Category: High Networth Individuals

Ireland Details Framework On Exchange Of Tax Rulings

The Irish Revenue has released guidance on how it will exchange information on the tax rulings it grants. Revenue eBrief No.65/16, which was released on July 5, 2016, sets out Revenue’s arrangements for implementing Council Directive (EU) 2015/2376; and the OECD’s framework for the compulsory spontaneous exchange of information in… – Continue reading

US Consumption Taxes Low In Global Comparison

A recent paper from the Tax Foundation (TF) pointed out that, while most Organisation for Economic Co-operation and Development (OECD) countries lean more on tax revenue from consumption taxes, the United States relies more on individual income tax, while raising relatively little from consumption taxes. The TF noted that “this… – Continue reading

Feds Sue Facebook Over Ireland Asset Sale That Cut IRS Tax Bill

The U.S. Internal Revenue Service (IRS) said Facebook Inc. may have understated the value of intellectual property it transferred to Ireland by “billions of dollars,” unfairly cutting its tax bill in the process, according to court papers. The U.S. Justice Department filed a lawsuit on Wednesday in federal court in… – Continue reading

Ghana losing tax revenue to extractive sector over lack of data

The absence of adequate data on the operations of businesses in the extractive sector continues to impede the GRA’s ability to fully implement Ghana’s transfer pricing policy. According to the Deputy Commissioner in charge of Policy Programs at the GRA, Edward Gyamerah, the issue makes it difficult to fully assess… – Continue reading

After Brexit, EU proposes tougher tax rules on trusts

The European Commission will propose on Tuesday stricter rules on trusts to prevent tax evasion, according to draft legislation seen by Reuters, in a move that Britain has long opposed and which was deferred until after the Brexit referendum. The EU push to identify owners of trusts has been in… – Continue reading

Multinational Companies Have Increased Their Work on BEPS Compliance, Thomson Reuters Survey Finds

Two-thirds of corporate tax executives surveyed say their companies are proactively preparing for the onslaught of new tax regulations resulting from the Base Erosion and Profit Shifting (BEPS) Action Plan. That`s a 22% increase in the past year. In Thomson Reuters 2015 BEPS Readiness Survey, 54% of respondents said they… – Continue reading

Tax haven route won’t work for post-Brexit UK, OECD says

The United Kingdom is unlikely to try to lure international investment by becoming a tax haven after it leaves the European Union, according to an internal memo prepared by the body responsible for the drafting international tax rules. The head of tax at the Organization for Economic Co-operation and Development,… – Continue reading

Google’s offices in Spain raided by tax authorities

Tax authorities in Spain have raided Google’s offices in Madrid as part of an investigation into tax evasion and fraud, TechCrunch understands. Local press and the Reuters news agency are also reporting the raids. The raid on Google’s Madrid headquarters and its Google Campus workspace are related to VAT payments… – Continue reading

How new EU tax laws impact Thai firms

THAI MULTINATIONAL companies will be impacted on their cross-border business activities due to rapidly evolving tax laws in Europe and Asia-Pacific. For instance, the European Union (EU) achieved a groundbreaking result on June 20 by agreeing to a package of tax measures to combat corporate tax avoidance, which will be… – Continue reading

IRS inversion rules face blowback

A regulatory effort by the Obama administration to crack down on tax deals is facing backlash from business groups and lawmakers on both sides of the aisle. While the Internal Revenue Service (IRS) rules were intended to combat inversions — transactions in which a U.S. company combines with a foreign… – Continue reading

Gov’t policies offer incentives for tax dodging

Tax dodgers in Greece enjoy multiple benefits: They pay less tax, they avoid social security contributions, they can protect their main residence from confiscation and have access to a number of social benefits, ranging from free nursery places for their children to various allowances. The temptation to declare an income… – Continue reading

New Zealand Poised to Toughen Rules for Offshore Trusts

New Zealand is poised to toughen its disclosure rules for offshore trusts in the wake of the massive data leak known as the “Panama Papers.” Tax expert John Shewan on Monday released a report recommending a big increase in the amount of information disclosed when a foreign trust sets up,… – Continue reading

GAAR not to apply on income from investments before April 1

The industry has been demanding that GAAR provisions should apply prospectively To clear the air on retrospective applicability of the stringent anti-avoidance GAAR rule, the I-T department has said the same will not apply to income from transfer of investments before April 1, 2017. General Anti-Avoidance Rule (GAAR), which will… – Continue reading

Taiwan-Italy Tax Treaty Takes Effect from 1 January 2016

With an aim to avoiding double taxation, improving the investment environment for Taiwan, and increasing the attractiveness of foreign investment into Taiwan, the Ministry of Finance in recent years has focused on entering into tax treaties with other jurisdictions. Following tax treaties signed with Italy and Austria, Taiwan entered into… – Continue reading

CRA has double standard for tax cheats

The CRA won’t divulge the identities of people convicted for stashing millions offshore, but it names and shames those caught owing small amounts of tax. The Canada Revenue Agency claims at least nine people have been convicted of offshore tax evasion over the last two years, receiving $4 million in… – Continue reading

CRA has double standard for tax cheats

The CRA won’t divulge the identities of people convicted for stashing millions offshore, but it names and shames those caught owing small amounts of tax. The Canada Revenue Agency claims at least nine people have been convicted of offshore tax evasion over the last two years, receiving $4 million in… – Continue reading

UK Must Comply With EU Privacy Law, Watchdog Argues

But Brexit May Upend Data Protection and Notification Rules Lawmakers and legal analysts are still struggling to analyze the impact of the June 23 referendum on Britain’s membership in the European Union (see Brexit: What’s Next for Privacy, Policing, Surveillance?). In the wake of a majority of U.K. voters opting… – Continue reading

Bulgaria adopts controversial amendments to the “Offshore Companies Act”

On 15 June 2016 the Bulgarian Parliament adopted long discussed amendments to the so called “Act on Economic and Financial Relations with Companies Registered in Jurisdictions with Preferential Tax Treatment, their Related Parties and Actual Owners” (the “Offshore Companies Act”, or the “Act”). The Act was adopted in 2014 and… – Continue reading

Death and Taxes: IRS Begins Procuring Offshore Client Accounts, Records from UBS

In what could be a significant development moving forward, UBS has provided the IRS with tax records and offshore accounts. UBS Group AG has come to an understanding with the US Internal Revenue Service (IRS), following a disagreement over client accounts in Singapore that had alleged tax evasion. The latest… – Continue reading

Tax conundrum for Indian-focused offshore private equity funds

Foreign private equity investors typically set up offshore pooling vehicles for routing investments into India, which offer them twin advantages of ease of administration and single window compliance with the Indian regulatory regime. Setting up such pooling vehicles in a tax favourable jurisdiction ensures that the interposition of the pooling… – Continue reading

Brexit Risks Losing Corporate Tax Break Worth Billions in U.K.

British multinational companies face new withholding taxes that may cost hundreds of billions of euros a year if U.K. voters decide to leave the European Union, international tax specialists say. A so-called Brexit “would have a major impact” on British corporations that have subsidiaries in the EU, said Daniel Gutmann,… – Continue reading

IRS Overlooks Noncompliance in Offshore Voluntary Disclosure Program

The Internal Revenue Service is missing out on imposing approximately $21.6 million in penalties on taxpayers who are denied entry or withdraw from its Offshore Voluntary Disclosure Program, according to a new report The report, from the Treasury Inspector General for Tax Administration, found the IRS needs to improve its… – Continue reading

Canada willingly makes tax deals with tax havens

The seeds of Canadian corporations hiding billions of dollars in offshore tax havens were sown more than 40 years ago, after the Canadian government pursued a series of tax treaties with tiny Caribbean and European nations. The 92 tax treaties now signed with countries such as Barbados, Jamaica and Malta… – Continue reading

New double tax treaty will help French businesses operating in Singapore, says expert

A new double tax treaty between France and Singapore will be of particular help to French companies operating in Singapore, especially in the construction industry, an expert has said. Franck Lagorce, an expert in French tax at Pinsent Masons, the law firm behind Out-law.com was commenting following an announcement from… – Continue reading

Australia to gain from Singapore joining OECD fight against multinational tax avoidance

Multinationals suspected of routing Australian profits via Singapore will be outed to tax authorities, with the low-tax nation this week signing up to the global plan to fight tax evasion. Companies including big miners BHP Billiton and Rio Tinto as well as technology giants Apple and Google, have admitted using… – Continue reading

Deals Canada signed to catch tax cheats allow billions in taxes to escape

Montreal-based clothing maker Gildan earned $396 million in profit last year, but paid just over $6 million in cash taxes — a rate of about two per cent. Drug maker Valeant, based in nearby Laval, Que., booked $1.1 billion in profit in 2014 but paid only $110 million in tax…. – Continue reading

Double Taxation Avoidance Bill passes second reading at House of Reps

The quest by the President Muhammadu Buhari’s administration to improve the ease of doing business in Nigeria and diversify the nation’s economy on Wednesday received a boost. This followed the passage of “a Bill for an Act to Provide for the Domestication and Enforcement in Nigeria of the Avoidance of… – Continue reading

Singapore joins tax framework led by OECD and G20

Under the new tax framework, Singapore will implement minimum standards aimed at preventing “aggressive tax planning” by multinationals. Locally headquartered multinationals will soon have to file reports broken down by country as well as income and taxes to the Inland Revenue Authority of Singapore (IRAS). In a statement on Thursday… – Continue reading

Washington ALJ Upholds Business and Occupation Tax Assessment on German Company’s Royalty Income

On May 31, 2016, the Washington Department of Revenue (DOR) Appeals Division released a Determination (No. 15-0251, 35 WTD 230) denying a German pharmaceutical company’s business and occupation tax (B&O) protest. The administrative law judge (ALJ) ruled that while the nondiscrimination provisions contained in Article 24 of the US-Germany Income… – Continue reading

Bulgarian Parliament amends law on offshore companies

Bulgarian MPs passed at second reading on June 15 a bill easing ownership restrictions on offshore companies, amending a law that was adopted in December 2013. Under the amended law, which will go into effect on July 1, corporate entities registered in tax havens will be allowed to hold up… – Continue reading

CRA shared information on smaller bank accounts with IRS

Contrary to FATCA, accounts under $50,000 have been disclosed The Canada Revenue Agency has been transferring information about Canadian bank accounts worth under $50,000 U.S to the U.S Internal Revenue Service but cannot say how many accounts below that threshold have been shared with the Americans. Under a controversial information-sharing… – Continue reading

BEPS Takes Center Stage At US OECD Tax Conference

Hundreds of policymakers, business executives, and senior tax officials met at the OECD International Tax Conference to discuss the recommendations proposed under the base erosion and profit shifting (BEPS) project and their impact on trade and investment. The conference, which was held in Washington DC on June 6-7, 2016, was… – Continue reading

Barcelona accept to pay 5.5-million-euro fine over tax evasion charges on Neymar transfer

Barcelona on Monday accepted to pay a 5.5-million-euro ($6.2 million) fine over Neymar’s contested 2013 transfer in a deal with prosecutors that sees the club avoid trial on tax evasion charges. “It was better to accept this agreement than continue on with the uncertainty that has dragged on for a… – Continue reading

Ashgabat, London sign convention on double taxation avoidance

Turkmenistan and the UK signed an intergovernmental convention in Ashgabat on avoidance of double taxation and prevention of fiscal evasion from taxes on income and capital gains, said the Turkmen foreign ministry in a message June 10. According to the ministry, the signing ceremony took place as part of a… – Continue reading

Italy: New international tax ruling in Italy

Multinational companies doing business in Italy, Italian companies doing business abroad and non-resident companies which intend to invest in Italy may use the new international tax ruling procedure to reach an advanced agreement with the Italian Tax Authorities regarding the taxation of income derived from cross-border transactions. Recently, Legislative Decree… – Continue reading

Passing Bilateral Tax Treaties Will Promote American Competitiveness

Pending before the United States Senate are a number of tax treaties. Seven of these are bilateral treaties between the U.S. and a foreign country, in this case Chile, Hungary, Japan, Luxembourg, Poland, Spain, and Switzerland. ATR urges all Senators to support these routine, yet important treaties that protect against… – Continue reading

Jamaica Facing Correspondent Banking Challenges

Finance Minister Audley Shaw says investors from Jamaica’s diaspora are challenged by international banks who are refusing to do correspondent banking with banks in Jamaica. Correspondent banking allows a financial institution to do business on behalf of banks in other countries, making it easy for persons to move cash from… – Continue reading

The OECD/G20 BEPS recommendations: boosting U.S. tax reform

Most American policymakers believe the U.S. corporate tax system needs reforming – and the facts back up their view The United States’ 39 percent combined statutory corporate tax rate is the highest among the largest 50 economies. The American tax and accounting system has trapped over $2 trillion of deferred… – Continue reading

India-Mauritius tax treaty: An end and a new beginning

Recent news of India and Mauritius signing a Protocol to amend their 33 year old tax treaty caused seismic changes in the tax world. Though not completely unanticipated, the change is significant for foreign investors to go back to the drawing board and reassess their structures. The tax treaty between… – Continue reading

BEPS Will Raise Taxes and Cost Worldwide

CHICAGO – Mid-sized international businesses around the world are afraid that upcoming international tax rules will hike their taxes, increase compliance costs, and interfere with their business strategies. In a report released over the weekend, the international management consultancy firm RSM showed that a significant portion of mid-sized international businesses… – Continue reading

Chile seeks to eliminate double taxation with China

SANTIAGO, June 7 (Xinhua) — The Foreign Relations Committee of the Chilean Senate approved Monday legal proposals to eliminate double taxation with China and three other countries. Chile and China first signed an agreement over the matter on May 25, 2015 in Santiago. “China is our main trading partner and… – Continue reading

Cyprus says ‘very close’ to revising tax treaty with India

In a step forward, Cyprus has said it is “very close” to revising the bilateral tax treaty with India as the island nation has accepted “in principle” proposals made by the Indian side on taxing capital gains. Cyprus, a source of significant foreign fund flows into the country, said rising… – Continue reading

HMRC claim it is winning the battle to crackdown on corporation tax

HMRC believe that that they have turned a corner in catching companies trying to avoid paying corporation tax after subjecting large businesses “to an exceptional level of scrutiny”. Data released following a Freedom of Information Act request by UHY Hacker Young showed 15 per cent decrease in the number of… – Continue reading

Iran To Launch Offshore Bank To Process International Payments

Iran is to launch an offshore bank on one of its Gulf islands “within a month”, according to a report by the official IRNA news agency, as it continues to seeks ways around restrictions on international payments. The bank will be set up on Kish Island, which has been developed… – Continue reading

HMRC to ‘bear down’ on tax planning in updated vision

A CLAMPDOWN on tax planning, a transformation of its services for taxpayers and delivering a professional, efficient and engaged organisation are the three key objectives for HMRC in its updated single departmental plan. The government department has outlined its main visions and objectives for the period between 2015 and 2020,… – Continue reading

Hungary, Turkmenistan sign double taxation avoidance agreement

Hungary’s State Secretary for Economic Development and Regulation István Lepsényi and Turkmenistanʼs Minister for Economy and Development Bazarov Batyr signed a double taxation avoidance agreement yesterday in Budapest, according to reports. Hungary and Turkmenistan initiated negotiations on the matter last year to allow for a more transparent and favorable business… – Continue reading

Corporates stress about reputational risk over non compliance with FATCA and CRS

Over half of senior executives from multinational financial firms are concerned that non-compliance with the Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standard (CRS) mandates could affect their reputations, a Thomson Reuters survey has found ‘The results of the survey demonstrate that institutions’ greatest concerns regarding FATCA and… – Continue reading

Global Tax Update – June 2016

Asia Pacific The January – March edition of tax highlights for the Asia Pacific region highlights industry developments from Australia, China, Hong Kong, India, Indonesia, Korea, Malaysia and Singapore including: Australia’s new tax system for Managed Investment Trusts The final stage of China’s B2V reform to be rolled out from… – Continue reading