In the last few years, particularly following the credit crunch, there has been a tangible focus on tax avoidance and clamping down on tax planning. Overnight, the rules of the game were changed and what was previously considered to be legitimate tax planning was condemned as being aggressive and morally… – Continue reading
In a further move to make tax systems fairer, more efficient, growth-friendly and transparent, the Commission presented an Action Plan to fundamentally reform corporate taxation in the EU and published a “Top 30” list of tax havens across the world. The Action Plan sets out a series of initiatives to… – Continue reading
The 11 European nations seeking a financial-transactions tax will meet Thursday in Luxembourg in a bid to decide how to design the measure, according to European Union officials. Participating states are wrangling over which trades to tax and who should collect revenue, according to planning documents obtained by Bloomberg News…. – Continue reading
The reported resurgence of cross-border mergers involving US companies that then move their corporate headquarters abroad shows that anti-tax avoidance measures passed last year were “a sticking plaster rather than a long-term solution”, an expert has said17 Jun 2015 The Financial Times reported (registration required) that demand for corporate ‘inversion’… – Continue reading
The U.S. Model Income Tax Treaty (the U.S. Model Treaty) generally represents the United States’ opening position in treaty negotiations. As a result, when changes to the treaty are proposed, international tax practitioners should be aware of the potential impact those changes can have on their existing inbound U.S. structures…. – Continue reading
Indian Government has finally heeded the clarion call of the taxpayers who were besieged by transfer pricing adjustments.That said, while an earnest beginning has been made, it would bring the matter to a perfect close if the apparent deficiencies in the draft rules were to be addressed Since its introduction… – Continue reading
Tax avoidance can be defined as aggressive tax-planning strategies and structures by multinational companies that take advantage of the gaps or mismatches in tax rules to shift profits to low-tax locations. While many countries around the world have either general or specific anti-avoidance legislation to tackle this problem, the current… – Continue reading
Foreign companies are likely to be penalised for failing to submit statements of transactions above Tk 3 crore with their associated overseas entities. The National Board of Revenue took the measure to curb illicit fund transfers and tax evasion. The penalty will be equivalent to 2 percent of the value… – Continue reading
Zambia Revenue Authority -ZRA- Commissioner General Berlin Msiska says the authority has granted tax deferment to some mining firms following cash flow challenges in the sector. Mr. Msiska says the deferment was given after the said firms applied because of challenges facing the sector and was granted in accordance with… – Continue reading
Windhoek Namibia’s Inland Revenue has established a transfer pricing unit. “We will be asking you for transfer pricing supporting documents soon,” said Acting Commissioner for Inland Revenue, Justus Mwafongwe, at the recent annual tax symposium hosted by the PwC’s Namibia Business School. Mwafongwe confirmed that the draft amendment bills to… – Continue reading
Bring together an impressive group of respected tax professionals from all over Africa, International Bureau of Fiscal Documentation (IBFD) is set to hold “Africa Tax Symposium, Trends in International Taxation: An African Perspective,” from June 18-19, 2015 in Livingstone, Zambia. IBFD announces that its inaugural The two-day event will present… – Continue reading
US companies have regained their appetite for controversial foreign takeovers that allow them to move overseas and escape US taxes, in spite of a White House crackdown to restrict so-called tax inversions last year, reports the Financial Times. According to several senior corporate advisers in the US and Europe, demand… – Continue reading
The LuxLeaks financial scandal, which entailed disclosure by the International Consortium of Investigative Journalists of tax rulings, galvanized public opinion and gave rise to the creation of TAXE, the European Parliament’s special committee on tax rulings. This article explains why TAXE was created and shares with you highlights from the… – Continue reading
With revenue from petroleum taxes at its lowest point in fifteen years, Nigeria is under even more pressure to tackle tax evasion and pursue other revenue enhancing initiatives. Indeed, experts have found that tax evasion plays a significant part in the over $50 billion that the continent loses every year… – Continue reading
MUMBAI: With its subsidiary Cairn India facing Rs 20,495-crore tax notice, billionaire Anil Agarwal-led Vedanta Group today said it is “frustrated” by the tax demand raised on it using retrospective legislation. The Income Tax Department had in March slapped a Rs 20,495 crore tax demand on Cairn India for failing… – Continue reading
Transfer pricing has emerged as a key focus area both globally and locally. From an international scene, the OECD/G20 venture — a club of advanced countries in Europe and North America, has been working on action plans to help tax administrations deal with Base Erosion and Profit Shifting (BEPS) project…. – Continue reading
Multinational firms said to be ‘cheating’ African countries out of billions of dollars that could be used for health care and education. G7 leaders Monday pledged to reform the international tax system by minimizing transfer pricing, according to Public Finance International. Transfer pricing involves internal transactions between a large company’s… – Continue reading
The Diverted Profits Tax (DPT), known by many as the “Google Tax”, is intended to stop large groups diverting profits from the UK by seeking to avoid creating a UK permanent establishment or using arrangements or entities which lack economic substance to exploit tax mismatches. Tax mismatches occur where intra-group… – Continue reading
The Argentine Supreme Court ruling on Toepfer International, a commodity exporting firm, has finally been published, tw o months after the decision, providing lessons for BEPS action 10 (cross border commodity transactions). This case, AFIP v Alfred C Toepfer Internacional, belongs to the first group of three controversies, related to… – Continue reading
NEW DELHI — India’s goal of a friendlier tax regime for global companies to help power China-beating economic growth is hitting a manpower hurdle. Fewer than 20 officials face the complex task of working with hundreds of multinationals on pacts to avert tax rows, people familiar with the matter said,… – Continue reading
In a year when technology deals are set to break records, U.K. targets are proving popular. About $20 billion of deals were struck for British technology companies in the last 12 months, almost double the amount spent a year earlier. U.S. buyers accounted for about half the acquisitions. They included… – Continue reading
Shire is considering a move to acquire Swiss biopharma company Actelion in a move that would boost its rare disease portfolio. According to a report in the Sunday Times, Shire made an informal approach to Actelion about a possible £12.4bn takeover several weeks ago, but the opening bid was turned… – Continue reading
Demands for greater transparency from business about their tax affairs have prompted more than half of all FTSE 100 companies to disclose information about their approach to taxation, compared with less than a third two years ago, reports the Financial Times. The rise in disclosures is a sign of the… – Continue reading
New Delhi/Mumbai: India’s goal of a friendlier tax regime for global companies to help power China-beating economic growth is hitting a manpower hurdle. Fewer than 20 officials face the complex task of working with hundreds of multinational companies (MNCs) on pacts to avert tax rows, people familiar with the matter… – Continue reading
Transfer pricing has been raking in significant tax controversies and has also emerged as one of the leading arms of the Indian tax law. Transfer pricing has been raking in significant tax controversies and has also emerged as one of the leading arms of the Indian tax law contributing a… – Continue reading
U.S. agricultural and crop chemicals giant Monsanto (MON) could shift its headquarters to Europe in a tax-savings strategy if the company succeeds in its $45 billion unsolicited bid to merge with rival Swiss rival Syngenta. Details of the tentative plan came Monday as Syngenta reiterated its opposition to the transaction,… – Continue reading
08/06/2015 – Pushing forward efforts to boost transparency in international tax matters, the OECD today released a package of measures for the implementation of a new Country-by-Country Reporting plan developed under the OECD/G20 BEPS Project. The Country-by-Country Reporting Implementation Package will facilitate a consistent and swift implementation of new transfer… – Continue reading
OECD propose country-by-country reports on their financial affairs Proposed new obligations on multinationals to produce country-by-country reports on their financial affairs will have a “massive impact” on them, a leading member of the Organisation for Economic Development and Cooperation has said. Pascal Saint-Amans , director of the Center for Tax… – Continue reading
Chevron Australia boss Roy Krzywosinski was complaining two weeks ago that taxes were too high in Australia. It was a pretty suave call from Krzywosinski. The latest financial statements for Chevron Australia Holdings show the company not only managed to avoid paying tax last year but it even pulled off… – Continue reading
The resurgent interest in transfer pricing abuse by multinationals might be missing the first “link in the chain” – the shifting of profits inside South Africa to the detriment of empowerment partners, workers, communities and the economy. This is the emerging line from a prominent think-tank, the SA Mining Development… – Continue reading
Tax administrators would be allowed to use hindsight to evaluate the appropriateness of transfer-pricing decisions made by companies in transactions involving hard-to-value intangible assets under an approach proposed by the Organisation for Economic Co-operation and Development (OECD) on Thursday. The OECD’s discussion draft looks at the issue of arm’s-length pricing… – Continue reading
A paper production line of SAScoat Viet Nam. The company is suspected of engaging in transfer pricing. HA NOI (Biz Hub) — The Debt and Asset Trading Corporation (DATC) has asked the General Department of Taxation to investigate SAScoat Viet Nam for transfer pricing, online newspaper Investment said. The request… – Continue reading
June 5: The Organisation for Economic Co-operation and Development (OECD) yesterday released a discussion draft concerning work in relation to Action 8 under the base erosion and profit shifting (BEPS) project concerning hard-to-value intangibles. Read the BEPS Action 8 discussion draft [PDF 62 KB] The following discussion provides initial impressions… – Continue reading
IN the wake of budgetary constraints, the government of Tanzania is tightening transfer pricing regulations and bolstering its tax enforcement actions in order to create new revenues, and in doing so, has increased the administrative compliance cost and burden for companies. Indeed, the government’s apex body charged with the administration… – Continue reading
Medtronic is on the lookout for early-stage technologies developed by medical device firms in the United States, as well as larger acquisitions that can help the company implement a three-pronged strategy, in the wake of its $43 billion merger with Covidien. The tax inversion deal allowed Medtronic to relocate to… – Continue reading
A great deal has been written and spoken about tax avoidance in recent years. Much of it has been ill-informed, tendentious or just plain wrong. Very little of it has made it any easier for a taxpayer or an adviser to know where the limits lie. Add to that the… – Continue reading
PLATINUM producer Lonmin came under renewed attack by Dick Forslund from the Alternative Information and Development Centre on Tuesday for its use of offshore entities to shift hundreds of millions of rand around the group. Using data presented at the Farlam commission of inquiry, Mr Forslund issued a report into… – Continue reading
The United States has the most damaging business tax system in the developed world because it taxes its businesses at high rates, taxes them on their worldwide income and denies them the ability to deduct the cost of their investments at the time they make them. There is wide agreement… – Continue reading
THE South African Revenue Service (SARS ) is to significantly beef up its capacity to deal with base erosion and profit shifting, which has received intense focus by MPs over the last few months. SARS commissioner Tom Moyane said on Wednesday 24 more tax specialists would be employed in the… – Continue reading
Law360, New York (June 3, 2015, 3:24 PM ET) — Final rules released Wednesday by the Internal Revenue Service meant to deter corporate inversions retain a strict bright-line rule that subjects an inverted company to sanctions if it does not have a substantial business presence in a foreign country, despite… – Continue reading
ANALYSIS Dakar, Senegal — Capital flight and illicit financial flows represent missed opportunities for generating state revenue desperately needed to finance key sectors of West Africa’s economy, tackle poverty and invest in social protection and safety nets. Though the exact amount lost annually is debated, the deficit is significant and… – Continue reading
Microsoft Corp. and the IRS are back in court, this time fighting about the U.S. tax agency’s interest in hiring David Boies, the lawyer who beat Microsoft in an antitrust case in 2000. The software company filed a federal lawsuit May 29 in Seattle, marking the latest legal flurry over… – Continue reading
The five biggest suppliers of publicly subsidised medicines in Australia recorded sales of nearly $5 billion last year but paid an average of just $10 million each in company tax. Research by the Parliamentary Library, obtained by Fairfax Media, has disclosed the tax contribution of multinational pharmaceutical companies, including Pfizer… – Continue reading
A “very interesting political situation” can be expected in the autumn when a number of different strands of the ongoing European, and global, debate on what to do about aggressive tax planning by multinationals, come together, one of the players involved said during a recent visit to Dublin, reports Irish… – Continue reading
Africa is known as the ‘paradox of plenty’. How can a continent so rich in natural resources be so poor? Economic growth is predicted to increase by 4.5% across the continent this year, despite falling oil prices and the Ebola crisis. South Africa’s economy, the second biggest in Africa is… – Continue reading
New Zealand: Budget 2015 The New Zealand Budget was handed down on 21 May 2015 and included a new tax on residential property sold within two years of purchase (with some exceptions). For further information on the New Zealand Budget see PwC New Zealand’s Budget commentary. New Zealand: Issues paper… – Continue reading
Avago Technologies Ltd.’s pending takeover of Broadcom Corp. taps an arcane tax structure that has being dusted off amid a rise in cross-border mergers. Avago said it is prepared to offer Broadcom shareholders special partnership units that would defer any taxes triggered by the $37 billion tie-up, which was announced… – Continue reading
The executive chairman of Walgreens Boots Alliance said the Deerfield-based drugstore chain was made a “whipping boy” by the Obama administration and elected officials opposed to corporate tax inversions. “The Obama administration and (Treasury Secretary Jack Lew) were taking the opportunity to select any company that was even thinking about… – Continue reading
With regard to direct tax, the government promulgated in 2012 a law named ‘Transfer Pricing’. The law is scheduled to be effective from July 01, 2015. Transfer pricing is a globally common phenomenon. In different countries of the world, this law is in existence. According to the best international practice,… – Continue reading
Portugal can be a very attractive country to live in from a tax point of view. The inheritance tax regime is very benign here, and there is no wealth tax. Tax efficient arrangements can lower tax liabilities on your investment and pension income. And if you are a new resident,… – Continue reading
