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Internal Revenue

Europe, Australia , India want their fair share of tax

December 14, 2012 by Reporter Leave a Comment

The big American corporates are not safe anymore  with their complicated  tax structures  that let them pay minimum  tax . France and India ( vodafone case) have already started taking steps  to  amend  their country legislation to  make it harder  for  big corporates  to profit in their country without paying full tax.make money in their country while  small business and other countries  doe not get their fair share of  profits taken from their country.

UK and Australia  are currently are looking into the tax strategy known as the   Double Irish Dutch Sandwich ( The manoeuvre allows multinationals to move large amounts of money to other subsidiaries in the form of royalty payments )

dont tax me bro

Google chairman Eric Schmidt has defended the company’s tax policies, saying of the internet giant’s moves to get out of paying billions of dollars: “It’s called capitalism”.

Amazon, Google and Starbucks have been accused of an “immoral” use of secretive jurisdictions and complex company tax  structures to avoid paying tax on British profits by a committee of MPs.-http://www.guardian.co.uk

Europe and UK  hit hard with  the recession have also  amended tax laws and intend taking legal action  and more scrutiny of tax legislation  to  claw back more tax from these big American  company’s. The US itself is hurting with  it not getting much of the tax share  even though many of these top Tech companies are originally from  the US , but have their head offices in tax saving accounting havens with  the result of US also not benefitting much from the profits of these companies.

Apple Inc the tech company everyone knows paid an income tax rate of only 1.9 per cent on its earnings outside the US in its latest fiscal year reports Sbs.com.au

AMAZON

FRANCE has demanded $US252 million ($A242.72 million) in back taxes from Amazon, bringing into spotlight the online retailer over its controversial corporate structure in Europe.

The back taxes that the French are seeking from Amazon relate to earnings in France for the years 2006-10 and “the allocation of income between foreign jurisdictions”

Small, brick-and-mortar retailers have a legitimate gripe that Amazon’s avoidance of the sales tax gives it a competitive advantages

The guardian reports “ Amazon avoids UK taxes by reporting European sales through a Luxembourg-based unit. This structure allowed it to pay a rate of less than 12% on foreign profits last year – less than half the average corporate income tax rate in its major markets.”

Google.

 

Img from : http://www.watoday.com.au/business/how-savvy-multinationals-curb-their-tax-bills-20121116-29hhm.html

Starbucks

The Seattle-based coffee STARBUCKS company has 700 British outlets in UK , but has paid just STG8.6 million in corporation tax in 14 years. Starbucks Corp says this is due to a process involving paying royalties to its European headquarters in The Netherlands – perthnow.com

Amazon and Google confirmed that the companies both use favourable tax jurisdictions – Luxembourg and Ireland, respectively – due to their low taxation levels.

Google

The soul of Google’s (GOOG) international operations is a plush looking office building in  Dublin. In 2009 the office, which houses roughly 2,000 Google employees, was credited with 88 percent of the search Company’s $12.5 billion in sales outside the U.S. Most of the profits from various countries surprisingly went to the tax haven of Bermuda and not even the USA.

The Australian government using a combination of beefed up transfer pricing rules and a commitment to setting up a think tank that will review the elaborate tax structures, is making it  clear that Google, Apple, Amazon and any other e-commerce giants will need to pay more tax in the future if its doing business on its  shores.

Filed Under: 2012, TAX, Technology, UK, World Tagged With: Internal Revenue, International Law, World

Countries Scramble to get more slice of the pie

May 26, 2012 by Reporter Leave a Comment

Since the new “FATCA Rules”, OECD GUIDELINES and changes in the US internal revenue of service policies in relation to international taxation, several countries have started having a look at their own policies.

When times are uncertain  everyone tries to secure what they have  and prevent erosion of  existing wealth , and that’s what many countries are trying to do right now.

tightrope

Australia is now looking closer at tech company giants who are getting away with paying minimum tax in Australia as per media reports

Mr Turnbull told The Australian Financial Review he was consulting with chief executives of local media companies after the Australian division of global online search giant Google released accounts this month showing it paid only $74,176 in tax despite earning an estimated $1.1 billion in revenue in 2011.

The new cloud service delivery now being promoted by almost all big tech companies is only going to muddy the waters even more with transfer pricing and other tax issues relating to it, with many countries missing out in revenue.

So what is FATCA ?

After the FBAR (Foreign Bank Account Reporting)was released, the Foreign Account Tax Compliance Act (FATCA) introduces new, and largely parallel, reporting requirements. The FATCA reporting requirements carry their own set of penalties and are filed with the tax return rather than separately.

FATCA requires foreign financial institutions (FFI’s), to report information about accounts held by U.S. taxpayers directly to the IRS. This is a major compliance duty put on the Australian banks and borne by the Australian banks so that the US authorities can claim a piece of their pie. You can read more about FATCA here

The FATCA can impact on  several AUSTRALIAN Banks ,Savings and Loan Associations ,Credit unions, Co-operative banking institutions  and other financial institutions in australia

Transfer pricing to be scrutinised in australia

Cash-strapped governments around the world are targeting transfer pricing. Transfer pricing in short is defined as  the practice in which companies send profits overseas to subsidiaries in low-tax countries

The ATO has found 68 of Australia’s top 100 corporations in 2008 had a subsidiary in a tax haven, low-tax jurisdiction or bank secrecy country as per this media report.

Even in India recently the Vodafone case was high on the media reports internationally as  India looks to amend its tax laws after a defeat in this case resulting in a loss of millions of dollars to India

OECD AND ARMS LENGTH

Definition as per OECD :

This valuation principle is commonly applied to commercial and financial transactions between related companies. It says that transactions should be valued as if they had been carried out between unrelated parties, each acting in his own best interest.

The Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (ISBN Number:978926409003) provide guidance on the application of the “arm’s length principle” for the valuation, for tax purposes, of cross-border transactions between associated enterprises. (OECD BOOKS ON transfer pricing)

The British tax office is also under pressure to investigate Apple after it emerged the US-based technology giant paid £10 million in ­British tax in 2010 while generating an estimated £6 billion in revenue and Online retailer Amazon is reported for recording about £8 billion in revenue in Britain over three years without paying tax.

Canada also has cracked down on multinationals that dodge tax through inflating profits or losses in dealings with their related companies overseas

Even with  the deepening crisis in Europe , the EU are trying to impose carbon tax on International airlines using EU airports. The tax proposes to not only covers the flight through EU sky but through out the world. It is a scheme to impose ‘a sort of tax’ outside EU airspace  which has got the ire of some other countries

LINKS:

OECD AND AUSTRALIA

International Taxation: When the Transfer Pricing

Filed Under: 2012, Australia, Business, World Tagged With: FATCA, Internal Revenue, Multinationals, OECD, TAX, Tech Giants, Transfer Pricing

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