Category: Corporates

Pfizer-Allergan Deal Refocuses Market on US Tax-inversion Rules

Pfizer Inc.’s buyout bid for Allergan Plc has financial markets on edge over a possible new move by the U.S. Treasury Department against tax-inversion deals, but the outlook for any such steps was still unclear. For months, Treasury has offered no fresh guidance on the inversion issue, leaving tax experts… – Continue reading

Cantillon: no escape from tax talk at G20 summit

Leaders of world’s major economies gather in Turkish city of Antalya Leaders of the world’s major economies gather in the Turkish city of Antalya this weekend for the tenth annual G20 summit. The summit takes place at a sensitive moment in international affairs. The war in Syria and the resulting… – Continue reading

Two states ordered to recover unpaid corporation tax

Luxembourg and Netherlands must recoup unpaid tax from Fiat and Starbucks of €20m-€30 each The European Commission has ordered Luxembourg and the Netherlands to recover unpaid tax from Fiat and Starbucks in the region of €20 million to €30 million each. On October 21st, competition commissioner Margrethe Vestager condemned tax… – Continue reading

Contractors urged to get international tax affairs in order

Contractors working abroad have been urged to get their international tax affairs in order following the introduction of new legislation. The Organisation for Economic Co-Operation and Development (OECD) has put in place a new automatic exchange of tax information, which means countries across the globe will able to access much… – Continue reading

Shah RukhShah Rukh Khan grilled for 3 hours over alleged FEMA violations Khan grilled for 3 hours over alleged FEMA violations

An ED officer said, “In spite of earning a profit in the first few IPL seasons, Shah Rukh failed to provide any satisfactory explanation for selling the equity shares within a year, that too to a company situated in a tax haven”. Mumbai, November 11 (PTI): The Enforcement Directorate has… – Continue reading

Brazil eyes offshore cash in bid to boost gov’t revenue

PSDB amendment in Lower House cuts Speaker Cunha out of deal, but Senate still has final say BRASILIA — The Lower House of Brazil’s Congress has approved a controversial amnesty bill for undeclared offshore assets, despite criticism from opposition lawmakers who say it would allow the laundering of illegally gained… – Continue reading

A Wale(s) of a Tax Strategy

Companies such as Apple, Starbucks, and Amazon are well known for legally using international law to their advantage when it comes to tax. Now a small Welsh town is mimicking their tactics. Independent traders in Crickhowell are moving their businesses “offshore” to avoid paying tax. The local businesses – including… – Continue reading

Details emerge of massive French tax evasion scam using Latvian bank

French publication Challenges on Friday published details of a massive tax evasion scam by the company France Offshore that promised to reduce tax bills for French nationals using a network of offshore companies and Latvia’s Rietumu Bank. According to Challenges, the massive fraud was masterminded by France Offshore’s Nadav Bensoussan… – Continue reading

OECD Warns Ireland That Growth Will Take More Than Just Low Taxes

Ireland has among the lowest taxes in Europe. However, the Organization for Economic Cooperation and Development (OECD) is not impressed. They warned Ireland that it will have to spend more time selling itself in the new era of global tax transparency if it wants to experience meaningful economic growth. OECD… – Continue reading

LUXEMBOURG: “DAC 2” LEGISLATION INTRODUCED; CRS-LIKE REGIME

A bill submitted to the Luxembourg Parliament in November 2015 would transpose, into Luxembourg domestic law, an EU directive amending a 2011 directive for administrative cooperation and concerning the exchange of information on request. The directive (2011/16/EU) as amended, is referred to as “DAC 2” (the updated “directive on administrative… – Continue reading

INDIA: NO TRANSFER PRICING ADJUSTMENT WHEN TAX AVOIDANCE NOT POSSIBLE

The Mumbai Bench of the Income-tax Appellate Tribunal held that an Assessing Officer cannot “mechanically” refer a taxpayer’s international transactions to a Transfer Pricing Officer for a determination of the arm’s length price, but must first independently conclude that the taxpayer did not determine the arm’s length price or did… – Continue reading

Transparency International: G20 failing on corruption

Corporate corruption is still prevalent in rich Group of 20 nations despite their pledges last year to close loopholes, according to Transparency International. It has listed Brazil, China and the US among the offenders. Transparency International on Thursday labeled this weekend’s G20 summit in Turkey as a mere “photo opportunity,”… – Continue reading

East West Bank falls short on preventing money laundering, Fed warns

Pasadena’s East West Bank must beef up its efforts to prevent money laundering after federal regulators said its practices were not sufficient. The bank, which has operations in the United States, Hong Kong, China and Taiwan, was ordered by the Federal Reserve on Thursday to correct problems with its anti-money-laundering… – Continue reading

Low taxes alone not enough for growth, says OECD

Chief economist says clampdown on tax avoidance will be ‘negative for Ireland’ Ireland will have to sell itself as more than just a low-tax destination in the new era of global tax transparency, OECD chief economist Catherine Mann has said. She said moves to better align taxable profits with real… – Continue reading

Brazil lower house passes amnesty for unreported offshore assets

BRASILIA, Nov 11 (Reuters) – The lower house of Brazil’s Congress approved amnesty for undeclared offshore assets on Wednesday despite criticism from opposition lawmakers who said it would allow the laundering of illegally gained money. To reduce its budget deficit, President Dilma Rousseff’s government is hoping to raise 11 billion… – Continue reading

Green card may no longer be a valuable asset for NRIs as Fatca sword hangs over their heads

MUMBAI: A US passport doesn’t look like such a priced possession anymore. Some Indians even want to surrender their hard-won green cards. India and the US are set to freely exchange financial information about their citizens, leaving no asset concealed. This could mean US tax officials imposing punitive levies on… – Continue reading

Big Pharma’s deal-making zeal could be on the wane

A rout in pharmaceutical and biotech stocks has altered the equation for chief executives thinking about big-ticket mergers and acquisitions. On one hand, target companies are much cheaper than they were: roughly $130 billion has been wiped off the Nasdaq biotech index since Hillary Clinton, the Democratic presidential front-runner, pledged… – Continue reading

US Justice Department Announces Two Banks Reach Resolutions Under Swiss Bank

The Department of Justice announced today that Banque Internationale à Luxembourg (Suisse) SA (BIL Switzerland) and Zuger Kantonalbank (ZGKB) have reached resolutions under the department’s Swiss Bank Program. These banks will collectively pay penalties totaling more than $13 million and continue to cooperate with the department. “The agreements reached today… – Continue reading

ANDY: IS OUR “ECONOMIC RECOVERY” BASED ON A SILICON BUBBLE?

Irish corporation tax returns are behaving oddly: the Department of Finance estimates that they are running €2 billion (74 percent) ahead of forecast for the year. Economist Seamus Coffey has described these figures as “very strange”. Coincidentally (or perhaps not) the global accounts of the Apple corporation revealed an increase… – Continue reading

Motor racing legend Alan Jones linked to serial conman Peter Foster

Australian motor racing legend Alan Jones has become embroiled in the collapse of an online gambling company operated by notorious conman Peter Foster which owes $11.5 million to about 150 investors. The 69-year-old former winner of the Formula One Drivers’ Championship was named in a writ to be lodged in… – Continue reading

Contractors running out of time

Contractors are running out of time to get to grips with international tax regulations, according to CXC Global. The contractor management specialist has warned professionals that the new automatic exchange of tax information, put in place by the OECD, will mean that countries will have considerably more information on potential… – Continue reading

Transfer pricing — the global phenomenon

THE world appears to be getting much smaller. Rapid technological advances, increased people mobility, and changes in the international political climate have all helped to break down many of the traditional barriers to global and regional trade. For dynamic, fast-growing businesses, this increased globalisation represents an excellent opportunity for businesses… – Continue reading

St Kitts & Nevis pursuing quiet diplomacy to recalibrate international relationships – PM Harris

The nine-month old Team Unity administration has been pursuing quiet diplomacy to recalibrate international relationships for the benefit of the people of St. Kitts and Nevis, reports SKN Vibes. So said St. Kitts and Nevis Prime Minister Dr. the Hon. Timothy Harris at last week’s press conference at government headquarters…. – Continue reading

Apple confident ahead of European Union tax judgement

Apple chief executive Tim Cook said he was feeling “pretty good” ahead of the European Union’s judgement on its Irish tax arrangements, as the company announced 1,000 new jobs in Ireland on Wednesday. Ireland’s tax arrangements with the US tech giant are under investigation by the EU to see if… – Continue reading

EU calls corporations to account for low-tax deals

European Union lawmakers have called 13 multinational companies to a meeting next week to talk about the low-tax deals they have struck with EU jurisdictions, reports CBC News. Among the companies to be questioned on Nov. 16 will be Amazon.com, Disney, Coca-Cola Co, Anheuser-Busch InBev NV, HSBC Holdings, Ikea Group… – Continue reading

UK: CHANGES TO INTEREST DEDUCTIBILITY RULES, IMPLICATIONS FOR TRANSFER PRICING

Following the October 2015 release of the OECD’s base erosion and profit shifting (BEPS) deliverables, some consultations in the UK have already been opened—including one on the UK’s rules concerning the deductibility of corporate interest expense and how this treatment would be affected by BEPS Action 4 (which seeks to… – Continue reading

Transparency is best tonic for multinational tax avoidance

‘Special purpose’ approach by accountants hides corporate secrets Amid the maelstrom over the GST, the Senate last night passed what may be the most useful piece of legislation yet to combat multinational tax avoidance. The new law was not carried by the government, whose track record on tackling big tax… – Continue reading

Fair’s Fair: Balancing The Interests of the State and of Wealthy Migrants

Clare Maurice, Arabella Murphy and Sophie Mazzier, Maurice Turnor Gardner LLP For better or worse, the concept of “fairness” is here to stay in relation to taxation, whether domestic or international. Politicians of all persuasions like to insist that their respective policies will ensure that everyone pays his or her… – Continue reading

Private Client 2015: Trust & Advisory Services Analysis

In this edition we also include the leading trustees, private bankers and accountants serving the private client industry. RBC Wealth Management leads our research in trust and advisory services with an impressive 18 names recommended. Alan Binnington specialises in establishing and administering trust and fiduciary structures for high net worth… – Continue reading

EY: Broadening the taxable basis across the GCC and MENA

To increase the scope of income tax laws, GCC countries are pursuing tax determinations with significantly broader interpretations of activities or actions that constitute doing business in-country. New concepts like Virtual Service Permanent Establishment and dependent agents are being used in Saudi Arabia and Kuwait to determine taxable presence or… – Continue reading

Australia: The transfer pricing Chevron decision – funding, parental support, currency… and the experts

Key Points: The rejection of the Commissioner’s position on the relevance of credit rating agencies and the relevance of implicit support will give rise to uncertainty going forward, as it is unclear how an arm’s length interest rate can be practically determined. The Federal Court’s recent decision in Chevron Australia… – Continue reading

Michael Gray: The UK’s tax avoidance scandal is a sorry tale

DID you hear the story about the Queen, tax evasion, a nationalised British bank for the rich and famous, a whistleblower and a £7bn under sale to ‘reward cronies and cheat the taxpayer’? Sounds like a pretty big deal, right? But last Thursday’s damning testimony from Helen Goodman MP –… – Continue reading

3 Stocks to Buy if Chris Christie Becomes President

A Chris Christie administration would likely make shareholders at some major U.S. companies very happy. The two-term New Jersey Governor has called for an array of pro-growth, business-friendly reforms as he bids for the Republican nomination. Christie is in favor of lowering corporate taxes so companies earn more profits, raising… – Continue reading

Irish PM defends country’s corporation tax arrangements

Irish Prime Minister Enda Kenny has defended his country’s low rate of corporation tax, currently set at 6.25 per cent, and Dublin’s arrangements with global corporations which house subsidiaries in the country, reports Digital Look. Over the last decade, major corporations such as Google and Dell have created corporate subsidiaries… – Continue reading

Vestager Lauds Tax Decisions as She Reviews Apple, Amazon Cases

The European Union’s top antitrust official lauded rulings ordering two companies to repay tens of millions of euros in back taxes as she considers similar decisions involving Apple Inc. and Amazon.com Inc. European Union competition chief Margrethe Vestager told lawmakers Monday that the rulings last month against Starbucks Corp. and… – Continue reading

Paradigm shift in tax landscape through BEPS must also engender tax certainty

A paradigm shift in the way business is conducted is taking place as new base erosion of profit shifting (BEPS) rules are aligned with tax systems, but more tax certainty and rules that suit specific African circumstances are needed, a Deloitte OECD Transfer Pricing Guidelines seminar heard on Wednesday, 04… – Continue reading

Crickhowell: Welsh town moves ‘offshore’ to avoid tax on local business

The Powys tax rebellion, led by traders including the town’s salmon smokery, local coffee shop, book shop, optician and bakery, could spread nationwide When independent traders in a small Welsh town discovered the loopholes used by multinational giants to avoid paying UK tax, they didn’t just get mad. Now local… – Continue reading

Why Australia’s landmark tax ruling against Chevron is a first battle in a global war on profit shifting

At a very high level, it’s a simple concept: a multinational borrows money from a related company overseas, and then uses the interest bill and the repayment methods to reduce tax exposure in Australia. If the loans – and the interest rates – are big enough, the tax savings can… – Continue reading

EU to rule on Apple tax avoidance by Christmas

Ireland is expecting European Union regulators to issue a decision on the country’s tax deal with Apple before the end of the year. The Irish finance minister said the move could force the iPhone maker to pay substantial back taxes. The European Commission has already ordered Dutch authorities to recover… – Continue reading

Bermuda: Day Of The Deed

Article by Patrick W Martin and Ashley Fife With a net worth of USD77.1 billion, Mexican telecoms businessman Carlos Slim Helú was ranked the second richest person in the world in a 2015 survey.1 At the end of 2014, 16 of Mexico’s citizens were on Forbes’ billionaires list.2 As for… – Continue reading

Mexico’s 16% Discount for Paying Cash Shows Tax Evasion’s Allure

On a warm afternoon last month, Mexican central bank Governor Agustin Carstens looked out over sun-drenched piles of dirt and construction equipment near Guadalajara and hailed the groundbreaking of a new currency-printing plant as a sign of a solid economy. There’s one catalyst for rising cash demand that isn’t a… – Continue reading