Ireland’s Horizon Pharma has launched a hostile takeover bid for Depomed of the US after being frustrated in its efforts to enter negotiations about combining the two companies. Horizon was a US company until September 2014 when it closed a $660m takeover of Irish company Vidara Therapeutics just days before… – Continue reading
The Australian Taxation Office has warned companies it will be focusing on money attributed to offshore marketing hubs and will use its stronger transfer pricing powers to go after them, reports the Sydney Morning Herald. Australian companies sent more than AU$100 billion to related parties in the low-tax nation of… – Continue reading
“American” corporations that “invert,” or establish offshore domiciles in order to avoid payment of U.S. taxes, are still feeding at the government trough. They have benefited from American laws, courts and infrastructure, becoming obscenely wealthy – yet refuse to return the favor to We The People. And who and what… – Continue reading
Silver streaming company Silver Wheaton Corp said it received a proposal from the Canada Revenue Agency (CRA) on Monday to reassess the company under various income tax rules. The CRA is seeking to tax streaming income earned by the company’s foreign units and said that Silver Wheaton’s taxable income should… – Continue reading
The UK Government’s goal is to make the UK the best place in the world to locate an international business; it has one of the most open economies globally, a highly skilled workforce, access to capital markets, a first-class infrastructure, and a highly competitive corporate tax system. UK tax policy… – Continue reading
A corporate tax reform coalition blasted President Obama’s international tax proposals on Tuesday, saying they would accelerate the sort of offshore maneuvers that Democrats want to eliminate. The Alliance for Competitive Taxation said that the White House’s proposal to impose a minimum tax on multinational corporations’ foreign earnings would only… – Continue reading
Booming demand for offshore tax services will trigger a £240m takeover deal involving a unit of Appleby Global, Sky News learns. The booming demand for offshore trust and fund administration services will be underlined in the coming days by a $370m (£238m) takeover deal involving Bridgepoint, the London-based buyout firm…. – Continue reading
Ukraine’s Cabinet of Ministers will remove Austria from the list of countries transactions with whose counterparties are subject to control under the law on transfer pricing on August 1, 2015. This is stipulated in Cabinet resolution No. 677 dated July 1, 2015, which is available on the government website on… – Continue reading
The ATO is looking to catch more big-time tax cheats by hiring new specialist public servants, just months after paying more than 400 of them tens of millions of dollars to leave. The Tax Office is advertising technical specialist jobs at APS 6, EL1 and EL2 pay levels in two… – Continue reading
Access to company data is vital if policymakers are to understand how changing regulatory requirements influence performance Much focus has recently fallen on the issue of tax avoidance, as research on the subject has increasingly shown that the global economy is losing out on billions of dollars to a byzantine… – Continue reading
VANCOUVER, July 6, 2015 /PRNewswire/ – Silver Wheaton Corp. (“Silver Wheaton” or the “Company”) (TSX:SLW) (NYSE: SLW) announces that it has received a proposal letter dated July 6, 2015 (the “Proposal”) from the Canada Revenue Agency (the “CRA”) in which the CRA is proposing to reassess Silver Wheaton under various… – Continue reading
As far as Sebi’s role goes, it might spread itself too thin if it chases every whiff of a tax scandal Lately, there have been a string of orders by the Securities and Exchange Board of India (Sebi) alleging misuse of stock exchanges for tax evasion. The market regulator’s investigations… – Continue reading
MUMBAI: The Central Board of Direct Taxes has signed a taxation rate agreement with BNP Paribas India Solutions, the local arm of the European bank, as part of efforts to reduce disputes with foreign companies over tax-related issues. BNP Paribas Solutions is the first company in the information technology and… – Continue reading
The Advance Pricing Agreement (‘APA’) program was introduced in August 2012. APA helps a tax payer to ascertain the transfer pricing between related party transactions upfront to avoid any litigation. The APA program has been a success and there has been a rise in the number of applications filed year… – Continue reading
On June 24, 2015, the World Customs Organization (WCO) published the WCO Guide to Customs Valuation and Transfer Pricing (the Guide). The primary purpose of the Guide is to assist customs officials in understanding the relationship between customs valuation and transfer pricing. However, the WCO also recommends members of the… – Continue reading
A firm directly involved in one of Europe’s largest tax scandals is now giving tax advice to the European Commission and member states. The audit firm, PricewaterhouseCoopers (PwC), sits in a group called the EU Joint Transfer Pricing Forum. The forum’s been around for years, but its mandate was recently… – Continue reading
Confidence has returned to real estate markets in Europe, and London is still a firm favourite with investors, offering vast tax-efficient opportunities for Qatari investors, according to Aqua Group, the first offshore trust company to receive licence from the Qatar Financial Center (QFC). In view of the need for better… – Continue reading
On June 8th 2015, the OECD released a new package of measures for the implementation of a new Country-by-Country (CbC) reporting plan developed under the OECD/G20 Action Plan on Base Erosion and Profit Shifting (BEPS) Project, aimed at improving transparency in international tax matters. The CbC reporting plan was founded… – Continue reading
Apart from placing full time expatriate employees in China, as an investor you may often need to send staff from the parent company to China to complete temporary projects. Common examples include quality control, engineering projects, training or consultancy. However, what many foreign investors don’t know is that such visits… – Continue reading
Multinational pharmaceutical companies are unable to assure Australians they are not being “ripped off” on the price of medicines as a result of their complex global supply chains. The Australian heads of nine of the biggest global drug suppliers were forced into the embarrassing admission on Tuesday after backing themselves… – Continue reading
OECD and G20 Action Plan on Base Erosion and Profit Shifting (BEPS) was adopted in 2013. It consists of 15 actions including transfer pricing, taxation of controlled foreign corporations (CFC), digital commerce, hybrid instruments, international information exchange, tax treaty shopping etc. In 2013, OECD working group prepared draft documents regarding… – Continue reading
The Executive Directorate of Revenue has announced that as part of the changes in the audit and tax collection system, it will oversee the transfer prices of companies headquartered abroad. In addition to the implementation of electronic billing and other changes that aim to improve the supervision of tax collections,… – Continue reading
Action 3 of the OECD’s Base Erosion and Profit Shifting (BEPS) agenda promised to address how countries could use controlled foreign corporation (CFC) rules to combat BEPS. Unfortunately (or fortunately, depending upon one’s vantage point), as is pretty much universally agreed, the OECD’s draft report on CFC rules (the “draft”)1… – Continue reading
The German government has announced plans to incorporate Action 13 (guidance on transfer pricing documentation and country¬by¬country (CbC) reporting) of the OECD’s BEPS project into local legislation. The wording of the new law is being drafted and may be published some time in autumn of this year. It is the… – Continue reading
VietNamNet Bridge – It is clear that the US has been increasing its investments in Vietnam and that Vietnam needs to grab the great opportunities brought by the capital flow. Dr Vu Chi Loc from the Hanoi Foreign Trade University noted that Vietnam’s deep integration into the global economy in… – Continue reading
OECD common reporting standard On 3 June 2015, the Treasurer announced that Australia had signed the Organisation for Economic Co-operation and Development’s (OECD) common reporting standard (CRS) Multilateral Competent Authority Agreement which enables automatic exchange of CRS information between countries. Australia proposes to implement the CRS from 1 January 2017,… – Continue reading
CUSTOMS and Excise would be adding four mobile container scanners that would become operational within the next two months. The scanners would be used for locating narcotics, arms and ammunitions and explosives as goods arrive in the country. Customs would also be acquiring six more sniffer dogs to assist its… – Continue reading
THE focus of a high-level inquiry into corporate tax avoidance will move to some of the globe’s biggest drug companies during hearings today. After revealing details of the tax minimisation strategies at Google, Apple and Microsoft, the Senate’s Standing Committee on Economics will hear from pharmaceutical executives in Sydney. Among… – Continue reading
A common mistake when analyzing the tax implications of a cross border transaction is to jump too quickly to the ramifications of a tax treaty without first having a clear handle on the tax implications under the Income Tax Act (Canada) (“ITA”). A related issue is that even though a… – Continue reading
By ESTHER MSETEKA, Mazabuka LUSAKA Stock Exchange (LuSE) chief executive officer Brian Tembo says there is need for Government to formulate a capital market policy that links foreign direct investment to listing. Mr Tembo said the country needs to find ways which can help create linkages between companies that invest… – Continue reading
Multinational drug companies are presenting a united front ahead of their appearance at the Senate’s corporate tax avoidance inquiry, insisting they are honest, ethical and pay their fair share of tax. Nine pharmaceutical companies, which between them receive billions of dollars in taxpayer-subsidised sales via the Pharmaceutical Benefits Scheme, will… – Continue reading
The Italian Supreme Court has ruled that transfer pricing adjustments applied by the tax authorities may be deemed legitimate even if they have been applied after a comparison between the transactions assessed and the ones carried out by and among third independent parties. In the case at issue, the tax… – Continue reading
Corporate entities are often deemed to be related in terms of excise law if (a) they are interconnected undertakings and / or (b) they have mutuality of interest in the business of each other. Excise and Customs law are the oldest surviving indirect tax legislations in India. Despite this, till… – Continue reading
The challenges faced by multinational enterprises (MNEs) in navigating the interface of transfer pricing and customs valuation rules is not a new phenomenon. However, due to a marked increase in recent years of the number of countries introducing or updating their transfer pricing legislation and scaling up their auditing and… – Continue reading
ICC has welcomed a new World Customs Organization’s (WCO) Guide to Customs Valuation and Transfer Pricing which includes ICC proposals for more coherent tax and customs revenue collection. Released this week as part of a new WCO Revenue Package, the new guide provides concrete guidance on revenue collection to governments… – Continue reading
U.S. lawmakers are exploring a new corporate tax break that would benefit companies already adept at avoiding taxes. The idea — known as a patent box or innovation box — would impose a lower tax rate on income generated from patents and other intellectual property housed in the U.S. This… – Continue reading
When Indian President Pranab Mukherjee gave Finance Bill 2015 his assent on May 14, most provisions were largely hailed as improvements to the business environment in India. Others, while seen as primarily positive, have been the cause of some concern. One such provision changes the residency test for companies doing… – Continue reading
Nguyen Anh Tuan, head of the agency, said at a press conference in mid-May that there were signs of dairy manufacturers and distributors committing transfer pricing. The majority of materials and finished dairy products are imported from overseas for domestic production and distribution as directed by the foreign partners. Therefore,… – Continue reading
Last year at this time, more than a dozen U.S.-based corporations were threatening to move their legal residence to foreign tax havens in a paper transaction known as an inversion. Facing a wave of public opposition, some corporations abandoned these inversion attempts—notably, drugstore chain Walgreens put its plans on ice,… – Continue reading
Former Prime Minister Alfred Sant said that as a matter of urgency all national parliaments should be active participants and decision makers in the process which the European Commission has been launched on the harmonisation of taxes in the eurozone. Dr. Sant said that having the same tax structures for… – Continue reading
Thailand’s Council of State is deliberating the country’s first law on transfer pricing. If passed the bill w ould allow Thailand Revenue Department (TRD) officials to enquire into profits from crossborder transactions of multinational companies. The final draft of the law w as approved by the Cabinet in May this… – Continue reading
It’s the $2 trillion question. That’s roughly how much U.S. multinational corporations have stashed offshore — money that both Republicans and Democrats would like to tap for revenue and cash that even some companies wouldn’t mind paying a reduced tax rate on. Democrats and some Republicans are interested in using… – Continue reading
Tax havens are used for more than just saving money. When companies take advantage of their lack of transparency for more sinister activities, shareholders can lose out. When Enron collapsed in 2002 investigators were faced with a convoluted network of subsidiaries and offshore partnerships stretching from the Cayman Islands to… – Continue reading
After a controversial political debate, the Swiss voters have decided to reject the popular initiative to introduce a federal inheritance tax with a vast majority of 71.7% in the popular vote of 14 June 2015.. The 26 Cantons also unanimously rejected the the popular initiative. The clear result shows that… – Continue reading
Companies registering their intellectual property in Israel will be charged only 5% tax on dividends. The committee considering changes in the Law for the Encouragement of Capital Investments, headed by former Ministry of Finance director general Yael Andorn, is recommending extension of the tax break granted under the law to… – Continue reading
The United States has been criticized on more than one occasion for failing to be a meaningful participant in the OECD’s multi-pronged initiative to address base erosion and profit shifting (BEPS). Some commentators have even gone so far as to accuse the United States of actively working against the BEPS… – Continue reading
THERE have been a number of challenges in implementing the 2015 mining tax regime, says Zambia Revenue Authority commissioner general Berlin Msiska. And Msiska says there is an immoral aspect to tax avoidance, even if it might be said not to be illegal. Msiska said in an interview that tax… – Continue reading
Someone once said that a good tax system enables the government to pluck the feathers from the taxpaying goose with the least amount of hissing, says Rod Houng-Lee. The least amount of hissing occurs when the law is simple and clear. The hissing increases exponentially when the law is more… – Continue reading
MUMBAI: The Central Board of Direct Taxes (CBDT) recently issued clarifications on the rollback provisions available under the advance pricing agreement (APA) mechanism in the arena of transfer pricing. While some clarifications – such as availability of a rollback even when a revised income tax return is filed, or the… – Continue reading
International tax rules will soon change, but companies’ behaviour may change sooner. There will soon be fewer places for multinational companies and ultra-rich individuals to squirrel away money. In November leaders of the G20 are expected to adopt a full range of measures to curb the practices of base erosion… – Continue reading
