Category: Ireland

Ireland: The taxman’s verdict

Pascal Saint-Amans sups water from a plastic cup, coughing and spluttering. There’s a weariness about him. He’s battling a cold, and is feeling “bloody sick”. The state of his health isn’t terribly surprising given his recent punishing travel schedule. New York last week preceded by Peru, where G20 finance ministers… – Continue reading

After Blow to Europe Tax Havens, Some Promise More Staying Power

Luxembourg and the Netherlands lost a bit of luster as tax havens for some of the world’s biggest companies this week, as the European Union fired its latest salvo aimed at multinational tax dodging. Yet the Netherlands is on pace to maintain its attractiveness as a tax-friendly address for multinationals,… – Continue reading

Apple Stakes Raised as EU Orders Starbucks, Fiat Tax Repayments

Apple Inc. and Amazon.com Inc. got a preview of what the European Union may have in store for them after regulators ordered Starbucks Corp. and a Fiat Chrysler Automobiles NV unit to repay millions of euros in back taxes. The EU said the coffee company and the Italian carmaker were… – Continue reading

Mandatory disclosure rules: OECD releases final paper on BEPS 12

What has happened? On 5 October 2015 the OECD issued its final paper on BEPS Action 12 Mandatory Disclosure Rules, Action 12 – 2015 Final Report (Paper). In this Alert we highlight the main issues and recommendations for taxation reform raised in the Paper. The Australian Treasurer’s BEPS Press Release… – Continue reading

EU: “TAX RULINGS” IN LUXEMBOURG, NETHERLANDS DEEMED ILLEGAL STATE AID

The European Commission today announced a decision that Luxembourg and the Netherlands granted selective tax advantages to two multinational corporate entities, and as such, these “tax advantages” are illegal under EU state aid rules. The EC concluded that the tax rulings granted by the tax authorities in Luxembourg and in… – Continue reading

Breaking News: The Gambia Is On The Verge Of Finalizing A Deal With Hong Kong Based Companies To Open An Offshore Bank In Banjul!

The rogue regime in Banjul is on the verge of finalizing an Offshore Banking deal with some Hong Kong multi-million dollar companies, the Freedom Newspaper can reveal. Under the new deal, the Jammeh government is going to open an Offshore Bank in The Gambia, with the primary objective of helping… – Continue reading

Ireland reveals Budget and international tax strategy

Ireland’s budget statement for 2016 (Budget) was delivered by the Minister for Finance last week. The Budget’s primary focus was on personal tax matters, which is somewhat unsurprising given the general election early next year. However, the Budget also contained two key announcements on Ireland’s corporation tax system.  In line… – Continue reading

Ireland: International Aspects Of Ireland’s Budget: 6.25% Knowledge Development Box And Country-By-Country Reporting

Following last week’s publication of the various OECD/G20 reports on the Base Erosion and Profit Shifting (“BEPS”) project, the Irish Budget delivered on 13 October 2015 contains the first Government initiative on implementing some of the recommendations. Key features are the introduction of the first of its kind knowledge development… – Continue reading

Worldwide: OECD Releases Final BEPS Recommendations – Now What?

On Oct. 5, 2015, the Organization for Economic Cooperation and Development (OECD) released a set of final reports on its 15 point action plan to address Base Erosion and Profit Shifting (BEPS). In an accompanying explanatory statement, the OECD also included plans for additional work on technical matters and a… – Continue reading

Ireland: Ireland’s Budget Statement 2016 – Key Points For Multinational Companies

Most of yesterday’s pre-election budget statement for 2016 (the “Budget“) by Ireland’s Minister for Finance (the “Minister“) focused on personal taxation. In the portion of his statement covering corporation tax, two key announcements were made in line with expectations following on from the publication of the final reports under the… – Continue reading

United States: Tax Policy Update – October 13, 2015

NUMBER OF THE WEEK: 0 The number of House Republicans who want to be speaker and can actually secure the necessary 218 votes as of today. After Majority Leader Kevin McCarthy’s dramatic exit from the race last week, the House GOP conference is taking the week-long Columbus Day recess to… – Continue reading

Starbucks and Fiat Chrysler’s tax avoidance deals to be ruled illegal

Companies face multimillion-euro repayment bills after EC’s 15-month investigation. Rulings on Amazon and Apple will follow Starbucks and Fiat Chrysler are expected to be billed for tens of millions of euros in additional taxes as the European commission prepares to rule that they had unlawful deals with the Netherlands and… – Continue reading

Korea seeks to adopt ‘Google tax’

South Korea is seeking ways to levy a corporate tax on profits of global technology companies and other multinationals as early as next year in response to growing criticism of their tax avoidance structures. The diverted profits tax is more widely called the “Google tax,” as U.S. tech giants such… – Continue reading

Ireland Publishes Updated International Tax Strategy

The Irish Government has published an update on its International Tax Strategy, in which Finance Minister Michael Noonan stresses that the country is “well positioned for the post-base erosion and profit shifting (BEPS) world.” According to Noonan, “This is not something that has happened by accident. Difficult but necessary changes… – Continue reading

‘Tax-havens’ routing 60pc of global trade

JAKARTA, Oct 19: As ‘tax-havens’ are now routing some 60 per cent of international trade, multinational corporations (MNCs) have become more aggressive in evading taxes. As the volume of global trade was estimated at $23.5 trillion in 2013, of which $18.5 trillion was trade in goods and the rest was… – Continue reading

Ireland is now a ‘pariah state’ over tax, says Corbyn insider

UK Labour party leader Jeremy Corbyn’s adviser wants Irish corporate taxes hiked Ireland is viewed as a “pariah state” by the international community due its corporate taxation policies, according to the man behind many of Jeremy Corbyn’s economic ideas. Economist Richard Murphy also said that Ireland should bring its corporate… – Continue reading

EU tax: Brussels set for multinational crackdown

Margrethe Vestager, the EU’s competition commissioner, looks set to launch the international community’s most punitive attack on corporate tax avoidance as early as next Wednesday, with rulings that could impose heavy costs on multinationals, reports the Financial Times. Ms Vestager is understood to have postponed her first trip to China… – Continue reading

Ireland translates aviation success to ship leasing according to new report

Ireland is growing as a global maritime business hub and its strengths in asset leasing could provide an alternative source of finance for shipping, according to a new report commissioned by the Irish Maritime Development Office and authored by tax advisors KPMG and legal firm Dillon Eustace, reports Splash. The… – Continue reading

Could Medtronic Move R&D To Ireland For Tax Purposes?

With Medtronic being one of Ireland’s largest employers, analysts say there is a new incentive for the medical device maker to prioritize its Dublin headquarters for R&D. In the eyes of developed nations, Ireland has become notorious for baiting multinational firms to its land with the offer of friendly tax… – Continue reading

Starbucks, Fiat Decisions Seen in First Wave of EU Tax Cases

Starbucks Corp. and a Fiat Chrysler Automobiles NV unit are set to be first in the firing line as European Union regulators issue a series of rulings over tax breaks for global companies, including Apple Inc. The EU may issue decisions against Starbucks and Fiat as soon as next week… – Continue reading

Joe Tynan: International tax changes on the horizon

As Noonan moves to stimulate domestic growth we need to think about the global debate The Irish economy is now in better shape than at any time since the beginning of the financial crisis. After many years of tough austerity measures, last year’s budget marked a turning point where Minister… – Continue reading

Mylan CEO Heather Bresch: We needed tax inversion in order to grow

The chief of the generic drug company discussed her “counterintuitive” strategy for creating U.S. jobs. Mylan is one of a handful of U.S. companies that has recently completed a controversial tax inversion, as the generic drug company moved its official base to the Netherlands earlier this year. While the decision… – Continue reading

Ireland plans 6.25 per cent patent-box tax as `Double Irish’ ends

Ireland will introduce a new lower tax on intellectual property to keep and win more overseas investment as the government phases out a controversial loophole known as the “Double Irish.”, reports Bloomberg. The new knowledge development box will tax profits from patented innovations such as technological and pharmaceutical developments at… – Continue reading

The U.S. Companies With The Most Offshore Cash

The use of tax havens is ubiquitous across America’s 500 largest companies. Collectively, they hold $2.1 trillion in offshore cash, according to a recent study by Citizens for Tax Justice and the U.S. PIRG Education Fund. Establishing foreign subsidiaries in places with little or no tax such as Bermuda or… – Continue reading

Big tech companies continue cutting profits to pay less tax in Spain

In 2014, seven major tech groups in Spain Declared collective profits of € 48.2 million, on Which They paid € 18.3 million in taxes. These online giants Real Their reduced corporate profits-through complex legal structures and accounting techniques That allowed them to shift part of the profits from Spain to… – Continue reading

Ireland, accused of giving tax breaks to multinationals, plans an even lower rate

Ireland, whose corporate tax rate of 12.5 percent is already one of the lowest in the developed world, said it would cut that rate in half for a new tax category — one covering revenue pegged to companies’ patents and other intellectual property. The Irish government, long criticized by other… – Continue reading

Report: AstraZeneca funnels billions into Dutch tax-avoidance scheme

AstraZeneca ($AZN) is not the first company to employ questionable tax-planning strategies, and it certainly won’t be the last. But the U.K.-based drugmaker is the latest poster child for tax avoidance. As The Guardian reports, AstraZeneca funneled billions of dollars into the Netherlands to get out of paying corporate taxes… – Continue reading

Ireland wins as UBS shifts fund from Cayman Islands

Swiss fund manager will use new Irish Icav structure to move product from the Caribbean domicile UBS has shifted a fund of hedge funds onshore to Ireland from the Cayman Islands, delivering another blow to the reputation of the Caribbean tax haven as the domicile of choice for international hedge… – Continue reading

Trouble Ahead for Hong Kong

Both internal and external factors threaten politics, economics Hong Kong’s run of good luck is running out. One obvious sign is the increasing interference of Beijing in its domestic affairs, most recently using tame Chief Executive C.Y. Leung and a clique of yes-men to interfere in a senior academic appointment… – Continue reading

Richards: Island’s critics have double standards

A blistering attack on major countries who brand offshore financial centres as tax havens has been launched by Bob Richards. The Minister of Finance warned that pressure on the offshore sector from abroad will continue into the foreseeable future. Mr Richards, speaking at the launch of a British Virgin Islands… – Continue reading

G20 economies to tackle corporate tax avoidance

G20 finance ministers have endorsed a package of measures to tackle corporate tax avoidance, but questions remain about whether certain countries will follow through on the plans or leave loopholes multinationals can exploit. The ministers agreed to back proposals drawn up by the OECD, which aim to shake up rules… – Continue reading

OECD report not the last word on Ireland’s FDI corporation tax regime

The global war on corporate tax avoidance doesn’t look like being so gruesome after all. The OECD reckons that governments are losing out on at least €213bn per year from aggressive tax planning by multinationals, reports the Irish Independent. A new book by a Berkeley University economics professor estimates that… – Continue reading

Commission asks public for views on CCCTB proposals

The Common Consolidated Corporate Tax Base is strongly opposed by Ireland The European Commission has opened a public consultation into its proposed scheme for a Common Consolidated Corporate Tax Base (CCCTB) ahead of its planned re-launch next year. The EU’s executive arm is seeking insights from stakeholders by January 8th… – Continue reading

ATO widens its multinational tax avoidance net to 80 companies

The Australian Tax Office will open negotiations with 80 multinational companies to encourage them to “restructure” in order to pay more tax on profits generated in Australia. The move represents a near tripling of the ATO’s multinational watch list after it embedded staff inside 30 companies to learn more about… – Continue reading

Uber and Airbnb confirm they send profit offshore

Uber and Airbnb have revealed in submissions to a federal inquiry that they route profit through companies in the Netherlands and Ireland, where taxes are lower. Uber and Airbnb have told a Senate corporate tax avoidance inquiry that while they comply with Australian tax laws, their Australian operations merely provide… – Continue reading

OECD proposals could save countries US$240bn in lost taxes

With the bulk of the OECD’s work on the BEPS project complete, attention will now turn to the implementation of the recommendations by member countries and others. Minister for Finance, Michael Noonan said that he welcomed the Base Erosion and Profit Shifting (Beps) report, and that the OECD’s proposals would… – Continue reading

OECD: countries commit to minimum standards on international tax dispute resolution

Countries should commit to minimum standards on the resolution of international tax disputes, the Organisation for Economic Co-operation and Development (OECD) said in a report published as part of its base erosion and profit shifting (BEPS) project.06 Oct 2015 The standards would include a commitment to “seek to resolve” cases… – Continue reading

Big U.S. firms hold $2.1 trillion overseas to avoid taxes: study

The 500 largest American companies hold more than $2.1 trillion in accumulated profits offshore to avoid U.S. taxes and would collectively owe an estimated $620 billion in U.S. taxes if they repatriated the funds, according to a study released on Tuesday. The study, by two left-leaning non-profit groups, found that… – Continue reading

Ireland tweaks tax regime to divert avoidance criticism

The Irish government is set to make further changes to the country’s corporate tax regime as it seeks to align itself with a global initiative to clamp down on corporate tax avoidance, reports the Financial Times. The change being considered will oblige companies that have global headquarters in Ireland to… – Continue reading

Gaming the System: Underlying Problems of the U.S. Tax Code Must be Addressed

Last year at this time, news about “tax inversions” was grabbing headlines – cases where large U.S. multinationals would buy a foreign company in a tax-friendly jurisdiction, and then relocate its headquarters to reap the tax arbitrage benefits. The Obama administration responded to the rash of high-profile inversions with new… – Continue reading

Internal Revenue Service Begins Reciprocal Automatic Exchange of Tax Information Under FATCA IGAs

On October 2, 2015, the Internal Revenue Service announced that it had achieved a key milestone in implementation of the Foreign Account Tax Compliance Act (FATCA), a critical anti-tax evasion law passed by Congress in 2010 but not fully implemented until July 2014. The milestone announced by the IRS was… – Continue reading

Horizon Pharma relocates U.S. headquarters to Lake Forest

Daily Herald Reports Specialty drug manufacturer Horizon Pharma, which moved its corporate headquarters from Deerfield to Ireland in 2014, announced it is relocating its U.S. headquarters from Deerfield to Lake Forest as part of a company expansion. The Dublin-based company reported it signed a long-term sublease on a 160,000-square-foot building… – Continue reading

It’s Here; The Automatic Exchange of Information Under FATCA Began September 30th

The IRS has announced that as of September 30, 2015 it will implement the automatic exchange of tax information as set forth in the Foreign Account Tax Compliance Act, (FATCA). The IRS Commissioner in announcing the implementation of the automatic exchange of information stated: “This information exchange is part of… – Continue reading

Plans to overhaul global tax system to be published

A plan for overhauling the global system for the taxation of multinationals, to be published on Monday in Paris, will contain major challenges and opportunities for Ireland’s vital foreign direct investment (FDI) sector, according to tax experts, reports the Irish Times. The culmination of two years’ work, the report by… – Continue reading

A Tax Revolution in the Making in EU

Europe’s stiff-neckedness is difficult to cure. To come to an agreement for supranational treatment of a certain issue there needs to be a large cataclysm or at least a large scandal. In the case of taxation policy the problem begins to gain urgent and most importantly European status after the… – Continue reading

OECD to unveil global tax plans

The OECD’s measures to reform international corporate tax systems will cause Ireland fewer problems than forecast, but for eurozone countries it will be just the beginning of greater and more detailed change. Following two years of constant meetings between tax experts from its 34 country members, the Paris-based body releases… – Continue reading