Managing editor | Anjana Haines |
---|---|
Categories | Law |
Frequency | Seven times a year |
Founded | 1989 |
Company | Euromoney Institutional Investor |
Country | UK |
Based in | London |
Language | English |
Website | internationaltaxreview |
ISSN | 0958-7594 |
ITR, previously known as International Tax Review, is a business-to-business publication focused on news analysis of tax policy and tax advice from around the world. This remit includes transfer pricing, corporate tax and indirect tax, particularly VAT and sales tax. [1] The magazine provides in-depth and strategic coverage of policy developments at the EU and the OECD, particularly the latter's BEPS project. [2]
International Tax Review was launched in London in November 1989 [3] [2] to cater to the tax services industry, publishing academic papers and covering court judgments on tax law. Over the years ITR has interviewed numerous politicians, including European commissioners Margrethe Vestager [4] and Pierre Moscovici, [5] as well as top tax professionals from companies such as Philip Morris, [6] Microsoft [7] and Johnson & Johnson. [8]
ITR follows the debate on tax avoidance, inequality and wealth distribution, often reporting on the Tax Justice Network and scandals like the Paradise Papers. In one case, ITR covered a debate at the OECD between low-tax advocate Arthur Laffer and tax campaigner Richard Murphy on the impact of tax competition, [9] whether it is possible to regulate tax competition [10] and what such a regulatory framework would look like. [11]
Since the early 2000s, ITR has regularly organised conferences like the Global Transfer Pricing Forum, [12] Women in Tax [13] and the Indirect Tax Forum. [14] At the same time, the magazine has published the World Tax Guide [15] in which it rates law and accounting firms. This includes firms like Deloitte, EY, PwC and KPMG. [16] [17]
ITR's awards program recognizes leading tax and transfer pricing firms. The group hosts three award ceremonies annually, recognizing the best work carried out in the Asia-Pacific, EMEA and Americas regions. [18] [19] In 2020, Deloitte was announced as the biggest winner across the Americas. [20] Caspian Legal Center from Azerbaijan, has been awarded as the Tax Firm of the Year in 2023 and 2024, and Transfer Pricing Firm of the Year in 2024 in the CIS region. [21]
ITR launched a sister publication called Transfer Pricing Week (later renamed TP Week) in 2007 to provide specialist coverage of international tax matters and policy, particularly issues like the arm’s length principle and controversies around EU state aid law. The publication ran until August 2019 when TP Week was wound up and the two platforms were merged into one.
As part of the Legal Media Group (LMG), ITR is published by Euromoney Institutional Investor, one of the biggest finance and business publishing companies in Europe. Euromoney is a FTSE 250 company and was owned by the Daily Mail and General Trust Group until it was spun-off in 2019. [22]
The Big Four are the four largest professional services networks in the world: Deloitte, EY, KPMG, and PwC. They are the four largest global accounting networks as measured by revenue. The four are often grouped because they are comparable in size relative to the rest of the market, both in terms of revenue and workforce; they are considered equal in their ability to provide a wide scope of professional services to their clients; and, among those looking to start a career in professional services, particularly accounting, they are considered equally attractive networks to work in, because of the frequency with which these firms engage with Fortune 500 companies.
Corporate haven, corporate tax haven, or multinational tax haven is used to describe a jurisdiction that multinational corporations find attractive for establishing subsidiaries or incorporation of regional or main company headquarters, mostly due to favourable tax regimes, and/or favourable secrecy laws, and/or favourable regulatory regimes.
A subsidy, subvention or government incentive is a type of government expenditure for individuals and households, as well as businesses with the aim of stabilizing the economy. It ensures that individuals and households are viable by having access to essential goods and services while giving businesses the opportunity to stay afloat and/or competitive. Subsidies not only promote long term economic stability but also help governments to respond to economic shocks during a recession or in response to unforeseen shocks, such as the COVID-19 pandemic.
Transfer pricing refers to the rules and methods for pricing transactions within and between enterprises under common ownership or control. Because of the potential for cross-border controlled transactions to distort taxable income, tax authorities in many countries can adjust intragroup transfer prices that differ from what would have been charged by unrelated enterprises dealing at arm’s length. The OECD and World Bank recommend intragroup pricing rules based on the arm’s-length principle, and 19 of the 20 members of the G20 have adopted similar measures through bilateral treaties and domestic legislation, regulations, or administrative practice. Countries with transfer pricing legislation generally follow the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations in most respects, although their rules can differ on some important details.
Deloitte Touche Tohmatsu Limited, commonly referred to as Deloitte, is a multinational professional services network based in London, England. Deloitte is the largest professional services network by revenue and number of employees in the world and is one of the Big Four accounting firms, along with EY, KPMG, and PwC.
Margrethe Vestager is a Danish politician currently serving as Executive Vice President of the European Commission for A Europe Fit for the Digital Age since December 2019 and European Commissioner for Competition since 2014. Vestager is a member of the Danish Social Liberal Party, and of the Alliance of Liberals and Democrats for Europe Party (ALDE) on the European level.
Ireland's Corporate Tax System is a central component of Ireland's economy. In 2016–17, foreign firms paid 80% of Irish corporate tax, employed 25% of the Irish labour force, and created 57% of Irish OECD non-farm value-add. As of 2017, 25 of the top 50 Irish firms were U.S.–controlled businesses, representing 70% of the revenue of the top 50 Irish firms. By 2018, Ireland had received the most U.S. § Corporate tax inversions in history, and Apple was over one–fifth of Irish GDP. Academics rank Ireland as the largest tax haven; larger than the Caribbean tax haven system.
Delinian is a British financial media company that has interests in business and financial publishing and event organisation.
Tax Analysts is a nonprofit publisher offering the Tax Notes portfolio of products, including weekly magazines featuring commentary, daily online journals featuring news and analysis, and research tools, all focused on tax policy and administration. Tax Analysts also promotes transparency in tax policymaking and holds regular conferences on key tax issues.
A tax haven is a term, often used pejoratively, to describe a place with very low tax rates for non-domiciled investors, even if the official rates may be higher.
An offshore financial centre (OFC) is defined as a "country or jurisdiction that provides financial services to nonresidents on a scale that is incommensurate with the size and the financing of its domestic economy."
The Double Irish arrangement was a base erosion and profit shifting (BEPS) corporate tax avoidance tool used mainly by United States multinationals since the late 1980s to avoid corporate taxation on non-U.S. profits. It was the largest tax avoidance tool in history. By 2010, it was shielding US$100 billion annually in US multinational foreign profits from taxation, and was the main tool by which US multinationals built up untaxed offshore reserves of US$1 trillion from 2004 to 2018. Traditionally, it was also used with the Dutch Sandwich BEPS tool; however, 2010 changes to tax laws in Ireland dispensed with this requirement.
A patent box is a special very low corporate tax regime used by several countries to incentivise research and development by taxing patent revenues differently from other commercial revenues. It is also known as intellectual property box regime, innovation box or IP box. Patent boxes have also been used as base erosion and profit shifting (BEPS) tools, to avoid corporate taxes.
Base erosion and profit shifting (BEPS) refers to corporate tax planning strategies used by multinationals to "shift" profits from higher-tax jurisdictions to lower-tax jurisdictions or no-tax locations where there is little or no economic activity, thus "eroding" the "tax-base" of the higher-tax jurisdictions using deductible payments such as interest or royalties. For the government, the tax base is a company's income or profit. Tax is levied as a percentage on this income/profit. When that income / profit is transferred to a tax haven, the tax base is eroded and the company does not pay taxes to the country that is generating the income. As a result, tax revenues are reduced and the country is disadvantaged. The Organisation for Economic Co-operation and Development (OECD) define BEPS strategies as "exploiting gaps and mismatches in tax rules". While some of the tactics are illegal, the majority are not. Because businesses that operate across borders can utilize BEPS to obtain a competitive edge over domestic businesses, it affects the righteousness and integrity of tax systems. Furthermore, it lessens deliberate compliance, when taxpayers notice multinationals legally avoiding corporate income taxes. Because developing nations rely more heavily on corporate income tax, they are disproportionately affected by BEPS.
Luxembourg Leaks is the name of a financial scandal revealed in November 2014 by a journalistic investigation conducted by the International Consortium of Investigative Journalists. It is based on confidential information about Luxembourg's tax rulings set up by PricewaterhouseCoopers from 2002 to 2010 to the benefits of its clients. This investigation resulted in making available to the public tax rulings for over three hundred multinational companies based in Luxembourg.
The OECD G20 Base Erosion and Profit Shifting Project is an OECD/G20 project to set up an international framework to combat tax avoidance by multinational enterprises ("MNEs") using base erosion and profit shifting tools. The project, led by the OECD's Committee on Fiscal Affairs, began in 2013 with OECD and G20 countries, in a context of financial crisis and tax affairs. Currently, after the BEPS report has been delivered in 2015, the project is now in its implementation phase, 116 countries are involved including a majority of developing countries. During two years, the package was developed by participating members on an equal footing, as well as widespread consultations with jurisdictions and stakeholders, including business, academics and civil society. And since 2016, the OECD/G20 Inclusive Framework on BEPS provides for its 140 members a platform to work on an equal footing to tackle BEPS, including through peer review of the BEPS minimum standards, and monitoring of implementation of the BEPS package as a whole.
Conduit OFC and sink OFC is an empirical quantitative method of classifying corporate tax havens, offshore financial centres (OFCs) and tax havens.
Apple's EU tax dispute refers to an investigation by the European Commission into tax arrangements between Apple and Ireland, which allowed the company to pay close to zero corporate tax over 10 years.
Ireland has been labelled as a tax haven or corporate tax haven in multiple financial reports, an allegation which the state has rejected in response. Ireland is on all academic "tax haven lists", including the § Leaders in tax haven research, and tax NGOs. Ireland does not meet the 1998 OECD definition of a tax haven, but no OECD member, including Switzerland, ever met this definition; only Trinidad & Tobago met it in 2017. Similarly, no EU–28 country is amongst the 64 listed in the 2017 EU tax haven blacklist and greylist. In September 2016, Brazil became the first G20 country to "blacklist" Ireland as a tax haven.
The global minimum corporate tax rate, or simply the global minimum tax, is a minimum rate of tax on corporate income internationally agreed upon and accepted by individual jurisdictions in the OECD/G20 Inclusive Framework. Each country would be eligible for a share of revenue generated by the tax. The aim is to reduce tax competition between countries and discourage multinational corporations (MNC) from profit shifting that avoids taxes.