Category: Legislation

The BEPS Initiative: Redefining International Tax Planning?

Technology companies frequently possess an international tax footprint before expanding their domestic tax footprint.  That may soon change as the Organisation for Economic Cooperation and Development (OECD) and its G20 member countries undertake an ambitious agenda to fundamentally alter the international taxation system.  The OECD released its Action Plan Addressing… – Continue reading

Scottish Parliament passes legislation establishing Scotland’s first tax collection system for 300 years

Legislation which will establish and govern Scotland’s first tax collection system in 300 years has been passed by the Scottish Legislation which will establish and govern Scotland’s first tax collection system in 300 years has been passed by the Scottish Parliament.21 Aug 2014 The Revenue Scotland and Tax Powers Bill… – Continue reading

Leading Liverpool tax specialist aids guidance in new HMRC tax fraud policy

Those committing tax evasion could face stricter consequences due to the change in government tax legislation, according to a top city accountant. Des Veney, Director of Haines Watts Chartered Accountants on Victoria Street, believes that as a result of the stern regulation, which came into effect earlier this month, UK… – Continue reading

New UK measures to counter avoidance schemes involving transfer of corporate profits

A new section 1305A of the UK Corporation Tax Act 2009 (CTA 2009) has been introduced by the UK Finance Act 2014 that applies to payments made from March 19, 2014 under avoidance schemes involving the transfer of corporate profits within a group. This new measure applies if: two companies… – Continue reading

Corporation tax: Rate cut likely as Prime Minister David Cameron set to let Northern Ireland go it alone

Northern Ireland looks set to be handed the power to slash corporation tax in a move with the potential to significantly boost our stuttering economy. In a development which could transform international investment, senior sources in London and Belfast predict that an announcement will be made no later than October… – Continue reading

Global Tax Topical Focus – Corporate Inversions FAQ

To some, US companies switching their tax residency to gain a tax advantage are economic “traitors.” To others, they are victims of a United States tax code that effectively punishes them for investing at home and encourages them to look for opportunities overseas. In this Tax-News Topical Focus, we try… – Continue reading

Stock options in an international context: treatment of an indemnity for waiving stock options, received by a corporate officer within the meaning of the tax treaty between France and the United Kingdom

In its October 4, 2013 decision, no. 351065, Mr. Clive Worms, the French Administrative Supreme Court reiterated that, under domestic tax law, an indemnity received by a French tax resident in compensation of his cancelled stock options qualifies as a compensation for work. On the day the options were granted, the… – Continue reading

Capital gains tax on non-UK residents – good news for certain institutional investors

Summary HMRC have announced that the new capital gains tax (“CGT”) charge on non-residents disposing of UK residential property, due to come into effect in April 2015, will not extend to institutional investors and companies with diverse ownership. Background In the Autumn Statement last year, the Chancellor announced the new… – Continue reading

Expats urged to review sources of UK income amid tax raid plans

Property owners and pensioners who face losing their personal tax allowances can take steps now to protect themselves, say experts Expats facing the possibility of losing their personal allowance under a tax raid proposed by George Osborne should not panic but look carefully at where their UK sources of income… – Continue reading

UK Reduces Scope Of New Property Gains Tax

The British Property Federation (BPF) and the Chartered Institute of Taxation (CIOT) have welcomed an announcement from HM Revenue and Customs (HMRC) that institutional investors and companies with diverse ownership will be excluded from plans for a new capital gains tax (CGT) on UK properties sold by non-residents. The charge… – Continue reading

The offshore world: Past, present and future?

The reputation of many jurisdictions, or so called ‘tax havens’, has been attacked by other nations, most which fail to apply the same policies that they advocate for others. Over the last two decades, International Financial Centers (IFCs) have made vast changes to their laws and their enforcement, aiming to… – Continue reading

Asia-Pacific Tax Forum proposed

BANGKOK: The United Nations’ Economic and Social Commission for Asia and the Pacific (ESCAP) has proposed to the regional countries creation of an ‘Asia-Pacific Tax Forum’ to monitor tax legislation and regulations across the region. This is to help develop regional best practice and address issues such as avoidance of… – Continue reading

Profit shifting ‘just a part’ of Africa tax loss

MULTINATIONAL companies shifting their profits from Africa to low-tax jurisdictions are only partly responsible for the erosion of the continent’s tax revenue bases. The African Tax Administration Forum (Ataf) believes some countries have signed away their tax revenue because of weak domestic policies, and ill-conceived tax incentives and mining contracts…. – Continue reading

British Virgin Islands: The Impact Of FATCA On British Virgin Islands Funds

In March 2014, the British Virgin Islands Government announced that it had concluded negotiations with the US with respect to a Model 1B Intergovernmental Agreement with the United States (the IGA). The IGA (which was eventually signed on 30 June 2014) provides the framework for the implementation of the US Foreign… – Continue reading

Russian FM Provides Anti-Offshore Law Update

Russia’s Finance Minister, Anton Siluanov, has told President Vladimir Putin that a new bill to deter Russian tax residents from hiding income offshore is expected to raise about RUB30bn (USD844m) from overseas accounts in Cyprus and the Netherlands. During a Government meeting on July 30, 2014, Siluanov explained that entrepreneurs… – Continue reading

The difference between a telecoms network and real estate? About $3.2 billion

Tax avoidance, the American way. Little Rock, Arkansas-based telco Windstream has caused a stir by announcing a novel scheme to reduce the amount of federal taxes it has to pay. It intends to spin off certain network assets into a publicly traded real estate investment trust (REIT). In so doing,… – Continue reading

Russian government to submit offshore taxation bill to parliament

Therefore, Russia “could receive about 30 billion rubles [about $900 million] in additional budget revenues [annually], which are extremely necessary,” Finance Minister Anton Siluanov noted NOVO-OGARYOVO, July 30. /ITAR-TASS/. Russia’s new offshore taxation rules will yield about $1 billion in tax revenues for state coffers annually, Finance Minister Anton Siluanov… – Continue reading

Pfizer refuses to rule out tax inversion deals

High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Emailftsales.support@ft.com to buy additional rights. http://www.ft.com/cms/s/0/b494286e-171e-11e4-b0d7-00144feabdc0.html#ixzz393LkTft5 Pfizer refuses to rule out tax inversion deals By Andrew Ward, Pharmaceuticals CorrespondentAuthor alerts… – Continue reading

Polish Lower Chamber Approves Proposals on Tax Treatment of Foreign-Controlled Companies

June 30 — Poland’s Sejm, the lower house of parliament, June 26 approved proposals to introduce guidelines to distinguish a foreign-controlled company for tax purposes, and approved Poland’s agreement for the avoidance of double taxation with the United Arab Emirates, as well as its tax information exchange agreements with Bermuda,… – Continue reading

YOUR TAXES: What you need to know about the US-Israel FATCA agreement

On June 30, the United States and Israel signed an intergovernmental agreement (IGA) regarding FAT CA. FAT CA became effective in the US and other countries on July 1 and will officially take effect in Israel once the Knesset passes enabling legislation. But the Bank of Israel has already instructed… – Continue reading

Isle of Man: FATCA Update

Two important dates have now passed in relation to Foreign Account Tax Compliance Act (“FATCA“) – 30 June 2014 when Financial Institutions were required to capture details of their existing customers for remediation purposes and 1 July 2014 when Financial Institutions were required to have procedures in place which would… – Continue reading

Budget 2014: Vodafone to continue international arbitration; 2012 retro-tax amendment stays

NEW DELHI: Vodafone Thursday said it will continue the process of international arbitration initiated under the India-Netherlands Bilateral Investment Treaty to resolve the ongoing Rs 20,000-crore tax dispute against India, while a local tax official said the department will continue with its tax demand on the telecom major. Earlier today, Finance Minister Arun Jailtey… – Continue reading

Tax authorities updated their interpretation of certain transfer pricing issues

On 1 July 2014, the Ministry of Revenues and Levies of Ukraine issued Order #368 ‘On amendment of generalised tax consultation on transfer pricing related issues, adopted by Order #699’, which significantly changed the respective tax consultation #699. In particular, the order included additional questions and clarifications and drastically changed… – Continue reading