Lobbyists representing firms including Google, Amazon and Apple claim ‘fundamental flaws’ in G20-led reforms The World Economic Forum in Davos, where Google, Microsoft and Facebook executives will discuss the digital economy on Thursday. Photograph: Fabrice Coffrini/AFP/Getty Images Lobby groups representing Google, Amazon and other powerful US tech multinationals have launched… – Continue reading
Democratic lawmakers Tuesday pushed legislation to stop U.S. companies from reincorporating overseas to reduce their tax bills, saying a wave of so-called inversions last year has nearly doubled the revenue the federal government will lose from those moves over the next decade. The bill would make it tougher for U.S…. – Continue reading
Both the OECD and the EU are exploring options to change how digital businesses are taxed, while NGOs are stepping up their pressure on tax authorities to challenge large companies’ transfer pricing arrangements. No matter how robust your digital business’s transfer pricing arrangements appear to have been in the past,… – Continue reading
Outlook: The OECD’s work on corporate tax avoidance has proceeded at a faster rate than many expected According to Oxfam, on current trends the richest 1 per cent of the world’s population will have a greater share of its wealth than the remaining 99 per cent within two years. The… – Continue reading
The Tax Story in 2015: Myths, Misconceptions and Reality Checks by Aswath Damodaran, Musings on Markets Each of us believes that we pay our fair share in taxes and that it is other people that do not, and not surprisingly, we find evidence to back up our priors. I find… – Continue reading
Observers of offshore financial centres will know that post 2008 they have been weathering a perfect storm. Firstly, reduced transactional flows, simply because there is less money available for structured finance and investment generally. Secondly, a constant barrage of negative publicity, which deliberately seeks to conflate tax evasion and tax… – Continue reading
A recent clarification issued to Foreign Portfolio Investors (FPIs) clarified that fund managers of FPIs who are present in India would not be treated as permanent establishments in India, addressing the concern that the FPIs may be taxable in India to the extent attributable to permanent establishments. An extension of… – Continue reading
Amazon made its bones avoiding taxes, and its tax history could bear on its current EU troubles. Amazon got bigger and more nimble than anyone else by betting on America’s love of tax avoidance.By edging the competition with no sales tax, Amazon grew to become the poster child of sales… – Continue reading
In May of 2014, financial firm Credit Suisse AG pled guilty to serious criminal charges. The giant bank aided and assisted approximately 22,000 wealthy U.S. taxpayers (whose names Credit Suisse AG escaped having to send to the Justice Department for law enforcement) for over a decade in filing false income… – Continue reading
High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. Luxembourg’s unorthodox tax deal with Amazon was laid bare by European Commission investigators on Friday, who believe it artificially lowered and “capped” the online retailer’s tax bill,… – Continue reading
New Assistant Treasurer Josh Frydenberg has dismissed concerns from business and tax experts that changing the international tax rules could result in Australia losing mining tax revenue to nations like China, describing it as a “furphy”. Mr Frydenberg has also raised Australia’s competitiveness internationally as a concern, saying corporate taxes… – Continue reading
Wisconsin’s Democratic Sen. Tammy Baldwin reintroduced legislation this week to implement the “Buffett Rule” as part of a tax fairness package. Baldwin and Sen. Sheldon Whitehouse, D-Rhode Island, introduced a bill that would require multi-million-dollar earners to pay at least 30 percent effective federal tax rate. It would generate an… – Continue reading
House Judiciary Committee chairman Bob Goodlatte, R-Va., this week jumpstarted the sputtering effort to allow states to collect sales taxes on sales by out-of-state, mostly Internet-based, sellers. Known as “home rule and revenue return,” his plan would allow Internet purchases to be taxed – but at the rate established by… – Continue reading
The International Chamber of Commerce (ICC) has reaffirmed its active engagement in the second phase of the G20 / Organization for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) project while underscoring the importance of a coordinated and consistent approach to tax law changes. ICC continues to… – Continue reading
Earlier this month, the Inland Revenue Authority of Singapore (IRAS) released revised transfer pricing guidelines, providing a better defined view of how the IRAS will handle transfer pricing matters. IRAS has explicitly noted that the arm’s length principle should be applied on a transaction-by-transaction basis, which suggests that each transaction… – Continue reading
If you want to abandon “lawful permanent resident” status, or if you want to rely on a treaty tie-breaker to claim nonresident status, you need to take some affirmative steps. Unfortunately, the taxpayer in Gerd Topsnik v. Commissioner1 did not do so. The taxpayer, a German citizen, applied for and… – Continue reading
NEW DELHI: Top officials from IT, BPO and eCommerce sectors today requested Finance Minister Arun Jaitley to address certain issues related to taxation in the Budget 2015-16, and provide incentives for setting up data centres in the country. They also suggested that the minister look at ways to help in… – Continue reading
THE taxman has checked up on more than 3000 of the super rich it says dodged more than $1.3 billion in tax last year. So far, it says it has recouped half that money. The Australian Taxation Office said that in 2013-14 it did compliance checks on 2440 of the… – Continue reading
With foreign investment, energy security and strategic partnerships at the top of his agenda, the Indian Prime Minister Narendra Modi criss-crossed eight countries, including the US, Australia, Japan and Nepal, meeting more than 40 international leaders in the first six months of his tenure. Mr Modi is riding high on… – Continue reading
(Bloomberg) -– So how did the previously obscure term tax inversions become part of Washington parlance, fodder for the next presidential campaign and the issue that helped derail a U.S. Treasury nominee? Thank, or blame, depending on your perspective, cutting-edge tax lawyers, populist Democrats, a banana seller, a drugmaker, a… – Continue reading
Quebec Finance Minister Carlos Leitão said in December he would ask Revenu Québec to look into whether Bombardier Inc. used Luxembourg as a way to avoid paying provincial taxes. What he didn’t say was that the results of those inquiries would remain secret. Washington-based International Consortium of Investigative Journalists discovered… – Continue reading
Outlook A missive from Amazon drops into my inbox. The retailer, tech giant, delivery drone developer and candidate to replace Spectre in the next Bond movie, wants to trumpet the thousands of new jobs it created last year. Six thousand, in case you were interested, and apparently that is the… – Continue reading
Top officials from IT, BPO and eCommerce sectors today requested Finance Minister Arun Jaitley to address certain issues related to taxation in the Budget 2015-16, and provide incentives for setting up data centres in the country. They also suggested that the minister look at ways to help in growth of… – Continue reading
On 6th January 2015, the Inland Revenue Authority of Singapore (“IRAS”) released revised transfer pricing guidelines, providing a better defined view of how the IRAS will handle transfer pricing matters. These guidelines call for taxpayers to prepare and maintain contemporary transfer pricing documentation. In addition, they specify thresholds for related… – Continue reading
PROVIDENCE — With tax reform one issue that congressional Republicans and Democrats might agree on this year, U.S. Sen. Sheldon Whitehouse announced Monday his plans to introduce three bills aimed at making the super rich pay more through a “fairer” tax system and closing loopholes that allow some corporations to… – Continue reading
On December 14, 2014, the government approved a major tax reform aimed at giving legal certainty and protecting taxpayers’ fundamental rights. The tax reform will be effective once it receives the non-binding opinion of the relevant committee of the Italian parliament. The tax reform covers several topics, with developments of… – Continue reading
Shareholders typically don’t object to tax inversion deals Nathan points out that — with some exceptions — shareholders are rarely opposed to tax inversion deals.They, not unreasonably, want the firms they invest in to be as profitable as possible, so they typically feel that corporate structures designed to avoid taxes… – Continue reading
Within the framework of the BEPS (Base Erosion and Profit Shifting) action plan, adopted in July 2013, on last September 16, the OECD published its first recommendations in the form of reports on 7 of the 15 points of the action plan: Address the tax challenges of the digital economy… – Continue reading
Globally, the sphere of taxation has witnessed a constant tussle between its primary players – while governments continually strive to maximise revenue and widen the tax base through successive amendments to tax laws and streamlining tax administration, taxpayers seek to arrange their affairs in a manner so that the incidence… – Continue reading
In a new paper, the Tax Foundation has recommended that the United States should reduce corporate tax rates and amalgamate corporate and shareholder taxes. The TF points out that the US loses about 60,000 corporations per year, with about one million having been lost since the last reform of corporate… – Continue reading
A pair of Democratic lawmakers in the House and Senate have re-introduced legislation aimed at preventing the abuse of offshore tax havens by multinational companies. Rep. Lloyd Doggett, D-Texas, a senior member of the tax-writing House Ways and Means Committee, and Sen. Sheldon Whitehouse, D-R.I., a member of the Senate… – Continue reading
CDE Op-Ed CommentaryGiven the recent problems American trading companies are having in establishing bank accounts in Hong Kong, viable alternatives need to be found. These issues, which are directly related to the American IRS carrying out extensive investigations in Hong Kong concerning breaches of the new FATCA regulations, have made… – Continue reading
Already on the radar of governments and regulatory bodies around the world, recent developments with respect to the Organization for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) Action Plan are raising further the profile of oil and gas companies globally with both tax authorities and the… – Continue reading
IT IS easy to forget how fast the world has changed. The iPad is only five years old. Facebook has been with us for just a decade. Skype has just had its 11th birthday. Those have resulted in big changes to the ways we interact, but they are in turn… – Continue reading
The landmark transfer pricing case involving GlaxoSmithKline has settled on the eve of the second Tax Court of Canada trial in the matter, scheduled to commence on January 12, 2015. “Counsel for Glaxo confirmed the settlement but the details remain confidential,” writes William Innes of Rueter Scargall Bennett in Bill… – Continue reading
Chinese nationals and companies operating overseas, who hold their fortunes outside of China, will soon be required to pay taxes on their worldwide earnings come Feb 1. Part of Beijing’s New Year resolution to crack down on tax avoidance and evasion, the general anti-avoidance rule (GAAR) and new penalties will… – Continue reading
SPECIAL REPORT: IS AMERICA LOSING IT’S CORPORATE SECTOR? Corporate inversions have been the dominant tax issue over the last year and have forced a serious evaluation of the U.S. corporate tax system. While there is widespread agreement that the U.S. corporate tax code is out of step with our global… – Continue reading
South Africa has lost out on billions in tax revenue in the past decade as large corporations, wealthy individuals and criminal syndicates slipped nearly R1-trillion out of the country. A Washington DC research and advocacy group, Global Financial Integrity, believes South Africa suffered “illicit financial flows” totalling more than $122-billion… – Continue reading
Regulators have updated guidelines regarding a little-known area of tax accounting that has become a political hot potato in recent years. Transfer pricing, as the process is called, refers to the price paid by one unit of a company to another for goods, services, intellectual property or financial transactions such… – Continue reading
British Members of Parliament (MPs) have questioned the Government’s unilateral decision to push for the introduction of a Diverted Profits Tax (DPT) ahead of the completion of the Organisation for Economic Cooperation and Development’s (OECD’s) work on base erosion and profit shifting (BEPS). In a debate held in Parliament on… – Continue reading
The UK is proposing to introduce a unilateral, non-OECD co-ordinated anti-BEPS provision, referred to in the media as the “Google Tax”, with effect from 1 April 2015. The draft provision is very complex, and it will be time consuming to assess its potential impact on many common cross-border business structures…. – Continue reading
As Chinese individuals and companies head overseas in greater numbers, the country’s tax authorities are starting to follow. The Beijing billionaires who set up cryptically named companies in the British Virgin Islands to hold their fortunes are in the cross hairs. So are the Guangdong salesmen living and working in… – Continue reading
From Premier International Tax Library With the publication in September of Notice 2014-52, the IRS has made it extremely difficult for any foreign corporation that is not primarily engaged in an active business to acquire a U.S. business in exchange for its stock without risking being transformed into a U.S…. – Continue reading
CRA has launched the Electronic Funds Transfer (EFT) initiative, introduced in the 2013 Budget as one of several new measures to crack down on international tax evasion and aggressive tax avoidance. Read: Top 10 tax changes of 2014 Effective January 1, 2015, certain financial intermediaries, including banks, have to report… – Continue reading
SINGAPORE (Reuters) – Singapore is updating guidelines on an accounting practice mired in controversy for helping multinational companies minimize their tax bills, as the city-state moves more in line with a crackdown by Western governments on aggressive tax avoidance. International taxation has come under scrutiny since a quirk of “transfer… – Continue reading
With substantial amendments to SA transfer pricing legislation in April 2012 – as well as a lack of any subsequently updated or final Practice Note from SARS – much uncertainty still surrounds the realm of transfer pricing in SA, says Lauren Hart, of Webber Wentzel, in an analysis on the… – Continue reading
India enacted transfer pricing rules in 2001, which require companies to conclude international transactions with associated enterprises at an arm’s length. The legislation is primarily targeted at large business groups who engage in base erosion and profit shifting to avoid paying corporate income tax in India. This article is the… – Continue reading
Many factors influence a foreign buyer’s decision to purchase residential real estate in the United States. Generally, most of these decisions tend to be driven by concerns over political and economic uncertainty in the buyer’s home country. Most foreigners do not leave their home country, family, and friends for trivial… – Continue reading
Countries are competing to lower their tax rates to please the corporate giants, but the result is a massive collective loss of revenue. Only international coordination can wipe out the practice and defeat the negative influence of the Big Four accounting firms. Tax havens have long existed in the popular… – Continue reading
On December 28, 2014 Ukrainian Parliament has adopted the Draft law No. 1264-1 “On amending the Tax Code of Ukraine regarding improvement of tax control over transfer pricing” as of 22.12.2014 (the Draft Law). In order to become effective, the Draft law has to be signed by the President of… – Continue reading
