Debt planning and restructuring is a common mechanism to minimize taxable income by increasing deductions among different entities in a multinational group of companies. As interest on debt is generally a deductible expense of the payor and taxed in the hands of the payee, groups may create intercompany loans to… – Continue reading
HMRC has put out an extraordinary publication about tax avoidance in which it seems to suggest, contrary to its messaging and policies thus far, that if a structure works, it is not tax avoidance, says Jolyon Maugham QC, specialist tax barrister at Devereux Chambers The publication in question, a ‘policy… – Continue reading
In its departmental plan for 2015-2020 published last month, HMRC set out it’s role “to help the honest majority to get their tax right and make it hard for the dishonest minority to cheat the system”. One of the headline objectives for this period is: “maximise revenues due and bear… – Continue reading
For now… corporations, as responsible global citizens, should endeavour to pay their fair share of taxes to avoid threats to their own long term sustainability. Multinational companies like Google, Starbucks, Facebook, Amazon and other global corporations are constantly coming under public fire for avoiding taxes on their British sales. For… – Continue reading
Another form of taxation that has gotten greater attention during the last two presidential election campaigns is the flat tax. A flat tax is a plan that will apply the same rate to every taxpayer, regardless of the income they have earned. At present, federal taxes are calculated on a… – Continue reading
France is seeking €1.6 billion in back taxes from Google, criticised for its use of aggressive tax optimisation techniques, a source at the finance ministry has said. “As far as our country is concerned, back taxes concerning this company amount to €1.6bn,” the official, who spoke on condition of anonymity,… – Continue reading
“We are clear. We will not stand for a minority of taxpayers continuing to seek out unacceptable ways to reduce the amount of tax they pay, and we will ensure HMRC has the tools to robustly tackle such activity.” So said David Gauke, Exchequer Secretary to the Treasury. A clampdown… – Continue reading
In this final instalment considering the draft clauses from the Finance Bill 2016 most relevant to financial planners, I am going to turn my attention to the ever-popular subject of tax avoidance and evasion. Every Budget and Finance Bill has plenty to say on this subject. As in the previous… – Continue reading
If you think Uncle Sam has too many other problems to worry about what assets you may be hiding overseas, think again. “Governments are catching up to the fact that there is now a global economy and are requiring increasing reporting to ensure they collect ‘their fair share’ of tax… – Continue reading
What is FATCA? FATCA refers to US legislation more fully known as the Foreign Account Tax Compliance Act and includes the US Treasury regulations implementing it. It was enacted as part of the Hiring Incentives to Restore Employment Act of 2010 (otherwise known as the, “HIRE Act”) on 18 March… – Continue reading
The Royal Bank of Scotland has worked accounting magic by investing in the distribution of movies such as Harry Potter, Batman Begins and Troy. It put money into 25 companies to enjoy a billion pounds worth of tax breaks between 1998 and 2007, according to Bloomberg. The deals involved a… – Continue reading
Pinsent Masons has accused HM Revenue & Customs (HMRC) of hypocrisy over its recent approach to tax planning and avoidance. Fiona Fernie, a partner at the law firm, said many of the government department’s investigations of late had been politically motivated, “concentrating on the best soundbites for ministers”. Tax avoidance… – Continue reading
Google’s top global tax executive told U.K. lawmakers that a new U.K. tax provision dubbed “the Google Tax” will not actually apply to the U.S. technology giant. The law, officially the Diverted Profits Tax, was introduced last year amid concerns that Google parent Alphabet Inc. and other global tech companies… – Continue reading
As part of what it describes as a ‘relentless’ effort to crack down on tax avoidance, HMRC has put out two publications highlighting problems with contractor loan schemes and misleading claims from scheme promoters, in a bid to deter taxpayers from any involvement In its Spotlight 29 document, HMRC says… – Continue reading
Cracking down on tax evasion could more than cover the cost of South West council cuts, campaigners claim, as they urge MPs to tackle financial loop holes. Local councillors argue that up to £380 million could be raised for Devon councils alone, if all businesses paid their “fair share” of… – Continue reading
The brands are known worldwide, and even though global companies like Google, Amazon, and Starbucks make billions — they pay little or no taxes at all in the UK and other markets where the firms make a majority of revenue and profits. Companies like Microsoft, Twitter, and Apple don’t set… – Continue reading
Revenue spike sees tech firm’s parent company, Alphabet, valued at $568bn – surpassing Apple’s valuation of $535bn Google has become the world’s most valuable listed company after announcing that its global revenues rose 13% to $75bn (£52bn) last year, and the group’s tax rate fell to just 17%. The group… – Continue reading
During last year’s Autumn Statement the Chancellor announced that SDLT rates would increase in relation to the purchase of additional residential properties. As with the 2014 Autumn Statement changes to SDLT rates for residential property, it was something of a surprise move. Transactions falling within the new ‘additional dwelling’ regime… – Continue reading
The formal IRS/Department of Justice (DOJ) Swiss Bank Program has concluded with 80 Swiss banks coming forward. The banks agreed to provide information about personnel, depositors and advisors who were participated in or assisted U.S. taxpayers in offshore tax evasion. In addition to disclosure and cooperation with investigations each of… – Continue reading
COMMUNIST trade union leader Ken Gill famously referred to taxation as “the price we pay for civilisation.” If so last week gave further evidence of just how uncivilised a country Britain has become after decades of neoliberalism. Google’s deal with HMRC has rightly prompted outrage and consternation at the sheer… – Continue reading
The European Commission proposed a set of new rules to curb tax avoidance by large companies. This follows Google’s £130m “sweetheart” tax deal with UK’s HM Revenue and Customs to allegedly avoid paying its fair share of corporate tax that spreads across ten years. Euronews reported that one of the… – Continue reading
European officials have been urged by the British government to remove Bermuda – a tax haven used by Google – from an official blacklist, according to reports. The behind-the-scenes lobbying by UK Treasury ministers involved a memo circulated among Tory MEPs in Brussels describing the sanctions against tax havens as… – Continue reading
The whistleblower who helped to reveal how Google was avoiding paying tax in the UK said that Britain needed to create better incentives to encourage more people to come forward and reveal how multinationals are avoiding paying tax to the exchequer. Like millions of others this weekend, Barney Jones is… – Continue reading
Finance Minister Bambang Brodjonegoro officially announced the aggregate tax revenue for 2015, amounting to Rp 1 quadrillion (US$72.46 billion). This record breaking number, however, was far below the target, by more than Rp 230 trillion. Still, the minister claimed the results were a decent achievement. This is true, especially because… – Continue reading
Could you be one of the lucky expats who qualifies for tax free living in the Seychelles? Or would you have to pay the Seychelles flat tax on personal income? At first glance it looks as though the Seychelles levies a flat rate of personal income tax, and at only… – Continue reading
Moving money out of the usual offshore secrecy havens and into the U.S. is a brisk new business. Last September, at a law firm overlooking San Francisco Bay, Andrew Penney, a managing director at Rothschild & Co., gave a talk on how the world’s wealthy elite can avoid paying taxes…. – Continue reading
Amazingly, 95% of married people file joint tax returns, making each spouse liable for everything on the return–and anything that might not be on the return. Filing a joint tax return is one of the more dubious perks of being married. Yes, joint filing can be more convenient, and can… – Continue reading
FATCA. Since July 2014, the five-letter acronym has instilled dread in the hearts of American expats all around the world. “The Foreign Account Tax Compliance Act (FATCA) requires banks to report information to the IRS regarding all financial accounts held by American clients,” Ines Zemelman, expat tax specialist and founder… – Continue reading
Transfer pricing is the general term for the pricing of cross-border and domestic, intra-group transactions between connected parties. It refers to the setting of prices for transactions between connected persons involving the transfer of property or services. Companies can be connected in various ways, for example, two wholly owned subsidiaries… – Continue reading
Here’s a transaction that did the rounds some years ago. If I wanted some foreign exchange in the future I could enter into a contract with a bank by which it would sell me some. Assume that, in order to get a bank to promise to give me $2bn in… – Continue reading
The Internal Revenue Service appears to have violated a court order once again requiring the preservation of evidence needed by investigators looking into questionable practices at the agency. In a case sure to stir up memories of the Lois Lerner investigation, which saw IRS Commissioner John Koskinen dragged before Congress… – Continue reading
Once the thrill of deciding to retire overseas has subsided, you normally start to think of all the things you need to do before you go. Picking the right removal firm, a lawyer to help you buy a new home are a couple, but the tax & financial implications of… – Continue reading
A group of businesses in the Welsh town of Crickhowell have gone offshore as part of a campaign to try and get HMRC to change tax laws. The Welsh town of Crickhowell is spearheading a unique campaign to get HM Revenue & Customs (HMRC) to change the laws so companies… – Continue reading
According to their acolytes, the rich are great innovators and job creators. But they haven’t lived up to that billing in this century as both job growth and overall economic growth have been extraordinarily weak since 2000. If their benefit to the economy is in doubt, no one can dispute… – Continue reading
WASHINGTON, D.C.—Recent media coverage has prompted impassioned calls for Congress to close the “loopholes” that supposedly explain why the 400 richest taxpayers paid an average federal individual income tax rate of 16.7 percent in 2012. A few weeks ago, the IRS released new data showing that the average federal individual… – Continue reading
With the issue of tax evasion a political priority and firmly in the media spotlight, the Public Accounts Committee kick-started 2016 with an evidence session with top HMRC officials as part of its inquiry into: Tackling tax fraud: how HMRC responds to tax evasion, the hidden economy and criminal attacks…. – Continue reading
Two weeks remain to influence draft legislation which reduces the ability for individuals to convert income distributions from a company into capital gains by way of winding-up that company, an expert has warned.19 Jan 2016. Proposals amending the Transactions in Securities (TIS) rules were published by HMRC on 9 December… – Continue reading
HMRC is set to repay tax to around 2,000 banking and IT contractors who used an offshore scheme because of a flawed process around issuing payment notices. The tax office issued so-called accelerated payment notices to individuals who used Isle of Man-based schemes to limit their income tax during the… – Continue reading
Wherever you and your clients stand on the ethics of tax avoidance – and on offers of 70% commission – moral considerations are now being superseded by more practical concerns of the personal damage attempting to avoid tax can cause, writes Laura Miller… There are many reasons to avoid tax… – Continue reading
The American dream can turn into a nightmare for expats wanting to switch their UK pensions to a Qualifying Recognised Overseas Pension Scheme (QROPS). Thousands of expats cross the Atlantic both ways with London home to Americans in sectors such as finance, entertainment and media, while Florida is a popular… – Continue reading
Banking and IT contractors forced to stump up tens of thousands of pounds to settle contested tax debts last year are now in line to be repaid, after the UK tax authority accepted it should not have issued payment demands. HM Revenue & Customs has withdrawn so-called accelerated payment notices… – Continue reading
What is the fate of taxpayers on double taxation provisions? The National Tax Policy (NTP) acknowledges this challenge when it states, “elimination of multiple taxation must be of major concern to government at all levels. This is because increased demand to grow internally generated revenue has led to the exercise… – Continue reading
Banking and IT contractors forced to stump up tens of thousands of pounds to settle contested tax debts last year are now in line to be repaid, after the UK tax authority accepted it should not have issued payment demands. HM Revenue & Customs has withdrawn so-called accelerated payment notices… – Continue reading
Wherever you and your clients stand on the ethics of tax avoidance – and on offers of 70% commission – moral considerations are now being superseded by more practical concerns of the personal damage attempting to avoid tax can cause, writes Laura Miller… There are many reasons to avoid tax… – Continue reading
Outgoing HM Revenue & Customs (HMRC) chief executive Lin Homer has said it is ‘unlikely’ to pursue further prosecutions against individuals involved in alleged tax evasion at HSBC’s Swiss private bank. HSBC was accused of helping wealthy clients to evade tax in February 2015, when the BBC’s Panorama programme reported… – Continue reading
Tough new measures targeting those who have not played by the tax rules have been criticised by a leading professional body concerned with taxation Anyone owing UK tax on their overseas income is set to face punitive penalties of at least 30pc of tax due, and potentially criminal prosecution, under… – Continue reading
