Category: Transfer pricing

UK: Weekly Tax Update – Monday 20 April

1 General news 1.1 HMRC organisation chart HMRC has published its latest organisation chart showing the names of senior management. One point to note is the number of senior people now in roles such as change management as opposed to being in pure technical roles. This clearly demonstrates the direction… – Continue reading

Parliament takes aim at corporate ‘looting’

MPs say transfer pricing, though legal, presents challenges when determining if firms have evaded taxation and they want the practice criminalised. The portfolio committee on trade and industry has heard calls for the criminalisation of transfer pricing – a practice that, when abused, results in large corporations shifting profits offshore… – Continue reading

Higher taxes probably avoidable if transfer pricing abuses curbed, says Davis

IF THE South African Revenue Service (SARS) focused on recovering money from transfer pricing abuses‚ Finance Minister Nhlanhla Nene probably wouldn’t have had to raise taxes by 1% in his budget speech‚ Judge Dennis Davis‚ head of the Davis Tax committee, told Parliament on Tuesday. He was briefing the portfolio… – Continue reading

Tax boss rebukes Google, Apple and Microsoft over Senate inquiry eviden

Commissioner Chris Jordan delivers rebuke to multinational tech giants contesting evidence they gave to a Senate inquiry into corporate tax avoidance The tax commissioner, Chris Jordan, has delivered a public rebuke to multinational tech giants Apple, Google and Microsoft, vigorously contesting evidence they gave to a recent Senate inquiry hearing… – Continue reading

Government of India versus FPI: Is there a solution?

MUMBAI/NEW DELHI: Markets fell 500 points on Monday. Punters’ worries about current tax disputes between Modi Sarkar and foreign portfolio investors (FPIs) being one reason why the Sensex dived. There has been a battle of phrases between FPIs and North Block. And it looks as if this will be a… – Continue reading

Metro Vietnam found owing over $23.6mn in tax in transfer pricing inspection

The Vietnamese unit of Germany’s Metro Cash & Carry will have to pay almost US$24 million in tax arrears after its wrongdoings have been unearthed in a transfer pricing inspection that concluded Monday. Metro Cash & Carry Vietnam Co. Ltd. began coming under scrutiny on suspicions of transfer pricing in… – Continue reading

Tax inspectors find $23.7 mln worth of violations at Metro Cash & Carry

Vietnamese tax inspectors have found multiple violations at the local subsidiary of German retail giant Metro, estimating them to be worth VND507 billion (US$23.7 million). Of the total amount, Metro Cash & Carry Vietnam was ordered to immediately pay VND62 billion ($2.8 million) in arrears of income taxes for its… – Continue reading

OECD plans for gathering data on ‘base erosion’ at a disappointingly early stage, expert says

International plans for gathering and analysing data on the extent to which multinational companies are artificially shifting their profits to low-tax jurisdictions are at a disappointingly early stage, an expert has said. Heather Self of Pinsent Masons, the law firm behind Out-Law.com, also said that the global governments involved in… – Continue reading

District of Columbia’s Transfer Pricing Enforcement Program and Combined Reporting Regime: Taking Two Bites of the Same Apple

In his recent article, “A Cursory Analysis of the Impact of Combined Reporting in the District”, Dr. Eric Cook claims that the District of Columbia’s (D.C. or the District) newly implemented combined reporting tax regime is an effective means of increasing tax revenue from corporate taxpayers, but it will have… – Continue reading

China: Asia Tax Bulletin – Spring 2015

CHINA Tax Free Reorganisations • With circulars 109 and 116 jointly issued in December 2014 by the Ministry of Finance and the State Administration of Taxation, the Chinese authorities have relaxed the conditions for internal reorganisations. • Circular 109 deals with internal reorganisations. Provided the pertinent requirements are met, the… – Continue reading

GLOBAL INFO EXCHANGE MUST TO CURB TAX EVASION, INDIA TELLS G-20

The Union Finance Minister, Arun Jaitley, expressed concern over transfer pricing and several other measures taken by MNCs to avoid paying tax on international transactions. The Dollar Business Bureau Stressing on the need to keep a check on tax evasion by multi-national companies (MNCs), India has asked the G20 members… – Continue reading

United States: As Tax Rules Shift, Companies Need Flexible Structures And Strategies

Technology companies with international operations are increasingly using global tax avoidance methods, despite growing opposition from the public and politicians in the U.S. and abroad. As this opposition fuels ongoing changes in tax rules, organizations must be able to quickly adapt their corporate structures and tax strategies to maintain a… – Continue reading

European Union: European M+A News, Spring 2015

EUROPEAN M&A DOS AND DON’TS FOR NON-EUROPEAN BUYERS Inbound M&A in Europe by non-European buyers increased in 2014 by 68.6% compared to 2013, representing over a third of USD 901.4 billion total European M&A.1 For non-European buyers the basic framework of transactions may be similar, but there are a number… – Continue reading

New transfer pricing monitoring unit to detect illicit outflows, says Atiur

Bangladesh authorities are working with counterparts abroad to recover proceeds of corruption (‘stolen assets’), in terms of the UN Convention Against Corruption (UNCAC), Bangladesh Bank (BB) Governor Dr. Atiur Rahman has said. The central bank chief disclosed this while speaking at an event title Addressing the Linkage Illicit Flows and… – Continue reading

Arun Jaitley pitches for low taxes, taxpayers as ‘partners not hostages’

Promising a ‘modern tax system’ with low and globally competitive rates, Finance Minister Arun Jaitley has assured foreign investors against any retrospective action and said taxpayers will be seen as “partners and not as potential hostages or victims”. For domestic taxpayers also, the rates need to be low as taxes… – Continue reading

Foreign Investors and India’s Tax Men Are Clashing Anew: Q&A

Nothing is certain in India except death and tax disputes. Ask foreign portfolio investors: they now face demands for past dues of as much as $6.4 billion. The wrangle stems from the Minimum Alternative Tax, or MAT, which officials say leads to a 20 percent levy on capital gains by… – Continue reading

Looking to expand into Singapore? All you need to know about transfer pricing regulations

Lee Curthoys, corporate tax lead at Radius, looks at Singapore’s changing transfer pricing regulations and tells us what we need to know. For a number of reasons, ranging from public safety to proximity to other Asian markets, Singapore is a popular destination for businesses looking to expand globally. In fact,… – Continue reading

Uranium demand is putting miner Cameco back on investors’ radar

The outlook for uranium, moribund for some time, is looking up. And that means shares of Cameco Corp., the Saskatoon-based miner one analyst calls “the only real blue-chip stock in the sector,” are up, too – about 20 per cent from their 52-week lows. The stock has received a host… – Continue reading

Jaitley promises 'modern tax system'

“Tax policy and administration should incentivise compliance. They should be administered fairly, transparently, with minimum discretion, with no harassment of taxpayers but also ensuring that tax evasion is dealt with firmly.” Promising a ‘modern tax system’ with low and globally competitive rates, Finance Minister Arun Jaitley has assured foreign investors… – Continue reading

Australia must break the shackles of intellectual property in FTAs

Last week some of Australia’s biggest and richest companies voluntarily fronted up to a senate inquiry on corporate tax avoidance. Bigwigs from big brands, including Apple, Google, Microsoft, Rio Tinto, BHP Billiton and Fortescue Metals, squirmed under the spotlight as they were grilled about how they (legally) shift profits offshore… – Continue reading

Treasurers should provide transaction documentation according to BEPS

Corporate treasury departments will have to start complying with International tax rules and provide documentation for transactions according to recent reports. G20 leaders attempted to reform the international tax system in July 2012 by setting up the Base Erosion and Profit Shifting (BEPS) project. This task was given to the… – Continue reading

Your Taxes: OECD helping governments collect more taxes

Israel joined the OECD in 2010. Background The Organization for Economic Cooperation and Development is spearheading a concerted effort to help governments around the world collect more taxes. The OECD is doing so by issuing a series of recommendations for tightening up corporate and personal tax measures. Individual governments are… – Continue reading

Tax Directors Expect Their Companies to Expand

Tax directors at many organizations anticipate their companies will grow by entering into new domestic and international markets in the years ahead, according to a new survey by BDO USA. In a sign of an improving economy, 50 percent of the 100 tax directors at $1billion-plus public companies surveyed by… – Continue reading

Administration Proposes to Repeal Deferral, Haircut the Foreign Tax Credit and Interest Expense Deductions, Override Treaties, and Abandon Arm’s-Length Transfer Pricing for Intangibles

As the above title indicates (it is only a modest exaggeration), the Treasury Greenbook regarding the FY 2016 budget proposes a radical restructuring of the system for U.S. taxation of foreign income of U.S. multinational enterprises (MNEs). Some Congressional players have suggested that these proposals are an opening bid in… – Continue reading

Tax Directors Anticipate Domestic and Cross-Border Growth Over The Next Three Years, According To The Inaugural BDO Tax Outlook Survey

– Rising Cost of Compliance Within The Tax And Financial Regulatory Environment Creates Opportunities For Increased Efficiency – CHICAGO–(BUSINESS WIRE)–As the economy continues to accelerate, many organizations plan to grow by entering into new markets in the years ahead, reveals the first ever BDO USA, LLP Tax Outlook Survey. Fifty… – Continue reading

Legal flash – Shanghai office – March 2015 – Announcement of the State Administration of Taxes concerning enterprise income tax on fees resident enterprises pay to overseas related parties

In recent years, the State Administration of Taxes (“SAT”) has paid closer attention to fees resident enterprises pay their overseas related parties, concerned that multinational groups have shifted profits away from China through aggressive tax planning and by paying unreasonable service fees and royalties overseas. Following PRC’s active participation in… – Continue reading

RPT-Commodity giants’ Singapore trading hubs under fire in tax probes

SINGAPORE, April 12 (Reuters) – The Singapore trading hubs of the world’s largest commodity companies are coming under scrutiny from the governments of some resource-producing countries who say they suspect they are using units in the Southeast Asian financial centre to avoid tax. Some of the world’s largest oil, mining… – Continue reading

Tax terrorism versus tax haven

The key is to arrive at a Goldilocks mean — rolling out tax-friendly policies while being firm with incorrigible offenders A phrase first used by Prime Minister Narendra Modi while addressing a group of businessmen in the run-up to the elections last year has now come back to haunt his… – Continue reading

Apple, Google Reject ATO’s Tax Avoidance Claims

Apple Australia follows Australian transfer pricing law and pays all of its taxes due in the Australian market in accordance with the law, Tony King, the Managing Director of Apple Australia, told the Senate Inquiry on corporate tax avoidance and minimization on April 8, 2015. In his opening remarks before… – Continue reading

France: French Tax Update – Early 2015 Noteworthy Case Law And Tax Transparency Package

The present French Tax Update will focus on (i) several noteworthy French and European Union court decisions issued in the last months of 2014 and in the first months of 2015, and (ii) the recent presentation by the European Commission of a package of tax transparency measures. VALIDITY OF TAX… – Continue reading

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

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