Category: Tax Planning

Government to review gas producers’ taxation – draft budget resolution for 2016

The Ukrainian government will review the system of taxation of gas production companies irrespective of their form of ownership. This is stipulated in the draft guidelines of Ukraine’s budget policy, or the budget resolution, for 2016, which was tabled by the Cabinet of Ministers in parliament. Among the other priorities… – Continue reading

Switzerland: Tax Briefing – Switzerland Takes Next Steps Towards Automatic Exchange Of Information In Tax Matters (AIA)

1. Introduction On 14 January 2015, the Swiss Federal Council opened consultations on two draft laws on the international exchange of information in tax matters. One of them deals with the OECD/Council of Europe administrative assistance convention signed by Switzerland on 15 October 2013. The other consultation deals with Switzerland’s… – Continue reading

Big Four firms consistently ‘unaware’ before tax inquiry

Representatives from “Big Four” accounting firm Deloitte were up before the Senate tax inquiry on Friday morning. They were keen to dispel any notion that their firm would have any involvement in tax avoidance. Senator Christine Milne asked if they were aware of the Deloitte document “Investing in Africa though… – 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

Auditors are not forensic investigators – Booker

Changes are in the pipeline which will have a dramatic impact on the way that auditing firms handle public-interest entities (PIEs) as from December 2016 – but Deloitte CEO Malcolm Booker is very wary about how this could work in practice. According to the legislation, auditors would have to enter… – 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

United States: Business Startup Issues That May Find You – Even If You Don’t Go Looking For Them

In my practice, I have found that a majority of my clients who create significant wealth do so through ownership of a private business or a concentrated stock position in a publicly traded company. What that means for you is that if you haven’t yet started a business or taken… – Continue reading

Mylan makes $29B bid for rival drugmaker Perrigo

Mylan-Perrigo deal would combine two generic drugmakers that recently left the U.S. for Europe. NEW YORK — In a deal that would combine two generic drugmakers that recently left the U.S. for Europe, Mylan says it wants to buy Perrigo for $205 per share, or $28.86 billion. Shares of both… – Continue reading

If they build it, will they come? ALAS Advisory Group prepares Final Program Design to present to MTC Executive Committee amidst light early interest from states

The Multistate Tax Commission’s (“MTC”) Arm’s-Length Adjustment Services Advisory Group (“the Group”) met via teleconference to continue working on the Final Program Design. States participating on the call were: Alabama, Florida, Kentucky, North Carolina, Pennsylvania, and the District of Columbia. State Interest Unexpectedly Low After the last meeting, on March… – Continue reading

Board of Adjustment Annulled the Reassessment Decision against Nokian Tyres Plc Concerning Tax Years 2007-2010

HELSINKI–(BUSINESS WIRE)–Regulatory News: Nokian Tyres plc (HEX:NRE1V) Stock Exchange Release 7 April 2015 3:15 p.m. Board of Adjustment annulled the reassessment decision against Nokian Tyres plc concerning tax years 2007-2010 The Board of Adjustment annulled the reassessment decision from the Tax Administration, according to which the Company was obliged to… – 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

Miners accused of avoiding tax in boom

Urgent changes are needed to Australian tax laws, say experts, amid claims BHP Billiton and Rio Tinto avoided paying billions of dollars in tax during the mining boom. The Australian Tax Office has the mining giants in its sights over claims they have been saving more than $750 million a… – Continue reading

Seychelles Sets Out Transfer Pricing Regime

The Seychelles Revenue Commission has issued, for comment, Public Ruling 2015-3, which explains the authority’s rules and procedures to enforce the arm’s length principle in respect of related-party transactions under Section 54 of the Business Tax Act, 2009. The Ruling states that in applying the arm’s length principle, the Commissioner… – Continue reading

Bad for business? Experts, industry insiders say part of Bentley tax plan will hurt job creation

This week, the Alabama Legislature approved the centerpiece of the Made in Alabama Job Incentive Package, which the Department of Commerce, Gov. Robert Bentley and the state’s economic developers hope will attract new companies and expansions of existing industry in Alabama. But lawmakers will soon debate another package of bills… – Continue reading

New Russian CFC Rules Will Impact Inbound U.S. Tax Planning

According to recent estimates, the number of wealthy Russians investing in the United States ballooned in 2014 as a result of political turmoil and a disintegrating ruble causing Russians to seek a safe haven for their wealth abroad. The amount of private net capital flowing out of Russia hit $120… – Continue reading

Valeant Finally Bags Salix for $11 Billion

After much of a clout about who will acquire Salix Pharmaceuticals (SLXP), Canadian Drug maker Valeant Pharmaceuticals International Ltd (VRX) completed the purchase for $11 billion last Wednesday. Salix Pharmaceuticals works in gastro instrumental drugs and it will provide Valeant with new therapeutic business. This is Valeant’s biggest buy so… – Continue reading

Tax Pros Wary After IRS Hires Quinn Emanuel Litigators

Law360, New York (April 06, 2015, 4:47 PM ET) — Microsoft Corp. recently brought to light the IRS’ hiring of litigators from Quinn Emanuel Urquhart & Sullivan LLP to assist with examining the tech company’s transfer pricing activities, and some tax professionals say the agency’s unprecedented move is troubling. In… – 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

The outlook for BEPS in 2015

National tax laws are struggling to keep pace with the rise of the digital economy and the progress of multinational companies. These factors leave gaps that are susceptible to misuse and lead to cases of double non-taxation, which undermine the integrity and fairness of tax systems around the world. The… – Continue reading

Energy company’s $11 billion transfer to Singapore rings tax avoidance alarm bells

An energy company operating in Australia transferred more than $11 billion to the low-tax jurisdiction of Singapore in a single year, heightening concerns that Australia is being duped by tax-minimising multinationals. The extraordinary scale of funds being moved out of the country by individual companies is revealed in an internal… – Continue reading

Weak tax systems, evasion behind 60% of global illicit money transfers — Report

Governments in resource-rich African countries must effectively negotiate the terms of operational contracts with mining companies and their affiliates if they are to avoid revenue losses that reduce their capacity to finance development, the African Civil Society Circle has said. The Circle is a coalition of nine civil society groups… – Continue reading

Google, Apple tax crackdown will fail without US support

Jurisdictional issues will limit success. It’s no secret that companies including Apple, Google and Amazon, seem to pay less than their fair share of tax in Australia. Despite booking huge revenues from sales to Australian customers they are able to reduce their profits in this country by shifting profits to… – Continue reading

Shome, Senapaty, Pai and Bala set up tax think-tank

BENGALURU: Parthasarathi Shome, who is chairman of the Tax Administration Reforms Commission (TARC) of the Union finance ministry, together with and former Wipro CFO Suresh Senapaty, has formed a taxation think-tank that will be based in Bengaluru.  Called International Tax Research Foundation (ITRF), the think-tank will study and understand the… – Continue reading

Africa: Weak Tax Systems, Evasion Behind 60 Percent of Global Illicit Money Transfers – Report

Governments in resource-rich African countries must effectively negotiate the terms of operational contracts with mining companies and their affiliates if they are to avoid revenue losses that reduce their capacity to finance development, the African Civil Society Circle has said. The Circle is a coalition of nine civil society groups… – Continue reading

Tax Authority to impose VAT on foreign Internet cos

A new circular says multinational corporations like Google and Facebook will pay taxes on online business with Israelis. Foreign Internet companies and another other foreign corporation with significant business in Israel must register with the VAT authorities as authorized dealers, and their transactions are liable to VAT. Under certain conditions,… – Continue reading

OECD launches tax avoidance mandatory disclosure plan

AS PART of its Base Erosion and Profit Shifting (BEPS) project, the OECD has launched a public consultation on Action 12 – the mandatory disclosure of tax avoidance strategies by multinational companies. The 83-page draft document provides examples of various disclosure regimes in place in member countries, setting out recommendations… – Continue reading

Charting the Limits of Acceptable Tax Planning in Singapore

In 2015, Singapore celebrates its 50th year of independence and also mourns the passing of its first Prime Minister Lee Kuan Yew who steered Singapore’s success for many critical years. From its origins as a British trading post in 1819, Singapore has grown into one of the busiest ports and… – Continue reading

Big business took $25 billion in tax relief in 2014, Tax Office figures show

Australia’s biggest 900 companies claimed tax deductions and exemptions worth a total $25 billion last year – enough to wipe out two-thirds of the current federal budget deficit at a stroke. As Treasurer Joe Hockey prompted a national “conversation” about tax reform, including the prospect of a higher and broader… – Continue reading

Netherlands: Record Rate Of Foreign Investment For The Netherlands

The US and Canada are fuelling a record influx of foreign investment in the Netherlands; our local expert looks at why Despite a fair bit of doom and gloom over global economy figures, foreign companies continue to grow – and they continue to look at the Netherlands to help fuel… – Continue reading

Deadline extended for filing of rollback provisions under advance pricing

Multinational companies who have filed applications for advance pricing agreements can now file their rollback applications by 30 June The income tax department has extended the deadline for filing of roll back applications for transfer pricing agreements by three months. Multinational companies who have filed applications for advance pricing agreements… – Continue reading

Netherlands causes Greece to miss out on €1.7m in tax, says report

The Netherlands’ tax regime is enabling a Canadian gold mining company to pay less tax in Greece, a report by a Dutch foundation concluded Monday (30 March). The Centre for Research on Multinational Corporations found that Greece has missed out on at least €1.7 million in tax revenues, because the… – Continue reading

Euro Unions Slam Big Four Accountancy Firms for Dodging Trillions in Tax

European trade unionists have called for the split-up of the Big Four accountancy firms, PWC, Ernst & Young, Deloitte and KPMG, who they say are using their dominant position to help multi-national companies avoid trillions of Euros in tax. The European Trade Union Confederation (ETUC) has called for the break-up… – Continue reading

BEPS Action Plan 15: Multilateral instrument for bilateral tax treaties

This article continues our series on the Base Erosion and Profit Shifting (BEPS) project, and the Action Plans that have so far been submitted, by the Organisation for Economic Co-operation and Development (OECD). We now look at Action Plan 15 on Developing a Multilateral Instrument to Modify Bilateral Tax Treaties…. – Continue reading

Sant abstains on resolution on tax transparency package

Labour MEP says tax harmonisation inhibits competitiveness of disadvantaged regions Labour MEP and head of delegation Alfred Sant has abstained on a European Parliament vote on a resolution on tax fairness. The resolution, which touches on a wide variety of tax related-issues, lays a basis for further parliamentary work on… – Continue reading