Category: Permanent establishment

Your Taxes: Israel to sign tax treaty with Panama

With regard to business operations, a resident of one country (e.g., Panamanian company) may be taxed in the other country (e.g., Israel) if it has a “permanent establishment” (PE) in the other country. Panama is famous for its canal, colorful history and cool offshore tax regime. To that we can… – Continue reading

India must go Hong Kong way to lure investors: Saurabh Mukherjea, CEO, Institutional Equities, Ambit Capital

Not only do Indians manage global investors’ money that is invested in India, Indian nationals often hold positions of responsibility in funds that have nothing to do with India. Now, given the rapid advances that have been made in technology, why aren’t these Indian nationals residing in India? Clearly, some… – Continue reading

Your Taxes: Going International

Going offshore means registering any intellectual property (IP) in an offshore company and delegating R&D and marketing to onshore companies. Money doesn’t grow on trees, and taking your business international is no picnic. On June 12, the International Business Structuring Association (IBSA) held a seminar to discuss ways of growing… – Continue reading

Administration of withholding tax (2)

The organisations making the payments are required to withhold tax from such payments and pay over the withheld amounts to their respective relevant Tax Authorities within 30days of receipt of payment or credit by the person or entity suffering the Tax. The relevant tax authorities to receive the WHT tax… – Continue reading

Cyprus: New Cyprus-UAE Double Tax Agreement Takes Effect

New agreement The new double tax agreement between Cyprus and the United Arab Emirates took effect from January 1 2014. For the most part, the agreement reproduces the corresponding provisions of the latest Organisation for Economic Cooperation and Development (OECD) Model Tax Convention verbatim. The principal departures from the OECD… – Continue reading

US Tax Cheats in Ireland Pocket Profits Worth Almost Half of GDP

It is a figure which Citizens for Tax Justice (CTJ), the US group which authored the report, says highlights Ireland’s popular use as a tax haven among US companies. Matt Gardner, executive director of the Institute on Taxation and Policy in Washington DC, tells IBTimes UK: “It’s a clear indicator… – Continue reading

Tax Chauvinism: Who Cares Where a Firm is Incorporated?

Following the recent offer by U.S drugmaker Pfizer to acquire British pharmaceutical firm AstraZeneca, congressional Democrats are proposing new limits on the ability of U.S.-based firms to establish foreign residence and thus cut their U.S. corporate tax bill. Even before this latest flap, the Obama Administration proposed curbs on this… – Continue reading

Latest from the U.S. on Five of the OECD BEPS Action Items

Robert Stack, deputy assistant secretary for international tax affairs with the U.S. Treasury, gave an update on several items in the OECD’s project to combat base erosion and profit shifting at the American Bar Association Section of Taxation’s May meeting. As reported more fully by Transfer Pricing Report’s Kevin Bell, Stack,… – Continue reading

Corporate Tax: Apple, Google, Dr Dre & Ireland’s continuing stateless companies

Corporate Tax Avoidance: Last week the news that Apple is considering buying Beats Electronics, a maker of expensive headphones that was founded by record mogul Jimmy Iovine and rap artist Dr Dre, for $3.2bn, got a lot of media attention. Dr Dre must have pissed-off Apple when he bragged on… – Continue reading

Caterpillar Dodged Billions in Taxes for Over a Decade

Caterpillar, industrial and construction equipment manufacturing Goliath, has been avoiding or deferring paying U.S. taxes for at least 13 years to the tune of approximately $2.4 billion, according to a report from the Homeland Security & Government Affairs Permanent Subcommittee on Investigations. “Tax evasion schemes rob the system of billions of… – Continue reading

In-transit: travelling bankers and potential PE implications in a post BEPS world

Wout Moelands, Hamir Khatau and Richard Collier, PwC UK Until the work of the OECD is completed, we can expect more frequent and assertive PE challenges, including the international origination arrangements conducted by travelling bankers or representative offices of banks. l. Introduction The PE rules provide tax authorities with a… – Continue reading

Double taxation risk in chasing multinational companies

A call to tax technology companies such as Apple and Google in the countries where they have substantial activities has re-ignited concerns companies may be taxed twice and stop business altogether. The Organisation for Economic Co-operation and Development, which is working on a global plan to prevent companies from avoiding paying… – Continue reading

United States: Remain Vigilant On Indian Permanent Establishments, Even After The Favorable e-Funds Decision

The U.S. and Indian competent authorities are famously at loggerheads over the principles to be applied in transfer-pricing double-tax cases.  Some of the important issues involved are:  the appropriate markup on costs for services; when and how to reward location savings; and whether marketing intangibles exist.  Virtually all of these… – Continue reading

Ireland’s Noonan Clarifies Corporate Tax Developments

Changes to Ireland’s residency rules, designed to eliminate mismatches between tax treaty partners, have not yet affected the residency status of any company, Finance Minister Michael Noonan has confirmed. The reforms were introduced in Noonan’s 2014 Budget and included in this year’s Finance Bill. They are intended to prevent companies… – Continue reading

United Kingdom: The OECD Base Erosion And Profit Shifting Action Plan

There has been considerable publicity in recent months on the alleged tax avoidance perpetrated by multinationals that has resulted in the Organisation of Economic Cooperation and Development (OECD) publishing its action plan on base erosion and profit shifting (BEPS). The action plan, consisting of 15 proposals to counter the perceived… – Continue reading