Category: Regulatory

Latin America business potential for Island

The World Captive Forum takes place in Florida next month Bermuda’s business chiefs will be out in force at next month’s World Captive Forum. The event, to be held in Florida, will include several speakers from Bermuda including lawyers, regulators and business leaders. And Bermuda delegates will use the event… – Continue reading

New Luxembourg-Singapore agreement for the avoidance of double taxation which will stimulate trade and investment flows between both jurisdictions enters into force

On 28 December 2015, the revised Luxembourg-Singapore Agreement for the Avoidance of Double Taxation (the New Treaty) entered into force. The New Treaty (1) allows Luxembourg investment vehicles to invoke benefits under the New Treaty, (2) reduces the withholding tax rates for dividends, interest and royalties, (3) increases thresholds to… – Continue reading

Indian companies with foreign units likely to be impacted by POEM guidelines

MUMBAI: Many manufacturing and trading subsidiaries of Indian companies that are currently operating independently outside India may have to pay taxes in India as they could fail the new test set under the Place of Effective Management (POEM) guidelines. Not just that, some of the companies could see complications with… – Continue reading

Gaming authority ‘convinced’ industry will withstand new EU tax laws

MGA executive chairperson Joseph Cuschieri warns organised crime within gaming industry ‘has never been this sophisticated’ Malta Gaming Authority’s executive chairman insisted that the gaming industry will continue to flourish on the island, even if proposed EU legislation to clamp down on tax avoidance goes through. “The threat [of a… – Continue reading

Sanders attacks tax dodging through Bermuda

US Democratic presidential hopeful Bernie Sanders has pledged a crackdown on tax avoidance involving Bermuda and other offshore jurisdictions. Mr Sanders, currently trailing Hillary Clinton in the race for the nomination as presidential candidate, made the promise on an online political channel in America. Mr Sanders said he would use… – Continue reading

Ireland: OECD Common Reporting Standard Implementation In Ireland – Implications For Irish Investment Funds And SPVs

On 18 December 2015, the Regulations implementing the OECD Common Reporting Standard (“CRS“) in Ireland were approved by the Irish Parliament. This update follows on from previous updates published by Maples and Calder Dublin on CRS and US FATCA and outlines the practical next steps for Irish investment funds and… – Continue reading

Dutch tax treatment of Brazilian ‘interest on equity’ payments as of 2016

On 15 September 2015, the Dutch government released its budget for 2016, containing the Tax Plan 2016, which includes certain amendments to Dutch tax law. One of the proposed amendments was the inclusion of an anti-hybrid rule in the Dutch participation exemption regime (“PER”). On 22 December 2015, the amendments… – Continue reading

Work on agreement on sharing tax data among EEU members in final stage

MINSK, 29 December (BelTA) – The work on the agreement on sharing tax data between member states of the Eurasian Economic Union (EEU) is in the final stage. The statement was made by Belarusian Tax and Duties Eurasian Economic Union (EEU)Minister Sergei Nalivaiko during the press conference hosted by the… – Continue reading

Ireland Issues Brief On EU Savings Taxation

The Irish Revenue has released a new brief detailing the impact on Irish paying agents of the European Union’s decision to replace the Savings Tax Directive with legislation providing for the automatic exchange of tax information. On November 10, the European Council repealed Directive 2003/48/EC on the taxation of savings… – Continue reading

Mexican Tax Reforms for 2016

On Nov. 18, 2015, reforms to the Mexican Income Tax Law (MITL), Tax Code, Excise Tax and Federal Income Law for 2016 (collectively, the Tax Reform) were published in the Federal Gazette. The Tax Reform reestablishes measures to promote savings and increase incentives for doing business in Mexico, some of… – Continue reading

New Guide On Tax Residency For UK Insurance, Financial Firms

The Association of British Insurers (ABI) and the Association of Professional Financial Advisers (APFA) have published updated joint guidance for insurers and financial advisers on the tax information requirements for new customers following changes to UK tax regulations. The new requirements are intended to ensure that the UK can exchange… – Continue reading

B&E | Measures to Control the Abuse of Offshore Tax Havens

“Cash Booked Offshore for Tax Purposes by U.S. Multinationals Doubled between 2008 and 2014” In recent years, U.S. multinational companies have sharply increased the amount of money that they book to foreign subsidiaries. An April 2015 study by research firm Audit Analytics found that the Russell 1000 list of U.S…. – Continue reading

Algeria: President Bouteflika Inks Presidential Decrees Ratifying Many Agreements

Algiers — President of the Republic Abdelaziz Bouteflika signed presidential decrees on the ratification of many cooperation agreements between Algeria and other States and international organizations, in accordance with Article 77-11 of the Constitution, said Sunday the Presidency of the Republic in a statement. One of the decrees concerns the… – Continue reading

BEPS Action Plan 2: Neutralizing the effects of hybrid mismatch arrangements

Hybrid mismatch arrangements are the focus of the 2-part Action Plan 2 of the Organisation for Economic Co-operation and Development’s (OECD’s) Base Erosion and Profit Shifting (BEPS) initiative. Hybrid Mismatch Arrangements abuse differences in the tax treatment of an instrument (i.e., a hybrid instrument) or an entity (i.e., a hybrid… – Continue reading

Bid to stamp out corporate tax avoidance unites Westminster parties

Current system viewed as unfair and too easy to circumvent Abolition of corporation tax is to be considered by a new cross-party group of MPs and peers who will subject ministers and business leaders to public interrogations in a bid to secure fairer and more responsible tax policies. The all-party… – Continue reading

‘Google tax’ on firms from 2016

Measure tries to keep firms from exploiting tax law variations Foreign and local businesses with annual sales of 100 billion won ($85 million) or more, and over 50 billion won in transactions with overseas entities must report international transactions to the tax authority starting next year. Known as the “Google… – Continue reading

US Swiss bank tax evasion program reaches $1 bn in fines

(MENAFN – AFP) US officials announced settlements with four more Swiss banks Wednesday to lift the total fines in the two-year disclosure program to more than 1 billion from 75 banks. “With today’s resolutions under the Swiss Bank Program, the department has reached agreements with 75 Swiss banks, imposed penalties… – Continue reading

Boustany introduces BEPS Act to protect U.S. companies’ country-by-country reporting

Legislation introduced on Tuesday by U.S. Rep. Charles Boustany (R-LA) would safeguard companies in country-by-country reporting requirements. The Bad Exchange Prevention Act follows the issuance by the Treasury Department on Monday of guidelines for adhering to the country-by-country reporting requirements under the Organization for Economic Cooperation and Development’s (OECD) Base… – Continue reading

Singaporean – Ecuadorian DTA entered into force

On December 18, 2015 the Inland Revenue Authority of Singapore issued a press release announcing that on that same date the Agreement between the Government of the Republic of Singapore and the Government of the Republic of Ecuador for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading

Singaporean – San Marinese DTA entered into force

On December 18, 2015 the Inland Revenue Authority of Singapore issued a press release announcing that on that same date the Agreement between the Government of the Republic of Singapore and the Government of the Republic of San Marino for the Avoidance of Double Taxation and the Prevention of Fiscal… – Continue reading

Singaporean – Seychellois DTA entered into force

On December 18, 2015 the Inland Revenue Authority of Singapore issued a press release announcing that on that same date the Agreement between the Government of the Republic of Singapore and the Government of the Republic of Seychelles for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading

Liechtenstein – Czech Republic: Tax Treaty Enters Into Force

The Income Tax Treaty between Liechtenstein and the Czech Republic entered into force on 22 December 2015. Its provisions will apply from 1 January 2016. The Treaty was signed on 25 September 2014. In accordance with the treaty, the following withholding taxes will apply: Dividends: 0% if the beneficial owner… – Continue reading

MoU signed with BD, Bahrain

Bangladesh and Bahrain have signed three instruments in Manama to further strengthen cooperation in various fields between the two countries. The instruments are Agreement on the Reciprocal Protection and Promotion of Investment, Agreement on the Avoidance of Double Taxation and a MoU on Foreign Office Consultations. The first two instruments… – Continue reading

Government cracks down on Blackmoney, detects over Rs 16,000-cr undisclosed income in 20 months

New Delhi: A government crackdown on black money has led to detection of undisclosed income of over Rs 16,000 crore since March 2014, while assets worth Rs 1,200 crore have been seized, Revenue Secretary Hasmukh Adhia said today. “In 2014-15 and 2015-16 (up to November), the Income Tax Department by… – Continue reading

UK Tax Haven: Five Big Investment Banks Paid No Corporation Tax in 2014

The British government is facing a credibility crisis over its pledge to ensure multinational corporations pay their fair share of tax, after it was revealed that five of the world’s largest investment banks paid no corporation tax in Britain last year, despite making billions in profits. Analysis of the banks’… – Continue reading

UK taxman warns expats that tax evasion penalties will get tougher in 2016

With a new year on the horizon it is often at this time when people start thinking about fulfilling a dream of moving abroad and making plans. Others may be thinking about moving back home. For people paying tax in the UK, the country’s tax man has come up with… – Continue reading

Is It the Real Thing? The IRS Makes $9+ Billion of Transfer Pricing Adjustments Against The Coca-Cola Company

On September 17, 2015, the IRS issued a statutory notice of deficiency to the Coca-Cola Company, increasing its federal income taxes for 2007-2009 by $3.3 billion, based primarily on transfer pricing adjustments exceeding $9 billion. On December 14, 2015, Coca-Cola petitioned the U.S. Tax Court to overturn the adjustments. This… – Continue reading

Philippines, Germany Update Tax Treaty

Germany and Philippines have completed the necessary domestic ratification procedures to bring their new double tax agreement into force. The two nations exchanged instruments of ratification on December 20 to replace their existing treaty, which was concluded in 1983. Negotiations on the upgraded treaty were concluded on July 20, 2012,… – Continue reading

IRS Issues Updated US Expatriate Tax Guide

The Internal Revenue Service (IRS) has released the 2015 update to Publication 54, which provides guidance on the special tax compliance rules for US citizens and resident aliens who work abroad or receive income from foreign countries. The worldwide income of US citizens or resident aliens is generally subject to… – Continue reading

Benchmarks trim losses; trade continues in red

Indian equity markets trimmed their losses and continue to trade weak in late morning session on account of selling in frontline blue chip counters. Sentiments remained down-beat with the repot that the Finance Ministry has cut its ambitious disinvestment revenue target by 57% to Rs 30,000 crore for the current… – Continue reading

Mohammed receives Slovak Prime Minister

His Highness Sheikh Mohammed bin Rashid Al Maktoum, Vice-President and Prime Minister of the UAE and Ruler of Dubai, on Monday received Robert Fico, Prime Minister of Slovakia, and members of the accompanying delegation at Zabeel Palace. During the meeting, Sheikh Mohammed accepted an invitation from the Slovak prime minister… – Continue reading

Ireland: CRS regulations are released, effective 31 December 2015

The Irish Revenue Commissioners have confirmed that the necessary statutory instrument to bring the final common reporting standard (CRS) regulations into Irish domestic law was signed 17 December 2015 and is effective 31 December 2015. Other recent developments concerning the automatic exchange of information (AEOI) regimes, include the publication of… – Continue reading