People may not like paying tax. But what is even less popular is the thought they have no choice while others have much more control over their tax bills. Several high-profile companies make millions of pounds worth of sales in the UK. But a series of media exposes found that… – Continue reading
Ireland’s Enterprise Minister Richard Bruton is undertaking his first investment mission since the Government announced major changes to the corporate tax regime as part of Budget 2015. Bruton is visiting the East Coast of the US as part of a program of engagement by the Government with multinational companies on… – Continue reading
European prosecutors and tax authorities are intensifying an investigation into a huge tax avoidance trading scheme costing European countries hundreds of millions of euros. The investigation centres on complex stock trades that major banks allegedly use to earn tax rebates. The practice was revealed by the Bureau three years ago…. – Continue reading
Revenue Minister Todd McClay today announced New Zealand’s timetable for participation in a global automatic exchange of information aimed at cracking down on tax evasion. G20 leaders announced the initiative in September 2013 – and in May 2014, New Zealand, along with all OECD countries, joined in the general declaration… – Continue reading
The OECD’s Action Plan on BEPS was published in July 2013 to reform the international tax system. The Action Plan identified 15 Actions to address BEPS. Seven of the 15 Action Plan items are now moving out of the station. I. Introduction On September 16, 2014 the OECD, together with… – Continue reading
Multinational life sciences companies should review their organizational structures and perform scenario planning to assess the likely impacts of the Organisation for Economic Co-operation and Development’s (OECD’s) Action Plan on Base Erosion and Profit Shifting (BEPS), says a new report from KPMG. “The Post Base Erosion and Profit Shifting World”… – Continue reading
At the 68th Congress of The International Fiscal Association in Mumbai, CBC-TV18’s Payaswini Upadhyay spoke to Sanjay Puri, Director, CBDT on the OECD’s work on Transfer Pricing principle of intangibles and India’s position on it and the kinds of transactions that the Department is looking at in the intangibles space…. – Continue reading
NEW YORK, Oct. 27, 2014 /PRNewswire/ — Bloomberg BNA’s International Tax Monitor and Tax Analysts interviewed Caplin & Drysdale’s Elan P. Keller concerning a pledge made at the 2014 OECD Forum on Tax Administration (FTA) by tax chiefs from 38 countries to invest in resources to implement a new standard… – Continue reading
Law360, New York (October 24, 2014, 2:10 PM ET) — The Organization for Economic Cooperation and Development delivered an agreement among over 130 tax commission delegates from 38 nations on its corporate base erosion and profit-shifting plan at the close of the Ninth Forum on Tax Administration in Dublin on… – Continue reading
Green Left Weekly and ActionAid will be co-sponsoring a Political Economy Society seminar at Sydney University on October 29 to discuss the case for greater international efforts to combat corporate tax avoidance before the G20 summit. Large corporations systematically avoid paying the statutory level of company tax — a low… – Continue reading
Officials from the Treasury and HM Revenue and Customs (HMRC) have been meeting with representatives of the PPP/ PFI industry to discuss the implications for infrastructure projects of possible restrictions to interest relief.24 Oct 2014 Corporate tax Tax Projects Construction Advisory & Disputes Infrastructure UK Europe In a report on… – Continue reading
Measures to ensure people who are not on social welfare or paying tax get relief on water charges will be brought forward at the committee stage of the Finance Bill, the Finance Minister has said. This follows controversy when it emerged that thousands of people would not be able to… – Continue reading
THE OECD has signalled support for the Government’s plan to introduce a so-called “Knowledge Development Box”, but warned that the devil would be in the detail. Pascal Saint-Amans, the director of the Centre for Tax Policy and Administration at the Paris-based Organisation for Economic Cooperation and Development (OECD), told the… – Continue reading
A new survey by E&Y released at its 33rd Annual International Tax Conference, titled “Connecting the dots” uncovered the issues of navigating multiple challenges, led by increased scrutiny and the effects of the Organisation for Economic Co-operation and Development’s (OECD) base erosion and profit shifting (BEPS) project. “Tax directors need… – Continue reading
ITR Correspondent • • • The G20 and OECD’s Base Erosion and Profit Shifting (BEPS) project has rarely been out of the headlines during 2014. At the heart of the BEPS project is the assumption international tax rules make it possible for profits to be taxed in countries that are… – Continue reading
21/10/14-Tax administrations will play a central role as governments move to implement the measures they have agreed to counter offshore evasion and combat tax avoidance by multinational enterprises. Global initiatives like the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project and the move toward automatic exchange of financial account account… – Continue reading
Foreign structures are tempting targets for governments, says Vanessa Houlder. When governments around the world embarked on a drive to plug tax loopholes in 2012, the urgency of the move was underpinned by rising tensions over austerity and inequality. Widespread public outrage over alleged tax-dodging by wealthy individuals and multinationals… – Continue reading
Unprecedented international collaboration is needed to overcome a single-, isolated-country view to tackling base erosion and profit shifting (BEPS) issues, Andrew Mills, Second Commissioner of Australian Taxation Office (ATO) for Law Design and Practice, has said. In a speech delivered at the Second Annual Tax Forum organized by the Tax… – Continue reading
The Organization for Economic Cooperation and Development’s (OECD) plan for base erosion and profit shifting (BEPS) is already affecting corporations, according to speakers participating in a Captive Insurance Companies Association (CICA) transfer pricing webinar. Polling results during the webinar revealed attendees’ opinions were in line with tax industry surveys indicating… – Continue reading
On July 15th 2014, the OECD published its 2014 update of the Model Tax Convention (“2014 OECD Update”). This update is the outcome of the work accomplished between 2010 and the end of 2013. It does not however take into account the OECD conclusions of the “Action Plan on Base… – Continue reading
The revenue implications for South Africa of ‘base erosion and profit shifting’ by corporate taxpayers are firmly in the crosshairs of the Davis Tax Committee (DTC) and Judge Dennis Davis hinted on Monday that recommendations were being considered to “detect and deter” tax-avoiding financial flows. Speaking at a G20 study… – Continue reading
There has been a lot of press coverage recently around the pricing and tax arrangements of multinationals, in particular Apple, Starbucks and Amazon. In this respect, the EU is undertaking in-depth investigates into these companies to establish whether the companies’ tax arrangements have breached EU State Aid rules. These cases… – Continue reading
Our Reaction The Irish Minister for Finance delivered his Budget 2015 (the “Budget”) speech this week. There was considerable domestic and international anticipation in advance of the Budget against a backdrop of significant recovery in the Irish economy and also international focus (including, in particular, under the OECD BEPS project)… – Continue reading
Budget measures including new foreign direct investment incentives discussed State agencies and Government Ministers and officials have launched a co-ordinated campaign of letters and phone calls to senior executives of foreign multinationals, to reassure them that Ireland remains a top destination for investment following the budget, Minister for Enterprise Richard… – Continue reading
AMONG several proposals for tax reform, the director-general of the Revenue Department has said the agency would propose an amendment to the Revenue Code concerning transfer pricing, aiming to provide greater clarity on the determination of fair transfer prices. The director-general has indicated that in past years many multinational companies,… – Continue reading
erne/New Delhi: In a major breakthrough in India’s fight against black money allegedly stashed abroad, Switzerland today said it will examine Indian requests for banking information on a priority basis and provide requested details in a time-bound manner. The Swiss authorities would also “assist in obtaining confirmation on genuineness of… – Continue reading
A new initiative to monitor MNCs moving headquarters to evade taxes promises success Largely unnoticed, India has come out strongly supporting an international initiative for plugging tax avoidance by multinational corporations (MNCs). The initiative has been endorsed at the last meeting of G20 finance ministers at Cairns in Australia. Known… – Continue reading
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
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
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
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
On October 7, 2014, the Organisation for Economic Cooperation and Development (OECD) published comments received from various stakeholders regarding the OECD’s work on establishing methodologies to collect and analyze data on base erosion and profit shifting (BEPS) and the actions to address it (Action 11). In the main, many commentators… – Continue reading
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
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
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
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
The UK government will continue to defend its ‘patent box’ tax break for income from qualifying intellectual property (IP) during discussions to develop a global corporate tax regime, a Treasury official has said.08 Oct 2014 Intellectual Property Tax Patents Corporate tax Life sciences Advanced Manufacturing & Technology Services UK Europe… – Continue reading
The UK government will continue to defend its ‘patent box’ tax break for income from qualifying intellectual property (IP) during discussions to develop a global corporate tax regime, a Treasury official has said.08 Oct 2014 Intellectual Property Tax Patents Corporate tax Life sciences Advanced Manufacturing & Technology Services UK Europe… – Continue reading
Eight of the top 200 companies publicly listed on the Australian stock exchange (ASX200) paid no taxes on profits averaging $50 million to more than half a billion dollars over the decade to 2013! More than 20 (10 percent) corporations paid an average tax rate of five percent or less…. – Continue reading
Amazon, the online retailer, is to face a formal investigation into its European corporate tax practices, the European Commission has announced. The Commission – the executive division of the 28-member European Union – says it will look at the tax agreement made between Amazon and Luxembourg. It suspects the deal… – Continue reading
On June 10, 2014, the Tax Court of Canada (“TCC”) delivered its most recent decision on transfer pricing, one which involved a Barbados structure. In Marzen Artistic Aluminum Ltd. v. The Queen[1] (“Marzen”), Justice Sheridan upheld the Canada Revenue Agency’s (“CRA”) transfer pricing adjustment as well as the penalty under… – Continue reading
OHN KEHOE The global tax plan being pursued by Australia as G20 president, to compel low-tax paying multinationals such as Google and Apple to contribute more revenue to government coffers, could be derailed by political resistance in the United States. A prominent US senator in congress who would likely become… – Continue reading
The UK government will shortly set out how it plans to implement globally agreed rules to prevent multinational companies from using artificial techniques to significantly reduce their tax bills, it has announced.06 Oct 2014 Tax Tax Disputes and Investigations UK Europe It has confirmed that it will consult on the… – Continue reading
We pay our taxes. Why won’t they? It’s the topic every tax official and finance minister in the developed world is talking about and acting on, yet we hear little about it in New Zealand. Cracking down on tax avoidance by the world’s biggest technology companies – among them Google,… – Continue reading
The IMA has welcomed plans by the Organisation of Economic Cooperation and Development (OECD) to review the impact of possible tax changes on investment funds. Earlier this month the OECD published a report on the development of its Base Erosion and Profit Shifting (Beps) plan, which is aimed at cracking… – Continue reading
Plans to tackle UK tax avoidance by international technology companies could damage UK competitiveness if they are brought in before international measures are finalised, a tax law expert has warned.02 Oct 2014 Corporate tax Tax Tax Disputes and Investigations TMT Advanced Manufacturing & Technology Services UK Europe Heather Self of… – Continue reading
British chancellor George Osborne’s promise to clamp down on a tax avoidance loophole widely used by multinational technology companies could actually result in a reduction in the amount of money the government takes in, the Chartered Institute of Taxation has warned. Patrick Stevens, the group’s tax policy director, admitted the… – Continue reading
eBay accused of tax avoidance, but insists it complies with letter of the law By Emma Woollacott, Sep 29, 2014Updated: September 30, 2014 7:24 AM Online auction site eBay got away with paying just £620,000 in tax on sales of over £1.3 billion last year, its latest accounts reveal. The… – Continue reading
The European Commission’s crackdown on the deal between Irish tax authorities and Apple Inc. marks an expansion in the growing global war on tax avoidance by multinational companies. Governments that enable it are now a target. Tuesday, the European Commission said the Irish tax authorities failed to conform to international… – Continue reading
The European Union has accused Ireland of swerving international tax rules by letting Apple shelter profits worth tens of billions of dollars from revenue collectors in return for maintaining jobs. European Competition Commissioner Joaquin Almunia told the Dublin government in a letter published on Tuesday that tax deals agreed in… – Continue reading
