International Tax News Blog

Archives: 2013

  • HMRC Tax Collection: Annual Report & Accounts 2012-13 - Public Accounts Committee

    by UK Parliament (PAC)

    In pursuing unpaid tax, HM Revenue & Customs (HMRC) has not clearly demonstrated that it is on the side of the majority of taxpayers who pay their taxes in full. It does not use the full range of sanctions at its disposal to pursue vigorously all unpaid tax, and its measure of the tax gap does not capture all the avoided tax that it should be collecting. HMRC massively over-estimated how much it would collect from UK holders of Swiss bank accounts, and in 2013-14 has so far collected only £440 million of the £3.12 billion predicted in the 2012 Autumn Statement. HMRC is not doing enough to collect tax credits debt or to tackle tax credit error and fraud.

    For the report, go here.

    By UK Parliament PAC, posted on Wednesday December 11, 2013
  • MPs accuse HMRC of being soft on big business

    by James Quinn (The Telegraph-UK)

    HM Revenue and Customs has been accused of failing to collect enough tax from big business and not using the powers at its disposal to do so by an influential committee of MPs.
    The Public Accounts Committee (PAC), chaired by Margaret Hodge, accused the tax man of “not clearly demonstrating that it [HMRC] is on the side of the majority of taxpayers who pay their taxes in full.”

    For the story, go here.

    By Quinn, James, posted on Thursday December 19, 2013
  • HMRC 'losing nerve' over tax affairs of multinationals but small businesses are targeted

    by London Evening Standard Correspondent

    A Parliamentary report has accused tax authorities of avoiding sanctioning major multinationals while pursuing small businesses and individuals.
    HM Revenue and Customs seems to "lose its nerve" when faced with the prospect of taking legal action against global giants, and has fallen short on the unpaid tax it hoped to extract from Swiss bank accounts - collecting just £440 million so far this financial year, rather than the £3.12 billion forecast after a bilateral agreement.

    For the story, go here.

    By Correspondent (London Evening Standard), posted on Thursday December 19, 2013
  • Morality versus legality in international taxation

    by ITR Correspondent

    Delivering an address on the morality versus legality debate at the Foundation for International Taxation’s December 5-7 conference in Mumbai, former Chief Justice of India SH Kapadia stated that in the Indian context, the discernible principles of law should prevail and not morality in a general sense.

    For the story, go here.

    By ITR Correspondent, posted on Monday December 16, 2013
  • EU 11 mull narrower FTT

    by Salman Shaheen - ITR

    The 11 EU member states looking to adopt a financial transaction tax (FTT) have discussed proposals for a narrower version of the tax to get it past stalled negotiations.

    For the story, go here.

    By Shaheen, Salman, posted on Tuesday December 17, 2013
  • Profit Shifting: U.S. Officials Urge Taxpayers to Comment On BEPS, Now in ‘Brainstorming' Phase

    by Dolores W. Gregory (Bloomberg)

    U.S. officials are urging taxpayers to provide detailed commentary on the Organization for Economic Cooperation and Development's action plan to combat base erosion and profit shifting (BEPS), particularly on the issue of hard-to-value transactions.
    Working Party No. 6 of the OECD, which is charged with addressing transfer pricing issues, is still in a “brainstorming phase” for BEPS, said Brian Jenn, attorney adviser in the Treasury Department's Office of the International Tax Counsel.

    For the story, go here. (subscription required)

    By Gregory, Dolores W., posted on Thursday December 12, 2013
  • Anti-Inversion Substantial Business Activity Regs to Be Finalized Next Plan Year

    by Andrew Velarde (Tax Analyats, tax Notes Today)

    Practitioners should not expect section 7874 anti-inversion regulations that provide guidance on substantial business activities to be finalized within the current business plan year, which ends June 30, but rather can expect finalization in the next business plan year, an IRS official said December 12.

    For the story, go here. (subscription required)

    By Velarde, Andrew, posted on Monday December 16, 2013
  • Treasury Official Previews FTC Guidance

    by Kristen A. Parillo (Tax Analysts, Tax Notes Today)

    The IRS and Treasury hope to release several guidance projects concerning foreign tax credits in 2014, according to acting Treasury Deputy International Tax Counsel Ginny Chung.

    For the story, go here. (subscription required)

    By Parillo, Kristen A., posted on Monday December 16, 2013
  • Tax Administration: IRS: Resource Issues Lead to Constraint On International Private Letter Rulings

    by Alison Bennett (Bloomberg)

    The Internal Revenue Service is “thinking more critically” about which requests for private letter rulings it will accept in the international area and the number it takes will likely be reduced, an agency official said.
    The IRS's Office of Associate Chief Counsel (International) is facing major resource constraints and will have to be more picky, Anne Devereaux, deputy associate chief counsel (international field service & litigation), said Dec. 13.

    For the story, go here. (subscription required)

    By Bennett, Alison, posted on Friday December 13, 2013
  • Back from the Dead: How to Revive Transfer Pricing Enforcement

    by Reuven S. Avi-Yonah - Univ. of Michigan Law School (Social cience Research Nwtwork)

    The OECD has recently come to recognize that the transfer pricing system does not work as intended. In its report on Base Erosion and Profit Shifting, the OECD recognizes that BEPS results in revenue losses that affect all states, especially poorer ones; that systematic tax avoidance by the richest and most powerful companies in the world undermines the general legitimacy of taxation; that it gives MNEs significant competitive advantages over purely domestic firms, resulting in inefficient allocations of investment and major distortions to economic activity; and that it skews the decisions of the MNEs themselves, resulting in overall economic welfare losses.

    This article will contrast three approaches to dealing with the BEPS problem: adopting a unitary taxation regime; ending deferral; and adopting anti base erosion measures. It concludes that while the first approach is the best long term option, the other two are more promising as immediate candidates for adoption in the context of US tax reform and the OECD BEPS project.

    For the paper, go here.

    By Avi-Yonah, Reuven S., posted on Wednesday December 4, 2013

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