Category: K-P

Transfer Pricing: BEPS And New Documentation Requirements

Introduction Successive surveys of tax executives and senior finance professionals at multinational companies show that risks associated with transfer pricing have become the number one tax-related concern for businesses operating across several jurisdictions. Ernst and Young’s (EY’s) latest Global Transfer Pricing Survey shows that businesses are taking increasing heed of… – Continue reading

Federation to sign TIEA’s with Ireland and South Africa

BASSETERRE, St. Kitts, May 21st 2014 (CUOPM) – The St. Kitts and Nevis Federal Cabinet has paved the way for the signing of Tax Information Exchange Agreements (TIEAs) with Ireland and South Africa.   Cabinet has approved the draft agreements between officials of the respective countries. “Those negotiation exercises have since… – Continue reading

Brazil’s Scolari under investigation for alleged tax evasion in Portugal

Luiz Felipe Scolari is the subject of a criminal investigation in Portugal, authorities said Wednesday, bringing an unwelcome distraction for the Brazil coach as his country prepares to host the World Cup. Officials wouldn’t say what the investigation is about. In Portugal, ongoing investigations fall under the country’s judicial secrecy… – Continue reading

Wyoming businessman jailed for using concealed Nevis bank account for tax evasion

BASSETERRE, St. Kitts – NEWS reaching this publication states that a businessman from Wyoming, United States of America was on Wednesday (May 7) sentenced to serve 36 months in jail for tax evasion.   According to a US Department of Justice press release, the businessman, Robert C. Sathre, appeared before US District… – Continue reading

Multinationals escape tax due to ‘exceptional’ rules, study claims

Large subsidiaries of multinationals, such as Apple and Google, which are based in Ireland are able to escape paying corporation tax due to an “exceptional” interpretation of tax laws by the Revenue Commissioners, a new study claims. A research paper by James Stewart, associate professor in finance at Trinity College… – Continue reading

Report: Netflix Sets French Headquarters In Luxembourg to Bypass Regulations

PARIS — Netflix is set to follow iTunes and Google’s footsteps: The service is expected to launch in Gaul in the fall but will be headquartered Luxembourg in order to avoid the heavy French regulations. French newspaper Les Echos reported the move will bring Netflix’s French outpost together with its other European headquarters —… – Continue reading

Nokia India, Finnish parent discuss tax evasion in emails

The department had slapped a tax demand of Rs 2,080 crore on the company last year while re-opening the assessment for AY 2006-07 and 2007-08. As Finnish phone-maker Nokia strives to meet the April 30 deadline for sealing the $7.2 billion deal with Microsoft, its tussle with the Indian tax… – Continue reading

50% of H-1B visas in 2013 went to offshore companies, mostly in India

WASHINGTON, DC: As the US Citizenship and Immigration Services (USCIS) opened its doors to this year’s round of H-1B visa applications, data show that about 50% of last year’s H-1B visas were granted to offshore companies, and the top two of those are based in India – Infosys and Tata… – Continue reading

Senate Probe: Caterpillar Avoided $2.4B in U.S. Taxes

Caterpillar avoided $2.4 billion in federal taxes between 2000 and 2012 by shifting $8 billion in profits from international parts sales to a tax haven in Switzerland, said Chairman Carl Levin, (D-MI), of the Senate Permanent Subcommittee on Investigations on Monday. Joining Microsoft (MSFT), Hewlett Packard (HPQ) and Apple (AAPL),… – Continue reading

I-T dept signs APAs with 5 MNCs, more pacts in offing

NEW DELHI: Seeking to reduce litigations and promote foreign investments, the Income Tax department has signed Advance Pricing Agreements with 5 multinational firms and plans to enter into more such pacts. “We have signed 5 APAs so far. We will be signing more in the coming days. Foreign companies are eager to… – Continue reading

Multinationals face new rules on aggressive tax avoidance

OECD plan to make practice of shifting locations ineffective New rules aimed at preventing the type of aggressive tax avoidance schemes run by some of the largest multinational employers here will begin to be introduced in September, according to a draft report seen by The Irish Times . Structures that artificially shift… – Continue reading

Caterpillar Previews Tax Defense for Senate Offshore Hearing (1)

Caterpillar (CAT:US) Inc. began defending its international tax maneuvers as a U.S. Senate investigative panel set an April 1 hearing to examine the company’s “offshore tax strategy.” Representatives from Caterpillar and PricewaterhouseCoopers LLP will testify, according to the hearing notice posted today by the Senate’s Permanent Subcommittee on Investigations. The committee, led… – Continue reading

Luxembourg Ordered to Give EU Tax-Deal Detail Amid Aid Probe (1)

European Union competition watchdogs ordered Luxembourg to hand over details of tax breaks for businesses after they said the Grand Duchy was hindering a state-aid probe spanning several EU nations. Luxembourg refused to deliver details concerning the 100 largest companies benefiting from a special program for companies whose profits stem… – Continue reading

Companies’ Offshore Profits Keep Piling Up

U.S. corporations added at least $206 billion to their stockpiles of offshore profits last year, parking earnings in low-tax countries until Congress gives them a reason not to. They have accumulated $1.95 trillion outside the U.S., up 11.8 percent from a year earlier, according to securities filings from 307 corporations…. – Continue reading

Ireland’s Noonan Clarifies Corporate Tax Developments

Changes to Ireland’s residency rules, designed to eliminate mismatches between tax treaty partners, have not yet affected the residency status of any company, Finance Minister Michael Noonan has confirmed. The reforms were introduced in Noonan’s 2014 Budget and included in this year’s Finance Bill. They are intended to prevent companies… – Continue reading

U.S. companies add offshore profits to avoid taxes

The largest U.S.-based companies added $206 billion to their offshore profit stockpiles last year in order to put earnings in low-tax countries, Bloomberg reported. Multinational companies accumulated $1.95 trillion outside the U.S., which was up 11.8 percent from a year earlier, according to securities filings from 307 corporations reviewed by Bloomberg. Governments… – Continue reading

Apple to IBM hoard $206b abroad to avoid US tax

The largest US-based companies added $206 billion to their stockpiles of offshore profits last year, parking earnings in low-tax countries until Congress gives them a reason not to. The multinational companies have accumulated $1.95 trillion outside the US, up 11.8 per cent from a year earlier, according to securities filings… – Continue reading

TAX FREE | US tech giants’ offshore cash piles earn interest from government: report

LONDON — Four of the biggest U.S. technology groups collectively hold an estimated $124 billion in U.S. Treasury debt, much of it offshore, earning them tax-free interest, the UK’s Bureau of Investigative Journalism (BIJ) said on Thursday. The finding means Apple Inc, Microsoft Corp, Google Inc and Cisco Systems Inc… – Continue reading

Taxpayers Pay $163 Billion In Interest To Apple, Cisco, Google, Microsoft In Offshore Accounts

United States taxpayers make large interest payments to the top four technology firmsfor the $163 billion in US government debt the companies own and shelter in tax-freeoffshore accounts. Apple, Cisco Systems, Google, and Microsoft legally hold $124 billion in US Treasury securities and $39 billion in US government agencydebt in accounts overseas, allowing them to avoid the 35… – Continue reading

Apple, IBM and Microsoft Lead U.S. Tax-Avoiding Spree

Apple Inc., IBM Corp. and Microsoft Corp. have been picked out as some of the main culprits of stockpiling profits abroad in order to avoid huge tax bills, according to Bloomberg. Last year, the largest U.S. firms collectively added an extra $206 billion to their offshore profit stockpiles based in low-tax countries. Together the… – Continue reading

Finnish envoy raps Indian tax laws

KOLKATA, MARCH 11: Aapo Polho, Ambassador of Finland to India, has said that taxation issues have diminished India’s attractiveness to global investors, including Finnish companies. Referring to mobile handset-maker Nokia’s conflict with the Indian Government over double taxation, he said, “The company (Nokia) played by the book”. “Over the past… – Continue reading

Brazil tries to grasp online cross-border taxation

The Brazilian government has been trying to catch up on a number of areas of the digital economy, one of them being online cross-border taxation – but not without controversy. During the Mobile World Congress (MWC) last month, the Brazilian communications minister Paulo Bernardo said Brazil is a “tax haven”… – Continue reading

Black money: Swiss exchanging ‘lawful’ info with India

New Delhi: With India stepping up its pursuit of alleged black money in Swiss banks, Switzerland says it is exchanging information with Indian authorities on all lawful requests, but cannot help on enquiries based on stolen banking data. The European country, which has often been accused of being the most… – Continue reading

G20 gives Google, Microsoft, Apple et al tax deadline

G20 finance ministers speak loudly, mention big stick The world’s top 20 finance ministers have signalled once again that they’re sick of their taxes disappearing offshore and have signalled a strong intention to get their cash back. The ministers in question are all members of the Group of Twenty (G20)… – Continue reading

U.S. scrutinizing Swiss insurers in offshore probe – WSJ

Feb 24 (Reuters) – U.S. prosecutors are widening their probe of how Swiss banks helped wealthy Americans avoid taxes to look at insurers as well, the Wall Street Journal reported on Monday, citing unnamed sources. Insurers in Switzerland have been preparing for months for U.S. officials to investigate products known as insurance… – Continue reading

Ortega’s Zara Fashions Tax Avoidance by Shifting Profits to Alps

Zara’s celebrity chic helps make its Spanish parent company, Inditex SA, the world’s biggest fashion retailer. Singer Taylor Swift, reality-television personality Kim Kardashian and Kate Middleton, Prince William’s wife, have all been spotted wearing the stylish, low-cost brand. Another reason for Inditex’s industry-best profit margins of almost 15 percent: the… – Continue reading

G20 to tackle transfer pricing with new tax exchange scheme

The days of multinational companies being able to use the Double Irish Dutch Sandwich to avoid taxation may soon be coming to an end, with the G20 group of nations looking to create a reporting standard to allow for automatic exchange of tax information. In the official communique coming at the end… – Continue reading

Global tax avoidance – a trillion dollar evil

In a world of widening inequality, it is perhaps the most pernicious injustice of them all. Multinational corporations and wealthy individuals avoiding tax on an unprecedented scale, shuffling assets, income and debt to the most favourable tax jurisdictions and confounding hapless authorities. It is impossible to identify exactly how much… – Continue reading

Irish Corporate Tax 2014: How official spin and distortion works – in short-term

Irish Corporate Tax 2014: The current Irish governance system has remained unchanged through boom and bust and the addiction to political spin, distortion and sometimes lies, works at least in the short term while in some cases it has an enduring impact. To paraphrase Abraham Lincoln, America’s 16th president, it’s possible “to… – Continue reading

Murdoch’s $880m tax win raises issues of global corporations’ tax liability

An $880 million payout to Rupert Murdoch’s News Corporation has reignited the debate over whether global companies pay their fair share of tax in Australia. News was paid the money after winning a long-running legal battle with the Tax Office relating to a 1989 restructure of the media empire involving… – Continue reading

A Solution for Corporate Tax Avoidance

Some three hundred years ago Sir Walter Scott asked, “Breathes there a man with soul so dead who never to himself hath said, This is my own, my native land.” Well, in America corporations are legally deemed  “persons,” so the answer to Scott’s question is “Yes,” at least when it… – Continue reading

New research makes it plain that Ireland is a tax haven

Is Ireland a tax haven? The Irish government bristles at the question, given rising interest in cracking down on offshore financial centers, but research from a Trinity College professor is pretty definitive: Yes, it is. When Ireland’s leaders defend their country from accusations that global companies like Apple use Irish… – Continue reading