The European Commission announced on August 30, 2016 that that Ireland granted undue tax benefits of up to €13 billion to Apple (http://europa.eu/rapid/press-release_IP-16-2923_en.htm). The Commission said this is illegal under EU state aid rules, because it allowed Apple to pay substantially less tax than other businesses. Ireland must now recover ... Read More
Category: International Tax Planning
26
Dec2016
The OECD has issued revised draft guidance on profit splits within multinational groups for transfer pricing purposes (BEPS Actions 8-10, Revised Guidance on Profit Splits July 4 – September 5, 2016). Israel joined the OECD in 2010.
Why is this important?
We live in a global village, but customers in each country ... Read More
December 26, 2016Leon Harris
26
Dec2016
Multinational groups, large and small, are now overhauling their international tax planning from top to bottom, due to BEPS, hopefully without getting into the Panama Papers.
What is BEPS?
On October 5, 2015 the OECD published a final comprehensive package of measures aimed at BEPS – Base Erosion Profit Shifting. Countries around ... Read More
December 26, 2016Leon Harris
21
Dec2016
Who sets the fiscal policy here? If you said the Finance Ministry, go to the back of the class. And if you said the Bank of Israel, take some extra classes. In practice, there is a new sheriff in town, in Israel and over 100 other countries…the OECD and its ... Read More
December 21, 2016Leon Harris
14
Dec2016
The Israeli tax Authority (ITA) and Swiss Finance Ministry signed on November 27 a declaration of intent regarding the exchange of information about financial accounts. The aim is to enhance cooperation regarding the supply of information, “egalitarian enforcement” of taxation in Israel, truthful tax payment and limit black money.
This is ... Read More
December 14, 2016Leon Harris
30
Sep2015
Leon Harris
It's been a long hot summer. Now it seems we are in for a warm winter taxwise, thanks to the OECD. Western governments asked the OECD to recommend ways of preventing offshore tax evasion committed by corporations and individuals. Over the last year the OECD has duly issued a ... Read More
September 30, 2015Leon Harris
30
Sep2015
Israel is not sufficiently proactive in detecting and investigating foreign bribery, with no prosecutions over the past 7 years, despite 14 allegations of foreign bribery involving Israeli individuals or companies. The OECD Working Group on Bribery is, however, encouraged by the recently-opened investigations, and will pay close attention to how ... Read More
September 30, 2015Leon Harris
30
Sep2015
Leon Harris
One of the things that spooks tax authorities the world over is that taxpayers may know more than they report. But tax authorities have a blunt weapon of retaliation – the ability to use hindsight when issuing tax assessments.
For example, suppose an Israeli pharmaceutical company discovers a new herb ... Read More
September 30, 2015Leon Harris
30
Sep2015
Leon Harris
Background
The OECD is spearheading a concerted effort to help governments around the world collect more taxes. The OECD is doing so by issuing a series of recommendations for tightening up corporate and personal tax measures. Individual governments are then likely to enact and/or implement such measures. Israel joined OECD ... Read More
September 30, 2015Leon Harris
30
Sep2015
Leon Harris
On February 6, the OECD announced that multinational groups with a turnover above EUR 750 million must start Country by Country reporting in their countries of residence in 2016. This simple procedural requirement is sending shock waves round the international business community.
Background
The OECD is spearheading a concerted effort to ... Read More
September 30, 2015Leon Harris