The industry has been demanding that GAAR provisions should apply prospectively To clear the air on retrospective applicability of the stringent anti-avoidance GAAR rule, the I-T department has said the same will not apply to income from transfer of investments before April 1, 2017. General Anti-Avoidance Rule (GAAR), which will… – Continue reading
Regardless of whether you were surprised, overjoyed, dismayed or showed any other emotion (perhaps anger as you saw world markets tank), Brexit is here. Yes, we’re talking about the British exit from the European Union. We are not sure why the media coined the term “Brexit,” when it’s not only… – Continue reading
With an aim to avoiding double taxation, improving the investment environment for Taiwan, and increasing the attractiveness of foreign investment into Taiwan, the Ministry of Finance in recent years has focused on entering into tax treaties with other jurisdictions. Following tax treaties signed with Italy and Austria, Taiwan entered into… – Continue reading
The Second Chamber of the Dutch Parliament has recently approved the bill between the Kingdom of the Netherlands, on behalf of Curaçao, and the United States to improve the international liability and the implementation of the Foreign Account Tax Compliance Act (FATCA). The Dutch Parliament also approved the bill proposal… – Continue reading
But Brexit May Upend Data Protection and Notification Rules Lawmakers and legal analysts are still struggling to analyze the impact of the June 23 referendum on Britain’s membership in the European Union (see Brexit: What’s Next for Privacy, Policing, Surveillance?). In the wake of a majority of U.K. voters opting… – Continue reading
Russian President Vladimir Putin has signed a law on ratifying Russia-Singapore agreement on the avoidance of double taxation and prevention of fiscal evasion with respect to the income taxes, according to the official internet portal of legal information. The accord reached on November 17, 2015 in Moscow is aimed at… – Continue reading
On 15 June 2016 the Bulgarian Parliament adopted long discussed amendments to the so called “Act on Economic and Financial Relations with Companies Registered in Jurisdictions with Preferential Tax Treatment, their Related Parties and Actual Owners” (the “Offshore Companies Act”, or the “Act”). The Act was adopted in 2014 and… – Continue reading
In what could be a significant development moving forward, UBS has provided the IRS with tax records and offshore accounts. UBS Group AG has come to an understanding with the US Internal Revenue Service (IRS), following a disagreement over client accounts in Singapore that had alleged tax evasion. The latest… – Continue reading
Foreign private equity investors typically set up offshore pooling vehicles for routing investments into India, which offer them twin advantages of ease of administration and single window compliance with the Indian regulatory regime. Setting up such pooling vehicles in a tax favourable jurisdiction ensures that the interposition of the pooling… – Continue reading
To check abuse of double taxation, India signs agreement with Belgium. The decision regarding this was taken in a meeting chaired by Narendra Modi. The Cabinet on Wednesday approved the signing of a protocol amending an agreement between India and Belgium for avoidance of double taxation and prevention of fiscal… – Continue reading
British multinational companies face new withholding taxes that may cost hundreds of billions of euros a year if U.K. voters decide to leave the European Union, international tax specialists say. A so-called Brexit “would have a major impact” on British corporations that have subsidiaries in the EU, said Daniel Gutmann,… – Continue reading
The Internal Revenue Service is missing out on imposing approximately $21.6 million in penalties on taxpayers who are denied entry or withdraw from its Offshore Voluntary Disclosure Program, according to a new report The report, from the Treasury Inspector General for Tax Administration, found the IRS needs to improve its… – Continue reading
Brussels (AFP) – The European Union agreed a raft of anti-tax evasion measures Tuesday that would make it harder for multinationals to shift profits to countries with lower taxes, but critics said they were too watered down. The proposals were agreed on provisionally by the EU’s 28 finance ministers on… – Continue reading
On 9 May 2016, Singapore passed the Income Tax (Amendment No. 2) Act 2016 (Amendment Act). This is a first step towards the implementation of the Common Reporting Standards (CRS) developed by the Organisation for Economic Cooperation and Development (OECD) into Singapore law. The legislation sets up the legal framework… – Continue reading
With just days remaining until Britain decides on its EU membership, the UK is at a crossroads. It has a historical choice to make, with various consequences attached to the decision on the 23rd of June on whether it becomes the first ever country to leave the EU. Those consequences… – Continue reading
The seeds of Canadian corporations hiding billions of dollars in offshore tax havens were sown more than 40 years ago, after the Canadian government pursued a series of tax treaties with tiny Caribbean and European nations. The 92 tax treaties now signed with countries such as Barbados, Jamaica and Malta… – Continue reading
A new double tax treaty between France and Singapore will be of particular help to French companies operating in Singapore, especially in the construction industry, an expert has said. Franck Lagorce, an expert in French tax at Pinsent Masons, the law firm behind Out-law.com was commenting following an announcement from… – Continue reading
Multinationals suspected of routing Australian profits via Singapore will be outed to tax authorities, with the low-tax nation this week signing up to the global plan to fight tax evasion. Companies including big miners BHP Billiton and Rio Tinto as well as technology giants Apple and Google, have admitted using… – Continue reading
Montreal-based clothing maker Gildan earned $396 million in profit last year, but paid just over $6 million in cash taxes — a rate of about two per cent. Drug maker Valeant, based in nearby Laval, Que., booked $1.1 billion in profit in 2014 but paid only $110 million in tax…. – Continue reading
The quest by the President Muhammadu Buhari’s administration to improve the ease of doing business in Nigeria and diversify the nation’s economy on Wednesday received a boost. This followed the passage of “a Bill for an Act to Provide for the Domestication and Enforcement in Nigeria of the Avoidance of… – Continue reading
Under the new tax framework, Singapore will implement minimum standards aimed at preventing “aggressive tax planning” by multinationals. Locally headquartered multinationals will soon have to file reports broken down by country as well as income and taxes to the Inland Revenue Authority of Singapore (IRAS). In a statement on Thursday… – Continue reading
On May 31, 2016, the Washington Department of Revenue (DOR) Appeals Division released a Determination (No. 15-0251, 35 WTD 230) denying a German pharmaceutical company’s business and occupation tax (B&O) protest. The administrative law judge (ALJ) ruled that while the nondiscrimination provisions contained in Article 24 of the US-Germany Income… – Continue reading
Bulgarian MPs passed at second reading on June 15 a bill easing ownership restrictions on offshore companies, amending a law that was adopted in December 2013. Under the amended law, which will go into effect on July 1, corporate entities registered in tax havens will be allowed to hold up… – Continue reading
Contrary to FATCA, accounts under $50,000 have been disclosed The Canada Revenue Agency has been transferring information about Canadian bank accounts worth under $50,000 U.S to the U.S Internal Revenue Service but cannot say how many accounts below that threshold have been shared with the Americans. Under a controversial information-sharing… – Continue reading
NEW DELHI: The government has constituted a working group to examine the “consequential issues” arising out of the changes in India’s tax treaty with Mauritius.The India-Mauritius Double Taxation Avoidance Convention was amended last month to introduce a levy to prevent investors from using the island nation as a shelter to… – Continue reading
Stamp duty will be doubled for foreign buyers of a median priced Sydney house under changes to be introduced in next week’s NSW budget. Based on the Sydney median house price of $995,804, the stamp duty bill for a foreign investor will increase by almost $40,000 – from $40,305 to… – Continue reading
Tax authorities and African governments have been urged to adopt effective information exchange systems based on proper implementation of international standards of transparency. This is necessary because exchange of information among member countries ensure that corporate bodies and individual taxpayers would have no safe haven to hide their income and… – Continue reading
Hundreds of policymakers, business executives, and senior tax officials met at the OECD International Tax Conference to discuss the recommendations proposed under the base erosion and profit shifting (BEPS) project and their impact on trade and investment. The conference, which was held in Washington DC on June 6-7, 2016, was… – Continue reading
The Netherlands and Switzerland have signed an agreement clarifying the tax treatment of certain collective investment vehicles (CIVs) in each jurisdiction under their bilateral double tax avoidance agreement. The Competent Authority Agreement was signed on June 8, 2016, and deals with the application of the 2010 Dutch-Swiss double tax treaty… – Continue reading
Members of the EU Parliament have welcomed an EU Commission proposal for an anti-tax avoidance directive but demanded tougher rules on foreign income and stricter limits on deductions of interest payments. They also called for more transparency for trust funds and foundations, common rules for “patent box” tax reductions on… – Continue reading
CHENNAI: The hardest thing in the world to understand is the income tax, is what Albert Einstein had famously said. Amid the long list of taxation categories, to assimilate what is taxable and what is exempted is hard. Even harder is to pay them, of course. As the June 15… – Continue reading
Last month the government announced an amendment to the Double Tax Avoidance Agreement between India and Mauritius. The DTAA was signed between the two countries in August 1982 and notified in December 1983. For the past thirty-three years it has been a key factor affecting foreign investment flows into India…. – Continue reading
Sydney-A new report by Oxfam said Australia’s federal government lost an estimated 5 billion US dollars in revenue in 2014 as a consequence of tax avoidance by multinational corporations with Australian operations. The non-governmental organization said in its report that investments from Australian-based big companies in tax havens globally grew… – Continue reading
Turkmenistan and the UK signed an intergovernmental convention in Ashgabat on avoidance of double taxation and prevention of fiscal evasion from taxes on income and capital gains, said the Turkmen foreign ministry in a message June 10. According to the ministry, the signing ceremony took place as part of a… – Continue reading
Poland has approved a general anti-avoidance rule (GAAR) which may be used retroactively with regard to undertakings or arrangements made before its introduction. The Act introducing a clause against tax avoidance [a general anti-avoidance rule – GAAR] comes into force within 30 days after its publication, likely in July 2016…. – Continue reading
Multinational companies doing business in Italy, Italian companies doing business abroad and non-resident companies which intend to invest in Italy may use the new international tax ruling procedure to reach an advanced agreement with the Italian Tax Authorities regarding the taxation of income derived from cross-border transactions. Recently, Legislative Decree… – Continue reading
Pending before the United States Senate are a number of tax treaties. Seven of these are bilateral treaties between the U.S. and a foreign country, in this case Chile, Hungary, Japan, Luxembourg, Poland, Spain, and Switzerland. ATR urges all Senators to support these routine, yet important treaties that protect against… – Continue reading
Finance Minister Audley Shaw says investors from Jamaica’s diaspora are challenged by international banks who are refusing to do correspondent banking with banks in Jamaica. Correspondent banking allows a financial institution to do business on behalf of banks in other countries, making it easy for persons to move cash from… – Continue reading
Ahead of India’s rolling out of anti-tax avoidance regulations, Cyprus has shown eagerness to amend the bilateral tax treaty allowing New Delhi to tax capital gains. In turn, has pitched to be taken off the blacklist or being considered a “notified jurisdiction” for not sharing tax information, which implies increased… – Continue reading
The legislature’s Finance Committee yesterday approved an anti-tax evasion bill, which, if passed into law, would subject all companies registered overseas to the 17 percent corporate income tax. While supportive of the legislation, the committee voted 7-5 in favor of allowing the Cabinet to set the implementation date to avoid… – Continue reading
The Indian government has signed up to a scheme to clamp down on tax evasion and corruption launched by Europe’s biggest nations, Britain’s government said on Wednesday. Signatories to the scheme – announced in April by Britain, France, Germany, Italy and Spain – undertake to give one another free access… – Continue reading
Most American policymakers believe the U.S. corporate tax system needs reforming – and the facts back up their view The United States’ 39 percent combined statutory corporate tax rate is the highest among the largest 50 economies. The American tax and accounting system has trapped over $2 trillion of deferred… – Continue reading
Four relatives of the Spanish king benefitted from an amnesty on tax evasion to ‘regularize’ previously undeclared assets worth over €4million, it has emerged. An elderly relative of the King, her son and two of her grandchildren, paid less than two percent to Spain’s treasury in order to make their… – Continue reading
Sinn Fein’s Matt Carthy has launched a stinging attack on Ireland’s corporate tax regime, arguing that Ireland’s reputation as an “enabler of massive tax avoidance for large corporations” is justified. Addressing the European Parliament in Strasbourg on Tuesday, the Midlands-North West MEP criticised the last government’s move to abolish the… – Continue reading
New U.S. Treasury regulations aimed at curbing tax inversions, where U.S. companies acquire foreign counterparts and headquarter abroad, seem to be working. But their broader goal – to keep American corporate capital at home – has failed. Consider the recent mergers-and-acquisitions activity. Chicago-based CF Industrial Holdings and Netherlands-based OCI called… – Continue reading
The double taxation avoidance agreement between Singapore and France entered into force on June 1, 2016. Under the deal, withholding tax on dividends would be capped at 15 percent in general; and at five percent where the beneficial owner is a company that owns directly or indirectly at least ten… – Continue reading
Recent news of India and Mauritius signing a Protocol to amend their 33 year old tax treaty caused seismic changes in the tax world. Though not completely unanticipated, the change is significant for foreign investors to go back to the drawing board and reassess their structures. The tax treaty between… – Continue reading
CHICAGO – Mid-sized international businesses around the world are afraid that upcoming international tax rules will hike their taxes, increase compliance costs, and interfere with their business strategies. In a report released over the weekend, the international management consultancy firm RSM showed that a significant portion of mid-sized international businesses… – Continue reading
SANTIAGO, June 7 (Xinhua) — The Foreign Relations Committee of the Chilean Senate approved Monday legal proposals to eliminate double taxation with China and three other countries. Chile and China first signed an agreement over the matter on May 25, 2015 in Santiago. “China is our main trading partner and… – Continue reading
In a step forward, Cyprus has said it is “very close” to revising the bilateral tax treaty with India as the island nation has accepted “in principle” proposals made by the Indian side on taxing capital gains. Cyprus, a source of significant foreign fund flows into the country, said rising… – Continue reading
