Introduction On 5 October 2015, the OECD delivered the final package (“Final Package”) of its comprehensive Action Plan on Base Erosion and Profit Shifting (“BEPS“). This marks a culmination of a process that started in September 2013, when the Group of 20 (“G20”) Leaders first endorsed the Action Plan on… – Continue reading
The Irish Government has published an update on its International Tax Strategy, in which Finance Minister Michael Noonan stresses that the country is “well positioned for the post-base erosion and profit shifting (BEPS) world.” According to Noonan, “This is not something that has happened by accident. Difficult but necessary changes… – Continue reading
Kolkata Bench of Tribunal in the case of Outotec GmbH v. DDIT : ITA No. 431 & 432 of 2014 & 283 of 2015 (Kol) dealt with the issue as to whether the sale of equipment, designs and drawings would be taxable under the provisions of the India-Germany DTAA and… – Continue reading
A former Valparaiso businessman who federal prosecutors say lived in Canada for seven years to avoid an obstruction and perjury trial has been sentenced to not quite two years in prison, after finally admitting that he lied under oath to protect an offshore account worth millions of dollars from creditors…. – Continue reading
JAKARTA, Oct 19: As ‘tax-havens’ are now routing some 60 per cent of international trade, multinational corporations (MNCs) have become more aggressive in evading taxes. As the volume of global trade was estimated at $23.5 trillion in 2013, of which $18.5 trillion was trade in goods and the rest was… – Continue reading
The Chartered Institute of Taxation has criticized the UK Government for proceeding with plans for a strict liability criminal offense for failing to declare offshore taxable income or gains. Under the proposals, magistrates would be given the power to impose an unlimited financial penalty and a custodial sentence of up… – Continue reading
Australia’s new Serious Financial Crime Taskforce (SFCT) is to launch investigations into serious international tax evasion and “phoenix activity” over the next two years. The SFCT has been operational since July 1 and, as of October 14, there are eight matters under investigation. More than 580 tax audits have been… – Continue reading
KEY POINTS What is the issue? Guernsey will be required to gather data for the calendar year 2016 for reporting under the Common Reporting Standard (CRS) in 2017. What does it mean for me? Practitioners should be aware that due diligence and reporting procedures are set to be amended and… – Continue reading
The number of banks with deferred prosecution agreements with the U.S. government keeps growing. The subject is tax evasion involving American account holders. Today, under FATCA, banks everywhere want to know if you are compliant with the IRS. And the IRS keeps updating its list of foreign banks where offshore… – Continue reading
Just one day after the October 15 deadline for filing personal income tax returns on extension, the Internal Revenue Service issued a strongly-worded warning to non-compliant taxpayers: take action now to fix your problem, or face serious consequences. At the same time, the IRS revealed, for the first time, that… – Continue reading
With more than 54,000 US taxpayers participating in the Offshore Voluntary Disclosure Program (OVDP) since 2009, the Internal Revenue Service (IRS) announced that it has collected more than USD8bn from this initiative to date. The IRS added that more than 30,000 taxpayers have also used the streamlined filing compliance procedures… – Continue reading
A little over a week ago the British parliamentarian, Sir Eric Pickles – a cabinet member until May of this year and a former Chairman of the Conservative Party – told the London Guardian that the British Prime Minister, David Cameron, was determined to have the BVI and the Cayman… – Continue reading
The rising wealth of Asia Pacific nations, including Singapore, means more and more people have looked internationally for opportunities to invest in overseas property markets. Recent stock market events have shown the importance of a diversified portfolio capable of riding out the storm when economic conditions put immense pressure on… – Continue reading
Cyprus will as of January 1, 2016 have a new tool in its arsenal to identify monies hidden abroad as the island will begin implementing the Common Reporting Standard (CRS), the Institute of Certified Public Accountants said. The CRS is formally referred to as the Standard for Automatic Exchange of… – Continue reading
UK Labour party leader Jeremy Corbyn’s adviser wants Irish corporate taxes hiked Ireland is viewed as a “pariah state” by the international community due its corporate taxation policies, according to the man behind many of Jeremy Corbyn’s economic ideas. Economist Richard Murphy also said that Ireland should bring its corporate… – Continue reading
Concerned about the impact of tax havens, world powers are tightening the noose on multinationals seeking tax advantages. India wants changes to its tax treaty with Mauritius, forcing the island’s new government to re-examine its business model and focus elsewhere. There is debate in the new government, which took office… – Continue reading
HONG KONG: Pakistan and Hong Kong SAR signed a landmark agreement for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income on Friday, a statement said. The agreement once implemented by Pakistan and Hong Kong SAR would encourage investment and business between the… – Continue reading
With more than 54,000 taxpayers coming in to participate in offshore disclosure programs since 2009, the Internal Revenue Service is reminding U.S. taxpayers with undisclosed offshore accounts that they should strongly consider existing paths established to come into full compliance with their federal tax obligations. Both the Offshore Voluntary Disclosure… – Continue reading
A new Protocol to the income tax treaty between Indonesia and the Netherlands was signed 30 July 2015 and will be effective 31 days after formal approval and ratification by both governments. Among the measures contained in the Protocol are revisions to the withholding tax rates on dividend payments. The… – Continue reading
The French Finance Minister, in an October 2015 press release, welcomed the agreement reached by the EU Finance Ministers on the introduction of provisions for the automatic exchange of information on cross-border tax rulings and the publication of the OECD reports on base erosion and profit shifting (BEPS). The French… – Continue reading
The details of the recently signed Income Tax Treaty between Jersey and Rwanda have become available. The treaty was signed on 26 June 2015. The treaty will come into force after the two countries exchange ratification instruments. The provisions of the treaty will have effect from 1 January of the… – Continue reading
Margrethe Vestager, the EU’s competition commissioner, looks set to launch the international community’s most punitive attack on corporate tax avoidance as early as next Wednesday, with rulings that could impose heavy costs on multinationals, reports the Financial Times. Ms Vestager is understood to have postponed her first trip to China… – Continue reading
The Luxembourg Finance Minister Pierre Gramegna Wednesday announced a tax amnesty measure for income from Luxembourg which has not been declared, a first in the Grand Duchy, reports the Luxemburger Wort. He announced an action to “launder” tax evaders during the presentation of the draft budget 2016 before the Chamber… – Continue reading
Several close associates of Russian President Vladimir Putin may have benefited from Deutsche Bank AG trades that are now coming under the glare of U.S. prosecutors, according to people familiar with the matter. The U.S. Department of Justice is investigating whether Germany’s biggest bank properly vetted as much as $6… – Continue reading
The September 29 2014 tax reforms (Law 20,780) introduced new provisions to the Tax Code (Decree-Law 830 1974, as amended), which empower the Tax Department to challenge transactions that have been carried out with the aim of avoiding taxes. These provisions introduce a general anti-avoidance rule for the first time…. – Continue reading
Government has made it easier for Australian companies to avoid paying tax, says Greens spokesperson Adam Bandt Greens MP Adam Bandt has lambasted the passing of new laws that ensure tax details of Australian-owned private companies are exempt from public disclosure rules, saying the government has made it easier for… – Continue reading
The central government is stepping up its anti-graft drive by cracking down on illegal lending and money-laundering operations in a bid to prevent outbound flows of stolen assets. The Ministry of Public Security says “black banks” and illegal currency exchanges have facilitated the flights of a number of former government… – Continue reading
BENGALURU: The Karnataka tax department’s recent proposal to e-commerce firms, considered a face-saver, may not be legally tenable, tax experts said citing High Court and apex court rulings. The Karnataka commercial taxes department, last week, asked e-commerce firms including Amazon, Flipkart and Snapdeal to deduct 1% of the money payable… – Continue reading
The following editorial appears in Friday’s Yomiuri Shimbun: International cooperation must be bolstered to close tax loopholes that can be exploited by multinational business corporations. The Group of 20 major economies and the Organization for Economic Cooperation and Development have worked out new international taxation rules to clamp down on… – Continue reading
The Department of Justice announced today that BBVA Suiza S.A. has reached a resolution under the department’s Swiss Bank Program. “Swiss banks such as BBVA Suiza S.A. are providing detailed information regarding their efforts to conceal U.S.-related accounts, and are turning over the names of individuals and entities that facilitated… – Continue reading
We are entering a new world of tax revenue wars, and no one can say who will emerge as the victor. All we know is that there will be tension over the next five years as governments seek to implement the global plan to end to tax havens from Luxembourg… – Continue reading
South Africa is allowing MTN potentially lucrative tax credits on money sent from its African operations to a letterbox company in Mauritius. Last week, amaBhungane and Finance Uncovered, a global reporting project, exposed how MTN’s African subsidiaries send billions in management fees to MTN International in Mauritius. The Mauritian entity… – Continue reading
Hong Kong (HKSAR) – The Hong Kong Special Administrative Region Government noted that the European Commission (EC) updated its webpage on October 12 on the listing of non-cooperative tax jurisdictions amongst the European Union (EU) Member States. After the Government’s liaison and clarification with relevant authorities, the technical error of… – Continue reading
(Bloomberg) — The People’s Bank of China is considering starting direct trading between the yuan and the Swiss franc, according to three people with direct knowledge of the matter. The Swiss franc would become the seventh major currency to be exchangeable directly for yuan in Shanghai, joining the U.S., Australian… – Continue reading
Ireland is growing as a global maritime business hub and its strengths in asset leasing could provide an alternative source of finance for shipping, according to a new report commissioned by the Irish Maritime Development Office and authored by tax advisors KPMG and legal firm Dillon Eustace, reports Splash. The… – Continue reading
A resolution was published in Panama’s official gazette in September 2015 replacing and “repealing” an August 2015 resolution, concerning how taxpayers may seek a ruling from the tax authorities as to whether benefits under income tax treaties for the avoidance of double taxation apply to the taxpayer’s specific transaction or… – Continue reading
With Medtronic being one of Ireland’s largest employers, analysts say there is a new incentive for the medical device maker to prioritize its Dublin headquarters for R&D. In the eyes of developed nations, Ireland has become notorious for baiting multinational firms to its land with the offer of friendly tax… – Continue reading
The Internal Revenue Service (IRS) has released a revised October 2015 version of its Publication 597, which provides information on the United States-Canada double taxation agreement (DTA), reports Tax News. A number of DTA provisions that most often apply to US citizens or residents who may be liable for Canadian… – Continue reading
In a summary judgment released on September 16, 2015, the Federal Court of Canada examined and disposed of the non-constitutional arguments in the Hillis and Deegancase[1] generally finding that the automatic data collection and disclosure of taxpayer information to the United States by Canada pursuant to the Canada-U.S. Intergovernmental Agreement… – Continue reading
PR chief, who pocketed more than £11m from his agency last year, attacks tax system for foreign-owned companies Matthew Freud has attacked the pittance Facebook pays in UK tax after footing a bill for almost £3m last year, as he pocketed more than £11m from his PR and marketing agency… – Continue reading
Golden visa EU citizens may freely register as residents in Portugal. However, non-EU citizens may also obtain residence in Portugal if they obtain a ‘golden visa’ by participating in investment activity and fulfilling certain requirements. Requirements Obtaining a golden visa requires one of the following types of investment: acquisition of… – Continue reading
Permanent Establishment Based on the new treaty the definition of permanent establishment also includes a building site or construction or installation project or any supervisory activities in connection with such site or project constitutes a permanent establishment only if it lasts more than 9 months. Dividends The withholding tax rate… – Continue reading
Finance professionals will play a key role in dealing with changes brought about by a global project to combat corporate tax avoidance. A GLOBAL effort to tackle the problem of companies that attempt to reduce their tax burden by exploiting loopholes in tax rules will impact the way global businesses… – Continue reading
The Canada Revenue Agency (CRA) rents office space from a Vancouver-based property developer – a company that exploits offshore tax havens in Liechtenstein, the British Virgin Islands and Channel Islands. Larco Investments Ltd. owns three buildings in Montreal, Calgary and Edmonton where they rent office space to the CRA. Larco… – Continue reading
The United States has rejected India’s claim that schemes such as Atal Pension Yojana, Rashtriya Swasthya Bima Yojana, Employees Provident Fund Organization and others should be taken into account while determining the size of population covered under social security schemes. In recently resumed talks on Totalization Pact, the US said… – Continue reading
In just over two months, thousands of U.S.-based financial institutions will face new requirements for sharing financial information. These businesses should get ahead of the deadline and start preparing for the impact these rules will have on their operations and bottom lines. The Organisation for Economic Co-operation and Development’s new… – Continue reading
MINSK, 15 October (BelTA) – The House of Representatives of the National Assembly of Belarus ratified the Belarus-Georgia intergovernmental agreement on avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and capital on 15 October, BelTA has learned. It is expected that the agreement… – Continue reading
x At present, says the Government, serial avoiders find themselves in no worse a position than someone who has used only one failed avoidance scheme and has decided not to do it again. They face no additional deterrent to stop them persistently seeking to circumvent the will of Parliament. With… – Continue reading
Starbucks Corp. and a Fiat Chrysler Automobiles NV unit are set to be first in the firing line as European Union regulators issue a series of rulings over tax breaks for global companies, including Apple Inc. The EU may issue decisions against Starbucks and Fiat as soon as next week… – Continue reading
Do your individual clients howl about paying too much federal income tax? Just wait until you get an earful from your business clients. Advertisement A new report from the Tax Foundation, a conservative-leaning think tank located in our nation’s capital, found that the United States has the third-highest marginal corporate… – Continue reading
