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Corporate Tax

News In Brief

  • Caterpillar: A BEPS case study

    April 24, 2014

    At the end of March, multinational manufacturer of construction and mining equipment, Caterpillar, was brought before the Senate to explain its tax affairs, accused of profit shifting and aggressive tax planning. Mirna Screpante, tax research specialist, describes the tax effects caused by the model currently accused of avoiding taxes.

  • CEOs acknowledge tax as a factor in business location decisions

    April 24, 2014

    Corporate taxpayers say tax is an influential factor when an international business is deciding where to locate itself.

  • Managing TP risks in Nigeria: The importance of proactivity

    April 24, 2014

    Nigerian transfer pricing rules are still in their relative infancy, but taxpayers must take adequate steps to prepare now if they are to effectively identify risk areas and plan with both the company policy and the prospect of audit in mind. Victor Adegite of KPMG Nigeria provides an overview and looks at what lessons can be learnt from experiences around the world.

  • Survey of company bosses shows appetite for more tax transparency

    April 24, 2014

    A survey of chief executive officers about the global economy has produced a number of headline-grabbing figures about their attitudes to tax, such as a surprising high level of support for country-by-country reporting, which would require them to disclose their companies’ income, profit and tax in each country in which they operate.

  • The journey into the future for Swiss principal companies?

    April 24, 2014

    Urs Landolf, Martina Walt and Christoph Pauli of PwC explain the impact new interpretations of principal company taxation by the Swiss federal tax authorities will have on all existing companies benefiting from circular no 8.

  • Jupiter Asset Management urges OECD to leave CIVs out of treaty abuse reform measures

    April 17, 2014

    The OECD has published stakeholder responses to its discussion draft on Action Point 6 of the BEPS Action Plan, which deals with treaty abuse. Funds and asset managers are calling for disparate treatment of collective investment vehicles (CIVs), while others are urging the OECD to reconsider its treaty preamble.

  • UK Treasury defends Patent Box against EC threat

    April 17, 2014

    The UK’s Patent Box could face amendments depending on the outcome of an EC investigation into whether it constitutes harmful tax competition that disadvantages other European member states.

  • Osborne hands HMRC greater powers to clamp down on tax haven use

    April 16, 2014

    UK Chancellor of the Exchequer George Osborne is granting HMRC new powers to prosecute those who evade taxes by stashing money offshore. The tax authority will no longer have to prove that a taxpayer intentionally evaded taxes.

  • Starbucks moving European HQ to London

    April 16, 2014

    Starbucks is set to pay more tax in the UK after today announcing it will move its European headquarters from the Netherlands to London. It has also pledged to create 1,000 new jobs in the country.

  • European decision in Felixstowe Dock to cause more changes to UK law

    April 15, 2014

    The European Court’s decision in the Felixstowe Dock case is likely to affect the UK regime for loss surrender in at least two ways, explains Rupert Shiers of Hogan Lovells.

  • Investment funds could be in the money after European court ruling against Poland

    April 11, 2014

    A European Court of Justice decision in favour of a US investment fund could cost EU member states billions of euros in withholding tax reclaims.

  • India: Shome reform committee report due next month

    April 10, 2014

    The Parthasarathi Shome-led Tax Administration Reform Commission (TARC) will next month release its first report since being set up to review existing tax administration mechanisms in India and make recommendations for improvement.

  • Macquarie joins calls for 25% Australian tax rate

    April 10, 2014

    After similar pleas throughout the past year, most recently from the Australian Tax Institute last month, Macquarie Group has now joined the calls for Australia to reduce its corporate tax rate. Macquarie says a 25% rate is necessary if Australia wants to become a regional financial services hub.

  • Nominations announced for European Tax Awards 2014

    April 10, 2014

    Deloitte and EY lead the race for International Tax Review’s 10th annual European Tax Awards, which will be presented at a dinner in London on May 21.

  • Russia: First hard-line draft law on CFC rules and corporate tax residency is out

    April 09, 2014

    On March 18, a few months after Putin’s address on the ’de-offshorisation’ of the Russian economy, the Finance Ministry published the first draft law on anti-avoidance rules. Artem Toropov of Goltsblat BLP explains how the draft law has already sent ripples through the Russian business community.

  • Revised Indian DTC takes aim at Vodafone-style transactions

    April 02, 2014

    The Indian government has released a revised version of the Direct Taxes Code (DTC) for public comment. One provision that stands out is aimed at bringing indirect share transfer transactions into the tax net.

  • Wyden tackles extender provisions

    April 02, 2014

    Ron Wyden, Senate Finance Committee chairman, has released a tax extenders Bill. Business lobbyists will be delighted that extender provisions (various tax breaks that expired at the end of last year) are receiving attention sooner rather than later, while House Republicans may view this as a blow to their hopes for comprehensive action on tax reform.

  • Adopting an Irish parent

    March 28, 2014

    From management consultants Accenture, to major pharmaceuticals including Perrigo, Forest Labs and Warner Chilcott, to manufacturer and equipment supplier Eaton Corporation to one of the world’s leading insurance groups, Willis, the shift to adopting an onshore Irish incorporated tax resident parent is gathering pace. Mason Hayes & Curran considers the rationale for such a shift and the long-term value creation for shareholders yielded by the shift.

  • Shared service centres require clear thinking

    March 28, 2014

    Transferring processes to a shared service centre can work for a tax department, explain Robert Risse, tax director of Henkel, and Ruediger Loitz of PwC, but taxpayers should work out why they are doing it first.

  • Argentina signs new tax treaty with Switzerland

    March 27, 2014

    Argentina has signed a new double tax treaty with Switzerland. The original accord was terminated in 2012, when Argentina also unilaterally terminated its treaties with Chile and Spain.

  • Big leap for European automatic information exchange after Austria and Luxembourg drop directive veto

    March 27, 2014

    After Luxembourg and Austria removed their longstanding veto to the move, the European Council this week strengthened EU rules on exchange of information on savings income, meaning member states will be better equipped to stamp out cases of tax fraud and tax evasion.

  • M&A and corporate taxpayers in light of the BEPS initiative: Part II

    March 27, 2014

    In part II of this article looking at M&A tax planning in light of recent BEPS developments, Napoleão Dagnese and Christoph Huber of OC Oerlikon analyse methods of allocating a global purchase price.

  • Debt/equity financing: Application of the Dutch participation exemption

    March 20, 2014

    Denis Pouw, partner at WTS Netherlands, analyses two recent rulings from the Dutch Supreme Court dealing with debt versus equity financing, and provides clarity on the applicability of the country’s participation exemption regime.

  • M&A and corporate taxpayers in light of the BEPS initiative

    March 20, 2014

    Tax planning in M&A transactions starts long before a transaction appears on the horizon and continues long after the deal is completed. Key challenges for the tax function are explored by Christoph Huber and Napoleão Dagnese of OC Oerlikon, a traditional Swiss multi-industries conglomerate with a footprint in 34 countries.

  • UK Budget: Welcome certainty for business as lobbying efforts pay off

    March 19, 2014

    Taxpayers craved certainty from the UK budget today and that is broadly what they got. George Osborne, the chancellor of the exchequer, even resisted the temptation to increase the bank levy, a regular measure in recent budgets, though the charge itself is set for a redesign.

  • Tax changes seek to boost Czech investment prospects

    March 18, 2014

    Changes to the Czech Republic's tax system, such as the possibility of selling securities tax free, are aimed at making the jurisdiction more attractive to foreign investors.

  • EXCLUSIVE: Pascal Saint-Amans defends OECD’s Common Reporting Standard despite loopholes identified by TJN

    March 13, 2014

    By shining a spotlight on loopholes and failing legislation, the Tax Justice Network has been at the fore of global tax policy development in recent years. In its latest report, it praises the OECD’s work on automatic information exchange, but identifies areas for improvement.

  • Australia’s Tax Institute puts pressure on Abbott to cut 30% tax rate

    March 12, 2014

    Australian businesses will see their tax burden fall if The Tax Institute gets its wish. The Institute has called on Australian Prime Minister Tony Abbott to cut the corporate tax rate to 25% in line with recommendations made in the Henry Review.

  • Cooperative compliance and enhanced relationships in Italy: Part II

    March 12, 2014

    In the second of a two-part series, Riccardo Petrelli and Simone Zucchetti of Tremonti Vitali Romagnoli Piccardi e Associati look at how existing regimes and pilots will influence the future of enhanced cooperation procedures in Italy.

  • UK Budget preview: Energy and banking sectors on alert

    March 12, 2014

    Next week’s UK Budget could bring good news for energy companies after the energy minister this week hinted at incoming tax relief measures, though it is unclear if intensive lobbying against the bank levy is going to pay off.

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