Category: Regulatory

Caribbean IFCs: Looking Beyond the International Initiatives

Caribbean IFCs continue to face the growing challenges as global standards struggle to manage certain risks across borders. Some of these challenges (such as cross border tax information sharing) have maintained their original format but intensified and we have seen several new initiatives (for example a push for beneficial ownership… – Continue reading

Amazon begins to book revenues in separate countries in what expert says is response to regulatory pressure

E-commerce giant Amazon has begun booking revenue in individual European companies, a move that tax expert Heather Self of Pinsent Masons, the law firm behind Out-Law.com, said is probably influenced by upcoming regulatory changes.26 May 2015 “As of 1 May, Amazon EU Sarl is recording retail sales made to customers… – Continue reading

Germany: Amazon Pays $16M in Tax, Earns $16B

The company decided to declare its revenues since European regulators started to investigate its accounting practices. Internet retailer Amazon paid about US$16 million to Germany in 2014, while the giant multinational recorded a total earning of US$16 billion in that country, according to the country’s regulators. In the past, the… – Continue reading

Big bucks, but no bankers jailed in $5.7B settlement

Six of the biggest names in global finance shelled out billions of dollars Wednesday to settle charges of rigging currency markets, but liberal lawmakers complain the government is just doling out slaps on the wrist. On Wednesday, the Justice Department announced a settlement that also saw five banks plead guilty… – Continue reading

EU Tax Committee Hears From Switzerland

A delegation from the European Parliament’s Special Tax Rulings Committee visited Switzerland on May 22. The delegation was received by Switzerland’s State Secretary for International Financial Matters, Jacques de Watteville. According to the Swiss Federal Council, talks focused on international corporate tax reform efforts and Switzerland’s work in this area…. – Continue reading

US Model Tax Convention Changes To Tackle Inversions

On May 20, 2015, the US Department of the Treasury released for public comment draft updates to the US Model Income Tax Convention, including provisions to deny treaty benefits to companies that change their tax residence via inversion transactions. The Treasury said other changes are intended to ensure that the… – Continue reading

Foreign taxpayers named by Switzerland

Switzerland has begun online publication of names of foreigners and foreign firms wanted in tax probes by their countries of origin, including Germany. American citizens are identified only by their initials. The Swiss Sunday newspaper “Sonntagszeitung” said the alpine nation was flooded with formal tracing requests from foreign tax authorities…. – Continue reading

Transfer pricing presents risks and opportunities

Businesses that operate globally continue to face complex tax issues, and transfer pricing – the practice of establishing arm’s-length prices for related-party cross-border transactions – has become more important than ever. When it comes to transfer pricing, I consider the Organization for Economic Co-operation and Development (OECD) Guidelines for Multinational… – Continue reading

Chile and China to Sign Several Agreements

Santiago de Chile, May 25 (Prensa Latina) Chile and China will sign several cooperation and trade agreements today in a ceremony at La Moneda Palace, in the presence of Chilean President Michelle Bachelet and Chinese Prime Minister Li Keqian. Li, who arrived in this capital yesterday afternoon, held a meeting… – Continue reading

Uzbekistan to amend legislation regarding offshore companies

Uzbekistan has developed a draft law on amendments and additions to the Tax Code regarding the companies established by the country’s residents in offshore zones. This remark was made by Uzbekistan’s Prosecutor-General Ikhtiyor Abdullayev, who was addressing the plenary session of the Eurasian Group on combating Money laundering and financing… – Continue reading

Switzerland Discloses Names of Alleged Foreign Tax Dodgers

Switzerland has begun revealing alleged foreign tax dodgers that are wanted by tax authorities in their native countries, Swiss newspaper Sonntagszeitung reported. MOSCOW (Sputnik) – Names, birth dates and nationalities of people suspected by their countries of origin to have stashed money in the alpine tax haven are being published… – Continue reading

UK FATCA: ARR deadline approaching for UK resident non-domiciled individuals

In November 2013 the governments of the Cayman Islands and the British Virgin Islands (“BVI”) entered into intergovernmental agreements with the United Kingdom (“UK IGAs”) which contained provisions for the establishment of a framework for the reporting of financial account information. That framework is similar in scope to the framework… – Continue reading

New GST obligations for offshore suppliers – Netflix subscriptions and so much more

Exposure draft legislation to extend the application of the GST to supplies of intangible products by foreign suppliers to Australian consumers has been released for consultation. While there has been considerable focus on the proposed expansion of the GST regime to cover supplies of “digital products”, the changes will also… – Continue reading

Range Concept: Less Litigation?

Litigation on transfer pricing issues has reached humongous proportion in India. The existing law of the use of arithmetic mean for determination of arm’s length price can be credited as a major igniter of such litigations as arithmetic mean had a tendency to be skewed by outlier comparables. Considering this… – Continue reading

Transfer pricing law new weapon

Thailand’s capacity for tracking how multinational companies shift income across borders within the same group to understate tax payments will increase after a transfer pricing law comes into force. The transfer pricing law, which is being deliberated by the Council of State, will authorise Revenue Department officials to ask parent… – Continue reading

To have and have not

Argentine political analysis is increasingly introspective but sometimes it is worth looking at developments in the wider world in order to place things in perspective. The substantial rise in the tax burden over the past decade has led to plenty of local moaning and groaning at both national and provincial… – Continue reading

Policy | San Marino. FATCA, Valentini meets Lazzari and Pedini Amati: ‘It’ s not a tax shelter ‘. The Serenissima

The Serenissima : Foreign Secretary replied to the interpellation submitted by Lazzari and Pedini Amati / FATCA, Valentini: “It is not to be considered as a tax shelter” / Agreement “virtually in place since July 2014”, the signature will come after the ok from Use “FATCA is not an instrument… – Continue reading

Malta’s credibility as financial centre takes another hit over battle for Gaddafi’s money

Malta’s credibility as a financial centre has taken another hit as news broke this week about a legal battle for the millions of euros accumulated by Mutassim Gaddafi – son of Libyan dictator Muammar Gaddafi – currently frozen in a Bank of Valletta account. Malta’s role in all this came… – Continue reading

WHY COMPETITION MAY SOMETIMES BE HARMFUL

While marketplace competition is desirable, competition among governments is not always desirable Is more competition always better? Most conventional economists would say yes. And, in the marketplace, that nugget of economists’ wisdom usually holds true. Every student of first-year economics is taught that competition is good for consumers, as it… – Continue reading

Russian Parliament Approves Amnesty for Offshore Capital

A bill offering legal amnesty to Russians who willingly declare their foreign assets sailed through Russia’s lower house of parliament on Friday, forcing companies and individuals to face a crucial question: to declare or not to declare? Under the legislation, known as the “capital amnesty bill,” businesses and citizens who… – Continue reading

Canada: New Bank Of Israel Directive Is Prompting Canadian Taxpayers To Bring Their Tax Affairs In Order

Change to the Procedural Requirements at the Bank of Israel The Bank of Israel has recently implemented measures that are designed to minimize legal and reputational risks for Israeli banks. The Bank of Israel circulated a draft directive for all Israeli banks by virtue of which all foreign (non-Israeli resident)… – Continue reading

Korea faces second ‘investor-state dispute’

Hanocal Holdings, a Dutch subsidiary of the Abu Dhabi-based International Petroleum Investment Company, has filed a lawsuit against the South Korean government through the World Bank’s International Center for Settlement of Investment Disputes. This is the second time that Korea is facing international arbitration under the “investor-state dispute settlement” process…. – Continue reading

Belgium and Russia sign new tax treaty

Belgium and the Russian Federation announced in March 2007 that they would negotiate a new double tax treaty (the “Treaty”). Nearly seven years after discussions began on 20 November 2008, the Treaty was finally signed on 19 May 2015 in Brussels. This newsflash is based on an unofficial version of… – Continue reading

Ukraine: Ukraine Updated A Blacklist Of Tax Havens For Application Of Transfer Pricing Rules On Cross-Border Operations

The Ukrainian legislation for transfer pricing came into force in 2013, with implementation of respective amendments to the Tax Code of Ukraine (“CCU”). However, at present the transfer pricing rules (provided for the CCU) are not applied accurately. In light of the above, in order to clarify the transfer pricing… – Continue reading

Ukraine: Ukraine Updated A Blacklist Of Tax Havens For Application Of Transfer Pricing Rules On Cross-Border Operations

The Ukrainian legislation for transfer pricing came into force in 2013, with implementation of respective amendments to the Tax Code of Ukraine (“CCU”). However, at present the transfer pricing rules (provided for the CCU) are not applied accurately. In light of the above, in order to clarify the transfer pricing… – Continue reading

Diverted Profits Tax: counterbalancing the UK’s “open for business” agenda?

The UK’s introduction of the diverted profits tax (DPT) has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) and in effect as of April 1, the DPT seemed intended to appease public anger at multinationals failing to pay their ”fair… – Continue reading

International tax and withholding considerations for US companies and their directors

To staff their board of directors with the best and most diverse talent, multinational companies commonly elect boards with international representation. It is also common for companies to convene periodic board meetings outside the United States. This may be done, for example, to provide board members with an opportunity to… – Continue reading