Why stop at $221 billion? Drug companies are entering another round of dealmaking, after plowing past the global record. Teva Pharmaceutical Industries Ltd.’s $40.5 billion agreement Monday to purchase Allergan Plc’s generic-medicines business puts the mechanism in place to trigger more takeovers. For starters, the remaining Allergan company — with… – Continue reading
None of the pharmaceutical companies that are accused of profit shifting have been taken to court, the Australian Taxation Office has said in written responses to the Senate inquiry into corporate tax avoidance. Earlier in July executives from the largest global pharmaceutical companies operating in Australia were hauled before the… – Continue reading
The Organisation for Economic Co-operation and Development’s (OECD’s) Parliamentary Group on Tax is meeting for the fourth time to discuss the implementation of the base erosion and profit shifting (BEPS) project. The meeting will take place in Paris on October 19, 2015. The timing has been carefully chosen to fall… – Continue reading
The July 21 edition of the Brazilian Official Gazette contained provisional measure 685 (PM 685), which creates an obligation on taxpayers to formally report to tax authorities certain transactions that result in tax benefits. The requirement is supposedly in line with the OECD’s base erosion and profit shifting (BEPS) project… – Continue reading
FEW tax hikes have been timed so badly – and retracted so fast – as that imposed on mineral royalties by Zambia’s President Edward Lungu in January. After threats of divestment from major mining houses and an outcry from the country’s Chamber of Mines, the massive hike in royalty taxes… – Continue reading
Globalisation has brought many benefits in terms of cross?border trade, efficiency, competition and the free movement of goods and labour. But it has also allowed multinational corporations (MNCs) much greater freedom to reconfigure the location of manufacturing, operations, sales and corporate services in ways which channel reported profits ? and… – Continue reading
On 8 June 2015, the Organisation for Economic Co-operation and Development (“OECD”) released a Country-by-Country Reporting Implementation Package developed under the OECD’s base erosion and profit shifting (“BEPS”) Action Plan 13: Re-examine Transfer Pricing Documentation. BEPS was identified as a risk to tax revenues, tax sovereignty and the tax fairness… – Continue reading
This article deals with the manner in which Canada has complicated, and rendered controversial, what in most other countries is straightforward — the deductibility of business related interest expense. The reasons to write about it are threefold: the almost-concurrent issuance of the Canada Revenue Agency’s administrative views on the matter… – Continue reading
With the focus of 2014 being international tax competition, 2015 shows signs of continuing this trend. The European Commission (COM) and European Parliament (EP) are starting to debate and extensively investigate Member States’ tax ruling policies, partly as a result of the LuxLeaks revelations and partly in relation to the… – Continue reading
Thwarted in its attempt to acquire the generic and specialty pharmaceuticals company Mylan, the Israeli–based Teva will purchase Ireland-based Allergan Generics for $40.5 billion in an acquisition that executive and investors at both companies — if not consumers — are applauding. “Teva’s deal with Allergan will create a market behemoth… – Continue reading
San Jose, California, USA – As a result of the much anticipated initial public offering of transportation game-changer Uber, more and more executives of start-up companies and their investors are interested in tax planning related to their own company’s IPO or buyout. Whenever a well-known start-up company appears that it… – Continue reading
The Republic of Cyprus has once again kept its promise to international investors and introduced on the 9th of July 2015 amendments to its tax legislation making the jurisdiction as attractive as never before. The purpose of these amendments is to clearly establish Cyprus as the leading tax jurisdiction in… – Continue reading
The Supreme Court-appointed special investigative team’s (SIT’s) recommendation of stricter norms for participatory notes (P-notes), to check the flow of unaccounted money, is likely to be viewed negatively by the market. The SIT had last week suggested the Securities and Exchange Board of India (Sebi) put in place regulations to… – Continue reading
Consultation Solution no. 176, published by the Brazilian Federal Revenue Secretariat on July 8, 2015, made clear the tax administration’s position to require application of the PCI and Pecex methods on import and export transactions involving commodities, by determining the reliable sources of information to obtain the parameter prices for… – Continue reading
The evolving tax landscape in the MENA region was discussed at the EY MENA Tax Conference held recently in London. The conference was attended by EY Tax specialists and senior finance and tax executives from major European companies with investments in the MENA region. Sherif El-Kilany, MENA Tax Leader, EY,… – Continue reading
Wealthy investors in multiple tax avoidance schemes are being leaned on to settle what the tax authority sees as due, or risk reputational damage, reports the Financial Times. Although the government has yet to legislate for powers to “name and shame” tax avoiders, HM Revenue & Customs has warned a… – Continue reading
Introduction US tax treaty policy can be affected by pressures for tax reform from within the United States and by major developments in international taxation from without. Talk of US tax reform has been widespread for years, although it is sometimes hard to gauge how much of the talk is… – Continue reading
Blatant corporate and personal tax evasion contributed to Greece’s debt crisis, but it’s dwarfed by the tax avoidance of U.S. multinationals operating in countries like Australia. There’s a popular misconception that Greece’s debt crisis was self-inflicted. ‘The Greeks are a bunch of tax evaders! They should never have been allowed… – Continue reading
Law 20,780 – published in the Official Gazette on September 29 2014 – introduced the most complex and comprehensive tax reform in Chile for decades. Several provisions are already in force, while others will enter into force on January 1 2016. Most of the remaining provisions will be in full… – Continue reading
The Commissioner of Taxation has released a new Practice Statement, PS LA 2015/4, setting out “refreshed” practice and procedures for Advance Pricing Arrangements (APAs). The process outlined in PS LA 2015/4 retains many of the features of the old APA process described in PS LA 2011/1, but adopts a new… – Continue reading
The government wants the UK’s largest businesses to sign a voluntary code of conduct on tax which would see them renounce aggressive tax planning and vow to follow the spirit as well as the letter of the law. Big businesses would also be obliged to publish an annual tax strategy,… – Continue reading
The digital economy is an increasing concern for taxpayers, especially in light of impending BEPS guidance, but how it will impact different industries will vary. The fundamental principle behind the digital economy, in terms of transfer pricing, is its reliance on intangible assets and the difficulties when deciding which jurisdiction… – Continue reading
As governments around the world establish austerity measures to compensate for decreases in tax receipts, a new catch phrase has emerged: double non-taxation. Double non-taxation is the phrase used by governments to denote untaxed or lightly taxed profits that result from effective, legal tax planning techniques. These techniques include application… – Continue reading
Pharmaceutical industry acquisition target Perrigo (PRGO) Wednesday said it’s buying German pharmacy company Naturwohl Pharma GMbH, the latest transaction in the sector’s surge of mergers and acquisitions. Perrigo, operated from Michigan but headquartered in Dublin following a corporate tax inversion, did not disclose terms of the deal for Naturwohl and… – Continue reading
The IRS’ investigation into Microsoft books centers on how the company uses its overseas subsidiaries for tax purposes. The company says the IRS audit has gone on long enough and the federal agency improperly hired an outside law firm to help in the investigation. Microsoft and the federal government have… – Continue reading
The drug industry has been labelled “passive aggressive” after responding to tough questions over its use of tax minimisation by warning paying more tax would damage the economy. The warning was contained in a “supplementary submission” to the Senate tax avoidance inquiry, following a public hearing a fortnight ago that… – Continue reading
July 17: A large manufacturing company has resolved its transfer pricing issues by means of a mutual agreement procedure (MAP) reached between India and Japan. The MAP was signed in less than a year of its application, following two meetings between the Competent Authorities of India and Japan. The MAP… – Continue reading
The Economic Freedom Fighters (EFF) said it would like to see prison sentences imposed on business executives who moved cash to tax havens – where the rate of taxation is lower than in South Africa – “to deal decisively with transfer pricing and illicit financial flows”. This is one of… – Continue reading
At a global summit that addressed how illicit financial flows interfere with reducing poverty, wealthy nations rejected a plan to expand the UN’s power to fight global tax evasion. The plan, promoted by developing economies and transparency groups, was the subject of the meeting between delegations of UN members from… – Continue reading
Switzerland lies in “pole position” to gain from changes to the UK tax system which could encourage high net worth individuals living there to consider moving, according to a leading tax expert, John Huber. However, Malta should be doing more to attract a share of them, he said. “Chancellor George… – Continue reading
In response to the economic downturn and the growing need for tax revenues, the Italian Tax Authorities (ITA), like authorities in many other jurisdictions, have more aggressively targeted multinationals and their tax planning strategies in recent years, resulting in more domestic and international tax controversies. Transfer pricing (TP) issues account… – Continue reading
Energy giants called to explain billions in tax havens To describe Gorgon as another super-sized resources project in Western Australia does not do justice to the scale and scope of the venture. When the taps are turned on later this year and liquefied natural gas begins to flow, Australia will… – Continue reading
Special Business News article by Rob Rotherham, KPMG tax division senior manager, on the effects of the UK Budget. With effect from April 1, 2015, the UK Government introduced a new tax: the Diverted Profits Tax. (DPT). The DPT is aimed at countering the use of aggressive tax planning techniques… – Continue reading
ARLINGTON, Va., July 14, 2015 /PRNewswire/ — Bloomberg BNA today announced the latest event in its Global Transfer Pricing Conference series with Baker & McKenzie, in association with the Tax Management Educational Institute, to be held September 17-18, 2015 in Shanghai, China. The conference provides an opportunity to hear from… – Continue reading
European Commission to issue decisions on four test cases, including Apple in Ireland, Until a few months ago, the medieval town of Athenry in County Galway owed its fame mainly to a song. Irish rugby and football fans often burst into stirring renditions of “The Fields of Athenry”, a ballad… – Continue reading
Hopes for a broad overhaul of the corporate tax system are fading as the 2016 elections draw closer, but momentum is building for one key change — the U.S. tax that companies would pay on overseas profits. A bipartisan proposal, to be introduced soon in Congress, would tax the estimated… – Continue reading
German supermarket chain Aldi has given the market a rare glimpse into its profitability in Australia, as part of its ongoing defence against claims it doesn’t pay its fair share of tax. Aldi is structured as a limited partnership in Australia and so is not required to provide detailed financial… – Continue reading
Developing nations and advocacy groups at a United Nations conference in Ethiopia are pushing for a new global body to tackle tax avoidance by companies, a move opposed by richer nations. Responsibility for tax standards should be moved to the UN from the Organization for Economic Co-operation and Development, a… – Continue reading
The short answer to the question of the connection between Canada’s new anti-terrorism laws and taxes is that recent amendments to the Income Tax and Excise Tax Acts which arise through the Anti-Terrorism Act permit more extensive disclosure and sharing of private and confidential taxpayer information. The longer answer is… – Continue reading
The Union Government on 12 July 2015 appointed international lawyer Rodrigo Oreamuno to arbitrate with the UK telecom major Vodafone in the 20000 crore rupees tax case on its behalf. Oreamuno replaces former Chief Justice of India RC Lahoti, who recused himself in May 2015. Vodafone already named Yves Fortier… – Continue reading
OECD guidance needs to be clear otherwise the process could favour the bigger nations In Paris last week, as Angela Merkel and Francois Hollande discussed events in Greece, the international tax system was being discussed in an underground meeting room at OECD headquarters. For almost two days tax authority delegates… – Continue reading
Switzerland and the EU have signed a major accord to automatically exchange information on the financial accounts of each other’s residents. EU taxpayers will no longer be able to hide undeclared funds in Swiss banks. After coming up to increased international pressure in recent years, Switzerland has signed up to… – Continue reading
Poor countries need to get better at raising tax, and multinational firms need to get better at paying it SOMALIA is not only one of the world’s poorest and least developed countries, it is also one of the most dangerous for tax collectors. By one reckoning a fifth of tax… – Continue reading
The National Board of Revenue (NBR) introduced the ‘Transfer Pricing Scheme’ hurriedly in the financial year 2011-2012. It, however, did not make any provision for infrastructure development to promote the scheme among concerned members of the public. Even it did not make any publicity for assessees, multinational and local companies… – Continue reading
DAKAR – Africa is usually perceived as a net beneficiary of the global financial system, with aid and investment flowing to the continent from richer parts of the world. This is simply not true. Illicit capital flight is draining Africa dry – costing the continent about one trillion dollars over… – Continue reading
The government’s grip over information is tightening not only in respect of transactions undertaken within the country but also overseas In a liberal economic and low tax rate environment, people are expected to go straight. Tax fraud and tax evasion deprive governments of revenues needed to restore growth and at… – Continue reading
On 4 June, the Organisation for Economic Co-operation and Development (“OECD”) published a discussion draft on “hard-to-value-intangibles” in terms of which the OECD proposes revising its Transfer Pricing Guidelines. In particular, it is proposed that tax authorities will be allowed to use ex post “evidence”, (i.e. hindsight), to assess the… – Continue reading
SEPANG: AirAsia X Bhd (AAX) has lodged an official complaint with the Securities Commission (SC) against GMT Research and seeks the regulator’s appropriate action against the research house for various misleading statements and allegations. AAX said GMT had accused the long-haul budget carrier, among others, of practising or allowing profit… – Continue reading
George Osborne’s family business struck a £6m deal with a property developer based in an offshore tax haven, it has been reported. The upmarket wallpaper firm Osborne & Little is claimed to have linked up with a corporation in the British Virgin Islands to turn its former headquarters in an… – Continue reading
The UK’s chancellor of the exchequer has said serial users of tax avoidance schemes will be ‘named and shamed’ as he promised to introduce further measures to tackle evasion, avoidance and aggressive tax planning in his Summer Budget. This move is part of a plethora of changes which chancellor George… – Continue reading
