A powerful business lobby is sounding the warning to lawmakers about a global effort to crack down on offshore tax evasion. The National Association of Manufacturers warned the top congressional tax writers that the so-called Base Erosion and Profit Shifting project “could have a negative impact on the global competitiveness… – Continue reading
Since the beginning of the global financial crisis, politicians, the media and people on the street have engaged in a series of “blame games” to point fingers and punish those responsible for their own economic ills. For the past few years, one “culprit” has been firmly in the spotlight –… – Continue reading
Swiss and Italian foreign ministers recently met to discuss taxation, finance, transport, and other cross-border issues. Didier Burkhalter, head of Switzerland’s Federal Department of Foreign Affairs, received Italian Foreign Minister Paolo Gentiloni for official talks in Bern on May 28. The ministers welcomed the bilateral agreement on finance and taxation… – Continue reading
Capital gains tax charges from 6 April 2015 The scope of capital gains tax (CGT) has been extended and now applies to gains arising on the sale of UK residential property by non-UK tax residents (non-residents). Only gains arising after 5 April 2015 are subject to the new charge as… – Continue reading
Hungary’s Minister of Foreign Affairs and Trade Peter Szijjártó met with local political and business leaders in Singapore yesterday. Szijjártó told Hungarian news agency MTI by phone that an agreement had been reached on the transfer of Patec Automotiveʼs capacity in China to Hungary. As a first step, the Singapore-based… – Continue reading
After securing Switzerland’s cooperation in getting information about people with undisclosed income in bank accounts, the tax department is now focusing on other such destinations. According to sources, other countries have also begun sharing information on assets held there by Indians, and the I-T department will investigate this and issue… – Continue reading
Registering a company in Singapore is as good as declaring that you have judged your options, made your preparations, and now that the time is right, you mean nothing but, business. Opening a company in Singapore is an act enough for the investors to gauge the depth of your intent… – Continue reading
NEW DELHI: Months after it failed to sign the G20 information sharing agreement, India is set to sign the global treaty on June 3 which will enable it to access data related to bank accounts from across the world, including tax havens that were earlier refusing to cooperate. While information… – Continue reading
The UK’s First-Tier Tribunal has ruled in favor of HM Revenue and Customs in a case involving a “rate-booster” tax avoidance structure. The FTT found that the scheme used by Next Brand Ltd (part of the Next group) artificially moved money around the group with the aim of claiming tax… – Continue reading
It’s been called mysterious, secretive, and shadowy, but when it comes to the so-called shell company created by former president Bill Clinton as a vehicle for the delivery of consulting services, there’s a whole lot less there than meets the eye. According to the Associated Press, in 2008, Clinton set… – Continue reading
ISLAMABAD: An investment exhibition, inviting the crème de la crème of society to put their money in real estate opportunities in the Middle East, does not sound like the kind of place the government may want to raid. But the Federal Board of Revenue (FBR) – which has been worried… – Continue reading
Research shows corporation tax receipts from banks are lower than before crisis despite global tax payments staying constant Britain’s banks are paying far less in corporation tax to the Exchequer than before the crisis, despite their profits improving and global tax payments staying constant. Research from Cambridge Judge Business School… – Continue reading
Many states in our nation suffer the effects of over-taxation. Whether it’s high state income taxes pushing families to seek brighter economic climates or high corporate taxes compelling businesses to relocate their headquarters, taxes play a huge role in how state economies function. One of the most contentious and potentially… – Continue reading
As wealthy foreigners rush to get citizenship in Malta under a new programme, the residency requirement is taking many forms. Russians rent high-end villas, then stay in five-star hotels when they visit. An American financier plans to live in Switzerland but occasionally vacation in Malta. One Vietnamese businessman, eager to… – Continue reading
Santiago de Chile, May 25 (Prensa Latina) Chile and China will sign several cooperation and trade agreements today in a ceremony at La Moneda Palace, in the presence of Chilean President Michelle Bachelet and Chinese Prime Minister Li Keqian. Li, who arrived in this capital yesterday afternoon, held a meeting… – Continue reading
PUTRAJAYA: Malaysia and Slovak today signed a protocol agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, here. The agreement was signed by Foreign Minister Datuk Seri Anifah Aman and Slovak Republic’s Deputy Prime Minister Miroslav Lajčák in conjuction with… – Continue reading
On May 18, the Supreme Court decided a Maryland case involving double taxation. Maryland’s tax code does not give full credit to residents who also pay taxes in states where they work. The Court sided with the taxpayers, and the decision may cost some states and cities millions of dollars…. – Continue reading
Hanocal Holdings, a Dutch subsidiary of the Abu Dhabi-based International Petroleum Investment Company, has filed a lawsuit against the South Korean government through the World Bank’s International Center for Settlement of Investment Disputes. This is the second time that Korea is facing international arbitration under the “investor-state dispute settlement” process…. – Continue reading
Georgia and Poland held negotiations in Warsaw this week over an agreement on avoiding double taxation on income and capital. At the bilateral meeting the sides initialed the renewal agreement, which is based on the OECD Model Convention 2014 and envisages the introduction of new standards of cooperation in taxation… – Continue reading
German tax law allows deferring the tax on certain disposal gains by transferring the hidden reserves in the disposed assets to similar newly acquired or newly produced assets (“Replacement Assets”). The tax deferral requires an allocation of the Replacement Assets to a German permanent establishment. The ECJ has recently ruled… – Continue reading
Egyptian tax on shares sold by non-residents In 2014, the Egyptian Income Tax law was changed to introduce a 10% Egyptian tax charge on the net gain realised on a disposal of shares in an Egyptian company. This tax charge is intended to apply to non-resident as well as resident… – Continue reading
BEIJING, May 21 (Xinhua) — China has signed agreements with 99 countries to avoid goods being taxed twice as they cross borders in order to benefit more domestic enterprises going global, said a senior taxation official on Thursday. Wang Wenqin, deputy director of the State Administration of Taxation’s international tax… – Continue reading
India has amended section 6 of the Income Tax Act to introduce place of effective management (POEM) as the test to determine the place of residence of companies in the country. The change was included Finance Act, 2015, which received the President’s assent on May 12, 2015. The change will… – Continue reading
(Special) — The recent slump in oil prices is causing many Canadian investors to move their money from energy-weighted markets at home to foreign markets for better yields. While this may be a profitable investment strategy, it also can create its own set of problems because many investors may not… – Continue reading
Maryland’s taxation policy violated the U.S. Constitution by taxing income that state residents earned in other states, the U.S. Supreme Court ruled on Monday. The nation’s apex said the state’s controversial policy imposed form of double taxation on residents. The court in its ruling said Maryland cannot impose form of… – Continue reading
Ruling opens door for HM Revenue & Customs (HMRC) to recoup losses from other firms which used rate-booster schemes High street retailer Next has been hit with a £22.4m tax bill after a court found that it diverted profits made in the UK to offshore havens to avoid paying tax…. – Continue reading
Georgia’s freshman Senator David Perdue is a big advocate of the Fair Tax – a proposal long linked to the Peach State that calls for replacing federal income taxes with a national sales tax on all goods and services. Perdue talked up the plan in the GOP primary and general… – Continue reading
THE BJP-led National Democratic Alliance government, which had made a lot of noise about black money and the illegal stashing of funds abroad in the run-up to general elections last year, finally got down to some serious work to tax ill-gotten wealth and curb its growth. Last week, the government… – Continue reading
NEW DELHI: The Justice Shah Committee, constituted to go into levy of MAT on FIIs, will look into all important “legacy” cases, Finance Minister Arun Jaitley said blaming conflicting judicial rulings for the controversy on the issue that has riled foreign investors. He also said that foreign investors had invited… – Continue reading
This note is intended as an introduction to inheritance tax (IHT) issues that need to be covered where a “non-dom” (an individual domiciled outside the UK) is planning on becoming resident in, or is already resident in, the UK. It should be emphasised that this is a complex subject, and… – Continue reading
The I-T dept has received over 500 applications from MNCs for signing APAs. Income-tax department has set a target of 50 advance pricing agreements (APAs) to be sealed with multinational companies in the current fiscal that will exempt cross-border transactions by these firms from rigorous auditing to check income suppression…. – Continue reading
Smartly setting up trusts requires knowledge of state tax laws, not just federal rules. Consider Robert L. McNeil, a chemist and onetime Pennsylvania resident who amassed a fortune as the business brain behind Tylenol. McNeil established trusts for his family but chose to locate them in Delaware, for tax purposes…. – Continue reading
Following on from a press release issued by the Treasurer on May 11th, the government has released a draft bill containing a new limb to the general anti-avoidance provision, which is directed at foreign multinational groups who have global revenue exceeding $1 billion. The law will apply where: • the… – Continue reading
YEREVAN, 15 MAY, ARMENPRESS. On May 15, Minister of Foreign Affairs of the Republic of Armenia Edward Nalbandyan, who is on a working visit to Bratislava, met with Deputy Prime Minister of Slovakia, Minister of Foreign and European Affairs Miroslav Lajčák. As the Department of Press, Information and Public Relations… – Continue reading
The minimum alternate tax row has damaged the credibility of government promises to enforce an investor-friendly tax regime and made the Indian stock market Asia’s worst performer this year New Delhi/Mumbai: Castleton Investment Ltd, a unit of GlaxoSmithKline Plc (GSK), in 2012 asked an arm of the Indian finance ministry… – Continue reading
House Foreign Affairs Committee Chairman Ed Royce (R-CA) and Congressional Armenian Caucus Co-Chair Frank Pallone (D-NJ) were among the first Congressional leaders to welcome the May 7th signing of the U.S.-Armenia Trade and Investment Framework Agreement (TIFA), a longstanding policy priority for the Armenian National Committee of America (ANCA). Chairman… – Continue reading
I. Introduction Following the approval by Parliament of Law No.23 of 11 March 2014 (hereinafter “Delega Fiscale”[1]), the Italian Government is now taking action and adopting the Legislative Decrees necessary to enforce this innovative tax reform. In fact, on 21 April 2015 the Council of Ministers has approved the drafts… – Continue reading
I. Introduction Following the approval by Parliament of Law No.23 of 11 March 2014 (hereinafter “Delega Fiscale”[1]), the Italian Government is now taking action and adopting the Legislative Decrees necessary to enforce this innovative tax reform. In fact, on 21 April 2015 the Council of Ministers has approved the drafts… – Continue reading
The latest changes to VAT and profit tax legislation, implications of recent measures taken to fight fiscal evasion, changes to international tax reporting rules and the need to improve holding legislation were some of the topics discussed by participants in BR’s 14th Tax & Law conference which took place in… – Continue reading
Saudi Arabia is interested in increasing the trade turnover with Azerbaijan, Minister of Commerce and Industry of Saudi Arabia Tawfiq bin Fawzan Al Rabiah said at the Azerbaijani-Saudi Arabian business forum in Baku May 15. “Although Azerbaijan and Saudi Arabia signed the intergovernmental agreements on elimination of double taxation and… – Continue reading
HE Obaid Humaid Al Tayer, Minister of State for Financial Affairs, received HE Philip Parham, UK ambassador to the UAE at the Ministry of Finance (MoF) premises in Abu Dhabi. The two parties discussed the bilateral economic relations between the countries and the latest development regarding the rounds of negotiations… – Continue reading
President Truong Tan Sang arrived at Heydar Aliyev international airport in Baku on May 13 afternoon for a three-day official visit to Azerbaijan. The President was welcomed at the airport by Azerbaijani Deputy Prime Minister Eyyubov Yaqub, Deputy Minister of Foreign Affairs Khalaf Aly Oglu Khalafov, Azerbaijani Ambassador to Vietnam… – Continue reading
The worldwide transfer pricing landscape is in a state of flux and the need for sound and reliable dispute resolution mechanisms has never been more important for multinational enterprises. In particular, where aggressive tax administrations such as India are concerned, double taxation is a key concern for businesses. Mutual agreement… – Continue reading
A Protocol amending the Agreement for the Avoidance of Double Taxation and Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital between South Africa and Cyprus was signed on the 1st of April 2015. According to the Protocol, Article 10 (“Dividends”) of the Double Tax Treaty… – Continue reading
Head of forum’s tax policy will push for reform to cut down on avoidance. The OECD has attacked the “extremely aggressive” tax planning of companies such as Google, Amazon and Apple as it pushes for reform of global tax rules to cut down on avoidance. Pascal Saint-Amans, who heads up… – Continue reading
NEW DELHI: The Special Investigation Team on black money informed the Supreme Court on Tuesday that 339 accounts in HSBC bank held by Indians had a net amount of Rs 6,400 crore on which the income tax department has raised a demand of Rs 4,520 crore. “Amount of Rs 237… – Continue reading
The announcement marks an attempt to defuse the raging controversy over MAT payouts, which has dented the outlook of foreign institutional investors toward the country’s stock and bond markets. The government on Monday announced it had stayed the issue of fresh notices to foreign institutional investors regarding the alleged non-payment… – Continue reading
I. VAT and Customs In many cases, the principal in the contract manufacturing relationship owns some or all of the raw materials, work-in-process and finished goods throughout the manufacturing process. The principal and many of the suppliers are typically outside of the manufacturing jurisdiction. 1. Generally Speaking, What Are The… – Continue reading
New rules applicable to payments made by Chinese companies to ‘related’ companies offshore will prevent them from artificially shifting profits to lower tax jurisdictions through “unreasonable” service and royalty payments, the State Administration of Taxation (SAT) has said. Circular 16, which came into force on 18 March, and its accompanying… – Continue reading
South African companies are unable to compete with multinationals selling goods and services online in the country, partly as a result of tax laws. This is according to financial services group PwC, which argues that the country has not kept pace with the changing global economy. “Currently, multinationals in the… – Continue reading
