AbbVie Inc. (ABBV) and Shire Plc agreed to terminate what would have been the biggest U.S. tax inversion after AbbVie pulled its support for the deal in the wake of proposed changes to U.S. rules governing such transactions. AbbVie, based in North Chicago, Illinois, planned to buy Shire for an… – Continue reading
Echegaray says account holders can take part in country’s fiscal amnesty If Argentines who hold 4,040 undeclared bank accounts in Switzerland don’t normalize their fiscal status and pay their debts, the AFIP tax bureau will file a complaint before the Office of Economic Crime and Money-Laundering (PROCELAC) requesting it investigates… – Continue reading
Lump sum taxation, the tailor-made measure tax regime designed to attract wealthy foreigners to Switzerland, is facing a crucial test as voters head to the polls on November 30 to decide whether or not to abolish the system for good. Proponents of the initiative say lump sum taxation is unfair… – Continue reading
Bombay High Court holds that shares issued at a premium by a resident entity to a non-resident entity is a capital account transaction and does not give rise to any income; Income arising from an International Transaction between AEs must satisfy the test of ‘income; as provided under the ITA… – Continue reading
Foreign structures are tempting targets for governments, says Vanessa Houlder. When governments around the world embarked on a drive to plug tax loopholes in 2012, the urgency of the move was underpinned by rising tensions over austerity and inequality. Widespread public outrage over alleged tax-dodging by wealthy individuals and multinationals… – Continue reading
A Residence Programme (“TRP Rules”) has been introduced with effect from 1 July 2013 for individuals who are nationals of the EU, EEA or Switzerland (but not Maltese nationals) in terms of Legal Notice 270 of 2014 and Articles 56(23) and 96 of the (Malta) Income Tax Act, Chapter 123… – Continue reading
DALLAS (CN) – Former Texas billionaire Sam Wyly filed for bankruptcy protection after a federal jury ordered him to pay as much as $400 million for using offshore trusts to hide stock trades. A noted philanthropist and contributor to Republican causes, Wyly, 77, of Dallas, made his fortune… – Continue reading
Climate Change Law Practice Group Blog, Environmental, Energy and Resources Law The BC Government tabled Bill 6, the Liquefied Natural Gas Income Tax Act, on October 2, 2014. Bill 6 sets out the features of the new LNG tax regime. The LNG taxation proposals have been the subject of great… – Continue reading
Unprecedented international collaboration is needed to overcome a single-, isolated-country view to tackling base erosion and profit shifting (BEPS) issues, Andrew Mills, Second Commissioner of Australian Taxation Office (ATO) for Law Design and Practice, has said. In a speech delivered at the Second Annual Tax Forum organized by the Tax… – Continue reading
Switzerland and Italy may agree amendments to their existing double tax agreement by spring 2015, Vieri Ceriani, Italy’s chief negotiator, has said. With the appointment of a new Government in Italy, Ceriani said that the provisions being sought by Italy, in particular on the division of taxes collected from Italian… – Continue reading
The Organization for Economic Cooperation and Development’s (OECD) plan for base erosion and profit shifting (BEPS) is already affecting corporations, according to speakers participating in a Captive Insurance Companies Association (CICA) transfer pricing webinar. Polling results during the webinar revealed attendees’ opinions were in line with tax industry surveys indicating… – Continue reading
With the BJP government arguing that the Double Taxation Avoidance Agreement entered into with Germany in 1995 by the then Congress government was the constraining factor in disclosing details of black money stashed abroad, the Congress Saturday hit back saying over a dozen pacts with similar confidentiality clause were signed… – Continue reading
(Reuters) – Italian luxury fashion house Prada SpA said on Monday its chairwoman Miuccia Prada and her husband, chief executive officer and fellow shareholder Patrizio Bertelli, are being investigated by Italian authorities over past taxes. The Hong Kong-listed company said in a statement it had been informed by the Italian… – Continue reading
New figures from HM Revenue & Customs reveal that almost five times more tax revenue is lost as a result of illegal activity than through avoidance. In fact, the figures show £3.1bn was lost in 2012-13 as a result of avoidance, compared with a total of £15.4billion from criminal attacks,… – Continue reading
The energy company has published retrospective accounts and pledges to stay away from tax havens Energy company SSE has become the first FTSE 100 business to be awarded the Fair Tax Mark, a scheme that aims to hold companies to account over their tax affairs. SSE, which has nine million… – Continue reading
New Zealand is losing $9.4 billion a year to economic crime. According to a draft report by the Serious Fraud Office, government ministers had been working on the cost of economic crime for two years. The report was expected to be presented before the Cabinet. A copy of the report… – Continue reading
Dividend represents a share of the company’s post-tax profit that is divided among its shareholders. In other words, once corporate tax has been paid on profit, the remaining earnings are distributed amongst shareholders as dividend. So far, so good. Then, this dividend is characterised as income in the hands of… – Continue reading
On 16 October, the Saeima (Parliament), in its final reading, passed the “Public Persons Enterprises and Capital Shares Governance Law” in order to promote more effective governance of companies owned by the state and local governments. The Secretary-General of the Organisation for Economic Cooperation and Development (OECD), Angel Gurría, has… – Continue reading
European Union finance ministers have reached a breakthrough agreement that will make it more difficult for tax cheats to hide their money. The new legislation, which had been blocked for years by countries with a reputation as tax havens, was approved last week after Luxembourg and Austria agreed to lift… – Continue reading
On July 15th 2014, the OECD published its 2014 update of the Model Tax Convention (“2014 OECD Update”). This update is the outcome of the work accomplished between 2010 and the end of 2013. It does not however take into account the OECD conclusions of the “Action Plan on Base… – Continue reading
The revenue implications for South Africa of ‘base erosion and profit shifting’ by corporate taxpayers are firmly in the crosshairs of the Davis Tax Committee (DTC) and Judge Dennis Davis hinted on Monday that recommendations were being considered to “detect and deter” tax-avoiding financial flows. Speaking at a G20 study… – Continue reading
Swiss authorities have confirmed that, if asked, they will assist India in efforts to confirm the genuineness of bank documents and will swiftly provide information on requests relating to non-banking dossiers. The commitment was made in a joint statement following a meeting between the Swiss State Secretary, Jacques de Watteville,… – Continue reading
Switzerland took a step forward on implementing its double taxation agreement (DTA) with Argentina as the Federal Council adopted the dispatch on the deal and submitted it to parliament for approval. Meanwhile, in Argentina the agreement has already been passed by the Foreign Affairs and Budget Committees of the Lower… – Continue reading
The Council agreed last tuesday, at a meeting of the Economic and Financial Affairs Council , on a draft directive extending the scope for the mandatory automatic exchange of information between tax administrations, enabling them to better combat tax evasion and to improve the efficiency of tax collection. The proposal… – Continue reading
There has been a lot of press coverage recently around the pricing and tax arrangements of multinationals, in particular Apple, Starbucks and Amazon. In this respect, the EU is undertaking in-depth investigates into these companies to establish whether the companies’ tax arrangements have breached EU State Aid rules. These cases… – Continue reading
Non-EU investment firms’ access to EU investors under MiFID 2 The recast Markets in Financial Instruments Directive (MiFID 2), along with its accompanying Regulation (MiFIR), were published in the Official Journal of the EU in June. The new legislation is currently expected to come into effect in January 2017. The… – Continue reading
Representation of foreign individuals who wish to purchase US residential property should include careful attention to the manner in which the income and gain from the property will be taxed in addition to the other aspects of ownership. In addition, it is important to be aware of the manner in… – Continue reading
Devolving further tax powers to Scotland would be “more complex than many might anticipate”, Scotland’s accountancy body has said. The Institute of Chartered Accountants of Scotland (ICAS) highlighted factors such as tax competition within the UK and the need to reduce tax avoidance. A commission is considering proposals for more… – Continue reading
In recent years, the United States has increased initiatives to counter tax evasion committed by U.S. persons who are not reporting and paying U.S. income tax on earnings derived from foreign financial assets. The Foreign Account Tax Compliance Act (“FATCA”) represents the latest major initiative in this regard, having been… – Continue reading
The Irish government decided last week to get rid of a tax loophole that has helped big multinational companies like Apple and Google avoid paying billions in taxes to any government at all. But hold the champagne: Ireland could well replace one problematic tax policy with another, leaving aggressive tax… – Continue reading
Nearly 105,000 financial institutions are listed on the US Internal Revenue Service (IRS) database of Foreign Account Tax Compliance Act (FATCA) organisations complying with the tax reporting rules for US citizens. The latest list was published on October 1, 2014 by the IRS and shows 104,344 financial organisations have signed… – Continue reading
IMF President Christine Lagarde (right) poses with OECD Secretary General Angel Gurria, prior to a meeting with International economic organisations at the OECD in Paris. PARIS: The moribund French economy could get a sharp boost each year over a decade if highly controversial reforms to help businesses are enacted, predictions… – Continue reading
These crimes hinder the development of societies, prevent strengthening the legitimacy of democracy SANTIAGO — Corruption and tax evasion are flagrant violations of human rights in Latin America, where they contribute to inequality and injustice in the countries of the region, according to studies and experts consulted by IPS. “Tax… – Continue reading
A number of American corporations are making news, and not in a good way. They have announced mergers with foreign companies so they can avoid paying U.S. taxes. They are seeking what is called a “tax inversion” and it allows an American corporation to merge with a foreign corporation, move… – Continue reading
New Delhi: Communist Party of India (Marxist) leader Brinda Karat on Saturday criticized the Prime Minister Narendra Modi-led NDA Government at the Centre for not disclosing the names of persons having money stashed away in safe havens abroad, and alleged that it exposed the utter hypocrisy and double standards of… – Continue reading
New Delhi: A delegation led by Shri Shaktikanta Das, Revenue Secretary and consisting of Shri K.V. Chowdary, Chairman, CBDT and ShriAkhileshRanjan, Joint Secretary (FT&TR) visited Switzerland on 15.10.2014 and held discussions with Swiss Finance and Tax Authorities on issues relating to Exchange of Information in tax matters. The Swiss delegation… – Continue reading
PANAMA CITY – Panama and Colombia said they will talk uninterruptedly to resolve a dispute that erupted after Bogota included the Central American nation on its list of tax havens. Panama’s vice president and foreign minister, Isabel De Saint Malo de Alvarado, and Colombia’s foreign minister, María Angela Holguín, delivered… – Continue reading
The tax gap has increased to £34bn in the past year according to the latest figure from HM Revenue and Customs (HMRC), but Baker Tilly’s George Bull has said that HMRC are nonetheless “winning the battle” against tax avoidance. The tax gap in the UK jumped from 6.6% in 2011-12… – Continue reading
Senate Finance Chairman Ron Wyden (D-Ore.) said Friday that he hopes to build on the pharmaceutical company AbbVie’s move away from a tax inversion. AbbVie’s board advised shareholders to vote against the proposed merger with the Irish competitor Shire, which Wyden said showed the company saw “the strategic business value… – Continue reading
COMMUNITY leaders in East Staffordshire have pledged to make a stand against tax dodgers, by backing a new campaign called Towns Against Tax Dodging. East Staffordshire Borough Council has signed up to the ActionAid movement, which aims to urge the Government to do more to tackle multi-national tax dodging in… – Continue reading
Some 19 British firms are at the center of an investigation into in a mammoth global money-laundering operation. The scheme was allegedly contrived to make $20bn (£12.5bn) worth of ill-gotten gains appear legitimate. The illicit funds are thought to have originated from criminal gangs and corrupt officials across the globe,… – Continue reading
IrishTonnageTax – The Irish Maritime Development Office (IMDO) has released a report Irish Tonnage Tax: Opportunities for the International Shipping Industry. The Irish tonnage tax regime has been established for over 10 years and offers one of the most competitive on-shore corporate tax rates to international shipping companies. The tonnage… – Continue reading
17/10/2014 – Full implementation of the structural reforms adopted and announced in France would boost potential annual economic growth by one third, or 0.4 percentage points per year over ten years, according to the OECD. In a report entitled Structural reforms in France: Impact on growth and options for the… – Continue reading
A plastic surgeon with a practice in the Basking Ridge section of Bernards has been accused of evading federal income taxes on more than $10 million of income. By ripping off the federal government, authorities said, David Evdokimow, 54, of Harding, led a lavish lifestyle. Now he is facing prison… – Continue reading
Ireland puts an end to a tax loophole that saved Google, Apple, Microsoft, and Facebook billions in taxes “Double Irish” might sound like a drink that corporate tax lawyers reach for at the prospect of paying higher tax bills, but it’s actually the name of a controversial — albeit legal… – Continue reading
Our Reaction The Irish Minister for Finance delivered his Budget 2015 (the “Budget”) speech this week. There was considerable domestic and international anticipation in advance of the Budget against a backdrop of significant recovery in the Irish economy and also international focus (including, in particular, under the OECD BEPS project)… – Continue reading
High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Emailftsales.support@ft.com to buy additional rights. Trustees of private family trusts are being urged to register with the US tax… – Continue reading
“It is the world’s best tax amnesty, “ says Morris Maroon, Head of the National Tax Team of law firm Rockwell Olivier. “There are only months before the best opportunity to turn foreign wealth tax-clean will come to an end. We will then see if the predictions of a particularly… – Continue reading
The reservation or grant of certain powers by settlors has always been possible under Bermuda’s trust law but, historically, there was some uncertainty about exactly how far settlors could go without calling the validity of the trust structure into question. The recently passed Trusts (Special Provisions) Amendment Act 2014 (TAA… – Continue reading
The much-awaited decision of the Bombay High Court was pronounced on October 10. Transfer pricing adjustment carried out in Shell/Vodafone case has been at the centrestage of every public discussion on Indian transfer pricing legislation. The incredulous stand taken by the tax authorities has evoked a strong response from investors… – Continue reading
