The IRS on 12 August 2015 released Rev. Proc. 2015-40 with respect to requesting competent authority (CA) assistance, and it is generally effective for CA requests filed on or after 30 October 2015. Rev. Proc. 2015-40 updates and supersedes Rev. Proc. 2006-54. The IRS concurrently released Rev. Proc. 2015-41 as… – Continue reading
In late July 2015, Treasury provided an initial notification of “more favorable terms” concerning “certain alternative procedures” under the Model 1 IGA. This notification has been updated, 18 August 2015. Read the updated Treasury notification [PDF 70 KB]
PwC’s views on the Government’s discussion document seeking feedback on proposals for GST and offshore online purchases Following on from the much anticipated Government’s discussion document seeking feedback on proposals for the collection of GST on online purchases of services and intangibles this morning, we are pleased to share our… – Continue reading
FOR MANY YEARS countries around the world have been engaging in the automatic exchange of information in order to tackle offshore tax evasion and other forms of non-compliance. The Organisation for Economic Cooperation and Development (OECD) has been active in facilitating automatic exchange of information by creating the legal framework,… – Continue reading
FATCA was enacted into law by section 501(a) of the Hiring Incentives to Restore Employments (HIRE) Act 2010 as a revenue offset to help pay for the continuation of unemployment benefits for workers laid off during the 2008-2010 financial crisis. In July 2008, the U.S. Senate Permanent Subcommittee on Investigations… – Continue reading
The Cayman Islands is confident that the pan-European marketing ‘passport’ will be extended to alternative investment funds (AIFs) set up in the jurisdiction, according to the Alternative Investment Management Association (AIMA). Cayman, where a high percentage of offshore hedge funds are registered, still awaits assessment by the European Securities and… – Continue reading
THE START OF THE implementation of the Foreign Account Tax Compliant Act on July 1, 2014, combined with the Organisation for Economic Cooperation and Development’s (OECD) adoption of the common reporting standard, the support by the European Union of the automatic exchange of information (AEI), and the strong support by… – Continue reading
IN THE LAST TEN YEARS the international community has tried to pressure Barbados into signing tax information exchange agreements. Successive administrations, however, have resisted by continuing to show preference for double taxation treaties. That has not stopped the pressure, and some would argue that in some ways the global players… – Continue reading
(CS) German financial institution HSH Nordbank reportedly reached a 22-million-euro settlement with prosecutors in Cologne over setting up offshore companies through Luxembourg to hide client assets from tax authorities. Newspaper “Süddeutsche Zeitung” and broadcasters NDR and WDR first reported on the deal on Tuesday. Allegedly, HSH Nordbank approached the prosecutor’s… – Continue reading
Subsidiaries in Luxembourg of food group had no staff and assets at year’s end of €1.3bn In its 2014 accounts Glanbia Luxfin, a subsidiary of Irish food group Glanbia, reported profits of $14.2 million and tax of $4,175, while Glanbia Luxinvest reported profits of €2.9 million and tax of €38,863…. – Continue reading
The queue of tax disputes awaiting litigation through the UK’s tax tribunals set a new record last year, with almost 30,000 cases waiting to be heard at the end of last year, according to official figures. The number of outstanding appeals by taxpayers to the first-tier tribunal increased by 8.5%… – Continue reading
Anyone with undisclosed overseas income, gains or assets will be wise to make use of the Liechtenstein Disclosure Facility while it lasts, according to tax experts at Baker Tilly, reports FT Adviser. Andrew Hubbard, a partner at the firm, warned advisers that everything he has heard has led him to… – Continue reading
Turkmen parliament ratified the country’s convention with South Korea on double taxation avoidance and prevention of fiscal evasion with respect to income taxes, the Turkmen government said August 19. Aside from that, according to the government message, the parliament ratified the country’s convention with Austria on avoidance of double taxation… – Continue reading
On 1 April 2015 Cyprus and South Africa signed a Protocol amending their existing double taxation agreement (“DTA”), which was signed in 1997 and has been in force since 8 December 1998. The Protocol amends the 1997 DTA in three areas, namely the definition of residence, withholding taxes on dividends… – Continue reading
South Africans with undisclosed offshore accounts may feel exposed after their offshore Swiss bank account information found its way into the public domain this year. The theft of information relating to some 30 000 HSBC accounts – the biggest banking leak in history – actually took place five years ago… – Continue reading
International finance centers play a significant role in Russian foreign direct investment (FDI). For example, in 2012 it was observed that 11 of the 40 main recipients of Russian FDI were IFCs. Of these finance centers, the largest recipients were the BVI, the Cayman Islands and Cyprus. Despite the popularity… – Continue reading
In its Resolution of March 25, 2015, on the Annual Tax Report (2014/2114(INI)), the European Parliament renewed its commitment to combating tax havens and tax avoidance. To be sure, most aspects of the resolution have been discussed before. Bundling these aspects into one comprehensive package, however, provides an intriguing snapshot… – Continue reading
Whatever one thinks of Europe’s ruling class, one thing is undeniable: it has chutzpah. Like a gambler who has lost his savings on roulette and decides to bet his house in hope that his luck will turn, the EU leadership is upping the ante in the destructive pursuit of an… – Continue reading
Singapore-based wealth managers, already under pressure from a global move towards tax information sharing, face a more immediate threat as Asian countries including Indonesia and India look to chase undeclared money in the low-tax city state. A global crackdown on tax evasion launched during the 2008 financial crisis has already… – Continue reading
The Singapore Shipping Association (SSA) is pushing for the city-state to have more double taxation agreements. Speaking at a media briefing on Tuesday, Rene Pedersen, chairman of the SSA International Committee said, “Singapore today has some 65 double taxation agreements and that’s actually not a lot.” By comparison the UK… – Continue reading
Financial Services Minister Hope Strachan said yesterday that the landscape of the country’s financial services industry would be strengthened as a result of the nation’s compliance with the tax information exchange agreements such as the US Foreign Account Tax Compliance Act (FATCA), saying that she was fairly satisfied that The… – Continue reading
The Finance Ministry of Ukraine has proposed that the limit for transactions subject to control under transfer pricing rules should removed and will provide a simulation in the short presentation on tax reform that will be prepared by September. The ministry also proposed that the upper limit of fines for… – Continue reading
With the objective of long-term sustenance of wealth created both inside as well as outside India and continuous revenue generation, high net-worth individuals (HNIs) in India have decrypted and adopted innovative methods for asset protection and estate planning. The latest addition to the existing gamut of methods are offshore investments… – Continue reading
Tax Commissioner Pierre Moscovici has confirmed that the European Commission has no plans, formal or informal, to harmonize corporation tax rates across the European Union. In a written question to the Commission, Jonathan Arnott, a UK Member of the European Parliament, asked the Commission to confirm its latest position on… – Continue reading
Commercial banks have been facilitating tax evasion for choice clients by misusing their inter-bank tax-free facilities and have cleared billions of rupees in July without deducing the 0.3% withholding tax. According to sources in the Federal Board of Revenue (FBR) and commercial banks, these banks have misused the mechanism of… – Continue reading
Questions over tax — hotly denied — feature in a row centring on one of the capital’s biggest art collectors One of London’s wealthiest but most secretive families is locked in a bitter feud over the ownership of its empire, which spans high-end London properties to African tobacco-trading businesses. A… – Continue reading
The following article by Dr Monica Galea John, partner in the Financial Services Department, analyses the manner in which the Fourth EU Anti Money Laundering Directive (the “Directive“) which has just made its way through the EU’s legislation, obliges, for the first time, EU member states to maintain central registers… – Continue reading
A Protocol to Double Taxation Avoidance Agreement between India and Denmark that has entered into force on February 1, 2015, has been notified by Notification No. 45/2015/F No. 503/02/1998-FDI-I, to expand the scope of Exchange of Information (EOI) clause under Article 26 by substituting the same with a new Article… – Continue reading
The U.S. Treasury Department’s Financial Crimes Enforcement Network will soon propose new rules that may require investment advisers to establish and implement written anti-money laundering programs designed to prevent advisory clients from using advisers to launder funds or perpetrate other criminal activities. The rules also may require advisers to report… – Continue reading
Greek lawmakers and European Union finance ministers have signed off on a third bailout deal, including a diverse range of tax increases and commitments to curtail spending. A memorandum between the two parties, released on the blog of the former finance minister Yanis Varoufakis, acknowledges that the Government has recently… – Continue reading
In DIT vs. M/s. Lufthansa Cargo India: TS- 299-HC-2015, the Delhi High Court held that payment made by assessee (an Indian company) to German company for carrying out overhaul repairs to aircrafts was fees for technical services (“FTS”) under section 9(1)(vii) of the Income Tax Act, 1961 (“the IT Act”)… – Continue reading
A narrative which is now familiar to those working in Africa or who are involved in projects relating to Africa tends to enter into all discussions related to poverty and income disparity on that continent. That narrative, that the poverty and deprivation which exist on the continent are directly attributable… – Continue reading
Taipei, Aug. 18 (CNA) Taiwan and China will sign two agreements on taxation and aviation safety in their next high-level meeting to be held in Fuzhou, China later this month, a senior official of Taiwan’s Mainland Affairs Council (MAC) announced Tuesday. The meeting between the chiefs of Taiwan’s Straits Exchange… – Continue reading
The private equity industry has long been known for its ability to take advantage of tax rules. But international changes are set to have an impact on their businesses. After a string of multinationals such as Apple, Google and Starbucks came under fire for paying minimal tax on their British… – Continue reading
There have not been too many applicants in the first month seeking to avail of the three-month long compliance window being offered by the government to come clean on unaccounted money in foreign shores, Justice (retd) MB Shah, who is heading the Special Investigation Team (SIT) on black money told… – Continue reading
The Tax Department of Cyprus has annouced that the FATCA reporting deadline has been moved to 31 August 2015 (from 14 August 2015). The FATCA Agreement between Cyprus and the United States was signed on 2 December 2014. FATCA seeks to obtain information on accounts held by U.S. taxpayers in… – Continue reading
The Senate inquiry into multinational tax avoidance will table an interim report today detailing some of its findings after holding five public hearings and receiving more than 100 submissions from some of the world’s largest companies including Apple, Microsoft, BHP, Rio Tinto and Google. The final report is due to… – Continue reading
In short… The current balance of competences between the EU and the UK on tax is quite intricate, with a tension between member states’ desire to determine their own tax systems and the EU-led aim of a level playing field. The EU most obviously influences member states’ indirect taxation (particularly… – Continue reading
Luxembourg has proposed major corporate tax changes which would bring the Grand Duchy into line with recent updates to the Parent-Subsidiary Directive. The Luxembourg government released Bill 6847 (the Bill) on August 5 2015, which includes proposed tax measures for corporations and follows several recent announcements from Finance Minister Pierre… – Continue reading
BENGALURU, AUGUST 17: To conduct research on present tax regulations, address uncertainties arising out of interpretation and ensure higher FDI, the International Tax Research and Analysis Foundation (ITRAF) was launched here on Monday. Headed by Parthasarathi Shome, an economist and former head of the panel on General Anti Avoidance Rules… – Continue reading
Taxes are the enforced proportional contributions from persons and property, levied by the state by virtue of its sovereignty for the support of government and for all public need. From the above definition it is seen that taxes are contributions to a common pool by the people for the use… – Continue reading
New data from Juniper Research has found that more than one in 10 adults worldwide will engage in some form of mobile or online gambling by 2019, with nearly half of adults in UK and Italian markets playing by that time. While to some extent the finding can be attributed… – Continue reading
The tax regime for foreigners who render services in South Africa for a relatively short period of time is a key area which expatriates and their employers are grappling with. These individuals (also more commonly known as ‘short-term business travellers’) are generally physically present in SA for periods ranging from… – Continue reading
The Bombay Stock Exchange (BSE) is putting in place a series of measures to prevent use of its exchange platform by various unscrupulous entities to evade taxes and launder money. These measures include putting additional circuit filters on stocks that are susceptible for price manipulation and reducing the number of… – Continue reading
New transparency requirements could see tax-dodging companies being listed on a ‘name and shame’ register, a Senate committee has proposed. The Australian Tax Office would also be forced to disclose all tax avoidance settlements which exceed a proposed $100 million threshold, Fairfax has reported. In addition, companies based in Australia… – Continue reading
Large South Korean companies have sent more than $400 billion to offshore tax havens over the past eight years, with nearly 40 percent of the amount yet to be returned home, data showed Sunday. According to the data by the Bank of Korea and other government agencies, local big firms… – Continue reading
Simplification of tax administration has always been on the government’s agenda. E-filing is one major steps in that direction as it increases the tax base. E-filing is almost paperless, where taxpayers need not submit any supporting documents. E-filing is mandatory for those qualifying as resident and ordinary resident and having… – Continue reading
Gaborone — Botswana and Mauritius on Saturday August 15 signed a Double Taxation Avoidance Agreement, renewing a convention the two countries have had since 1995. Minister of Finance and Development Planning, Mr Kenneth Matambo represented Botswana while Mauritius’ Minister of Foreign Affairs, Regional Integration and International Trade, Mr Marie Joseph… – Continue reading
Luxembourg currently has 76 income tax treaties in force, and there are 29 treaties under negotiation. Tax treaties can provide a legal framework not only for the avoidance of double taxation and fiscal evasion, but also for international administrative cooperation between Luxembourg and its treaty partners in terms of mutual… – Continue reading
IT IS the corporate equivalent of burning the American flag. A “tax inversion” is a manoeuvre in which a (usually American) firm acquires or merges with a foreign rival, then shifts its domicile abroad to reap tax benefits. A spate of such deals last year led Barack Obama to brand… – Continue reading
