Category: Tax Planning

MotoGP » Emotional Marquez responds to Andorra critics

MotoGP champion Marc Marquez hit hard by criticism of a planned move to Andorra, will continue to pay tax in Spain. MotoGP champion Marc Marquez gave an emotional response to the criticism he has received within Spain over a reported move to Andorra. Speaking during Friday’s preview for the Superprestigio… – Continue reading

Bombardier among companies using legal tax havens at expense of home country

MONTREAL – The problem is not that Bombardier Inc. played a complex shell game since at least 2010 by refinancing and redirecting US$500 million of its financing activities to Luxembourg, a notorious tax haven. It’s that it does so legally — and is hurting its home country despite being one… – Continue reading

American lawmakers will put their rubber stamp on global profit-shifting

All those Dutch sandwiches, double Irishes and Luxembourg, uh, lunchboxes that US multinational companies use to defer taxes and shift profits abroad are expected to be re-empowered today when the Senate votes to enact a one-year tax extension package. Included in the package is a renewal of two breaks, one… – Continue reading

Taxing Diverted Profits: The Empire Strikes Back

There’s big news from across the pond. The U.K. government’s Autumn Statement (formerly known as the pre-Budget report), released December 3, promises to change how multinational corporations will be taxed – and offers a cautionary tale for would-be U.S. tax reformers. Britain will introduce a “diverted profits” tax, targeting corporations… – Continue reading

European Commission boss Juncker admits he’s ‘weakened’ by tax scandal

Jean-Claude Juncker under pressure over his deals as PM of Luxembourg The arch-federalist EU chief is alleged to have courted tax avoidance deals He has now admitted he has been ‘weakened’ by the revelations It emerged his regime agreed deals with Walt Disney and Koch Industries Jean-Claude Juncker has admitted… – Continue reading

Putin Says Tax Rules Should Remain Unchanged

Russia’s President, Vladimir Putin, has said that tax legislation should remain unchanged for the next four years, and that he wants a one-off tax amnesty for individuals who repatriate capital to Russia. Addressing the Federal Assembly, Putin said that there is a need for stable legislation and predictable rules, which… – Continue reading

Disney Uses Complex Tax-Avoidance Scheme, ‘Lux Leaks’ Files Show

Florida Center for Investigative Reporting The Walt Disney Co. generates $18.2 billion per year in economic activity in Florida and and is responsible for more than one in every 50 jobs in the Sunshine State, according to a study the company paid for in 2011. But here’s something Disney won’t… – Continue reading

Finance Ministry Reacts To Latest ‘LuxLeaks’

Responding to another leak, the Luxembourg Finance Ministry has said that the advance tax rulings issued to multinationals by the country’s tax authority are not, and never have been, secret. The Ministry issued a statement on December 10 acknowledging the publication by the International Consortium of Investigative Journalists (ICIJ) of… – Continue reading

Bezos Ducks US Tax Court Subpoena In Transfer Pricing Case

Law360, New York (December 11, 2014, 3:21 PM ET) — Amazon.com Inc. CEO Jeff Bezos got out of having to testify in a suit concerning a Luxembourgian subsidiary and tax obligations for the years 2005-2006, when the U.S. Tax Court granted his motion to quash the Internal Revenue Service’s subpoena… – Continue reading

Burger King will avoid $117m in tax from Tim Hortons merger, activists say

Findings from Americans for Tax Fairness directly contradict Burger King’s earlier insistence that the merger would create ‘no tax benefit’ Burger King acquires Tim Hortons and calls Obama’s bluff on tax Burger King stands to avoid paying hundreds of millions of dollars in US taxes if it completes its pending… – Continue reading

Luxembourg tax files: Juncker admits position weakened by scandal

Jean-Claude Juncker breaks silence to say revelations are personally damaging as calls increase for harmonisation of EU tax rules European Commission president Jean-Claude Juncker has admitted that his position has been weakened by a scandal exposing Luxembourg’s role in corporate tax avoidance schemes. Juncker survived a no-confidence vote in the… – Continue reading

US Republican presidential hopeful Jeb Bush uses UK fund that could lower his American tax bill

Jeb Bush, a front-runner to become the Republican Party’s next presidential nominee, has used Britain to set up a private equity fund that could possibly allow it to avoid paying tax in America. The potentially damaging revelation was uncovered by the financial news wire Bloomberg and could pose a serious… – Continue reading

Commissioner expresses ‘reasonable doubt’ over Apple tax deal

The new EU Competition Commissioner has said there is reasonable doubt about whether Apple’s tax arrangements with Ireland were legal. In her first comments on the investigation into the US tech giant’s tax affairs in Ireland, the Danish Commissioner Margrethe Vestager said the case remained open. This is despite Minister… – Continue reading

Experts disagree that tax-dodging offshore companies less popular

Exports of Ukrainian goods through offshore companies fell by 90 percent in the first nine months of this year, according to the State Fiscal Service, dropping to $334 million. British Virgin Islands, a jurisdiction known for the lack of transparency, remains the most popular offshore destination with Ukrainian companies, attracting… – Continue reading

Next move: Thailand as HQ and trading hub of Asean

THAILAND has offered tax incentives for regional operating headquarters and international procurement centres for more than 10 years, but there are fewer than 300 companies operating ROHs or IPCs. Recently, the Cabinet approved a measure promoting Thailand as the shared-services hub of the Asean Economic Community. It is expected that… – Continue reading

Tax Reform In 2015 Can Impact Apple

Summary Corporate tax reform is getting closer, repatriation of foreign profits is a possible outcome. Reform may end the practice of deferment, meaning overseas cash hordes will no longer be part of common corporate practice. Many large U.S. companies will have decisions on how to use funds that are no… – Continue reading

Ferrari Said to Weigh Moving Fiscal Base Outside Italy

Ferrari SpA is considering moving its fiscal residence outside Italy to save on corporate taxes as the supercar maker prepares for its spinoff from Fiat Chrysler Automobiles NV (FCAU), people familiar with the matter said. The manufacturer, which uses the colors of the Italian flag in its logo, may follow… – Continue reading

New UK ‘diverted profits tax’ on multinationals will raise very little tax, says expert

A new UK tax on the ‘diverted profits’ of multinationals operating in the UK “is probably not needed, will be hard to apply and will raise little money” according to one expert. 10 Dec 2014 Corporate tax Tax International tax UK Europe Heather Self of Pinsent Masons, the law firm… – Continue reading

MotoGP: Marc Marquez rumoured to have moved to Andorra for tax reasons

TWICE-WORLD champion in MotoGP Marc Márquez is reported to have moved to Andorra to reduce his taxes. The 21-year-old, who scooped up the top title in his rookie year, 2013, and repeated the performance the following season, is said to be earning around 10 million euros a year – but… – Continue reading

Hong Kong firm financing owners of 3 mobile network had secret tax deal

Hutchison Whampoa had profit of €429.6m but paid just €65,067 tax in Luxembourg A Luxembourg company that provides indirect financial support to 3 Ireland, is among the latest batch of entities found to be availing of secret tax deals in Luxembourg. Hutchison Whampoa Europe Investments Sarl (HWEI) – part of… – Continue reading

Vodafone Vs I-T dept: ITAT rules in favour of tax dept

This transfer pricing dispute arose from transactions involving Vodafone in 2007-08. The I-T department had red flagged the sale of call centre business to Hutchison Whampoa Properties India and the assignment of Call Options. n the latest from Vodafone’s Rs 8,500 crore trasfer pricing case versus the Income Tax department,… – Continue reading

EU finance ministers agree on measures against tax avoidance

RUSSELS, Dec. 9 (Xinhua) — European Union (EU) finance ministers Tuesday agreed on two taxation measures towards combating corporate tax avoidance and aggressive tax planning. According to a statement, finance ministers have given their political backing to the anti-abuse clause of the Parent Subsidiary Directive and to the mandatory exchange… – Continue reading

BREAKING NEWS — Palm Beach Billionaire David Koch, Brother Charles Named in Euro Tax Haven Scandal!

LUXEMBOURG  — Palm Beach billionaire David Koch and his equally-loaded brother Charles got the government of Luxembourg to sign a secret, custom-made deal that allowed their companies to save hundreds of millions of dollars that otherwise would have been taxed in the United States. On its website this morning, the… – Continue reading

Beating the big business tax minimisation schemes

Peter Mac Swedish “flatpack” furniture manufacturer IKEA has suffered a number of blistering mass media attacks for business practices that reduce their Australian tax liabilities to a tiny fraction of the company’s profits here. The criticism is certainly justified. Most ordinary working taxpayers, as well as companies that don’t engage… – Continue reading

Malta: A Question Of Substance

Malta continues to receive glowing reviews internationally as a stable financial services centre of repute within the European Union. Over the past fifteen years, Malta has moved seamlessly from being an offshore to an onshore jurisdiction, through the implementation of several legal, tax and regulatory rules intended to stimulate domestic… – Continue reading

Ireland: Property Investment Structures In Ireland: Irish Investment Opportunities

In recent times there has been a welcome return to activity in the Irish real estate market. Overseas investors have been circling and private equity groups have started investing heavily in Irish real estate amid confidence that the Irish economy has stabilised and is returning to growth. In this briefing… – Continue reading

Israeli Swiss Bank Tax Evasion Investigation Widens

A senior figure is suspected of secretly keeping accounts in a Swiss bank that were not reported to the tax authorities in Israel, in an affair called the “Swiss Bank Affair,” sources inform “Globes.” Israel Tax Authority investigators conducted a search of the senior figure’s home. As in the information… – Continue reading

UK: Moving to the UK from France

Some statistics rank London as the fourth largest ‘French’ city by population, and the number of French individuals moving to the UK is growing. This is not surprising – the UK offers a highly favourable tax regime for ‘non-domiciled’ individuals moving to the UK, while entrepreneurs, professionals and high net… – Continue reading

Revenue Quebec looking into whether Bombardier is using a European tax haven

Quebec’s finance minister says he understands Bombardier Inc. pays its taxes according to Quebec and Canadian laws and that “we receive what we should receive.” But nevertheless, Carlos Leitão said he has asked Revenue Quebec to look into whether Bombardier is using a European tax haven to avoid provincial taxes…. – Continue reading

Disney and Microsoft dragged into Luxembourg tax avoidance scandal engulfing EU chief Jean-Claude Juncker

Grand Duchy accused of allowing multinational firms to pay virtually no tax Leaked documents reveal more firms used Luxembourg to lower tax There is no suggestion that the tax schemes used by firms are illegal But scandal has dragged in Luxembourg’s former PM Mr Juncker Giant US businesses Disney and… – Continue reading

Jersey: Chancellor Must Address Root Causes Of Tax Evasion

In advance of the UK Chancellor’s Autumn Statement, Geoff Cook, CEO of Jersey Finance said: “The Chancellor has shown a strong commitment to tackling tax evasion and I look forward to hearing more detail behind his future plans in this regard in the Autumn Statement. It is vital that the… – Continue reading

ECONOMYAustralia to crack down on corporate tax avoidance

Australia may follow the UK in implementing a “diverted profits” tax on multinationals to crack down on tax avoidance. Joe Hockey, Australia’s treasurer, said on Tuesday that his office is exchanging information with London on its “Google tax”, which was announced last week, writes Jamie Smyth in Sydney. I am… – Continue reading

New Luxembourg leaks reveal Disney, Koch Industries tax deals

(Reuters) – Tax deals that entertainment giant Walt Disney Co., commodities group Koch Industries [KCHIN.UL] and others agreed with the Luxembourg authorities were revealed on Tuesday by the International Consortium of Investigative Journalists (ICIJ). The ICIJ said the two companies engaged in complex restructurings, and channeled hundreds of millions of… – Continue reading

Tax deals raise questions over Ireland’s growth spurt

Four years after entering a punishing €67bn bailout, the Irish economy is booming again. Gross domestic product expanded at an annual rate of 5.5 per cent between January and June. The European Commission expects Ireland to be the fastest-growing country in the eurozone in 2014. Yet a chorus of economists… – Continue reading

Luxembourg tax files: how Juncker’s duchy accommodated Skype and the Koch empire

The EU’s most powerful official is under mounting pressure as dozens more multinational corporate names are dragged into the Luxembourg tax scandal following a new leak of confidential documents on Tuesday. Jean-Claude Juncker, president of the European commission, has been battling to distance himself from the growing furore over the… – Continue reading

Swedish Tax Agency reviews TP legislation and proposes changes

The Swedish Tax Agency has, on request by the Swedish Government (Ministry of Finance), evaluated the transfer pricing documentation rules’ functionality and proposed possible changes to simplify the application. The first step was to make an international comparison of the rules in relevant, comparable OECD countries. An overall assessment showed… – Continue reading

United States: Why Has The IRS Outsourced Microsoft’s Transfer Pricing Audit To A Private Law Firm?

Perhaps it was just a matter of time until the Internal Revenue Service decided to “outsource” its tax audit and litigation function to a private entity, i.e., a law firm. As reported in the December 8th issue of Tax Notes, the Service has hired the law firm of Quinn Emanuel… – Continue reading

B2B: Beneficial Owner of Income: Treaty Benefits and the Introduction of the New Rules

The MT Conferences section did not involve the reporting or the editorial staff of The Moscow Times. Russian business is trembling in expectation of the new year when major changes recently introduced to the tax legislation will enter into force. There has been a lot of discussion regarding the increase… – Continue reading

US Anti-Inversion Bill ‘Could Save More Revenue’

The Joint Committee on Taxation has increased, from USD19.5bn to more than USD33.5bn, its estimate of tax revenue that could be saved over a ten-year period from legislation to restrict corporate inversions introduced by Democrat lawmakers in the United States House of Representatives in May this year. A recent letter… – Continue reading

Margaret Hodge to grill PwC and Shire over tax avoidance in Public Accounts Committee

The accountant PricewaterhouseCoopers and drugs giant Shire are due face a tense parliamentary showdown over tax avoidance with an angered Margaret Hodge today. PwC’s head of tax, Kevin Nicholson, was summoned to face Ms Hodge’s powerful Public Accounts Committee following reports last month that multinational corporations advised by PwC Luxembourg… – Continue reading

The Country Has Spoken

While the dust is still settling from the mid-term elections and the pundits are trying to figure out what it all means, the American people have made their collective voices heard and delivered a message that they do not like the country’s direction. Exit polling data from Election Day showed… – Continue reading

Tax Avoidance: The LuxLeaks Scandal Explained

On November 6th, 2014, the ICIJ journalists’ network revealed its investigation into leaked documents from professional services firm PricewaterhouseCoopers. Their analysis shows that over 340 multinational companies use schemes to avoid paying taxes – schemes made possible by Luxembourg’s particularly favourable tax laws. How did the ICIJ work together on… – Continue reading

PriceWaterhouseCoopers chief Kevin Nicholson denies lying over tax deals

Nicholson stands by previous testimony to MPs, as accountants are accused of mass-marketing tax avoidance schemes The head of tax at one of the UK’s top accounting groups was accused of lying to parliament about his firm’s role in devising controversial tax deals for clients in Luxembourg. Kevin Nicholson, PwC… – Continue reading

Whistleblower Alleges Vanguard Cheated On Taxes, Costing Taxpayers More Than $1 Billion

On May 1, 1975, Princeton graduate John C. Bogle launched an investment company on a bold new idea: it would be owned by its member funds and operated for the benefit of its shareholders. That company, the Vanguard Group, is now one of the world’s largest investment companies with about… – Continue reading

Sri Lanka receives $1.42 billion as foreign direct investment in 2013

Islamic Finance has garnered an increased interest in the last few years and has the potential to develop the capital markets of Sri Lanka and assist in the development of infrastructure along with encouraging foreign investment in the island state, according to an economist in Sri Lanka. In an interview… – Continue reading

Luxembourg Braces for New Wave of Tax-Deal Revelations

Luxembourg’s government is on alert for a new wave of tax revelations that Prime Minister Xavier Bettel expects to hit the country in the coming days. The country’s Finance Minister Pierre Gramegna received a new batch of questions from a group of investigative reporters that indicate more documents revealing alleged… – Continue reading