POLITICIANS in the rich world like to splutter about the ever more elaborate dodges that big multinational firms undertake to minimise their tax bills. But doing something about them is trickier. America’s Congress is struggling to agree on ways to stop companies “inverting”—switching domicile to reduce tax bills (see article)…. – Continue reading
As the finance ministers and central bank governors from the world’s 20 largest economies gather in a convention centre in the Australian city of Cairns this weekend, anti-capitalist protesters will likely accuse them of doing the bidding of the globe’s all-powerful multinational corporations. But the Group of 20’s financial chieftains… – Continue reading
Having recently blasted corporate tax evaders, the deputy president now has egg on his face after Lonmin’s Bermuda tax avoidance tactics surfaced. Evidence before the Marikana commission that Lonmin moved millions in platinum revenue from South Africa to tax-free Bermuda is likely to prove embarrassing for ANC deputy president Cyril… – Continue reading
Yesterday saw the release of the first set of deliverables under the OECD’s project on base erosion and profit shifting (BEPS). These constitute the “building blocks” for an internationally agreed and co-ordinated response to government and media concerns in recent years about the perceived way in which shortcomings in relevant… – Continue reading
THE CLAMPDOWN on tax avoidance by multinational corporations has been bolstered by a series of recommendations made by the OECD. Companies including Google, Amazon and Starbucks have been in the firing line for their use of offshore jurisdictions to drive down their UK tax liabilities. In particular, the companies have… – Continue reading
HONG KONG – The government of Hong Kong has recently announced that it will support the Organization for Economic Cooperation and Development’s (OECD) new global standards on the automatic exchange of information for the purpose of enhancing tax transparency and combating cross-border tax evasion. Earlier this year, the OECD released… – Continue reading
Luxury brand came under investigation after routing €680m through its Irish unit Apple and Google are names regularly cited when it comes to using Ireland for aggressive tax planning, but the practice is open to a much wider range of businesses. Bulgari, the Italian jewellery giant whose products were made… – Continue reading
Cyprus has accepted a key condition put forward by India on effective exchange of information on tax avoiders Cyprus has accepted a key condition put forward by India on effective exchange of information on tax avoiders, hoping its move, which comes amid continuing talks on amending their mutual tax treaty,… – Continue reading
The Organization for Economic Cooperation and Development has released its first set of recommendations for a coordinated international approach to combat tax avoidance by multinational enterprises, under the OECD/G20 Base Erosion and Profit Shifting Project. The OECD and the Group of 20 finance ministers hope to create a single set… – Continue reading
India has seemingly reached an impasse with both Cyprus and Mauritius over the re-negotiation of their respective double taxation avoidance agreements (DTAA). For the former, the disagreement relates to Cyprus’s status as a notified jurisdictional area (NJA) in India, whilst for the latter, it pertains to the update of their… – Continue reading
The OECD will today publish its first recommendations for a co-ordinated international approach to combat tax avoidance by multinational enterprises under the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project. Meanwhile there is already evidence in Europe that the confluence of massive tax avoidance and increased concerns about privacy is… – Continue reading
On September 16, 2014, the Organisation for Economic Co-operation and Development (OECD) released its first seven of 15 deliverables under the OECD/G20 base erosion and profit shifting (BEPS) project (the 2014 BEPS Package). The 2014 BEPS Package arises from the Action Plan on Base Erosion and Profit Shifting (the BEPS Action Plan),… – Continue reading
The past few years have seen a quantum leap in globalisation, resulting in free movement of capital and labour, shifting of manufacturing bases from high-cost to low-cost locations, gradual removal of trade barriers, technological and telecommunication developments, etc. These developments have, on one hand, led to increasing sophistication in tax… – Continue reading
Transfer pricing continues to be a critical issue for the Indonesian Tax Office (“ITO”). In an effort to provide much needed clarity on transfer pricing practices, particularly in relation to transfer pricing audits, the ITO issued PER 22[1] to provide guidance to auditors on what they should be focusing on in… – Continue reading
BANGKOK, Sept 10 (Bernama) — Developing countries may be losing over US$160 billion annually due to corporate tax avoidance – money that could fund greater policy ambitions to get the global economy out of the doldrums and moving towards a more inclusive and sustainable future. Greater policy ambition in both… – Continue reading
Noble Energy and Jordan recently signed a nonbinding agreement for the sale of 8.5% of Leviathan’s gas over the course of 15 years, for as much as $15 billion. By Avi Bar-Eli | Sep. 9, 2014 | 2:47 AM The preliminary deal for the sale of gas to Jordan from… – Continue reading
MONTREAL – The disclosure by Valeant Pharmaceuticals International Inc. that it is under audit by the U.S. Internal Revenue Service is raising further doubts among tax specialists about the future of the Quebec-based drug company’s tax strategies. Valeant estimates it has achieved US$2.5-billion in tax and other “corporate structure” savings… – Continue reading
Antony Ting describes it as “like finding treasure”. It was 18 months ago when the powerful US congressional committee blew the lid on Apple’s aggressive corporate tax structure, which allowed it to funnel $US44 billion dollars out of the countrythrough a network of tax haven subsidiaries. Dr Ting, a senior… – Continue reading
(India and Switzerland are…) NEW DELHI: India and Switzerland are finding it difficult to break a deadlock over sharing information on secret bank accounts held in the European nation but both sides are close to finalising the first accord on a bilateral advance pricing agreement that will allow taxpayers to… – Continue reading
Audits may now be based on risk of tax evasion The government has dropped the Rs 15-crore threshold for referring transactions between a multinational company and its Indian subsidiary for compulsory scrutiny by the tax department. It might, instead, move towards a risk-based approach to identify international transactions prone to… – Continue reading
PRESSURE is mounting both within and outside Parliament for the government to introduce dedicated legislation to ban transfer pricing when it is used as a tax-avoidance measure to shift profit offshore. South Africa is estimated to lose tens of billions of rand annually from the abuse of transfer pricing by… – Continue reading
Stopgap efforts to prevent corporate tax inversions won’t fix the underlying problems With Congress about to return for a final push before the midterm elections in November, one topic on everyone’s lips is so-called corporate inversions. The practice, where a large U.S. company buys a smaller foreign company in order… – Continue reading
To ensure location-based profits stay on shore. Treasurer Joe Hockey has promised to direct the Tax Office to target multinational businesses who charge Australians more for technology and ship the profits offshore to avoid tax. In a pre-G20 speech this morning, Hockey outlined the ways the Government plans to tighten… – Continue reading
COMPLICATED transfer pricing legislation remains a burden and has become an increased risk for multinational firms doing business in SA and the rest of the continent. Transfer pricing is the price charged for goods and services in cross-border transactions between two companies within the same multinational group. Companies can become… – Continue reading
TRANSFER pricing occurs whenever there is a transaction between two business enterprises which are part of the same group of companies or are controlled by a common person. In simple terms we refer to such parties as related parties. The business enterprises can include companies, limited liability partnerships, partnerships, branches,… – Continue reading
Tax authorities throughout the world are cracking down on taxpayers – individuals and corporations – that utilize some aggressive tax planning strategies. While most of these schemes are perfectly legal and merely take advantage of loopholes in theinternational tax system, there is a growing concern that they not only threaten… – Continue reading
In its ongoing efforts to control tax evasion, China’s State Administration of Taxation (SAT) has recently published an instruction (Tax Office General Fa [2014] No 146), calling on national and local tax bureaus to investigate transfer pricing practices of Chinese enterprises. Under scrutiny by the SAT are all transactions involving… – Continue reading
CFOs of multinationals need to prepare by assessing how much their companies engage in profit shifting to cut their taxes. Do you have responsibility, whether direct or dotted line, for the tax function in your company? Does your company have, or plan to have, operations outside the United States? If… – Continue reading
VietNamNet Bridge – The bad news about tax evasion and debt repudiation cases by foreign invested companies has darkened Vietnam’s foreign direct investment (FDI) landscape. Tuoi Tre newspaper has reported that Austrian Harald Biebl, director of the HCM City-based Bach Hop Company, operational in Vietnam since 2005, has fled the… – Continue reading
A new section 1305A of the UK Corporation Tax Act 2009 (CTA 2009) has been introduced by the UK Finance Act 2014 that applies to payments made from March 19, 2014 under avoidance schemes involving the transfer of corporate profits within a group. This new measure applies if: two companies… – Continue reading
Law360, Washington (August 18, 2014, 5:20 PM ET) — Medical device manufacturer Zimmer Holdings Inc. is protesting a $79 million Internal Revenue Service assessment arising from transfer pricing adjustments that the agency made on transactions, including licensing agreements, between itself and a Dutch subsidiary, according to court records made public… – Continue reading
The Canada Revenue Agency is speeding up the frequency of reassessments of Cameco’s tax returns in what may be an attempt to pressure Cameco to settle out of court. Cameco’s cash is being tied up as they are required to remit 50% of each disputed bill. Cameco could ultimately be… – Continue reading
