High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Email ftsales.support@ft.com to buy additional rights.http://www.ft.com/cms/s/0/4cff6b02-650f-11e4-ab2d-00144feabdc0.html#ixzz3IHz72Wk5 HM Revenue & Customs is ramping up the pressure on tax avoidance by warning… – Continue reading
UK Disclosure Facilities – Background HM Revenue & Customs (HMRC) has offered several opportunities over the past seven years to encourage errant tax payers to come forward in order to regularise their tax affairs on relatively benign terms. In 2007 HMRC offered the Offshore Disclosure Facility (ODF) which afforded taxpayers… – Continue reading
ICC has expressed concern that the Organization for Economic Co-operation and Development (OECD) Action Plan on combating Base Erosion and Profit Shifting (“BEPS”), mandated by the G20, may inadvertently incur severe collateral damage on compliant taxpaying companies of all sizes as a result of well-meaning measures undertaken unilaterally by states… – Continue reading
Update on Accelerated Payments HMRC have recently published a briefing on the requirement of tax avoidance scheme users to make upfront payments of tax, known as ‘Accelerated Payments’. The briefing explains why HMRC believe it was necessary for them to be granted the power to demand tax ahead of the… – Continue reading
Noonan makes no reference to Irish Water charges or tax credits in Finance Bill speech Abolition of the “double Irish” corporate structure will not bring an end to “international tax planning”, Minister for Finance Michael Noonan has said. The change would, however, “address the reality that Ireland’s company tax residence… – Continue reading
The taxation of a person is based on two principles: Source and Residence. A person for tax purposes includes an individual, trust, company, partnership and any form of business arrangement one chooses to take on. It should be noted that with globalisation, there is a constant mix of these two… – Continue reading
It is important that the Brisbane G20 Summit on Nov. 15–16 is a success. In an increasingly integrated global economy, effective forums for economic cooperation are needed. The 2008 global financial crisis was the catalyst for the G20 becoming a leaders’-level forum. The Washington, London, and Pittsburgh summits helped save… – Continue reading
November 3: The Organisation for Economic Cooperation and Development today released a discussion draft of the proposed modifications to Chapter VII of the OECD Transfer Pricing Guidelines relating to low value-adding intra-group services. Action 10 of the OECD’s action plan on base erosion and profit shifting (BEPS) directs the OECD… – Continue reading
NEW YORK — Shifting the address of his Liberty Global Inc. from Colorado to London last year didn’t just put billionaire John C. Malone in a position to reduce his company’s tax bill. He also took precautions to avoid the capital-gains hit that the so-called inversion would trigger for him… – Continue reading
London is an increasingly important hub for offshore law firms, which are winning business from City-based financial institutions, and clients in Russia, western Europe and sub-Saharan Africa. Offshore law firms are constantly evolving, it seems. Traditionally, they operated in one offshore territory: whether the British Crown dependencies of Jersey, Guernsey… – Continue reading
Property purchases in Ireland help Liberty Global chairman John Malone avoid tax Billionaire Irish American businessman John Malone, who owns a number of prestigous properties in Ireland, didn’t just reduce his company’s tax bill when he shifted the address of UPC parent Liberty Global from Colarado to London last year…. – Continue reading
New York • Shifting the address of his Liberty Global Inc. from Colorado to London last year didn’t just put billionaire John C. Malone in a position to reduce his company’s tax bill. He also took precautions to avoid the capital-gains hit that the so-called inversion would trigger for him… – Continue reading
Adds details on P&G halting operations in ARGENTINA, details on impact) Nov 3 (Reuters) – Procter & Gamble said on Monday it had temporarily suspended operations in ARGENTINA after the country’s tax authority, which has accused the company of tax fraud, said it started meetings with the world’s No.1 HOUSEHOLD… – Continue reading
High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Email ftsales.support@ft.com to buy additional rights. http://www.ft.com/cms/s/0/e56ca00c-6010-11e4-98e6-00144feabdc0.html#ixzz3I617l1GT It is no secret that Apple, Starbucks and Amazon are among several high-profile companies… – Continue reading
It is all about transfer pricing issue which is not unique to India. Still, the judgment of the Bombay High Court of October 10, 2014, in the case of Vodafone India Services vs Union of India, has drawn a lot more attention than it would otherwise have. The main reason… – Continue reading
Foreign profits sit on sidelines as companies seek tax reform. WASHINGTON — They are all companies that call Minnesota home: Medtronic, 3M, St. Jude Medical, General Mills and Ecolab. But they also all hold 90 percent or more of their cash outside the United States. Amid a growing national political… – Continue reading
The implementation of ‘Transfer Pricing’ regulations needs a relook as most of the disputes on tax from global business community is on transfer pricing, according to the industry body Bangalore Chamber of Industry and Commerce (BCIC) Chairman Direct Taxes Expert Committee K R Sekar. Delivering his address on ‘Transfer Pricing… – Continue reading
HA NOI (VNS) — Appropriate policies and enhanced management capacity are critical in the fight against transfer pricing to ensure a healthy business investment environment in Viet Nam, said experts on Wednesday. They were participating in an online discussion on the Government’s e-portal. Transfer pricing is causing losses to the… – Continue reading
Medical device companies Wright Medical Group Inc. and Tornier NV have agreed to merge in an all stock USD3.3bn transaction that will involve the transfer of Wright’s tax domicile from the US to the Netherlands. Wright’s deal with Tornier is one of the few corporate tax inversions that have been… – Continue reading
Just over two-thirds (67%) of in-house tax specialists and lawyers are ‘somewhat or very concerned’ about tax adjustments which they expect to follow from the implementation of OECD guidance on transfer pricing. This is one of the conclusions of ‘Transfer Pricing: Intangible Property, Tangible Profits’, a report from ALM Legal… – Continue reading
U.S. tax law creates perverse incentives for American companies to hold cash offshore, and the U.S. Treasury recently announced proposals to deter the practice. The proposals have triggered an outcry that ranges from criticisms that the Obama administration has overstepped its authority, on one side, to criticisms that the proposals… – Continue reading
Taxes are the price of a civilised society and without them no state can provide social infrastructure, alleviate poverty, subsidise corporations or rescue distressed banks. But tax revenues are under relentless attack and corporate ingenuity in avoiding taxes shows no limits. Companies have become very adept at shifting profits to… – Continue reading
In front of European Commissioners, leading politicians, chief executives of huge multinationals, senior bank bosses and billionaires, the Egyptian investment tycoon was asked to set the tone of the forum, a three-day lobbying event funded by the EU. Dr Heikal is founder and chairman of Qalaa, an African investment fund… – Continue reading
Hawala networks are being replaced by sophisticated transfer pricing approaches. The image is easy to envision. Corrupt politicians, crooked corporate honchos and evil criminals stashing away their ill-gotten gains in shady Swiss banks. Thousands of crores of rupees that should be earning India tax revenue wilfully being hidden from authorities… – Continue reading
66% of Law Firms Work With at Least Some of Their Tax Clients to Identify and Document All Relevant Intangible Assets for Transfer Pricing NEW YORK, Oct. 30, 2014 (GLOBE NEWSWIRE) — As scrutiny by tax authorities mounts, the identification and documentation of intangible assets, such as patents, trademarks and… – Continue reading
VietNamNet Bridge – Recent surveys about the tax policies applied to foreign-invested enterprises (FIEs) show that Vietnamese have become choosier about foreign direct investment (FDI) and FIEs (foreign-invested enterprises). “Do you think that the FIEs in Vietnam are transparent in tax payments?” was one survey question raised by Thoi Bao… – Continue reading
New U.S. tax rules applicable to Covidien acquisition make deal less attractive, Moody’s said. Two Wall Street rating firms expect to downgrade Medtronic Inc.’s debt because the company will have to borrow $13.5 billion more than it expected to buy health care supplier Covidien and move the combined company to… – Continue reading
KUCHING: Accounting firm Deloitte Malaysia stressed on the government increasing focus on transfer pricing whereby there is a new requirement for taxpayers to declare if one has prepared all the necessary transfer pricing documentations. In the past, one was only required to disclose related-party transactions but there was no requirement… – Continue reading
US banana producer and distributor Chiquita has decided to terminate its proposed inversion with its rival Fyffes, in a deal which would have involved moving its tax residence to Ireland, and will instead be acquired. Chiquita’s decision comes after the announcement of non-legislative measures by the US Treasury Department on… – Continue reading
Canada’s Competition Bureau says that Burger King’s plan to buy Tim Hortons does not pose a competitive threat to the fast food industry. The antitrust watchdog issued a No Action Letter (NAL) Tuesday, confirming that it reviewed the proposed transaction and concluded that it will not, at this time, “challenge… – Continue reading
Background The “Authorized OECD Approach” (“AOA”) rule for taxation of permanent establishments (“PE”) was introduced in Japan’s 2014 tax reform and will be applied to fiscal year commencing April 1, 2016. The new rule includes changes to source rules, the introduction of transfer pricing to intra-company transactions, and the introduction… – Continue reading
The OECD’s Action Plan on BEPS was published in July 2013 to reform the international tax system. The Action Plan identified 15 Actions to address BEPS. Seven of the 15 Action Plan items are now moving out of the station. I. Introduction On September 16, 2014 the OECD, together with… – Continue reading
Wright Medical Group Inc. (WMGI), a U.S. maker of bone implants, will merge with Tornier NV, creating a new company valued at $3.3 billion in the latest proposed tax inversion since tighter rules were announced last month. The legal address for the new company, to be called Wright Medical Group… – Continue reading
(Bloomberg) — The U.S. attempt to stop companies from leaving the country for tax reasons won’t stop Pfizer Inc., which is still considering a deal to move America’s biggest drugmaker abroad, said Chief Executive Officer Ian Read. “I see no reason why we wouldn’t be able to do an inversion,”… – Continue reading
(Reuters) – Giving Scotland more tax-raising powers would increase the complexity of Britain’s already-lengthy tax code and may create new loopholes for tax avoidance, accountants and tax advisors told British legislators on Tuesday. Scottish voters rejected independence from Britain in a referendum last month, swayed in part by British politicians’… – Continue reading
Multinational life sciences companies should review their organizational structures and perform scenario planning to assess the likely impacts of the Organisation for Economic Co-operation and Development’s (OECD’s) Action Plan on Base Erosion and Profit Shifting (BEPS), says a new report from KPMG. “The Post Base Erosion and Profit Shifting World”… – Continue reading
At the 68th Congress of The International Fiscal Association in Mumbai, CBC-TV18’s Payaswini Upadhyay spoke to Sanjay Puri, Director, CBDT on the OECD’s work on Transfer Pricing principle of intangibles and India’s position on it and the kinds of transactions that the Department is looking at in the intangibles space…. – Continue reading
NEW YORK, Oct. 27, 2014 /PRNewswire/ — Bloomberg BNA’s International Tax Monitor and Tax Analysts interviewed Caplin & Drysdale’s Elan P. Keller concerning a pledge made at the 2014 OECD Forum on Tax Administration (FTA) by tax chiefs from 38 countries to invest in resources to implement a new standard… – Continue reading
NEW YORK–(BUSINESS WIRE)–Tax inversion deals have effectively been repriced by the US Treasury signaling an end to “hop-scotch” loans and other tax structuring opportunities, according to Fitch Ratings. AbbVie’s purchase of Shire and the planned merger of Salix Pharmaceuticals and Cosmo Technologies, both pulled since the Treasury announcement, were scuttled… – Continue reading
KIGALI, Rwanda – The need of a tax law on reverse VAT to be harmonized among EAC states was highlighted during the recently concluded East African Business Summit that took place in Kigali. “Tax law on reverse VAT can be harmonized among EAC states,” Rwanda Revenue Authority Commissioner General Richard… – Continue reading
Genuine tax planning will remain legitimate despite a new anti-avoidance crackdown relating to inheritance tax, says a tax partner at Lodders Solicitors in Cheltenham. Eamonn Daly said HM Revenue & Customs was only after those who constantly tried to push the boundaries, coming up with ruse after ruse. He explained:… – Continue reading
SPECULATION is swirling over what the Treasury will do to raise R44-billion in additional tax revenue over the next three years — without inflicting too much pain on a fragile economy. Finance Minister Nhlanhla Nene confirmed that there would be tax policy and administrative “reforms” to shore up flagging revenue… – Continue reading
One of the stories that firms deserting our country like to tell is that by moving their corporate domicile (but not their actual headquarters) outside U.S. borders to duck taxes, they will be able to use cash they have parked offshore to expand their operations in the United States. So… – Continue reading
There’s no doubt the arms length principle has holes, and it may be the time to reconsider the way governments approach transfer pricing Amazon, Fiat, Vodafone, Starbucks, Apple… The list of companies facing scrutiny for their failure to properly implement the arms length principle into their transfer pricing policies this… – Continue reading
On October 14, 2014, the Irish Minister for Finance released proposals as part of the 2015 Irish Budget that would cause Irish incorporated non-resident (“INR”) companies to be treated as tax resident in Ireland beginning January 1, 2015. The goal is to shut down the use of so-called “Double Irish”… – Continue reading
“The issue of substance and taxation is, and always will be, a core column of the Irish taxation system,” Michael Noonan, Ireland’s Finance Minister, said at his Department’s Tax Policy Conference on October 21, 2014, underscoring that Ireland’s strategy is to play fair but play to win. Beginning by discussing… – Continue reading
Countries that work together like Ireland and the US “need to be cognisant” of the impact their tax policies have on each other, new US Ambassador to Ireland Kevin O’Malley said in a speech yesterday. He said cross-border mergers can make the Irish and American economies stronger, but that “these… – Continue reading
In June, the European Commission (“EC”) announced the opening of three investigations into tax rulings in Ireland, Luxembourg and the Netherlands and, in particular, into tax rulings applied by Ireland to Apple, by Luxembourg to Fiat Finance and, last, by the Netherlands to Starbucks. In October 2014, the EC announced… – Continue reading
Business Standard October 23, 2014 Last Updated at 23:20 IST The Bombay High Court recently in the case of Vodafone India Services Private Limited (Vodafone) held that the foreign direct investment (FDI) received by the Indian company in the form of share capital cannot be taxed in India under the… – Continue reading
On 29 July 2014, the China State Administration of Taxation (SAT) released an internal notice to the China tax authorities at the provincial levels, in the name of “Notice on Antiavoidance Investigation against Large Amount Outbound Payments” (Circular Shui Zong Ban Fa [2014] No. 146, Notice 146), urging a nationwide… – Continue reading
