Consultation on the ATO’s practical guide for offshore marketing hub arrangements is kicking off in August. The guide may also assist taxpayers with offshore intellectual property (IP) hubs. Here is what you need to know if you market Australian produced goods offshore or have centralised your IP offshore. Do you… – Continue reading
The European Union (EU) doesn’t like the special tax deals that are offered to companies to entice them to set up in Switzerland. So the Swiss government is working hard to find a replacement. One element of their new plan is to offer patent boxes. A recent study by economists… – Continue reading
With the focus of 2014 being international tax competition, 2015 shows signs of continuing this trend. The European Commission (COM) and European Parliament (EP) are starting to debate and extensively investigate Member States’ tax ruling policies, partly as a result of the LuxLeaks revelations and partly in relation to the… – Continue reading
Introduction US tax treaty policy can be affected by pressures for tax reform from within the United States and by major developments in international taxation from without. Talk of US tax reform has been widespread for years, although it is sometimes hard to gauge how much of the talk is… – Continue reading
This report summarizes the OECD paper describing the consensus approach on intangible property regimes under BEPS Action 5. On 6 February 2015, the Organisation for Economic Co-operation and Development (OECD) released a trio of papers that address three of the focus areas in its Action Plan on Base Erosion and… – Continue reading
Apple, Google, and other major U.S.-based multinationals may soon be able to bring more of their foreign-earned income back to American shores without facing a huge tax burden, as lawmakers are moving forward on a tax reform framework that could eliminate taxes on international earnings and authorize a one-time repatriation… – Continue reading
Top lawmakers and the White House are in the early stages of discussing an ambitious overhaul of how the U.S. taxes its multinational firms, according to officials involved in the effort. The talks, part of an effort to find funding for a long-term highway bill, are preliminary and could yet… – Continue reading
Germany and the Netherlands have signed a new agreement that provides for the “spontaneous” exchange of information on advance pricing agreements and advance tax rulings. The agreement was signed in Brussels on July 14, 2015. Under the new agreement, both countries have committed to the mutual exchange of information on… – Continue reading
In May 2012, Cyprus introduced a package of incentives and tax exemptions relating to investment in intellectual property rights, commonly known as an “IP box.” Intellectual property projects are particularly susceptible to cross-border planning by reason of the mobility of intellectual property rights, which do not consist of physical assets… – Continue reading
DEVELOPED countries throughout the world are stepping up efforts to curb base erosion and profit shifting (BEPS), a scheme used by multinational companies to avoid paying taxes estimated as high as $200 billion globally, especially when doing business across different jurisdictions. At the 2015 Asia Pacific Tax Symposium hosted last… – Continue reading
ARLINGTON, Va., July 14, 2015 /PRNewswire/ — Bloomberg BNA today announced the latest event in its Global Transfer Pricing Conference series with Baker & McKenzie, in association with the Tax Management Educational Institute, to be held September 17-18, 2015 in Shanghai, China. The conference provides an opportunity to hear from… – Continue reading
European Commission to issue decisions on four test cases, including Apple in Ireland, Until a few months ago, the medieval town of Athenry in County Galway owed its fame mainly to a song. Irish rugby and football fans often burst into stirring renditions of “The Fields of Athenry”, a ballad… – Continue reading
On July 8, 2015, the International Tax Reform Working Group, which is co-chaired by Senators Rob Portman (R-OH) and Chuck Schumer (D-NY), released its long-awaited report that Senate Finance Committee Chairman Orrin Hatch (R-UT) has said is the precursor to comprehensive tax reform in the United States. What does the… – Continue reading
House Ways and Means Chairman Paul Ryan (R-Wis.) made it clear Thursday that tapping offshore corporate profits was his top choice for funding a longer-term highway bill. In fact, Ryan declined to even lay out what the House GOP’s “Plan B” might be, ahead of a looming July 31 deadline… – Continue reading
Sens. Rob Portman (R-Ohio) and Chuck Schumer (D-NY) today released a long-awaited tax reform plan that reads like a wish list for multinational corporations. The Senate Finance Committee working group’s report provides recommendations for restructuring the federal government’s international corporation tax rules. The plan is long on misguided ideas and… – Continue reading
The UK Government’s goal is to make the UK the best place in the world to locate an international business; it has one of the most open economies globally, a highly skilled workforce, access to capital markets, a first-class infrastructure, and a highly competitive corporate tax system. UK tax policy… – Continue reading
Ireland’s attractively low rate of corporate taxation is once again under pressure with the recent release of the European Commission’s new action plan to tackle tax avoidance. The commission has been prompted into this politically ambitious move by public outcry over big, usually American, companies avoiding tax in the EU…. – Continue reading
Top Democrats are increasingly embracing a framework for taxing offshore corporate earnings that has long been favored by Republicans, as the two parties seek a deal that could provide long-term funding for the nation’s highways Sen. Charles Schumer (D-N.Y.) is the latest Democrat to get on board, releasing a plan… – Continue reading
New York State is increasingly reliant on China as a consumer of services and manufactured goods. In 2014, New York exported approximately US$4 billion to China, making it the state’s sixth largest export market. The top five exports to China are transportation equipment, waste & scrap, machinery (except electrical), primary… – Continue reading
Copycat China is notorious . Many Western companies hesitate to enter China or to bring in technology, because of valid concerns about loss of intellectual property. This concern is even greater when it comes to innovating or conducting R&D in China. But there is encouraging news: the framework for IP… – Continue reading
Brazilian President Dilma Roussef met with President Barack Obama at the White House this week. Below is the new multi-faceted partnership. The United States and Brazilian relationship has been unstable since the U.S. spying policy became known in 2013. Brazilian President Dilma Roussef canceled a 2013 visit to Washington, D.C…. – Continue reading
The European Commission has released a working paper that looks at how significant the introduction of the modified nexus approach will be for the tax affairs of multinational companies that use patent box regimes Entitled Patent Boxes Design, Patents Location, and Local R&D, the paper suggests “that in the majority… – Continue reading
The Unified Patent Court (UPC) Agreement will not be ratified in the UK this year, the Intellectual Property Office (IPO) has confirmed. In a statement sent to Out-Law.com, the IPO ruled out ratification of the Agreement this year but said that it intends to complete the “domestic preparations” for ratification… – Continue reading
The biggest hurdle to stopping multinational tax evasion isn’t the companies themselves. It’s the governments behind them. As the OECD works swiftly on its plan to stop multinational tax evasion, the United States has already signalled it’s not happy with what’s being proposed. The US has always been clear on… – Continue reading
U.S. lawmakers are exploring a new corporate tax break that would benefit companies already adept at avoiding taxes. The idea — known as a patent box or innovation box — would impose a lower tax rate on income generated from patents and other intellectual property housed in the U.S. This… – Continue reading
It’s the $2 trillion question. That’s roughly how much U.S. multinational corporations have stashed offshore — money that both Republicans and Democrats would like to tap for revenue and cash that even some companies wouldn’t mind paying a reduced tax rate on. Democrats and some Republicans are interested in using… – Continue reading
Companies registering their intellectual property in Israel will be charged only 5% tax on dividends. The committee considering changes in the Law for the Encouragement of Capital Investments, headed by former Ministry of Finance director general Yael Andorn, is recommending extension of the tax break granted under the law to… – Continue reading
Someone once said that a good tax system enables the government to pluck the feathers from the taxpaying goose with the least amount of hissing, says Rod Houng-Lee. The least amount of hissing occurs when the law is simple and clear. The hissing increases exponentially when the law is more… – Continue reading
Washington, June 21 (IANS): Indian Finance Minister Arun Jaitley is wooing American investors with twin assurances — more economic reforms and a stable policy regime with no intention to legislate or apply laws retrospectively. Jaitley has held talks with US Treasury Secretary Jacob Lew, Commerce Secretary Penny Pritzker and US… – Continue reading
Business and politicains all want it but welfare reform demand from London has thrown up an unexpected hurdle If corporation tax were cool, Eamonn Donaghy of KPMG in Belfast would be the Bono of his world – half quiet tax accountant, half buccaneering campaigner with a nifty sideline in high-level… – Continue reading
Top congressional lawmakers have ramped up discussions over international tax reform as the outlook for business and comprehensive reform has dimmed. The president has flatly rejected individual rate cuts, and efforts toward business-only reform have flagged as the pass-through community has rejected most proposals that would leave it out of… – Continue reading
LAS VEGAS, June 4, 2015 /PRNewswire/ — Remark Media, Inc. (NASDAQ: MARK) today announced that its Board of Directors has adopted a plan, known as the Tax Benefit Preservation Plan, designed to protect the significant potential long-term tax benefits presented by the company’s net operating losses. Remark intends to seek… – Continue reading
It’s time for a complete overhaul of the global tax system to ensure each company pays their fair share, says Nobel laureate Joseph Stiglitz. A group of leading economists — led by Stiglitz — issued a call Tuesday for countries to overhaul the system to prevent multinationals such as Apple… – Continue reading
The five biggest suppliers of publicly subsidised medicines in Australia recorded sales of nearly $5 billion last year but paid an average of just $10 million each in company tax. Research by the Parliamentary Library, obtained by Fairfax Media, has disclosed the tax contribution of multinational pharmaceutical companies, including Pfizer… – Continue reading
Registering a company in Singapore is as good as declaring that you have judged your options, made your preparations, and now that the time is right, you mean nothing but, business. Opening a company in Singapore is an act enough for the investors to gauge the depth of your intent… – Continue reading
Following our article at the end of last year on the potential changes to the UK patent box regime further details have been released on the new regime, timings and additional work to be done. On 6 February 2015, the Organisation for Economic Co-operation and Development (OECD) published a paper… – Continue reading
France and Germany want to see common basic corporation tax rates across the EU, according to reports France and Germany are pushing plans to introduce a minimum corporation tax rate across the continent, it was reported today, in a move that could result in higher taxes on British companies. European… – Continue reading
Big pharma’s poison pill The tax commissioner wants a senate inquiry to examine tax minimisation by multinational drug companies. Analysis with Heath Aston. Pharmaceutical companies will be put under the microscope by the Senate tax avoidance inquiry which recently exposed rampant “offshoring” of profits by Google, Apple and Microsoft. Tax… – Continue reading
The UK’s introduction of the diverted profits tax (DPT) has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) and in effect as of April 1, the DPT seemed intended to appease public anger at multinationals failing to pay their ”fair… – Continue reading
International fast-food giant McDonald’s avoided paying half a billion dollars of tax in Australia over a five-year period by shifting profits through the low-tax nation of Singapore, a new report by a global coalition of trade unions says. The report, which has been funded and commissioned by a coalition of… – Continue reading
Technology companies need to stop “extremely aggressive” tax planning, the man charged with reforming global tax rules has told the BBC. He says these “push the boundaries of what is legal”. Pascal Saint-Amans, who runs the OECD’s Centre for Tax Policy, said that new standards would require companies to pay… – Continue reading
FATCA reporting commences In our March client briefing we noted that the Tax Information Authority in the Cayman Islands (“TIA”) had launched its online portal for the automatic exchange of tax information (the “AEOI Portal”), which can be accessed from its website (www.tia.gov.ky). The deadline for reporting Cayman Islands financial… – Continue reading
The corporate community is increasingly sounding the warning to Congress: Europe is coming after us on taxes. With tax reform talks stumbling in Washington, the fear for corporate titans is that other countries are already implementing a global set of recommendations meant to crack down on offshore tax avoidance. Lobbyists… – Continue reading
Dropbox has become the latest technology firm to skirt local tax rates after confirming it will bill its customers from a company set up in Ireland. In an email sent to users on the weekend, Dropbox confirmed it would bill its international users using the entity Dropbox Ireland from June…. – Continue reading
The American Chamber of Commerce has warned that new Irish tax incentives may fail because they do not match the needs of multinationals, reports the Irish News. The chamber, which represents 700 US companies, has said the forthcoming Knowledge Development Box – which will replace the discredited Double Irish structure… – Continue reading
Choosing the right location for the centralization and management of your IP is a very important strategic business decision. The ideal location to establish an IP structure is one that can serve the organization’s business strategies/model, safeguard and protect its IP and more important to contribute to its tax optimization…. – Continue reading
U.S. Ambassador to Armenia Richard Mills on Tuesday confirmed reports that a U.S.-Armenia Trade and Investment Treaty will be signed during President Sargsyan’s working visit this week to Washington, DC, the final step in the negotiation of a bilateral economic accord long sought by the Armenian National Committee of America… – Continue reading
The Davis Tax Committee (“DTC”) recently addressed the issue of base erosion and profit shifting (“BEPS”) in South Africa. The international importance of transfer pricing was once again emphasized when 4 out of the 15 actions identified in the OECD Action Plan on BEPS related to transfer pricing. The 15… – Continue reading
The patent box regime, adopted at the end of 2014 with Italy’s Stability Law, was recently modified by the Investment Compact Decree and implemented into law at the end of March 2015. A distinctive feature of the Italian regime is that the measure now also covers trademarks and designs. A… – Continue reading
The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project is changing the international tax landscape by building a new international consensus on how to tackle BEPS. In September 2014, the first seven of the deliverables under the 15-point BEPS Action Plan were presented to G20 Finance Ministers when they met… – Continue reading
