In October 2013 Minister Michael Noonan presented Budget 2014. The Minister’s budget speech indicated that one of the primary aims of that Budget was to bring Ireland back to a position where it could fund itself fully through the international markets in a sustainable way, at competitive interest rates. It… – Continue reading
There is a great need to protect traditional knowledge in order to curb the exploitation of holders of indigenous knowledge, particularly the elderly. It has been observed that the elderly have indigenous knowledge but their wisdom is being stolen from them and used for commercial purposes while they languish in… – Continue reading
Americans have overcome oligarchy before — and there’s no reason we can’t do it again. Rising inequality seems to pose an insurmountable political problem. If the underlying causes are technological change and globalization, the forces appear to be unstoppable. Alternatively, if the causes are primarily political and involve the power… – Continue reading
The Luxembourg Intellectual Property (IP) tax regime will be aligned to the “modified nexus approach”, as per Pierre Gramegna, Luxembourg’s Finance Minister. The IP regime is expected to be modified in 2015 and to be in force no later than 30 June 2016. This is driven by the OECD’s Base… – Continue reading
FATCA 1. New FATCA IGA guidance notes On 3 February 2015, the Jersey Chief Minister’s Department published the latest version of the Guidance Notes on the Taxation (International Tax Compliance) (Jersey) Regulations 2014 in relation to the implementation of obligations arising under the intergovernmental agreements (IGAs) with the US and… – Continue reading
International plans for gathering and analysing data on the extent to which multinational companies are artificially shifting their profits to low-tax jurisdictions are at a disappointingly early stage, an expert has said. Heather Self of Pinsent Masons, the law firm behind Out-Law.com, also said that the global governments involved in… – Continue reading
Technology companies with international operations are increasingly using global tax avoidance methods, despite growing opposition from the public and politicians in the U.S. and abroad. As this opposition fuels ongoing changes in tax rules, organizations must be able to quickly adapt their corporate structures and tax strategies to maintain a… – Continue reading
Dixcart, an international business support services provider, has released a new guide on the UK’s Diverted Profits Tax, which was altered ahead of its introduction on April 1, 2015. The DPT is intended to counter aggressive tax avoidance by multinational companies. It is charged at a rate of 25 percent… – Continue reading
Last week some of Australia’s biggest and richest companies voluntarily fronted up to a senate inquiry on corporate tax avoidance. Bigwigs from big brands, including Apple, Google, Microsoft, Rio Tinto, BHP Billiton and Fortescue Metals, squirmed under the spotlight as they were grilled about how they (legally) shift profits offshore… – Continue reading
Duncan Card believes that his new law firm will be instrumental in attracting foreign investment to the Island. Bennett Jones (Bermuda) Ltd, which practises in association with the Canadian law firm of the same name, will be led by managing principal Mr Card, a Bermudian who has returned with his… – Continue reading
1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins Canada is a federal state, with legislative powers divided between the federal and provincial governments. The federal government has legislative jurisdiction over issues concerning Canada as a whole, including foreign affairs, international trade, banking, telecommunications,… – Continue reading
Every year, corporations and wealthy individuals use complicated gimmicks to shift U.S. earnings to subsidiaries in offshore tax havens – countries with minimal or no taxes – in order to reduce their federal and state income tax liabilities by billions of dollars. While tax haven abusers benefit from America’s markets,… – Continue reading
Historically taxpayers have faced difficulty overcoming a presumption against a change in domicile to a foreign jurisdiction. Intellectual property generally will be the most valuable asset held by technology companies and, in fact, many other business entities across all sectors of the economy. A recent analysis of S&P 500 companies… – Continue reading
International and local experts discuss best judicial solutions for intellectual property and money laundering crimes UAE – Dubai Judicial Institute (DJI), in partnership with the Office of Overseas Prosecutorial Development, Assistance and Training (OPDAT) of the U.S. Department of Justice, held a special joint workshop designed to raise more awareness… – Continue reading
China has introduced measures to deny income tax deductions for certain service fees and royalties paid by Chinese companies to their overseas affiliates. They appear to stem from China’s initiatives to implement rules it sees as related to the OECD’s Base Erosion and Profit Shifting project (BEPS) They will likely… – Continue reading
The Western world needs to tackle multi-national tax avoidance a “bit like” it has tackled the Islamic State terrorist group, maverick Liberal senator Bill Heffernan says. Senator Heffernan has for years argued tax avoidance is a threat to sovereignty and thinks it will take a coalition of Western countries to… – Continue reading
• Starbucks ran its European business – including UK – through Holland • But Dutch division paid just £1.9million tax on profits of £300million • Now details of UK company at heart of new probe have started to emerge • A Starbucks spokesman said it complies ‘with all relevant tax… – Continue reading
It has been revealed that illicit financial transfers are draining Africa of massive resources needed to uplift its majority poor from the claws of poverty and provide both productive and social infrastructure for development. The African Civil Society Circle, a group of nine civil society organizations and think tanks from… – Continue reading
Jurisdictional issues will limit success. It’s no secret that companies including Apple, Google and Amazon, seem to pay less than their fair share of tax in Australia. Despite booking huge revenues from sales to Australian customers they are able to reduce their profits in this country by shifting profits to… – Continue reading
New EU plans to force governments to send quarterly reports on tax rulings are a “revolutionary” step towards overcoming corporate secrecy, the bloc’s tax commissioner has said. The blueprint published two weeks ago by the Commission would establish a system of automatic exchange of information on tax rulings and require… – Continue reading
Summary:A new discussion paper released by the Australian government suggests that the emergence of new financial transaction technology such as bitcoin is making it tough for the country’s authorities to clamp down on tax avoidance. The emergence of new technology is proving to be problematic for Australia’s tax system, according… – Continue reading
Labour MEP says tax harmonisation inhibits competitiveness of disadvantaged regions Labour MEP and head of delegation Alfred Sant has abstained on a European Parliament vote on a resolution on tax fairness. The resolution, which touches on a wide variety of tax related-issues, lays a basis for further parliamentary work on… – Continue reading
Businesses still have concerns over the drafting of a new tax on multinationals said tax expert Heather Self of Pinsent Masons, the law firm behind Out-law.com. She was commenting after the UK’s Finance Bill, which contained the legislation for the new tax, completed its rapid progress through Parliament when it… – Continue reading
Irish firm featured in Luxleaks coverage has set up a new company: Glanbia Cheesip Ltd In the wake of the Luxleaks controversy last year, then chair of the Revenue Commissioners Josephine Feehily said that a company’s tax policies contained the potential for reputational risk if the strategies they were implementing,… – Continue reading
Tackling tax evasion should be a top EU priority. EU countries and the European Commission should play a leading role in discussing how to fight tax fraud and aggressive tax planning in the OECD and other relevant fora, says Parliament in its resolution on tax, voted on Wednesday. The resolution,… – Continue reading
The recent release of Ireland’s major strategy paper, ‘IFS2020 – A strategy for Ireland’s financial services sector 2015-2020’ addresses Ireland’s five year strategy in further developing the country as a global leader in the financial services sector. Over the past 25 years, Ireland’s international financial services sector has grown dramatically,… – Continue reading
The Abbott Government will shortly release a discussion paper on the Australian tax system. It will be the first step towards the much anticipated tax white paper. International factors should figure prominently in the white paper — specifically, how to ensure that Australia has a resilient tax system given the… – Continue reading
The Organisation for Economic Co-operation and Development (OECD) has briefed leaders of the Group of Twenty (G-20) nations on recent advances towards the conclusion of its base erosion and profit shifting project, which it says may be completed ahead of schedule. The OECD presented a report to the G-20 Finance… – Continue reading
As discussed in prior posts, an asset sale transfers only the assets of the business, whereas a stock sale transfers some or all of the ownership interest in the business as well as its obligations and liabilities. In this continuing examination of how to structure a business sale, the next… – Continue reading
The Federal Board of Revenue (FBR) has received a budget proposal of the Overseas Investors Chamber of Commerce & Industry (OICCI) regarding reduction in activation tax on mobile phones from Rs 250 to Rs 150 and withdraw sales tax on SIM card issuance and IMEI tax to avoid double taxation… – Continue reading
In Ruling No. 27296, Italy’s Supreme Court rejected the tax authorities’ appeal against an Italian company’s transfer of goods and services to its German parent. The Supreme Court ruled that if there is no clear economic advantage for a company, simply proving a transaction is not at arm’s-length is insufficient… – Continue reading
1.GENERAL QUESTIONS 1.1 Why is the Commission presenting a Tax Transparency Package? The Commission has made the fight against tax evasion and corporate tax avoidance a political priority, with a view to creating a socially and economically more efficient Single Market. While much has been done to advance this agenda… – Continue reading
As the OECD/EU project on Base Erosion and Profit Shifting (“BEPS”) moves towards its next set of reports in autumn 2015, Ireland Inc.’s low tax offering has been, and will be, further refined. While the 12.5% corporate tax rate remains beyond approach both domestically and internationally, the BEPS initiative has… – Continue reading
Irish Prime Minister Enda Kenny has reiterated his “rock-solid” commitment to the country’s 12.5 percent corporate tax rate. In a speech to the Irish Chamber of Commerce, Atlanta, Kenny said that his Government is “fully committed to pursuing policies that create the ideal conditions for enterprise and investment.” He pointed… – Continue reading
Two business federations from the Netherlands and Germany have urged the Organisation for Economic Co-operation and Development to ensure that there is a level playing field under new international rules proposed for preferential regimes for intellectual property (IP) income, reports Tax News. The two organizations’ statement concerns the development of… – Continue reading
You may have noted there’s an election in the offing Worstall on Wednesday As the tech news outlet of record has told us, UK chancellor George Osborne is preparing to bring in the “Google Tax”. Properly known as the Diverted Profits Tax, it is supposed to be a way of… – Continue reading
The Canada Border Services Agency (CBSA) has informed the Canadian importing community that importers may be entitled to obtain customs duty refunds in connection with downward transfer pricing adjustments having the effect of correcting/reducing invoiced prices that served as the basis of customs valuation of imported goods. On January 19,… – Continue reading
The Australian Taxation Office should be given the power to ignore multinational transactions that fail to pass the “common sense test” and ensure that technology company profits are taxed where they are earned, the Australia Institute submission to the inquiry into corporate tax avoidance says. The submission takes a swipe… – Continue reading
ARLINGTON, Virginia, March 10, 2015 /PRNewswire/ — Bloomberg BNA today announced an addition to its lineup of keynote speakers for the Global Transfer Pricing Conference: Paris, held in conjunction with Baker & McKenzie, on March 30-31 immediately after the Organisation for Economic Co-operation and Development (OECD) Global Forum on Transfer… – Continue reading
Just months after the Obama administration cracked down on mergers that helped US companies skirt domestic taxes, a wave of foreign takeovers is steering more tax revenue away from the US, reports the Wall Street Journal. In deals known as “tax inversions,” which spiked in 2014, US companies acquired foreign… – Continue reading
Ireland has become the top destination for US multinational investment and the economic bond between the countries is only likely to intensify, according to a leading Wall Street economist, reports the Irish Examiner. In a report on the economic relationship between Ireland and the US, compiled for the American Chamber… – Continue reading
The Public Accounts Committee (PAC) met last month to ask HM Revenue & Customs (HMRC) about its efforts to curb tax avoidance, including how HMRC has developed its transfer pricing approach to counteract tax arrangements such as those by Google, Amazon and Starbucks. Present at the hearing on February 11,… – Continue reading
The Global Transfer Pricing Guide is created to assist tax and finance professionals responsible for cross-border tax planning and compliance with their inquiries. Sterling Heights, Michigan (PRWEB) March 02, 2015 Global accountancy network UHY releases its 2015 “Global Transfer Pricing Guide” to assist tax and finance professionals responsible for cross-border… – Continue reading
Bill Shorten, criticised for adopting a near invisible profile as Labor Leader, outlined a “policy brief” on Monday intended to tackle multinational tax avoidance and add nearly $2 billion to consolidated revenue over three years. The four-pronged approach includes changing the so-called thin-capitalisation rules allowing corporations to claim tax deductions… – Continue reading
Corporate tax reform has emerged as an area of potential bipartisan action in the United States Congress over the next few months. But fundamental questions about the right approach remain. There is widespread agreement that the US corporate tax system is deeply flawed. The rate is too high; the base… – Continue reading
IN THIS INSTALLMENT of our series on the Base Erosion and Profit Shifting (BEPS) initiatives of the Organization for Economic Co-operation and Development (OECD), we will tackle Action Plan 8 on the revisions to Chapters I, II and VI of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax… – Continue reading
Al Tamimi & Company – Advocates and Legal Consultants Surabhi Singhi Kataria Tax planning has always been a topic of international debate and adjudication. The borderlines between permitted tax planning/avoidance and unlawful tax evasion have occupied the centre stage across the globe with several modern economies emphasizing the need for… – Continue reading
Profits outside US exceed non-US sales for company selling $1,000 a pill HepC therapy Gilead Science, whose $1,000-a-pill hepatitis C treatment is one of the world’s most expensive drugs, is avoiding billions of dollars in US taxes by booking profits overseas. The company, which has operations in Ireland, reported foreign… – Continue reading
The breathless conundrum for IP companies is four-fold: not only should royalties be taxed at a low rate in order to maximise profits; but also research and development (R&D) or acquisition costs should be considered as allowable expenses to the maximum possible effect, whilst also the jurisdiction where the IP… – Continue reading
The government is set to make changes in the income tax rules to seek overseas operational details of multinational businesses that have a turnover of over R5,000 crore in India in order to decide which companies should be audited for income suppression, reports Gireesh Chandra Prasad in New Delhi. The… – Continue reading
