The Swiss Government has tasked the Finance Ministry with responding to the OECD’s recommendations on base erosion and profit shifting. Welcoming the OECD’s proposals, the Council said: “In general, the project outcomes will allow for [the] better coordination of international tax law rules and make it possible to close the… – Continue reading
The Swiss Federal Council has adopted a dispatch on the implementation of tax information exchange agreements with Belize and Grenada. The Council adopted the dispatch on October 7. It will now be submitted to Parliament for approval. The TIEAs were signed with Grenada on May 19 and with Belize on… – Continue reading
The Union Cabinet chaired by the Prime Minister Narendra Modi, has approved the protocol amending the convention and the protocol between India and Israel, for avoidance of double taxation and for prevention of fiscal evasion with respect to taxes on income and on capital. The protocol provides for internationally accepted… – Continue reading
NEW DELHI, OCTOBER 7: The Union Cabinet on Wednesday gave its nod for the introduction of a ‘limitation of benefit’ clause in the double taxation avoidance convention (DTAC) with Israel. The ‘LOB’ Article is an anti-abuse provision aimed at preventing misuse of the convention. The protocol that received the Cabinet’s… – Continue reading
On 6 October 2015, the Council of the European Union reached agreement on a proposal for a Council Directive (‘the New Directive’) amending Directive 2011/16/EU (Directive on administrative cooperation between Member States) and requiring automatic exchange of information on ‘advance tax rulings’ (‘Tax Rulings’) and ‘advance pricing arrangements’ (‘APAs’) between… – Continue reading
NEW DELHI: The Centre is in talks with Mauritius with regard to the long-pending revision of the bilateral tax treaty, Revenue Secretary Hasmukh Adhia said today. “We are in discussion with them. Some negotiations have already taken place and they wanted to reopen certain issues. we are in discussion with… – Continue reading
Colombia and Panama have given each other another 60 days to come to agreement on how to combat Colombian tax evasion through Panamanian banks. The two countries failed to meet the negotiation deadline set for the exchange of tax information after one year, extending a further 60 days, in a… – Continue reading
Once again, Commonwealth Caribbean countries are under attack as “tax havens”, even though they are nothing of the sort. This time it is not only the usual countries which have been listed. Trinidad and Tobago has been included, and we can bet that Jamaica and Guyana will be added unless… – Continue reading
Hong Kong (HKSAR) – Six orders for implementing the tax information exchange agreements (TIEAs) with six Nordic jurisdictions (i.e. Denmark, the Faroes, Greenland, Iceland, Norway and Sweden), and an order for implementing the Fourth Protocol to the Comprehensive Arrangement for the Avoidance of Double Taxation with the Mainland (the Arrangement)… – Continue reading
Introduction The Foreign Account Tax Compliance Act (FATCA) requires non-US financial institutions, including investment entities, to report US account holders to the Internal Revenue Service (IRS). This reporting is causing US taxpayers living abroad to consider whether they have been adequately filing annually their income and information returns in the… – Continue reading
The deadline for participation in Italy’s current voluntary disclosure program has been extended from September 30 to November 30, 2015, following the decision taken at a Cabinet meeting on September 28, reports Tax News. In addition, those individuals who file an application form to enter the program by the new… – Continue reading
European Commission list identifies the city as one of 30 non-cooperative tax jurisdictions, reports the South China Morning Post. The European Commission is likely to remove Hong Kong from its list of top 30 tax havens, according to a source familiar with the situation. The source, who cannot be identified,… – Continue reading
WASHINGTON, D.C., Sept. 30, 2015 –His Excellency Dr. Eugene Newry, Bahamas Ambassador to the United States, has written a letter to Municipal Officials of the District of Columbia and Federal Congressional Officials protesting “in the strongest terms” The Bahamas’ designation as a “tax haven” by D.C. authorities in the District… – Continue reading
On 5 August 2015, the Luxembourg government presented a bill implementing Council Directives 2014/86/UE and 2015/121/UE amending Council Directive 2011/96/UE of 30 November 2011 on the common taxation applicable in the case of parent companies and subsidiaries of different Member States (the Parent-Subsidiary Directive). In accordance with Directive 2014/86/UE, the… – Continue reading
The Base Erosion and Profit Shifting (BEPS) Action Plan adopted by the OECD and G20 countries in 2013 recognised that enhancing transparency for tax administrations by providing them with adequate information to assess high-level transfer pricing and other BEPS-related risks is a crucial aspect for tackling the BEPS problem. Against… – Continue reading
The Internal Revenue Service has entered into landmark Competent Authority Agreements with authorities in Australia and the United Kingdom to support the implementation of the Foreign Account Tax Compliance Act (FATCA). The US has signed FATCA intergovernmental agreements with both of these nations. Each of these agreements provides that Competent… – Continue reading
Andorra’s Ambassador to Spain, Jaume Gaytan, and the Ambassador of the Italian Republic in Andorra, Pietro Sebastiani, last week signed an agreement on the exchange of information on tax matters. Gaytan and Sebastiani noted that the tax information exchange agreement (TIEA) between the two territories builds upon existing strong bilateral… – Continue reading
The Isle of Man has continued its programme of developing closer economic and taxation co-operation with other countries by concluding a Tax Information Exchange Agreement (TIEA) with the Cayman Islands. This is the Isle of Man‘s 33rd TIEA. The agreement was signed by Hon. G. Wayne Panton MLA, the Cayman… – Continue reading
On September 16, 2015, the Honorable Mr. Justice Martineau rendered summary judgment in the matter of Hillis and Deegan v. The Attorney General of Canada, docket T-1736-13 (2015 FC 1082). As a matter of background (and as discussed in a previous post), on August 11, 2014, the plaintiffs, Hillis and… – Continue reading
What constitutes an HNI is a tricky question? In general parlance, HNIs are understood to be the individuals with ultra-high networth with deep pockets having surplus investible funds. As per the Credit Suisse global wealth report, currently India is home to around 1,500 ultra-high networth individuals with wealth of at… – Continue reading
BY DAVID JESSOP— The Caribbean has just 18 congressional working days from Sunday, September 20 to try to have the U.S. Congress address an act naming 17 Caribbean nations as “tax havens”. If passed without amendment, it could have the effect of reputationally damaging the countries concerned with unpredictable trade,… – Continue reading
33rd Tax Inform Exchange Agreement The Isle of Man has finalised its 33rd Tax Information Exchange Agreement today. The agreement was signed earlier by Treasury Minister Eddie Teare and from next year, it’ll allow the Isle of Man and the Cayman Islands to exchange information. Mr Teare says both the… – Continue reading
With less than two weeks remaining until many countries are required to exchange tax information with the U.S. pursuant to the Foreign Account Tax Compliance Act (FATCA), the U.S. has agreed to provide partner jurisdictions with more time to implement information exchange systems. Today, the Treasury Department and the Internal… – Continue reading
The Caribbean has just 18 congressional working days from Sunday September 20 to try to have the US Congress or the District of Colombia address an act naming 17 Caribbean nations as “tax havens”. If passed without amendment it could have the effect of reputationally damaging the countries concerned with… – Continue reading
Read the full newsletter. The OECD’s recent recommendations1 with respect to transfer pricing documentation and country-by-country reporting may have the most significant impact on multinational enterprises (“MNEs”) of all of the OECD’s BEPS proposals. The adoption of these recommendations, without consensus on effective dispute resolution, is likely to alter the… – Continue reading
(ZIZ News) — Tuesday’s sitting of the National Assembly featured heated debates on the Foreign Account Tax Compliance (United States of America) (Implementation and Enforcement of InterGovernmental Agreement) Bill 2015. Prime Minister, Hon. Dr. Timothy Harris, who sought leave to have the bill read a first and second time, was… – Continue reading
An initiative intended to catch tax dodgers could have a negative impact on those with perfectly legitimate bank accounts. Tax expert Howard Bilton offers advice The draconian Foreign Account Tax Compliance Act (FATCA), introduced by the US Government to tackle tax evasion by its citizens, has already affected Britons living… – Continue reading
Bern, 09.09.2015 – The tax information exchange agreements with Andorra, Greenland, San Marino and the Seychelles have come into force. They will apply from 1 January 2016. Following the completion of the corresponding ratification processes, the tax information exchange agreements (TIEA) have come into force with Andorra (27 July 2015),… – Continue reading
The international financial sector faces a perilous future. Major challenges loom over an uncertain global economy, while a decidedly negative political climate poses an existential threat to the offshore financial community. With each passing year, thanks to demographic changes and poorly designed fiscal policies, politicians from high-tax nations will be… – Continue reading
The General Manager of the Italian Revenue Agency, Rossella Orlandi, has confirmed that there have so far been 10,000 requests to enter into Italy’s current voluntary disclosure program, compared with only around 1,000 applications received by May. The program allows taxpayers who apply by September 30 to regularize undeclared capital… – Continue reading
No declaration of foreign assets can be made which have been acquired during the year for which a notice under specified sections of the I-T Act has been issued The government has recently come up with a new legislation namely Black Money (Undisclosed Foreign Income and Assets) and Imposition of… – Continue reading
On September 8, 2015 the Cypriot Ministry of Finance published an announcement titled: “Conclusion of a Protocol that will amend the Convention for the Avoidance of Double Taxation and the prevention of fiscal evasion with respect on taxes on income between the Republic of Cyprus and the Government of Ukraine… – Continue reading
In September 2014, the Hurun Research Institute published its annual listing of the richest people in China. It showed that IT tycoon Ma Yun had increased his personal fortune during the last year by 500% to $25 billion and in doing so, had climbed to first position on the list…. – Continue reading
SEJONG, Sept. 3 (Yonhap) — More South Koreans reported their overseas financial accounts to authorities in 2015 than a year earlier as the government turns up the heat on individuals and companies to disclose hidden assets, the tax office said Thursday. The government has taken a firmer stance toward people… – Continue reading
Two Cayman residents are challenging a decision by the Tax Information Authority to comply with a tax information exchange request by the U.S. Internal Revenue Service. Lee and Sheila Aronfeld are naturalized citizens of the Cayman Islands but remain taxpayers in the United States, where they are subject to a… – Continue reading
New Zealand: GST and the digital economy The New Zealand Government has released a Discussion Document regarding the proposal to impose goods and services tax (GST) on online purchases of goods and services from offshore suppliers by New Zealand resident consumers. The publication Taxing by the megabyte: New Zealand’s GST… – Continue reading
Italy’s Cabinet on August 7 approved legislation to ratify the tax agreements signed with Switzerland, Liechtenstein, and Monaco. The protocol to the existing double tax agreement between Italy and Switzerland was signed on February 23, 2015. The Cabinet noted that, once the protocol enters into force following ratification by both… – Continue reading
Ministry of Finance officials say they are “monitoring developments” in Washington after the District of Columbia included Bermuda on a list of tax havens. The Island was one of 39 jurisdictions named on the list in changes to the municipality’s Budget Support Act. The changes will first have to be… – Continue reading
The Deputy Premier and Minister of Finance Bob Richards today [Aug 28] commented on a report that Bermuda has been named to a new tax haven list drawn up by the District of Columbia in the US. While such changes would first have to be reviewed by the US Congress… – Continue reading
The Swiss cabinet has urged parliament to reject an initiative aimed at maintaining banking secrecy for domestic private bank clients. In recent years, Switzerland’s much-vaunted tradition of banking secrecy has been under constant pressure. On Wednesday the government dismissed calls to anchor the protection of domestic Swiss banking secrecy in… – Continue reading
Sofia. Bulgarian Council of Ministers approved at its regular Wednesday sitting an agreement on exchange of information on tax matters signed between the governments of Bulgaria and Guernsey. The cabinet proposes the National Assembly ratifies the document, the press service of the Government announced. The agreement sets conditions for the… – Continue reading
This month’s feature examines proposals for new tax information reporting requirements for large multinational businesses as part of wider and ongoing changes to the international tax system – proposals which have been described by international tax experts as the most significant development in the field of transfer pricing since TP… – Continue reading
To check black money generation, the government today approved signing and ratification of the agreement between India and Seychelles for exchange of information with respect to taxes, reports the Economic Times. The agreement will stimulate the information exchange between India and Seychelles for tax purposes, which will help curb tax… – Continue reading
The Cayman Islands is confident that the pan-European marketing ‘passport’ will be extended to alternative investment funds (AIFs) set up in the jurisdiction, according to the Alternative Investment Management Association (AIMA). Cayman, where a high percentage of offshore hedge funds are registered, still awaits assessment by the European Securities and… – Continue reading
IN THE LAST TEN YEARS the international community has tried to pressure Barbados into signing tax information exchange agreements. Successive administrations, however, have resisted by continuing to show preference for double taxation treaties. That has not stopped the pressure, and some would argue that in some ways the global players… – Continue reading
South Africans with undisclosed offshore accounts may feel exposed after their offshore Swiss bank account information found its way into the public domain this year. The theft of information relating to some 30 000 HSBC accounts – the biggest banking leak in history – actually took place five years ago… – Continue reading
Financial Services Minister Hope Strachan said yesterday that the landscape of the country’s financial services industry would be strengthened as a result of the nation’s compliance with the tax information exchange agreements such as the US Foreign Account Tax Compliance Act (FATCA), saying that she was fairly satisfied that The… – Continue reading
Gaborone — Botswana and Mauritius on Saturday August 15 signed a Double Taxation Avoidance Agreement, renewing a convention the two countries have had since 1995. Minister of Finance and Development Planning, Mr Kenneth Matambo represented Botswana while Mauritius’ Minister of Foreign Affairs, Regional Integration and International Trade, Mr Marie Joseph… – Continue reading
The Swiss Federal Council has adopted a dispatch on the implementation of a tax information exchange protocol to its double tax agreement (DTA) with Italy. The protocol to the 1976 DTA was signed on February 23, 2015. It brings its information exchange provisions into line with the Organisation for Economic… – Continue reading
Switzerland and Belize signed a tax information exchange agreement (TIEA) on August 10, 2015. The agreement is Switzerland’s ninth TIEA. It provides for the exchange of information upon request. It covers Swiss federal, cantonal, and communal taxes on income and capital, and the cantonal and communal inheritance and gift taxes…. – Continue reading
