An inflow of bank deposits to Luxembourg from Asia and the Gulf have replaced reductions from European countries such as France and Germany following an overhaul of the Grand Duchy’s tax secrecy regime, reports the Financial Times. Pierre Gramegna told the Financial Times in an interview that “bank secrecy had… – Continue reading
The European Investment Bank (EIB) must tighten up its lending rules to prevent its money being funnelled through tax havens, NGOs have warned in a new report, reports EU Observer. The report ‘Towards a Responsible Taxation Policy for the EIB’, published on Tuesday (21 April) by transparency NGOs Re-Common and… – Continue reading
Like many other public banks, the European Investment Bank (EIB) leverages its own means by acting as a catalyst for private investment through various financial mechanisms. Too often, though, attempts to attract private capital result in unpredictable risks and higher-than projected costs for the public coffer, write Xavier Sol and… – Continue reading
Companies would be forced to reveal any arrangements that are used to avoid tax, and those not paying their fair share of tax would be named and shamed on a “worst offenders” list, under a plan by the Greens. The party has released a discussion paper detailing policies to fight… – Continue reading
The man chosen by Treasurer Joe Hockey to lead the review of the nation’s tax system has publicly criticised the British government’s “Google tax”, the inspiration for the Coalition’s looming crackdown on multinational profit shifting. Robert Jeremenko, who is running the tax white paper process in Mr Hockey’s office, described… – Continue reading
The OECD Mutual Agreement Procedure Statistics for 20131 (MAP Statistics), released on November 25, 2014, show a dramatic surge in the inventory of mutual agreement procedure (MAP) cases among OECD member countries. The MAP Statistics confirm that the potential for double taxation is increasing. This is reflected most starkly in… – Continue reading
On April 2, 2015, the Israeli tax authority (“ITA”) published a draft new circular containing new and unprecedented guidelines with respect to the income tax and VAT aspects applicable to foreign enterprises that transact with Israeli customers over the internet (“the Circular” and “Foreign Enterprises”, respectively). The Circular, in its… – Continue reading
“The business tax system today is inefficient, overly complex, and too riddled with loopholes,” said Mark Mazur, assistant secretary for tax policy at the U.S. Department of Treasury. So much so, in fact, that it can’t fulfill its function to be a world-class system, he noted. Mazur, speaking Tuesday at… – Continue reading
SOUTH Africa’s Finance Minister Nhlanhla Nene says African leaders need to focus more on tax policies and the diversification of tax resources in order to foster growth. Speaking at an African Tax Administration Forum conference on Tuesday, he said the global focus on international taxation offered a unique opportunity for… – Continue reading
Summary:Australia and the UK have reached a deal aimed at helping tackle profit-shifting practices by multinational companies, such as Apple, Google, and Microsoft. Australia and the United Kingdom have agreed to form a joint working group to tackle profit shifting by multinational companies such as Google, Apple, and Microsoft. The… – Continue reading
International plans for gathering and analysing data on the extent to which multinational companies are artificially shifting their profits to low-tax jurisdictions are at a disappointingly early stage, an expert has said. Heather Self of Pinsent Masons, the law firm behind Out-Law.com, also said that the global governments involved in… – Continue reading
In his recent article, “A Cursory Analysis of the Impact of Combined Reporting in the District”, Dr. Eric Cook claims that the District of Columbia’s (D.C. or the District) newly implemented combined reporting tax regime is an effective means of increasing tax revenue from corporate taxpayers, but it will have… – Continue reading
In recent years we have seen a seismic shift in the tax transparency landscape. The US Foreign Account Tax Compliance Act (US FATCA) has proved to be a watershed moment and we are rapidly moving towards a global network of automatic information exchange spearheaded by the OECD’s Common Reporting Standard… – Continue reading
CHINA Tax Free Reorganisations • With circulars 109 and 116 jointly issued in December 2014 by the Ministry of Finance and the State Administration of Taxation, the Chinese authorities have relaxed the conditions for internal reorganisations. • Circular 109 deals with internal reorganisations. Provided the pertinent requirements are met, the… – Continue reading
Business is braced for a slew of new anti-avoidance measures after the UK general election next month as politicians compete on promises to raise billions of pounds from closing tax loopholes, reports the Financial Times. A cross-party consensus is emerging over the scope for a renewed crackdown. Last week Vince… – Continue reading
Technology companies with international operations are increasingly using global tax avoidance methods, despite growing opposition from the public and politicians in the U.S. and abroad. As this opposition fuels ongoing changes in tax rules, organizations must be able to quickly adapt their corporate structures and tax strategies to maintain a… – Continue reading
Finance Minister Arun Jaitley has sought urgent implementation of common reporting standards on automatic exchange of information globally, asserting that it is the only way to tackle the challenges posed by black money and stop tax evasion. The problem of offshore tax evasion and flow of illicit money can be… – Continue reading
The Italian Ministry of Economy and Finance has removed the Isle of Man from its blacklist. The new list implements provisions, announced in the Italian Budget for 2015, that jurisdictions that have exchange of information arrangements with Italy are excluded from its blacklist on the deductibility of costs. The effect… – Continue reading
On 17 March 2015 Cyprus and Bahrain signed a new double taxation agreement. Like all of Cyprus’s recent DTAs it closely follows the 2010 OECD Model Tax Convention. Its main provisions are summarised below. Taxes covered The agreement applies to taxes on income imposed by either country. In Bahrain these… – Continue reading
Last week some of Australia’s biggest and richest companies voluntarily fronted up to a senate inquiry on corporate tax avoidance. Bigwigs from big brands, including Apple, Google, Microsoft, Rio Tinto, BHP Billiton and Fortescue Metals, squirmed under the spotlight as they were grilled about how they (legally) shift profits offshore… – Continue reading
The South African Revenue Service (SARS) has issued a revised draft interpretation note that discusses the principles and guidelines for the considering the “place of effective management” in determining the tax residence of a company. SARS points out that the concept of residency is critical in determining a company’s South… – Continue reading
OECD director admits UK’s Google tax may undermine some of the body’s BEPS work GOVERNMENT plans to introduce a diverted profits tax have caused embarrassment at the OECD, according to Pascal Saint-Amans [pictured], the body’s director leading the Base Erosion and Profit-Shifting (BEPS) project. Appearing via video link before Australia’s… – Continue reading
Corporate treasury departments will have to start complying with International tax rules and provide documentation for transactions according to recent reports. G20 leaders attempted to reform the international tax system in July 2012 by setting up the Base Erosion and Profit Shifting (BEPS) project. This task was given to the… – Continue reading
BEIJING: A total of 57 countries have been approved as founding members of a Chinese-led infrastructure bank, Beijing said on Wednesday, and Norway is included despite frosty relations over a Chinese dissident’s Nobel prize. No nations that formally sought to become founding members of the Asian Infrastructure Investment Bank (AIIB)… – Continue reading
Lithuania thanks Japan for lending support to the ambition to join OECD On 15 April 2015, Minister of Foreign Affairs of Lithuania Linas Linkevicius in a meeting with Parliamentary Deputy Minister for Foreign Affairs of Japan Kentaro Sonoura expressed his gratitude to Japan for supporting Lithuania’s ambition to join the… – Continue reading
Israel joined the OECD in 2010. Background The Organization for Economic Cooperation and Development is spearheading a concerted effort to help governments around the world collect more taxes. The OECD is doing so by issuing a series of recommendations for tightening up corporate and personal tax measures. Individual governments are… – Continue reading
Taxes have risen by around one per cent on the average worker’s wage in Organisation for Economic Co-operation and Development (OECD) countries since 2014, although the majority of governments have not increased income tax rates, the OECD has said. In its Taxing Wages 2015 report, the OECD looks at the… – Continue reading
Tax directors at many organizations anticipate their companies will grow by entering into new domestic and international markets in the years ahead, according to a new survey by BDO USA. In a sign of an improving economy, 50 percent of the 100 tax directors at $1billion-plus public companies surveyed by… – Continue reading
The Italian Ministry of Finance has removed Guernsey from its revised tax blacklist. Amendments within the 2015 Finance Act mean that the anti-tax haven deduction blacklist has been revised to exclude all countries that have an adequate exchange of information with Italy. Sinéad Leddy, Head of Technical at Guernsey Finance,… – Continue reading
As the above title indicates (it is only a modest exaggeration), the Treasury Greenbook regarding the FY 2016 budget proposes a radical restructuring of the system for U.S. taxation of foreign income of U.S. multinational enterprises (MNEs). Some Congressional players have suggested that these proposals are an opening bid in… – Continue reading
ISLAMABAD: The Federal Board of Revenue (FBR) has sought foreign assistance for improvement in two key areas; capacity building of officers and staff and IT infrastructure development. “FBR is of the view that if developed, both of these areas can only play key role in bringing FBR at par with… – Continue reading
Taxes on wages have risen by about one percent for the average worker in OECD countries between 2010 and 2014, even though the majority of governments did not increase statutory income tax rates, according to the Organisation for Economic Cooperation and Development’s (OECD’s) Taxing Wages 2015 report. According to the… – Continue reading
– Rising Cost of Compliance Within The Tax And Financial Regulatory Environment Creates Opportunities For Increased Efficiency – CHICAGO–(BUSINESS WIRE)–As the economy continues to accelerate, many organizations plan to grow by entering into new markets in the years ahead, reveals the first ever BDO USA, LLP Tax Outlook Survey. Fifty… – Continue reading
1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins Canada is a federal state, with legislative powers divided between the federal and provincial governments. The federal government has legislative jurisdiction over issues concerning Canada as a whole, including foreign affairs, international trade, banking, telecommunications,… – Continue reading
The Revenue Office will take steps to tax social networking sites and implement other regulations related to e-commerce. After the implementation of this regulation, all such virtual sites will be deemed as “work places” and the advertisers of social networking sites will also be deemed as “electronic tax payers.” Moreover,… – Continue reading
The Minister of Finance for Luxembourg says his country – labelled by critics as a tax haven for multinational corporations – is committed to sweeping international tax reforms being pushed by the G20 and the Organization for Economic Co-operation and Development, as long as they create a “level playing field.”… – Continue reading
The Ministry of Finance (MoF) recently signed a memorandum of understanding (MoU) with Umm Al Quwain Free Trade Zone Authority (UAQ FTZ). This agreement has been signed to ensure international standards of transparency in the exchange of information for tax purposes, as per Organisation for Economic Cooperation and Development (OECD)… – Continue reading
In recent years, the State Administration of Taxes (“SAT”) has paid closer attention to fees resident enterprises pay their overseas related parties, concerned that multinational groups have shifted profits away from China through aggressive tax planning and by paying unreasonable service fees and royalties overseas. Following PRC’s active participation in… – Continue reading
The reporting obligations imposed on lawyers are inconsistent and confused. Tax avoidance has become a central issue in the election campaign. So what is usually a topic for a small, specialist group of lawyers has become an item of general interest. And, yes, there is a strong link to lawyers’… – Continue reading
Offshore investment entities in the Cayman Islands and many other international financial centers should now start turning their attention to compliance with the Common Reporting Standard (“CRS”) promulgated by GATCA – Global FATCA. They must document all account holders existing on December 31, 2015, with the exception of entities with… – Continue reading
Finance Minister Mathias Cormann insists the government is not shying away from reform despite a tough year selling its first budget. Senator Cormann says pursuing important economic reform is a “marathon, not a sprint”. “If it was easy, anyone could do it,” he told Sky News on Sunday. Senator Cormann… – Continue reading
Listed companies in developed market could be avoiding as much as $82b annually London: Listed companies in developed markets are avoiding at least $82 billion (Dh301 billion) of tax a year by using tax havens and other minimisation strategies, according to detailed analysis of more than 1,000 businesses. The revelation… – Continue reading
There was a moment on Tuesday evening – hours before the first public hearing of the Senate inquiry into corporate tax evasion – when Treasurer Joe Hockey and his advisers should have sensed a firestorm approaching. Sandwiched between a story on a Gold Coast diet blogger accused of pinching other… – Continue reading
BERLIN: The Governments of France and Germany signed an amendment to the France-German treaty dated (the “Treaty”), which will have an impact in the future for certain investments in real estate. For France, this amendment follows the amendment to France-Luxembourg signed on 5 September 2014 which also impacts foreign investments… – Continue reading
At its sixth annual conference, the George Soros-founded Institute for New Economic Thinking will feature prominent left-wing economists Thomas Piketty, Joseph Stiglitz, and self-described Marxist and Greek Finance Minister, Yanis Varoufakis. By itself that wouldn’t be remarkable, but the meeting will come with the implicit endorsement of the U.S. taxpayer… – Continue reading
The Organisation for Economic Co-operation and Development formally invited Costa Rica to apply as a candidate for membership this week, five years after it began its push to join the exclusive club of developed economies. The news of Costa Rica taking one more step closer to joining the league of… – Continue reading
On 31 March 2015, the Governments of France and Germany signed an amendment to the France-German treaty dated (the “Treaty”), which will have an impact in the future for certain investments in real estate. For France, this amendment follows the amendment to France-Luxembourg signed on 5 September 2014 which also… – Continue reading
Apple Australia follows Australian transfer pricing law and pays all of its taxes due in the Australian market in accordance with the law, Tony King, the Managing Director of Apple Australia, told the Senate Inquiry on corporate tax avoidance and minimization on April 8, 2015. In his opening remarks before… – Continue reading
The present French Tax Update will focus on (i) several noteworthy French and European Union court decisions issued in the last months of 2014 and in the first months of 2015, and (ii) the recent presentation by the European Commission of a package of tax transparency measures. VALIDITY OF TAX… – Continue reading
1. Introduction On 14 January 2015, the Swiss Federal Council opened consultations on two draft laws on the international exchange of information in tax matters. One of them deals with the OECD/Council of Europe administrative assistance convention signed by Switzerland on 15 October 2013. The other consultation deals with Switzerland’s… – Continue reading
