Foreign investors, not to mention the country itself, need a more stable and predictable regime Foreign companies are depressingly used to run-ins with the Indian taxman. A string of groups, including Vodafone, IBM and Cairn Energy, have been hauled into the dock for not paying their dues in recent years…. – Continue reading
The Alternative Information Development Centre (Disclosure: AIDC’s economist Dick Forslund contributes to Daily Maverick, most recently about Lonmin) has been served with an interdict application in the Johannesburg High Court to try to prevent the organisation from holding a press conference about Lonmin’s finances, especially relating to the use of… – Continue reading
Transactions within, rather than between, companies now accounts for about a quarter of Australia’s economic output, the Tax Office says. In a sign of the challenges facing the government’s crackdown on corporate tax erosion, the ATO said related-party dealings now amounted to more than a quarter of a billion dollars… – Continue reading
NEW DELHI: Vodafone welcomed an Indian court ruling in favor of the British mobile giant which was engaged in a $490-million tax battle with local authorities. The tax fight is one of several embroiling the British company that has become a symbol of problems facing foreign firms doing business in… – Continue reading
Vodafone has emerged victorious against the Indian taxman in the latest bout of litigation between the two. The important point for the rest of us being what it tells us about those endless claims of tax avoidance and tax evasion by large companies. It’s not just that large amounts of… – Continue reading
Introduction Action 1: the digital economy Action 2: hybrid mismatch arrangements Action 5: harmful tax competition Action 6: preventing tax treaty abuse Action 8: guidance on transfer pricing and intangible assets Action 13: transfer pricing documentation and country-by-country reporting Action 15: developing a multilateral legal instrument Next steps Introduction On… – Continue reading
For a large majority of the ever-increasing number of British expatriates with pensions which remain in the UK, a Qualifying Recognised Overseas Pension Scheme (QROPS) provides a viable and sometimes integral role in retirement planning. This counts for those now residing in Europe, Asia and the Middle East, however arguments… – Continue reading
The European Commission’s recent action to crack down on special deals some European Union governments offer to corporations could be a blow to multinational corporations’ tax-dodging strategies. As we noted in a report earlier this year, three European countries (Ireland, Luxembourg and the Netherlands) are among the top twelve tax… – Continue reading
Medical device giant Medtronic is close to finishing a deal to move its tax headquarters to Ireland and boost its stock price. But while shareholders face taxes on those gains, the company is shelling out more than $60 million to make sure its CEO and 25 other top officials won’t… – Continue reading
Endo International Plc (ENDP) agreed to buy Auxilium Pharmaceuticals Inc. (AUXL) for about $2.6 billion to gain testosterone products. Endo will pay $33.25 a share, and Auxilium holders will be able to choose cash, stock or a combination of the two, the companies said today in a statement. The price… – Continue reading
VietNamNet Bridge – Foreign automobile and electronics manufacturers often choose foreign enterprises for their parts and accessory suppliers instead of Vietnamese companies because it allows them to engage in transfer pricing, some analysts have claimed. Samsung, Toyota, Canon and other giants in the manufacturing industry have complained many times that… – Continue reading
Australian tax authorities allege multinational oil giant Chevron used a series of loans and related party payments worth billions of dollars to slash its tax bill by up to $258 million. New documents filed in a long-running dispute in the Federal Court show how Chevron allegedly engaged in a complex… – Continue reading
The question has often arisen whether “international law” is an oxymoron – whether “obligations” in income tax treaties and other international agreements are really binding upon the parties, when they are not buttressed by some sort of enforcement mechanism. That question has never been more relevant in the tax world… – Continue reading
As a part of the OECD/G20 project to combat base erosion and profit shifting (“BEPS”), the OECD released the first set of reports and recommendations on September 16, 2014. These reports address seven of the actions described in the 15-point action plan to address BEPS published in July 2013 (the… – Continue reading
Overview I have mentioned in prior articles that I was a Spanish and Portuguese major as an undergraduate. During the time that I was attending law school at the University of Miami, the early 1990’s, the Brazilians had yet to arrive in South Florida in a significant manner. The Brazilian… – Continue reading
Medtronic announced last week that it will go ahead with its Covidien buyout despite a recent notification by the U.S. Department of the Treasury and the Internal Revenue Service discouraging tax-avoiding corporate inversion deals. Per the new guidelines, companies will not be able to avoid paying U.S. taxes when accessing… – Continue reading
The Organization for Economic Cooperation and Development (OECD) has released the first components of its comprehensive plan for creating an agreed set of international rules for fighting base erosion and profit shifting (BEPS) and ending opportunities for double non-taxation. The four model legal instruments and three reports are the first… – Continue reading
BANGALORE, India — One of the world’s biggest cellular phone manufacturing plants, located in the southern India city of Chennai, will stop production of mobile phones and down shutters after Nov. 1. Microsoft, its lone customer, has terminated a subcontract agreement. “Microsoft has informed Nokia that it will be terminating… – Continue reading
The UK government will continue to defend its ‘patent box’ tax break for income from qualifying intellectual property (IP) during discussions to develop a global corporate tax regime, a Treasury official has said.08 Oct 2014 Intellectual Property Tax Patents Corporate tax Life sciences Advanced Manufacturing & Technology Services UK Europe… – Continue reading
The non-legislative measures put forward by the Treasury Department on September 22, to deter multinationals from using corporate inversions to move their tax residence abroad and move away from the high United States tax rate, have so far produced a mixed bag of results. The measures are aimed at preventing… – Continue reading
The UK government will continue to defend its ‘patent box’ tax break for income from qualifying intellectual property (IP) during discussions to develop a global corporate tax regime, a Treasury official has said.08 Oct 2014 Intellectual Property Tax Patents Corporate tax Life sciences Advanced Manufacturing & Technology Services UK Europe… – Continue reading
HM Revenue and Customs (HMRC) is consulting on draft regulations that will exclude two types of persons from the definition of “promoter” for the purposes of the Promoters of Tax Avoidance legislation. The regulations are intended to meet concerns raised during the development of the primary legislation. They are relieving… – Continue reading
The taxman is willing to “negotiate and strike a balance” with multinationals being audited for transfer pricing misconduct, a drive it says has a potential to realise over Sh30 billion. The Kenya Revenue Authority told a workshop organised by the Association of Chartered Certified Accountants in Nairobi that this will… – Continue reading
Eight of the top 200 companies publicly listed on the Australian stock exchange (ASX200) paid no taxes on profits averaging $50 million to more than half a billion dollars over the decade to 2013! More than 20 (10 percent) corporations paid an average tax rate of five percent or less…. – Continue reading
Amazon’s tax arrangements with Luxembourg are being investigated by E.U. regulators, as the online retailer becomes the latest global company to be accused of striking tax-minimising deals with member states that may break bloc rules. Corporate tax avoidance has come under the spotlight on both sides of the Atlantic in… – Continue reading
Amazon is believed to have exploited a slightly different tax loophole in Luxemborg to wash away most local taxes The European Union (EU) made waves late last month when its antitrust regulators — a part of the trade-regulating body known as the European Commission (EC) — issued a preliminary finding… – Continue reading
The European Commission has opened an in-depth investigation to examine whether the decision by Luxembourg’s tax authorities with regard to the corporate income tax to be paid by Amazon in Luxembourg comply with the EU rules on state aid. The opening of an in-depth investigation gives interested third parties and… – Continue reading
On June 10, 2014, the Tax Court of Canada (“TCC”) delivered its most recent decision on transfer pricing, one which involved a Barbados structure. In Marzen Artistic Aluminum Ltd. v. The Queen[1] (“Marzen”), Justice Sheridan upheld the Canada Revenue Agency’s (“CRA”) transfer pricing adjustment as well as the penalty under… – Continue reading
A tax-based industrial policy will not produce an innovative economy, writes James Stewart 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/bde702e4-4d5e-11e4-bf60-00144feab7de.html#ixzz3HKJXRQha Irish… – Continue reading
OHN KEHOE The global tax plan being pursued by Australia as G20 president, to compel low-tax paying multinationals such as Google and Apple to contribute more revenue to government coffers, could be derailed by political resistance in the United States. A prominent US senator in congress who would likely become… – Continue reading
The Italian tax authorities have been intensifying their focus on transfer prices involving financial intercompany transactions such as loans. Multinational corporations frequently resort to such transactions to optimise and rationalise the financial management of the entire group. In certain cases, the said optimisation tools pertaining to intercompany financial resources may… – Continue reading
We pay our taxes. Why won’t they? It’s the topic every tax official and finance minister in the developed world is talking about and acting on, yet we hear little about it in New Zealand. Cracking down on tax avoidance by the world’s biggest technology companies – among them Google,… – Continue reading
On Tuesday, September 30, 2014, the European Commission (the Commission) published its decision to open an investigation intoIreland’s transfer pricing practices. The Commission is also reviewing the transfer pricing practices of other EU Member States, including the Netherlands and Luxembourg. Any advanced pricing agreement (APA) or other tax ruling within the EU… – Continue reading
Plans to tackle UK tax avoidance by international technology companies could damage UK competitiveness if they are brought in before international measures are finalised, a tax law expert has warned.02 Oct 2014 Corporate tax Tax Tax Disputes and Investigations TMT Advanced Manufacturing & Technology Services UK Europe Heather Self of… – Continue reading
Fiat-Chrysler (FIA.MI) reiterated on Thursday that a tax agreement granted by Luxembourg to one of its subsidiaries was legitimate and said the potential financial impact of a European Commission probe into the matter would not be significant. A tax concession that Luxembourg authorities granted to Fiat Finance and Trade in… – Continue reading
When the Obama administration clamped down last month on companies that reincorporate abroad to escape high U.S. taxes, it did not address a tax-dodging technique known as “earnings stripping,” leaving some to wonder if it is the next target. Earnings stripping is widely practiced and covers a range of financial dealings that… – Continue reading
An Assembly committee approved a Democrat-backed bill Thursday that would prevent the state or an independent authority from contracting a company that is structured to avoid paying taxes by having their corporate headquarters overseas. The Commerce and Economic Development Committee voted 7-3, splitting along party lines, to pass the bill… – Continue reading
eBay accused of tax avoidance, but insists it complies with letter of the law By Emma Woollacott, Sep 29, 2014Updated: September 30, 2014 7:24 AM Online auction site eBay got away with paying just £620,000 in tax on sales of over £1.3 billion last year, its latest accounts reveal. The… – Continue reading
Her Majesty’s Revenue and Customs (HMRC) UK will assist Federal Board of Revenue (FBR) on tax and customs reform initiatives encompassing development of special skills to identify cases of transfer pricing, techniques to catch tax evaders and use of IT to control tax avoidance. It is learnt on Monday that the… – Continue reading
George Osborne, the Chancellor of the Exchequer over here in the UK, has just announced at the Conservative party conference that he’ll be changing the tax laws to make sure that Google GOOGL +0.16% and other tech multinationals (Facebook, Microsoft MSFT -0.17%, possibly Apple AAPL +0.64%, among them) end up… – Continue reading
The European Commission’s crackdown on the deal between Irish tax authorities and Apple Inc. marks an expansion in the growing global war on tax avoidance by multinational companies. Governments that enable it are now a target. Tuesday, the European Commission said the Irish tax authorities failed to conform to international… – 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. Brussels has challenged Luxembourg over a tax ruling offering potentially illicit support to a Fiat subsidiary, opening a… – Continue reading
Tax attack Bill Shorten accuses the government during Tuesday’s question time of going soft on corporate tax avoidance; Tony Abbott says Labor did nothing in government. Autoplay ONOFFVideo feedbackVideo settings Bill Shorten: Corporate tax avoidance costs Australian business The Pulse Live: Judith Ireland blogs live from Parliament The Abbott government… – Continue reading
Yahoo is one of the weirdest companies in the world. That’s because it appears to be worth less than nothing. Here’s the best way to see this: Yahoo passively owns large swathes of two Asian internet companies — Chinese e-commerce giant Alibaba and a Japanese firm called Yahoo Japan. Add… – Continue reading
European regulators are set to examine whether Apple violated EU law by striking special tax deals with the Irish government. The European Commission opened an initial investigation into Apple’s tax affairs in June, looking at whether the company’s two percent tax rate in Ireland — far less than the standard 12.5… – Continue reading
Inland Revenue has gone shopping for a database to help it fight erosion of the tax base and “profit stripping” by multinational corporations. The database will help the taxman to independently assess the level of profitability companies should be returning for tax purposes by benchmarking the prices multinationals charge their… – Continue reading
(Bloomberg) — AbbVie Inc. is examining plans to raise additional financing to complete its takeover of Shire Plc, after U.S. officials imposed new obstacles to so-called tax inversion deals, people with knowledge of the matter said. AbbVie may seek to borrow as much as $7 billion more than it originally… – Continue reading
Canada should not count on building its economy by luring U.S. multinationals over the border with low tax rates in light of an announcement from the U.S. Treasury Department this week. The department outlined new measures to block companies from escaping U.S. taxes by moving earnings outside the country. This… – Continue reading
Back in the eighties and nineties, the Wyly brothers ran, and owned huge stakes in, a weird bunch of public companies, including some craft stores, some software companies, and a reinsurer. These companies were good and made the Wyly brothers a lot of money. An odd biological fact is that… – Continue reading
A good way to build a stronger economy is to create a fairer and more efficient tax code — one that promotes business investment and job creation in the United States. That is why the President has proposed business tax reform that will simplify the tax code by lowering the… – Continue reading
