Category: Regulatory

Automatic Exchange of Information / Business / Framework / G20 / India / Internal Revenue Service (IRS) / Jurisdiction / OECD / Switzerland / Tax Authority / Tax Laws

Black money: Switzerland finds India’s data security laws ‘adequate’ for auto-sharing banking info

Posted On: August 6, 2017

The notification follows hectic parleys between India and Switzerland for introduction of AEOI (Automatic Exchange of Information) under guidance of G20, OECD (Organisation for Economic Cooperation and Development) and other global organisations. Switzerland found India’s data security and confidentiality laws “adequate” for entering into an automatic exchange of information pact,… – Continue reading

Australia / Australian Taxation Office / Business / Tax Avoidance

Company-tax cuts make trusts more attractive as tax minimisation strategy – experts

Posted On: August 3, 2017

An ATO ruling is being interpreted as allowing ‘bucket companies’ linked to trusts to be eligible for lower tax rate The federal government’s company-tax reforms are making the use of family trusts even more attractive as a tax minimising strategy, experts have warned. The Coalition’s company tax rate cut from… – Continue reading

IMF / Income Tax / Jurisdiction / Multinationals / Tax Reform / Tax Relief / USA

IMF Calls For Rethink On US Tax Reform Design

Posted On: August 3, 2017

The current plan for US tax reform would disproportionately benefit the wealthy, the International Monetary Fund has said, recommending more support for low-income taxpayers and higher indirect taxes. On the need for tax reform, the IMF said in its Article IV consultation for the United States that “the US personal… – Continue reading

Automatic Exchange of Information / Common Reporting Standard / South Africa / Voluntary Disclosure Program

Deadline for SARS voluntary disclosure soon

Posted On: August 2, 2017

Taxpayers have been reminded of the looming deadline for the Special Voluntary Disclosure Programme (SVDP) on 31 August 2017. SVDP is a window period for individuals and companies to regularise undisclosed or unauthorised foreign assets and associated income. It came into effect on 1 October 2016. Taxpayers are urged to… – Continue reading

Double Taxation / Double Taxation Agreement / Nigeria / Singapore

Nigeria, Singapore sign agreement to curb double taxation

Posted On: August 2, 2017

Nigeria’s federal government on Wednesday signed an agreement with Singapore that would help companies operating in the two countries avoid double taxation in their different bases. The agreement clearly spells out taxing rights of the two countries in respect of different incomes derived from each country. It will specifically assist… – Continue reading

FATCA / Internal Revenue Service (IRS) / Jurisdiction / Offshore Voluntary Disclosure Program / Tax Evasion

IRS Criminal Investigation chief plans new enforcement programs

Posted On: August 2, 2017

The International Revenue Service’s Criminal Investigation unit is readying two new programs focusing on data investigations and international tax enforcement. The data initiative will tie together the information uncovered by the IRS’s field offices around the country with headquarters in Washington, D.C. “We are standing up a nationally coordinated data… – Continue reading

Advance Pricing Agreement / Croatia / Legislation / Transfer pricing

Croatia implements Advance Pricing Agreements (APAs)

Posted On: August 2, 2017

APAs were recently implemented in the Croatian tax legislation. Our Transfer Pricing team briefly presents the main points of the Croatian legislation related to an APA. Transfer pricing legislation was introduced in Croatia by way of the Corporate Income Tax Act (CIT) on 1 January 2005. However, the Croatian tax… – Continue reading

Capital gains / Capital Gains Tax / Double Taxation / India / Property / Shares

New I-T rules may lead to double taxation, circumstantial valuation difficulties for share transfer

Posted On: August 2, 2017

The Act currently provides for income taxable as ‘capital gains’ to be computed after taking into account the full value of consideration received or accrued on transfer of a capital asset “A person doesn’t know how much he has to be thankful for until he has to pay taxes on… – Continue reading

Costa Rica / Income Tax / OECD / Revenue / Tax Evasion / Tax Reform / VAT

Higher and ampler sales tax recommended

Posted On: August 2, 2017

The Costa Rican government is very interested in forming part of the Organization for Economic Co-operation and Development (OECD http://www.oecd.org/ ). The OECD is formed by 35 nations to promote policies that will improve the economic and social well-being of people around the world. Last Thursday, economist Bert Brys, explained… – Continue reading

Budget / Business / Double Taxation Agreement / EU / Ireland / United Kingdom / VAT

Irish FinMin Considers Impact Of Brexit On Taxes

Posted On: August 2, 2017

As part of the Irish Budgetary process, officials from the Finance Department have published a paper on the implications of Brexit for Ireland’s tax system. The paper was prepared for consideration by the Tax Strategy Group (TSG), an interdepartmental committee chaired by the Finance Department. The papers produced by the… – Continue reading

EU / Tax competition / Tax Haven / United Kingdom

UK Will Not Become A ‘Tax Haven’ After Brexit: Hammond

Posted On: August 1, 2017

The UK will not engage in aggressive tax competition to attract business post-Brexit, Chancellor Philip Hammond has said. He added that the country’s economy will remain aligned with the European model after leaving the EU. “It is often said that London would consider launching into unfair competition in terms of… – Continue reading

Income Tax / India / Residency / Tax Laws

Learning with Times: Earning abroad? Know the tax rules

Posted On: August 1, 2017

Indians who are on deputation overseas or have settled overseas — whether by way of acquiring a permanent residency such as a green card in the US, or acquiring citizenship of a foreign country — need to be aware of their tax obligations in India. A recent move seeking details… – Continue reading

Business / China / Individuals / Tax Collection / Tax Evasion / Value Added Tax

Multi-dollar tax evasion discovered in import companies

Posted On: August 1, 2017

HÀ NỘI — A number of enterprises have taken advantage of technology used for tax collection to avoid paying taxes. The Law on Value Added Tax (VAT) regulates that unprocessed, or preliminarily processed, agricultural, forestry and aquatic products imported from foreign countries are not subject to VAT. However, if these… – Continue reading

Automatic Exchange of Information / Common Reporting Standard / Offshore / South Africa / Voluntary Disclosure Program

SA taxpayers with offshore cash, assets given deadline to disclose info

Posted On: August 1, 2017

The Common Reporting Standard (CRS) allows for the automatic exchange of information between tax authorities. Local taxpayers who may have stashed their assets in cash and property offshore have a month to disclose their earnings and ownership details to the South African Revenue Services (Sars). The deadline for the Special… – Continue reading

Banking / Bonds / Double Taxation / Interest / Lebanon / Revenue

Bankers in Lebanon cry foul over ‘double taxation,’ look to President

Posted On: July 31, 2017

BEIRUT: The Association of Banks in Lebanon and other private sector leaders are weighing the few options open to them as recently approved new tax measures, poised to be implemented soon, threaten to have a detrimental effect on their businesses and the overall economy. The few available options include trying… – Continue reading

Goods and Services Tax / Income Tax / India / Tax Evasion

Indian government to detect tax evasion using analytics on traditional data and social media information

Posted On: July 31, 2017

The algorithm will match residents’ spending patterns, as evidenced from their social media postings, with their declared income. Bloomberg reported that the Indian government will be rolling out a new data analytics platform, called Project Insight, to catch tax evaders. In addition to traditional taxation data, such as IT returns,… – Continue reading

FATCA / IGA / Jurisdiction / Offshore Tax Evasion / Turkmenistan / USA

US, Turkmenistan ink deal to implement FATCA provisions

Posted On: July 29, 2017

US Ambassador Allan Mustard and Turkmenistan’s Minister of Finance Gochmyrat Myradov signed an Intergovernmental Agreement (IGA) to implement the provisions of the Foreign Account Tax Compliance Act (FATCA), said the US Embassy in Ashgabat. The agreement underscores growing international cooperation to curb offshore tax evasion and marks a step forward… – Continue reading

Austria / Tax Avoidance / Tax Evasion / Tax Fraud

Austrian finance minister: fighting tax evasion will be EC presidency priority

Posted On: July 29, 2017

ZURICH (Reuters) – Pushing forward European and international measures to prevent profit shifting and international tax fraud will be a top priority for Austria’s European Council presidency in the second half of 2018, Austrian Finance Minister Hans Joerg Schelling said on Saturday. “The cross-border fight against tax fraud and tax… – Continue reading

EU / Jurisdiction / Malta / Offshore Financial Centres / Tax Avoidance / Tax Haven

‘Malta is main EU tax haven’ – study

Posted On: July 29, 2017

“Disproportionate” value disappears from economic system compared to GDP Malta ranks first among a number of EU countries in a list of what a new study calls 24 “sink offshore financial centres”, which it says are typically characterised as tax havens. The study, published this week in the academic journal… – Continue reading

Corporate Tax / Dividends / Earnings stripping / Interest / IRS / Multinational Corporations / USA

US government delays Obama earnings-stripping rule deadline

Posted On: July 29, 2017

The change converts tax-deductible interest payments employed by the schemes into taxable stock dividends. The U.S. government on Friday gave companies an extra year to comply with an Obama-era regulation meant to crack down on corporations that try to minimize their U.S. tax bills by shifting profits abroad to countries… – Continue reading

Brunei / Cambodia / Double Taxation / Double Taxation Agreement / Framework / Tax Evasion

Kingdom, Brunei pen agreement over taxes

Posted On: July 28, 2017

Cambodia signed a double taxation agreement (DTA) with Brunei aimed at preventing dual taxation and fiscal evasion, the Ministry of Economy and Finance said yesterday in a press release. This is the third DTA agreement that Cambodia has signed after Singapore and China, while the government is currently developing framework… – Continue reading

Banking / Compliant / Tax Reform / Zambia

Zambia revenue agency to freeze bank accounts without tax numbers

Posted On: July 28, 2017

LUSAKA, July 28 (Xinhua) — Zambia’s revenue agency warned on Friday that it will freeze all bank accounts holders without Tax Payer Identification Number (TPIN) by the end of this year. The Zambia Revenue Authority (ZRA) said having a TPIN was a pre-requisite to all procedures of tax registration and… – Continue reading

Armenia / Double Taxation / Israel

Israel, Armenia Sign MoU on Abolishing Double Taxation

Posted On: July 27, 2017

Israel wants to develop friendly relations with Armenia, according to that country’s Regional Cooperation Minister, Tsakhi Hanegbi, who told Foreign Minister Edward Nalbandian on Wednesday as he kicked off an official visit to Armenia. He said that the purpose of his visit was to advance those ties. The two signed… – Continue reading

Double Tax Treaty / Georgia / Kyrgyzstan

Kyrgyzstan ratifies double tax treaty with Georgia

Posted On: July 26, 2017

On 22 June 2017, the parliament of Kyrgyzstan approved the bill ratifying the tax treaty signed with Georgia on 13 October 2016. Currently, the ratification from Georgian side is still pending, and in order to become law and to be ratified, the bill still needs to be signed by the… – Continue reading

Budget / Corporate Tax / Income Tax / Tax Reform / Transfer pricing

Tax Issues That Have Executives Biting Their Nails

Posted On: July 26, 2017

Federal income tax reform is by far the biggest concern of corporate tax executives, a new survey from Bloomberg BNA reveals. Survey of Corporate Tax Departments 2017 spotlights several key tax issues, and “corporate tax professionals are facing a wealth of challenges as they look to prepare their businesses for… – Continue reading

Framework / Indonesia / Singapore / Tax Amnesty / Tax Collection / Tax Evasion / Tax Reform

Indonesia Passes Law to Chase Tax Evaders Overseas

Posted On: July 26, 2017

New law to fulfill requirements under OCED’s AEOI framework Move could unlock billions of dollars of assets kept abroad Indonesia moved a step closer to hunting down tens of billions of dollars it believes its citizens have hidden abroad after political parties agreed to seek a parliamentary approval for a… – Continue reading

Automatic Exchange of Information / Banking / Russia / Tax Authority

More Rich Russians Are Declaring Foreign Bank Accounts

Posted On: July 26, 2017

The number of wealthy Russians declaring foreign assets has spiked in recent months, the RBC news outlet reported, citing research conducted by real estate broker Tranio and British company Adam Smith Conferences. The number of Russians with assets worth at least $1 million who revealed foreign bank accounts has increased… – Continue reading

Banking Secrecy / Philippines / Tax Reform

DOF courts Senate support in relaxing bank secrecy law

Posted On: July 26, 2017

The Department of Finance (DOF) on Wednesday asked the Senate to support the proposal relaxing the country’s bank secrecy law as it would allow the Bureau of Internal Revenue (BIR) to conduct the proper audit in tax fraud cases. Absolute bank secrecy is one of the “major” issues that need… – Continue reading

Corporate Tax / France / Google / Ireland / Permanent establishment / Revenue / Tax Avoidance / Tax Collection / Tax Dispute

France Open To Negotiated Tax Settlement With Google

Posted On: July 25, 2017

France intends to appeal against a recent court decision in favor of Google in a major tax avoidance case, but is open to settling the dispute outside of court, a government minister has said. In an interview with Les Echos, Minister of Action and Public Accounts, Gerald Darmanin, said that… – Continue reading

Business / Capital gains / Corporate Tax / Framework / Income Tax / Ireland / United Kingdom

Ibec Publishes Irish Budget Wish List

Posted On: July 24, 2017

Business group Ibec has said that the Irish Government must “Brexit proof” its 2018 Budget, improve its foreign direct investment model, and implement a range of tax reforms to compete with the UK. Publishing the group’s pre-Budget submission, Ibec Director of Policy and Public Affairs, Fergal O’Brien said: “The Irish… – Continue reading

Business / Compliant / Europe / Greece / Italy / Jurisdiction / Legislation

Worldwide: Italy And Greece Among Most Complex Places In The World For Accounting And Tax Compliance

Posted On: July 24, 2017

Italy is the most complex jurisdiction in Europe and comes in first place globally for ‘tax’ complexity, while Greece is most complex in the world for ‘compliance.’ Italy and Greece are among the five most complex jurisdictions in the world for Accounting and Tax compliance, according to TMF Group’s inaugural… – Continue reading

Corporate Tax / Income Tax / Legislation / Luxembourg / OECD / Revenue

OECD Praises Luxembourg’s Tax Regime

Posted On: July 24, 2017

The OECD has praised Luxembourg’s tax regime for its predictability, although it sounded a warning about the volatility of tax revenues from the financial sector. In its latest assessment of the Luxembourg economy, the OECD said that Luxembourg’s strong economic performance was due partly to “business-friendly regulations, a predictable tax… – Continue reading

Exemptions / Income Tax / Offshore Tax Haven / South Africa / Tax Exempt

The consequences of scrapping tax exemptions on income earned outside SA

Posted On: July 24, 2017

Economist Magnus Heystek says that government’s push towards scrapping tax exemptions for South Africans earning a salary in foreign country will encourage a tax revolt. South Africans have expressed a mix of concern and outrage over the past week, following the news that the government is seeking to scrap tax… – Continue reading

Inheritance Tax / Japan / Residence / Tax Evasion

Gift and inheritance tax reforms leave more of Japan’s foreign residents liable

Posted On: July 23, 2017

Reader M wrote to Lifelines about Japan’s inheritance tax law, which he calls “one of the most punitive in the world”: I’ve read with interest a number of articles in The Japan Times recently about the Japanese government’s efforts to make it easier for foreigners to obtain permanent residence in… – Continue reading

Dubai / Residence / South Africa / Tax Laws / UAE

Bizarre tax treaty could let the Guptas leave SA with billions: report

Posted On: July 23, 2017

The Gupta family sought advice on how to move tens of billions of rands to the United Arab Emirates, revealing the enormous size of their empire, according to a report by the Sunday Times. The treaty which came into effect in March this year, stops the South African Revenue Service… – Continue reading

Australia / Multinationals / Tax Avoidance / Tax Evasion / United Kingdom

Govt shies away from ‘draconian’ penalty to stop multinational tax dodgers

Posted On: July 22, 2017

Tax avoidance by multinationals is better dealt with by an international treaty than harsher measures brought in by Australia and the United Kingdom, Revenue Minister Judith Collins says. In an interview with TV3’s The Nation, the minister said she had not ruled out the idea of diverted profit tax, which… – Continue reading

Australia / Capital Gains Tax / Housing / Residence / Tax Break

Australia Announces Housing Tax Breaks

Posted On: July 21, 2017

The Australian Government has unveiled a package of housing tax breaks, including a new scheme for first-time buyers, a superannuation incentive for downsizers, and tighter rules for foreign residents. In a joint release, Treasurer Scott Morrison and his Assistant Minister, Michael Sukkar, said: “Housing affordability is a major issue affecting… – Continue reading

Double Taxation / EU / HMRC / United Kingdom / VAT

UK To Levy VAT On Telecoms Services For Overseas Brits

Posted On: July 21, 2017

HM Revenue and Customs (HMRC) has released guidance on a change to value-added tax rules to tax services used outside the EU by UK consumers. The changes, which were introduced in the Spring Budget 2017, will affect suppliers of mobile telecommunication services, private consumers, and non-business users who consume telecommunication… – Continue reading

Framework / Ireland / Residence / Tax Authority / Withholding Tax

Irish Committee Calls For WHT For Overseas Artists

Posted On: July 21, 2017

The Irish Parliament’s arts committee has recommended the introduction of a “foreign artists’ withholding tax (WHT) scheme.” The committee has released a report on the Government’s Culture 2025 initiative, which is intended to provide a framework for the development of Irish arts, culture, and heritage over the next eight years…. – Continue reading

Capital gains / HMRC / Inheritance Tax / Legislation / Residence / United Kingdom

2017 changes to the taxation of non-domiciliaries – deemed domicile status, rebasing, cleansing mixed funds, business investment relief

Posted On: July 21, 2017

THE BENEFITS OF NON-DOMICILE STATUS An individual who is resident but not domiciled in the UK does not pay tax on overseas income and gains, as long as they are kept outside the UK and are not used to provide benefits in the UK. This is called the remittance basis… – Continue reading

Business / Cambodia / Double Taxation / Double Taxation Agreement / Framework / Tax Evasion / Thailand / Withholding Tax

Push to draw up Cambodia-Thai tax treaty

Posted On: July 20, 2017

Representatives from the tax authorities of Cambodia and Thailand have agreed in principle to speed up a proposed double taxation agreement that would protect their nationals from dual taxation and encourage bilateral investment. The agreement was made last week during a two-day consultation workshop in Bangkok for tax officials from… – Continue reading

Automatic Exchange of Information / Indonesia

DPR Will Pass Perppu on AEOI into Law: Former Official

Posted On: July 19, 2017

Hadi Poernomo, former Director General of Tax, the Finance Ministry, believes that the House of Representatives (DPR) will pass the regulation in lieu of law (Perppu) No. 1/2017 on Automatic Exchange of Information (AEOI) into law. “The Perppu is similar what was agreed between the DPR and the government on… – Continue reading

India / Law Firm / Offshore / Tax Avoidance / Tax Evasion / Tax treaties

Panama papers: India discusses tax info exchange with global joint task force to plug evasion

Posted On: July 19, 2017

India has participated in the global joint task force meet to discuss with countries information exchange as it looks to pursue work on the Panama Papers, the finance ministry said on Tuesday. The Joint International Taskforce on Shared Intelligence and Collaboration (JITSIC) meeting was reconvened in Paris in the last… – Continue reading

Income Tax / India / Tax Authority / Tax Evasion

India Issues Update On Tax Evasion Crackdown

Posted On: July 19, 2017

The Indian tax authority has announced that it has begun the second phase of its Operation Clean Money initiative, within which it will challenge those taxpayers that have potentially failed to declare all their income. The agency said that 556,000 taxpayers’ affairs will be scrutinized as amounts deposited in bank… – Continue reading

Australia / Capital gains / Capital Gains Tax / Income Tax / Trust

Australia Improves Financial Services Tax Regime

Posted On: July 19, 2017

The Australian Government has moved to clarify the tax treatment of foreign investors, following concerns over the practical operation of the Investment Manager Regime (IMR) and the new tax system for managed investment trusts (MITs). The aim of the IMR is to attract foreign investment to Australia and the promote… – Continue reading

Canada / Canada Revenue Agency / Common Reporting Standard / Offshore Tax Haven / Privacy / Residence / Tax cheats / Tax Evasion

‘Come to CRA before we go to you’: International deal designed to expose offshore tax cheats

Posted On: July 18, 2017

Canada and dozens of other countries will automatically share banking information of non-residents Canadians with secret overseas bank accounts could soon find themselves at risk of being exposed by a new international agreement designed to help catch tax cheats. Under the Common Reporting Standard, dozens of countries will share information… – Continue reading

Business / Central Board of Direct Taxes (CBDT) / Incorporation / India / Jurisdiction / Place of Effective Management (PoEM)

Taxation of foreign companies regarded as ‘resident’ in India

Posted On: July 18, 2017

Tax liability under the Income-tax Act, 1961 (‘the Act’) of any person is determined based upon his residential status. A person resident of India is taxable on his income accruing across the globe [see End Note 1] while a non-resident is taxable only on the income accruing or arising or… – Continue reading

Multinationals / New Zealand / Tax Avoidance / Tax Haven / Transfer pricing

Labour plans crackdown on multinational tax avoidance to help fund spending plans

Posted On: July 18, 2017

Labour is threatening to crack down on multinational companies that are dodging paying their fair share of tax in a move it believes will net $200 million a year in extra tax for the Government. Leader Andrew Little said according to Inland Revenue, New Zealanders were missing out by hundreds… – Continue reading

Bulgaria / Cyprus / EU / European Commission / Legislation / Portugal / State Aid / Tax Avoidance / Tax competition / Tax Planning

EU Takes Legal Action Against Portugal, Two Others on Tax Deals

Posted On: July 18, 2017

The European Commission launched legal proceedings against Portugal, Bulgaria, and Cyprus for not adopting, in their national laws, European Union legislation requiring all EU countries to exchange tax rulings granted to multilateral companies. The legislation was adopted in the wake of the 2014 LuxLeaks scandal that revealed more than 100… – Continue reading

Accelerated Payment Notices / Corporates / HMRC / Individuals / Tax Authority / Tax Avoidance / United Kingdom

HMRC tops £4bn in tax avoidance scheme crackdown

Posted On: July 18, 2017

HM Revenue and Customs (HMRC) has collected more than £4bn through its controversial ‘pay now, dispute later’ accelerated payment notices rules, for people who have used a tax avoidance scheme. HMRC said that more than 75,000 accelerated payment notices (APNs) have been issued to people under enquiry for tax avoidance… – Continue reading

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