Bermuda–MNE Tax

Americas

OECD unveils stage 2 peer review assessments under BEPS Action 14 regarding mutual agreement procedure (MAP) for Andorra, Bahamas, Bermuda, British Virgin Islands, Cayman Islands, Faroe Islands, Macau, Morocco and Tunisia: OECD→

April 14, 2022

Americas

US Senate Finance Chair looking into pharma international tax abuse

January 19, 2022

Pharmaceutical industry tax practices involving the use of offshore subsidiaries to avoid paying US taxes are the target of an investigation by US Senate Finance Committee Chair Ron Wyden (D-Ore.), who requested information from Bristol Myers Squibb on January 18; this latest information request follows a similar letter sent to . . .

Americas

White House’s hopes of an international tax revenue windfall may be overblown

October 29, 2021

Alex M. Parker, Capitol Counsel LLC, discusses how, without the political support for raising tax rates, Democrats are looking to an overhaul of the international tax system to help pay for the USD 1.75 trillion spending package; but some recent estimates say . . .

Americas

Bermuda’s tax advantage in (re)insurance industry will diminish under global minimum tax, which will reduce, but not eliminate, gap in effective tax rate between Bermuda and non-Bermuda companies: Fitch Ratings→

October 20, 2021

Americas

European banks’ tax haven use persists but varies widely, study finds

September 7, 2021

Large European banks report an average of 20% of their profits in tax havens, but some report more than half of their profits in such jurisdictions while others report none, according to a September 6 report from the EU Tax Observatory . . .

Africa

Profit shifting persists as corporate tax rates drop 30% in 20 years, OECD study finds

July 29, 2021

The OECD’s annual “Corporate Tax Statistics,” released July 29, reports that the statutory corporate income tax rate in 111 reviewed jurisdictions declined from an average of 28.3% in 2000 to . . .

Americas

Nike’s transfer pricing state aid dispute: the underlying issues

July 19, 2021

New York City Economist Dr. J. Harold McClure analyzes the issues underlying the transfer pricing dispute involving Nike, following the General Court of the European Union’s July 14 ruling declining to annul the European Commission’s state aid investigation regarding . . .

Americas

Danish High Court rules on beneficial ownership of dividends for tax purposes

May 5, 2021

Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, discusses a highly-anticipated High Court of Eastern Denmark ruling issued May 3 that resolves two tax disputes concerning beneficial ownership . . .

Americas

Switzerland rejects Biden’s tax haven claim: swissinfo.ch→

May 3, 2021

Americas

Bermuda leaders chafe at Biden’s tax haven label: Scott Neill / The Royal Gazette→

May 3, 2021

Americas

Google UK reports its 2020 financials: the transfer pricing implications

April 28, 2021

Dr. J. Harold McClure, New York City, discusses the transfer pricing implications of Google UK’s 2020 financial report . . .

Americas

MNEs shifted USD 1 trillion in profits offshore to tax havens, ICIJ study says: Scilla Alecci / International Consortium of Investigative Journalists→

April 5, 2021

Americas

Tax havens begin sharing information about entities that earn income from IP, other mobile activities

March 31, 2021

Twelve tax haven countries, for the first time, provided information about the activities of some business entities located in their countries to the countries where the entities’ parents or beneficial owners are tax residents, the OCED today announced. Anguilla, the Bahamas . . .

Asia-Pacific

US multinationals tax payments halved, investment and revenues boosted following 2017 tax overhaul, JCT report finds

March 24, 2021

US MNEs paid substantially lower corporate taxes following the 2017 Tax Cut and Jobs Act, both domestically and globally, a March 19 report from the US congressional Joint Committee on Taxation concludes. . .

Americas

Bermuda lists jurisdictions treated as reportable jurisdictions for country-by-country reporting: Bermuda Ministry of Finance, Treaty Unit→

February 8, 2021

Africa

Using US IRS data, authors conclude that Bermuda, Ireland, Netherlands are US MNEs’ most important tax havens: Petr Janský, Javier Garcia-Bernando, Thomas Tørsløv /Springer→

January 5, 2021

Americas

Pillar 2 is a big threat to Bermuda re/insurers, trade group rep says: Intelligent Insurer→

September 14, 2020

Africa

OECD reports assess cross-border tax dispute resolution in Andorra, Bahamas, Bermuda, BVI, Cayman Islands, Faroe Islands, Macau, Morocco, Tunisia

July 30, 2020

The OECD on July 27 published reports approved by a group of 135+ countries known as the “Inclusive Framework on BEPS” that assess . . .

Africa

EU blacklist: Cayman Islands added with other three jurisdictions

February 18, 2020

Davide Anghileri, a researcher at the University of Lausanne, writes that during today’s meeting, the EU Council added four countries to the EU list of non-cooperative jurisdictions for tax purposes and removed 16 countries from the gray list . . .

Americas

Unanimity not required to update global rules for taxing multinational groups, OECD’s Saint-Amans says

October 18, 2019

The OECD’s “pillar one” proposal to update the global rules for allocating multinational group profit and related taxing rights can be implemented even if . . .

American Samoa

Netherlands government publishes revised draft list of low tax jurisdictions

October 8, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper, Amsterdam, discuss the Dutch government’s October 7 release of a draft list of low tax jurisdictions which makes four changes from the previous list. . . .

Americas

Uber generated $6.1 b Dutch tax deduction by transferring IP with increased value from a Bermuda sub to Dutch sub controlled by Singapore company: Lynnley Browning & Eric Newcomer / Bloomberg→

August 12, 2019

Africa

CIAT database reflects progress made by 15 countries implementing BEPS recommendations

August 9, 2019

In an August 8 update, the Inter-American Center of Tax Administrations (CIAT) has reported on 15 member countries’ progress adopting . . .

BVI, Bermuda, Cayman top tax haven list; UAE, UK, France most aggressive in lowering other countries withholding tax via treaty: Tax Justice Network→

May 29, 2019

American Samoa

EU Council revises tax blacklist, plans less frequent list updates

May 17, 2019

Davide Anghileri of the University of Lausanne discusses today’s decisions by the EU Council regarding the EU list of non-cooperative tax jurisdictions . . .

Americas

Tax laws of 12 low-tax countries including BVI, Bermuda, Cayman don’t harm other countries, 131-country group concludes

July 23, 2019

An OECD-led 131-country coalition, known as the “Inclusive Framework on BEPS,” has approved. . .

Americas

Bermuda, Aruba, Barbados set to be removed from EU tax blacklist, EU official says: Reuters→

May 13, 2019

Africa

OECD seeks input on tax dispute resolution in Andorra, Anguilla, Bahamas, Bermuda, BVI, Cayman, Faroe Islands, Macau, Morocco, Tunisia

July 17, 2019

The OECD on July 5 requested taxpayer feedback on the tax treaty dispute . . .

Africa

New CIAT database tracks BEPS implementation in 36 countries

February 22, 2019

The Inter-American Center of Tax Administrations (CIAT) on February 21 released . . .

Americas

Google shifted USD 23 billion income to tax haven Bermuda in 2017 using Dutch shell company: Reuters→

January 4, 2019

Americas

Bermuda likely to be removed from EU list of non-cooperative jurisdictions, finance minister says: Government of Bermuda→

April 9, 2019

Americas

Tax reform’s BEAT hits US MNE’s Bermuda reinsurance affiliates driving M&A activity: Bethan Moorcraft / Insurance Business→

September 10, 2018

Switzerland consults on introducing automatic exchange of tax information with 22 countries

December 1, 2016

The Swiss government has today announced a consultation on commencing automatic exchange of information in tax matters with 22 countries, writes Davide Anghileri, a lecturer at the University of Lausanne . . .

American Samoa

Netherlands publishes tax ‘blacklist’ for CFC rules

January 8, 2019

Jian-Cheng Ku, Robin Theuns, and Rhys Bane of DLA Piper Nederland N.V., discuss the Dutch Ministry of Finance’s blacklist of low tax jurisdictions for controlled foreign company purposes. published December 28, 2018 . . .

Americas

Bermuda, France to exchange country-by-country reports on multinationals

September 22, 2017

Bermuda and France will exchange country-by-country reports on multinational businesses, Bermuda’s Premier and Minister of Finance David Burt announced today. Speaking before . . .

Americas

US signs CAA agreements with Bermuda, Jersey for exchange of country-by-country tax reports

December 8, 2017

The US government has announced that it has reached competent authority agreements (CAAs) with Bermuda and Jersey to annually exchange country-by-country reports on the tax affairs of large multinational . . .

Americas

Bermuda signs agreement for exchange of country-by-country tax reports

April 20, 2016

Bermuda has become the 33rd signatory to a multilateral agreement setting out the parameters for the automatic exchange between tax administrations. . . .

Americas

Google avoided $3.6 billion tax in 2015 via ‘Dutch Sandwich’ structure: Jeremy Kahn & Martijn Van Der Starre / Bloomberg→

January 3, 2017

See: Bloomberg.

Americas

Bermuda updates country-by-country reporting guidance for large MNEs

August 10, 2018

Bermuda’s government has released an updated version of its guidance notes for large multinationals on country-by-country reporting. The guidance . . .

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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