He said steps are being taken to put in place a robust information security mechanism in the Income Tax department Non-disclosure of overseas assets will become a “very risky affair” from 2017 as government will by then start getting information on them from foreign countries, Minister of State for Finance… – Continue reading
Right to levy capital gains tax by India is also part discussions, he said India is engaged in “positive talks” with Mauritius on revision of bilateral tax treaty as some issues still need to be sorted out, an official said today. “Negotiations have been going on. Talks with Mauritius have… – Continue reading
A blockbuster tax cut deal, with a 10-year cost of $889 billion and counting, is deep into negotiations on Capitol Hill, proving that Congress doesn’t care about the deficit as long as the right groups get the giveaways. Virtually every year, Congress packages a series of over 50 tax breaks… – Continue reading
On 23 November 2015 Guernsey issued regulations to implement the Common Reporting Standard (“CRS”) under Guernsey’s domestic law. The regulations follow on from the commitment made on 29 October 2014 by Guernsey, along with the other Crown Dependencies and a number of other jurisdictions, to start exchanging information under the… – Continue reading
Tax cheats can breathe a little easier. The gun-toting Internal Revenue Service investigators who send felons to prison are retiring in droves and there’s no one to replace them. IRS Criminal Investigation agents are the elite special forces in the never-ending war on tax evasion. They are feared among criminals… – Continue reading
MUMBAI: Indian banks and mutual funds have in the past fortnight started warning NRIs who hold an American passport or are working in the US that their accounts could be frozen unless they get a tax-compliant certificate from US authorities, thanks to a treaty signed by New Delhi and Washington…. – Continue reading
Australians hiding funds and investments offshore to avoid paying tax have been put on notice. The federal government on Thursday introduced to parliament legislation to enable the tax office to crack down on taxpayers hiding funds overseas. It implements an OECD scheme allowing the sharing of information between foreign tax… – Continue reading
NEW DELHI, DEC 3: Domestic taxpayers would do well to fully disclose their foreign assets with Indian tax authorities, Jayant Sinha, Minister of State for Finance, has said. Non-disclosure of foreign assets could turn a “risky” proposition for taxpayers, Sinha said in his inaugural address at the 6th meeting of Automatic… – Continue reading
The union cabinet on Wednesday approved signing an agreement for amending the double taxation avoidance convention with Japan that was first signed in 1989 to check fiscal evasion, an official statement said. “The protocol will facilitate information exchange on tax payments, including bank transactions and on those without domestic tax… – Continue reading
Leaders from the Group of 20 largest economies (G20) met in Turkey last month to put their final stamp of approval on a major overhaul of the international rules governing corporate taxes. The vote was the icing on a cake that the Organization for Economic Cooperation and Development (OECD) has… – Continue reading
A lengthy and yet complex investigation by The Botswana Gazette into financial affairs of the company in the shady tax haven of Bermuda blows the lid off the dealings amounting to P29 million with a mailbox sister company that has no office, employees or any legitimate business activities. Not only… – Continue reading
The Organisation for Economic Co-operation and Development (OECD) sees treaty shopping as an important source of Base Erosion and Profit Shifting (BEPS). In this context, it identified the prevention of treaty abuse as one of fifteen issues or “actions” in respect of which recommendations were to be formulated as part… – Continue reading
Michael Dunkley has hit back at calls for Bermuda to make its beneficial ownership information public, claiming that critics are “attempting to solve a problem that does not exist”. After three days of meetings in London, the British Overseas Territories agreed to put information on the people who ultimately own… – Continue reading
On November 30, 2015, the UK tax authorities at HM Revenue and Customs (HMRC) reached an agreement with Jersey about the interpretation of the company residence tie-breaker provision of the Jersey-UK income tax treaty. After reviewing other income tax treaties that contain similar provisions, HMRC will now take the view… – Continue reading
Amid all the diplomatic comings and goings on Syria and how to tackle Islamic State, an important but little-noticed high-level gathering has been taking place in London. The Overseas Territories were holding the fourth meeting of their Joint Ministerial Council at Lancaster House. Leaders from Anguilla, Bermuda, British Virgin Islands,… – Continue reading
HONG KONG, Dec. 2, 2015 /PRNewswire — Demand for asset protection, wealth planning and funds by high net worth individuals in Asian countries will drive continued growth in the offshore industry, according to OIL’s sixth “Offshore 2020” annual market research study. OIL, the leader in international incorporations and corporate services… – Continue reading
The reporting deadline for Portuguese financial institutions to communicate information required under the FATCA regime to the Portuguese tax authorities has been extended to 31 December 2015. The FATCA deadline was extended by a 30 November 2015 order. This is the second time that the FATCA reporting deadline has been… – Continue reading
Within days, the IRS will be able to revoke your passport for unpaid taxes. This bad idea has been kicking around for several years. This time, it is buried within 1300 pages of highway legislation. The government will surely see it as a nice complement to FATCA, the Foreign Account… – Continue reading
We are all aware of “base erosion and profit shifting” or “BEPS”. On 5 October 2015, the OECD released its final reports in connection with its BEPS Action Plan including its final report on Action 15 dealing with the development of a multilateral instrument to modify bilateral tax treaties (“Final… – Continue reading
Corporation tax receipts for the year came to €4.6bn in 2014. By October this year, receipts had already exceeded that, with the expectation that the full-year receipts will be around €6.5bn with the Budget projecting growth in receipts in 2016 of 10 per cent. In a little over a year,… – Continue reading
Royal Decree 1021/2015, of November 13, establishing the obligation to identify the tax residence of persons who hold or control certain financial accounts and to provide information concerning them in the area of mutual assistance. On November 17 last the above-mentioned Royal Decree was published in the Official State Gazette…. – Continue reading
Lawmakers seek late deal to scale back ‘Cadillac tax’ Lawmakers are making a late push to repeal or scale back Obamacare’s “Cadillac tax” by the end of the year, eying inclusion of changes in a broader tax package, wrote Peter Sullivan of The Hill. But lawmakers in both parties say… – Continue reading
The U.S. multinational will likely be investigated for evading taxes with Luxembourg’s help, following a report by trade unions earlier this year. McDonald’s is under investigation by European Union regulators for illegal tax deals with Luxembourg, according to sources close to the inquiry. The multinational—joining a list of EU tax… – Continue reading
The Government has recently launched a consultation on amending the UK’s interest deductibility rules for companies. The consultation follows the OECD’s recommendations as part of the Base Erosion and Profit Shifting (BEPS) project. In line with those recommendations, it is proposed that a company’s net interest deductions be limited to… – Continue reading
An EU deal with Liechtenstein, which will make it harder for EU citizens to hide cash from the tax man in bank accounts there, was endorsed by Parliament in a vote on Wednesday. Under the deal, the EU and Liechtenstein will automatically exchange information on the bank accounts of each… – Continue reading
By SYLVESTER MWALE – THE Government has resolved to liquidate the outstanding US$300 million owed to Eastern and Southern African Trade and Development (PTA) Bank accumulated through petroleum importation. The arrears would be dismantled in four installments within a period of one year. Chief Government Spokesperson Chishimba Kambwili said in… – Continue reading
Thailand’s vote this past May to implement a new transfer pricing law is expected to come into effect in the early part of the new year. Transfer pricing refers to the sale of goods or services between branches of a company or subsidiary companies to a parent enterprise, and most… – Continue reading
Swiss Senate has sealed the end of banking secrecy for foreign clients, following the House of Representatives in accepting the legal groundwork for the automatic exchange of information. The decision paves the way for a “decorous funeral for tax secrecy,” as senator Roberto Zanetti of the leftwing Social Democrats put… – Continue reading
Inland Revenue is looking at the tax treatment of hybrid debt and equity instruments and the use of related party loans funding local subsidiaries as part of a global clamp-down on tax avoidance. Acting deputy commissioner of policy and strategy David Carrigan told Parliament’s finance and expenditure select committee that… – Continue reading
The Global Forum established an AEOI group in consequence of the G20 Leaders’ Declaration in September, 2013 with a view to establish a mechanism to monitor and review the implementation of the new global standard on automatic exchange of information. As India and other countries enhance their cooperation to crack… – Continue reading
Members of the European Parliament have tasked the EU Commission to table measures to improve corporate tax transparency, coordination, and EU-wide policy convergence, in legislative recommendations passed by the Economic and Monetary Affairs Committee on December 1, 2015. The recommendations build on the work of EU Parliament’s Special Committee on… – Continue reading
Republicans in both chambers of Congress said international tax reform is necessary to retain companies in the United States following pharmaceutical giant Pfizer’s announcement it is moving its headquarters overseas after its merger with Ireland-based Allergan, citing the country’s high corporate tax rates. During hearings in the House Ways and… – Continue reading
UK tax authority HM Revenue and Customs (HMRC) has announced a change of view on the interpretation of the company residence articles in 16 double taxation agreements (DTAs), reports Tax News. The change was prompted by an agreement with Jersey on the interpretation of the company residence tie-breaker article in… – Continue reading
AUTOMATIC EXCHANGE OF INFORMATION IN TAX MATTERS – THE COMMON REPORTING STANDARD Introduction The Common Reporting Standard (CRS) is a tool which facilitates the automatic exchange of information at a global level. The fight against tax evasion in cross border transactions has become a priority for Government around the globe…. – Continue reading
Taxes levied on foreign stock dividends can be recouped, but it makes most sense for high-net-worth clients with multimillion-dollar positions Advisers could be missing out on a way to maximize returns on their clients’ foreign investments. Americans investing in non-U.S. stocks could be earning less of a return than they’d… – Continue reading
Congress tightens the tax abuse of Americans who live and work abroad Doubling down on Americans living and working abroad is a way for the Internal Revenue Service to squeeze the turnip a little harder in pursuit of a little more blood. The Obama administration, which has never met a… – Continue reading
As the Joint Ministerial Council meeting continues in London this week Financial Services Minister Hon Wayne Panton says he intends to meet with European States in a bid to have Cayman removed from their lists of third-country, Non-cooperative Tax Jurisdictions. The minister, speaking at the last sitting of the Legislative… – Continue reading
Things are heating up in the economic substance doctrine area, which could lead to a U.S. Supreme Court review of the IRS’s aggressive arguments for the doctrine. Certiorari Petitions Salem Financial Inc. and Bank of New York Mellon Corporation have both petitioned for Supreme Court review of the Federal Circuit… – Continue reading
The European Commission’s use of state aid rules to challenge corporate tax agreements is causing uncertainly for businesses in Europe, Luxembourg finance minister Pierre Gramegna has said. Gramegna told the Financial Times this week that the situation “raises so many issues about predictability and certainty”. The Commission announced in October… – Continue reading
Taxes levied on foreign stock dividends can be recouped, but it makes most sense for high-net-worth clients with multimillion-dollar positions Advisers could be missing out on a way to maximize returns on their clients’ foreign investments. Americans investing in non-U.S. stocks could be earning less of a return than they’d… – Continue reading
Holiday home owners and others who inadvertantly break new tax rules could be ‘criminalised’ Holiday home owners who miscalculate tax owed, and those inheriting offshore money, face having their income wiped out entirely due to new penalties and punishments being introduced in the New Year. HM Revenue & Customs has… – Continue reading
A new international framework is targeting tax avoidance—and it has implications for captive insurers. Jenny Coletta of Ernst & Young explains In recent years, tax authorities around the world have been increasingly scrutinising captive insurance arrangements, focusing on questions relating to commercial purpose, pricing and substance. In what is likely… – Continue reading
Former UBS bank executive Raoul Weil believes the United States tried to use him to batter down Swiss banking secrecy by having him arrested and placed on trial last year. In an interview with the Tages-Anzeiger newspaper on Wednesday, Weil said the US Department of Justice intended to “lead me… – Continue reading
The introduction of the so-called “offshore tax” in Latvia may have adverse effects on Latvia’s accession to the Organization for Economic Cooperation and Development (OECD), reports LETA. The OECD has informed Latvia about this, urging the country to consider the potential effects of the “offshore tax” on its progress towards… – Continue reading
1. On November 30 (Mon.), an exchange of diplomatic notes for the entry into force of the Agreement between the Government of Japan and the Government of the State of Qatar for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (signed… – Continue reading
On 17 September, 2015, China State Administration of Taxation (“SAT”) released the Discussion Draft of Implementation Measures for Special Taxation Adjustments (“Discussion Draft”), as a complete revamp to the existing trial version of the Implementation Measures, i.e., Circular 2. Circular 2 has been serving as a backbone transfer pricing (“TP”)… – Continue reading
The Common Reporting Standard (CRS) is the standard for automatic exchange of financial account information produced by the Organisation for Economic Cooperation and Development (OECD) which provides for systematic and periodic automatic exchange of information between signatory jurisdictions. At its heart is a requirement for financial institutions, including British Virgin… – Continue reading
Following a directive proposal put forward by the European Commission as part of a package of measures in March, the European Council reached political agreement on a directive amending the text of 2011/16/EU directive on administrative cooperation in the field of taxation. EU member states will be required to automatically… – Continue reading
The Channel Islands (Jersey and Guernsey) have long been known as leading offshore centres for the establishment of investment funds and other investment structures. In particular, Channel Island vehicles are often used for alternative investment structuring – including private equity, infrastructure and real estate. This article explains the trends in… – Continue reading
Amazon Anonymous van drove through central London emblazoned with the line: ‘Enjoy unlimited instant tax dodging subsidised by government hand-outs. Anywhere, anytime’ Anti-Amazon campaigners drove a van through central London yesterday that was emblazoned with a crowdfunded, fake Amazon advert attacking the online retailer’s alleged tax avoidance. Booksellers have championed… – Continue reading
