Author: TP News

EU directive on minimum effective tax rate – implementation of OECD Pillar II

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The European Commission has proposed a Directive ensuring a minimum effective tax rate for the global activities of large multinational groups. The proposal delivers on the EU’s pledge to move extremely swiftly and be among the first to implement the recent historic global tax reform agreement, which aims to bring fairness, transparency and stability to the international corporate tax framework. The proposed directive follows closely the international agreement and sets out how the principles of […]

ResMed Inc has entered a $381.7 million tax settlement agreement with the Australian Tax Office

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ResMed – a world-leading digital health company – in an October 2021 publication of results for the first quarter of FY 2022, informs that a $381.7 million tax settlement agreement has been entered with the Australian Tax Office. The dispute concerns the years 2009 through 2018, in which the ATO alleged that ResMed should have paid additional Australian taxes on income derived from the company’s Singapore operations. Excerpts from the announcement “Operating cash flow for […]

Pandora Papers – a new leak of financial records

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A new huge leak of financial records revealed by ICIJ, once again shows widespread use of offshore accounts, shell companies and trusts to hide wealth and/or avoid taxes. The new leak is known as the Pandora Papers and follows other recent leaks – lux leak, panama papers, paradise papers. The International Consortium of Investigative Journalists obtained 11.9 million confidential documents from 14 separate legal and financial services firms, which the group said offered “a sweeping […]

ATO and Singtel in Court over Intra-company Financing Arrangement

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In 2001, Singtel, through its wholly owned Australian subsidiary, Singapore Telecom Australia Investments Pty Limited (Singtel Au), acquired the majority of the shares in Cable & Wireless Optus for $17.2 billion. The tax consequences of this acqusition was decided by the Federal Court in Cable & Wireless Australia & Pacific Holding BV (in liquiatie) v Commissioner of Taxation [2017] FCAFC 71. Cable & Wireless argued that part of the price paid under a share buy-back […]

Perrigo has settled its €1.6 billion tax bill with the Irish Revenue for €297 million

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Pharmaceutical group Perrigo has settled a €1.6 billion case with the Irish Revenue Commissioners for €297 million. Perrigo was issued a tax assessment in 2018. The assessment related to Perrigo’s tax treatment of income generated by the sale of the rights to Tysabri – a drug for the treatement of multiple sclerosis. The tax authorities held that proceeds form the sale of these rights – more than $ billion – was a capital transaction taxed […]

OECD releases statement on support of the two pillar tax plan – joined by 130 countries

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A OECD statement has been issued where 130 countries and jurisdictions have agreed to join and support the two pillar plan. A small group of 9 countries have not yet joined the Statement. “The two-pillar package aims to ensure that large Multinational Enterprises (MNEs) pay tax where they operate and earn profits, while adding much-needed certainty and stability to the international tax system. Pillar One will ensure a fairer distribution of profits and taxing rights […]

G7 Support for OECD’s proposal on a Global Tax Reform – Pillar I and II

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The G7 has agreed to back an international agreement on global tax reforms aimed at ending the reign of tax havens and have big international companies start paying their fair share of taxes. Under Pillar One of the reform, multinationals will be required to pay tax in the countries where they sell there products – and not just where they have their headquarters. The rules would apply to largest global firms with at least a […]

US Senate Committee request records related to tax schemes involving Caterpillar and Renaissance Technologies

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In a letter dated 28. April 2021 the US Senate Committee on Finance has request records related to tax schemes involving Caterpillar and Renaissance Technologies. “In 2015, Caterpillar disclosed that a federal grand jury in Illinois had begun investigating an alleged tax scheme involving the company’s Swiss subsidiary. This investigation led to raids by federal agents on three different Caterpillar offices in March 2017. 4 Days after the raids, Caterpillar announced it retained Mr. Barr […]

UN releases New 2021 Practical Manual on Transfer Pricing

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On 27 February 2021 UN released a new 2021 Practical Manual on Transfer Pricing. “…this third edition of the Manual makes improvements in usability and practical relevance, updates and improves the existing text, including on Country Practices (Part D) and has new content, in particular, on financial transactions, profit splits, centralized procurement functions and comparability issues. Improved capacity development based on the Manual has encouraged and contextualized developing country feedback, helped identify these priority areas […]

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