New Delhi: With India stepping up its pursuit of alleged black money in Swiss banks, Switzerland says it is exchanging information with Indian authorities on all lawful requests, but cannot help on enquiries based on stolen banking data. The European country, which has often been accused of being the most… – Continue reading
Cayman is continuing preparations for the implementation of the US Foreign Accounts Compliance Act (FATCA). So far the island has signed two inter-governmental agreements (IGAs), and legislation is currently being drafted to meet the requirements of the new law. Chief Compliance Officer at DMS Offshore Investment Services Don Ebanks says… – Continue reading
The aggressive approach of Indian tax authorities on transfer pricing and international tax matters underlines the government’s intention of taking strong action to defend its tax base. When it comes to taxation of cross-border transactions, India’s inclination to widen the source-based tax rules is clearly demonstrated by the retrospective amendments,… – Continue reading
The Canada-British Virgin Islands (BVI) tax information exchange agreement (TIEA) came into force on 11 March 2014. The TIEA was signed in May 2013, and the effective date provisions are set out in article 13 of the agreement. The BVI is now party to 25 TIEAs. The BVI-Canada TIEA is… – Continue reading
Jersey Finance has welcomed the signing of the Tax Information Exchange Agreement (TIEA) with Belgium which took place in London on Thursday (March 13, 2014). The new agreement brings the total number of tax agreements Jersey has now signed with EU Member States to 20, which includes both TIEAs and… – Continue reading
Russia’s Finance Ministry has received suggestions from several offshore zones on organization of negotiations on exchange of tax information, Russia’s Deputy Finance Minister Sergei Shatalov told a Week of Russian Business on Monday. “Lately, the finance ministry has received suggestions from the British Virgin Islands, Bermuda Islands, the Isle of… – Continue reading
PARIS – The OECD is initiating an international discussion into measures to prevent the occurrence of profits shifting and tax evasion through the abuse and misuse of international tax treaties. Late last week the Organization for Economic Cooperation and Development released a public discussion draft “Preventing the Granting Of Treaty Benefits In… – Continue reading
Once you do your taxes internationally, you will soon face the concept of fiscal residency, or residence for purposes of taxation. Especially if you have no previous experience with living and working abroad, or if you aren’t a financial expert, you may need to think about this topic for the first… – Continue reading
New Zealanders living and working overseas can breathe a little easier now tax authorities have agreed that renting out a house they own in New Zealand doesn’t automatically make them a New Zealand taxpayer. The Inland Revenue Department has issued an interpretation of New Zealand residency after a Taxation Review… – Continue reading
A resident is defined in section 1 of the Income Tax Act No. 58 of 1962 (“the Act”). The definition includes a place of effective management test as one of the tests to determine the residence of a company. In terms of the definition a company that has its place of effective… – Continue reading
American Citizens Abroad (ACA) has provided testimony to the Senate Homeland Security and Governmental Affairs Permanent Investigations Subcommittee following its recent hearing on offshore tax evasion, and has recommended that the United States should implement a residence-based tax (RBT) system to avoid penalizing American expatriates. The ACA, as the principal… – Continue reading
NASSAU, The Bahamas – The Commonwealth of The Bahamas and the Czech Republic entered into an Agreement on the Exchange of Information on Tax Matters during a signing ceremony at the Ministry of Foreign Affairs on Thursday, March 6, 2014. Minister of State for Finance Michael Halkitis signed for The… – Continue reading
This was an appeal to the Court of Appeal from the decision of the Royal Court of Jersey, by which the Royal Court dismissed an appeal brought under Article 14(1)(c) of the Taxation (Exchange of Information with Third Countries) (Jersey) Regulations 2008 (the “Regulations”) and upheld the decision of the… – Continue reading
New Delhi: The Income Tax department has rebutted Vodafone’s notice under BIPA saying that the pact between India and Netherlands does not cover taxation issues. “Tax department has sent its response to Vodafone saying BIPA does not cover tax issues,” an official source said. The response to the Bilateral Investment… – Continue reading
PRLog (Press Release) – Mar. 4, 2014 – NICOSIA, Cyprus — As of January 1st 2014, Cyprus entered into five new Double Tax Treaties (DTT’s) with Estonia, Finland, Portugal, Spain and Ukraine expanding its already rich list of DTTs. All the agreements aim to avoid double taxation between the mentioned… – Continue reading
BANGALORE: In response to the letter written by finance minister P. Chidambaram, the Swiss finance minister Eveline Widmer-Schlumpf has informed that the Swiss authorities can’t share the details of the bank accounts held by Indians in Swiss bank without the consent of the account holders, reports Economic Times. An Indian… – Continue reading
Negotiations between the governments of Cyprus and Latvia on a new double taxation agreement, which began in 2006, appear to be reaching the final stages. The Latvian authorities have now published the text of the final draft agreement, which requires the approval of the Latvian Cabinet of Ministers before signature…. – Continue reading
Canada has aligned with the thinking of other countries around the world in battling against international tax avoidance. As the treaties that Canada has with other countries come up for renewal, exchange of information agreements are being added to updated treaties while exchange of information document agreements are being drawn… – Continue reading
The President of Tynwald, the Hon Clare Christian, has welcomed His Excellency Mr Dominik Furgler, Ambassador of Switzerland to the United Kingdom, to Tynwald. His Excellency was joined by his wife, Mrs Hayam Furgler and Ms Rebekka Benesch, First Secretary for Financial and Fiscal Affairs on a two-day visit which… – Continue reading
The Republican Party has recently formally approved a petition to repeal the Foreign Account Tax Compliance Act – the repeal comes just 5 months before the act is set to come into effect. The main sponsor of the Republic party resolution to repeal FACTA, is Solomon Yue, who is a… – Continue reading
NEW DELHI: The Swiss authorities have told the Indian government they will not be able to share information on bank accounts without the consent of the account-holders. In a letter last month, Switzerland’s finance minister also told her Indian counterpart that the 2011 Double Taxation Avoidance Agreement, under which India… – Continue reading
Gibraltar lawmakers unanimously approved new legislation that will dramatically expand Gibraltar’s network of agreements for the exchange of tax information. The legislation implements OECD’s Convention on Mutual Administrative Assistance in Tax Matters in Gibraltar ahead of the March 1 deadline. The move is part of the Government of Gibraltar’s policy… – Continue reading
Luxembourg has been widely hailed as an international investment center for years. The Association of the Luxembourg Fund Industry (ALFI) provides a number of reasons underlying the country’s designation as a top fund-industry choice. Its legal and regulatory framework for investment funds is recognized for its excellence by the global… – Continue reading
Kevin E. Packman is a Partner in our Miami office While Israel welcomes immigrants, and even provides them with tax incentives, it is serious about ending any perceived notion that it is somehow complicit with taxes evaded by its foreign residents in their home country. As such, it plans to… – Continue reading
The Russian Finance Ministry will offer companies based offshore but with operations in Russia a choice: either disclose their ultimate beneficiaries and maintain their zero tax rate, or pay taxes at the higher Russian rate. Under Russia’s current corporate tax structure, offshore beneficiaries of Russian companies are treated as de-facto… – Continue reading
Batam, Riau Islands (ANTARA News) – Indonesias finance ministry is preparing four strategies to withdraw funds worth Rp1,500 trillion kept in Singaporean banks, an official stated here on Wednesday. “We are preparing four strategies,” remarked Deputy Minister of Finance Bambang Brodjonegoro. The four strategies are tax incentives, eradication of double… – Continue reading
Ordinarily resident’s global income is taxable in India I worked in Sweden for about two months this year. What will be the tax implication of my earnings there? —Shruti The tax implications in India of income earned in Sweden would depend upon your tax residential status in India during the… – Continue reading
The Vodafone tax issue has affected investor sentiments towards India: ABAX Corporate CEO NEW DELHI, FEBRUARY 26: The Vodafone tax dispute and General Anti-Avoidance Rules have impacted investor sentiment badly. Coupled with the delay in revising the Double Taxation Avoidance Agreement (DTAA) with Mauritius, fund flow from the island-nation has… – Continue reading
A documentary on the working of tax havens in the context of the double taxation avoidance treaty between India and Mauritius reveals that while India may have received foreign investments due to the treaty, tax losses on its account run to the tune of tens of thousands of crores. Is it worth… – Continue reading
The Cyprus government has announced the signature of a new double taxation agreement with Norway. Double taxation avoidance between Cyprus and Norway is currently regulated by the 1951 double tax agreement between Norway and the United Kingdom, which was extended in 1955 to include several British colonies, including Cyprus. On… – Continue reading
Montenegro held the first round of talks with the Kingdom of Spain for the conclusion of an avoidance of double taxation agreement and prevention of income tax. Montenegrin delegation was led by Mitar Bajčeta, chief of the Directorate of Customs System and Customs Policy in the Ministry of Finance, and… – Continue reading
Kevin Thorn of the Thorn Law Group comments on the recent guilty plea by a United States Taxpayer with undisclosed overseas bank accounts as one in a long line of ongoing IRS and DOJ investigations into U.S. citizens with hidden overseas bank accounts. Thorn observes the U.S. government’s expanded… – Continue reading
The overlap of Australia’s new transfer pricing laws with the thin capitalization rules is causing challenges and likely duplication of analysis for taxpayers – particularly for the arm’s length amount-of-debt test. Australia legislated comprehensive new transfer pricing laws in 2012[i] and 2013.[ii] These laws were passed in two installments: Subdivision 815-A, dealing with… – Continue reading
Switzerland must adopt a position on sharing bank client data with foreign tax authorities more quickly than originally thought and cannot hold back until all other countries have introduced the practice, its finance minister told a Swiss newspaper. So far, 42 countries have declared an interest in automatically sharing information… – Continue reading
G20 finance ministers speak loudly, mention big stick The world’s top 20 finance ministers have signalled once again that they’re sick of their taxes disappearing offshore and have signalled a strong intention to get their cash back. The ministers in question are all members of the Group of Twenty (G20)… – Continue reading
Finance ministers and central bankers from the world’s most powerful economies have vowed to crack down on offshore tax evasion by big multinationals. Bill English was among the who’s who of the finance world meeting in Sydney yesterday. New Zealand is not one of the G20 but was conferred unofficial… – Continue reading
Credit Suisse Group , Switzerland’s second biggest bank, went to great lengths to assist US customers trying to open Swiss bank accounts and evade taxes, entertaining them at a Swiss-themed ball in New York and golf tournaments in Florida and opening a branch in the Zurich airport to serve Americans… – Continue reading
CYPRUS and Norway on Monday signed an agreement for the avoidance of double taxation. A statement said the text agreed between the finance ministries of the two countries would contribute to the further development of trade and economic relations between Cyprus and Norway, as well as other countries. “The updating,… – Continue reading
The Foreign Account Tax Compliance Act (“FATCA”) requires foreign financial institutions (“FFIs”) to disclose the foreign accounts of U.S. taxpayers to the Internal Revenue Service (“IRS”). FFIs that fail to comply with FATCA will be subject to a 30% withholding tax on certain U.S. source income starting July 1, 2014…. – Continue reading
Back in April 2013, the G5 Governments agreed to work together on a pilot scheme on multilateral and standardized exchange of tax information, with a new initiative on information exchange, based on the so-called FATCA (Foreign Account Tax Compliance Act) exchange model. Luxembourg, Liechtenstein, Malta, Greece, Iceland and Colombia have… – Continue reading
Group-of-20 nations agreed to implement a global standard for automatically exchanging information between tax authorities by the end of 2015, the Organization for Economic Cooperation and Development said. The endorsement is a step toward putting an end to “banking secrecy as we know it,” Pascal Saint-Amans, director of the OECD’s… – Continue reading
Barbados’ financial-services sector is rated as the second-largest source of foreign exchange earnings, behind tourism, for which new markets are being sought outside of Canada. On Thursday, central bank governor, Dr DeLisle Worrell, said the country has been losing business in its International Business and Financial Services Sector (IBFS), which… – Continue reading
Winston Churchill said there is “no such thing as a good tax.” Surely, then, it follows that no good can come from double taxation. While it’s difficult to feel sympathy for Conrad Black, who earned approximately $3.39 million with another $1.7 million of taxable benefits in 2002, the underlying principles… – Continue reading
The Manx government has asked S&P to stop its ratings after the agency warned of risks to the island’s financial services industry from international regulation The Isle of Man government has told Standard & Poor’s to stop rating its debt after the agency downgraded the island’s credit rating. S&P cut… – Continue reading
Congress is on a roll, trying to track down hidden offshore accounts, and the latest news is a report that shows which states have the most taxpayers disclosing such accounts (California is No. 1), and where they are located (Switzerland is tops). All told, taxpayers in at least 45 states… – Continue reading
The United States permanent subcommittee will be holding a hearing as they try to solve issues surrounding offshore tax evasion as prosecutors conduct criminal probes of 14 banks including credit Suisse Group AG. According to a statement by the committee, the focus will be on the status efforts to hold… – Continue reading
The United States is pushing measures to close tax evasion loopholes with global co-operation at the G-20 summit in Sydney, Australia, where the group of 20 advanced and emerging economies are meeting. The U.S. is bent on reducing the loopholes used by MNCs to avoid tax. Just ahead of the… – Continue reading
The battle against offshore tax evasion is gaining momentum after Australia and the US struck a deal to combat tax-dodgers and G20 members prepared to sign off on a scheme for the automatic exchange of tax information. American Treasury Secretary, Jack Lew, and federal Treasurer, Joe Hockey, announced in Sydney… – Continue reading
It’s a u-turn, but unavoidable: bankers and politicians are preparing for the automatic exchange of tax information. Switzerland has helped develop the new standard, which the OECD wants to fast-track worldwide. The days when Swiss finance ministers said banking secrecy was non-negotiable and carved in stone are over. Switzerland has… – Continue reading
A government bill has been submitted to the Knesset to amend the Income Tax Ordinance, adding a chapter on the exchange of information under international conventions. This will allow the Israel Tax Authority to share information with tax authorities of other countries, including countries with which has no tax treaty,… – Continue reading
