Category: Regulatory

Pakistan, Switzerland to sign agreement for bank account information exchange: Dar

Finance Minister Ishaq Dar on Wednesday told the National Assembly that Pakistan will sign an agreement with Switzerland on exchange of information regarding bank accounts on March 21. “The Swiss government offered to sign such an agreement with Pakistan in the third quarter of the current month that will enable… – Continue reading

Five things agents and developers need to know about the non-dom tax changes

From 6 April 2017, non-dom owners of UK property will be liable to inheritance tax (IHT) at 40% on any UK residential property they own. This has always been the case where a non-dom (broadly an individual who is resident in the UK but who has their permanent home abroad)… – Continue reading

India, Belgium sign protocol to amend double taxation avoidance agreement

New Delhi, March 9 (IANS) India and Belgium have signed a Protocol to amend the double taxation avoidance agreement to curb tax evasion, an official statement said on Thursday. “India and Belgium have signed a protocol amending the existing agreement and protocol between the two countries for avoidance of double… – Continue reading

Romania Joins BEPS Inclusive Framework

Romania approved legislation to join the OECD’s base erosion and profit shifting Inclusive Framework on March 2. As an Associate member under the Inclusive Framework, Romania will work on an equal footing with other associates and G-20 and OECD countries in the development of further BEPS standards and the peer… – Continue reading

Hong Kong Government Considers Expanding Its List of “Reportable Jurisdictions” for Automatic Exchange of Information

Under increasing international pressure, the Hong Kong government is considering expanding its Automatic Exchange of Information (AEOI) implementation by imposing broader information collection obligations, entering into more bilateral AEOI agreements at a faster pace, and possibly joining the multilateral AEOI agreement. Background Hong Kong legislated to adopt the OECD Common… – Continue reading

Chancellor slaps 25% charge on people who move pensions abroad to dodge UK tax bills

People still be able to shift pensions overseas tax-free if they and their pot are located in same country Stiff new penalty is aimed at those who retire to one country while parking their pension in an offshore tax haven The Chancellor is to slap a 25 per cent charge… – Continue reading

Anti-money laundering rule looms for advisers

WASHINGTON — In the current deregulatory environment, investment advisers might expect a reprieve from new federal compliance rules. But one exception is the proposal for an anti-money-laundering regulation, which experts believe is likely to become the law of the land, bringing with it a significant new compliance responsibility. A year… – Continue reading

Offshore tax evasion: compliance and penalties – part 1

Sometimes it can be hard to keep up with the avalanche of government announcements on tax avoidance and evasion. In the first of a two part series, Jason Collins, a member of the CIOT’s management of taxes sub-committee and partner at Pinsent Mason, provides an overview of the rapidly changing… – Continue reading

Wolf proposal to eliminate Delaware loophole

Creating a fairer tax system is on the state budget agenda again with a proposal from Democratic Gov. Tom Wolf to eliminate a business tax loophole. Wolf wants to close the Delaware loophole — a mechanism that allows businesses headquartered in other states to avoid paying taxes on their operations… – Continue reading

Irish Citizen Denied US Tax Refund On Gambling Winnings

The United States Court of Federal Claims has turned down a claim from an Irish citizen that more than USD5m in US tax withheld on gambling winnings should be refunded under the US-Ireland double tax avoidance treaty. The claim was filed by the plaintiff, John P McManus, after USD5.22m in… – Continue reading

Inflation: How government is collecting more tax revenues by stealth

These three CGT exclusions have remained unchanged for five years. Over the last few years government has collected a significant amount of tax revenue by not fully adjusting the personal income tax tables for inflationary increases in earnings, thereby increasing the effective tax rate of individuals. A middle-class individual earning… – Continue reading

MPs approved exchange of information

The parliament transposed the EU regulation, whose aim is to secure comprehensive and effective administrative collaboration between tax administrations via mandatory automatic exchange of information. International corporations will be required to submit reports about their activities in every EU country in which they do business. This stems from the amendment… – Continue reading

HK’s proposed dedicated tax regime for offshore aircraft leasing

The Hong Kong Government has put forward a proposal to amend its tax laws to establish a dedicated tax regime for aircraft owners/lessors based in Hong Kong and leasing to offshore (including PRC) lessees/airlines (see Timeline / References below) (“Proposed Regime”). Assuming there are no surprises or drafting issues in… – Continue reading

Israel: “Wallet Companies”- Draft Tax Bill Within The Scope Of The Arrangements Law For 2017 – 2018

Recently, the Finance Committee concluded its deliberations regarding the imposition of tax legislation pertaining to “wallet companies” (companies owned by individuals who provide services through them) within the scope of the Arrangements Law for 2017 – 2018. The original draft bill was softened and even sweetened for a particular period… – Continue reading

Bills, cars, bank accounts: the Italian Revenue Service will chase evaders who pretend to be abroad

The Italian Revenue Agency is stepping up its fight against international tax evasion. The tax authority will focus on undeclared funds and income held abroad by Italian taxpayers who have become resident abroad since January 1, 2010. Controls will be based on selected lists, which will first target the most… – Continue reading

Indiana Combined Reporting and Transfer Pricing Studies

On October 1, 2016, the Indiana Office of Fiscal and Management Analysis of the Indiana Legislative Services Agency released a Combined-Reporting Study and a Transfer Pricing Study. These studies, which address corporate income tax issues, were required by legislation passed in 2016. The Combined-Reporting Study discusses the reduction of state… – Continue reading

S. Korea Probing Toyota Korea over Suspected Tax Evasion

South Korea’s tax authorities have been investigating the local importer of Toyota and luxury Lexus vehicles over suspected tax evasions since late 2016, industry sources said Friday. In November, the Seoul office of the National Tax Service (NTS) launched a tax audit into Toyota Korea over suspicions that it paid… – Continue reading

KPMG offshore tax dodge a ‘facade’ designed to hide money, ex-client says

Accounting firm’s contracts with federal government questioned. A former client of the accounting giant KPMG says a tax dodge that involved wealthy people gifting their money to an offshore jurisdiction was a “facade” designed to hide money from the taxman. The client, who spoke to CBC’s the fifth estate and… – Continue reading

EU Mulls Tax Sanctions for Countries Branded Tax Havens

Countries that end up on the European Union’s list of tax havens could subject companies operating within their borders to tax sanctions—such as withholding taxes and denied deductions for royalty payments—damaging the businesses’ ability to offset losses in the jurisdictions. Following a March 1 meeting, politicians identified a range of… – Continue reading

Government introduces bill to establish ITA as a statutory body

New legislative proposals aim to establish the BVI International Tax Authority (ITA) as a fully fledged independent government institution in the British Virgin Islands with its own legal personality, giving it autonomy over the performance of its functions. The ITA was initially established within the Ministry of Finance to administer… – Continue reading

3 Key Tax Rules Governing Typical Business Deductions

What is a business expense deduction? A business expense deduction is a deduction allowed for ordinary and necessary expenses paid or incurred in connection with an individual’s trade, business or profession. IRC Section 62(a)(1) operates to assure that all trade or business expenses, deductible as delineated under specific IRC Sections,… – Continue reading

New Zealand: New Zealand To Enact Tighter Foreign Trust Disclosure Rules

The New Zealand Parliament has passed a Bill which, following royal assent, will meaningfully increase disclosure obligations for NZ resident trustees of NZ foreign trusts. The Taxation (Business Tax, Exchange of Information, and Remedial Matters) Bill, was passed by Parliament on 14 February 2017. The Bill contains important provisions relating… – Continue reading

U.S. Agents Raid Caterpillar Over Offshore Tax Practices

Federal agents raided three Caterpillar buildings near its Illinois headquarters on Thursday, company and law enforcement officials said, in an escalation of an inquiry into the heavy equipment manufacturer’s offshore tax practices. Caterpillar has been dogged by accusations that it slashed its domestic tax bill by shifting corporate profits from… – Continue reading

Russian Federation: Confirmation Of Direct Investment In Capital To Apply A Reduced Tax Rate On Payment Of Dividends

On 30 December 2016 the Commercial Court of Voronezh Oblast delivered a judgement in case No. А14-10190/2014 (the “Decision”) under the claim of Ilyushin Finance Co. Open Joint Stock Company (the “Company”). The case is an example of a broad interpretation of the list of documents confirming entitlement to a… – Continue reading

Foreign person NRA tax withholding

Nonresident Alien NRA tax withholding is applicable to U.S sourced income paid to foreign person and does not apply to payments made to U.S. persons. Foreign persons include nonresident alien individual, foreign partnerships, foreign corporations, foreign estates, and foreign trusts. The tax generally must be withheld from the payment made… – Continue reading

Oman’s ministry of finance launches taxation portal

Muscat: A portal for entities subjected to taxation was launched on Wednesday by the ministry of finance. The ministry, represented by the Secretariat General for Taxation launched the portal www.taxoman.gov.om. The portal has legislations, taxation charts and agreements on avoidance of double taxation as well as developments in the field… – Continue reading

IRS Reminds International Taxpayers of Filing Obligations

The Internal Revenue Service (IRS) has reminded certain non-US citizens, such as international students and scholars working or receiving scholarship funds, that they may have special requirements to file a US tax return. The IRS also reminded withholding agents, such as payroll professionals or universities, that accurately filed Forms 1042-S,… – Continue reading

Inheritance tax Residence Nil Rate Band: why it won’t benefit everyone

The new Residence Nil Rate Band will allow people to pass on property to their descendants tax free. But some people need to take action now or risk missing out. In April, a major change to inheritance tax (IHT) law comes into effect with the launch of the Residence Nil… – Continue reading

Vietnam-US double taxation avoidance agreement approved

The Government recently issued a resolution to ratify an agreement and a protocol on avoiding double taxation and preventing income tax evasion between Vietnam and the United States of America. The Ministry of Foreign Affairs was asked to complete necessary procedures in accordance with law. Meanwhile, the Ministry of Finance… – Continue reading

EU wants stricter transparency rules on ownership to prevent tax evasion and fight Money Laundering

The European Parliament’s Monetary Affairs and Civil Liberties committees’ overwhelming support for access by EU citizens to information concerning the beneficial owners of companies without having to demonstrate a ‘legitimate interest’ and trusts would have to meet the same requirements. MEPs agreed the on their position on EU Anti-Money Laundering… – Continue reading

Global transfer pricing standards with local impacts

THE ORGANISATION for Economic Cooperation and Development (OECD) initiated the base erosion and profit shifting (BEPS) project in 2013 to address perceived gaps in international tax rules causing a loss of revenues for governments of about US$100 billion to $240 billion (Bt3.5 trillion to Bt8.4 trillion) annually. The OECD’s BEPS… – Continue reading

Chinese companies seek cheaper offshore debt after rule change

[HONG KONG] More Chinese companies are looking to raise debt offshore after Beijing approved a new funding structure last month that makes it easier and cheaper to tap foreign lenders. China’s foreign exchange regulator in January let domestic companies bring home cash raised through offshore bonds secured by onshore guarantees,… – Continue reading

Increasing tax revenue: Is a new approach required?

The importance of taxation to a nation’s economic wealth and development cannot be overemphasised. However, the achievement of this goal is often undermined by tax evasion and deliberate attempts by multinationals to shift profits from one jurisdiction to another, amongst others. Over the years, Nigeria has attempted to use taxation… – Continue reading

Tax evasion: 453 fake registered persons detected

KARACHI: Directorate Intelligence and Investigation, (DI&I) Inland Revenue Karachi has detected around 453 fake registered persons, who were reportedly involved in Rs 5.6 billion tax evasion. According to sources, the DI&I-IR, Karachi under the supervision of its Director Hyder Ali Dharejo has kicked off a crackdown against tax mafia, who… – Continue reading

Netherlands: Trends I Netherlands Moves Away From Fiscal Offshore Industry

The Netherlands is slowly but surely steering away from facilitating the use of its corporate income tax system by companies that are set up merely to obtain tax benefits. These companies, which often do not actually carry out activities in the Netherlands, have contributed to the perception among policy makers… – Continue reading

Canada To Ramp Up Efforts Against Tax Evasion

The Canadian Government has said that it will review its tax ruling process and voluntary disclosures program as part of its response to recommendations made last year by a parliamentary committee. In October 2016, the Standing Committee on Finance released its report on the Canada Revenue Agency’s (CRA’s) efforts to… – Continue reading

Luxembourg: Luxembourg’s New Transfer Pricing Rules: Some Compliance Required!

On 22 December 2016 the Luxembourg Parliament passed article 56bis of the Luxembourg Income Tax Law (LITL). This provision gives taxpayers and tax authorities more guidance on how to apply the arm’s-length principle. The new article can be seen as a transposition of OECD BEPS reports (actions 8-9-10) released in… – Continue reading

Taxing issues: multinationals still routing profits through Ireland

New Oxfam report indicates Government measures to tackle tax avoidance are failing Multinationals are continuing to route billions of euro in profit to and through Ireland to avoid tax, according to a new report by Oxfam Ireland. The study, which suggests that Government measures aimed at tackling tax avoidance are… – Continue reading

Transfer Pricing in China

Transfer pricing—the price charged for intercompany transactions between entities in different tax jurisdictions—can be used to shift funds within a multinational corporation (MNC), and serves as an effective means to manage a firm’s finances. Transfer pricing—the price charged for intercompany transactions between entities in different tax jurisdictions—can be used to… – Continue reading

Companies Get Draft Instructions for U.S. Global Tax Reports

U.S. multinational companies with more than $850 million in annual consolidated gross income now have draft instructions for filing IRS reports on their global tax and profits. The Internal Revenue Service added instructions to the draft Form 8975 and accompanying draft Schedule A it released in December 2016, companies that… – Continue reading

HSBC discloses tax evasion probes in India, other countries

Global banking giant HSBC has disclosed being probed by tax authorities in India and several other countries, including against its Swiss and Dubai units, for allegedly abetting tax evasion of four Indians and their families. Besides, the bank has been approached by the regulatory and law enforcement agencies of various… – Continue reading

Tax evasion can lead to hefty fine, jail term under new Omani law

Muscat: Dodging taxes can lead to a jail term of up to three years and a maximum fine of OMR50,000 under tax law amendments published by the Ministry of Finance, as government begins its crack down on evaders. Out of the 300,000 companies registered by the Oman Chamber of Commerce… – Continue reading