Tax-driven “inversion” deals that let companies flee the U.S. tax system by relocating abroad, if only on paper, would be curbed under legislation introduced in Congress, as Pfizer Inc (PFE.N) pursues such a deal with rival Allergan Plc (AGN.N). Wisconsin Democratic Representative Mark Pocan’s bills likely have little chance of… – Continue reading
The chief executive of one of the world’s largest independent financial advisory organizations unambiguously condemned the Foreign Account Tax Compliance Act in a recent series of comments. deVere Group CEO Nigel Green likened the act, which went into effect in July 2014, to a “masterclass in fiscal imperialism and the… – Continue reading
In a time of fiscal austerity, it is breathtaking to learn that Congress has allowed Fortune 500 companies to avoid an estimated $620 billion in federal taxes on earnings they are holding offshore. While the inaction by lawmakers on this issue may create the impression that there is nothing to… – Continue reading
NEW YORK, Nov. 9, 2015 /PRNewswire/ — Business executives cited an increased compliance burden as their biggest concern with the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting initiative (37.7 percent), according to an October Deloitte poll. Other concerns included double taxation of income (17 percent) and… – Continue reading
Small and medium-sized businesses that don’t have the resources to patent intellectual property may still be able to benefit from the Knowledge Development Box (KDP) under plans being considered by the Government. The Department of Finance is looking at allowing SMEs with patentable assets, but without the resources to get… – Continue reading
The opaque governance structure of sports federations makes them less accessible to independent oversight and therefore more prone to corruption, the deputy managing director at Transparency International, a global anti-corruption movement, told Sputnik. ST. PETERSBURG (Sputnik) – Earlier this year, separate investigations by US and Swiss prosecutors uncovered deep-rooted corruption… – Continue reading
No member state of the Caribbean Community (CARICOM) ranks among the top 20 jurisdictions worldwide for financial secrecy. The United States of America (at number 3), Germany (8), Japan (12) and Britain (15), all rate as bigger tax havens than any CARICOM jurisdiction, according to the Tax Justice Network (TJN),… – Continue reading
New law in Poland expands the requirements for transfer pricing documentation, and includes country-by-country (CbC) reporting. The new provisions essentially reflect the recommendations made in Action 13 the OECD’s base erosion and profit shifting (BEPS) project, and provide for CbC, master file and local file reporting. The legislation was passed… – Continue reading
The Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting action plan is likely to have a major impact on tax planning at multinational corporations by both tax professionals and corporate treasurers. Tom Driscoll, U.S. managing partner for international tax, transfer pricing, and indirect tax at Deloitte Tax… – Continue reading
The BVI has announced amendments to its Anti-Money Laundering (AML) regime in order to ensure continued compliance with developing international standards on transparency and AML regimes. Amendments to the legislation have recently been published (Code of Practice and Regulations) and the proposed changes are to take effect on 1 January… – Continue reading
(Seychelles News Agency) – Seychelles’ efforts to comply with the widely-recognised Organisation for Economic Co-operation and Development (OECD)’s regulations on the sharing of tax information has led the island nation’s jurisdiction to be rated ‘largely compliant’. This follows a re-assessment of the island nation’s ‘practical implementation’ of its legal and… – Continue reading
On 14 October 2015, the Luxembourg Minister of Finance presented a bill to Parliament on the state budget for 2016. This bill contains several proposals affecting corporate taxpayers. One of the main proposals is the abolition of the intellectual property regime. Similar tax relief systems, known as “IP box” or… – Continue reading
JOHANNESBURG – South African has lost R250 billion in the form of service payments over a three-year period, highlighting the significant risk base erosion and profit shifting (BEPS) is posing to the country’s tax base, a South African Revenue Service (Sars) official has said. Almost R80 billion of this were… – Continue reading
The blacklisting of Hong Kong by the European Union is over for the moment with Spain explaining to the EU it didn’t have HK on its list. In the course of investigation, Harbour Times receives a quick response from the Latvian embassy in Beijing to clarify their stance on Hong… – Continue reading
Sixteen peer review reports were released at the recent plenary meeting of the OECD Global Forum on Transparency and Exchange of Information for Tax Purposes on October 29-30, 2015. The release of the reports follows reviews of those territories’ legislation for the exchange of tax information and their frameworks for… – Continue reading
One year after the announced closing off of the Double Irish tax arrangement, U.S. multinationals once again turned their attention to Dublin as Ireland announced details of the Knowledge Development Box, or KDB. This new component to its corporate tax regime will allow companies to pay a reduced corporate tax… – Continue reading
Republican lawmakers are sounding the alarm about the Obama administration’s plans for Iran, warning officials are on the verge of waiving tax penalties that make it harder for companies to do business in the country. The administration has not responded to an inquiry from the tax-writing House Ways and Means… – Continue reading
After being in effect for only a week, the Council of the District of Columbia (Council) unanimously enacted legislation today that will repeal the list of tax haven jurisdictions specifically enumerated in the D.C. Code. The legislation, titled the Fiscal Year 2016 Second Budget Support Clarification Emergency Amendment Act of… – Continue reading
On August 4 and 5, 2015, the FC heard oral arguments in a lawsuit—commenced on August 11, 2014 by two Canada-US citizens—that challenges the law implementing the Canada- US intergovernmental agreement (IGA) relating to FATCA (Virginia Hillis et al. v. The Attorney General of Canada et al., court file no…. – Continue reading
Claiming that a lot of information on illicit funds is lying unused by the Indian authorities, HSBC whistleblower Herve Falciani said on Tuesday that he is willing to cooperate with the investigative agencies in their black money probe but would need protection in return. He also claimed that millions of… – Continue reading
Australia hosts significant quantities of illicit funds from outside the country, according to the 2015 Financial Secrecy Index. The Tax Justice Network’s index, released every two years, rates countries based on financial transparency. The latest index rates Australia 44 out of 100 (from 47 in the previous survey) meaning it… – Continue reading
As of July 15 2015, 55 financial institutions and banks in Ghana have registered themselves to comply with FATCA. So, chances are that if you tried to open a bank account in Ghana, the bank now requires you to fulfil some United States (U.S.) reporting obligations in addition to the… – Continue reading
The UK has been rated “more of a tax haven” than the Channel Islands, in a financial transparency report. The biennial study by campaign group Tax Justice Network (TJN) ranked the UK above the islands. TJN director, John Christensen, said the islands had “made significant improvements” by signing up to… – Continue reading
Australian taxpayers could get a bill of rights, and better compensation schemes if they have been wronged by the Australian Taxation Office, following a new review by the Inspector-General of Taxation. On Monday, Ali Noroozi launched his review examining whether there’s scope to introduce a taxpayer bill of rights, similar… – Continue reading
WASHINGTON—The United States is one of the world’s most secret financial jurisdictions, according to a watchdog group’s new global ranking. The Tax Justice Network, an international think tank based in the United Kingdom, on Monday unveiled the 2015 Tax Secrecy Index, which lists the countries that most allow financial secrecy… – Continue reading
At the end of this year an amnesty for UK tax resident persons whose offshore income and gains have not been disclosed to HMRC closes, and it is important the implications are understood according to Michael Crowe, a director at Grant Thornton in the Isle of Man. In the UK’s… – Continue reading
Amazon is reportedly liable for online tax fraud if the company fails to investigate traders who are using their sites to avoid sales tax. According to experts, online marketplaces such as Amazon and eBay could be held liable for all unpaid VAT if action was taken against them. The report… – Continue reading
A Financial Action Task Force (FATF) delegation visits Israel this week to consider Israel’s application for membership. “Israel is working tirelessly to upgrade its standing as a regional leader in the struggle against money laundering and financing of terrorism through persistent regulatory changes and a more effective regime. Up until… – Continue reading
Place of residence key as Holyrood prepares to unveil levy on income it will impose north of the Border from April, writes Jeff Salway HM Revenue & Customs has moved to clear up misconceptions lingering over new income tax rules taking effect in Scotland as Holyrood prepares to unveil the… – Continue reading
Pfizer’s bid for $113bn Dublin-based drug maker Allergan is the biggest merger of the year, anywhere. It’s potentially good news for the Irish exchequer, which may gain a massive new taxpayer, and for businesses here like Arthur Cox, Allergan’s adviser on Irish corporate law. But a deal that may well… – Continue reading
South African Tax Legislation: Proposed Amendments in an International Tax Context[1] This article sets out a brief summary of some of the proposed amendments introduced by recent South African draft Tax Bills. The article focuses on amendments in the context of international taxation. The draft Taxation Laws Amendment Bill, 2015… – Continue reading
Gold Fields and Sasol have clinched the top awards in PwC’s Building Public Trust Awards: Excellence in the field of tax reporting in 2015. Gold Fields was the overall winner in the category for tax reporting for multinational companies, while Sasol was announced the overall winner in the category tax… – Continue reading
The tax authorities continue to abide by the principle of “what is not forbidden is allowed”, using contradictory norms of the Russian Tax Code to their advantage. As a result, there is a surge in tax audits by territorial tax authorities during which they check whether prices charged in transactions… – Continue reading
Final recommendations about how multinational companies should be allowed to shift profits among different tax jurisdictions were issued this month, and the U.S. Congress has not yet indicated whether it will consider legislation in response to the proposals. Issued by the Organisation for Economic Cooperation and Development (OECD) on October… – Continue reading
In a BEPS seminar organised by the Federation of Enterprises in Belgium this week, with a special focus on the practical consequences for Belgian enterprises, a representative of the Belgian Ministry of Finance, Steven Van Elsuwe;, provided more details on the new legislative proposals that have been prepared so far,… – Continue reading
The Ambassador of the United States of America, John R. Phillips, today in the Republic for the signing of the intergovernmental FATCA, met this morning at Palazzo Begni, the Secretary of State for Foreign Affairs, Pasquale Valentini. A bilateral especially focused on the issues – all current – which has… – Continue reading
Following the recent Irish budget statement (the “Budget”), the Finance Bill 2015 (the “Bill”) has been published and it implements the changes announced by the Irish Minister for Finance (the “Minister”). The Bill includes additional detail on: the new knowledge development box (“KDB”); and Ireland’s implementation of country by country… – Continue reading
French online gambling is overseen by the Regulatory Authority for Online Gaming (ARJEL), the ruling organization responsible for imposing a series of strict and sometimes puzzling regulations that often limit the market’s full potential. ARJEL President Charles Coppolani attempted to clear some of the confusion earlier this month at the… – Continue reading
A decision by the Federal Court of Australia has key implications for transfer pricing of intercompany financing transactions, as well as implication for other broader intercompany arrangements. The case concerns the transfer pricing implications of an intercompany loan agreement between an Australian taxpayer and its U.S. subsidiary (CFC) and whether… – Continue reading
Government action against tax avoidance has made the headlines on numerous occasions over the past few years, with significant developments in litigation, legislation and early tax collection, via a combination of follower notices and accelerated payment notices. Add to this the expansion of the disclosure of tax avoidance schemes, hallmarks… – Continue reading
On the heels of extensive preparation for the implementation of FACTA in St. Kitts and Nevis, banks and other financial institutions are now starring down the barrel of additional financial accounts information reporting on a wider scale. The Organization for Economic Co-operation and Development (OECD) has proposed a global version… – Continue reading
Citing the need to boost job growth locally and around the United States, Rep. Jerry McNerney, D-Stockton, has introduced legislation that would close tax loopholes that encourage companies to send jobs overseas and that would make companies reveal their outsourcing. The idea behind the legislative package is to provide greater… – Continue reading
There was a time when, from a tax perspective, South Africa’s “mini budget” used to be a non-event. The main emphasis was on the annual budget speech delivered in February each year when they announced tax policy proposals. However, over the past few years there has been an increasing tax… – Continue reading
Taxation of Profits of Controlled Foreign Companies (CFC): Double Taxation Conventions must prevail over domestic rules The Superior Court of Justice (STJ) has recently decided a case involving the applicability of Brazilian CFC rules in cases in which the controlled company is located in a country with which Brazil has… – Continue reading
Provisional Measure No. 692/2015 increases the income tax rate on capital gains earned by individuals and certain companies1 from 15% to 15%-30%. As from January 1st, 2016, when the new rules will become applicable, capital gains earned on the sale or disposition of any assets or rights located in Brazil… – Continue reading
The Anti-money Laundering (AML) Bill has remained stuck in the Senate Standing Committee on Finance since February this year. The opposition, which has the majority in the upper house, is not letting it go through because of its misplaced fears that it would be misused by the Federal Board of… – Continue reading
The European Commission looks highly likely to make a finding against Ireland in relation to its tax arrangements with Apple, following two similar findings during the week involving Starbucks and Fiat. It is perplexing that the EC doesn’t just come out and make the announcement. The delay is leading to… – Continue reading
Bermuda is battling hard to make its voice heard in Washington’s corridors of power as the controversy around hedge fund reinsurers rumbles on. The Association of Bermuda Insurers and Reinsurers (ABIR) had a team of company tax directors in the US capital city to brief congressional staff on its position… – Continue reading
Since the revelations on government surveillance and data capture by Edward Snowden, journalists have rightfully raised concerns about governments’ insatiable appetite for data collection and the resulting encroachment on citizens’ civil liberties. In the EU an individual’s right to privacy is regarded as a human right in accordance with Art…. – Continue reading
The Cayman Islands Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations, 2015 (the “CRS Regulations”) were issued on 16 October 2015. Cayman Islands Government Industry Advisory – CRS Regulations Are in Effect The CRS Regulations, which are the first part of two in the roll-out of the Cayman… – Continue reading
