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
Swiss police carried out a series of raids across German-speaking Switzerland in the early hours of Thursday morning, including the premises of private bank, J. Safra Sarasin. The authorities were acting on a request for legal assistance from Germany in a fraud and tax evasion case against the bank and… – 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/0/75090936-5aa2-11e4-b449-00144feab7de.html#ixzz3HLsJSGv7 Fears have been raised that the government may clamp down on a popular means… – 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
Officials from the Treasury and HM Revenue and Customs (HMRC) have been meeting with representatives of the PPP/ PFI industry to discuss the implications for infrastructure projects of possible restrictions to interest relief.24 Oct 2014 Corporate tax Tax Projects Construction Advisory & Disputes Infrastructure UK Europe In a report on… – Continue reading
THE OECD has signalled support for the Government’s plan to introduce a so-called “Knowledge Development Box”, but warned that the devil would be in the detail. Pascal Saint-Amans, the director of the Centre for Tax Policy and Administration at the Paris-based Organisation for Economic Cooperation and Development (OECD), told the… – Continue reading
There is a common misunderstanding in the charity world that tax avoidance, and its ugly sister – tax abuse, cannot be regarded as applying to charities except where charities are ‘hijacked’ to line the pockets of wealthy ostensible donors. But that is simply not the case. A charity which seeks… – Continue reading
Ireland puts an end to a tax loophole that saved Google, Apple, Microsoft, and Facebook billions in taxes “Double Irish” might sound like a drink that corporate tax lawyers reach for at the prospect of paying higher tax bills, but it’s actually the name of a controversial — albeit legal… – Continue reading
UK investors relinquish more than £680 million in rightful returns due to withholding tax Research has revealed that an estimated £13.2bn ($22.4bn) of investors’ rightful returns from foreign shares and bonds were lost in the latest financial year because Witholding Tax (WHT) on dividends and income is not being reclaimed…. – Continue reading
Oct. 10 — Withholding agents and foreign financial institutions will be given extra time to comply with requirements for determining an account holder’s foreign status, the IRS said. The Internal Revenue Service, in Notice 2014-59 issued Oct. 10, said withholding agents, foreign financial institutions and payers have until Jan. 1,… – Continue reading
It is said that Argentina faces an economic and political crisis every 10 years. Whenever a crisis arises, Argentinians’ right of ownership is at risk. Devaluation, asymmetric pesification and the current foreign exchange restrictions are a few examples of the challenges we face. What’s more, according to a recent OECD… – Continue reading
Tax Justice Network Africa, which campaigns against harmful tax policies that favour the wealthy and perpetuate inequality, has moved to the High Court to stop a double-taxation treaty between Kenya and Mauritius. Mauritius is a popular tax haven for companies with multinational operations, tilting scales against countries that sign bilateral… – Continue reading
A tax civil society has sued National Treasury Secretary Henry Rotich over an ‘illegal’ agreement signed with Mauritius, in a major litigation that could affect thousands of companies operating in Kenya. The suit filed at the High Court by Tax Justice Network-Africa (TJN-A) demands that Rotich withdraws a taxation treaty… – 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
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
European body adds another high-profile name to its crackdown on multinationals’ tax avoidance in bloc. The European Union is broadening its crackdown on multinationals’ tax avoidance schemes, opening an investigation yesterday into Amazon’s practices on suspicion the online retailer is not paying its dues on profits made across the 28-nation… – 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
The Internal Revenue Service plans to take additional actions to improve taxpayer compliance with a law related to the disposition of foreign investments in U.S. real property, according to a new government report. The report, from the Treasury Inspector General for Tax Administration, noted that Congress passed the Foreign Investment… – 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
In Starr International Company, Inc., v. United States, the taxpayer (“Starr International Company, Inc.” or “SICO”) filed a complaint in the United States District Court for the District of Columbia seeking a tax refund from the IRS of approximately $38 million. The refund is allegedly due to an overpayment of… – Continue reading
(CS) As part of a European tour organised by Republicans Overseas, US Senator Mike Lee on Tuesday visited Luxembourg to rally support for the repeal of the Foreign Account Tax Compliance Act, more commonly known as FATCA. Luxembourg and the US signed FATCA as an inter-governmental agreement in March this… – Continue reading
American NRIs who invest in India are up in arms that since April this year a large number of Indian mutual funds have stopped accepting investments from them. Some mutual funds’ websites explicitly say so, while others have opted for quietly discouraging any such investors that turn up. And this… – Continue reading
Despite Fears, U.K. Luxury-Home Market Didn’t Melt Down A fear of annual mansion taxes on the wealthy, many of them foreigners, is causing ripples in luxury housing markets on both sides of the Atlantic. In London, an Italian hedge-fund executive withdrew an offer a few weeks ago for a 4,000-square-foot… – Continue reading
Barcelona and Argentina star Lionel Messi is to face trial for alleged tax evasion, a Spanish judge has ruled. The judge rejected a prosecution recommendation to drop the charges on the grounds the player’s father was responsible for his finances. Messi and his father Jorge are accused of defrauding the… – Continue reading
While it’s said that death and taxes are inevitable, enough money and clever maneuvering can apparently help sidestep the latter. Witness the so-called dividend arbitrage, which is raising concerns from regulators thanks to its ability to allow big banks to create $1 billion per year in revenue, according to The… – 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
German Finance Minister Wolfgang Schaeuble is working on closing a tax loophole whereby German firms use so-called “patent box” tax breaks available abroad on profits generated from patented research to minimize tax bills, according to a magazine report. Business weekly Wirtschaftwoche said a potential new restriction on the practice, similar to one in… – Continue reading
PORT LOUIS: Mauritius has provided details on majority of information requests received from Indian authorities in the last one year, according to a government official. India has concerns that Mauritius, which is one of the top sources of foreign direct investments into the country, is being used for round-tripping of… – Continue reading
The fund management industry could be exempted from new global rules intended to combat tax avoidance by multinational companies if further work finds that they may “hamper legitimate transactions”, according to the Office for Economic Cooperation and Development (OECD).26 Sep 2014 Corporate Tax Corporate tax Tax Disputes and Investigations Investment… – Continue reading
The Swiss Federal Council has launched a consultation on changes to the flat-rate tax credit, which seeks to ensure double tax relief for permanent establishments of companies that are located in Switzerland. The proposed change affects permanent establishments in Switzerland that are part of a company domiciled in a country… – Continue reading
Interpretative Act (Ato Declaratório Interpretativo) No. 7, of August 15, 2014, issued by the Brazilian Internal Revenue Service (Receita Federal do Brasil – RFB), hereinafter referred to simply as IA 7/2014, deals with the taxation of cross-border payments for the use of data centers located abroad (i.e. based outside Brazil), known… – Continue reading
Multinational companies could be robbing Uganda of billions of shillings through double taxation treaties (DTTs), a new survey has revealed. The study, DTTs in Uganda: Impact and Policy Implications, by Seatini Uganda and ActionAid, shows that many companies are extracting resources and selling their goods and services in Uganda, but… – Continue reading
Multinational companies could be robbing Uganda of billions of shillings through double taxation treaties (DTTs), a new survey has revealed. The study, DTTs in Uganda: Impact and Policy Implications, by Seatini Uganda and ActionAid, shows that many companies are extracting resources and selling their goods and services in Uganda, but not… – Continue reading
POLITICIANS in the rich world like to splutter about the ever more elaborate dodges that big multinational firms undertake to minimise their tax bills. But doing something about them is trickier. America’s Congress is struggling to agree on ways to stop companies “inverting”—switching domicile to reduce tax bills (see article)…. – Continue reading
As the finance ministers and central bank governors from the world’s 20 largest economies gather in a convention centre in the Australian city of Cairns this weekend, anti-capitalist protesters will likely accuse them of doing the bidding of the globe’s all-powerful multinational corporations. But the Group of 20’s financial chieftains… – Continue reading
Yesterday saw the release of the first set of deliverables under the OECD’s project on base erosion and profit shifting (BEPS). These constitute the “building blocks” for an internationally agreed and co-ordinated response to government and media concerns in recent years about the perceived way in which shortcomings in relevant… – Continue reading
THE CLAMPDOWN on tax avoidance by multinational corporations has been bolstered by a series of recommendations made by the OECD. Companies including Google, Amazon and Starbucks have been in the firing line for their use of offshore jurisdictions to drive down their UK tax liabilities. In particular, the companies have… – Continue reading
The OECD will today publish its first recommendations for a co-ordinated international approach to combat tax avoidance by multinational enterprises under the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project. Meanwhile there is already evidence in Europe that the confluence of massive tax avoidance and increased concerns about privacy is… – Continue reading
A proposed clampdown on global tax avoidance took a step forward on Tuesday with a leading global think tank releasing key recommendations ahead of a G-20 meeting later this month. The practice of companies shifting their profits to other country’s jurisdictions to avoid paying tax has drawn criticism from governments… – Continue reading
While Senate Democrats continue to examine specific legislative proposals to deter US multinationals from using corporate inversions to move their tax residence abroad, Republicans remain insistent that any specific anti-inversion legislation should be explicitly linked to comprehensive tax reform. A new bill has been put forward by Charles Schumer (D… – Continue reading
On September 16, 2014, the Organisation for Economic Co-operation and Development (OECD) released its first seven of 15 deliverables under the OECD/G20 base erosion and profit shifting (BEPS) project (the 2014 BEPS Package). The 2014 BEPS Package arises from the Action Plan on Base Erosion and Profit Shifting (the BEPS Action Plan),… – Continue reading
With an eye to next year’s federal election, the Harper government has begun to sprinkle tax-relief treats across the country. Small businesses got theirs last week with a break on employment insurance premiums. Sometimes, however, what governments don’t do can be as telling as their actions. The Finance Department has… – Continue reading
Using foreign stocks to diversify your portfolio can be a good move for investors looking to collect dividends and protect capital. But owners of dividend paying foreign stocks can find themselves being hit by another type of tax: foreign dividend withholding tax. Keeping as much of your dividends as possible… – Continue reading
Withholding on US source income under FATCA started on 1 July 2014. The withholding will apply to gross “proceeds of sale” of securities bearing US source income (which includes repayment of principal on a loan to a US borrower) and, potentially, to “foreign passthru payments” from January 2017. Now that… – Continue reading
Sen. Charles Schumer (D-N.Y.) released legislation Wednesday seeking to roll back the tax benefits for companies that reincorporate abroad. Schumer’s bill takes aim at a maneuver known as earnings stripping, a process by which U.S. subsidiaries can take tax deductions on interest stemming from loans from a foreign parent. The… – Continue reading
The Federal Court has handed down its decision in the case of Task Technology v Commissioner of Taxation in relation to the tax treatment of specific software payments. The case related to payments made by Task to CaseWare International Inc (CWI) for the right to market and distribute CWI software to end users… – Continue reading
If Lib Dems return to government in May, ‘big projects’ would need funding Mr Clegg said well-off would have to pay price – with mansion tax a priority Also wants capital gains tax raised, bringing political stance closer to Labour Party would enforce Royal Charter on press regulation in… – Continue reading
HM Revenue & Customs has established a taskforce to deal specifically with people trying to dodge property tax in the south west of England and in south Wales. The taskforce will target those who have sold one or more properties and haven’t paid capital gains tax or disclosed rental income…. – Continue reading
