Category: Profit Shifting

European Union: EC’s Proposal For Automatic Exchange Of Tax Rulings

On March 18th 2015, the European Commission published a new initiative on tax transparency to fight tax evasion and avoidance. The initiative includes a proposal to extend the scope of the Directive on Administrative Co-operation in the field of direct taxation (2011/16/EU), amended by Council Directive 2014/107/EU (the “Directive”) by… – Continue reading

Luxembourg thrives after tax regime shake-up

An inflow of bank deposits to Luxembourg from Asia and the Gulf have replaced reductions from European countries such as France and Germany following an overhaul of the Grand Duchy’s tax secrecy regime, reports the Financial Times. Pierre Gramegna told the Financial Times in an interview that “bank secrecy had… – Continue reading

EIB: From bad banking to good banking

Like many other public banks, the European Investment Bank (EIB) leverages its own means by acting as a catalyst for private investment through various financial mechanisms. Too often, though, attempts to attract private capital result in unpredictable risks and higher-than projected costs for the public coffer, write Xavier Sol and… – Continue reading

Google tax: Hockey top adviser attacked plan in former role

The man chosen by Treasurer Joe Hockey to lead the review of the nation’s tax system has publicly criticised the British government’s “Google tax”, the inspiration for the Coalition’s looming crackdown on multinational profit shifting. Robert Jeremenko, who is running the tax white paper process in Mr Hockey’s office, described… – Continue reading

OECD MAP Statistics Show Pressing Need for Mandatory Binding Arbitration

The OECD Mutual Agreement Procedure Statistics for 20131 (MAP Statistics), released on November 25, 2014, show a dramatic surge in the inventory of mutual agreement procedure (MAP) cases among OECD member countries. The MAP Statistics confirm that the potential for double taxation is increasing. This is reflected most starkly in… – Continue reading

African leaders advised to focus on tax policies

SOUTH Africa’s Finance Minister Nhlanhla Nene says African leaders need to focus more on tax policies and the diversification of tax resources in order to foster growth. Speaking at an African Tax Administration Forum conference on Tuesday, he said the global focus on international taxation offered a unique opportunity for… – Continue reading

Australia reaches tax loophole crackdown deal with UK

Summary:Australia and the UK have reached a deal aimed at helping tackle profit-shifting practices by multinational companies, such as Apple, Google, and Microsoft. Australia and the United Kingdom have agreed to form a joint working group to tackle profit shifting by multinational companies such as Google, Apple, and Microsoft. The… – Continue reading

OECD plans for gathering data on ‘base erosion’ at a disappointingly early stage, expert says

International plans for gathering and analysing data on the extent to which multinational companies are artificially shifting their profits to low-tax jurisdictions are at a disappointingly early stage, an expert has said. Heather Self of Pinsent Masons, the law firm behind Out-Law.com, also said that the global governments involved in… – Continue reading

China: Asia Tax Bulletin – Spring 2015

CHINA Tax Free Reorganisations • With circulars 109 and 116 jointly issued in December 2014 by the Ministry of Finance and the State Administration of Taxation, the Chinese authorities have relaxed the conditions for internal reorganisations. • Circular 109 deals with internal reorganisations. Provided the pertinent requirements are met, the… – Continue reading

GLOBAL INFO EXCHANGE MUST TO CURB TAX EVASION, INDIA TELLS G-20

The Union Finance Minister, Arun Jaitley, expressed concern over transfer pricing and several other measures taken by MNCs to avoid paying tax on international transactions. The Dollar Business Bureau Stressing on the need to keep a check on tax evasion by multi-national companies (MNCs), India has asked the G20 members… – Continue reading

UK, Australia To Push Diverted Profits Taxes

UK Chancellor George Osborne and Australian Treasurer Joe Hockey have committed to establishing a working group to urgently consider and develop initiatives centered around the UK’s Diverted Profits Tax. The announcement was made at the Group of Twenty (G-20) Finance Ministers and Central Bank Governors Meeting, which was held in… – Continue reading

Tax Office requests impromptu hearing of tax avoidance inquiry to tackle claims by former ATO executive

The Senate inquiry into corporate tax avoidance will unexpectedly return on Wednesday after the Australian Taxation Office requested a supplementary public hearing to refute allegations made in evidence by former ATO executive Martin Lock. Mr Lock told the inquiry earlier this month that the Tax Office gives up “billions of… – Continue reading

IT tax dodgers strangle homegrown talent

Macquarie Telecom has given full voice to an extremely serious problem facing Australian technology companies: That is, the gaming of the global tax system by multinationals puts Australia’s home-grown technology players who pay tax in Australia at a significant competitive disadvantage. This is a simple equation. It doesn’t matter how… – Continue reading

Australia must break the shackles of intellectual property in FTAs

Last week some of Australia’s biggest and richest companies voluntarily fronted up to a senate inquiry on corporate tax avoidance. Bigwigs from big brands, including Apple, Google, Microsoft, Rio Tinto, BHP Billiton and Fortescue Metals, squirmed under the spotlight as they were grilled about how they (legally) shift profits offshore… – Continue reading

Treasurers should provide transaction documentation according to BEPS

Corporate treasury departments will have to start complying with International tax rules and provide documentation for transactions according to recent reports. G20 leaders attempted to reform the international tax system in July 2012 by setting up the Base Erosion and Profit Shifting (BEPS) project. This task was given to the… – Continue reading

Your Taxes: OECD helping governments collect more taxes

Israel joined the OECD in 2010. Background The Organization for Economic Cooperation and Development is spearheading a concerted effort to help governments around the world collect more taxes. The OECD is doing so by issuing a series of recommendations for tightening up corporate and personal tax measures. Individual governments are… – Continue reading

Tax Directors Expect Their Companies to Expand

Tax directors at many organizations anticipate their companies will grow by entering into new domestic and international markets in the years ahead, according to a new survey by BDO USA. In a sign of an improving economy, 50 percent of the 100 tax directors at $1billion-plus public companies surveyed by… – Continue reading

Tax Directors Anticipate Domestic and Cross-Border Growth Over The Next Three Years, According To The Inaugural BDO Tax Outlook Survey

– Rising Cost of Compliance Within The Tax And Financial Regulatory Environment Creates Opportunities For Increased Efficiency – CHICAGO–(BUSINESS WIRE)–As the economy continues to accelerate, many organizations plan to grow by entering into new markets in the years ahead, reveals the first ever BDO USA, LLP Tax Outlook Survey. Fifty… – Continue reading

Social networking sites to become work places

The Revenue Office will take steps to tax social networking sites and implement other regulations related to e-commerce. After the implementation of this regulation, all such virtual sites will be deemed as “work places” and the advertisers of social networking sites will also be deemed as “electronic tax payers.” Moreover,… – Continue reading

Legal flash – Shanghai office – March 2015 – Announcement of the State Administration of Taxes concerning enterprise income tax on fees resident enterprises pay to overseas related parties

In recent years, the State Administration of Taxes (“SAT”) has paid closer attention to fees resident enterprises pay their overseas related parties, concerned that multinational groups have shifted profits away from China through aggressive tax planning and by paying unreasonable service fees and royalties overseas. Following PRC’s active participation in… – Continue reading

Senate tax inquiry: Google, Apple, Microsoft policies highlight golden days of tax laxness

There was a moment on Tuesday evening – hours before the first public hearing of the Senate inquiry into corporate tax evasion – when Treasurer Joe Hockey and his advisers should have sensed a firestorm approaching. Sandwiched between a story on a Gold Coast diet blogger accused of pinching other… – Continue reading

Australian Senate tax grandstanding: A preparation for austerity

An Australian Senate parliamentary committee hearing on Wednesday was dominated by the fire and brimstone of Labor and Greens politicians directed against tax avoidance by major corporations. Labor Senator Sam Dastyari called on Australian Tax Commissioner Chris Jordan to “name some of Australia’s worst corporate offenders,” declaring that they “should… – Continue reading

Company tax secrets are safe unless they lie: tax commissioner

Companies appearing before a senate inquiry into tax avoidance are on notice that any false evidence they give will be corrected by the Tax Office. Tax Commissioner Chris Jordan urged the committee to ask individual companies to disclose their own tax positions. He would correct the record if they provided… – Continue reading

China’s pre-emptive strike on OECD profit-shifting initiative

China has introduced measures to deny income tax deductions for certain service fees and royalties paid by Chinese companies to their overseas affiliates. They appear to stem from China’s initiatives to implement rules it sees as related to the OECD’s Base Erosion and Profit Shifting project (BEPS) They will likely… – Continue reading

U.S. companies have $2.1 trillion worth of profit stored overseas

The U.S. Congress must find a way to tax offshore profits stored by some of the world’s largest corporations. Currently letting their earnings safely mount up abroad, lawmakers are considering a special “deluxe” tax rate to get money from the companies. A recent study from the Center for Effective Government… – Continue reading

West should tackle corporate tax avoidance the way it has Islamic State, Senator Bill Heffernan says

The Western world needs to tackle multi-national tax avoidance a “bit like” it has tackled the Islamic State terrorist group, maverick Liberal senator Bill Heffernan says. Senator Heffernan has for years argued tax avoidance is a threat to sovereignty and thinks it will take a coalition of Western countries to… – Continue reading

Google, Apple and Microsoft defend tax set-up that shifts revenue offshore

Executives tell Senate inquiry paying tax overseas for Australian sales is how the global tax system works, while News Corp Australia demands Netflix pays GST Senior executives from three major tech firms have defended corporate structures which allow most of the revenue from their Australian operations to be taxed in… – Continue reading

Experts caution Australia on unilateral ‘Google tax’

Taxation experts have warned against unilateral action on corporate tax avoidance, telling a Senate Economics Committee Australia should be proactive and show leadership in the OECD and G20 tax processes already underway. The inquiry, initiated by Greens leader Christine Milne, is exploring tax avoidance and aggressive minimisation by corporations registered… – Continue reading

Singapore doesn’t condone tax abuse, MOF says

Singapore does not condone any abuse of its tax system, a Ministry of Finance (MOF) spokesman said on Tuesday, in response to a Straits Times query following media reports that the Australian government is pursuing global miners BHP Billiton and Rio Tinto for channelling billions of dollars in iron ore… – Continue reading

Google says give R&D tax breaks to small techies, not big guys

Tax breaks for research and development should be targeted to smaller technology start-ups, rather than big companies that will most likely make the investments regardless of incentives, Google Australia will tell the senate inquiry into corporate tax avoidance. Google Australia’s managing director, Maile Carnegie, will be appearing before the inquiry… – Continue reading

Corporate tax avoidance inquiry to begin this week, examining some of Australia’s biggest companies

The financial arrangements of some of Australia’s biggest companies will be in the spotlight this week with a Senate inquiry taking evidence on corporate tax avoidance. The inquiry was initiated by the Greens leader Christine Milne and supported by the Federal Opposition. “We have to actually start really pushing on… – Continue reading

Finland To Support African International Tax Reforms

On April 2, 2015, the Finnish tax authority signed a co-operation pact with the African Tax Administration Forum (ATAF), to support African tax authorities to implement changes to their international tax and transfer pricing regimes. The co-operation deal, which will extend to the administrations of over 35 African nations, focuses… – Continue reading

Big business set to face Senate tax avoidance inquiry

Tax avoidance takes centre stage this week with a parliamentary inquiry due to hold its first public hearings. The Senate inquiry into Tax Avoidance and Profit Shifting will start taking evidence from major technology and mining companies. The inquiry was prompted by a report which found tax minimisation strategies employed… – Continue reading

OECD discussion draft considers Controlled Foreign Corporation Rules

On April 3, 2015, as part of its Action Plan on Base Erosion and Profit Shifting (BEPS), the OECD released a discussion draft entitled “BEPS Action 3: Strengthening CFC Rules” (the Draft) for comments. The Draft stresses the importance of CFC rules in countering base erosion and profit shifting, and… – Continue reading

Africa loses $528.9 billion to illicit transfers in a decade

It has been revealed that illicit financial transfers are draining Africa of massive resources needed to uplift its majority poor from the claws of poverty and provide both productive and social infrastructure for development. The African Civil Society Circle, a group of nine civil society organizations and think tanks from… – Continue reading