Category: Regulatory

Big UK companies halve provisions for disputed tax bills

The amount big companies set aside to cover disputed tax bills has more than halved over the past three years to £1.7bn this year, reports the Financial Times. Even though businesses fear more disputes as tax authorities become increasingly tough, they are showing reluctance to be drawn into conflicts that… – Continue reading

Implementation Of The Multilateral Competent Authority Agreement And Foreign Account Tax Compliance Act

SEBI on August 26, 2015 released a notification on the captioned head. It informed the intermediaries that India has joined The Multilateral Competent Authority Agreement (MCCA). Further on July 09, 2015, the Governments of India and United States of America signed an agreement to improve international tax compliance and to… – Continue reading

G20 finance communique: Long on reassurance, light on policy

G20 Finance Ministers and Central Bank Governors released their third communique of 2015 over the weekend. Their rhetoric is notable for the calm statement of positive reassurance on the macroeconomic environment, although the direct policy commitments appear to be light on. In the communique, Ministers and Governors recognised the significant… – Continue reading

EU States Told To Address Widening VAT Gap

Tax Commissioner Pierre Moscovici has urged European Union (EU) member states to “take the steps needed to fight tax evasion and tax fraud,” after new figures showed that the value-added tax (VAT) gap did not narrow in 2013. According to a new Commission report, the total amount of VAT lost… – Continue reading

Indian Competent Authority Akhilesh Ranjan On BEPS

At the 69th IFA Congress in Basel, Taxsutra’s Arun Giri, accompanied by well known tax expert Mukesh Bhutani, interviewed India’s Competent Authority Akhilesh Ranjan. Mr. Ranjan is leading the country’s charge on BEPS, and offers candid views on various issues including confidentiality of information, possibility of a BEPS outcome that… – Continue reading

Firms told to prepare for FATCA implementation

THE BUREAU of Internal Revenue (BIR) has advised Philippine financial institutions to start preparing for the implementation of a United States law requiring the reporting of bank accounts held by American taxpayers locally. In an advisory, the BIR said the start of reporting will not yet take place at the… – Continue reading

Ex parte preservation orders: Krok v CSARS

This case was an appeal from the Gauteng Division of the High Court to the Supreme Court of Appeal (“SCA”) pertaining to the correctness of the granting of an ex parte preservation order application that was brought against Mr Krok by the Commissioner of the South African Revenue Service (“SARS”) in… – Continue reading

Political courage needed on tackling inequality

Government must make good on its vows, says Jamie Livingstone In less than two weeks, leaders from 193 states will meet at the United Nations in New York to formally adopt, in effect, a new plan to fight extreme poverty, tackle inequality and end hunger. The Sustainable Development Goals (SDGs)… – Continue reading

Israeli banks named in Australian tax evasion affair

Former Nudie Juice CEO Andrew Binetter allegedly sought the destruction of incriminating files at Bank Hapoalim. The names of Israeli banks Bank Hapoalim (TASE: POLI) and Israel Discount Bank (TASE: DSCT) have been mentioned in the Australian press as involved in alleged tax fraud in the millions of dollars by… – Continue reading

Phuket Expat Finance: QROPS – Back to Basics

PHUKET: In 2005 the EU Commission proposed a directive that laid the foundations for a radical change in the portability of an individual’s pension. British, Dutch and Irish nationals were given the flexibility to move certain private pensions to the jurisdiction of their choice, rather than leave it in their… – Continue reading

Iran, Iraq sign three major economic agreements

Tehran, Sept 6, IRNA – Economy Minister Ali Tayyebnia and visiting Iraqi Finance Minister Hoshyar Zebari, in a meeting on Sunday, signed three strategic economic agreements. The three agreements were about customs cooperation, avoiding double taxation and encouraging joint investments. Tayyebnia said that Iran-Iraq trade, including other cooperation such as… – Continue reading

Colleen P. Waddell, Managing Director, Outlier Solutions to Speak at the Knowledge Group’s FATCA Event

New York, NY, September 05, 2015 –(PR.com)– The Knowledge Group/The Knowledge Congress Live Webcast Series, the leading producer of regulatory focused webcasts, has announced today that Colleen P. Waddell, Managing Director, Outlier Solutions will speak at the Knowledge Group’s webcast entitled: “Latest Regulatory Developments Under FATCA: Best Compliance Practices Uncovered… – Continue reading

Supreme Court finds taxpayer entitled to double tax treaty relief on share of Delaware LLC profits

On 1 July 2015, the Supreme Court (in Anson v HMRC4) held that a taxpayer was entitled to treaty relief on his share of a Delaware LLC’s profits. This casts doubt on HMRC’s published position (though each case must be judged on its own facts). The taxpayer, a UK “non-domiciled”… – Continue reading

Panama reviews AML, tax info exchange legislation

Panama’s Presidential High Level Commission for the Defense of International and Financial Services (CANDSIF) recently held a meeting to review the country’s progress on improving tax transparency and combating money laundering, reports Tax News. In particular, CANDSIF reviewed legislation passed earlier this year as part of Panama’s commitment to address… – Continue reading

Black money law: Beneficiaries in overseas discretionary trusts may face enquiry

MUMBAI: Indian tax authorities will ignore conventions to pierce trust structures used by most people to stash black money abroad. Persons who are named as beneficiaries in overseas discretionary trusts are likely to face enquiry even if they do not receive any money from such trusts. The taxman will look… – Continue reading

Funding for businesses facing APNs

A funding line has been launched to help business taxpayers facing payment deadlines arising from Accelerated Payment Notices (APNs) APNs, introduced in 2014, enable HMRC to request full upfront payment of disputed tax within 90 days. They are issued to individuals and companies suspected of partaking in aggressive avoidance schemes…. – Continue reading

Further developments in the BEPS project

A number of further publications have been released this quarter as part of the Organisation for Economic Co-Operation and Development’s (OECD’s) Base Erosion and Profit Shifting (BEPS) project. These include: The 8 June 2015 publication by the OECD of a package of measures relating to “country- by-country reporting” (relevant to… – Continue reading

Troy Kelley Hit With New Money Laundering, Tax Evasion Charges

Washington State Auditor Troy Kelley faces additional charges of money laundering and tax evasion. The U.S. Attorney’s office announced the new charges Thursday afternoon. The charges are contained in a superseding indictment against Kelley. The first-term Democrat now faces a total of 17 federal charges, including five new counts of… – Continue reading

Last minute funding to help SMEs pay tax bills

Commercial finance provider LDF has launched a funding line to help taxpayers facing payment deadlines arising from accelerated payment notices issued by HMRC. Accelerated payment notices, otherwise known as APNs, were first introduced in 2014. Designed to change the economics of avoidance, the notice enables HMRC to request full upfront… – Continue reading

German businesses criticise changes to investment fund taxation

German business groups have hit out at Berlin’s plan to reform how it taxes investment funds, warning on Thursday that the proposed changes would hurt pension provisions and reduce the attractiveness of Europe’s largest economy as a place to invest. The finance ministry announced plans in July to reform the… – Continue reading

FRANCE: DIVIDENDS RECEIVED BY PARENT COMPANIES; DIFFERENT TAX TREATMENT CHALLENGED

The Court of Justice of the European Union (CJEU) today issued a judgment concluding that the different tax treatment of dividends received by parent companies of tax-integrated groups, with such treatment depending on the location where the subsidiaries are established, is contrary to EU law. The CJEU judgment therefore holds… – Continue reading

india turkey offshore imf residency G20

The recent shocks in the global economy triggered by the Chinese devaluation of yuan and its economic slowdown are likely to dominate discussions in the two-day meeting of G20 Finance Ministers and Central Bank Governors starting here tomorrow over which India has expressed serious concern. Finance Minister Arun Jaitley arrived… – Continue reading

Tax scandal probe hit by setback as EU refuses to hand over documents to MEPs

The European Commission is refusing to hand over documents to MEPs investigating whether EU member states are using special tax regimes that favour large multinational corporations such as Facebook and Amazon. EU economics commissioner Pierre Moscovici wrote to the European Parliament’s special committee on tax rulings (TAXE) this week claiming… – Continue reading

Tories ease pressure on Cayman Islands over tax transparency

Britain’s Conservative government has relaxed demands on the Cayman Islands to create a register detailing company ownership, despite Prime Minister David Cameron’s previous call for Overseas Territories to adopt the measure to promote transparency. The UK’s Overseas Territories and Crown Dependencies make up almost 25 percent of the world’s tax… – Continue reading

UK seems to relax pressure on Caymans over company register

Grant Shapps, Foreign Office minister, says on visit that Cayman Islands could use existing systems to help tax authorities The UK government appears to have relaxed its pressure on the Cayman Islands to create a register of company ownership, despite David Cameron’s plea last year for overseas territories to do… – Continue reading

Reports of overseas financial accounts rise in 2015

SEJONG, Sept. 3 (Yonhap) — More South Koreans reported their overseas financial accounts to authorities in 2015 than a year earlier as the government turns up the heat on individuals and companies to disclose hidden assets, the tax office said Thursday. The government has taken a firmer stance toward people… – Continue reading

Bequeathing DOTAS

HMRC has published draft regulations which will extend the application of the disclosure of tax avoidance schemes (DOTAS) regime to inheritance tax (IHT) avoidance structures. The draft regulations set out the circumstances in which arrangements will be required to be registered under the DOTAS regime. Registration will be required where… – Continue reading

Making the invisible visible: Senate inquiry into corporate tax avoidance releases interim report

The inquiry raises some larger and perhaps more challenging questions about Australia’s corporate tax system and what is acceptable and unacceptable tax minimisation. On 18 August 2015, the Senate inquiry into corporate tax avoidance tabled a long-awaited interim report, with the subtitle “You cannot tax what you cannot see”. The… – Continue reading

Member states stonewall EP tax probe

HMRC reintroduces Australian fund to Rops listEU member states are lobbying the European Commission to prevent it from disclosing information on tax rulings to a European Parliament probe, reports the EU Observer. EU economics commissioner Pierre Moscovici, in a letter sent Monday (31 August) to the head of the parliament’s… – Continue reading

Argentina Tells HSBC to Remove CEO in Tax Evasion Dispute

HSBC’s Argentine unit told to remove CEO and one director HSBC accused of helping capital flight by wealthy Argentines Argentina’s central bank revoked the licenses of two top executives at HSBC Holdings Plc’s local unit, including the chief executive officer, arguing they had failed to prevent clients from laundering funds… – Continue reading

IRS issues new APA procedural guidance

On August 12 the IRS issued final guidance (Rev. Proc. 2015-40) significantly updating procedures for requesting and obtaining an advance pricing agreement (APA) from the Advance Pricing and Mutual Agreement (APMA) program. All new APA requests will need to be filed under these “new procedures”, however, an APA request may… – Continue reading

Black money: Swiss Parliament to take up India pact soon

Switzerland’s parliament will soon take up the issue of inking a crucial Automatic Exchange of Information (AEOI) agreement with India, a move that could help combat the menace of black money and erect a platform to enable the exchange of information between the two countries. “The domestic procedures regarding AEOI… – Continue reading

Latest Central Bank move on banking oversight will help reduce risk

Lack of information about ‘opaque’ special purpose vehicles make it difficult to assess financial stability implications The legendary Warren Buffett once described some shadow banking activities as “financial weapons of mass destruction”. By that he meant they pose a huge threat to the global financial system, as these investment structures… – Continue reading

STM scopes out Australian QROPS offering as business booms

International pensions administrator STM Group is looking to offer QROPS tailored for UK expats in Australia after HMRC scrapped thousands of schemes from its approved list in July. During an interview with International Adviser, STM – which has trading offices in both Malta and Gibraltar – cited plans to expand… – Continue reading

Survey: Business leaders would pay more tax for greater clarity

Three-quarters of global business leaders would accept higher taxes in exchange for greater clarity on acceptable tax planning, the Grant Thornton International Business Report has found. The survey of 2,580 businesses in 35 countries noted a significant increase from the last time the question was asked – last year –… – Continue reading

LUXEMBOURG: FINAL VERSION OF FATCA GUIDANCE

The Luxembourg tax authorities released a final version of an administrative circular and an updated administrative circular to implement provisions under the FATCA (Foreign Account Tax Compliance Act) regime concerning the automatic exchange of information between Luxembourg and the United States. An intergovernmental agreement (IGA), that follows the Model 1… – Continue reading

Irish Gambler John McManus seeks $5.22 Million tax refund from IRS citing international treaty

One of Ireland’s richest persons, John P. McManus, seeks $5.2 million from the U.S. government after it was wrongfully withheld from his $17.4 million gambling winnings to cover taxes. In a complaint filed Monday in the U.S. Court of Federal Claims, McManus accuses the withholding agent of erroneously withholding the… – Continue reading