Category: Regulatory

Dutch Tax Bill 2016: what will change?

The Dutch government presented its Tax Bill 2016 on 15 September 2016. Three elements of this bill could specifically affect multinationals, international investors and investment funds with Dutch headquarters or group companies: The anti-avoidance rules in respect of non-resident taxation of foreign corporate shareholders and the dividend withholding tax treatment… – Continue reading

Cyprus: Cyprus Tax Law: New Non Domiciled Rules And Notional Interest Deduction

This summer brought some very significant amendments to the Cyprus tax laws, further enhancing Cyprus’ favourable tax regime. On 17 July 2015, the following laws were amended: The Special Defense for Contribution law No. 117(I) of 2002 as amended; The Income Tax Law No 118(I) of 2002 as amended; and… – Continue reading

HMRC prevails in trial against £200m double taxation loophole

HM Revenue and Customs (HMRC) has succeeded against a £200 million tax avoidance scheme which exploited the UK’s double taxation agreement with the Isle of Man, whereby people are not taxed on the same income in both the UK and the Isle of Man. Those who took advantage of the… – Continue reading

Joe Tynan: International tax changes on the horizon

As Noonan moves to stimulate domestic growth we need to think about the global debate The Irish economy is now in better shape than at any time since the beginning of the financial crisis. After many years of tough austerity measures, last year’s budget marked a turning point where Minister… – Continue reading

MEPs express disappointment in tax ruling directive

Members of the European Parliament’s Economic and Monetary Affairs Committee have described last week’s agreement on a directive for the automatic exchange of information on tax rulings as a “missed opportunity”. The European Commission said last week that the Economics and Financial Affairs Council of the European Union (ECOFIN) had… – Continue reading

Canada: Central Management And Control Determines The Residency Of A Trust For Provincial Tax Purposes

Individuals and families whose tax plans include trusts should take note of the recent decision of the Supreme Court of Newfoundland and Labrador in Discovery Trust v Minister of National Revenue (“Discovery Trust”)1 – the first case to deal with the issue of the residency of a trust for provincial… – Continue reading

Foreign investment and tax: what the ATO’s expanded armoury means for foreign investment into Australia

A series of recent developments means that tax is now a key part of the Australian foreign investment regime and the foreign investment rules have significantly more bite. When determining whether a foreign investment proposal is “contrary to the national interest”, the Foreign Investment Review Board (FIRB) actively considers the… – Continue reading

David Gauke Outlines UK’s Response To BEPS Reports

David Gauke, the Financial Secretary to the UK Treasury, has said that international agreement on the OECD’s base erosion and profit shifting (BEPS) reports “is just the start of the process of reform.” In a speech to EY’s 34th Annual International Tax Conference, Gauke said: “To ensure timely, effective implementation,… – Continue reading

BEPS: CURRENT STATUS OF IMPLEMENTATION IN VARIOUS COUNTRIES

Last week’s OECD release of the final package of measures for a coordinated international approach to the reform of the international tax system, under the OECD/G20 base erosion and profit shifting (BEPS) project, marks the end of the discussion and recommendation phase, and the start of the implementation and practical… – Continue reading

EU states have few concerns over Gibraltar tax regime

The number of EU countries that regard Gibraltar’s tax regime as harmful has dropped from nine to seven, according to updated information released by the European Commission yesterday, report the Gibraltar Chronicle. The Commission database collects information on how the EU’s 28 members view other countries’ tax regimes. When it… – Continue reading

Guernsey Association of Compliance Officers keeps Guernsey out in front

The Guernsey Association of Compliance Officers (GACO) October seminar covered the introduction of the Information Gateway Online Reporter (IGOR), an online portal for the purpose of collecting and exchanging Automatic Exchange of Information. https://igorforum.digimap.gg GACO chairman and Carey Olsen partner Mark Dunster said it is a key objective for the… – Continue reading

The Algeria and the United States sign an agreement on sharing tax information

The Algeria and the United States signed Tuesday in Algiers an intergovernmental agreement on the sharing of tax information between the two countries and to promote financial transparency and the strengthening of bilateral and international fight against tax evasion. The agreement, first of its kind concluded by the US with… – Continue reading

Federal Council adopts dispatch on double taxation agreement with Oman

Bern, 14.10.2015 – Today, the Federal Council adopted the dispatch on the new double taxation agreement (DTA) with Oman and submitted it to Parliament for approval. The agreement will promote bilateral economic relations and contains provisions on the exchange of information upon request in accordance with the OECD standard. Aside… – Continue reading

FACTA and the New Frontier in Offshore Reporting Enforcement

FATCA was passed to prevent U.S. citizens from evading tax by focusing primarily on foreign financial institutions with U.S. account holders. The Foreign Account Tax Compliance Act (FATCA) was enacted as part of the 2010 Hiring Incentives to Restore Employment Act, and its provisions became effective as of 7/1/14. FATCA… – Continue reading

Conference Focuses on Intersection of Tax Law and Citizenship

Tax experts from the United States, United Kingdom, Canada, Brazil and Israel spoke at a two-day conference at Michigan Law about the challenges of the Foreign Account Tax Compliance Act (FATCA) and a multitude of other issues at the intersection of the law of taxation and citizenship. Panel discussions at… – Continue reading

Newly signed CAAs facilitate FATCA data exchange between U.S.-U.K & Australia

To facilitate the exchange of Foreign Account Tax Compliance Act (FATCA) data under the intergovernmental agreements (IGAs) with Australia and the U.K., the U.S. Competent Authority has signed Competent Authority Arrangements (CAAs) with the Competent Authority of each country, announced IRS officials on September 24. The CAAs are the first… – Continue reading

OECD lists the top 10 toughest countries on tax evasion

The Organisation for Economic Cooperation and Development (OECD) is behind the new measures to automatically exchange tax information between nations and manage the differences on how tax issues are dealt with. Top ten countries The contractor management specialist CXC Global has identified the ten countries with the most aggressive approach… – Continue reading

ANCA Welcomes Congressman Ted Lieu’s Advocacy for a U.S.-Armenia Double Tax Treaty

LOS ANGELES—The Armenian National Committee of America – Western Region (ANCA-WR) is expressing its appreciation to Congressman Ted Lieu for authoring a letter to U.S. Treasury Secretary Jacob Lew in support of a U.S.-Armenia Double Tax Treaty. The accord, if concluded, would, by limiting the prospect of double taxation, remove… – Continue reading

Commerzbank agrees with prosecutors on fine for tax evasion -report

Oct 14 Germany’s Commerzbank has agreed with Cologne prosecutors to pay 17 million euros ($19.49 million) of fines for tax evasion, Sueddeutsche Zeitung reported on Wednesday, without citing the source of the information. Germany’s second biggest bank by market value is the country’s third lender after Hypovereinsbank and HSH Nordbank… – Continue reading

CBDT inks 4 more advance pricing pacts

MUMBAI: The Central Board of Direct Taxes (CBDT) on October 13 signed four unilateral advance pricing agreements (APAs), including India’s second APA with a rollback provision. The nature of the transactions covered under these agreements varied from software development to share price valuation. According to government sources, the total number… – Continue reading

Brazil: Tax Information Exchange Agreement With Brazil

On December 29, 2014, Uruguayan Congress ratified the Tax Information Exchange Agreement entered into between Uruguay and Brazil (“the TIEA”). The TIEA is patterned after the OECD Model. The Contracting Parties undertake to cooperate with each other through the exchange of any information which might be foreseeably relevant for tax… – Continue reading

A Pakistani, who has failed in Pakistan, combating tax evasion abroad

ISLAMABAD: Talent is universal, opportunities are not. A Pakistani is combating tax fraud in America and Russia using the same technology he earlier employed in Pakistan discovering 3.5 million out-of-tax-net rich individuals. Unlike the appreciation of his efforts abroad, the data he compiled in Pakistan has been thrown into the… – Continue reading

Max Biaggi Injured in MTB Crash, Uncertain for Qatar, also Under Investigation for Tax Fraud

After confirming that he would take part in the final round of the 2015 World Superbike Championship in Qatar, Max Biaggi’s presence at Losail this weekend is no longer a sure thing. The multiple World Champion has taken a fall from his mountain bike and sustained muscular injuries that may… – Continue reading

Putting the Final BEPS Reports into Perspective: from Recommendations to Implementation

The Organization of Economic Cooperation and Development (OECD) released its final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) Project on Monday October 5th, 2015. The final package of BEPS measures includes new minimum standards on: country-by-country reporting, which for the first time will give tax administrations a… – Continue reading

PAC/PEC applauded at APNIFFT AGM in Uganda

The National Assembly member (NAM) for Foni Bintang Karanai constituency has said that during the recent annual general meeting (AGM) of African Parliamentarian Network on Illicit Financial Flows and Tax (APNIFFT) held in Entebbe, Uganda, African parliamentarians present had applauded the Public Accounts Committee and Public Enterprises Committee (PAC/PEC) of… – Continue reading

Companies prepare for BEPS with mock runs to fix potential tax problems

MUMBAI: Several multinationals, including Indian companies with a global presence, have initiated impact assessments to identify and fix potential problems in their tax reporting when countries start implementing a new international standards to check tax avoidance by multinationals. The Organisation for Economic Co-operation and Development (OECD) last week released the… – Continue reading

Turnbull’s tax reform may see reviving his own tax report that he wrote 10 years ago

x Australian Prime Minister Malcolm Turnbull announces his new federal cabinet during a media conference at Parliament House in Canberra, Australia, September 20, 2015. Australia got its fifth prime minister in as many years on Monday after the ruling Liberal Party voted to replace Abbott with former investment banker Malcolm… – Continue reading

Beyond the Black Money Bill

No focus on stock markets and other money-laundering machines After all the noisy assertions, only Rs4,147 crore of unaccounted wealth was declared during the special 90-day compliance window of the The Undisclosed Foreign Income and Assets (Imposition of Tax) Act, 2015 (Black Money Bill). Of this, just Rs2,488 crore will… – Continue reading

Big tech companies continue cutting profits to pay less tax in Spain

In 2014, seven major tech groups in Spain Declared collective profits of € 48.2 million, on Which They paid € 18.3 million in taxes. These online giants Real Their reduced corporate profits-through complex legal structures and accounting techniques That allowed them to shift part of the profits from Spain to… – Continue reading

Dhaka, Thimphu in talks to sign double taxation avoidance deal

Staff Correspondent The National Board of Revenue on Monday started negotiations with Bhutan to sign an agreement on avoidance of double taxation and prevention of tax evasion and capital flight from the country. A five-member delegation led by NBR chairman Md Nojibur Rahman has been carrying out the first round… – Continue reading

Companies ‘are scrambling to boost tax transparency amid global crackdown’

Companies around the world are scrambling to overhaul how they communicate with the public when it comes to how much tax they pay, according to professional services firm KPMG. While the Senate is currently investigating multinational firms such as Apple and Google over potential tax avoidance, other countries are also… – Continue reading

Ireland, accused of giving tax breaks to multinationals, plans an even lower rate

Ireland, whose corporate tax rate of 12.5 percent is already one of the lowest in the developed world, said it would cut that rate in half for a new tax category — one covering revenue pegged to companies’ patents and other intellectual property. The Irish government, long criticized by other… – Continue reading

OECD RELEASES BEPS ACTION PLAN

The OECD has finally released its long-expected set of reports regarding its Base Erosion and Profit Shifting (BEPS) project. Reducing the number of action points from 15 to 13, the OECD presented recommendations and common responses to align international tax rules and tackle base erosion and profit shifting. All recommendations… – Continue reading

NBR to sign deal with Bhutan to avoid double taxation

Bangladesh is set to sign an agreement with Bhutan to avoid double taxation to boost investments, trade and facilitate information exchange between the two Saarc nations, the National Board of Revenue said in a statement. A team led by NBR Chairman Md Nojibur Rahman is now in Thimpu to take… – Continue reading

Your Taxes: OECD starts the BEPS tax revolution

Israeli importers and exporters, hi-tech and trading groups will all be in the base erosion and profit shifting firing line. On October 5 the Organization for Economic Cooperation and Development published a final comprehensive package of measures aimed at multinational corporations, large and small, that engage in BEPS – base… – Continue reading

Unilateral, Bilateral, Multilateral: Winds of change to watch for post-BEPS

With the adoption of the BEPS package, OECD and G20 countries, as well as all developing countries that have participated in its development, will lay the foundations of a modern international tax framework under which profits are taxed where economic activity and value creation occurs. Focus will now shift to… – Continue reading

Commission Updates Info On EU Tax Blacklists

The European Commission has compiled an updated list of third countries that feature on the tax blacklists of European Union member states. The new list reflects changes in member states’ assessments of third countries’ standards, corrections to national lists, and Estonia’s decision to withdraw all countries from its blacklist. The… – Continue reading

Geneva Bank Jobs Fall to Lowest Since Crisis Amid Regulatory Woe

Banking jobs in Geneva slipped to the lowest level since the 2008 financial crisis amid regulatory pressures, tax scrutiny and consolidation in the Swiss finance industry, according to lobby group Geneva Financial Center. Employees at banks in the city fell 3 percent to 18,855 in the 12 months through August,… – Continue reading

Report: AstraZeneca funnels billions into Dutch tax-avoidance scheme

AstraZeneca ($AZN) is not the first company to employ questionable tax-planning strategies, and it certainly won’t be the last. But the U.K.-based drugmaker is the latest poster child for tax avoidance. As The Guardian reports, AstraZeneca funneled billions of dollars into the Netherlands to get out of paying corporate taxes… – Continue reading

Brazil: BEPS: Rule Of Law Can Avoid Mountains And Cloudy Skies For Companies

The tax world followed with great interest today´s launch of the final package of BEPS. Having the BEPS report finalized is indeed a great achievement and, as pointed out by Mr. Angel Gurría, OECD Secretary General, in his Twitter, “Agreement of #BEPS package is a historic day in our effort… – Continue reading

Budget 2016 – Revealed: Government to introduce new lower corporation tax rate for companies that spend more on innovation

THE Government will introduce a new lower corporation tax rate in today’s budget in a bid to increase R&D investment and innovation. It is understood the new lower rate will only apply if a company agrees to a certain level of investment in research and development as part of the… – Continue reading