The central government is stepping up its anti-graft drive by cracking down on illegal lending and money-laundering operations in a bid to prevent outbound flows of stolen assets. The Ministry of Public Security says “black banks” and illegal currency exchanges have facilitated the flights of a number of former government… – Continue reading
We are entering a new world of tax revenue wars, and no one can say who will emerge as the victor. All we know is that there will be tension over the next five years as governments seek to implement the global plan to end to tax havens from Luxembourg… – Continue reading
South Africa is allowing MTN potentially lucrative tax credits on money sent from its African operations to a letterbox company in Mauritius. Last week, amaBhungane and Finance Uncovered, a global reporting project, exposed how MTN’s African subsidiaries send billions in management fees to MTN International in Mauritius. The Mauritian entity… – Continue reading
Hong Kong (HKSAR) – The Hong Kong Special Administrative Region Government noted that the European Commission (EC) updated its webpage on October 12 on the listing of non-cooperative tax jurisdictions amongst the European Union (EU) Member States. After the Government’s liaison and clarification with relevant authorities, the technical error of… – Continue reading
Ireland is growing as a global maritime business hub and its strengths in asset leasing could provide an alternative source of finance for shipping, according to a new report commissioned by the Irish Maritime Development Office and authored by tax advisors KPMG and legal firm Dillon Eustace, reports Splash. The… – Continue reading
A resolution was published in Panama’s official gazette in September 2015 replacing and “repealing” an August 2015 resolution, concerning how taxpayers may seek a ruling from the tax authorities as to whether benefits under income tax treaties for the avoidance of double taxation apply to the taxpayer’s specific transaction or… – Continue reading
With Medtronic being one of Ireland’s largest employers, analysts say there is a new incentive for the medical device maker to prioritize its Dublin headquarters for R&D. In the eyes of developed nations, Ireland has become notorious for baiting multinational firms to its land with the offer of friendly tax… – Continue reading
The Internal Revenue Service (IRS) has released a revised October 2015 version of its Publication 597, which provides information on the United States-Canada double taxation agreement (DTA), reports Tax News. A number of DTA provisions that most often apply to US citizens or residents who may be liable for Canadian… – Continue reading
In a summary judgment released on September 16, 2015, the Federal Court of Canada examined and disposed of the non-constitutional arguments in the Hillis and Deegancase[1] generally finding that the automatic data collection and disclosure of taxpayer information to the United States by Canada pursuant to the Canada-U.S. Intergovernmental Agreement… – Continue reading
Golden visa EU citizens may freely register as residents in Portugal. However, non-EU citizens may also obtain residence in Portugal if they obtain a ‘golden visa’ by participating in investment activity and fulfilling certain requirements. Requirements Obtaining a golden visa requires one of the following types of investment: acquisition of… – Continue reading
Permanent Establishment Based on the new treaty the definition of permanent establishment also includes a building site or construction or installation project or any supervisory activities in connection with such site or project constitutes a permanent establishment only if it lasts more than 9 months. Dividends The withholding tax rate… – Continue reading
Finance professionals will play a key role in dealing with changes brought about by a global project to combat corporate tax avoidance. A GLOBAL effort to tackle the problem of companies that attempt to reduce their tax burden by exploiting loopholes in tax rules will impact the way global businesses… – Continue reading
The Canada Revenue Agency (CRA) rents office space from a Vancouver-based property developer – a company that exploits offshore tax havens in Liechtenstein, the British Virgin Islands and Channel Islands. Larco Investments Ltd. owns three buildings in Montreal, Calgary and Edmonton where they rent office space to the CRA. Larco… – Continue reading
The United States has rejected India’s claim that schemes such as Atal Pension Yojana, Rashtriya Swasthya Bima Yojana, Employees Provident Fund Organization and others should be taken into account while determining the size of population covered under social security schemes. In recently resumed talks on Totalization Pact, the US said… – Continue reading
In just over two months, thousands of U.S.-based financial institutions will face new requirements for sharing financial information. These businesses should get ahead of the deadline and start preparing for the impact these rules will have on their operations and bottom lines. The Organisation for Economic Co-operation and Development’s new… – Continue reading
MINSK, 15 October (BelTA) – The House of Representatives of the National Assembly of Belarus ratified the Belarus-Georgia intergovernmental agreement on avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and capital on 15 October, BelTA has learned. It is expected that the agreement… – Continue reading
x At present, says the Government, serial avoiders find themselves in no worse a position than someone who has used only one failed avoidance scheme and has decided not to do it again. They face no additional deterrent to stop them persistently seeking to circumvent the will of Parliament. With… – Continue reading
Starbucks Corp. and a Fiat Chrysler Automobiles NV unit are set to be first in the firing line as European Union regulators issue a series of rulings over tax breaks for global companies, including Apple Inc. The EU may issue decisions against Starbucks and Fiat as soon as next week… – Continue reading
The Dutch government presented its Tax Bill 2016 on 15 September 2016. Three elements of this bill could specifically affect multinationals, international investors and investment funds with Dutch headquarters or group companies: The anti-avoidance rules in respect of non-resident taxation of foreign corporate shareholders and the dividend withholding tax treatment… – Continue reading
This summer brought some very significant amendments to the Cyprus tax laws, further enhancing Cyprus’ favourable tax regime. On 17 July 2015, the following laws were amended: The Special Defense for Contribution law No. 117(I) of 2002 as amended; The Income Tax Law No 118(I) of 2002 as amended; and… – Continue reading
HM Revenue and Customs (HMRC) has succeeded against a £200 million tax avoidance scheme which exploited the UK’s double taxation agreement with the Isle of Man, whereby people are not taxed on the same income in both the UK and the Isle of Man. Those who took advantage of the… – Continue reading
Individuals and families whose tax plans include trusts should take note of the recent decision of the Supreme Court of Newfoundland and Labrador in Discovery Trust v Minister of National Revenue (“Discovery Trust”)1 – the first case to deal with the issue of the residency of a trust for provincial… – Continue reading
A series of recent developments means that tax is now a key part of the Australian foreign investment regime and the foreign investment rules have significantly more bite. When determining whether a foreign investment proposal is “contrary to the national interest”, the Foreign Investment Review Board (FIRB) actively considers the… – Continue reading
The Algeria and the United States signed Tuesday in Algiers an intergovernmental agreement on the sharing of tax information between the two countries and to promote financial transparency and the strengthening of bilateral and international fight against tax evasion. The agreement, first of its kind concluded by the US with… – Continue reading
Bern, 14.10.2015 – Today, the Federal Council adopted the dispatch on the new double taxation agreement (DTA) with Oman and submitted it to Parliament for approval. The agreement will promote bilateral economic relations and contains provisions on the exchange of information upon request in accordance with the OECD standard. Aside… – Continue reading
FATCA was passed to prevent U.S. citizens from evading tax by focusing primarily on foreign financial institutions with U.S. account holders. The Foreign Account Tax Compliance Act (FATCA) was enacted as part of the 2010 Hiring Incentives to Restore Employment Act, and its provisions became effective as of 7/1/14. FATCA… – Continue reading
Tax experts from the United States, United Kingdom, Canada, Brazil and Israel spoke at a two-day conference at Michigan Law about the challenges of the Foreign Account Tax Compliance Act (FATCA) and a multitude of other issues at the intersection of the law of taxation and citizenship. Panel discussions at… – Continue reading
On 15 September 2015, the Bulgarian Council of Ministers submitted to the Bulgarian Parliament a proposal to implement the US Fair and Accurate Credit Transactions Act (FATCA) through changes in the Bulgarian Social Security Code. The proposed changes will effectively lead to the creation of an automated system for transfer… – Continue reading
To facilitate the exchange of Foreign Account Tax Compliance Act (FATCA) data under the intergovernmental agreements (IGAs) with Australia and the U.K., the U.S. Competent Authority has signed Competent Authority Arrangements (CAAs) with the Competent Authority of each country, announced IRS officials on September 24. The CAAs are the first… – Continue reading
LOS ANGELES—The Armenian National Committee of America – Western Region (ANCA-WR) is expressing its appreciation to Congressman Ted Lieu for authoring a letter to U.S. Treasury Secretary Jacob Lew in support of a U.S.-Armenia Double Tax Treaty. The accord, if concluded, would, by limiting the prospect of double taxation, remove… – Continue reading
MUMBAI: The Central Board of Direct Taxes (CBDT) on October 13 signed four unilateral advance pricing agreements (APAs), including India’s second APA with a rollback provision. The nature of the transactions covered under these agreements varied from software development to share price valuation. According to government sources, the total number… – Continue reading
On December 29, 2014, Uruguayan Congress ratified the Tax Information Exchange Agreement entered into between Uruguay and Brazil (“the TIEA”). The TIEA is patterned after the OECD Model. The Contracting Parties undertake to cooperate with each other through the exchange of any information which might be foreseeably relevant for tax… – Continue reading
After confirming that he would take part in the final round of the 2015 World Superbike Championship in Qatar, Max Biaggi’s presence at Losail this weekend is no longer a sure thing. The multiple World Champion has taken a fall from his mountain bike and sustained muscular injuries that may… – Continue reading
The Organization of Economic Cooperation and Development (OECD) released its final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) Project on Monday October 5th, 2015. The final package of BEPS measures includes new minimum standards on: country-by-country reporting, which for the first time will give tax administrations a… – Continue reading
The National Assembly member (NAM) for Foni Bintang Karanai constituency has said that during the recent annual general meeting (AGM) of African Parliamentarian Network on Illicit Financial Flows and Tax (APNIFFT) held in Entebbe, Uganda, African parliamentarians present had applauded the Public Accounts Committee and Public Enterprises Committee (PAC/PEC) of… – Continue reading
The number of letter box companies in the Netherlands continues to grow, despite both mounting criticism and tougher rules aimed at combating tax evasion, the Volkskrant said on Tuesday. The number of letter box firms – so called because they only exist on paper – rose 17% to 14,425 over… – Continue reading
Information on Completing the Form 8802, Application for United States Residency Certification Many U.S. treaty partners require the IRS to certify that the person claiming treaty benefits is a resident of the United States for federal tax purposes. The IRS provides this residency certification on Form 6166, a letter of… – Continue reading
x Australian Prime Minister Malcolm Turnbull announces his new federal cabinet during a media conference at Parliament House in Canberra, Australia, September 20, 2015. Australia got its fifth prime minister in as many years on Monday after the ruling Liberal Party voted to replace Abbott with former investment banker Malcolm… – Continue reading
Staff Correspondent The National Board of Revenue on Monday started negotiations with Bhutan to sign an agreement on avoidance of double taxation and prevention of tax evasion and capital flight from the country. A five-member delegation led by NBR chairman Md Nojibur Rahman has been carrying out the first round… – Continue reading
Companies around the world are scrambling to overhaul how they communicate with the public when it comes to how much tax they pay, according to professional services firm KPMG. While the Senate is currently investigating multinational firms such as Apple and Google over potential tax avoidance, other countries are also… – Continue reading
The Internal Revenue Service has made progress on implementing the Foreign Account Tax Compliance Act, including explaining the various requirements to the affected stakeholders, according to a new report. The report, from the Treasury Inspector General for Tax Administration, examined FATCA, which was included as part of the HIRE Act… – Continue reading
Bangladesh is set to sign an agreement with Bhutan to avoid double taxation to boost investments, trade and facilitate information exchange between the two Saarc nations, the National Board of Revenue said in a statement. A team led by NBR Chairman Md Nojibur Rahman is now in Thimpu to take… – Continue reading
Israeli importers and exporters, hi-tech and trading groups will all be in the base erosion and profit shifting firing line. On October 5 the Organization for Economic Cooperation and Development published a final comprehensive package of measures aimed at multinational corporations, large and small, that engage in BEPS – base… – Continue reading
With the adoption of the BEPS package, OECD and G20 countries, as well as all developing countries that have participated in its development, will lay the foundations of a modern international tax framework under which profits are taxed where economic activity and value creation occurs. Focus will now shift to… – Continue reading
Muscat: Bilateral trade between Oman and Spain has risen by 62 per cent, the European country’s top diplomat in Oman has said. Speaking at an event to celebrate his country’s National Day, Jose Urtasun, Spain’s Ambassador to the Sultanate, said, “Spain receives the most hydrocarbon exports from Oman of any… – Continue reading
Banking jobs in Geneva slipped to the lowest level since the 2008 financial crisis amid regulatory pressures, tax scrutiny and consolidation in the Swiss finance industry, according to lobby group Geneva Financial Center. Employees at banks in the city fell 3 percent to 18,855 in the 12 months through August,… – Continue reading
AstraZeneca ($AZN) is not the first company to employ questionable tax-planning strategies, and it certainly won’t be the last. But the U.K.-based drugmaker is the latest poster child for tax avoidance. As The Guardian reports, AstraZeneca funneled billions of dollars into the Netherlands to get out of paying corporate taxes… – Continue reading
The tax world followed with great interest today´s launch of the final package of BEPS. Having the BEPS report finalized is indeed a great achievement and, as pointed out by Mr. Angel Gurría, OECD Secretary General, in his Twitter, “Agreement of #BEPS package is a historic day in our effort… – Continue reading
Gov. Udom Emmanuel of Akwa Ibom has decried what he called the high rate of tax evasion in Nigeria, describing it as inimical for the development of the country. Emmanuel said this at the opening of the Mandatory Professional Training Programme of the Chartered Institute of Taxation of Nigeria (CTIN)… – Continue reading
India and Israel will sign a double taxation avoidance pact and explore ways to ramp up engagement in diverse sectors during President Pranab Mukherjee’s three-day historic visit to the Jewish state, the first by an Indian Head of State, beginning tomorrow, reports NDTV. Ahead of his visit, Israel said the… – Continue reading
