Introduction Transfer pricing methods and tested parties Troubling trend Tools for taxpayers Introduction In some recent transfer pricing audits the Internal Revenue Service (IRS) has ‘flipped the tested party’ after examining transactions between related US and foreign companies. Typically, this practice results in the attribution of a larger portion of… – Continue reading
Three-member AP Shah Committee has recommended extending minimum alternate tax (MAT) relief to foreign companies which do not have permanent establishment or public business in India. In an earlier version, the committee had sought to restrict MAT to foreign institutional investors and foreign portfolio investors. The committee had also not… – Continue reading
Tax authority alerts police amid suspicion that foreign companies have defrauded its system over past three years Denmark’s tax authority said on Wednesday that it had alerted police after foreign companies appeared to have drained more than 800m euros from the system in what would be the country’s biggest tax… – Continue reading
Three-member AP Shah Committee has recommended extending minimum alternate tax (MAT) relief to foreign companies which do not have permanent establishment or public business in India. In an earlier version, the committee had sought to restrict MAT to foreign institutional investors and foreign portfolio investors. The committee had also not… – Continue reading
This Annual Conference Provides Global Tax Compliance Experts With Insight on Adopting an Internationally Accepted Standard of Tax Transparency and Compliance NEW YORK, NY–(Marketwired – August 25, 2015) – marcus evans, the world’s largest event management group, will host the 4th FATCA and Global Tax Compliance Forum on November 4-6,… – Continue reading
This article is an outline of tax havens and the effects that such systems have on competition outcomes. In the quest to attract Foreign Direct Investment (FDI), governments especially those in developing countries engage potential investors in negotiations and provide various incentives to reach development agreements. Those incentives may include… – Continue reading
Hopeful of settling disputes with 120 US companies in next 3 months NEW DELHI, AUG 23: India will, in the next three months, settle tax disputes involving 120 US companies, Revenue Secretary Shaktikanta Das has said. This will be done under the new framework agreement on Mutual Agreement Procedure (MAP)… – Continue reading
Introduction Individuals whose domicile of origin is outside United Kingdom Non-UK individuals with UK domicile of origin Consultation and legislation New inheritance tax rules for UK residential property held within offshore corporate envelopes Comment Introduction Individuals domiciled outside the United Kingdom might have been justified in thinking that they would… – Continue reading
(CS) German financial institution HSH Nordbank reportedly reached a 22-million-euro settlement with prosecutors in Cologne over setting up offshore companies through Luxembourg to hide client assets from tax authorities. Newspaper “Süddeutsche Zeitung” and broadcasters NDR and WDR first reported on the deal on Tuesday. Allegedly, HSH Nordbank approached the prosecutor’s… – Continue reading
The following article by Dr Monica Galea John, partner in the Financial Services Department, analyses the manner in which the Fourth EU Anti Money Laundering Directive (the “Directive“) which has just made its way through the EU’s legislation, obliges, for the first time, EU member states to maintain central registers… – Continue reading
A narrative which is now familiar to those working in Africa or who are involved in projects relating to Africa tends to enter into all discussions related to poverty and income disparity on that continent. That narrative, that the poverty and deprivation which exist on the continent are directly attributable… – Continue reading
It is the irony of ironies. Dollar for dollar, the tobacco companies appear to do more for Australian hospitals, roads and schools than any other group of foreign-controlled multinationals who operate in this country. An analysis of the financial statements of the three major tobacco companies here, Philip Morris (Australia)… – Continue reading
The rise of Islamic finance and sukuk issuances have brought with it a growing phenomenon: Shariah banking is increasingly taking advantage of offshore banking jurisdictions, and this for a number of reasons, reports the Gulf Times. Many offshore centres around the world meanwhile offer a wide range of features allowing… – Continue reading
A CAMPAIGN questioning the “fairness” of land ownership launched across Scotland yesterday. Our Land is a month-long initiative created by Common Weal, Women for Independence and land reform campaigners Andy Wightman and Lesley Riddoch and aims to highlight problems caused by a land ownership system that “allows a handful of… – Continue reading
FATCA refers to provisions contained in the Hiring Incentives to Restore Employment Act (the ‘HIRE’ Act) signed into law on 18 March 2010 in the United States. The main purpose of FATCA is to identify and gather information on US persons who may be evading tax through the use of… – Continue reading
WASHINGTON, D.C. (WDAM) –This is a news release from the U.S. Department of Justice. Two tax return preparers with offices located in California, Maryland and New York were sentenced today in Los Angeles for facilitating an offshore tax fraud scheme, announced Acting Assistant Attorney General Caroline D. Ciraolo of the… – Continue reading
Senate Republicans insist they’re deeply skeptical of Rep. Paul Ryan’s push for an agreement on international tax reform, but acknowledge a plan with bipartisan support would be hard to turn aside. With the Senate’s own highway bill is only funded for half of its six-year span, Republicans said this week… – Continue reading
The Labuan International Business and Financial Centre is attempting to encourage more Indonesian companies to register in the jurisdiction to take advantage of its low-tax regime and trading and investment links with key economies in the Asia-Pacific region. The Labuan IBFC held the Jakarta chapter of its ASEAN (Association of… – Continue reading
Law firm Edwin Coe maps out the upcoming changes to the taxation of high net worth individuals in the UK, as announced in the last two Budgets. While many commentators have focused their sympathies on those reliant on benefits following last month’s Summer Budget, law firm Edwin Coe argues that… – Continue reading
After resubmitting a bill for a third time, which seeks to put a clear divide between offshore companies and public money, leaders of the Green Party LMP spoke at length about the necessity of this bill, during a press conference yesterday, Hungarian news agency MTI reported. LMP co-leader, András Schiffer,… – Continue reading
THOUSANDS of pieces of land across Scotland have been snapped up by huge offshore companies – many of which are based in the world’s biggest tax havens. The revelation has prompted fears that firms owning Scottish land are dodging taxes, or even acting as fronts for laundering money. In total… – Continue reading
What is the difference between 30 per cent of zero and 20 per cent of zero? Correct: precisely $5227.27 less than a Bronwyn-Bishop-taxpayer-funded helicopter trip from Melbourne to Geelong. A reduction in the corporate tax rate, as unrelentingly espoused by the business lobby in its pro-GST campaign, may be a… – Continue reading
The Foreign Account Tax Compliance Act (FATCA)[LR1] is generally associated with reporting requirements for foreign banks and foreign entities to disclose the names of U.S. individuals using such foreign vehicles to hide U.S. financial accounts. (See all three blog posts in this series on FATCA compliance.) However, there is an… – Continue reading
There is an intimate relationship between art and finance. In the public sphere, the state plays a predominant role in funding and maintaining national art collections. The private sphere is dominated by private patronage. For example, artists in medieval Italy were funded by wealthy families such as the Medici, and… – Continue reading
Requiring the Land Registry to publish information about foreign companies that own property in England and Wales could ultimately speed up the recovery of money from fraudsters who have “hidden” victims’ money in a variety of corporate structures, an expert has said. UK prime minister David Cameron announced new measures… – Continue reading
The Prime Minister took small bites as he tucked into the Indonesian street food alongside a local celebrity, singer and actress Maudy Ayunda. “London is not a place to stash your dodgy cash”. Transparency worldwide says shell companies are a common way for moving corrupt money around the world. Some… – Continue reading
Blaming foreigners for homegrown economic woes is a tradition of sorts in Washington. In recent years, the favored scapegoat has been China and its folkloric trade indiscretions. But, lately, some have taken to demonizing foreign companies for the sins of a broken U.S. corporate tax system. Given the importance of… – Continue reading
Foreigners must not be able to buy UK homes with “plundered or laundered cash” as part a global effort to defeat corruption, David Cameron has said. Speaking in Singapore, the prime minister vowed to expose the use of “anonymous shell companies” to buy luxury UK properties – often in London…. – Continue reading
Where a foreign company renders professional services to a South African company in South Africa, it is important that the foreign entity considers whether, as a result of rendering such services, the foreign company will create a permanent establishment in South Africa. The reason why this becomes important is that… – Continue reading
White-collar criminals who launder billions by buying luxury UK properties must be tackled, Prime Minister David Cameron said on Tuesday. Experts warn these fraudsters are distorting the UK property market and pushing up house prices in the process. Cameron’s criticism of money laundering formed part of a broader speech on… – Continue reading
A new report says house prices in the United Kingdom have been on the rise over foreign criminals’ purchasing of British property. According to the Times report, foreign crime lords are pushing up house prices in Britain by laundering billions of pounds through the purchase of expensive properties. The report… – Continue reading
On 8 June 2015, the Law “On optional declaration of assets and bank accounts (deposits) by individuals” (the “Capital or Tax Amnesty Law”) came into force. It was announced as part of the deoffshorisation campaign and opens a window of opportunity for the business community to declare “grey” assets without… – Continue reading
A report published today by Global Witness, alleging that an individual with ties to a former Kazakh public official owns large swathes of London, follows much recent interest in the issue of public officials owning property in the UK via secretive corporate structures that conceal their interest. Earlier this month,… – Continue reading
Categorizing it as a “large scale, continuing, complex commercial crime,” a judge has sentenced two Calgary businessmen to prison for five years for defrauding the federal government of millions in taxes that should have been paid on registered retirement savings plans. Court of Queen’s Bench Justice Peter McIntyre said Steven… – Continue reading
Top lawmakers and the White House are in the early stages of discussing an ambitious overhaul of how the U.S. taxes its multinational firms, according to officials involved in the effort. The talks, part of an effort to find funding for a long-term highway bill, are preliminary and could yet… – Continue reading
In cooperation with their Latvian colleagues, Ukrainian investigators have uncovered and frozen more than USD 80 mln (EUR 73 mln) worth of funds in Latvian bank accounts. The funds were moved there by Serhiy Kurchenko, a well-known associate of ousted president Viktor Yanukovych, the Russian LSM site reported yesterday via… – Continue reading
HM Revenue and Customs (HMRC) has launched four consultations on the UK Government’s proposed new approach to tackling offshore tax evasion. Under the proposals, corporates who are deemed to have failed to prevent tax evasion or the facilitation of tax evasion would face a criminal offence. A separate strict liability… – Continue reading
Over the past few months, several foreign portfolio investors registered in India have received notices from the Indian tax authorities demanding payment of Minimum Alternate Tax in respect of transactions which took place over the course of prior assessment years. The Indian Government has indicated that it could raise several… – Continue reading
HSBC Global Asset Management head of internationals Mark Newsam explains why he identifies Asia as potentially the strongest future growth opportunity for the group’s offshore business. How big is HSBC Global Asset Management within the inter-national space? HSBC Global Asset Management is the investment management business of the HSBC Group,… – Continue reading
On July 8, 2015, the International Tax Reform Working Group, which is co-chaired by Senators Rob Portman (R-OH) and Chuck Schumer (D-NY), released its long-awaited report that Senate Finance Committee Chairman Orrin Hatch (R-UT) has said is the precursor to comprehensive tax reform in the United States. What does the… – Continue reading
House Ways and Means Chairman Paul Ryan (R-Wis.) made it clear Thursday that tapping offshore corporate profits was his top choice for funding a longer-term highway bill. In fact, Ryan declined to even lay out what the House GOP’s “Plan B” might be, ahead of a looming July 31 deadline… – Continue reading
Shipping should not panic in wake of proposed U.K. non-dom tax changes, Moore Stephens says Shipowners likely to be affected by wide-ranging changes to the taxation of non-U.K.-domiciliaries introduced in the U.K. Summer Budget have been urged not to panic by international accountant and shipping adviser Moore Stephens, which says… – Continue reading
How should non resident or non domiciled buyers of UK residential property own or hold residential property? Overseas buyers or owners of UK residential property above £1m in value need to consider carefully in what name or legal structure they should buy or hold property for their protection and to… – Continue reading
Where Qualified Dividend Treatment Is Important, Serious Consideration Should Be Given to Ensuring the Company Is Eligible for Treaty Benefits Before Taking It Public. Dividends generally are taxed at ordinary income rates (up to 39.6 percent for individuals). Qualified dividends derived by individuals, however, are taxed at the preferential rate… – Continue reading
With a new government at India’s center and positive macroeconomic fundamentals working in its favor, the private equity industry is expected to invest more actively into India over the short to medium term. In the past year, inflation has steadily tapered, the fiscal deficit has been reduced, domestic demand has… – Continue reading
Channel 4 documentary shows agents in wealthy districts agreeing to continue with purchase to be made with ill-gotten gains from Russian health budget Top estate agents in Britain’s wealthiest postcodes are willing to turn a blind eye to apparent money laundering by corrupt foreign buyers, according to an investigation by… – Continue reading
With the increasing focus by the Internal Revenue Service (IRS) on offshore activities, it is important to understand the tax return and information return filing obligations that may be associated with such activities. Because application of many of these obligations is not entirely clear in certain common situations, many taxpayers… – Continue reading
MOSCOW, July 3 (RAPSI) – The State Duma, Russia’s lower house of parliament, on Friday adopted in its third and final reading a government-drafted bill that prohibits state procurement from companies registered in offshore jurisdictions, RIA Novosti reports. The provisional bill stipulates that a legal entity registered in a state… – Continue reading
The National Oversight and Whistleblowers (NOW) will be lodging reports with Australian authorities to investigate Majlis Amanah Rakyat (Mara) for possible tax evasion and money laundering in its purchase of four Melbourne properties between late 2012 and early 2013. Its director Akmal Nasir will travel to Australia next week to… – Continue reading
Legal and General has offloaded its Dublin-based offshore business, L&G International, to Canada Life Group for an undisclosed sum. Launched in 2007, the unit was a subsidiary of L&G, based in Dublin. It provides investment and tax planning solutions, primarily focused on the UK high net-worth market. The business has… – Continue reading
