Already from December 1, 2015 come into force provisions requiring all financial institutions calling their clients to make statements about their residence tax (FATCA – Foreign Account Tax Compliance Act). It is the first significant action since records to OPF. FATCA imposes on foreign institutions, including the Polish reporting obligations… – Continue reading
YEREVAN, NOVEMBER 23, ARMENPRESS. A businessman should not pay the same tax for two times for a unilateral deal. The agreement of avoidance of double taxation with respect of taxes on income and on capital signed between Armenia and the USA is one of the factors that will contribute to… – Continue reading
The OECD’s final report on Action 13 under the base erosion and profit shifting project—which calls for countries to adopt a country-by-country reporting template, master file and local file—has the potential to be one of its “greatest legacies.” Marlies de Ruiter, head of the Organization for Economic Cooperation and Development’s… – Continue reading
LK Hewlett St. Kitts-Nevis Permanent Representative to the OAS, Dr. Everson Hull has expressed strong views on the impact of FATCA on the region’s banking system. Delivering a presentation to over 200 banking executives and other stakeholders in the financial services sector from across the Caribbean at the recent Caribbean… – Continue reading
The IRS has upgraded the Foreign Account Tax Compliance Act (FATCA) Online Registration System, enabling sponsoring entities to register their sponsored entities to obtain a global intermediary identification number. The upgraded system also will allow users to update their information, download registration tables and change their financial institution type. The… – Continue reading
The European Commission has requested that the Netherlands amend the limitation on benefits clause in its double tax treaty with Japan. The Commission said that, on the basis of previous cases such as Gottardo (C-55/00) and Open Skies (C-466/98), a member state concluding a treaty with a third country cannot… – Continue reading
Nawaz Sharif has turned his full attention for close relations with Central Asian states since the five of them broke away from Russia 23 years ago. Fast track negotiations between Central Asian and Pakistani leaderships are slated to turn their countries into a big, new economic zone. Their desire and… – Continue reading
Tax Commissioner Chris Jordan has become more picky about entering agreements with multinationals aimed at giving companies certainty about their tax payment requirements in Australia in future years. Taxpayers can lock in their tax payment for a period of about three years via an “advanced pricing agreement”, or APA. Technology… – Continue reading
Failed tax avoidance business Welbeck hired young actors to push schemes onto City big earners, and reaped millions in commissions that fuelled lifestyles of fast cars and exotic holidays, according to a whistleblower who worked at the firm. Welbeck Solutions sold pensions and financial products, but it specialised in tax… – Continue reading
Private companies that were given a historical exemption from filing annual financial reports are run by a who’s who of corporate Australia, including Malcolm Turnbull Private companies associated with Australia’s business elite, including prime minister Malcolm Turnbull, are on a list of entities not required to publish tax information under… – Continue reading
Towards compliance with tax information sharing laws put in place in recent times, all financial intermediaries are mandated to seek information from account holders. They are also obliged to share information of your account with relevant authorities. SEBI too has issued guidelines on identification of beneficial ownership and mandated all… – Continue reading
The North will have its own 12.5pc corporate tax rate from 2018. This means that it will compete harder against the Republic for FDI projects, writes Dan White The 12.5pc company tax rate will no longer be confined to the southern part of the island. Last week’s ‘Fresh Start’ agreement… – Continue reading
On the face of it, Malta literally has the highest corporate tax rate in the EU. At 35%, it hardly seems to be a competitor to European tax havens like Ireland and Cyprus, both applying a rate of 12.5%, or territories like Gibraltar. At a rate of 10%, the latter… – Continue reading
Nov 22, 2015- Lack of clarity over double taxation on petroleum products from China will delay the signing commercial agreement with Petro-China. For now, the government is sending a technical team of Nepal Oil Corporation (NOC) to China on Monday to clarify the issue of taxation before a high level… – Continue reading
Notice 2015-79—released November 19, 2015, by the Treasury Department and IRS—announces their intention to issue regulations relating to inversion transactions and post-inversion restructuring transactions. Notice 2015-79 provides for rules that: Limit the ability of domestic companies to effect an inversion Limit the advantages of certain post-inversion restructuring transactions Clarify certain… – Continue reading
The Chancellor could target capital gains tax for extra revenue when he delivers his Autumn Statement next week as gains from investors and landlords hit their highest on record in the past financial year, accountants suggest. George Osborne, who will unveil his spending plans for Britain next Wednesday, is under… – Continue reading
Company used actresses including former Alan Partridge star to bombard financial sector workers with cold calls The grey Basinghall Street office building, in the heart of London’s City financial district, gives few clues about the frenzy of activity that was going on inside. But for years, this was the home… – Continue reading
This week, the IRS released Notice 2015-79, which describes intended regulations to cover inversions and related transactions. Colloquially, an inversion refers generally to a transaction in which a domestic corporation is acquired by a foreign corporation. I.R.C. §§ 367 and 7874 operate as the anti-inversion rules; § 367 deals with… – Continue reading
The blacklisting saga did not start with Spain, but it did end with a timely correction related to it. Harbour Times explains how Hong Kong was taken off the Spanish tax haven list. Friends of Harbour Times would be familiar with the remedy of Hong Kong being named a non-cooperative… – Continue reading
The European Commission has requested that Spain amend its rules on the taxation of certain income obtained by foreign non-profit entities and of certain contributions to such entities. The crux of the Commission’s complaint is that foreign non-profit entities that derive income from Spain, but which are established in another… – Continue reading
We are all aware of “base erosion and profit shifting” or “BEPS”. On 5 October 2015, the OECD released its final reports in connection with its BEPS Action Plan including its final report on Action 15 dealing with the development of a multilateral instrument to modify bilateral tax treaties (“Final… – Continue reading
The Ministry of Finance issued a regulation with guidance concerning the procedures for the exchange of financial information with other jurisdictions and countries. The “automatic exchange of information” (AEOI) process will allow for the exchange of data to verify and confirm compliance with tax obligations, including information from financial institutions…. – Continue reading
Introduction Withholding obligation Proposed amendment Comment Introduction The 2015 Taxation Laws Amendment Bill proposes an amendment to Section 35A of the Income Tax Act (58/1962), dealing with withholding percentages from payments due to non-resident sellers of immovable property situated in South Africa. The proposed amendment raises interesting questions regarding compliance… – Continue reading
The US Department of the Treasury said that the United States introduced new restrictions to prevent US-based multinationals from restructuring after mergers to establish foreign parent companies in order to avoid paying taxes. WASHINGTON (Sputnik) — The United States introduced new restrictions to prevent US-based multinationals from restructuring after mergers… – Continue reading
MUMBAI: India’s forthcoming budget may draw from some of the recommendations, especially in the realm of transfer pricing, contained in the final package of ‘Base Erosion and Profit Shifting’ (BEPS) measures, rolled out in October. Certain anti-abuse measures, such as thin capitalization, which for tax purposes disallows interest payments beyond… – Continue reading
Swaziland will implement the United States Foreign Accounts Tax Compliance Act FATCA 2010 by collecting tax from US individuals and companies operating in the country.APA learnt on Friday that the act, whose objective is the facilitation of the exchange of financial information between US and other countries where its citizens… – Continue reading
Introduction Tax exemptions Eligibility Trademarks Calculating tax benefits Eligible costs Introduction At the end of 2014, the government presented the 2015 budget, which introduced a ‘Patent Box’ tax regime in line with similar schemes adopted in other European countries. It applies to corporate income tax and regional tax on productive… – Continue reading
THE United States of America (USA) wants all companies of US origin, individuals and body corporates that are resident in Swaziland to report their financial information in their home country, the USA. This development is a result of Swaziland government announcing that it will implement the United States Foreign Account… – Continue reading
Introduction Facts Decision Introduction The European Court of Justice (ECJ) recently ruled that the system of interim taxation for Austrian private foundations does not comply with EU law.(1) A special feature of private foundations is the so-called ‘interim tax’ – a type of corporate income tax. Pursuant to Section 13(3)… – Continue reading
The European Commission has asked the German Government to amend its inheritance tax (IHT) law after finding that current rules discriminate against those who are not resident in Germany for tax purposes in certain situations. Under German IHT law, a special maintenance allowance is granted to surviving spouses or registered… – Continue reading
The governments of Malta and the Caribbean island of Caraçao have signed a treaty, which both sides say will prevent tax evasion and the double taxation of companies operating in both jurisdictions. In line with internationally agreed standards, Malta’s finance minister Edward Scicluna and his counterpart from Caraçuo Jose Jardim… – Continue reading
NEW DELHI: Concerned over the misuse of double taxation treaty with Mauritius by certain entities, the government is working on measures to check such practices, a Finance Ministry official said today. The government is in the process of revising the Double Taxation Avoidance Agreement (DTAA) with Mauritius. Tax treaty amendments,… – Continue reading
Plans that would effectively end the UK’s non-domicile status for tax purposes have the potential to do more harm than good and could be contrary to EU law, according to the Institute of Chartered Accountants. The changes, announced by chancellor George Osborne in the 2015 summer budget, mean that non-UK… – Continue reading
On November 17, 2015 Russia and Singapore signed a Protocol revising the existing Agreement between the Government of the Russian Federation and the Government of the Republic of Singapore for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (Hereafter: the Protocol)…. – Continue reading
Malta recently ranked first for efficiency in transposing directives into national legislation – but the chairman of Finance Malta, Kenneth Farrugia, believes that the pace of innovation needs to accelerate. “We claim to be nimble, but we need to push it much more. Innovation needs to be much faster paced…. – Continue reading
British oil and gas contractors are amid a huge financial upheaval as a combination of job cuts and tax changes threaten their well-paid lifestyle. Thousands of contractors in the oil and gas industry worldwide have lost their jobs as companies look to protect their cash by sacking staff. The oil… – Continue reading
Officials from the ministries of finance and economy of five CEE countries (Czech Republic, Hungary, Poland, Romania and Slovakia) have called for a joint approach to combat VAT fraud and increase VAT collection in a conference hosted by PricewaterhouseCoopers (PwC) in Budapest on Thursday. According to the EU Commission data,… – Continue reading
On November 19, 2015 the European Commission published the key decisions of its November infringement package. One of the key decision mentioned is the Commission’s decision to request Germany to bring its inheritance tax rules on special maintenance allowances in line with EU law. According to a press release issued… – Continue reading
Compare this to the 2601 tax-related incarcerations in 2014 in the US. Jail for tax evasion is common in that country. The most well- known case is that of the gangster Al Capone who spent 7 years in jail as far back as 1932 to 1939. In recent years, actor… – Continue reading
On November 19, 2015 the European Commission published the key decisions of its November infringement package. One of the key decision mentioned is the Commission’s decision to request the Netherlands to amend the Limitation on Benefits (LOB) clause in the Dutch-Japanese Tax Treaty for the Avoidance of Double Taxation, which… – Continue reading
CANBERRA – Several multinational companies have approached the Australian Taxation Office to negotiate before the Coalition Government’s tougher anti-avoidance laws take effect in January, tax commissioner Chris Jordan has said in opening remarks to the Senate inquiry into corporate tax avoidance. While not naming the companies, Jordan said he expects… – Continue reading
Under the Double Taxation Treaties (“DTT“) General Communiqué (Serial No. 3) (published in the Official Gazette dated July 15, 2015 and No.29417); it is stated that in cases where the incomes earned by individuals and legal entities resident in Germany through their professional services in Turkey are taxed through withholding… – Continue reading
Employees in tax functions need to fundamentally change the way they use and gather data if they are to meet the growing demands on business of tax transparency, reform and technology enabled decision making. PwC’s latest research into the Tax function of the future – Unlocking the power of data… – Continue reading
It has been announced on the official website of the Directorate of Revenue Administration on July 30, 2015 that the “Agreement on Increasing International Tax Compliance through Extended Information Exchange” was signed in Ankara between Turkey and USA within the scope of Foreign Accounts Tax Compliance Act (“FATCA“). Under the… – Continue reading
U.S. Treasury Secretary Jacob Lew today wrote to the leaders of the congressional tax writing committees, and provided an update on the status of Treasury’s administrative actions concerning corporate inversions. In a version of the letter being widely circulated, Secretary Lew wrote that, later this week, Treasury intends to issue… – Continue reading
In recent days, the new Speaker of the House Paul Ryan (R-Wis.) signaled a priority for international tax reform in 2016. And if the newest recommendations from the Organization of Economic Cooperation and Development (OECD) are any indication of what’s ahead on the global tax scene for American businesses, it… – Continue reading
PRESS RELEASE – On November 19, the government of St. Lucia signed an agreement with the Government of the United States of America to implement the U.S. Foreign Account Tax Compliance Act (FATCA). Enacted by the U.S. Congress in 2010, FATCAtargets non-compliance by U.S. taxpayers using foreign accounts. FATCA requires… – Continue reading
Earlier this week the heads of state of the 20 largest global economies have agreed to adopt the 15 BEPS action points in their respective countries. Ample reason to take a closer look at the details and implications of one of the most far-reaching upcoming tax adjustments. Action 4 of… – Continue reading
Measures Will Impact Financial Services, Investment Fund, Aviation Leasing and Other Sectors G20 finance ministers last week finally approved the wide-ranging “BEPS” reforms to the international tax system. The measures include a proposed new OECD treaty definition of “Permanent Establishment” under which the mere negotiation of contracts could create a… – Continue reading
Tax administrators want to maximise the amount of revenue collected without stifling the county’s competitiveness as a business destination. How should ASEAN countries navigate changing international conditions to meet this goal? By Rebecca Tan – As Benjamin Franklin once famously said, “In this world, nothing can be said to be… – Continue reading
