Where do I hold my company?

Article Abstract:

British multinational corporations can achieve tax efficiencies by retaining or forming intermediate holding companies. This strategy appears to go against the trend among multinationals of streamlining corporate structures and management reporting since it adds another layer of bureaucracy without generating visible benefits for the company. However, the peculiarities of the UK's double tax relief system make intermediate holding companies an important global tax planning tool for British multinationals. British tax laws enable international business enterprises to gain tax efficiencies, such as tax-advantageous repatriation of overseas profits, tax deferral and the potential to deploy overseas profits, through the use of offshore intermediate holding companies benefiting from a favorable tax regime.

Tax Management, United Kingdom, Tax accounting, Holding companies, Tax policy, Foreign source income taxation, Controlled foreign corporations

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Global warming

Article Abstract:

The tax implications of transfer pricing are drawing increasing attention all over the world. Revenue authorities worldwide, particularly the US IRS, are taking steps to make sure that they are getting paid the right amount of tax by multinational companies. In response to this development, the Organization for Economic Cooperation and Development (OECD) is making radical changes to its guidelines on transfer pricing. The organization continues to recommend the 'arm's length' pricing principle and three methods for determining an arm's length price. These are the comparable uncontrolled price method, the resale price method and the cost plus method. In its new guidelines, the OECD introduces transactional net margin as another acceptable pricing method.

Standards, Transfer pricing

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ICC slams transborder tax proposals

Article Abstract:

The Council of Europe and the Organization for Economic Cooperation and Development (OECD) have jointly prepared the "Draft Multilateral Convention on Mutual Administrative Assistance in Tax Matters," designed to limit opportunities for tax evasion on the part of multinational corporations. The International Chamber of Commerce is opposed to the proposed tax rules, since it believes their provisions will restrict multinational development and discourage firms from entering new markets internationally. The rules, as drafted, would facilitate national taxation authorities' cooperation in assessing tax for companies operating in more than one country, and are scheduled for approval by the 24 OECD member nations in November 1986.

Europe, Laws, regulations and rules, International aspects, Tax administration and procedure, Tax administration, Economic policy, Tax evasion, Council of Europe, International Chamber of Commerce

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