Category: Tax Planning

Corporate Tax: Apple, Google, Dr Dre & Ireland’s continuing stateless companies

Corporate Tax Avoidance: Last week the news that Apple is considering buying Beats Electronics, a maker of expensive headphones that was founded by record mogul Jimmy Iovine and rap artist Dr Dre, for $3.2bn, got a lot of media attention. Dr Dre must have pissed-off Apple when he bragged on… – Continue reading

UPDATE 1-Russia’s Polyus Gold considers call to come home

MOSCOW, April 11 (Reuters) – Polyus Gold, Russia’s biggest gold miner, is considering state proposals to encourage the rebasing of Russian firms currently owned by offshore entities and intends to explore these issues with the government, the company said on Friday. The comments of the Jersey-registered company, whose share listing is… – Continue reading

India to scrap Rs 15-cr threshold for auditing MNC deals

India is set to scrap the R15-crore threshold for referring every international transaction between an MNC’s arms for compulsory transfer pricing audit, and about to embrace a more focused approach to zero in on cross-border transactions with potential for tax evasion. The proposed risk-based selection of transactions between MNC arms… – Continue reading

What qualifies as direct investment under Cyprus-Russia double tax agreement?

Introduction Article 10 of the Russia-Cyprus double tax agreement grants taxing rights over dividends to the state of residence of the company paying the dividends (in addition to the state of residence of the recipient). The tax that may be imposed in the state in which the dividends originate is… – Continue reading

Congress Considers Making Offshore Tax Loopholes Permanent

On Tuesday, the House Ways and Means Committee holds a hearing to discuss making permanent several of multinationals’ favorite tax code provisions, including the Apple loophole. Thus the House, like the Senate, is in the early stages of enacting these expired provisions yet again. That’s how Congress traditionally gives multinationals their offshore tax loopholes: propose… – Continue reading

Ireland’s effective corporation tax at approximately 10.8pc over a decade – report

IRELAND’s effective rate of corporation tax averaged between 10.7pc and 10.9pc over the last decade, a report by the Department of Finance states. It claims that the tax paid by companies is close to the 12.5pc headline rate, amid controversy over the amount paid by multinationals here. The Department commissioned… – Continue reading

Irish Economy 2014: Ibec forecasts robust growth in tax-related services exports

Irish Economy 2014: Ibec, Ireland’s leading business lobby group, in its latest economic forecast today forecasts “continued robust growth in services exports and a recovery in goods exports.” The strong growth in services mainly reflects tax-avoidance related revenue diversions to Ireland that do not reflect local economic activity. If the… – Continue reading

Report: Netflix Sets French Headquarters In Luxembourg to Bypass Regulations

PARIS — Netflix is set to follow iTunes and Google’s footsteps: The service is expected to launch in Gaul in the fall but will be headquartered Luxembourg in order to avoid the heavy French regulations. French newspaper Les Echos reported the move will bring Netflix’s French outpost together with its other European headquarters —… – Continue reading

Alibaba IPO Appeal Could Make It Target For Scutiny From Beijing

The much-anticipated initial public offering of Chinese Internet giant Alibaba Group could be a double-edged sword for the company: Investors are drooling for a piece of the action in that country’s burgeoning online payment market, but its growing use in illegal transactions could attract scrutiny from Chinese government regulators. Alibaba,… – Continue reading

I-T dept signs APAs with 5 MNCs, more pacts in offing

NEW DELHI: Seeking to reduce litigations and promote foreign investments, the Income Tax department has signed Advance Pricing Agreements with 5 multinational firms and plans to enter into more such pacts. “We have signed 5 APAs so far. We will be signing more in the coming days. Foreign companies are eager to… – Continue reading

United States: Remain Vigilant On Indian Permanent Establishments, Even After The Favorable e-Funds Decision

The U.S. and Indian competent authorities are famously at loggerheads over the principles to be applied in transfer-pricing double-tax cases.  Some of the important issues involved are:  the appropriate markup on costs for services; when and how to reward location savings; and whether marketing intangibles exist.  Virtually all of these… – Continue reading

Budget 2014: Tax advisers caught out on corporate properties

THE PENSIONS INDUSTRY may have been caught on the hop with George Osborne’s unexpected upheaval of the regime, but tax advisers didn’t get away scot-free. While Budgets have been more benign under the coalition government, advisers were caught out with revisions to the taxing of properties purchased within corporate wrappers. The… – Continue reading

How Suntech, Chinese Solar Giant, Was Snared In An Italian Fraud Scandal

As 2008 began, the future looked brilliant for green energy giant Suntech Power and its high-flying founder, Shi Zhengrong. Suntech was one of the world’s largest makers of solar panels, the first non-state-owned Chinese  company traded on the New York Stock Exchange. And Shi, born to a farm family so… – Continue reading

Argentine Official Meets FIFA’s Blatter on Soccer Tax Avoidance

Argentina’s tax agency head is meeting FIFA President Sepp Blatter today to tell him how soccer teams are evading taxes in the $3.7 billion player trading market. Ricardo Echegaray has traveled to the soccer ruling body’s headquarters in Zurich to inform Blatter that his agency has detected techniques used by… – Continue reading

Perenna Kei, World’s Youngest Billionaire, May Be Helping Family Hide Offshore Wealth

More bits of information have emerged regarding China’s secretive, young billionaire Perenna Kei. After Forbes Magazine put Kei on their list of the world’s youngest billionaires, the search for details began. Most publications could not confirm her identity, as several photos were published mistakenly labeling Kei. A new photo of… – Continue reading

Tax Avoidance/ Evasion: UK Budget’s new rules; US senators want 30 Swiss bankers extradited

Tax Avoidance/ Evasion: On Wednesday George Osborne, UK chancellor, proposed new rules in his Budget 2014 statement to reduce the opportunities for rich individuals and companies to avoid or evade personal and corporate taxes. Also this week, two prominent US senators wrote to the Justice Department to seek extradition of about 30… – Continue reading

Liverpool children’s hospital goes offshore

DESPITE George Osborne’s platitudes to last month’s G20 meeting in Australia – “It is not fair if big companies avoid their taxes by shifting their profits around artificially” – the Eye has discovered that the government has signed its most significant PFI deal to date (a new £190m children’s hospital… – Continue reading

Wealthy investors protest against new UK tax rules

Proposals to tighten the screws on users of tax avoidance schemes in next week’s Budget have sparked protests from wealthy investors and their advisers who say the measures would be retrospective and “completely contrary to natural justice”. Thousands of financiers, celebrities, entrepreneurs, and other wealthy users of tax avoidance schemes will potentially… – Continue reading