On 22 December 2014, the Italian Parliament approved the Budget for 2015.40 Among other measures, the Law introduces the possibility of an exemption from corporate income tax (IRES, generally levied at 27,5%) and local tax (IRAP, generally levied at 3,9%) on income derived from qualifying intangible assets (such as patents,… – Continue reading
The Government introduced legislation on ‘disguised remuneration’ in the Finance Bill last week to target the practice of using third party vehicles such as offshore trusts to allow employees to avoid or defer the payment of income tax or national insurance contributions. However, it has emerged that MPs will not… – Continue reading
Nokain Tyres is appealing a tax adjustment for 2007-2010 that requires the tiremaker to pay an extra 87 million euros. The adjustment includes an additional 55 million euros in additional taxes and 32 million in punitive taxes that must be paid by January 2016, Tyres and Accessories reported. Nokian described… – Continue reading
(MENAFN – Qatar News Agency) The Ministry of Finance attain several achievements during the past year, most notably the issuance of Law No. 2 of 2015 on the financial system of the State, which included provisions for preparing and implementing the general budget and the final account of the State…. – Continue reading
A vote taken in the European Parliament could effectively rob Malta of its ability to attract multinational companies and their millions of Euros in taxation revenue. A vast majority of MEPs, spanning across all political groups showed their support for a resolution, prepared in Parliament’s Economic and Monetary Affairs Committee…. – Continue reading
FOCUS: New UK government plans to penalise those who help others evade tax could punish those who unknowingly enable evasion and could create conflicts of interest and the danger of double jeopardy. The government will introduce a new civil penalty for those who deliberately “enable” offshore tax evasion. It also… – Continue reading
Provide high-net-worth individuals with (further) incentives to relocate to Cyprus. This is one of the objectives of the introduction of the non-domicile rules (voted on the 9th of July 2015, among other tax reforms) that came into force on the 17th of July 2015 (date of the publication in the… – Continue reading
Latvian President Raimonds Vejonis on December 15th accepted the credentials of the Japanese Ambassador to Latvia, Mariko Fujii, and noted an increase in Latvia-Japan trade recently but said there was still room for growth in economic cooperation, the Latvian president’s press service reported LETA. He said that a treaty for… – Continue reading
Tax payers are more concerned about the invasion of their privacy rather than an investigation into their tax affairs Tax payers have just over a fortnight left to voluntarily utilise the favourable terms of the Lichtenstein Disclosure Facility (LDF) before it is closed on 31 December 2015. It will be… – Continue reading
The Organisation for Economic Co-operation and Development (OECD) announced that the OECD has responded to a request from the European Commission to include additional fields in the common reporting standard (CRS) XML schema. The EC request was made so as to further the work of the European Commission and the… – Continue reading
The tax commission of the ruling coalition (the Liberal Democratic Party and New Komeito) on 10 December 2015 reached an agreement for a draft outline of tax reform proposals for 2016. Among the items in the draft outline are proposals for transfer pricing documentation rules based on Action 13 (Transfer… – Continue reading
On 10 December 2015, the Belgian Parliament voted – in plenary session – the bill “on the communication of information relating to financial accounts, by Belgian financial institutions and the Federal Public Authority of Finance, within the framework of an automatic exchange of information at international level for tax purposes”…. – Continue reading
Journal: The EU’s ongoing investigation into Luxembourg’s tax agreements with multinational corporations is threatening to leave a black mark on the Grand Duchy at the end of its six-month European presidency. Luxembourg’s finance ministry could face legal action from the European Commission, as the EU authority continues its probe into… – Continue reading
For the Socialist Senator Roberto Zanetti, the reform is an open-heart surgery, which must be done with great accuracy. Under pressure from the EU, G20 and the OECD, also Switzerland is obliged to give up his special tax regimes for holding companies and management companies. After years of negotiations with… – Continue reading
The Belgian Minister of Finance has just shared new insights on how Belgium will be addressing the outcome of the OECD/G20 project in relation to Base Erosion and Profit Shifting (“BEPS”). He opted to do so via the “Plan to combat tax fraud”. The title of his policy note is… – Continue reading
Provisions under new article 76A of Mexico’s tax law reflect certain items of the OECD’s base erosion and profit shifting (BEPS) project—in particular expanded transfer pricing disclosure requirements that will apply for the 2016 tax year. Background The Mexican government’s 2016 federal budget, presented 8 September 2015, included proposals for… – Continue reading
There are a number of ways to structure your offshore fund and the best option for you will depend largely on the location of the manager, your investor base and the type of investments that the fund will make. I have set out a summary of the three most common… – Continue reading
Executive summary On 9 December 2015, the UK released draft clauses for Finance Bill 2016 as well as consultation documents. The key items released include: A new requirement for large businesses to publish their tax strategies as they relate to or affect UK taxation. This sits alongside new ‘special measures’… – Continue reading
According to Baroness Neville-Rolfe, Parliamentary Under Secretary of State at the Department for Business, Innovation and Skills, the United Kingdom “is at the forefront of a dramatic increase in transparency about company ownership” in developed countries. However, it is the UK which is going to provide the testing ground for… – Continue reading
On 5 October 2015, the OECD published its final report on Action Point 7 of the BEPS initiative (Preventing the Artificial Avoidance of Permanent Establishment Status), which entails a significant change to the current definition of permanent establishment (PE) in article 5 of the OECD Model Tax Convention. The purpose… – Continue reading
In 10 years between 2004 and 2013, Ghana has lost a cumulative $4 billion to illicit financial flows. A report issued last week by the Global Financial Integrity (GFI), a Washington DC-based research and advisory organization found that every year $401 million leave the shores of Ghana illicitly. The report… – Continue reading
Caribbean territory Saint Kitts and Nevis has proposed legislative changes to improve its ability to exchange information with treaty partners in tax matters. The territory’s Prime Minister, Timothy Harris, explained that the changes have been prompted by an increasing number of requests from treaty partners, which he attributed to a… – Continue reading
On December 15, 2015 the OECD issued a press release announcing that on that same date Monaco signed the Multilateral Competent Authority Agreement (MCAA), bringing the total number of signatories to 76. According to the overview of Signatories of the MCAA and the intended first information exchange date, Monaco intends… – Continue reading
On December 15, 2015 the European Commission issued a media release announcing that on that same date it adopted new rules to make it easier for EU Member States’ tax authorities to exchange financial information so that they can ensure full tax transparency and cooperation. According to the media release… – Continue reading
Dividend income from foreign companies is not treated the same as dividend from domestic companies, for tax purposes The two key advantages of investing in equities are the possibility of higher returns and tax efficiency. In the long term, equity has outperformed other asset classes. And, according to Income tax… – Continue reading
The Australian Taxation Office (ATO) has released a Taxpayer alert on arrangements involving the use of offshore entities which source goods (procurement hub) on behalf of Australian resident multi-national enterprises (MNEs) (TA 2015/5). In the alert the ATO announces that it is currently reviewing arrangements involving the use of offshore… – Continue reading
The BVI Business Companies Act 2004 (“BCA“) is shortly due to be amended by the BVI Business Companies (Amendment) Act 2015 (the “Amendment Act”). As well as keeping the British Virgin Islands (“BVI“) corporate regime at the forefront of compliance with international standards, the Amendment Act is intended to provide… – Continue reading
(CN) – A Russian nuclear energy official living in Maryland has been sentenced to four years in federal prison on money laundering charges, the Justice Department announced Tuesday. Vadim Mikerin, 56, of Chevy Chase. Md. was also ordered to forfeit more than $2.1 million, after he pleaded guilty to charges… – Continue reading
The UK Government has confirmed that it will legislate for a new criminal offense for corporations that fail to take adequate steps to prevent the facilitation of tax evasion. Tax authority HM Revenue and Customs (HMRC) has published responses to four consultations on anti-evasion measures announced at the March 2015… – Continue reading
FATCA (the Foreign Account Tax Compliance Act) came into force in July 2014. It is far-reaching and may impose a compliance burden on the trustees of New Zealand family trusts, even if no US persons are involved. IRD has recently issued further draft guidance on the application of FATCA to… – Continue reading
More good news for Hong Kong before the end of 2015: Italy decided to remove Hong Kong from its national blacklist on November 30, 2015. Italy ratified a comprehensive agreement for the avoidance of double taxation (CDTA) signed with Hong Kong on June 18, 2015. Facilitating an early removal of… – Continue reading
Three Swiss banks, including a unit of France’s Crédit Agricole SA, will pay a total of more than $130 million to the U.S. Justice Department to avoid possible prosecution for helping Americans evade taxes, the department said on Tuesday. The Zurich-based unit of Crédit Agricole will pay $99.2 million, the… – Continue reading
Lately, the IRS is warning offshore account holders to disclose before it’s too late. Under FATCA, banks everywhere want to know if you are compliant with the IRS. And the cost of compliance for many people is growing. The IRS updated its list of foreign banks where accounts trigger a… – Continue reading
the company will make a complaint against the decision Nokian Tyres plc (HEX:NRE1V) has received a renewed reassessment decision from the Tax Administration, according to which the Company is obliged to pay EUR 87 million additional taxes with punitive tax increases and interests concerning tax years 2007-2010. Payment must be… – Continue reading
The US has refused to join the Common Reporting Standard (CRS) which binds banks to share information about assets with tax services of other countries. Switzerland has accused the US of double standards and abuse of confidence. On May 6, 2014, 47 countries agreed on a common reporting standard, an… – Continue reading
Italian Trade Agency (ITA) President Ricardo Monti is actively working to get more companies and individuals to invest in his country. Monti was recently in Japan as part of a push to attract Japanese businesses and individuals to invest in the country. To assist with investment in the country, the… – Continue reading
[BEIJING] China’s central bank is on guard against a sudden attack on the yuan in offshore markets, and is ready to intervene if the gap between offshore and onshore exchange rates becomes destabilising, sources involved in policy discussions say. Though the People’s Bank of China (PBOC) wants to avoid a… – Continue reading
European evaluators urged Vatican prosecutors on Tuesday to move ahead and bring charges in some of the 25 money-laundering investigations they have opened over the past few years as part of beefed-up measures to prevent illicit activity at the Vatican’s scandal-marred bank. The Council of Europe’s Moneyval committee issued the… – Continue reading
The opera singer, who sang the famous duet Barcelona with Freddy Mercury, has also been fined a quarter of a million euros. Spanish soprano Montserrat Caballé, 82, has been sentenced to six months in prison for tax evasion after taking a deal in which she plead guilty to the charges…. – Continue reading
Coffee chain Starbucks said it paid £8 million in corporation tax last year after posting record UK profits. The UK arm of the US-based chain said pre-tax profits jumped to £34.2 million in the year to September 27, compared with less than £2 million a year ago – as it… – Continue reading
Celebration, FL One of the basic principles of the 3.8% “net investment income tax” (NIIT) under §14111 is that the tax does not apply to individuals who are classified as “nonresident aliens” for U.S. income tax purposes, as defined in §7701(b).2 What was not clarified in the statute, however, was… – Continue reading
Main principles of Direct Taxation – Double Tax Treaties In our third article in a series of articles on the tax challenges of the digital economy, we shall be providing you hereunder with a brief overview of the principles of direct taxation, with a focus primarily on the taxation of… – Continue reading
Dear clients and cooperation partners, This newsflash will tell you about findings reflected in court judgements with regard to application of resale price method, and in particular – contradictions in calculation of arm’s length profit level. Recent transfer pricing judgements in Latvia lead to increased controversy in application of resale… – Continue reading
Ukrainian President Petro Poroshenko hopes that the signing of the revamped intergovernmental agreement to avoid double taxation would facilitate the development of economic relations between Ukraine and Cyprus. “Following the negotiations, the parties signed 4 documents, inter alia, those allowing the avoidance of double taxation. The head of state expressed… – Continue reading
In 2002, a corporation could establish a fiscal year end for Quebec tax purposes that differed from its year end for British Columbia and federal tax purposes – referred to as a Quebec year end shuffle. In Veracity Capital Corporation v. Canada, 2015 BCSC 2278 (copy attached), taxpayers transferred shares… – Continue reading
Billionaire investor Carl Icahn has a strong opinion on almost every subject, especially politics. He’s also quite happy to share that opinion with anyone who will listen to or read what he has to say. Icahn’s comments this week on how to stop future tax-motivated corporate inversions such as the… – Continue reading
Phillip Paulwell’s response to a question from opposition member Gregory Mair about when a bill to amend the Access to Information Act (ATI) will be taken to Parliament is, at the very least, unsatisfactory and should not be accepted. Paulwell, the leader of government business in the House of Representatives,… – Continue reading
A TAX amnesty introduced by the Fiji Revenue and Customs Authority netted the Government more than half a billion dollars within a span of six weeks. This was revealed by Attorney-General and Minister for Finance Aiyaz Sayed-Khaiyum during his closing remarks at the 17th A-G’s Conference in Natadola last Saturday…. – Continue reading
Hundreds of millions of dollars of revenue could be up for grabs as the Tax Office announces reviews of multinationals using offshore hubs in Singapore to minimise their tax. The ATO has issued a warning to multinationals to come forward immediately to discuss their overseas hub arrangements, if they have… – Continue reading
Stricter Tax and documentation requirements for foreign transactions “Amazon, Facebook, Google and Starbucks pay little taxes …” or “Luxembourg attracts international corporations” – headlines like these have 62 states and the OECD called into action. The result was “base erosion and profit shifting” BEPS shortly. Even the German SME sector… – Continue reading
