In August 2015, the Organisation for Economic Co-operation and Development (OECD) published the first edition of the Common Reporting Standard (CRS) Implementation Handbook to provide practical guidance to assist government officials in implementing the Standard for Automatic Exchange of Financial Account Information in Tax Matters (AEOI). The AEOI and CRS… – Continue reading
The Irish Revenue has issued a brief explaining how the implementation of a most favored nation clause in Ireland’s tax treaty with Estonia will affect the tax treatment of royalties. Ireland’s Double Tax Convention (DTC) with Estonia became effective in 1999. It contains a provision whereby the tax treatment of… – Continue reading
For a month starting May 3, The Treasury of the Australian government will be accepting submissions from interested parties to comment on a newly-released discussion paper entitled ‘GST treatment of digital currency’ as part of the 2016-17 Budget. The Treasury says the government has realized that consumers are ‘double taxed’… – Continue reading
The tax treatment of non-domiciled individuals is changing again from April 2017. The changes were first announced in the 2015 Summer Budget, and a Consultation document was issued in September 2015 setting out further details. The proposed changes target three key areas: The taxation of non-domiciled individuals who have been… – Continue reading
US disregarded entities owned by foreign persons would be treated as domestic corporations under regulations proposed by the US Internal Revenue Service (IRS) on Friday (REG-127199-15). The new rules would apply for purposes of the reporting, record maintenance, and other compliance requirements that apply to 25% foreign-owned domestic corporations under… – Continue reading
Hot off the heels of the Panamanian documents leak, 5 EU countries announced last month that they have agreed to exchange beneficial ownership information. France, Germany, Italy, Spain and the UK will now automatically exchange information on the ultimate beneficial owners of companies and trusts. These 5 EU countries are… – Continue reading
Only a week after the so-called Panama Papers burst into the media spotlight early last month, the Canadian government issued a news release vowing to “crack down on tax evasion and tax avoidance.” The leak of a staggering 11.5 million documents from a Panama City law firm promised to reveal… – Continue reading
Islamabad—The Benami Transactions (Prohibition) Bill, 2016 will enable the government to tackle with the problem of tax evasion and black money and transactions being carried out in other people’s names. The said bill will also to put an end to benami transactions, and to empower the government to recover such… – Continue reading
With regard to the increasing talk in the US Congress on tax reform, American Citizens Abroad (ACA) has provided the House of Representatives Ways and Means Committee with a full reform proposal for the enactment of residence-based taxation (RBT) for American expatriates. ACA has said lawmakers should enact RBT instead… – Continue reading
Governor Jack Markell will extend Delaware’s hospitality (home to more corporations than people) to Blockchain firms. Speaking at the Bitcoin community’s event in New York, Consensus 2016, Democratic Governor Jack Markell announced an initiative by the U.S State of Delaware to embrace the blockchain industry. His plan is to provide… – Continue reading
TOKYO — Do the rich and powerful really dodge taxes? They do. The “Panama Papers” – 11.5 million or so documents leaked from a Panama law firm specializing in tax shelters of various kinds and degrees of ingenuity – are shocking, however, not only to the naively innocent but to seasoned… – Continue reading
The US District Court for the Southern District of Ohio has dismissed a case brought by Senator Rand Paul (R – Kentucky) and a group of individuals, who attempted to make several challenges to the Foreign Account Tax Compliance Act (FATCA) and the Report of Foreign Bank and Financial Accounts… – Continue reading
Australia announced a further crackdown on multinational tax avoidance in its annual budget on Tuesday, including the planned introduction of a UK-style diverted profits tax (DPT), that it expects to raise A$3.9 billion over the next four years. The government is creating a new Tax Avoidance Taskforce of 1,000 specialist… – Continue reading
On 28 January 2016, and in response to the OECD’s Base Erosion and Profit Shifting (BEPS) project, the European Commission published a package of anti-avoidance measures as part of its ongoing plans to ultimately introduce a common consolidated corporate tax base (CCCTB). The package comprises: a draft anti-avoidance Directive, with… – Continue reading
Unctad thinktank shows firms funnelled $221bn in 2015 through low-tax jurisdictions such as the Netherlands and tax havens in the Caribbean The UN has urged governments to stem the flow of funds to tax havens after companies funnelled $221bn (£152bn) into countries with low tax rates last year. The Netherlands… – Continue reading
As with any offshore financial centre, secrecy has been synonymous with the Channel Islands of Jersey. But the reason for the strong relations between the self-governing British dependency and the United Arab Emirates – still not known to many – is not confidentiality alone. It has not been so long… – Continue reading
IT’S ALL COMING TOGETHER: Corporate inversions. The Panama Papers. Those European investigations into big-name companies like Apple. And the BEPS project coming out of the Organization for Economic Cooperation and Development. As Tax Pro Katy O’Donnell reports, tax practitioners and wonks might like to say that some of those things… – Continue reading
Panama Papers’ disclosures now and earlier dealings of Vodafone through Cayman Islands are stories of famous tax havens, which evoke discussions of how tax evasion takes place. These are all direct taxes, mainly corporate tax, and not indirect tax. These are cases of tax planning that come to the fore… – Continue reading
Minutes after midnight on Saturday, Chen Sheng, a businessman from the southern city of Wenzhou, got a value-added tax (VAT) invoice after paying his bill at a hotel in Beijing. To his surprise, the invoice was the very first issued in China after the country replaced all business tax with… – Continue reading
The Internet and Mobile Association of India’s (IAMAI’s) pushback against the equalization levy on e-commerce transactions introduced in the union budget shows up the difficulty revenue authorities will have when they try to protect their tax base. The last word on this subject hasn’t been said and the original budget… – Continue reading
The deadline for Canadians to file their taxes is rapidly approaching and if you haven’t filed the necessary paperwork you could face stiff penalties.While the usual deadline to file tax returns is April 30, because the date falls on a Saturday this year the deadline has been extended until Monday,… – Continue reading
Colombia and Panama will sign a financial information-sharing deal aimed at helping Bogota combat tax evasion, the two Central and South American countries said late on Thursday. The deal, set to be signed by the Panamanian and Colombian presidents in June, would establish an initial phase of information sharing until… – Continue reading
Introduction Even though a trust may be established under the laws of a US state and have a US trust company serving as trustee (hereinafter a ‘US-based trust’), this does not mean that it is a US domestic trust for income tax purposes. If non-US persons make substantial decisions for… – Continue reading
As world leaders consider what to do about the revelations emerging from the Panama Papers, Liberia’s government will be worrying about the fall-out that may cross the Atlantic Ocean from the affair. The European Union has announced it will be creating a new “tax haven blacklist”, to be released by… – Continue reading
Prosecutions for tax evasion almost halved across Canada in just three years, figures released to Global News show. Fewer Canadians were taken to court for tax evasion in every part of the country between 2012-13 and 2014-15. In Ontario, cases fell to 47 from 119 just three years earlier. Manitoba… – Continue reading
The UK Government has launched a consultation on plans to make the disclosure of value-added tax avoidance schemes (VADR) system more closely resemble the Disclosure of Tax Avoidance Schemes (DOTAS) regime. According to the consultation, “VADR should be more closely aligned with DOTAS to provide early information on new avoidance… – Continue reading
Thomson Reuters Checkpoint has just released a special report addressing the European Commission’s Anti-Tax Avoidance Package (ATA) and other global Country-by-Country Reporting (CbCR) developments designed in conformity with the OECD BEPS Action 13 recommendations. The report, BEPS Filing Requirements for Multinationals Under Country-by-Country Reporting, will help multinational enterprises (MNEs) gauge… – Continue reading
The government of the British Virgin Islands (“BVI”) has recently clarified the filing deadlines under the various automatic exchange of information regimes in a number of bulletins and press releases. UK FATCA / UK CDOT The BVI government has advised that BVI Reporting Financial Institutions will be able to enrol… – Continue reading
On January 27, 2016, 31 Countries (among them Mexico) signed the Multilateral Competent Authority Agreement for automatic exchange of Country-by-Country reports (the “Agreement”) to be received from their taxpayers as part of the implementation of Action 13 of the Base Erosion and Profit Shifting Action Plan issued by the Organisation… – Continue reading
THE DOUBLE taxation treaty (DTA) between India and Thailand has been successfully renegotiated and agreed to by both states and will come into force in January next year. The key highlights include a reduction of withholding tax on dividends, interest and royalties. Article 10 reduces the dividend withholding tax to… – Continue reading
Sen. Charles Schumer (D-N.Y.) on Tuesday said he is interested in working with other lawmakers to see if an agreement on international tax reform can be reached as soon as this year. “I’m game to do it because I think it’s really important for American competitiveness,” he said at… – Continue reading
The former PwC employee turned whistleblower behind the LuxLeaks scandal that implicated Luxembourg in industrial tax avoidance went on trial in the tiny European duchy on Tuesday. Antoine Deltour, 30, a former auditor at global accounting firm PwC, is accused of stealing documents from his employer before he quit the… – Continue reading
THE Bureau of Internal Revenue (BIR) recently issued Revenue Memorandum Circular (RMC) No. 32-2016 setting the amendments in the provisions of the Philippines-New Zealand tax treaty, which was originally entered into on Oct. 2, 2008. The Protocol includes the following changes: 1. The rate for dividends was changed to a… – Continue reading
An award for informers who help check tax evasion and inclusion of exhibition organisers in the VAT net are some of the strategies devised by the Delhi government to boost its revenue in the current financial year, officials said. The informer award would go to people who help the government… – Continue reading
On October 5, 2015, the Organization for Economic Cooperation and Development (OECD) issued final tax policy recommendations stemming from its Base Erosion and Profit Shifting (BEPS) project. The reports, endorsed by the G20 Finance Ministers on October 8 and by the G20 leaders at their November 15-16 summit, consist primarily… – Continue reading
Each year the IRS comes out with a list of the most notable tax scams, informing the public on what to be on the lookout for come tax season. Each year the IRS comes out with list of tax scams called the Dirty Dozen, which is used to bring public… – Continue reading
Greek banks and the state are in the process of creating a national register for offshore company owners, in compliance with a European Union directive to that effect. The register will be created on the Teiresias databank, known from its list of insolvent borrowers. Access will be granted to the… – Continue reading
COMPANIES profiting from schools and hospitals built under private finance initiatives in Scotland are based in tax havens such as Jersey and Guernsey. An analysis carried out by the Sunday Herald has revealed numerous examples of PFI projects in Scotland which have owners based offshore. The owners include an offshoot… – Continue reading
Australia is following the path of the United Kingdom and is planning to create a public register that will unmask the shell company owners who take advantage of tax avoidance by the international companies. The Guardian reported that the Canberra government has expressed on making a public commitment to put… – Continue reading
Of the 2,000 plus offshore accounts that HSBC was alleged to have been associated with, as per the Panama Papers leak, only 5% were still active, HSBC chairman Douglas Flint has said. Speaking at the bank’s annual general meeting, he said the leaks indicated the need for banks to keep… – Continue reading
Ministers agree to propose joint list of tax havens and approve plan to automatically exchange data on shell company owners EU finance ministers have approved a series of measures to tackle tax-evading methods that were exposed by the Panama Papers. Speaking on the second day of talks in Amsterdam, Jeroen… – Continue reading
A world away from Panama, the sleepy eastern Hungarian village of Komlóska has become a kind of tax haven – to survive. The village of 300 inhabitants is in one of Hungary’s poorest regions with high unemployment and a shrinking population. But in 1990 the mayor, László Köteles, decided to… – Continue reading
The mid-May plenary of the OECD’s Forum on Tax Administration will review members’ progress on implementing the OECD’s base erosion and profit shifting (BEPS) recommendations and discuss next steps. Representatives from tax administrations will discuss how to better provide technical assistance to developing countries with the support of international organizations…. – Continue reading
Embarrassing our politicians and other public figures into publishing their tax returns is muddle-headed and distracting, however briefly satisfying. What we should be focused on is not what individuals are paying to the Treasury, interesting though that is, but unreasonable tax avoidance by multinational companies. There is a danger of… – Continue reading
THE OECD, IMF, World Bank and the UN have formed a platform for collaboration on tax to improve tax systems around the world and strengthen BEPS’ grip on developing nations. Designing and implementing standards for international tax matters is high on the agenda for the new platform, with the four… – Continue reading
The Panama Papers row has failed to deter Permira and TPG from bidding for offshore trust firms, Sky News learns. Some of the world’s biggest buyout firms are queuing up to buy a string of offshore trust administrators despite the escalating global furore about the leaked Panama Papers. Sky News… – Continue reading
ANALYSIS: Despite some action from both Labor and Coalition governments, multinationals are still using accounting tricks to avoid paying Australian tax.While politicians in Canberra bicker over whether or not to cut company tax, or whether it’s acceptable for effective income tax rates to rise through bracket creep, glaring leaks in… – Continue reading
A federal prosecutor in New York has opened a criminal investigation involving the Panama Papers — a trove of materials from a Panamanian law firm that show a massive, secretive world of offshore industry. In a letter to the International Consortium of Investigative Journalists (ICIJ), U.S. Attorney Preet Bharara wrote… – Continue reading
History shows us that tax evasion can have terrible effects, from economic inequality to societal collapse. In a world seemingly inured to financial scandals, the Panama Papers leak has reminded us of their capacity to shock. This huge document dump, which has revealed thousands of offshore accounts held in the… – Continue reading
Genesis of CbC Reporting and How it will Affect U.S. Multinational Enterprises Country-by-country (CbC) reporting is essentially exactly what it sounds like: a report that shows every country where a multinational enterprise (MNE) operates and allocates income, earnings and pays taxes. The CbC report regulations proposed by the Internal Revenue… – Continue reading
