With substantial amendments to SA transfer pricing legislation in April 2012 – as well as a lack of any subsequently updated or final Practice Note from SARS – much uncertainty still surrounds the realm of transfer pricing in SA, says Lauren Hart, of Webber Wentzel, in an analysis on the… – Continue reading
India enacted transfer pricing rules in 2001, which require companies to conclude international transactions with associated enterprises at an arm’s length. The legislation is primarily targeted at large business groups who engage in base erosion and profit shifting to avoid paying corporate income tax in India. This article is the… – Continue reading
Many factors influence a foreign buyer’s decision to purchase residential real estate in the United States. Generally, most of these decisions tend to be driven by concerns over political and economic uncertainty in the buyer’s home country. Most foreigners do not leave their home country, family, and friends for trivial… – Continue reading
Countries are competing to lower their tax rates to please the corporate giants, but the result is a massive collective loss of revenue. Only international coordination can wipe out the practice and defeat the negative influence of the Big Four accounting firms. Tax havens have long existed in the popular… – Continue reading
On December 28, 2014 Ukrainian Parliament has adopted the Draft law No. 1264-1 “On amending the Tax Code of Ukraine regarding improvement of tax control over transfer pricing” as of 22.12.2014 (the Draft Law). In order to become effective, the Draft law has to be signed by the President of… – Continue reading
Overseas property buyers have to pay significantly more tax than domestic buyers in Singapore and Hong Kong, making them the most costly places for foreigners to invest in residential real estate in Asia Pacific, says Knight Frank Singapore and Hong Kong are the most costly places for a foreigner to… – Continue reading
The 4,029-page tax code is so complex both parties want to revise it. On business tax reform, they share surprising common ground, raising the potential for partial tax reform to be enacted this year. As the 114th Congress convenes this week, it has a golden opportunity to rid itself of… – Continue reading
The Inland Revenue Authority of Singapore (IRAS) has published an updated consolidated e-Tax Guide on the country’s transfer pricing regime. The e-Tax Guide, which was released on January 6, 2015, is divided into three main parts. Part I of the Guide provides background on the treatment of related-party transactions and… – Continue reading
With particular reference to issues associated with the requirements of the Foreign Account Tax Compliance Act (FATCA), the United States Internal Revenue Service (IRS) has updated Publication 515: The Withholding of Tax on Nonresident Aliens and Foreign Entities. It is specified that the Publication is for withholding agents who pay… – Continue reading
(CS/vb) A former PwC employee could face up to 10 years in prison for leaking thousands of documents in what has become known as the LuxLeaks scandal, his lawyer has said. Informant Antoine Deltour spoke on French television station Canal+ on Tuesday, saying that among experts, tax avoidance schemes via… – Continue reading
THE South African Revenue Service (SARS) has already begun to tackle the erosion of the tax base through profit shifting, which was addressed in an interim report of the Davis tax committee that was released last month for public comment. SA loses billions of rand in revenue annually through the… – Continue reading
A tax information exchange agreement signed between the Isle of Man and Lesotho has come into force. The government says it’s part of its programme of developing closer economic and taxation co-operation with other countries around the world. It was signed in September 2013 in London by Treasury Minister Eddie… – Continue reading
PM’s trip to principality comes after Catalan ex-leader’s revelations about hidden accounts Prime Minister Mariano Rajoy is expected to sign an agreement that will include a system for automatically sharing tax information between Andorra and Spain during an official two-day visit to the principality that begins on Wednesday. The agreement… – Continue reading
New research shows that 2014 saw many fundamental changes across the global tax system as governments look to reform their regimes for the long term, complying with new OECD guidelines, whilst significantly clamping down on multinationals in light of increasing public media scrutiny. The research was undertaken by Taxand, a… – Continue reading
SINGAPORE – On December 9, 2014, Singapore became the first country in Southeast Asia to sign an Intergovernmental Agreement (IGA) on tax information sharing with the United States. The signing follows an in substance agreement reached between Singapore and the US in May 2014. Most countries around the world have… – Continue reading
Barbados appears to be moving into full financial information-sharing mode as the world’s most powerful countries put their foot down on tax evasion. It is already known that last November Government signed an Inter Governmental Agreement with the United States (US) to exchange information on their citizens who have thousands… – Continue reading
Data as of a week before deadline The total number of Indian financial institutions who have signed up with the American tax authorities under the Foreign Account Tax Compliance Act (FATCA) was less than 500 as per data from less than a fortnight ago. There were a total of 442… – Continue reading
The Federal Board of Revenue (FBR) is planning to introduce amendments to the income tax law in next federal budget (2015-16) to effectively deal with the transfer pricing issues of non-resident companies. Sources told Business Recorder on Monday that the first meeting of the FBR’s transfer pricing unit would be… – Continue reading
The Federal Board of Revenue (FBR) is planning to introduce amendments to the income tax law in next federal budget (2015-16) to effectively deal with the transfer pricing issues of non-resident companies. Sources told Business Recorder on Monday that the first meeting of the FBR’s transfer pricing unit would be… – Continue reading
Due to its geographical proximity to the mainland, modern and (until now) friendly banking system and transparent legal regime, Hong Kong has long served as a popular gateway into China for foreign businesses. Americans in particular have favored the former British colony, which retains its widespread use of the English… – Continue reading
Controversial proposals for a law to make failing to declare offshore income a criminal offence seem to have been put on the backburner by The Treasury. Chancellor George Osborne announced the measure as part of a campaign to stamp out tax evasion as part of his Budget 2014. However, no… – Continue reading
TWO noteworthy taxation amendments came into effect on the 1st of January 2015. The first tax amendment relates to the deductibility of interest paid to a person who is not liable to tax in South Africa, for example non-residents. The section in question, section 23M of the Income Tax Act,… – Continue reading
What’s coming our with with regards to the Foreign Account Tax Compliance Act (FATCA) in 2015? 2015 sees a number of impeding developments regarding FATCA compliance as the US presses on with its quest to target tax non-compliance by U.S. taxpayers with foreign accounts. Nick Matthews, Global Head of Forensic… – Continue reading
What’s coming our with with regards to the Foreign Account Tax Compliance Act (FATCA) in 2015? 2015 sees a number of impeding developments regarding FATCA compliance as the US presses on with its quest to target tax non-compliance by U.S. taxpayers with foreign accounts. Nick Matthews, Global Head of Forensic… – Continue reading
As a means of encouraging the development of intellectual property (IP) in Italy, rather than elsewhere, a “patent box” preferential tax regime has been introduced with effect from January 1, 2015, at the same time as a restructuring of the country’s research and development (R&D) tax credit system. Following the… – Continue reading
The Cayman Islands government announced it will not implement a central register of beneficial ownership information, but will continue its current method of providing this type of information to law enforcement, tax and regulatory authorities. At the same time, government proposes to enact new legislation that will improve access to… – Continue reading
Multinational enterprises (MNEs) may be concerned about various aspects of the six Discussion Drafts released during the third week of December 2014 as part of the Base Erosion and Profit Shifting (BEPS) Action Plan. Three of the papers are within Action items 8 to 10 of the BEPS Action Plan… – Continue reading
Medtronic Inc. took one step closer to becoming an Irish company when shareholders voted in favor of acquiring Dublin-based medical supply maker Covidien Ltd. Covidien shareholders similarly voted on the deal early today and also approved it. The acquisition now goes before the Irish High Court, which may take several… – Continue reading
Easy access drawdown rules for Qualifying Recognised Overseas Pension Scheme (QROPS) come with a twist in the tail. The Treasury and HM Revenue & Customs (HMRC) have confirmed QROPS are included in pension reforms that start from April 6, 2015 – which means retirement savers can access their QROPS fund… – Continue reading
Cyprus’ double tax treaty network has been expanded with three new agreements with Spain, Lithuania and Norway becoming effective as of January 1, 2015, boosting the island’s services sector that has been hammered by Russia’s intentions to clamp down on offshore interest and provide an amnesty for the repatriation of… – Continue reading
As the Organisation for Economic Co-operation and Development (OECD) passes the halfway point in its joint project with the G20 to address base erosion and profit shifting (BEPS) concerns, it is worth pausing to examine what the consequences of some of the proposed changes may be. Much of the focus… – Continue reading
Holley Nethercote commercial & financial services lawyers David Court, a partner at Holley Nethercote Commercial and Financial Services Lawyers was recently interviewed by an international publication regarding the implementation of FATCA in Australia. Below are some of David’s thoughts – How have you approached FATCA? What’s your biggest challenge? What… – Continue reading
HSBC, Sovereign, FedEx, DHL & UPS all expecting summons from IRS American IRS officials are said to be carrying out investigative work concerning FATCA transgressions from the American Consulate in Hong Kong, according to a report issued in the South China Morning Post. The article quoted Travis Benjamin, a Partner… – Continue reading
The future for offshore tax planning, also known as “aggressive tax planning” is likely to be limited to if not curtailed by the global exchange of information agreement signed in October, 2014 by 51 countries and growing. The link below is to a video summary of the predicted consequences of… – Continue reading
Trusts established by Portuguese resident individuals are now to be taxed for the first time after new rules were introduced on 1 January. On 17 December last year, the Government of Portugal introduced a change to its tax law meaning distributions from trusts to Portuguese residents would be taxed at… – Continue reading
The Cayman Islands has published a new report stating that, while it will not introduce a central registry of information on the beneficial ownership of companies, it will tighten up its beneficial ownership regime in other areas. The report follows industry consultation between November 2013 and February 2014 and broadly… – Continue reading
Multinationals told to be more cautious about intra-group transactions as Beijing imposes stiff measures against avoidance and evasion Multinationals have been advised to take notice of Beijing’s New Year resolution to crack down on tax avoidance and evasion, especially after the announcement of the general anti-avoidance rule (GAAR) and new… – Continue reading
HSBC Holdings and the city of Hong Kong, which were last month linked to an international tax evasion network, are currently under scrutiny as part of efforts by U.S. authorities to hunt down American tax evaders, the South China Morning Post (SCMP) reported Monday, citing lawyers. Official with the U.S…. – Continue reading
U.S. Internal Revenue Service officials are stepping up an international tax evasion investigation into HSBC Holdings and the city of Hong Kong in an effort to crack down on American tax evaders, the South China Morning Post reported. IRS officials are now stationed in overseas Asian jurisdictions, including at the… – Continue reading
Chief Palestinian negotiator Saeb Erekat on Saturday described as “piracy” an Israeli decision to stop the transfer of Palestinian tax revenues collected on behalf of the Palestinian Authority. “We were unofficially told a few hours ago that the Israeli government had decided to hold back tax revenues it collects on… – Continue reading
IN A PREVIOUS column (http://www.bworldonline.com/content.php?section=Economy&title=the-oecd-action-plan-on-base-erosion-and-profit-shifting&id=99561), we wrote about the general framework of the Base Erosion and Profit Shifting (BEPS) initiative, why addressing BEPS is a key priority for many governments across the globe, and the 15-point BEPS Action Plan drafted by the Organization for Economic Co-operation and Development (OECD). The… – Continue reading
FORMER Minister for Justice Gerry Collins has declined to comment on correspondence from his solicitors accusing the Public Accounts Committee of “exceeding its jurisdiction” in any further pursuit of allegations he had an Ansbacher offshore account. Mr Collins, as well as another retired Limerick minister, Des O’Malley, earlier this month… – Continue reading
New Delhi: As a probe continues into misuse of stock markets for routing black money and tax evasion, the regulatory and other agencies suspect that GDR route is being used for bringing back suspected illicit funds stashed abroad. The modus-operandi, in cases currently under scanner, involves an intricate web of… – Continue reading
We will probably never know their names, but one thing we do know – one in 20 of the richest people in Australia tried to evade paying their fair share of tax in recent years. By what authority do we know this? By none other than the Australian Taxation Office…. – Continue reading
COUNCILLORS will consider a call to join a national campaign against tax dodging at the next meeting of West Dorset District Council. Beaminster councillor Caroline Payne has submitted a notice of motion, which will be considered by members at the meeting on Thursday, January 8. The motion reads: “Please could… – Continue reading
Will a person working both in India and outside for a certain time be taxed in both the countries or is there any tax regulation present. Indians have become accustomed to taking up jobs outside India as an offshore assignment or project. That means spending some part of the year… – Continue reading
MUMBAI – At least 1,000 individuals and companies have come under Securities and Exchange Board of India’s (Sebi) scanner for allegedly using stock markets to evade taxes and launder money through companies mostly existing on paper. Sebi is focussing on securities market related violations by these individuals and companies, who… – Continue reading
The Price of Offshore Revisited was written by James Henry, a former chief economist at the consultancy McKinsey, for the Tax Justice Network. Tax expert and UK government adviser John Whiting said he was sceptical that the amount hidden was so large. Mr Whiting, tax policy director at the Chartered… – Continue reading
Europe’s tax showdown could be headed straight to people’s wallets. With the new year, a change in fiscal rules in the European Union is increasing the tax on many purchases of digital content like e-books and smartphone applications. Under the new rules, first approved in 2008, the tax rate on… – Continue reading
India is considering removing Cyprus from the blacklist of countries that do not share details about tax evaders after examining information given the island nation, reports from New Delhi have suggested. India had blacklisted Cyprus in 2013 for not sharing information about tax evaders. “They (Cyprus) have given some information…. – Continue reading
