By Aiofie White (Bloomberg BNA)
McDonald's Corp. shrugged off Brexit by announcing plans to switch its non-U.S. tax base to the U.K., ditching Luxembourg, where its fiscal arrangements are under attack from European Union regulators.
In an apparent vote of confidence in the U.K., the company said Dec. 8 it is creating a new international holding company based in Britain, which decided in June to quit the EU. The new company will be responsible for most of the royalties received from licensing McDonald's intellectual property rights outside the U.S. It will pay U.K. corporate tax, according to an e-mailed statement.
by William Hoke (Tax Notes)
Despite widespread outrage prompted by the disclosures in 2014 of the LuxLeaks tax rulings granted by Luxembourg authorities to multinational companies, the number of sweetheart deals entered into by the Grand Duchy and other European countries has increased by 160 percent from 2013 through 2015, a nongovernmental organization said in a report issued December 7.
by Joe Kirwin (Bloomberg BNA)European Union finance ministers have failed to agree on extending anti-tax avoidance rules to hybrid mismatches—the mismatch in tax outcomes due to different jurisdictional tax treatments—between member countries and foreign territories, amid disputes over financial sector exemptions and an implementation date.
by Vanessa Houlder (Financial Times)Overlooking white sands and turquoise water, One Cable Beach is the latest oceanfront condominium to be built on the sun-drenched coastline of the Bahamas. Yet its top selling point is not the natural beauty of its surroundings. Instead it is the financial privacy it offers investors trying to escape from a looming crackdown on tax evasion.
by Stephanie Soong Johnston (Tax Notes)The OECD has published additional guidance on country-by-country (CbC) reporting under action 13 2015 WTD 193-30: Consultation Documents and Responses of the base erosion and profit-shifting project, and it has published statistics for 2015 on the timeliness of completing mutual agreement procedure (MAP) cases as part of an effort to improve effectiveness of dispute resolution mechanisms under action 14.
by ITR Correspondent (International Tax Review)A bill of tax amendments submitted by the Executive Branch and approved by the Mexican Congress included changes to Article 5-I of the Value Added Tax Law (VAT Law), regarding the creditable VAT of fixed assets or expenses incurred in preoperative periods (i.e. before generating VAT income on its activities).
by Stephanie Bodoni (Bloomberg BNA)Apple Inc. and European Union competition watchdogs clashed on a public stage for the first time since regulators ordered Ireland to claw back a record-breaking 13 billion euros ($13.9 billion) in back taxes from the company.
by Mindy Herzfeld (Tax Notes)Many in the tax and business world are excited about the possibility that 2017 could bring meaningful tax reform based on the reform blueprint released by the U.S. House Ways and Means Committee in June. But the destination-based cash flow tax proposed by the Republican plan would be a major overhaul of the code -- far beyond even the Tax Reform Act of 1986. It is far from certain that such a radical change will be achievable.
by Joe Kirwin (Bloomberg BNA)European Union member countries are considering a “substance test” to determine whether a country or jurisdiction with a zero corporate tax rate qualifies as a tax haven that doesn’t reflect “real economic activity.”
by Joseph J. Schatz (POLITICO Pro)President-elect Donald Trump's plan for a corporate tax overhaul next year could bolster the European Union's efforts to reduce international avoidance through tax reform efforts of their own — but don't count on it.