In September, 2016, we discussed that the European Commission’s probe into Apple, which resulted in an order for the tech giant to pay up to €13 billion ($14.5 billion) in back taxes to Ireland, was prompted by a U.S. Senate investigation, European Union Competition Commissioner Margrethe Vestager said on Friday.
Tag Archive for OECD
As I hear it, if the Netherlands were to substantively amend its ‘maximum 20% bonus of salary’ regulation, then the relocation decision for many EU facing funds would be an easy choice. But because of that regulation, it has created an opportunity for other cities to pitch to the institutions for the funds and trading business relocation.
Speaking at a April 28,2016 transfer pricing symposium held by the University of San Diego School of Law, Robert Stack, US Treasury Deputy Assistant Secretary (International Tax Affairs) addressed the “gap-year” issue arising from the implementation of CbC reporting in some jurisdictions for tax years beginning on or after 1 Read more
We previously posted, Get Ready For The US Proposed Plan to Require Banks to Identify Owners of Shell Companies! where we discussed that the United States government is close to issuing a rule that will for the first time require banks and other financial institutions to find out the identities of people hidden behind shell companies.
The rule is meant to close a major loophole in the American Read more
On April 12, 2016 the European Commission presented a proposal that would require all large Multinational Enterprises with operations in the European Union to Publicly Disclose certain tax-related information for all their entities in the EU and in designated tax havens on a country-by-country (CbC) basis.
The European Commission has indicated that it will establish a common EU list of tax haven jurisdictions as soon as possible. Read more
On April 4, 2016 we posted Huge Leak From the Panamanian Law Firm Mossack Fonseca! where we discussed that, the offshore planning world was set on fire with the news that 11 million documents were leaked from the Panamanian law firm Mossack Fonseca.
They showed how Mossack Fonseca has helped clients launder money, dodge sanctions and evade tax. The company says it has Read more
Government officials from around the world have called on the OECD to convene a special project meeting of the Joint International Tax Shelter Information and Collaboration (JITSIC) Network to explore possibilities of co-operation and information-sharing, identify tax compliance risks and agree collaborative action, in light of the “Panama Papers” revelations.
Commentary on the The Panama Papers & The Disclosure of 14,000 Clients’ 214,000 Offshore Companies Files and Assets
A leak of searchable 11.5 million files, that’s 2.6 terabytes of data, from the embattled offshore services provider Mossack Fonseca. Every email, client note, asset and income statement, instruction, communication, .. since 1977! 2.6 terabytes of data, 11.5 million files, is a lot of files and scanned documents to comb through, so this leak is potentially, and probably, more significant than the 2014 ICIJ reported on leak or even the HSBC and UBS’ leaks. Read more
Transfer pricing methodologies are beginning to spread far beyond the narrow confines of section 482. Consider two very recent examples:
• Argentina had enacted revenue raising measures designed to penalize companies that would shift profits from Argentina to a tax haven. Argentina used an OECD BEPS transfer pricing rationale in enacting these anti-tax-haven provisions. Most Argentinian enterprises that make use of tax havens use Panama for that tax haven purpose, in part because of the commonality of language. Panama sued Argentina, arguing that the Argentinian tax restrictions are an artificial trade constraint. Panama brought suit at the World Trade Organization (WTO). Other countries are now involved. Panama won the initial round at the WTO, but Panama has joined the OECD’s Global Forum, a measure that would ultimately bring the country into compliance with the OECD’s Transfer Pricing Guidelines. Panama’s attack is similar to the attack on DISC before GATT three decades ago
The OECD in October released its final recommendations under its project to combat tax base erosion and profit shifting, which included a plan for having companies file reports in their home jurisdictions detailing their business activities such as taxes accrued, profits and number of employees.
The IRS has now proposed rules requiring large companies to report information for each country of operation including the amount of revenue, profit or loss, capital and accumulated earnings, consistent with OECD recommendations designed to combat base erosion and profit shifting. The rules (REG-109822-15) would apply to U.S. parent companies with at least $850 million in annual revenue for the preceding annual accounting period, for the taxable year beginning on or after the rules are made final, ensuring that, for most companies, they won’t take effect before Jan. 1, 2017.
The proposed regulations affect U.S. persons that are the parent of a MultiNational Enterprise (MNE) group, with annual revenue for the preceding annual accounting period of $850 million or more. Read more
The OECD will release the final package of measures for a coordinated international approach to reform the international tax system under the OECD/G20 Base Erosion and Profit Shifting (BEPS) strategy to tackle tax avoidance by multinational companies on Monday October 5, 2015.
The final outcomes of the BEPS Project will be presented by Pascal Saint-Amans, Director of the OECD Centre for Tax Policy and Administration, during a webcast news conference at 2:00 p.m. (CET).
A technical briefing via webcast on the BEPS deliverables will follow, at 4:00 p.m. (CET).
The OECD/G20 BEPS Project provides governments with clear international solutions to Read more