Category: Government Bodies

What Does Closing the ‘Double Irish’ Tax Loophole Mean for Pharma?

As the Irish government considers closing an infamous tax loophole for corporations, Wall Street has been scrambling to gauge the effect on the pharmaceutical industry. So far, the prognosis seems that damage will largely be minimal. Known as the ‘Double Irish,’ the loophole allows companies to send royalty payments for… – Continue reading

OECD targets diesel and company cars

Taxes on fuel and corporate benefit need to rise significantly, says agency The Organisation for Economic Co-operation and Development (OECD) has launched a war of words on diesel fuel and company cars, claiming that the taxation levels on both are costing governments billions and seriously harming the environment. “The cost… – Continue reading

Fourth protocol to Canada-UK Treaty eliminates withholding tax on arm’s length interest, but preserves tax exemption for gains on disposition of shares and interests deriving value from Canadian real property

On July 21, 2014, the governments of Canada and the United Kingdom signed the fourth protocol (Protocol) amending the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading

Isle of Man: Crypto-Currencies And The Isle Of Man

The Isle of Man is showing great enthusiasm for crypto-currencies – from the landlord at a popular Douglas drinking hole to the Lieutenant Governor, everyone is talking about digital currency and the potentially huge benefits to the Island. The Isle of Man Financial Supervision Commission (FSC) has announced plans to… – Continue reading

Harper Government Strengthens Tax Collaboration with India

Minister Findlay meets with Indian counterpart during trade mission to India DELHI, INDIA–(Marketwired – Oct. 15, 2014) – Canada Revenue Agency The Honourable Kerry-Lynne D. Findlay, P.C., Q.C., M.P., Minister of National Revenue, met today with Nirmala Sitharaman, India’s Minister of State for Commerce and Industry and Minister of State… – Continue reading

Malta Holding Companies 2014/15

Malta, like Cyprus, has been obliged to dismantle its old ‘offshore’ companies regime as a trade-off for joining the European Union. EU membership has, however, brought about certain benefits for Maltese companies trading across borders, and, coupled with investment-friendly government policies and some interesting tax planning opportunities, Malta remains one… – Continue reading

Firms Expect Transfer Pricing Policy Impact From BEPS Project

A vast majority of companies headquartered in the United States expect increased scrutiny of their transfer pricing practices in the short-term as a result of the Organisation for Economic Cooperation and Development’s (OECD’s) base erosion and profit shifting (BEPS) project. A recent EY survey, Connecting The Dots, concluded that 30… – Continue reading

Monaco Signs OECD Multilateral Tax Convention

Monaco has become the 84th jurisdiction to commit to strengthen international tax cooperation through its participation in the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. Welcoming the signing by José Badia, Monaco’s Minister for Foreign Affairs and Cooperation, the Organisation for Economic Cooperation and Development’s (OECD’s) Secretary-General, Angel… – Continue reading

International tax avoidance: Is it eroding Canada’s tax base and how should we respond?

TORONTO , Oct. 2, 2014 /CNW/ – Aggressive international corporate tax avoidance by multinational corporations has become the subject of intense political scrutiny. U.S. politicians have called out some American multinationals, including Apple, Amazon, Starbucks and Google, for relocating profits abroad to avoid U.S. taxes. More recently, politicians accused Burger… – Continue reading

Can the EU tame the multi-national tax dodgers? Why Europe wants to turn the screw on the big guns

The screw is being turned on American companies that use complex structures to whittle down their tax bills. But is the latest EU probe a paper tiger or a game changer? It was supposed to be good news. Amazon’s announcement yesterday that it would hire 1,000 staff was dressed up… – Continue reading

UPDATE 3-Ireland calls time on austerity, “Double Irish” tax dodge

* Ireland to end tax regime that saved multinationals billions * Swift upturn ushers in tax cuts rather than austerity * Government faces backlash over uneven nature of recovery (Adds finance minister interview, Google comment) By Padraic Halpin and Conor Humphries DUBLIN, Oct 14 (Reuters) – Ireland will phase out… – Continue reading

Alleged mastermind of UBS tax evasion scheme faces trial

(Reuters) – Former UBS bank executive Raoul Weil was the mastermind of the Swiss bank’s illegal offshore operations that helped thousands of Americans evade taxes, prosecutors said at the start of his federal trial on Tuesday. Weil, 54, was the third-highest ranked executive at the Zurich-based wealth management firm and… – Continue reading

After years of pressure, Luxembourg drops bank secrecy rules

(Reuters) – Luxembourg agreed on Tuesday to end its bank secrecy rules from 2017, yielding to a decade of pressure from Germany and the United States and marking a breakthrough in global efforts to reduce tax evasion. Luxembourg, whose banks hold deposits worth 10 times the nation’s annual economic output,… – Continue reading

Swiss pledge to review business taxation

The Swiss finance minister, Eveline Widmer-Schlumpf, and her counterparts from European Union member states have signed a joint statement aimed at ending a controversy over corporate taxes. The declaration, signed in Luxembourg on Tuesday, includes the Swiss government’s plans to push ahead with abolishing certain preferential tax regimes for foreign… – Continue reading

Tax relief scheme for tech firms under threat from Europe

Hitech firms are being warned that they should take advantage of tax relief on patent related profits now before a threatened clamp down by the European Union according to Richard Hopes, Partner at Alliotts accountants based in Surrey and London. Richard Hopes, Partner at Alliotts accountants and a specialist in… – Continue reading

The Big Picture: Wealth and Estate Planning in Argentina

It is said that Argentina faces an economic and political crisis every 10 years. Whenever a crisis arises, Argentinians’ right of ownership is at risk. Devaluation, asymmetric pesification and the current foreign exchange restrictions are a few examples of the challenges we face. What’s more, according to a recent OECD… – Continue reading

Bono: ‘We are a tiny country and tax laws have brought Ireland the only prosperity we’ve ever known

U2 frontman Bono has claimed that the controversial tax laws which have helped multinationals avoid billions in tax have “brought our country the only prosperity we’ve known”. In an interview with the Observer, the singer said the Irish economy needs companies like Apple, Facebook and Google, which have been the… – Continue reading

India’s challenge on corporate taxation

Foreign investors, not to mention the country itself, need a more stable and predictable regime Foreign companies are depressingly used to run-ins with the Indian taxman. A string of groups, including Vodafone, IBM and Cairn Energy, have been hauled into the dock for not paying their dues in recent years…. – Continue reading

India may have to wait for automatic exchange of Swiss info

India may have to wait longer for joining “selected” countries with whom Switzerland plans to do automatic exchange of information on tax matters, even as Indian and Swiss officials will meet soon to iron out their bilateral arrangements on suspected tax evasion cases. Switzerland has started a process for putting… – Continue reading

Tax chief to meet Swiss bank heads

Moshe Asher is seeking information about accounts in Switzerland belonging to Israelis. The Israel Tax Authority is stepping up it efforts to combat overseas tax shelters for Israelis. Sources inform “Globes” that Israel Tax Authority director Moshe Asher is expected to travel to Switzerland next week in order to meet… – Continue reading

Courts could dismiss Swiss bank data

Say judge may find evidence inadmissible because it was supplied by a whistleblower As the AFIP tax bureau starts reviewing information it recently obtained from the French government on undeclared bank accounts held by Argentines in Switzerland, tax experts have warned that using the data might be harder than it… – Continue reading

Ireland Said to Weigh Phasing Out Double Irish Tax Break

Ireland’s finance ministry officials are weighing phasing out a tax device used by multinational companies including Google Inc., according to a person with knowledge of the matter, as the European Union looks into the practice. Ireland is considering whether to eliminate a technique known as the “Double Irish,” which allows… – Continue reading

Vodafone Wins Another Indian Tax Case; This Time Over Transfer Pricing

Vodafone has emerged victorious against the Indian taxman in the latest bout of litigation between the two. The important point for the rest of us being what it tells us about those endless claims of tax avoidance and tax evasion by large companies. It’s not just that large amounts of… – Continue reading

OECD releases finalised proposals on key tax base erosion concerns

Introduction Action 1: the digital economy Action 2: hybrid mismatch arrangements Action 5: harmful tax competition Action 6: preventing tax treaty abuse Action 8: guidance on transfer pricing and intangible assets Action 13: transfer pricing documentation and country-by-country reporting Action 15: developing a multilateral legal instrument Next steps Introduction On… – Continue reading

FATCA Notebook: Former IRS Chief, Taxpayer Advocate Criticize FATCA; Switzerland Moves Toward Greater Transparency

This week brings a wealth of news in the FATCA arena, which we summarize in today’s post. First, former acting IRS Commissioner Steven Miller speaks out against FATCA and suggests that the benefits of the new information reporting regime imposed by FATCA may not outweigh its costs. An article published… – Continue reading

European Commission Crackdown on Special Tax Deals

The European Commission’s recent action to crack down on special deals some European Union governments offer to corporations could be a blow to multinational corporations’ tax-dodging strategies. As we noted in a report earlier this year, three European countries (Ireland, Luxembourg and the Netherlands) are among the top twelve tax… – Continue reading

Foreign manufacturers use foreign parts suppliers to avoid tax: Analysts

VietNamNet Bridge – Foreign automobile and electronics manufacturers often choose foreign enterprises for their parts and accessory suppliers instead of Vietnamese companies because it allows them to engage in transfer pricing, some analysts have claimed. Samsung, Toyota, Canon and other giants in the manufacturing industry have complained many times that… – Continue reading

ATO alleges complex Chevron scheme slashed tax bill by $258m

Australian tax authorities allege multinational oil giant Chevron used a series of loans and related party payments worth billions of dollars to slash its tax bill by up to $258 million. New documents filed in a long-running dispute in the Federal Court show how Chevron allegedly engaged in a complex… – Continue reading

EU turns its attention to Amazon

European body adds another high-profile name to its crackdown on multinationals’ tax avoidance in bloc. The European Union is broadening its crackdown on multinationals’ tax avoidance schemes, opening an investigation yesterday into Amazon’s practices on suspicion the online retailer is not paying its dues on profits made across the 28-nation… – Continue reading

EU tax evasion bank data agreement said to be close

There are reportedly about to be major moves in the fight against tax evasion within the European Union. The region’s finance ministers are said to be close to an agreement on automatic sharing of bank data so that the authorities could spot tax dodging or illicit money flows more easily…. – Continue reading

ActionAid Asks EIB to Publish Report on Mopani Tax Evasion

The following joint press release was circulated by non-governmental organisations ActionAid Zambia, Christian Aid, and Counter Balance, including the full text of their letter appealing to the European Investment Bank (EIB) to publish their findings on possible tax evasion activity at the Mopani Copper Mine, which is owned and operated… – Continue reading

BEPS, Broken Promises, and What the OECD Can Learn from the WTO About Dispute Settlement Procedures

The question has often arisen whether “international law” is an oxymoron – whether “obligations” in income tax treaties and other international agreements are really binding upon the parties, when they are not buttressed by some sort of enforcement mechanism. That question has never been more relevant in the tax world… – Continue reading

Worldwide: OECD Releases First BEPS Recommendations To G20 In Accordance With Action Plan

As a part of the OECD/G20 project to combat base erosion and profit shifting (“BEPS”), the OECD released the first set of reports and recommendations on September 16, 2014. These reports address seven of the actions described in the 15-point action plan to address BEPS published in July 2013 (the… – Continue reading

Espírito Santo Financial to File for Bankruptcy

LONDON – The Espírito Santo Financial Group, which at one point held about 25 percent of the bailed-out Portuguese lender Banco Espírito Santo, said on Thursday that it would file for bankruptcy after it was denied creditor protection by a Luxembourg court last week. Espírito Santo Financial is part of… – Continue reading

Canada: OECD Issues Work On BEPS Actions

The Organization for Economic Cooperation and Development (OECD) has released the first components of its comprehensive plan for creating an agreed set of international rules for fighting base erosion and profit shifting (BEPS) and ending opportunities for double non-taxation. The four model legal instruments and three reports are the first… – Continue reading