Category: Regulatory

A place in the sun: Retiring overseas requires careful tax planning

Jason Porter explores the tax regimes in Portugal, France, Malta and Cyprus – four of the most advantageous territories for UK ex-pat retirees People aged 55 and over are now entitled to their pension in the form of a lump sum, to be taxed at marginal rates applying in the… – Continue reading

BREAKING: US and Armenia to sign Trade and Investment Framework Agreement

U.S. Ambassador to Armenia Richard Mills on Tuesday confirmed reports that a U.S.-Armenia Trade and Investment Treaty will be signed during President Sargsyan’s working visit this week to Washington, DC, the final step in the negotiation of a bilateral economic accord long sought by the Armenian National Committee of America… – Continue reading

New tax rules proposed for e-commerce transactions

In the 2015 Budget Speech presented to the National Assembly on 25 February 2015 the Minister of Finance announced that amendments will be proposed to change the rules for the digital economy in line with the latest guidance issued by the Organisation for Economic Co-operation and Development (“OECD”) in its… – Continue reading

EU delays decisions on Apple, Amazon tax probes

BRUSSELS–The European Union won’t meet a self-imposed June deadline for deciding whether four multinational companies including Apple Inc. and Amazon.com Inc. benefited from illegal tax sweeteners, the bloc’s antitrust chief Margrethe Vestager said Tuesday. “We won’t meet the deadline we set ourselves [of] the end of the second quarter,” Ms…. – Continue reading

The Davis Tax Committee on BEPS and the transfer pricing of intangibles in South Africa

The Davis Tax Committee (“DTC”) recently addressed the issue of base erosion and profit shifting (“BEPS”) in South Africa. The international importance of transfer pricing was once again emphasized when 4 out of the 15 actions identified in the OECD Action Plan on BEPS related to transfer pricing. The 15… – Continue reading

The President signed into law the dot. FATCA

Passing between tax administrations Polish and US information on accounts and income tax residents predicts signed by the president Bronislaw Komorowski law on ratification of the agreement with the USA on the use of so-called FATCA Act. As reported by the presidential office, in terms of the Act of 20… – Continue reading

Taxation in Spain

A guide to Spanish taxation in 2015 for expats, with up-to-date information on income tax, VAT, property tax and other taxes for residents and non-residents in Spain. If you are living and working in Spain, you will be liable to pay Spanish taxes on your income and assets and will… – Continue reading

Guernsey Chief Minister meets EU Commissioner Moscovici

Guernsey’s Chief Minister, Jonathan Le Tocq, met today with Pierre Moscovici, the European Commissioner for Economic and Financial Affairs, Taxation and Customs. Deputy Le Tocq’s meeting, which was alongside Jersey’s Chief Minister, Ian Gorst, came at the beginning of a series of engagements over the next 48 hours in Brussels…. – Continue reading

Thai transfer pricing on the verge of new era

Thailand is expected to introduce new transfer pricing (TP) laws in the near future, which will apply to all companies in the Kingdom with related-party transactions. At a recent Deloitte seminar on “Thailand TP Developments”, with participation from senior officials from the Revenue Department, we shared some valuable insights on… – Continue reading

Round Tripping: The Bane of Indian Tax Treaties

Mauritius and Singapore are both examples of countries with Double Taxation Avoidance Agreements (DTAAs) with India, meaning dividends from corporations that are paid out to shareholders are not taxed further, having already been taxed at the corporate level. This legislation has meant that such countries have been used to “round-trip”… – Continue reading

HSBC Judge Seeks More Information About Sanctions Compliance

A federal judge demanded to know more about HSBC Holdings Plc’s compliance with its trade sanctions and anti-money-laundering deal with the U.S. after a monitor said the bank was “too slow” to mend its ways. U.S. District Judge John Gleeson in Brooklyn, New York, ordered the government to file a… – Continue reading

Italians arrest ex-Swiss banker for ‘tax fraud’

Authorities in Milan said on Monday that they have detained a former Swiss banker for allegedly helping wealthy Italian clients evade taxes and launder large sums of money, including the proceeds of embezzlement. Italian financial police (Guardia di Finanza) from Varese northwest of Milan said that Filippo Dollfus, a former… – Continue reading

The Italian IP box – an opportunity for the fashion industry

The patent box regime, adopted at the end of 2014 with Italy’s Stability Law, was recently modified by the Investment Compact Decree and implemented into law at the end of March 2015. A distinctive feature of the Italian regime is that the measure now also covers trademarks and designs. A… – Continue reading

Those Gruelling U.S. Tax Rates: A Global Perspective

The Tax Foundation released its inaugural “International Tax Competitiveness Index” (ITCI) on September 15th, 2014. The United States was ranked an abysmal 32nd out of the 34 OECD member countries for the year 2014. (See accompanying Table 1.) The European welfare states such as Norway, Sweden and Denmark, with their… – Continue reading

International organizations poised to impact presidential race

With a new candidate seemingly entering the race for president each week, national attention is understandably focused on American politics. But while Americans spare little mind for the goings-on of international organizations, their activities not only have significant impact around the world, but could also play a role in the… – Continue reading

FinCEN Seeks to Curb Trade-Based Money Laundering Through Lowered Reporting Threshold

On April 21, 2015, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a Geographic Targeting Order (“GTO”) lowering reporting thresholds and triggering additional recordkeeping requirements for certain financial transactions in a move that is likely to have effects far beyond the 700 Miami-based electronics exporters that are specifically… – Continue reading

IRS Plans to Shift Risk of Withholding Agent Fraud to the Taxpayer for Foreign Withholding

Chapter 3 of the Internal Revenue Code requires payors (and recipients) of certain types of U.S. source income to withhold tax if the beneficial owner or recipient is a non-U.S. person for income tax purposes. Chapter 4 also imposes similar withholding under FATCA for payments to foreign financial institutions and… – Continue reading

Tax dues: State moots one time settlement

State government is contemplating One Time Settlement scheme to recover over Rs.2,000 crore pending commercial tax revenue dues locked up in various litigations. Finance Minister Yanamala Ramakrishnudu, who recently held a review meeting in Vijayawada to review the division-wise revenue collections and shore up tax collection by plugging loopholes in… – Continue reading

Taiwan, Canada agree on double taxation avoidance

Taipei, May 2 (CNA) Taiwan has reached an agreement with Canada on the avoidance of double taxation at an annual bilateral economic consultation, the Ministry of Economic Affairs (MOEA) said Saturday. The double taxation avoidance pact, which will be signed very soon, will be favorable to Taiwan businesses because it… – Continue reading

It’s FATCA time in Luxembourg

A year after the signing of the intergovernmental agreement regarding FATCA (Foreign Account Tax Compliance Act) between Luxembourg and the United States, the bill of law was finally introduced on 27 March 2015 to the Luxembourg Parliament. The bill of law relates to the exchange of tax information between the… – Continue reading

Jaitley warns India Inc. against profiting from liberal tax regime

Warning corporates not to take unfair advantage of the liberalised tax environment, Finance Minister Arun Jaitley on Friday said the world is moving towards a more transparent regime that would remove the veil of secrecy from unlawful transactions. “I think, for every assessee, every person in the commercial business also,… – Continue reading

MAT tangle: 5 foreign portfolio investors including National Westminster Bank, BNP Paribas, take I-T department, government to court

MUMBAI: Five Foreign Portfolio Investors (FPIs) on Thursday mainly from the US and the UK have dragged the Indian government and the Income Tax department to the court for levying Minimum Alternate Tax (MAT) on their capital gains for the year 2011-12. The five FPIs — National Westminster Bank Plc,… – Continue reading

Truth Be Told: International Pension Plans in Bermuda

With its enviable reputation in offshore trusts, pensions and insurance, Bermuda is an ideal jurisdiction for employers to establish international pension and employee benefit plans (IPPs). Global organisations may consider establishing Bermuda IPPs for employees who work outside their home country or the home country of both the employees and… – Continue reading

BEPS – Historic Reforms

The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project is changing the international tax landscape by building a new international consensus on how to tackle BEPS. In September 2014, the first seven of the deliverables under the 15-point BEPS Action Plan were presented to G20 Finance Ministers when they met… – Continue reading

The Growing Role for IFCs in a World of Increasing Transparency

The debate around transparency, information exchange and beneficial ownership continues to evolve and has demanded a real focus for those working in International Finance Centres (IFCs), which frequently find themselves in the frame when it comes to ill-considered accusations relating to secrecy and illicit financial flows. In fact, Jersey and… – Continue reading

Why Did The U.S. Pay This Former Swiss Banker $104 Million?

Bradley Birkenfeld was released from federal prison in August 2012 after serving 2½ years for his role as a Swiss banker hiding millions of dollars for wealthy American clients. Five weeks later, he found himself in the kitchen of a small rental house in Raymond, New Hampshire. At that moment,… – Continue reading

BEPS Action 10 – discussion draft on profit splits in global value chains

Introduction The Organisation for Economic Cooperation and Development (OECD) recently issued a discussion draft on the use of profit split methods in relation to transfer pricing and in the context of global value chains as part of the Base Erosion and Profit Shifting (BEPS) project.(1) This update provides an overview… – Continue reading

Barbados: Its Systems Validated

During 2014, Barbados again produced strong evidence of the underlying strength of its financial system. All of the financial stability indicators and stress tests performed for the financial system strongly indicate that the system remains stable with the capacity to withstand a wide variety of severe economic shocks. It is… – Continue reading

Tax avoidance culture still thrives despite clampdown

The game of cat and mouse between tax authorities and citizens has been played for a very long time. People have been dodging taxes for centuries. But the more nuanced and sophisticated game of avoiding tax is a more recent phenomenon. Indeed, when it comes to tax avoidance the game… – Continue reading

Singapore’s government says it’s not a tax haven, it’s a value-adding hub

Singapore is not a tax haven, it’s a value-adding hub. That is the claim of the island nation’s Economic Development Board, the Singaporean government agency that’s been charged with attracting business and investment. It has disputed recent claims at the Senate inquiry into corporate tax avoidance that it’s being used… – Continue reading