The announcement marks an attempt to defuse the raging controversy over MAT payouts, which has dented the outlook of foreign institutional investors toward the country’s stock and bond markets. The government on Monday announced it had stayed the issue of fresh notices to foreign institutional investors regarding the alleged non-payment… – Continue reading
If you are moving or trading goods across borders, this topic should be of primary importance from both a Transfer Pricing and Customs perspective. There is potential for you to have Transfer Pricing and Customs exposures in your supply and value chains as a result of the OECD/G20 initiative on… – Continue reading
The Federal Reserve barred Markus Walder, the former head of North America offshore banking at Credit Suisse Group AG, and four other previously indicted ex-bankers at the company from employment in the banking industry. The five were indicted for conspiracy to defraud the U.S government by assisting U.S. citizens’ evasion… – Continue reading
The Chinese government has been paying close attention recently to the effects of offshore entities having ownership or control of Chinese companies or assets. Following the release of the draft Foreign Investment Law in January 2015, the State Administration of Taxation (SAT) issued a Bulletin on the tax treatment of… – Continue reading
The Ministry of Finance (MoF) recently organised a consultative meeting at its premises in Abu Dhabi; which was attended by key UAE foreign investment partners at a federal and local level. The meeting covered future plans to grow the UAE’s network of double taxation avoidance as well as protection and… – Continue reading
I. VAT and Customs In many cases, the principal in the contract manufacturing relationship owns some or all of the raw materials, work-in-process and finished goods throughout the manufacturing process. The principal and many of the suppliers are typically outside of the manufacturing jurisdiction. 1. Generally Speaking, What Are The… – Continue reading
There are no untouchables in Croatia when it comes to tax evasion, Finance Minister Boris Lalovac said on Tuesday, commenting on investigations of several Croatian citizens with huge amounts in foreign bank accounts. They have been called to the Tax Administration to explain “such large amounts and declare their assets,”… – Continue reading
Efforts by the Australian government to combat money laundering could have a highly impact effect upon the huge revenues its reaping from foreign purchases of domestic property. Regulators have recently come under fire for failing to adequately monitor foreign acquisitions of Australian real estate and ensure that they are in… – Continue reading
New rules applicable to payments made by Chinese companies to ‘related’ companies offshore will prevent them from artificially shifting profits to lower tax jurisdictions through “unreasonable” service and royalty payments, the State Administration of Taxation (SAT) has said. Circular 16, which came into force on 18 March, and its accompanying… – Continue reading
Money laundering and the increasing role it plays in terrorist financing is almost never out of the news. The extent to which terrorist groups are able to mobilise support has risen significantly and many, such as the Islamic State of Iraq and the Levant (ISIL), are clearly very well-financed. Thanks… – Continue reading
Key Points: A key requirement for the anti-avoidance rules to apply will be that a principal purpose of the scheme is to avoid a taxable presence in Australia. Treasurer Joe Hockey has today confirmed that Australia is going to bolster its income tax anti-avoidance rules to counter large multinationals (global… – Continue reading
On 5 May 2015 the Federal Supreme Court rendered its long awaited decision on a withholding tax (WHT) reimbursement claim related to Total Return Swaps. The case was based on essentially the following facts: a Danish bank entered into swap contracts with clients in England, Germany, France and the US…. – Continue reading
On 1 April 2015 the British Virgin Islands (BVI), Cayman Islands and 19 other jurisdictions were removed from Italy’s blacklist of jurisdictions. As a result it will now be easier for Italian individuals and companies to engage in business with those based in the Cayman Islands and the BVI. The… – Continue reading
Investigative reporter suggest financial rewards for tax whistleblowers “Whistleblowers should receive protection when they reveal behavior that goes against the public interest and not only when they reveal illegal activities. There should also be more openness about tax rulings and similar arrangements and countries which defraud other countries should be… – Continue reading
A record 1,336 US taxpayers gave up their passports or their green cards in the first quarter of 2015, according to Treasury Department statistics published in the Federal Register. The Treasury is required by statute to publish a quarterly list including the name of each individual who has lost or… – Continue reading
Grant Wardell-Johnson, KPMG Tax Partner, has said that while it would have been better for Australia to await the outcome of the OECD’s base erosion and profit shifting Action Plan, the international tax measures proposed recently by Treasurer Joe Hockey “have the benefit of being highly targeted.” On May 11,… – Continue reading
South African companies are unable to compete with multinationals selling goods and services online in the country, partly as a result of tax laws. This is according to financial services group PwC, which argues that the country has not kept pace with the changing global economy. “Currently, multinationals in the… – Continue reading
Introduction The Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) decided in mid-March 2015 that Switzerland should enter Phase 2 of the Peer Review. This decision represents a clear statement by the OECD that Switzerland’s legal and regulatory framework for information exchange complies with internationally… – Continue reading
Tax analysis: Catherine Richardson, associate at Cadwalader, Wickersham & Taft LLP, examines the aspects of the Finance Act 2015 (FA 2015) which concern targeting avoidance using carried-forward losses. What is the target for the new rule countering tax avoidance involving carried-forward losses? Where losses for tax purposes arise within a… – Continue reading
A special European Parliament committee to probe tax avoidance schemes is facing mounting obstacles to its work. The problems, which include access to documents, administrative delays, and internal disagreements risk undermining the MEP’s investigation into how government-backed tax rulings allow multinationals, in some cases, to pay less than 1 percent… – Continue reading
There are two pressing concerns facing us in 2015. First, the increased crackdown on multinational corporations reportedly using offshore tax hubs to avoid taxes will make summer 2015 the make or break season for the global economy. On the one hand, the argument is made that firms such as Apple,… – Continue reading
Australia to fine tech tax-dodgers 100% of their avoided tax, plus profits Australia’s treasurer* Joe Hockey has revealed that he and other money ministers from the Organisation for Economic Co-operation and Development (OECD) have shared plans to have online retailers charging the appropriate consumption tax on intangibles and goods bought… – Continue reading
The Conservatives are set to press on with efforts to counter tax avoidance and evasion, with measures on the way including the exchange of information with foreign tax authorities, reports the Financial Times. All the major parties pledged in the election campaign to raise billions more each year from individuals… – Continue reading
FATCA-TRAC has the advantage of being a ‘software’ that is already installed, tested and running in ten institutions globally Multitek recently launched a tool that automates the entire process associated with the regulation of US law or FATCA ‘Foreign Account Tax Compliance’. FATCA-TRAC, created for banks and financial institutions in… – Continue reading
KPMG in Saudi Arabia is hosting a seminar on taxation of US individuals and the impact of Foreign Accounts Tax Compliance Act (FATCA) at the Marriott Hotel in Riyadh on May 26. Under US tax law, US citizens and US permanent residents (green card holders) are required to file US… – Continue reading
The Income Tax Treaty between Guernsey and Monaco entered into force on 9 May 2015 and its provisions will take effect from 1 January 2016. The Treaty was signed on 7 April 2014. In accordance with the treaty, the following withholding taxes will apply: Dividends: 0%. Interest: 0%. Royalties: 0%.
Global business The European Union outlined its strategy to create a digital single market. The thrust of the proposals include establishing standard rules for buying goods online, pruning cross-border regulations on telecoms and reducing the tax burden on businesses. But the plan also calls for a “comprehensive assessment” of whether… – Continue reading
On May 7th, 2015, the US Treasury Department published its first quarter 2015 list of individuals who have chosen to expatriate and it was yet again an eye opening number. The 1,335 published names is the highest quarterly figure ever reported in the Federal Register. The number of individuals voluntarily… – Continue reading
The Italian Revenue Agency has confirmed that it collected a record EUR14.2bn in additional tax revenue from its actions against tax evasion during 2014. Revenue from the Revenue Agency’s tax enforcement activities last year increased by over EUR1bn, a growth of eight percent compared with 2013. This result was achieved… – Continue reading
The Australian government announced a world-leading crackdown on Monday on alleged tax avoidance by 30 multinational companies that will likely force them to restructure their businesses before next year, reports Reuters. “These companies are diverting profits earned in Australia away from Australia to no-tax or low-tax jurisdictions,” Treasurer Joe Hockey… – Continue reading
Ease of integration and flexibility of strategic reporting platform drive Colombia’s largest bank to expand partnership Tax reporting solution now deployed in five countries as a result of agreement AxiomSL, a leading provider of regulatory reporting and risk management solutions to the financial services industry, announced today that Bancolombia, Colombia’s… – Continue reading
A mixed bag of topics for this week’s edition of Lifelines: ‘Gaijin card’ deadline looms First up are the new residence cards, which have replaced the old alien registration cards (aka gaijin cards) for foreign residents. If you are still using your old card, be aware that the deadline for… – Continue reading
The government should stop looking for more borrowed money and take immediate steps for resource mobilisation to overcome fiscal deficit Taxation is a lot like sheep shearing. As long as you shear a sheep, it will continue to produce a new crop of wool but you can skin the animal… – Continue reading
THE issue of tax evasion is a concern for various Governments around the world. Tax authorities continue to face challenges from both local businesses and multinational corporations. In Zambia has the challenge has been to ensure that traders, local manufacturers and multinationals pay taxes due to the treasury. The situation… – Continue reading
After finding them guilty of manipulation in the stock market for making illegal gains, Sebi has restrained the 178 entities, including Pine Animation, from accessing the securities market. In a fresh clampdown on misuse of stock market platform for suspected money laundering activity, Sebi today banned Pine Animation and 177… – Continue reading
Another Swiss bank has signed up for a voluntary Justice Department program aimed at cracking down on offshore tax evasion. Vadian Bank, based in St. Gallen, Switzerland, agreed to pay $4.25 million under the agreement, in exchange for avoiding prosecution. Under the Swiss bank program, financial institutions also have to… – Continue reading
ISLAMABAD: As authorities struggle to increase tax collection, the state is considering a proposal that could see a levy of 10% tax on profit made on foreign remittances placed in savings accounts. The proposal comes as the government suspects that the amount sent through remittances could be black money being… – Continue reading
Deloitte managing tax partner Thomas Pippos says the IRD are using electronic payments and websites to pursue tax cheats Budget-conscious tax collectors are increasingly turning to popular websites and other e-channels to chase undeclared taxable income, a top accountant says. Inland Revenue Department no longer had capacity or interest in… – Continue reading
You’re just over a month to prepare for the provision of the first Russian banks reporting FATCA. In the future, Russia will reach the full exchange of information with the United States, who also contribute to the development of the domestic economy. By June 29, the Russian banks will be… – Continue reading
It may be time for another letter from Tom Cotton. Cotton, the Republican senator from Arkansas, had been in office only a few weeks back in March when he got 46 senators to sign on to an open letter to the leadership of Iran. The letter pointed out that agreements… – Continue reading
Chile’s Senate on May 5, 2015, approved a bill that strengthens the Internal Revenue Service (SII). The bill was passed with 30 votes in favor and none against, with one abstention. It will now be sent to the Chamber of Deputies for consideration, following changes made by the Senate. The… – Continue reading
Recently the Polish Ministry of Finance has presented a new bill introducing amendments to the Tax Ordinance and proposed amendments to the income tax regulations. Deferral of the effective date of the general anti-abuse clause On May 4, 2015 the Polish Ministry of Finance published a draft amendment to the… – Continue reading
Bold step on non-resident levy likely to be first of many. A tax policy paper released yesterday proposes changes on the taxation of non-residents in respect of New Zealand-sourced interest income. These changes, if implemented, will affect large multinationals, banks and even individual New Zealand borrowers. As the first significant… – Continue reading
CFOs of multinational corporations have mixed reactions to the Organization of Economic Cooperation and Development’s crackdown on base erosion and profit shifting by global companies, according to a new survey. The survey, by the tax advisory business Taxand, found that multinational CFOs are split 52 percent (agree) versus 48 percent… – Continue reading
The U.S. Internal Revenue Service is planning to broaden the use of subpoenas of documents in cases where the name of a taxpayer under investigation is not known. The so-called John Doe summonses were a breakthrough for the IRS in tackling offshore tax evasion when they were first addressed to… – Continue reading
THE THAWING OF RELATIONS between the United States (US) and Cuba will open up the opportunity for Barbados to “serve as an intermediary for investment into Cuba”. But two prominent American lawyers, including one who advises Government, have warned that the “on paper” advantage Barbados has under its double taxation… – Continue reading
New Delhi: Market regulator Securities and Exchange Board of India (Sebi) has asked bourses to take immediate action against entities involved in misuse of stock exchange system for tax evasion, Parliament was told Friday. Preliminary enquiries conducted by the regulator in the recent past, inter alia, indicate that certain persons/companies… – Continue reading
The Income and Capital Tax Treaty between Ireland and Thailand entered into force on 11 March 2015 and will enter into effect on 1 January 2016. The Treaty was signed on 4 November 2013. In accordance with the treaty, the following withholding taxes will apply: Dividends: 10%. Interest: • 0%… – Continue reading
Corporations that have reclassified themselves as “foreign-owned” received approximately $1 billion in federal contracts over the last five years. These companies profit from American tax dollars despite avoiding U.S. taxes themselves. That could soon change. Two members of Congress have reintroduced legislation that would block these companies from winning lucrative… – Continue reading
Global giant Standard Chartered Bank has been allowed by regulator Sebi to offer advisory services on regulated offshore products like stocks, bonds and mutual funds in markets outside India. “… SCB can advise on regulated offshore securities and investment products, which are in the nature of marketable securities issued by… – Continue reading
