Category: Legislation

Tax Planning And Portugal’s Non Habitual Residence Scheme

Portugal can be a very attractive country to live in from a tax point of view. The inheritance tax regime is very benign here, and there is no wealth tax. Tax efficient arrangements can lower tax liabilities on your investment and pension income. And if you are a new resident,… – Continue reading

Common tax base proposed for EU by Brussels

Brussels competition arm investigating Ireland for use of ‘comfort letters’ to companies The European Commission is to propose a mandatory common corporate tax base next month as part of a wide-ranging clampdown on corporate tax avoidance. Under a discussion document to be looked at by EU commissioners in Brussels today,… – Continue reading

Transfer prices: international environment and its impact on national legislation and regional operations

The countries of the Central American region have incorporated and reformed their legislations to the international regulations of Transfer prices and practically all the applicable legal provisions to related parties have already been expanded in the region, which implies, that the companies with regional presence must visualize, review and engage… – Continue reading

Gibraltar: Rising Above Regulatory Clouds

The medium-term uncertainty of the UK’s continued membership of the EU remains a cloud on Gibraltar’s financial horizon, for the Rock’s membership of the 27-nation body – and thus her role as a stepping-stone into Europe’s vast financial market – is under Britain’s umbrella. And it is partly in response… – Continue reading

Amazon begins to book revenues in separate countries in what expert says is response to regulatory pressure

E-commerce giant Amazon has begun booking revenue in individual European companies, a move that tax expert Heather Self of Pinsent Masons, the law firm behind Out-Law.com, said is probably influenced by upcoming regulatory changes.26 May 2015 “As of 1 May, Amazon EU Sarl is recording retail sales made to customers… – Continue reading

Germany: Amazon Pays $16M in Tax, Earns $16B

The company decided to declare its revenues since European regulators started to investigate its accounting practices. Internet retailer Amazon paid about US$16 million to Germany in 2014, while the giant multinational recorded a total earning of US$16 billion in that country, according to the country’s regulators. In the past, the… – Continue reading

Uzbekistan to amend legislation regarding offshore companies

Uzbekistan has developed a draft law on amendments and additions to the Tax Code regarding the companies established by the country’s residents in offshore zones. This remark was made by Uzbekistan’s Prosecutor-General Ikhtiyor Abdullayev, who was addressing the plenary session of the Eurasian Group on combating Money laundering and financing… – Continue reading

New GST obligations for offshore suppliers – Netflix subscriptions and so much more

Exposure draft legislation to extend the application of the GST to supplies of intangible products by foreign suppliers to Australian consumers has been released for consultation. While there has been considerable focus on the proposed expansion of the GST regime to cover supplies of “digital products”, the changes will also… – Continue reading

Russian Parliament Approves Amnesty for Offshore Capital

A bill offering legal amnesty to Russians who willingly declare their foreign assets sailed through Russia’s lower house of parliament on Friday, forcing companies and individuals to face a crucial question: to declare or not to declare? Under the legislation, known as the “capital amnesty bill,” businesses and citizens who… – Continue reading

Belgium and Russia sign new tax treaty

Belgium and the Russian Federation announced in March 2007 that they would negotiate a new double tax treaty (the “Treaty”). Nearly seven years after discussions began on 20 November 2008, the Treaty was finally signed on 19 May 2015 in Brussels. This newsflash is based on an unofficial version of… – Continue reading

Ukraine: Ukraine Updated A Blacklist Of Tax Havens For Application Of Transfer Pricing Rules On Cross-Border Operations

The Ukrainian legislation for transfer pricing came into force in 2013, with implementation of respective amendments to the Tax Code of Ukraine (“CCU”). However, at present the transfer pricing rules (provided for the CCU) are not applied accurately. In light of the above, in order to clarify the transfer pricing… – Continue reading

Ukraine: Ukraine Updated A Blacklist Of Tax Havens For Application Of Transfer Pricing Rules On Cross-Border Operations

The Ukrainian legislation for transfer pricing came into force in 2013, with implementation of respective amendments to the Tax Code of Ukraine (“CCU”). However, at present the transfer pricing rules (provided for the CCU) are not applied accurately. In light of the above, in order to clarify the transfer pricing… – Continue reading

Diverted Profits Tax: counterbalancing the UK’s “open for business” agenda?

The UK’s introduction of the diverted profits tax (DPT) has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) and in effect as of April 1, the DPT seemed intended to appease public anger at multinationals failing to pay their ”fair… – Continue reading

British Virgin Islands: When Life Gives You Lemons… The BVI And The Global Push For Tax Transparency

It is quite clear that the more recent past has seen a notable shift in the debate from various supranational initiatives implemented over the years, designed to curtail the activities of smaller offshore financial centres, towards the real issues of tax transparency, regulatory cooperation and managing systemic risk in the… – Continue reading

OECD strengthens recommendations on transfer pricing documentation

In 2014, the Organization for Economic Co-operation and Development (“OECD”) began making recommendations to Member States for the implementation of certain actions aimed at limiting base erosion and profit shifting, known as “BEPS”. The project includes 15 actions, representing 15 areas of regulation that allow states to monitor data which… – Continue reading

AIG Jamaica Moves Its Business Offshore: To Finalise Exit By 2016

Three years after a major restructuring of the business, general insurer AIG Jamaica is moving its operations offshore but will continue to write business for clients here. AIG Jamaica Insurance Company Limited was formerly Chartis Jamaica Insurance Company Limited, which was created in 2012 when sister company American Home Assurance… – Continue reading

US, Korea agree to exchange financial account information

During a Cabinet meeting Tuesday, chaired by deputy Prime Minister Choi Kyung-hwan,in his role as acting prime minister, the government passed a revised bill that requires the automatic exchange of financial account information for taxpayers from both countries every year, reports Arirang. The agreement will also ensure confidentiality and the… – Continue reading

DFSA and DIFC Registrar of Companies co-host FATCA Outreach Workshop

The Dubai Financial Services Authority (DFSA) and the Dubai International Financial Centre (DIFC), Registrar of Companies (RoC), jointly hosted an outreach workshop last week regarding the Foreign Account Tax Compliance Act (FATCA). FATCA is extra-territorial US legislation that affects Financial Institutions (FIs), particularly those which have accountholders who are US… – Continue reading

UK: Non-UK Domiciliaries: Inheritance Tax Issues And Opportunities

This note is intended as an introduction to inheritance tax (IHT) issues that need to be covered where a “non-dom” (an individual domiciled outside the UK) is planning on becoming resident in, or is already resident in, the UK. It should be emphasised that this is a complex subject, and… – Continue reading

PANAMA UPDATE: New Regime on Bearer Shares Effective in 2015

Executive Summary: The Panamanian government has engaged in an extensive period of consultations with local and foreign experts, practitioners, professionals and regulators, in a concerted effort to ensure that the jurisdiction continues to embody the highest international standards in terms of functionality and transparency (while preserving confidentiality). To that effect,… – Continue reading

Australia: Federal budget 2015-16: Quick guide – the big business measures

Last night, the Federal Treasurer, Joe Hockey MP, released the 2015-16 Federal Budget. After public self-evaluation of its last budget as over-reaching, the Government has gone back to basics whilst still focussing on repairing the budget deficit in the medium to long term. The budget deficit is projected to be… – Continue reading

Italian tax reform: facilitating inbound foreign investments

I. Introduction Following the approval by Parliament of Law No.23 of 11 March 2014 (hereinafter “Delega Fiscale”[1]), the Italian Government is now taking action and adopting the Legislative Decrees necessary to enforce this innovative tax reform. In fact, on 21 April 2015 the Council of Ministers has approved the drafts… – Continue reading

Italian tax reform: facilitating inbound foreign investments

I. Introduction Following the approval by Parliament of Law No.23 of 11 March 2014 (hereinafter “Delega Fiscale”[1]), the Italian Government is now taking action and adopting the Legislative Decrees necessary to enforce this innovative tax reform. In fact, on 21 April 2015 the Council of Ministers has approved the drafts… – Continue reading

Tax evasion fight ‘risks making life hard for all taxpayers’

The latest changes to VAT and profit tax legislation, implications of recent measures taken to fight fiscal evasion, changes to international tax reporting rules and the need to improve holding legislation were some of the topics discussed by participants in BR’s 14th Tax & Law conference which took place in… – Continue reading

Joe Hockey’s tax reform ‘too little, too early’, says Sam Dastyari

Treasurer Joe Hockey is facing criticism for both acting too quickly and not doing enough on tax avoidance by multinational ¬companies after tabling legislation on Tuesday night to stop companies shifting taxable profits out of Australia. An unnamed 30 multinational companies with more than $1 billion in revenue from Australia… – Continue reading

Bahamas Releases Proposed FATCA Legislation & Guidance Notes For Industry Consultation

The Bahamas Ministry of Financial Services released draft copies of the FATCA Legislation and the FATCA Guidance Notes to meet the International Tax Compliance Requirements of the Model 1 FATCA Intergovernmental Agreement (IGA) between the Bahamas and the United States of America (US). The new FATCA Bill was drafted in… – Continue reading

OECD condemns Silicon Valley for “extremely aggressive” tax planning

Head of forum’s tax policy will push for reform to cut down on avoidance. The OECD has attacked the “extremely aggressive” tax planning of companies such as Google, Amazon and Apple as it pushes for reform of global tax rules to cut down on avoidance. Pascal Saint-Amans, who heads up… – Continue reading

Hong Kong: The Impact Of BEPS On Your Relationship With Customs Authorities

If you are moving or trading goods across borders, this topic should be of primary importance from both a Transfer Pricing and Customs perspective. There is potential for you to have Transfer Pricing and Customs exposures in your supply and value chains as a result of the OECD/G20 initiative on… – Continue reading