The appeal court in Paris has confirmed that the Swiss UBS banking group is guilty of having facilitated tax evasion and money laundering in France, and on that basis the banking group was issued a €5,625 million fine plus confiscation of €1 billion and damages in the sum of €800 millions.
Swiss UBS bank to pay € 1,8 billion fine for “facilitation of tax evasion and money laundering”
Category: Transfer Pricing News | Tag: Facilitating, Money laundering, Switzerland, Tax advisor liability, Tax evasion, UBS
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- TPG2022 Chapter VIII Annex example 1 1. Example 1 illustrates the general principle that contributions should be assessed at value (i.e. based on arm’s length prices) in order to produce results that are consistent with the arm’s length 2. Company A and Company B are members of an MNE group and decide to enter into a...
- TPG2022 Chapter V paragraph 5.52 There would be an exemption from the general filing requirement for MNE groups with annual consolidated group revenue in the immediately preceding fiscal year of less than EUR 750 million or a near equivalent amount in domestic currency as of January 2015. Thus, for example, if an MNE that keeps...
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- TPG2022 Chapter VI Annex I example 6 14. In Year 1, a multinational group comprised of Company A (a country A corporation) and Company B (a country B corporation) decides to develop an intangible, which is anticipated to be highly profitable based on Company B’s existing intangibles, its track record and its experienced research and development staff....
- TPG2022 Chapter VIII Annex example 4 17. Company A and Company B are members of an MNE group and decide to undertake the development of an intangible through a CCA. The intangible is anticipated to be highly profitable based on Company B’s existing intangibles, its track record and its experienced research and development staff. Company A...
- TPG2022 Chapter II paragraph 2.47 Following the principles in Chapter I, an uncontrolled transaction is comparable to a controlled transaction (i.e. it is a comparable uncontrolled transaction) for purposes of the cost plus method if one of two conditions is met: a) none of the differences (if any) between the transactions being compared or between...
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- TPG2022 Chapter VIII paragraph 8.38 In the example in paragraph 8.33, the participants, Companies A and B, expect to benefit from the CCA in the ratio 75:25. In the first year the value of their pre-existing contributions is 10 million for Company A and 6 million for Company B. As a result, a net balancing...
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- TPG2022 Chapter VI Annex I example 28 101. Company A is the Parent company of an MNE group with operations in country S. Company B is a member of the MNE group with operations in country T, and Company C is also a member of the MNE group with operations in country U. For valid business reasons...