Category: Corporates

From Choppergate to Lara Bingle, spending is the taxing issue

It was Kerry Packer who famously told the nation’s politicians “if anybody in this country doesn’t minimise their tax they want their head read” because “as a government I can tell you you’re not spending it that well that we should be paying extra”. The words have gone down in… – Continue reading

Report :Julius Baer Seeks Deal With US To Settle American Offshore Accounts Case

Swiss private banking group Julius Baer Group Ltd. (JBAXY.PK,JBARF.PK) may have to pay more than it anticipated to settle a case with the U.S. Justice Department over American offshore accounts, according to media report quoting people familiar with the matter. The report indicated that the U.S. prosecutors could ask Julius… – Continue reading

Court’s winding-up ruling on Hong Kong’s Yung Kee goose restaurant sends signal to offshore companies

Legal experts say court order for restaurant’s parent company based in British Virgin Islands could lead to resolution of more disputes in city Hong Kong’s top court recently gave the go-ahead for the parent company of the famous Yung Kee roast goose restaurant in Central to be wound up, despite… – Continue reading

Netflix is latest multi-million-pound global company that does not pay UK corporation tax despite generating £200m of revenue in Britain

Netflix the online movie rental service did not pay any UK corporation tax last year, despite generating an income of £200million in Britain. The world’s biggest internet movie streaming service has five million subscribers in the UK alone and has proved a hit by offering U.S. shows like House of… – Continue reading

Pakistani bank in NY takes steps to allay US concerns after being hit by curbs

NEW YORK – The General Manager of Pakistan’s Habib Bank Ltd., New York branch, said Friday that steps have been taken to address the concerns of U.S. authorities after being hit by an enforcement order that barred the bank from conductingany dollar-clearing transactions or accepting any new accountsfor U.S. dollar… – Continue reading

Australia: Country-by-country reporting guidelines

The Australian Taxation Office (ATO) on 17 December 2015 released guidelines that address country-by-country reporting. The ATO release—Law Companion Guideline (LCG) 2015/3—discusses Tax Laws Amendment (Combating Multinational Tax Avoidance) Act 2015 that was enacted earlier this month and discusses, in particular, Schedule 4. Background Schedule 4 created Subdivision 815-E of… – Continue reading

Tim Cook calls notion of Apple avoiding US taxes ‘political crap’

Apple CEO says the company pays ‘every tax dollar we owe’ amid debate in the US over corporations avoiding tax by using offshore units Apple’s chief executive Tim Cook has dismissed as “total political crap” the notion that the technology giant was avoiding taxes. Cook’s remarks, made on CBS’ 60… – Continue reading

Foreign-invested footwear manufacturers show their power

Footwear is one of the industries with high export turnover. However, the profitable industry is being controlled by companies from South Korea and Taiwan. According to the Vietnam Leather & Footwear Association (Lefaso), with 800 enterprises and 1 million workers, FIEs account for one-fourth of total number of footwear makers,… – Continue reading

Swiss Banker to Royalty to Pay $45.4 Million to End U.S. Tax Probe

Edmond de Rothschild (Suisse) SA agreed to pay $45.4 million to avoid prosecution for helping U.S. clients evade taxes, admitting it aided them in moving cash and using sham offshore entities to hide money from the Internal Revenue Service. Rothschild is the 68th Swiss bank to reach an accord with… – Continue reading

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Case law Chevron appeal to the Full Federal Court Chevron Australia Holdings Pty Ltd has appealed the decision of the Federal Court in Chevron Australia Holdings Pty Ltd v Commissioner of Taxation (No 4) [2015] FCA 1092 to the Full Federal Court. For details of the Federal Court decision, please… – Continue reading

US Justice Department Announces Joint Resolution With Two Banks Under Swiss Bank

The Department of Justice announced today that Edmond de Rothschild (Suisse) SA and Edmond de Rothschild (Lugano) SA (collectively EdR Switzerland) reached a joint resolution under the department’s Swiss Bank Program. EdR Switzerland will pay a penalty of more than $45 million. The Swiss Bank Program, which was announced on… – Continue reading

India: Marketing intangibles by licensed manufacturer, no transfer pricing adjustment

The Delhi High Court held that the taxpayer’s advertising, marketing, and sales promotion expenses were not an “international transaction” under provisions of India’s tax law, and thus, could not be the basis of a transfer pricing adjustment. The court further held that a “bright line test” as applied by the… – Continue reading

EU: Draft “anti-BEPS” directive, addressing corporate tax planning and evasion

The Council of the European Union released details of a possible draft EU directive, addressing certain “anti-base erosion and profit shifting” (anti-BEPS) initiatives. The issues addressed concern certain international aspects of the proposal for an EU “common consolidated corporate tax base” (CCCTB), and reflect issues that are directly related to… – Continue reading

Australia lays bare corporate tax details

The Australian Government’s efforts to improve tax collections are more urgent amid falling revenue from weak commodity prices, the Wall Street Journal reports Malcolm Turnbull’s government took the rare step of making public the tax affairs of scores of multinationals, highlighting that many big names—including Apple Inc. and Volkswagen AG… – Continue reading

The deal between Turkey and FATCA

Turkey’s ruling Justice and Development Party (AKP) government, in power for 13 years, has been notoriously lax and often late when it comes to implementing stringent rules controlling money in order to ensure better transparency in financial movements, halt tax evasion, prevent illicit funding and disrupt money laundering activities. That… – Continue reading

Spin Master Reaches Agreement With Canada Revenue Agency to Resolve Previously Disclosed Transfer Pricing Matter

Liability below the mid-point of the range in IPO prospectus TORONTO, Dec. 18, 2015 /CNW/ – Spin Master Corp. (“Spin Master” or the “Company”) (TSX: TOY) announced today that it has reached a settlement agreement with the Canada Revenue Agency (“CRA”), which resolves a previously disclosed transfer pricing matter arising… – Continue reading

Battle of words over taxation

On December 8, there was a brief note in the media about the fact that Malta had managed to include a reference to flexibility into a European Council communiqué on taxation. You would be forgiven for overlooking it, assuming it was just a pedantic attempt to score political points. Think… – Continue reading

UPDATE 1-Australia unmasks 600 firms which paid no tax on big profits in 2014

SYDNEY, Dec 17 (Reuters) – Australia on Thursday identified 600 companies which it said paid no tax last financial year, including Halliburton Co and Hilton Worldwide Holdings Inc, as part of a campaign to challenge “overly aggressive” tax arrangements. The Australian Taxation Office published the income and tax rates of… – Continue reading

Swiss bank hid assets for Jews, then tax evaders

Dreyfus Sons & Co. has operated for two centuries as a private Swiss bank, catering to Jewish clients who wanted to hide assets from the Nazis during the 1930s and World War II. More recently, it helped U.S. clients hide assets from the Internal Revenue Service by concealing their true… – Continue reading

Australian tax office names names in multinational avoidance row

Australian tax authorities on Thursday took the unprecedented step of publishing the records of hundreds of companies, including Google Inc (GOOGL.O) and Apple Inc APPL.O, which show they paid little or no tax on their in-country earnings. Of more than 1,500 largely foreign-owned companies which reported total earnings over A$100… – Continue reading

New Corporate Offence Modelled on The Bribery Act

Summary In the March 2015 Budget the Chancellor announced tough new sanctions for tax evasion, intended to have a deterrent effect. After a period of consultation, the intention to proceed with these measures was confirmed in the 2015 Autumn Statement. In summary, the measures to be implemented are:  A new… – Continue reading

EC Extends Investigation Into Apple Tax Deal

The European Commission has extended its investigation into a tax ruling provided by the Irish Government to Apple. The Commission has asked the Irish authorities for additional information on the case. Irish media reports that the Government does not anticipate a decision until 2016. In late November, Finance Minister Michael… – Continue reading

‘Pfizer tie-up ‘opportunity’ for Ireland says IDA boss

The $160bn (€146.5bn) merger of US pharmaceutical giant Pfizer with Dublin-based Allergan is an “opportunity” for Ireland, according to IDA chief executive Martin Shanahan. Last month Pfizer, the world’s largest pharmaceutical company, announced plans to merge with Botox manufacturer Allergan in a deal that will create the world’s biggest drug… – Continue reading

LUXEMBOURG’S LUXLEAKS DEAL

Journal: The EU’s ongoing investigation into Luxembourg’s tax agreements with multinational corporations is threatening to leave a black mark on the Grand Duchy at the end of its six-month European presidency. Luxembourg’s finance ministry could face legal action from the European Commission, as the EU authority continues its probe into… – Continue reading

Uber’s Double Dutch tax dodge undermining local economies

Why would anyone object to Uber, the user-friendly online drive-share service? Uber’s many riders obviously love it, but it seems civic officials are having conniptions. Their main complaint is that Uber drivers are unlicensed to carry passengers and might not have adequate insurance. In addition, officials are genuinely concerned that… – Continue reading

Mexico: Reminder of expanded transfer pricing disclosures for 2016

Provisions under new article 76A of Mexico’s tax law reflect certain items of the OECD’s base erosion and profit shifting (BEPS) project—in particular expanded transfer pricing disclosure requirements that will apply for the 2016 tax year. Background The Mexican government’s 2016 federal budget, presented 8 September 2015, included proposals for… – Continue reading

Australia shuts down investment schemes run by fund linked to 1MDB

The Australian Federal Court has ordered five investment schemes managed by Avestra Asset Management to shut down, The Australian reported today, following the fund’s link to the 1Malaysia Development Berhad (1MDB) controversy. It was reported that the judge made the decision after going through a report from liquidators, who unearthed… – Continue reading

Profitability or integrity? Why not both?

Growth and profitability have been at the crux of the corporate agenda and defined the way businesses function. Companies have nevertheless encountered challenges while trying to achieve these goals, which have inevitably required them to sometimes ‘work around the way of the land’. For instance, it is a common concern… – Continue reading

Swiss banks pay $130M to avoid US tax evasion charges

Three Swiss banks, including a unit of France’s Crédit Agricole SA, will pay a total of more than $130 million to the U.S. Justice Department to avoid possible prosecution for helping Americans evade taxes, the department said on Tuesday. The Zurich-based unit of Crédit Agricole will pay $99.2 million, the… – Continue reading

Foreign Banks Pay To Avoid Tax Evasion Charges As More Americans Disclose Offshore Accounts

Lately, the IRS is warning offshore account holders to disclose before it’s too late. Under FATCA, banks everywhere want to know if you are compliant with the IRS. And the cost of compliance for many people is growing. The IRS updated its list of foreign banks where accounts trigger a… – Continue reading

Nokian Tyres received EUR 87 million additional payable tax in Finland regarding years 2007-2010

the company will make a complaint against the decision Nokian Tyres plc (HEX:NRE1V) has received a renewed reassessment decision from the Tax Administration, according to which the Company is obliged to pay EUR 87 million additional taxes with punitive tax increases and interests concerning tax years 2007-2010. Payment must be… – Continue reading

China ready to moderate sharp offshore yuan falls: sources

[BEIJING] China’s central bank is on guard against a sudden attack on the yuan in offshore markets, and is ready to intervene if the gap between offshore and onshore exchange rates becomes destabilising, sources involved in policy discussions say. Though the People’s Bank of China (PBOC) wants to avoid a… – Continue reading

Icahn Says Stop Corporate Inversions By Giving Tax Break

Billionaire investor Carl Icahn has a strong opinion on almost every subject, especially politics. He’s also quite happy to share that opinion with anyone who will listen to or read what he has to say. Icahn’s comments this week on how to stop future tax-motivated corporate inversions such as the… – Continue reading

Piper Jaffray Sees Renewed Monsanto (MON) Bid for Syngenta (SYT) Near Start of 2016

DuPont and Dow are now officially combining and Piper Jaffray analyst, Brett Wong, thinks further consolidation is coming with Monsanto (NYSE: MON) likely to renew the pursuit of Syngenta (NYSE: SYT) towards the beginning of the year. Piper thinks a renewed bid for Syngenta would be viewed negatively by investors… – Continue reading

ATO to unveil large business hit list, clamps down on Singapore hubs

Hundreds of millions of dollars of revenue could be up for grabs as the Tax Office announces reviews of multinationals using offshore hubs in Singapore to minimise their tax. The ATO has issued a warning to multinationals to come forward immediately to discuss their overseas hub arrangements, if they have… – Continue reading

BEPS also applies to medium-sized businesses

Stricter Tax and documentation requirements for foreign transactions “Amazon, Facebook, Google and Starbucks pay little taxes …” or “Luxembourg attracts international corporations” – headlines like these have 62 states and the OECD called into action. The result was “base erosion and profit shifting” BEPS shortly. Even the German SME sector… – Continue reading

Ireland regains its swagger in the tax arena

Something unusual is happening with the Irish corporation tax in 2015 — so unusual that Ireland’s top tax man felt obliged to write to the parliament to explain what is going on. But the explanation left a lot to be desired. According to government data, Ireland received 57.7 percent more… – Continue reading

EU probe of Apple’s Irish tax deal extended to 2016

A European Union investigation into whether Apple’s bespoke tax arrangement with the Irish government amounts to illegal state aid has been delayed again, as officials in Brussels continue to gather more information. “We do not expect any decision until after the new year,” a spokesperson for the European Commission told… – Continue reading

European Union: EU Combats International Tax Planning: The Amended Parent Subsidiary Directive

You have probably read about the OECD’s comprehensive base erosion and profit shifting (or BEPS) action plan aimed at tackling undesirable international tax planning by corporates. In recent years, the EU, particularly the European Commission, has put substantial effort into accelerating BEPS-like measures in an EU context. A striking example… – Continue reading

Coca-Cola Fights $9.4 Billion Transfer Pricing Adjustment

Dec. 14 — The Coca-Cola Co. filed a petition in U.S. Tax Court challenging a proposed $9.4 billion income adjustment related to the company’s transfer pricing for tax years 2007-09 (Coca-Cola Co. v. Commissioner, T.C., petition filed, 12/14/15). If the adjustment is sustained, the company could face a tax bill… – Continue reading

Meg Hillier: Meet the Public Accounts Committee chairwoman taking over from Margaret Hodge

Meg Hillier has a tough act to follow. This parliament’s Public Accounts Committee chairwoman had a ringside seat watching her predecessor, Margaret Hodge, tear into tax avoiders and the tax man. “It is very exciting – you see all the guts of Whitehall spilled out in front of you,” she… – Continue reading