Category: Regulatory

Mexico: Latin American Tax: Special Report

Mexico is experiencing a rough time, economically speaking at the moment, but hopes are high for better times ahead. With new tax laws and a relatively young government, these are interesting times for this country. To find out more about how the recent tax reforms will affect Mexico and the… – Continue reading

South African type controversy in Sri Lanka

(October 28, 2015, Colombo, Sri Lanka Guardian) “I and my family members have no secret accounts in Dubai banks,”said the Rajapaksa ‘Crown Prince’ Namal when the media published reports about a secret account in a Dubai bank of a son of a VVIP. The media reports stated that the Sri… – Continue reading

Fund industry must act now or face crunch time in the final countdown to Global FATCA, says Linedata

With the starting line for implementation only two months away, Justin Hayes, product manager at Linedata, the leading international software and technology provider, says fund administrators and investment managers need to get to grips with the OECD’s Common Reporting Standards, dubbed ‘Global FATCA’, before it’s too late. “Financial institutions in… – Continue reading

EU: Special Committee on Tax Rulings votes recommendations

Parliament’s Special Committee on Tax Rulings recommended measures to make corporate taxes in the EU fairer and more transparent, after eight months of fact finding, in a vote Monday evening in Strasbourg, EU News reports. The report – prepared by co-rapporteurs Elisa Ferreira and Michael Theurer – was approved by… – Continue reading

ITALY: INCOME TAX TREATY WITH HONG KONG ENTERS INTO FORCE

An income tax treaty between Italy and Hong Kong has entered into force, with the exchange of instruments of ratification. The official communication of the Italian Ministry of Foreign Affairs announcing this exchange was published in the official journal on 26 October 2015. BLACK LIST, WHITE LIST Italy’s “black list”… – Continue reading

Thousands of Defiant Foreign Investment Companies Probed

TEMPO.CO, Jakarta – Finance Minister Bambang Brodjonegoro said that a total of 4,000 foreign investment (PMA) companies were under scrutiny over tax evasions. “Mostly, [the companies] practiced transfer pricing,” Bambang said at his office on Tuesday, October 27, 2015. Bambang explained that the probe was not about the potential of… – Continue reading

Australia out of step with global corporate tax rate trends

Australia’s corporate tax rate is higher than the global average, according to KPMG’s 2015 global tax rate survey, SmartCompany reports. While Australia’s corporate tax rate currently sits at 30 per cent, the global average sits at 23.68 per cent. The United States has the highest corporate tax rate at 40… – Continue reading

More paper work for MF investors from Nov 1

With effect from November 1, mutual fund investors will have to make additional declaration pertaining to foreign account tax compliance act (FATCA) and common reporting standards (CRS) for all new accounts opened, failing which their applications will get rejected. Under FATCA and CRS, Indian financial institutions will be required to… – Continue reading

Linedata: The time is now for CRS

Investment managers and fund administrators should act now in order to be prepared for the Organisation for Co-operation and Development (OECD) Common Reporting Standard (CRS) ahead of the start of the first reporting period, according to Justin Hayes, product manager for Linedata. The CRS, sometimes called a global version of… – Continue reading

Fighting tax evasion: EU and Liechtenstein sign new tax transparency agreement

Under the new agreement, Liechtenstein and EU Member States will automatically exchange information on the financial accounts of each other’s residents from 2017. Pierre Moscovici, Commissioner for Economic and Financial Affairs, Taxation and Customs, said: “Today the EU and Liechtenstein are sending out a clear message: we are partners in… – Continue reading

Belgian tax official reveals details on new transfer pricing documentation requirements and BEPS plans

In a BEPS seminar organised by the Federation of Enterprises in Belgium this week, with a special focus on the practical consequences for Belgian enterprises, a representative of the Belgian Ministry of Finance, Steven Van Elsuwe;, provided more details on the new legislative proposals that have been prepared so far,… – Continue reading

Transfer pricing makes big splash on global taxes

Multinationals have generated big-time revenues with its subsidiaries spread all over the world, which means huge profits and that’s taxable income. In recent years, a number of conglomerates – Amazon, Apple, Google and Starbucks – have engaged in so-called profit-shifting (profit allocation) via transfer pricing methods to pay minuscule taxes…. – Continue reading

Fund industry must act now or face crunch time in the final countdown to Global FATCA

Sunday 1st November will mark two months until the start of the first reporting period under the OECD’s Common Reporting Standards (‘Global FATCA’). Justin Hayes, product manager at Linedata, comments on why there is now no time to waste for investment managers and fund administrators to prepare for the burdensome… – Continue reading

U.S. corporate income tax is self-defeating

For many years, policymakers have criticized the strategies that American corporations use to reduce their taxes by shifting income and capital offshore. The impetus behind these strategies is the U.S. corporate income-tax rate — at 35 percent, the highest of any industrialized nation, easily surpassing countries such as the U.K…. – Continue reading

FATCA, bilateral meeting Pasquale Valentini – John R. Phillips

The Ambassador of the United States of America, John R. Phillips, today in the Republic for the signing of the intergovernmental FATCA, met this morning at Palazzo Begni, the Secretary of State for Foreign Affairs, Pasquale Valentini. A bilateral especially focused on the issues – all current – which has… – Continue reading

Barbados and Slovakia sign tax agreement

A DOUBLE TAXATION agreement was signed between Barbados and the Slovak Republic this afternoon. Minister of International Business Donville Inniss signed on Barbados’ behalf at a ceremony at Hilton Barbados. It is the 37th treaty signed between Barbados and another territory while Barbados became the 74th country to sign an… – Continue reading

Brazilian wealth seeks Cayman deals in complex environment

(CNS Business): The use of Cayman Islands funds as a wealth management tool for high net worth Latin American families was debated last week at the STEP LatAm Conference in Brazil, where kidnapping is a constant worry for the wealthy and demand for outbound investments is fuelled by privacy and… – Continue reading

UPDATE 1-Indonesia’s Lippo to shift REITs from Singapore to Indonesia-CEO

JAKARTA, Oct 28 (Reuters) – Indonesian conglomerate Lippo Group plans to shift two real estate investment trusts (REITs) with 35 trillion rupiah ($2.6 billion) in assets from Singapore to Indonesia next year in order to benefit from new tax breaks offered by Jakarta. Lippo’s move could be followed by at… – Continue reading

Russia Wants to Put Austria on Tax Haven List

Austria is on the preliminary list of 119 countries and territories which from the point of view of Russian authorities don’t guarantee the exchange of tax information with Russia. If the document is implemented, as planned, in form of a resolution, Russian investors in Austria will face massive tax disadvantages… – Continue reading

MF investos have to give info under FATCA from Nov

Come November 1, mutual fund investors will have to provide details and declaration pertaining to Foreign Account Tax Compliance Act (FATCA) and common reporting standards (CRS) for all new accounts opened, failing which fund houses are likely to reject their applications. While some fund houses have already started this process… – Continue reading

HUNGARY: IMPLEMENTING TRANSFER PRICING-RELATED BEPS ACTIONS

Action 13 of the final package of reports issued by the Organisation for Economic Cooperation and Development (OECD) under the base erosion and profit shifting (BEPS) project focuses on a company group’s global value chain and transfer pricing policy, and introduces a standardized three-tiered approach to transfer pricing documentation—core documentation… – Continue reading

FRANCE: RECENT TRENDS IN TRANSFER PRICING, SURVEY

The European Commission recently published new rulings, the OECD published its base erosion and profit shifting (BEPS) final reports, and many countries are reviewing and reinforcing their transfer pricing rules—and France is no exception. Tax professionals in France have observed certain recent trends with regards to transfer pricing. The current… – Continue reading

Ireland’s Finance Bill 2015 – key changes for international companies and financial institutions

Following the recent Irish budget statement (the “Budget”), the Finance Bill 2015 (the “Bill”) has been published and it implements the changes announced by the Irish Minister for Finance (the “Minister”). The Bill includes additional detail on: the new knowledge development box (“KDB”); and Ireland’s implementation of country by country… – Continue reading

New IRS regulations for mixed-use projects financed with tax-exempt bonds have practical importance

On October 27, 2015 the U.S. Treasury Department and Internal Revenue Service published final regulations concerning the treatment of “mixed-use” projects financed with tax-exempt bonds. These new regulations have significant and immediate importance for tax planning and tax compliance of tax-exempt bond issuers and borrowers. A copy of the new… – Continue reading

It’s Huffed And It’s Puffed, But HSBC Is Likely To Remain In The UK

After teasing the UK financial community — and the government — with a thinly-veiled threat to decamp from Britain, HSBC has continued to stoke speculation that it’s looking for more hospitable headquarters. Back in April, HSBC announced a review of whether to quit the UK, a somewhat provocative statement, coming,… – Continue reading

AUSTRALIA: TRANSFER PRICING, INTERCOMPANY FINANCING TRANSACTIONS

A decision by the Federal Court of Australia has key implications for transfer pricing of intercompany financing transactions, as well as implication for other broader intercompany arrangements. The case concerns the transfer pricing implications of an intercompany loan agreement between an Australian taxpayer and its U.S. subsidiary (CFC) and whether… – Continue reading

IRS urges Americans living in Canada to come clean after courts allow CRA to share account information with U.S.

The Internal Revenue Service is encouraging all non-compliant U.S. citizens, including those among the 1 million Americans who are resident in Canada, to take advantage of its voluntary disclosure programs initiated in 2009 and 2012. The move comes just a few weeks after Canadian courts refused to issue injunctions prohibiting… – Continue reading

Ireland cuts tax for IP profits

Ireland has announced a new 6.25 per cent corporate tax rate for intellectual property research Ireland’s 12.5 per cent corporate tax rate is already one of the lowest in Europe, Economia reports. Now, companies investing in research and development (R&D) will be able to avail of the even lower rate… – Continue reading

Ethiopia, Switzerland keen to bolster ties

Ethiopia and Switzerland have expressed their commitment to strengthen bilateral relations covering various regional and global issues of common interest, according to a joint statement issued on Tuesday by the two countries.The communiqué was released after talks between Swiss President Simonetta Sommaruga and Ethiopian Prime Minister, Hailemariam Desalegn, on Tuesday… – Continue reading

Managing The Changing Tax Landscape: The OECD’s BEPS Recommendations Will Impact Every Multinational

The global climate for international tax is rapidly changing. The OECD, the EU and tax authorities around the world have focused attention on tax planning implemented by leading multinational companies. The OECD believes that tax planning and related structures lead to an annual revenue loss of US$100-240 billion. Since 2013,… – Continue reading

Tony Wickenden: The fine line between tax avoidance and evasion

Government action against tax avoidance has made the headlines on numerous occasions over the past few years, with significant developments in litigation, legislation and early tax collection, via a combination of follower notices and accelerated payment notices. Add to this the expansion of the disclosure of tax avoidance schemes, hallmarks… – Continue reading

Iranian ambassador takes office in Uzbekistan

Uzbekistan’s Foreign Minister Abdulaziz Kamilov received the copies of credentials of Iran’s new Extraordinary and Plenipotentiary Ambassador Bahman Agharazi Dormani, Uzbek Foreign Ministry said. During the meeting, the sides discussed the status and priority areas of Uzbek-Iranian cooperation in political, trade, economic, cultural, humanitarian and other spheres. They reiterated mutual… – Continue reading

Guernsey: A Guide To Guernsey’s New Non-Resident Capital Gains Tax Rules

The new non-resident capital gains tax came into force in Guernsey on 6 April 2015. The rules intend to capture disposals of residential property in the United Kingdom by all non-residents. These notes provide a summary of who and which property is affected, and describe how a new UK tax… – Continue reading

Banks Et Al Brace For More Financial Account Information Reporting

On the heels of extensive preparation for the implementation of FACTA in St. Kitts and Nevis, banks and other financial institutions are now starring down the barrel of additional financial accounts information reporting on a wider scale. The Organization for Economic Co-operation and Development (OECD) has proposed a global version… – Continue reading

Your Taxes: Exporters beware of sales agents

On October 5 the OECD published recommended measures that purport to tackle BEPS – Base Erosion Profit Shifting. Exporters around the world need to take note of the latest recommendations of the OECD. Any business that uses overseas agents or warehouses should take note. A company resident in country A… – Continue reading