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
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
Authorities in China have been doubling their efforts since April to track down illicit assets exported overseas. The People’s Bank of China, the Ministry of Public Security, the Supreme People’s Court, the Supreme People’s Procuratorate, and the State Administration of Foreign Exchange have been working together in this operation. Chinese… – Continue reading
Swiss firms have bagged major business from global brands such as GSK, Novartis and Crédit Suisse this year, while their Asia ventures have come good. The legal minds behind the Glaxo-SmithKline and Novartis asset swap, global banking investigations, Schaeffler’s €2bn high yield bond issuance and Dufry’s £1.05bn takeover of Nuance… – Continue reading
Foreign companies entering the U.S. market for the first time will want to consider how their operations can be structured to minimize U.S. taxes. Although sales into the U.S. can be arranged in some cases to keep profits offshore, a sufficient presence ”on the ground” can pull sales income (and… – Continue reading
An independent panel appointed by Bank Leumi Le-Israel Ltd. recommended that a former chairman and chief executive officer both return bonuses after the lender agreed to pay a fine to U.S. authorities in a tax probe. An insurer for the former bank officials will pay an additional $92 million. Leumi,… – Continue reading
The Government of India, Ministry of Finance had on August 7, 2015, in order to comply with the information reporting requirements of the US’ Foreign Account Tax Compliance Act (hereinafter referred to as ‘FATCA’), made amendments in the Income-tax Rules, 1962. WHAT IS FATCA’S BACKGROUND? FATCA is a broad set… – Continue reading
The US Internal Revenue Service has begun receiving data from foreign banks about US expats’ overseas bank accounts and is now sharing data with certain foreign tax authorities to also support their tax enforcement efforts. The first tax information exchanges on September 30, 2015, were facilitated by a platform put… – Continue reading
Financial think tank and lobby group the New City Initiative has warned that regulation is destroying competition within the asset management industry. With several major regulatory changes due to be implemented in the next few years, the think tank has analysed the impact of the new rules on boutique asset… – Continue reading
KUWAIT: The Cabinet has called on ministers and senior officials of state bodies to submit their financial disclosure reports to the Anti-Corruption Authority as soon as possible. The call was made by the Cabinet during its customary weekly meeting held at Bayan Palace yesterday under chairmanship of HH the Prime… – Continue reading
Over 20 multinationals in Mexico should be paying tax, says Finance Secretary It has been dubbed “double non-taxation” and it’s an international practice that was the focus of discussion last week in Lima, Peru. It is also something that Mexico’s finance authorities want to see addressed. It was during a… – Continue reading
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
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
At a recent tax conference a senior Justice Department official reaffirmed the commitment of the U.S. Department of Justice to continue offshore enforcement efforts. As is widely reported the official stated: “We are well beyond Switzerland at this point,” she said, citing enforcement announcements concerning India, Israel, Liechtenstein, Panama, the… – Continue reading
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
(Ferenstein Wire) – Big tech companies are safeguarding billions of dollars in offshore tax havens, according to a new study. Apple alone, the biggest offender, is stashing $181 billion in revenue with an estimated tax burden of $59.2 billion. In other words, Apple’s taxes could pay for nearly the entirety… – Continue reading
To solve the problem of the haze afflicting Singapore, Indonesia and Malaysia, extraterritorial action is needed to quench the forest fires in Indonesia that are generating the haze. A cross-border solution is a necessary answer even if it raises questions of national sovereignty. The Singapore Government should implement laws that… – Continue reading
Merely because exemption has been granted under the Indian Income Tax Act, foreign tax credit cannot be denied The Karnataka High Court, in the case of Wipro Ltd, apart from other substantial questions on law, has held that tax credit for the income tax paid in a foreign jurisdiction shall… – Continue reading
The CBDT has clarified that MAT provisions will not be applicable to those FIIs /FPIs which do not have a permanent establishment in India, for the period prior to 1 April 2015. An amendment to the IT Act will be made in the winter session of Parliament and directions have… – Continue reading
The hedge fund trade to gain exposure and then encourage a U.S. corporation to enter into an acquisition transaction with a foreign corporation where it incorporates internationally to lower its tax burden, known as a corporate inversion, might have slowed of late, but the issue is now being addressed at… – Continue reading
Oct. 7 — The IRS offered two-pronged guidance on the effective dates of agreements for entities that apply on or after April 1 to be withholding foreign partnerships or withholding foreign trusts under the Foreign Account Compliance Act. In general, the Internal Revenue Service said Oct. 7, entities that apply… – Continue reading
NEW YORK, Oct. 9, 2015 /PRNewswire/ — KPMG’s Tax Governance Institute (TGI) will examine the final recommendations from the Organisation for Economic Co-operation and Development (OECD) on Base Erosion and Profit Shifting (BEPS) and discuss what they could mean for U.S. multinationals during a live video webcast on Tuesday, Oct…. – Continue reading
On October 2, 2015, the U.S. Internal Revenue Service (IRS) announced the exchange of financial account information with certain foreign tax administrations in compliance with their obligations under various intergovernmental agreements (IGAs) put in place to implement the Foreign Account Tax Compliance Act (FATCA). IRS Commissioner John Koskinen stated that… – Continue reading
BARBADOS continues to be plagued by unjustified attacks from powerful nations, Prime Minister Freundel said yesterday as he confirmed two countries had moved to take Barbados off their tax haven blacklist. The Prime Minister told a two-day conference at the Hilton Barbados Resort, which forms part of International Business Week… – Continue reading
Dozens of banks signed amnesty agreements disclosing tactics, providing prosecutors with valuable information At a rate of one or two a week, Swiss banks are doing what was once unthinkable: revealing to the world how they helped wealthy Americans cheat on their taxes. Once bastions of secrecy, 41 Swiss banks… – Continue reading
On October 5, the Organization for Economic Cooperation and Development (OECD) unveiled the consensus plan reached by the Group of 20 and more than 40 other countries regarding its base erosion and profit shifting (BEPS) project. BEPS refers to tax-dodging tactics by multinationals that erode a home country’s tax base… – Continue reading
As a business leader, EY is proud to announce a seminar from its series of regulatory updates, aimed to keep stakeholders abreast of current changes in legislation. The FATCA and OECD Common Reporting Standard (CRS) seminar will be held on October 20, 2015 at the Hilton, St Julian’s between 08:30… – Continue reading
U.S. Sen. Sherrod Brown, appearing Friday at the City Club of Cleveland, said the United States has to again understand that money that targets road and bridge development and other infrastructure improvements is an investment. “Our parents left us with a transportation system and an infrastructure that was the envy… – Continue reading
Treasury Secretary Jack Lew said Friday that the Obama administration would implement new rules that would lead to sharing business’s information with foreign governments. Lew praised the final recommendations from an Organization for Economic Cooperation and Development project meant to battle offshore tax avoidance, saying there was a “critical need… – Continue reading
VietNamNet Bridge – Minister of Planning and Investment Bui Quang Vinh has disagreed with the opinion that Coca-Cola has been conducting transfer pricing in Vietnam, affirming that the soft drink manufacturer is innocent until proven guilty. Vinh made the statement at the Vietnam Global Investment Forum held in Hanoi in… – Continue reading
Remarkably on schedule, the OECD this week issued a comprehensive and integrated set of measures to attack base erosion and profit shifting (BEPS) on a global basis. Comprising 15 “Actions” on central issues such as transfer pricing, country-by-country reporting and transfer pricing documentation, treaty abuse, preferential tax regimes, permanent establishments,… – Continue reading
The Department of Justice announced today that Schaffhauser Kantonalbank (SHKB) has reached a resolution under the department’s Swiss Bank Program. The Swiss Bank Program, which was announced on Aug. 29, 2013, provides a path for Swiss banks to resolve potential criminal liabilities in the United States. Swiss banks eligible to… – Continue reading
A quarter of companies say they won’t meet the first deadline proposed by the Organisation of Economic Co-operation and Development (OECD) in its base erosion and profit shifting (BEPS) action plan, reports Economia. Globally, 74 per cent said they will complete their country-by-country analysis by the first due date, December… – Continue reading
Oct 8 (Reuters) – German Finance Minister Wolfgang Schaeuble said on Thursday he would propose a monitoring scheme to ensure the full implementation of a proposed system to overhaul the way international companies are taxed. The Organisation for Economic Cooperation and Development (OECD) published proposals on Monday to change outdated… – Continue reading
Today, counsel for the taxpayer and the Franchise Tax Board (“FTB”) argued before the California Supreme Court in The Gillette Company & Subs. v. California Franchise Tax Board. This case has been watched closely by taxpayers and tax practitioners on a national level since briefing was completed nearly two years… – Continue reading
Singapore has given the thumbs up to an international plan that aims to clamp down on tax avoidance by multinational firms, reports the Straits Times. The Republic says if the plan is soundly implemented, it will help foster free and fair economic competition. Singapore agrees with the main principle of… – Continue reading
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
Senior tax executives are preparing for changes in the tax landscape as a result of the Organization for Economic Co-operation and Development’s base erosion and profit shifting project. A new survey by Ernst & Young, presented Thursday at its 34th Annual International Tax Conference, found 88 percent of tax directors… – Continue reading
The Swiss Federal Council has adopted a dispatch on the implementation of tax information exchange agreements with Belize and Grenada. The Council adopted the dispatch on October 7. It will now be submitted to Parliament for approval. The TIEAs were signed with Grenada on May 19 and with Belize on… – Continue reading
WASHINGTON — The Texas and Florida Bankers Associations have requested a rehearing before the U.S. Court of Appeals (D.C. Circuit) of its August decision to dismiss their case challenging the validity of 2012 IRS regulations requiring deposit interest income to be reported and setting up an exchange agreement on U.S…. – Continue reading
The IRS has posted text of a Competent Authority arrangement (CAA) between the United States and Hungary, pursuant to the intergovernmental agreement (IGA) signed in 2014 to implement the FATCA regime. The CCA with Hungary follows CAAs that were signed by the United States in September 2015 with both the… – Continue reading
It’s no conspiracy theory that mega-corporations benefit from dodging taxes and that there are a bevy of legal loopholes accountants use to ensure businesses lose as little money as possible to the government. Few of these loopholes sound as nefarious as shuffling money into offshore accounts in the Cayman Islands… – Continue reading
Government should look to the example set by Barbados and start charging Value Added Tax (VAT) on betting and gaming activities in Trinidad and Tobago. This was the advice coming from Tax Director of KPMG’s TT operations, Nicole Joseph, during a post-budget forum hosted by the American Chamber of Commerce… – Continue reading
On October 5, 2015, the OECD released its final reports relating to the OECD/G20 base erosion and profit shifting (BEPS) project (the Final Reports). The BEPS project began in 2013 and has received unprecedented attention from governments and the private sector. The Final Reports outline the OECD’s recommendations and the… – Continue reading
A senior officials say they have no legal jurisdiction over the accounts maintained in foreign countries and governments there can cooperate only in case of established criminal conspiracy While the government has threatened rigorous action against black money hoarders after tepid response to its one-time compliance window, it may have… – Continue reading
NEW DELHI: India has found global allies in its fight against black money. Germany, France, Switzerland, Singapore, Mauritius and the British Virgin Islands are among those that are providing information, or will soon start doing so, on assets held by Indians, helping the Narendra Modi government in its campaign to… – Continue reading
Patent box regimes typically apply deeply discounted tax rates to income derived from intellectual property. Recently unveiled draft legislation may pave the way for a US patent box regime and incentivize taxpayers to reevaluate their global structures. Introduction The US imposes the highest corporate income tax rate (35%) in the… – Continue reading
In 2016, hundreds of directors, managers, principal points of contact (PPCs), compliance officers, administrators, and Money Laundering Reporting Officers (MLROs) serving Cayman Islands funds, banks, trust companies and other Reporting Financial Institutions (RFIs) will start to feel the full force of ‘a great wind’: global tax transparency. If you are… – Continue reading
Guidance issued by the French tax administration sets forth instructions for French “reporting financial institutions” to follow in order to comply with the Model 1 intergovernmental agreement (Model 1 IGA), signed between France and the United States, for purposes of implementing the FATCA regime. The guidance, a set of four… – Continue reading
There’s enough cash sitting in offshore bank accounts to wipe out the federal deficit — if only it was subject to U.S. taxes. That’s because U.S. companies are saving some $620 billion by parking profits outside the country, according to the latest accounting from Citizens for Tax Justice and U.S…. – Continue reading
