed: how AstraZeneca avoids paying UK corporation tax

Pharmaceuticals group defends use of legal avoidance scheme, after paying no UK corporation tax over two years despite global profits of £3bn AstraZeneca, one of Britain’s largest businesses, is using a multimillion-pound tax avoidance scheme in the Netherlands, set up months after the UK relaxed its tax laws for multinationals… – Continue reading