Author: ONF

Switzerland: Total Return Swaps – Swiss Federal Supreme Court Sides With Federal Tax Authority (FTA) By Denying Reimbursement Of WHT

On 5 May 2015 the Federal Supreme Court rendered its long awaited decision on a withholding tax (WHT) reimbursement claim related to Total Return Swaps. The case was based on essentially the following facts: a Danish bank entered into swap contracts with clients in England, Germany, France and the US…. – Continue reading

MEPs voice support for whistleblowers

Investigative reporter suggest financial rewards for tax whistleblowers “Whistleblowers should receive protection when they reveal behavior that goes against the public interest and not only when they reveal illegal activities. There should also be more openness about tax rulings and similar arrangements and countries which defraud other countries should be… – Continue reading

KPMG Responds To Hockey’s Tax ‘Integrity’ Measures

Grant Wardell-Johnson, KPMG Tax Partner, has said that while it would have been better for Australia to await the outcome of the OECD’s base erosion and profit shifting Action Plan, the international tax measures proposed recently by Treasurer Joe Hockey “have the benefit of being highly targeted.” On May 11,… – Continue reading

Online tax laws holding SA companies back

South African companies are unable to compete with multinationals selling goods and services online in the country, partly as a result of tax laws. This is according to financial services group PwC, which argues that the country has not kept pace with the changing global economy. “Currently, multinationals in the… – Continue reading

Switzerland: Switzerland’s Practice Of Information Exchange Regarding Stolen Data

Introduction The Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) decided in mid-March 2015 that Switzerland should enter Phase 2 of the Peer Review. This decision represents a clear statement by the OECD that Switzerland’s legal and regulatory framework for information exchange complies with internationally… – Continue reading

UK: Finance Act 2015 – Avoidance Using Carried-Forward Losses

Tax analysis: Catherine Richardson, associate at Cadwalader, Wickersham & Taft LLP, examines the aspects of the Finance Act 2015 (FA 2015) which concern targeting avoidance using carried-forward losses. What is the target for the new rule countering tax avoidance involving carried-forward losses? Where losses for tax purposes arise within a… – Continue reading

MEPs’ Luxleaks probe risks falling apart

A special European Parliament committee to probe tax avoidance schemes is facing mounting obstacles to its work. The problems, which include access to documents, administrative delays, and internal disagreements risk undermining the MEP’s investigation into how government-backed tax rulings allow multinationals, in some cases, to pay less than 1 percent… – Continue reading

OECD nations gang up on internet retailers, tax dodgers

Australia to fine tech tax-dodgers 100% of their avoided tax, plus profits Australia’s treasurer* Joe Hockey has revealed that he and other money ministers from the Organisation for Economic Co-operation and Development (OECD) have shared plans to have online retailers charging the appropriate consumption tax on intangibles and goods bought… – Continue reading

Tories aim to raise extra £5bn a year in tax avoidance clampdown

The Conservatives are set to press on with efforts to counter tax avoidance and evasion, with measures on the way including the exchange of information with foreign tax authorities, reports the Financial Times. All the major parties pledged in the election campaign to raise billions more each year from individuals… – Continue reading

Monsanto-Syngenta Could Be a Tax Inversion Under Current Rules

(Bloomberg) — Monsanto Co.’s potential acquisition of rival agricultural-chemical maker Syngenta AG could be structured as a tax inversion under current U.S. rules despite political resistance to such deals, according to an analysis by Bloomberg Intelligence. Switzerland’s Syngenta last week rejected St. Louis-based Monsanto’s $45 billion takeover offer. Monsanto, the… – Continue reading

Global news briefs from the Economist

Global business The European Union outlined its strategy to create a digital single market. The thrust of the proposals include establishing standard rules for buying goods online, pruning cross-border regulations on telecoms and reducing the tax burden on businesses. But the plan also calls for a “comprehensive assessment” of whether… – Continue reading

Australia to crack down on alleged tax avoidance by 30 multinationals

The Australian government announced a world-leading crackdown on Monday on alleged tax avoidance by 30 multinational companies that will likely force them to restructure their businesses before next year, reports Reuters. “These companies are diverting profits earned in Australia away from Australia to no-tax or low-tax jurisdictions,” Treasurer Joe Hockey… – Continue reading

Fatca special report

Changing Requirements and Changing Methods As the first year of the US Foreign Account Tax Compliance Act (Fatca) being in effect is almost complete, the rules for reporting still appear to be in flux, as are the ways firms are responding to Fatca compliance and setting out methods to address… – Continue reading

Bancolombia Adds AxiomSL FATCA Solution to Reporting Platform

Ease of integration and flexibility of strategic reporting platform drive Colombia’s largest bank to expand partnership Tax reporting solution now deployed in five countries as a result of agreement AxiomSL, a leading provider of regulatory reporting and risk management solutions to the financial services industry, announced today that Bancolombia, Colombia’s… – Continue reading

Lexmark Considered Inversion Before Kofax Deal

Lexmark International Inc. considered moving its headquarters overseas to save money on taxes earlier this year, according to chief financial officer David Reeder. But the printing company decided to stay in its Lexington, Ky. home, after spending the bulk of its offshore cash to buy software developer Kofax Ltd.s

No shock and awe, just a sedate affair

AUSTRALIANS hoping to gorge on offerings intended to stimulate the economy in Tuesday’s Federal Budget have been warned to prepare for lukewarm but at least digestible fare. Though the electorate’s appetite has been whet by the sizzling entree of another Reserve Bank rate cut this week, economists expect the main… – Continue reading

Sebi cracks down on Rs 420-cr tax fraud, bars 178 entities

After finding them guilty of manipulation in the stock market for making illegal gains, Sebi has restrained the 178 entities, including Pine Animation, from accessing the securities market. In a fresh clampdown on misuse of stock market platform for suspected money laundering activity, Sebi today banned Pine Animation and 177… – Continue reading

On stashed cash: State could impose 10% tax on remittances

ISLAMABAD: As authorities struggle to increase tax collection, the state is considering a proposal that could see a levy of 10% tax on profit made on foreign remittances placed in savings accounts. The proposal comes as the government suspects that the amount sent through remittances could be black money being… – Continue reading

British property tax system now the most ‘complex’ in the world, says PwC

Analysts at the accountancy firm found that the UK system was even more intricate than the equivalent structure in France The British property tax system is now the most “complex” in the world, endangering London’s reputation as an investment haven, according to new analysis from accountancy firm PwC. Research showed… – Continue reading

The web helps the taxman chase cheats

Deloitte managing tax partner Thomas Pippos says the IRD are using electronic payments and websites to pursue tax cheats Budget-conscious tax collectors are increasingly turning to popular websites and other e-channels to chase undeclared taxable income, a top accountant says. Inland Revenue Department no longer had capacity or interest in… – Continue reading

Signs of radical settlement for Scotland emerge after poll results

The Conservative majority alongside a nationalist landslide in Scotland reopened the question of powers for the Scottish government, raising the prospect that the Tories might offer Edinburgh full control over taxes and domestic expenditure. The first signs of a radical new settlement emerged on Friday when Boris Johnson, the London… – Continue reading

Standard Chartered offshore RMB index drops in March

Banking multinational Standard Chartered’s renminbi Globalization Index (RGI) fell to 2,117 in March, down 1 percent from the previous month, the bank announced on Thursday. Renminbi-denominated cross-border Society for Worldwide Interbank Financial Telecommunication (SWIFT) payment was the only positive contributor to the RGI in March. Foreign exchange turnover, offshore renminbi… – Continue reading

Craig Elliffe: Multinationals face tax change

Bold step on non-resident levy likely to be first of many. A tax policy paper released yesterday proposes changes on the taxation of non-residents in respect of New Zealand-sourced interest income. These changes, if implemented, will affect large multinationals, banks and even individual New Zealand borrowers. As the first significant… – Continue reading

Record 1,337 Americans give up their passports

HONG KONG (CNNMoney) -Hasta la vista, Uncle Sam! A record 1,337 Americans gave up their passports in the first three months of the year, according to new data released by the U.S. government. That’s nearly 40% of the 3,415 Americans that renounced citizenship last year, suggesting that U.S. renunciations will… – Continue reading

Multinational CFOs Split on OECD Crackdown on Tax Evasion

CFOs of multinational corporations have mixed reactions to the Organization of Economic Cooperation and Development’s crackdown on base erosion and profit shifting by global companies, according to a new survey. The survey, by the tax advisory business Taxand, found that multinational CFOs are split 52 percent (agree) versus 48 percent… – Continue reading

GoldenSource: Five years on, FATCA is a friend

After five years of the US’s Foreign Account Tax Compliance Act (FATCA), financial institutions need to play the long game for future gain, according to GoldenSource’s Dev Bhudia. Bhudia, vice president of product management at GoldenSource, wrote in an article that the challenge now is not classifying clients or managing… – Continue reading

Sebi keeping tabs on exchange misuse for tax evasion: Sinha

New Delhi: Market regulator Securities and Exchange Board of India (Sebi) has asked bourses to take immediate action against entities involved in misuse of stock exchange system for tax evasion, Parliament was told Friday. Preliminary enquiries conducted by the regulator in the recent past, inter alia, indicate that certain persons/companies… – Continue reading