Below are just a few of the developments covered in Bloomberg BNA's international tax publications this week:
The European Commission says Ireland’s transfer pricing tax arrangements with Apple Inc. defy the arm’s-length principle established by the Organization for Economic Cooperation and Development, allowing Apple to shift profits and pay a tax rate less than other companies based in the country.
G20 finance ministers unanimously welcomed the release of the OECD’s Action Plan on Base Erosion and Profit Shifting, hailed as “the most prominent step towards modernization of the international tax system in 100 years.” The BEPS project has achieved exceptional coverage with the support of 44 countries, and has been widely praised for its global initiative to close tax loopholes across countries. For a quick tour of the deliverables released, see our previous blog post here.
Despite the U.S. Treasury Department’s attempts to curb corporate inversions, Burger King Worldwide Inc. is going ahead as planned to buy Canada’s Tim Hortons Inc. in a merger supposedly driven by long term growth and not tax benefits. President Obama has accused companies in similar deals of “gaming the system,” and Treasury is moving to block the use of exploitative tax arrangements involving intracompany “hopscotch” loans, spin-offs and earnings stripping practices. For more insight into the inversions debate, see our previous blog post here.
Swiss bank UBS AG has lost its fight appealing a 1.1 billion euro ($1.4 billion) bail order for money laundering charges linked to tax evasion, stating that it was “very disappointed at the decision” of what it calls a “highly politicized process.” French investigators have also been looking into HSBC Holdings Plc. to determine whether its units encouraged tax evasion practices.
Israel approved a deal with American chip maker Intel Corp. offering unprecedented tax breaks for the company and a five-year benefits package worth $300 million in return for Intel’s $6 billion commitment to upgrade its factory based in Kiryat Gat. The investment will be a “strategic asset” according to Finance Minister Yair Lapid, having beaten Ireland in winning over the technology company to continue its operations in Israel.
For more information on these developments and other international tax news, sign up for a free trial of the Premier International Tax Library.
Vanessa Yu, Editor
All Bloomberg BNA treatises are available on standing order, which ensures you will always receive the most current edition of the book or supplement of the title you have ordered from Bloomberg BNA’s book division. As soon as a new supplement or edition is published (usually annually) for a title you’ve previously purchased and requested to be placed on standing order, we’ll ship it to you to review for 30 days without any obligation. During this period, you can either (a) honor the invoice and receive a 5% discount (in addition to any other discounts you may qualify for) off the then-current price of the update, plus shipping and handling or (b) return the book(s), in which case, your invoice will be cancelled upon receipt of the book(s). Call us for a prepaid UPS label for your return. It’s as simple and easy as that. Most importantly, standing orders mean you will never have to worry about the timeliness of the information you’re relying on. And, you may discontinue standing orders at any time by contacting us at 1.800.960.1220 or by sending an email to email@example.com.
Put me on standing order at a 5% discount off list price of all future updates, in addition to any other discounts I may quality for. (Returnable within 30 days.)
Notify me when updates are available (No standing order will be created).
This Bloomberg BNA report is available on standing order, which ensures you will all receive the latest edition. This report is updated annually and we will send you the latest edition once it has been published. By signing up for standing order you will never have to worry about the timeliness of the information you need. And, you may discontinue standing orders at any time by contacting us at 1.800.372.1033, option 5, or by sending us an email to firstname.lastname@example.org.
Put me on standing order
Notify me when new releases are available (no standing order will be created)