Labour MEP warns that EU tax harmonisation against the interests of Malta and other European islands and peripheral regions Labour MEP and former Prime Minister Alfred Sant told the European Parliament that EU tax harmonisation goes against the interests of Malta and other peripheral regions and islands with limited endowments… – Continue reading
On Friday, Coca-Cola Co. said that it may owe the IRS an extra $3.3 billion in federal income taxes. According to the company, the Internal Revenue Service found after a five-year-long audit that the soft drink giant may owe the federal government $3.3 billion along with interest for the 2007… – Continue reading
The Swiss Bankers Association (SBA) has waded into the ongoing anti-tax evasion political debate by urging lawmakers not to burden banks with too many regulations, reports Swiss Info. The SBA said on Thursday that it supported the introduction of automatic tax data sharing with other countries. However, the lobby group… – Continue reading
European Commission president Jean-Claude Juncker has denied involvement in sweetheart deals that allowed hundreds of multinationals to slash their tax bills by locating to Luxembourg, despite being prime minister of the country for almost 20 years, reports the Financial Times. Facing questions from a committee of EU lawmakers set up… – Continue reading
Poland’s lower house (Sejm) on 11 September 2015 passed a bill containing amendments to the tax laws, including changes to the rules governing transactions between related parties—the transfer pricing rules. If enacted, the transfer pricing rules would be effective 1 January 2017. Among the legislative changes, new rules would: Increase… – Continue reading
The Internal Revenue Service has issued a notice extending the time under which certain transitional rules for the Foreign Account Tax Compliance Act, or FATCA, will apply. FATCA was included as part of the HIRE Act of 2010 and requires foreign financial institutions to report on the assets of U.S…. – Continue reading
Speed read On 15 September 2015 the Dutch government published its Tax Plan 2016. In this e-alert we discuss the legislative proposals in the Tax Plan which are of interest for companies. 1 INTRODUCTION Today, the Dutch Ministry of Finance published its Tax Plan 2016. In fact, the government sent… – Continue reading
CORNING — Corning Inc.’s handling of profits it earns overseas has quickly become an issue in the 2016 presidential campaign. The Fortune 500 company’s refusal to bring back to the U.S. more than $12.4 billion in overseas profits first drew criticism from U.S. Sen. Bernie Sanders, an independent from Vermont…. – Continue reading
On 16 September 2014, the OECD released the report on the tax challenges of the digital economy (the “Report”) under its Action Plan on Base Erosion and Profit Shifting (“BEPS”). The Report recognises that because the digital economy is increasingly becoming the economy itself, it would be difficult, if not… – Continue reading
Welcome to this special edition of Jones Day’s Global Tax Update. Almost two years ago, the Organisation for Economic Co-operation and Development (“OECD”) launched a radical and far-reaching review of the international tax system. The project’s name, BEPS (base erosion and profit shifting), provides a good insight into its objectives:… – Continue reading
Galway Bay FM Newsroom – Supermac’s boss Pat McDonagh has spoken out against McDonald’s alleged tax avoidance schemes which could have reportedly cost the EU almost 4 billion euro. It follows a meeting of the European Parliaments TAXE Committee today to investigate the 3.7 billion euro tax avoidance. It’s alleged… – Continue reading
Australian Treasurer Joe Hockey: Australian companies can take greater advantage of Israel’s knowledge-based economy. There is no tax treaty between Australia and Israel, but the lack will soon be made good, according to an announcement by Joe Hockey, Treasurer in the Australian government. “As part of the Government’s ongoing efforts… – Continue reading
HMRC has today published new draft guidance notes to cover the automatic exchange of financial account information under the International Tax Compliance Regulations 2015 (SI 2015 No. 878) (the Regulations), which were made in the spring. The main document is a new draft HMRC guidance manual covering the Regulations. The… – Continue reading
The 2016 Mexican Economic Package includes a proposal for country-by-country (CbC) reporting of tax information by certain multinational corporations. The Package, which was submitted to Congress by the Government on September 8, 2015, seeks to bring Mexican transfer pricing documentation rules into line with the Organisation for Economic Co-operation and… – Continue reading
Through Wetsvoorstel Overige Fiscale Maatregelen 2016, released on September 15, the Netherlands has confirmed the introduction of a new country-by-country (CbC) reporting obligation for multinational corporations. These regulations provide for the implementation of the recommendations of the Organisation for Economic Co-operation and Development (OECD) on transfer pricing documentation under Action… – Continue reading
The Swiss Federal Council has given the Swiss delegation to the OECD, the “go ahead” to accept the final BEPS reports— expected to be released possibly as early as the end of September 2015. This action indicates that Switzerland could implement and apply the new standards in the near future,… – Continue reading
“I want to commend the government for bringing this bill to parliament,” said Opposition Leader Hon. Dr. Denzil Douglas said today of the government tabled Foreign Account Tax Compliance Act (USA) (Implementation and Enforcement) Bill 2015. During his presentation on the bill’s debate in the National Assembly today (Sept 15),… – Continue reading
UK tax authority HM Revenue and Customs (HMRC) has published an e-brief on the Scottish Rate of Income Tax (SRIT), which is due to enter into effect from April 2016. From April 1, 2016 the Scottish Parliament will have responsibility for a SRIT. Parliament will be able to set the… – Continue reading
More than 90 jurisdictions, including all 34 member countries of the Organisation for Economic Co-operation and Development (“OECD”) and the G20 members, have committed to implement the Common Reporting Standard for automatic exchange of tax information (“CRS”). Building on the model created by FATCA, the CRS creates a global standard… – Continue reading
Issues of the Uzbek-Iranian bilateral relations’ development were discussed during the meeting of Uzbek Foreign Minister Abdulaziz Kamilov with Iranian Ambassador Ali Mardoniy Fard, who is completing his diplomatic mission in the country, said the message released Sept.16 by the foreign ministry of Uzbekistan. During the meeting, the sides exchanged… – Continue reading
SINGAPORE first entered a double taxation agreement (DTA) with Thailand in 1975. After 40 years, Singapore and Thailand signed a new DTA on June 11, 2015. The newly signed DTA has not yet been ratified by either country, and will go into force after it is. Below are some of… – Continue reading
Specialist tax advice looks set to be the biggest area for adviser business growth as pension freedoms takes effect and retirement planning becomes more complex, according to recent research by Prudential. Offshore, inheritance tax, business and retirement planning advice are named as potential growth areas as more advisers expect to… – Continue reading
Hong Kong’s Financial Services Development Council (FSDC) has released a report setting out recommendations on policies, including tax measures, to enhance the city’s role as a regional and global financial booking center. Financial institutions utilize such centers to enter into contracts for financial products, undertake primary obligations for delivery or… – Continue reading
Action 6 (Treaty Abuse) is a key element of the OECD’s BEPS Project. Action 6 targets, in summary, “treaty shopping”, i.e., where a person in country A, which is not, in principle, eligible to benefit from a given tax treaty with country B, invests through an entity in country C… – Continue reading
Past Progress and Prospects Harmful tax practices (e.g., tax havens, preferential tax regimes, tax rulings) are characterised by the propensity to erode tax bases of other countries which allegedly leads to an undesirable race-to-the-bottom on taxation rates. Action 5 of the OECD Action Plan on Base Erosion and Profit Shifting… – Continue reading
Read the full newsletter. The OECD’s recent recommendations1 with respect to transfer pricing documentation and country-by-country reporting may have the most significant impact on multinational enterprises (“MNEs”) of all of the OECD’s BEPS proposals. The adoption of these recommendations, without consensus on effective dispute resolution, is likely to alter the… – Continue reading
In a decision released August 14, the Tax Court of New Jersey ruled that an intangible holding company with no physical presence was required to file a New Jersey corporation business tax (CBT) return and pay the related tax due based on its income.1 No relief was available to the… – Continue reading
Some Italian parliament members published a proposal for a new law that may dramatically change the scenario for e-commerce and web operators doing business in Italy. The proposal (called by some commentators as “Digital” or “Web Tax”) is substantially a combination of domestic rules affecting the taxation of the digital… – Continue reading
The Organisation for Economic Cooperation and Development (OECD) has recommended that Ireland lower its high effective marginal income tax rates, abolish the reduced value-added tax (VAT) rate for the tourism industry, and phase in a planned Local Property Tax (LPT) hike. The recommendations are made in the OECD’s latest Economic… – Continue reading
On September 15, the Dutch government released its Budget 2016, containing the Tax Plan 2016 which includes certain amendments to Dutch tax law. The government will discuss the plans the coming weeks in parliament. Further to these discussions, some elements of the Tax Plan 2016 may change. Most proposals will… – Continue reading
EU committee set up to investigate aggressive tax planning concludes its report in weeks Lobbyists representing internet company Facebook could be banned from entering the European Parliament following a request by the parliament’s special committee on tax to revoke access to multinationals who refused to cooperate with the committee’s inquiries…. – Continue reading
The Transactional Net Margin Method (‘TNMM’) is a prescribed method for determining the arm’s length price in some cases. It also enjoins the adjustment owing to capacity under-utilization differences. Sizes of entities and level of activities differ, so does the available comparables for the purpose of transfer pricing adjustments. The… – Continue reading
Economist Richard Murphy, a long-standing critic of the Channel Islands, has told ITV News he believes the Bailiwicks are secretive “tax havens” that undermine the UK’s tax system. We spoke to him immediately after today’s Prime Minister’s Questions, where Jeremy Corbyn spoke for the first time as leader of the… – Continue reading
A federal court judge dismissed an attempt to put an early stop to a controversial program in which the Canadian government agreed to share financial information of an estimated one million “U.S. persons” living in Canada with the Internal Revenue Service. Particularly troubling to some opponents is that the agreement… – Continue reading
The night that Uber started offering its ride-hailing service in Costa Rica, vandals – reportedly taxi drivers – smashed the windows of one of the company’s cars in protest. Traffic police impounded two Uber vehicles earlier that same night. Airbnb, however, another staple of the so-called “sharing economy,” has been… – Continue reading
Malta provides an outstanding opportunity for private equity and venture capital managers. It has a flexible LP structure, an extensive network of double tax treaties, a favourable local tax regime and experienced service providers who can provide a cost-effective solution,” comments Felicity Cole (pictured), Head of the Funds Department at… – Continue reading
Mombasa county has launched another attempt to collect levies on cargo at the port after earlier attempts were rejected by the Kenya Ports Authority (KPA). Through the Finance Bill 2015/2016, the county wants to directly tax shipping lines and cargo owners unlike in the previous bid where it sought to… – Continue reading
AUGUST DECLINE:Deposits at banks’ offshore banking units plunged 7.3 percent to 49.79 billion yuan and fell 2 percent to 277.15 billion yuan at domestic banking units Yuan deposits at Taiwanese banks fell 2.88 percent to 326.94 billion yuan (US$51.29 billion) last month from July, as the Chinese currency’s widening volatility… – Continue reading
Transparency International called today on European Commission President Jean-Claude Juncker to publicly support legislation that would allow citizens to scrutinise the corporate taxes paid by multinational companies to governments. Juncker will appear tomorrow in front of a special tax committee at the European Parliament to defend the Commission’s track record… – Continue reading
The Inland Revenue Board of Malaysia in September 2015 issued guidance concerning the requirements for compliance with an intergovernmental agreement (IGA) to implement the FATCA regime. The FATCA guidance notes provide guidelines and practical information for Malaysian-based financial institutions, businesses, their advisers, and officials dealing with application of the FATCA… – Continue reading
Former HSBC Bank employee Hervé Falciani gave a USB stick with eight names of alleged tax evaders to the four Greek prosecutors who took his testimony at the Greek Embassy in Paris. According to information from an anonymous source at the Public Prosecutor’s office, the list of names includes two… – Continue reading
‘I’m not going to buy into that’ Joe Hockey refuses to feed speculation that he could be replaced as Treasurer by Scott Morrison under the new Prime Minister Malcolm Turnbull. Malcolm Turnbull’s first full day as PM: Live coverage Joe Hockey signals he’s ready to serve on Malcolm Turnbull’s frontbench… – Continue reading
Exclusive: company faces renewed questions over its fitness as security contractor at Australian detention centres on Manus Island and Nauru Wilson Security faces renewed questions about its fitness as security contractor in Australia’s offshore detention centres in light of its corporate links to a tax haven, a corruption scandal that… – Continue reading
Changing Attitudes to Tax Reputation Risk In recent years, it seems that any discussion of tax includes mention of the moral obligation taxpayers have to “pay their fair share.” Many believe this theme began to get traction in 2011 when Warren Buffett realized that he was paying proportionately less taxes… – Continue reading
The Government should reduce the rate of capital gains tax (CGT) and expand corporation tax relief for start-up companies in next month’s budget to boost growth in the financial technology sector, Financial Services Ireland (FSI), a unit within employers’ group Ibec, has urged, reports the Irish Times. In a 10-page… – Continue reading
The tax arrangement for the Kingdom (BRK) will be replaced by a new tax system in relation to the Netherlands and Curaçao. The new tax arrangement was adopted by the Dutch House of Representatives on September 10 of this year, reports the Curacao Chronicle. The tax arrangement between Curaçao and… – Continue reading
IN SPITE of the challenges from large developing countries, assurance has been given that Barbados is sticking with the International Business and Financial Services sector. This is according to Prime Minister Freundel Stuart, who used the opportunity over the weekend to commend Minister of International Business, Donville Inniss, for his… – Continue reading
NEW DELHI: Finance minister Arun Jaitley has promised “fairest and predictable taxation regime” while inviting US businesses to invest in the country. Speaking at the 11th Indo-US Economic Summit organised by the Indo-American Chamber of Commerce ahead of the India-US Strategic and Commercial Dialogue (SACD) in Washington later this month,… – Continue reading
Under the I-T Act, 1961, taxpayers are broadly categorised as Ordinary Resident, Not Ordinarily Resident (NOR) and Non-Resident (NR). Reporting and paying taxes on overseas incomes and assets come with their own set of challenges. Under the I-T Act, 1961, taxpayers are broadly categorised as Ordinary Resident, Not Ordinarily Resident… – Continue reading
The largest producer of nitrogen-based fertilizer in the United States, CF Industries, is considering merging with a Dutch competitor and moving its headquarters overseas to avoid the “double taxation” of profits earned by overseas subsidiaries going to the domestic company. Curtis Dubay, a tax and economic research fellow with The… – Continue reading
