Today, the Organization for Economic Cooperation and Development (OECD) released statistics for the 2014 reporting period on the mutual agreement procedure (MAP) caseloads of all of its member countries and of non-OECD economies that agreed to provide such statistics. The OECD has already provided MAP statistics for reporting periods 2006… – Continue reading
The Organisation for Economic Cooperation and Development (OECD) today released annual statistics on the mutual agreement procedure (MAP) caseloads of all its member countries and of non-OECD economies that agree to provide such statistics for the 2014 reporting period. Today’s OECD release explains: The MAP statistics correspond to the 2014… – Continue reading
A pending Protocol, that would amend the income tax treaty between Luxembourg and France, may not be effective until 2017. RATIFICATION PENDING The Luxembourg Parliament passed a bill to ratify the fourth Protocol to the income tax treaty (1958) between Luxembourg and France. However, it currently appears that the ratification… – Continue reading
On 10 November 2015, the Danish Ministry of Taxation introduced a draft bill (bill no. L46) including an amendment to section 3B of the Danish Tax Control Act (skattekontrolloven). The purpose of the proposed amendment is to implement Action Point 13 of the BEPS Initiative (Guidance on Transfer Pricing Documentation… – Continue reading
Through tweaks to the Model Tax Convention, the OECD believes its work on profit shifting will stem elaborate structures, such as commissionaire arrangements, used by large multinationals to avoid the creation of a permanent establishment. The Organization for Economic Cooperation and Development, however, responded to concerns from taxpayers by narrowing… – Continue reading
The U.K. and the U.S. governments will adopt different approaches to implementing the OECD’s final package of measures to tackle base erosion and profit shifting, panelists at a London forum said. The U.K. government considers an inclusive, multilateral instrument to upgrade bilateral tax treatments as the “best way” for countries… – Continue reading
DESPITE repeated allegations from the Spanish government that Gibraltar is a tax haven, news is regularly received that suggests this is far from the case, and that the government has been doing all that it can to ensure that it complies as fully as possible with international standards, whilst generating… – Continue reading
LK Hewlett Customers throughout the region are likely to see additional or increased fees and charges as their banks incur mounting financial burden in the face of FATCA and CRS. The regional banks have recently had to expand their IT, security and human resources to become compliant with the US’… – Continue reading
Already from December 1, 2015 come into force provisions requiring all financial institutions calling their clients to make statements about their residence tax (FATCA – Foreign Account Tax Compliance Act). It is the first significant action since records to OPF. FATCA imposes on foreign institutions, including the Polish reporting obligations… – Continue reading
Big name companies have faced a lot of criticism from the media about the low taxes they pay in some countries. Lately, the Organisation of Economic Cooperation and Development (OECD) has finalised a set of recommendations to stop base erosion and profit shifting (BEPS). The rules are aimed at curbing… – Continue reading
YEREVAN, NOVEMBER 23, ARMENPRESS. A businessman should not pay the same tax for two times for a unilateral deal. The agreement of avoidance of double taxation with respect of taxes on income and on capital signed between Armenia and the USA is one of the factors that will contribute to… – Continue reading
The OECD’s final report on Action 13 under the base erosion and profit shifting project—which calls for countries to adopt a country-by-country reporting template, master file and local file—has the potential to be one of its “greatest legacies.” Marlies de Ruiter, head of the Organization for Economic Cooperation and Development’s… – Continue reading
LK Hewlett St. Kitts-Nevis Permanent Representative to the OAS, Dr. Everson Hull has expressed strong views on the impact of FATCA on the region’s banking system. Delivering a presentation to over 200 banking executives and other stakeholders in the financial services sector from across the Caribbean at the recent Caribbean… – Continue reading
The IRS has upgraded the Foreign Account Tax Compliance Act (FATCA) Online Registration System, enabling sponsoring entities to register their sponsored entities to obtain a global intermediary identification number. The upgraded system also will allow users to update their information, download registration tables and change their financial institution type. The… – Continue reading
The European Commission has requested that the Netherlands amend the limitation on benefits clause in its double tax treaty with Japan. The Commission said that, on the basis of previous cases such as Gottardo (C-55/00) and Open Skies (C-466/98), a member state concluding a treaty with a third country cannot… – Continue reading
Nawaz Sharif has turned his full attention for close relations with Central Asian states since the five of them broke away from Russia 23 years ago. Fast track negotiations between Central Asian and Pakistani leaderships are slated to turn their countries into a big, new economic zone. Their desire and… – Continue reading
Tax Commissioner Chris Jordan has become more picky about entering agreements with multinationals aimed at giving companies certainty about their tax payment requirements in Australia in future years. Taxpayers can lock in their tax payment for a period of about three years via an “advanced pricing agreement”, or APA. Technology… – Continue reading
Failed tax avoidance business Welbeck hired young actors to push schemes onto City big earners, and reaped millions in commissions that fuelled lifestyles of fast cars and exotic holidays, according to a whistleblower who worked at the firm. Welbeck Solutions sold pensions and financial products, but it specialised in tax… – Continue reading
Private companies that were given a historical exemption from filing annual financial reports are run by a who’s who of corporate Australia, including Malcolm Turnbull Private companies associated with Australia’s business elite, including prime minister Malcolm Turnbull, are on a list of entities not required to publish tax information under… – Continue reading
“India’s concerns are known…there can be no compromise on the issue of terror…India’s longstanding position is that there is no good or bad terror and all forms of terrorism are unacceptable and must be fought by the global community as well as each and every country”, the source told reporters…. – Continue reading
Towards compliance with tax information sharing laws put in place in recent times, all financial intermediaries are mandated to seek information from account holders. They are also obliged to share information of your account with relevant authorities. SEBI too has issued guidelines on identification of beneficial ownership and mandated all… – Continue reading
The North will have its own 12.5pc corporate tax rate from 2018. This means that it will compete harder against the Republic for FDI projects, writes Dan White The 12.5pc company tax rate will no longer be confined to the southern part of the island. Last week’s ‘Fresh Start’ agreement… – Continue reading
NEW DELHI: Tightening the noose around Indians whose names figured in the ‘stolen’ Swiss HSBC bank black money list, the Enforcement Directorate has begun a preliminary investigation in these cases for an independent hawala and money laundering probe. The agency recently has begun obtaining from various court registries the details… – Continue reading
On the face of it, Malta literally has the highest corporate tax rate in the EU. At 35%, it hardly seems to be a competitor to European tax havens like Ireland and Cyprus, both applying a rate of 12.5%, or territories like Gibraltar. At a rate of 10%, the latter… – Continue reading
Nov 22, 2015- Lack of clarity over double taxation on petroleum products from China will delay the signing commercial agreement with Petro-China. For now, the government is sending a technical team of Nepal Oil Corporation (NOC) to China on Monday to clarify the issue of taxation before a high level… – Continue reading
The United States is on the verge of economic collapse. It is being tipped over the edge by its own government with an unquenchable thirst for taxes and incurable addiction to spending. The financial system in the United States and everywhere else in the world is in danger of disintegrating… – Continue reading
Notice 2015-79—released November 19, 2015, by the Treasury Department and IRS—announces their intention to issue regulations relating to inversion transactions and post-inversion restructuring transactions. Notice 2015-79 provides for rules that: Limit the ability of domestic companies to effect an inversion Limit the advantages of certain post-inversion restructuring transactions Clarify certain… – Continue reading
The creation of the Group of Twenty (G20) was believed to serve as a remedy to the harsh realities of the world today. The initial formation of the Group of Seven G7 could do little to avert pertinent challenges both the developing and the developed nations face frequently. So a… – Continue reading
The Chancellor could target capital gains tax for extra revenue when he delivers his Autumn Statement next week as gains from investors and landlords hit their highest on record in the past financial year, accountants suggest. George Osborne, who will unveil his spending plans for Britain next Wednesday, is under… – Continue reading
Company used actresses including former Alan Partridge star to bombard financial sector workers with cold calls The grey Basinghall Street office building, in the heart of London’s City financial district, gives few clues about the frenzy of activity that was going on inside. But for years, this was the home… – Continue reading
This week, the IRS released Notice 2015-79, which describes intended regulations to cover inversions and related transactions. Colloquially, an inversion refers generally to a transaction in which a domestic corporation is acquired by a foreign corporation. I.R.C. §§ 367 and 7874 operate as the anti-inversion rules; § 367 deals with… – Continue reading
The blacklisting saga did not start with Spain, but it did end with a timely correction related to it. Harbour Times explains how Hong Kong was taken off the Spanish tax haven list. Friends of Harbour Times would be familiar with the remedy of Hong Kong being named a non-cooperative… – Continue reading
The European Commission has requested that Spain amend its rules on the taxation of certain income obtained by foreign non-profit entities and of certain contributions to such entities. The crux of the Commission’s complaint is that foreign non-profit entities that derive income from Spain, but which are established in another… – Continue reading
Wrap platforms are increasingly evolving to meet the needs of investors looking offshore for growth, with the addition of managed funds, ETFs and SMAs, Cameron Garrett writes. Traditionally, the investment portfolios of Australians have been heavily weighted towards investing in Australian equities. This is an interesting statistic, especially as the… – Continue reading
The UK has climbed to 15th place in the latest World Bank Group and PwC Paying Taxes report, and is third top among G-20 countries, behind Saudi Arabia and Canada. Paying Taxes 2015 measures how burdensome a country’s tax regime is on the average medium-sized company. The report found that… – 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
The UK’s All-Party Parliamentary Group on Responsible Tax will on November 23 launch a public consultation on the impact of the OECD’s base erosion and profit shifting on the tax rules in place in the UK. Led by Margaret Hodge, the former Chair of the UK’s Public Accounts Committee, the… – Continue reading
Three Swiss banks will pay a total of more than $81 million to the U.S. Justice Department to avoid possible prosecution for helping Americans to evade taxes, the department said on Thursday. The three banks, the Swiss unit of BNP Paribas SA (BNPP.PA); KBL (Switzerland) Ltd (LU0092281103.BR); and Bank CIC,… – Continue reading
The Ministry of Finance issued a regulation with guidance concerning the procedures for the exchange of financial information with other jurisdictions and countries. The “automatic exchange of information” (AEOI) process will allow for the exchange of data to verify and confirm compliance with tax obligations, including information from financial institutions…. – Continue reading
Introduction Withholding obligation Proposed amendment Comment Introduction The 2015 Taxation Laws Amendment Bill proposes an amendment to Section 35A of the Income Tax Act (58/1962), dealing with withholding percentages from payments due to non-resident sellers of immovable property situated in South Africa. The proposed amendment raises interesting questions regarding compliance… – Continue reading
The US Department of the Treasury said that the United States introduced new restrictions to prevent US-based multinationals from restructuring after mergers to establish foreign parent companies in order to avoid paying taxes. WASHINGTON (Sputnik) — The United States introduced new restrictions to prevent US-based multinationals from restructuring after mergers… – Continue reading
MUMBAI: India’s forthcoming budget may draw from some of the recommendations, especially in the realm of transfer pricing, contained in the final package of ‘Base Erosion and Profit Shifting’ (BEPS) measures, rolled out in October. Certain anti-abuse measures, such as thin capitalization, which for tax purposes disallows interest payments beyond… – Continue reading
Swaziland will implement the United States Foreign Accounts Tax Compliance Act FATCA 2010 by collecting tax from US individuals and companies operating in the country.APA learnt on Friday that the act, whose objective is the facilitation of the exchange of financial information between US and other countries where its citizens… – Continue reading
Introduction Tax exemptions Eligibility Trademarks Calculating tax benefits Eligible costs Introduction At the end of 2014, the government presented the 2015 budget, which introduced a ‘Patent Box’ tax regime in line with similar schemes adopted in other European countries. It applies to corporate income tax and regional tax on productive… – Continue reading
THE United States of America (USA) wants all companies of US origin, individuals and body corporates that are resident in Swaziland to report their financial information in their home country, the USA. This development is a result of Swaziland government announcing that it will implement the United States Foreign Account… – Continue reading
Introduction Facts Decision Introduction The European Court of Justice (ECJ) recently ruled that the system of interim taxation for Austrian private foundations does not comply with EU law.(1) A special feature of private foundations is the so-called ‘interim tax’ – a type of corporate income tax. Pursuant to Section 13(3)… – Continue reading
On 18 June 2013, the Progressive led government issued a press release titled, “Cayman’s Action Plan Includes Beneficial Ownership”. The press statement came on the heels of the UK taking over the Presidency of G8, at the 17-18 June 2013 G8 Summit in Northern Ireland. The most interesting part of… – Continue reading
The European Commission has asked the German Government to amend its inheritance tax (IHT) law after finding that current rules discriminate against those who are not resident in Germany for tax purposes in certain situations. Under German IHT law, a special maintenance allowance is granted to surviving spouses or registered… – Continue reading
Ownership of Kildrummy Estate creates legal block for police investigators POLICE INVESTIGATIONS into wildlife crime failed in the face of a bureaucratic nightmare identifying the landowner behind a complex structure of offshore land secrecy. The conviction of gamekeeper George Mutch for wildlife crimes committed in 2012 on Kildrummy Estate opened… – Continue reading
Chinese authorities have uncovered the country’s biggest underground banking case involving transactions totalling more than 410 billion yuan ($64 billion), official media reported, part of a drive to combat illegal capital outflows. The investigation, which started in September and focused on the costal province of Zhejiang, found that dozens of… – Continue reading
