Swiss authorities have confirmed that, if asked, they will assist India in efforts to confirm the genuineness of bank documents and will swiftly provide information on requests relating to non-banking dossiers. The commitment was made in a joint statement following a meeting between the Swiss State Secretary, Jacques de Watteville,… – 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
The much-awaited decision of the Bombay High Court was pronounced on October 10. Transfer pricing adjustment carried out in Shell/Vodafone case has been at the centrestage of every public discussion on Indian transfer pricing legislation. The incredulous stand taken by the tax authorities has evoked a strong response from investors… – Continue reading
n this second part of our overview of current transfer pricing regulations on the African continent, we focus on relevant provisions in, amongst others, Ghana, Nigeria and Uganda. The Ghanaian Transfer Pricing Regulations, 2012 (L.I.2188) (the Ghanaian Regulations) were introduced by the Ghana Revenue Authority (GRA) on 27 July 2012,… – Continue reading
A report claiming Lonmin is engaging in two transfer pricing arrangements is misleading and false, the company said on Thursday. It was responding to a report titled “The Bermuda connection: Profit shifting and unaffordability at Lonmin 1999-2012″, released by the Alternative Information and Development Centre (AIDC) on Thursday morning. “Lonmin… – 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
On July 21, 2014, the governments of Canada and the United Kingdom signed the fourth protocol (Protocol) amending the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading
Oslo : Allaying investors fear, President Pranab Mukherjee today said that the Bombay High Court verdict in the Vodafone taxation case, if it prevails, will help Finnish phone manufacturer Nokia as also 26 others. In his interview to Finnish media ahead of his departure to Helsinki, Mukherjee here said the… – 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
Malta, like Cyprus, has been obliged to dismantle its old ‘offshore’ companies regime as a trade-off for joining the European Union. EU membership has, however, brought about certain benefits for Maltese companies trading across borders, and, coupled with investment-friendly government policies and some interesting tax planning opportunities, Malta remains one… – 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
Foreign investors, not to mention the country itself, need a more stable and predictable regime Foreign companies are depressingly used to run-ins with the Indian taxman. A string of groups, including Vodafone, IBM and Cairn Energy, have been hauled into the dock for not paying their dues in recent years…. – Continue reading
The Alternative Information Development Centre (Disclosure: AIDC’s economist Dick Forslund contributes to Daily Maverick, most recently about Lonmin) has been served with an interdict application in the Johannesburg High Court to try to prevent the organisation from holding a press conference about Lonmin’s finances, especially relating to the use of… – Continue reading
Transactions within, rather than between, companies now accounts for about a quarter of Australia’s economic output, the Tax Office says. In a sign of the challenges facing the government’s crackdown on corporate tax erosion, the ATO said related-party dealings now amounted to more than a quarter of a billion dollars… – Continue reading
NEW DELHI: Vodafone welcomed an Indian court ruling in favor of the British mobile giant which was engaged in a $490-million tax battle with local authorities. The tax fight is one of several embroiling the British company that has become a symbol of problems facing foreign firms doing business in… – Continue reading
Vodafone has emerged victorious against the Indian taxman in the latest bout of litigation between the two. The important point for the rest of us being what it tells us about those endless claims of tax avoidance and tax evasion by large companies. It’s not just that large amounts of… – 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
VietNamNet Bridge – Foreign automobile and electronics manufacturers often choose foreign enterprises for their parts and accessory suppliers instead of Vietnamese companies because it allows them to engage in transfer pricing, some analysts have claimed. Samsung, Toyota, Canon and other giants in the manufacturing industry have complained many times that… – Continue reading
Australian tax authorities allege multinational oil giant Chevron used a series of loans and related party payments worth billions of dollars to slash its tax bill by up to $258 million. New documents filed in a long-running dispute in the Federal Court show how Chevron allegedly engaged in a complex… – 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
BANGALORE, India — One of the world’s biggest cellular phone manufacturing plants, located in the southern India city of Chennai, will stop production of mobile phones and down shutters after Nov. 1. Microsoft, its lone customer, has terminated a subcontract agreement. “Microsoft has informed Nokia that it will be terminating… – 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
The taxman is willing to “negotiate and strike a balance” with multinationals being audited for transfer pricing misconduct, a drive it says has a potential to realise over Sh30 billion. The Kenya Revenue Authority told a workshop organised by the Association of Chartered Certified Accountants in Nairobi that this will… – 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 is believed to have exploited a slightly different tax loophole in Luxemborg to wash away most local taxes The European Union (EU) made waves late last month when its antitrust regulators — a part of the trade-regulating body known as the European Commission (EC) — issued a preliminary finding… – Continue reading
The European Commission has opened an in-depth investigation to examine whether the decision by Luxembourg’s tax authorities with regard to the corporate income tax to be paid by Amazon in Luxembourg comply with the EU rules on state aid. The opening of an in-depth investigation gives interested third parties and… – 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 Italian tax authorities have been intensifying their focus on transfer prices involving financial intercompany transactions such as loans. Multinational corporations frequently resort to such transactions to optimise and rationalise the financial management of the entire group. In certain cases, the said optimisation tools pertaining to intercompany financial resources may… – Continue reading
On Tuesday, September 30, 2014, the European Commission (the Commission) published its decision to open an investigation intoIreland’s transfer pricing practices. The Commission is also reviewing the transfer pricing practices of other EU Member States, including the Netherlands and Luxembourg. Any advanced pricing agreement (APA) or other tax ruling within the EU… – 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
Fiat-Chrysler (FIA.MI) reiterated on Thursday that a tax agreement granted by Luxembourg to one of its subsidiaries was legitimate and said the potential financial impact of a European Commission probe into the matter would not be significant. A tax concession that Luxembourg authorities granted to Fiat Finance and Trade in… – Continue reading
Her Majesty’s Revenue and Customs (HMRC) UK will assist Federal Board of Revenue (FBR) on tax and customs reform initiatives encompassing development of special skills to identify cases of transfer pricing, techniques to catch tax evaders and use of IT to control tax avoidance. It is learnt on Monday that the… – Continue reading
George Osborne, the Chancellor of the Exchequer over here in the UK, has just announced at the Conservative party conference that he’ll be changing the tax laws to make sure that Google GOOGL +0.16% and other tech multinationals (Facebook, Microsoft MSFT -0.17%, possibly Apple AAPL +0.64%, among them) end up… – Continue reading
High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Brussels has challenged Luxembourg over a tax ruling offering potentially illicit support to a Fiat subsidiary, opening a… – Continue reading
Tax attack Bill Shorten accuses the government during Tuesday’s question time of going soft on corporate tax avoidance; Tony Abbott says Labor did nothing in government. Autoplay ONOFFVideo feedbackVideo settings Bill Shorten: Corporate tax avoidance costs Australian business The Pulse Live: Judith Ireland blogs live from Parliament The Abbott government… – Continue reading
European regulators are set to examine whether Apple violated EU law by striking special tax deals with the Irish government. The European Commission opened an initial investigation into Apple’s tax affairs in June, looking at whether the company’s two percent tax rate in Ireland — far less than the standard 12.5… – Continue reading
Inland Revenue has gone shopping for a database to help it fight erosion of the tax base and “profit stripping” by multinational corporations. The database will help the taxman to independently assess the level of profitability companies should be returning for tax purposes by benchmarking the prices multinationals charge their… – Continue reading
Corporate financial accounting and taxation are complex subjects. For this reason, many people tune out when issues that involve corporate tax practices rise to the level of public debate. Unfortunately, many legislators shy away from these issues for similar reasons. But while corporate taxation can be mind-bogglingly complex, nontax experts… – Continue reading
European Union Tax Commissioner Algirdas Šemeta has welcomed a raft of new measures to combat international tax avoidance, in agreement between the finance ministers of the G20 at a meeting in Cairns, Australia. The ministers have agreed on a several recommendations that were made to address key areas which were… – Continue reading
Three years ago, Russia adopted new transfer pricing legislation. The new rules became effective on Jan. 1, 2012. They are in line with international standards (OECD Guidelines on Transfer Pricing), but their concept was, and still is, quite new for the Russian tax authorities. Thus the rules provide for a transition period until 2017: For the years 2012… – Continue reading
The Chartered Institute of Taxation’s Tax Policy Director has said the “first wave of reports [from the Organization for Economic Cooperation and Development on base erosion and profit shifting] is a significant step forward in the process of modernizing the international tax system, but the test will be getting international… – Continue reading
THE UK is the first of 44 countries to commit to the new country-by-country reporting model, the Treasury has confirmed. Put forward by the OECD last week as part of a wider movement against tax avoidance by large corporations, UK-based multinationals will have to report to HMRC where they make… – Continue reading
In recent years, Russian tax legislation has adopted many modern international tax concepts and practices. Most notably, transfer pricing rules, consolidated groups of taxpayers, easy electronic communications between taxpayers and tax authorities have all become part of standard working practice. However, there is always room for improvement. The current global economic and political situation dictates that new initiatives… – Continue reading
Reports that Lonmin was evading tax were denied by a spokeswoman on Monday, after calls that the company should be investigated. “It is completely false, we are busy preparing a statement,” spokeswoman Sue Vey said. Vey said she was not sure when the statement would be released. Earlier, Sars spokesman… – Continue reading
Plans to curb tax avoidance will hit Ireland. Most countries are set to force multinationals to pay more tax and as the political controversy grows, our own role in these activities will come under ever increasing scrutiny On Tuesday the OECD, the Paris-based club of the world’s richest economies, published… – Continue reading
