Thursday, September 15, 2016

Mind the gap- the arm's length principle and MNE value creation

Melissa Ogier is a visiting fellow who has ongoing collaboration with the TTPI.

Her recent paper focuses on an in-depth study of transfer pricing and multinational enterprises ...

DRAFT – Please do not quote without permission of the author

Mind the gap- the arm's length principle and MNE value creation 
Global Capitalism and Predatory Practices of Transnational Corporations in Developing Countries  by  Awwad Alnesafi,  Stephen Kasumba and Hamed A. Aldhuaina (12 Sep 2016)

Introduction of Stringent Transfer Pricing Documentation Requirement  

TRANSFER PRICING DOCUMENTATION  


 
Financial Times:
“The ATO clearly feels that the days of using a black letter law approach to tax planning are well and truly over and advisers should be more focused on the spirit of the law,” said Michael Croker, tax leader at the chartered accountants organisation.

Jason Casas, head of transfer pricing at Grant Thornton, said: “It is becoming clear that any attempt to set up any artificial or contrived structures to sidestep the new anti-avoidance law will only increase a company’s tax risk.”
Australia warns companies against trying to avoid its 'Google tax'  


Breaking Bad: What Does the First Major Tax Haven Leak Tell Us?
  While there is now significant literature in law, politics, economics, and other disciplines that examines tax havens, there is little information on what tax haven intermediaries — so-called offshore service providers such as trust, finance and other financial service providers — actually do to facilitate offshore tax evasion and other global financial crimes. To provide insight into this secret world of tax havens, this article relies on the author’s study of the first major tax haven data leak obtained by the International Consortium for Investigative Journalists. A hypothetical involving Breaking Bad’s Walter White is used to explain how offshore service providers help non-resident investors engage in offshore tax evasion.
 




 
Australia to extend money laundering laws  

‘Our new taskforce will tackle those who manipulate who manipulate the use of trusts to gain an unfair advantage,’ ATO Assistant Commissioner Tony Poulakis said.
Targeting Tax-Crime magazine 

Is Self Assessment Working?