Category: Double Taxation

Lots of BEPS Output – What Outcome?

*Ernst & Young LLP, New York, NY The BEPS beat plays on. Congratulations to the OECD for meeting (mostly) the ambitious goals for release of their reports on seven action items in September 2014 – right on schedule on September 16. The documents released on September 16 relate to Action… – Continue reading

Taiwan and South Korea may open negotiations on economic agreements: officials

TAIPEI, Taiwan — Taiwan and South Korea are now more prepared to sign economic agreements, such as investment insurance and double taxation prevention pacts, South Korea’s representative to Taiwan Cho Baek-sang said yesterday. Cho made the comment at the first Taiwan-South Korea humanities exchange conference, held by the de facto… – Continue reading

Tax Inversions Wrap Up

There has been a recent surge in anti-tax inversion legislation discouraging companies attempting to shift corporate subsidiaries or headquarters to low-tax or tax-free countries. The issue was subjected to a great deal of publicity in April 2014 during the failed hostile takeover by Pfizer (NYSE:PFE) for AstraZeneca (NYSE:AZN) when Pfizer… – Continue reading

Singapore, Indonesia on track to curb cross-border tax evasion

An agreement to help crack down on cross-border tax evasion is being worked on by Singapore and Indonesia. The two nations are working on implementing the framework for the automatic exchange of information (AEOI) on tax matters, as they look to keep improving trade and investment ties. The move was… – Continue reading

Netherlands – Tax regulation with Curaçao not effective before 2016

December 17:  The Dutch Ministry of Finance announced that a new regulation for the avoidance of double taxation between the Netherlands and Curaçao is expected to be effective beginning 1 January 2016. The Dutch government bill concerning this regulation is pending consideration by the Lower House. Once approved, the bill… – Continue reading

Japan, Qatar reach tax treaty agreement

TOKYO, Dec 17 (KUNA) — Japan and Qatar have reached a substantive agreement on a bilateral tax treaty that will help businesses and investors avoid double taxation involving the two countries, the Foreign Ministry announced Wednesday. The agreement aims to clarify the taxation on cross-border investment and economic activities between… – Continue reading

OECD tax proposals threaten Irish deals with multinationals

Think tank targets key aspects of Republic’s role in multinationals’ tax affairs Key features of Ireland’s role in the tax affairs of major technology companies such as Google and Microsoft are being targeted by the OECD’s base-erosion and profit-shifting (Beps) project, it has emerged. Ideas being worked on by the… – Continue reading

Singapore, Indonesia to enhance cooperation on sharing tax information

Singapore’s Ministry of Finance say both parties enjoy “excellent cooperation” regarding tax matters, and have agreed to update the existing Avoidance of Double Taxation Agreement as the next step. SINGAPORE: The Republic and Indonesia will be looking to increase cooperation on the sharing of tax information in the coming days,… – Continue reading

New bilateral investment treaties will help India avoid arbitration

NEW DELHI: Bilateral investment treaties that the government will enter into from now on will have a provision preventing foreign investors to drag India to arbitration on any issues that have been settled by a judicial authority. Wiser from being dragged to arbitration in numerous cases, such as the Vodafone… – Continue reading

Saudi- Ernst 1amp Young hosts seminar on Zakat regulations

(MENAFN – Arab News) Ernst & Young one of the world’s leading professional services organizations hosted the 12th annual tax seminar on recent updates on Saudi Arabian zakat regulations and corporate income tax Law and its bye-laws in Jeddah on Thursday. Over 100 executives bankers and accountants attended this Seminar…. – Continue reading

The inversion backlash

Something strange happened in 2014 — Americans became very interested in corporate tax policy. It started in the spring, when U.S.-based pharmaceutical giant Pfizer, which produces blockbuster drugs like Lipitor and Viagra, floated a possible merger with its British-based rival AstraZeneca. Normally a merger of that size would make a… – Continue reading

Black money conundrum

The wise thing is to forget the past, bring reforms to prevent generation of black money Considering other man’s point of view is Decency — George Orwell This quality seems to be in short supply in India although it is the most needed even to understand any black money retrieval…. – Continue reading

The OECD action plan on Base Erosion and Profit Shifting

IN TAX, the latest global buzzword is “BEPS” or base erosion and profit shifting. BEPS refers to the practice of multinational corporations (MNCs) of shifting profits from high tax jurisdictions to low tax jurisdictions as a tax mitigation strategy. In February 2013, the Organization for Economic Co-operation and Development (OECD)… – Continue reading

Exemptions, concessions: FBR suffers Rs 361 billion annual loss

The Federal Board of Revenue (FBR) is suffering massive revenue loss of Rs 361 billion per annum on account of estimated tax expenditure in direct taxes, ie, equivalent to 1.6 percent of the Gross Domestic Product (GDP) as a result of exemptions and concessions to various sectors. Former Finance Minister… – Continue reading

Investor protection agreement negotiations to begin soon

Dubai: Hong Kong and the UAE will soon start negotiations to sign an investor protection agreement on a bi-lateral basis, John C Tsang, Financial Secretary of Hong Kong told Gulf News during his visit to the UAE. “The agreement will create a lot more comfort for people who are investing… – Continue reading

IT’S OFFICIAL: RS4,479 CR STASHED IN SWISS BANKS

The Income Tax Department has informed the Special Investigation Team (SIT) on Black Money that prosecution proceedings for non-furnishing of account details by Indians stashing black money abroad are in progress in 27 cases (under Section 276 D of the I-T Act) and has even filed a case in court… – Continue reading

Finance Ministry Reacts To Latest ‘LuxLeaks’

Responding to another leak, the Luxembourg Finance Ministry has said that the advance tax rulings issued to multinationals by the country’s tax authority are not, and never have been, secret. The Ministry issued a statement on December 10 acknowledging the publication by the International Consortium of Investigative Journalists (ICIJ) of… – Continue reading

UK Finance Bill 2015 — Draft Clauses Published

This Alert provides more details on the most significant measures contained in the draft Finance Bill. Draft clauses of the UK Finance Bill 2015 were published on 10 December 2014. They will now be the subject of consultation until 4 February 2015. This Alert provides more details on the most… – Continue reading

India keen to assist Barbados

THE CONCLUSION of an air services agreement and training opportunities for Barbadians were among the areas discussed, when India’s High Commissioner, Subashini Murugesan, paid a courtesy call on Permanent Secretary in the Ministry of Foreign Affairs, Charles Burnett. Burnett received the High Commissioner on behalf of the Minister of Foreign… – Continue reading

The Luxembourg ministry of Finance comments on the latest publications by the ICIJ

The ministry of Finance acknowledges the publication by the International Consortium of Investigative Journalists (ICIJ) and affiliated medias of a further series of advance tax decisions (“rulings”) issued by the Luxembourg tax administration. As with previous publications (“Luxleaks”), the way in which these documents were acquired is highly questionable. The… – Continue reading

Hong Kong exchanges notes with Japan regarding comprehensive agreement on avoidance of double taxation

Hong Kong (HKSAR) – The Government of the Hong Kong Special Administrative Region today (December 10) exchanged notes with the Government of Japan regarding the Exchange of Information (EoI) Article in the Agreement between the Government of the Hong Kong Special Administrative Region of the People’s Republic of China and… – Continue reading

Jersey: Jersey Finance Welcomes Tax Agreement With Romania

Jersey Finance has welcomed the signing of a Tax Information Exchange Agreement (TIEA) between Jersey and Romania this week. The agreement, which was signed by the Minister for External Relations, Senator Sir Philip Bailhache, and the Romanian Ambassador, His Excellency Ion Jinga, at the Romanian Embassy in London on Monday… – Continue reading

Finance Ministry declines to share details on black money probe

New Delhi: Citing national security and confidentiality clauses, Finance Ministry has declined to disclose information on exchange of correspondence among India, Swiss and German authorities in connection with the black money probe. Replying to an RTI query, the ministry said it was obtaining information regarding Indians having accounts in foreign… – Continue reading

Mauritius Yet to Agree on Tax Treaty Revision: Finance Minister

New Delhi: The government on Tuesday said Mauritius is yet to agree to certain proposals to the long pending revision of bilateral tax treaty. “India has made certain proposals for revision of DTAC (Double Taxation Avoidance Convention) to end round tripping and other aspects. Mauritius is yet to agree to… – Continue reading

Luxembourg says disclosing tax rulings to other states

(Reuters) – Luxembourg is giving details of its tax deals with foreign firms to governments that ask for them, its finance ministry said on Tuesday, addressing critics of its role in helping companies avoid taxes on a global scale. In a statement issued after a Belgian minister revealed he was… – Continue reading

B2B: Beneficial Owner of Income: Treaty Benefits and the Introduction of the New Rules

The MT Conferences section did not involve the reporting or the editorial staff of The Moscow Times. Russian business is trembling in expectation of the new year when major changes recently introduced to the tax legislation will enter into force. There has been a lot of discussion regarding the increase… – Continue reading

Switzerland fends off Indian ‘fishing’

Mumbai: As India continues its pursuit of black money allegedly stashed abroad, Switzerland has said it would not entertain any ‘fishing expedition’ and authorities cannot ask for names of all Indian account holders in Swiss banks without doing their own independent investigations. Switzerland’s ambassador to India Linus von Castelmur also… – Continue reading

Black money: Switzerland asks India for proof

As India continues its pursuit of black money allegedly stashed abroad, Switzer-land has said it would not entertain any ‘fishing expedition’ and authorities cannot ask for names of all Indian account holders in Swiss banks without doing their own independent investigations. Switzerland’s Ambassador to India Linus von Castelmur also said… – Continue reading

Rikvin Publishes a New Guide on Advantages of Doing Business in India via Singapore

PRWEB.COM NewswireSingapore (PRWEB) December 06, 2014 Buoyant by Singapore Government’s foreign direct investment policies, efficient corporate tax regime, robust intellectual property safeguards, and exemptions on qualifying foreign-sourced incomes, several big Indian companies such as Flipkart, InMobi, Crayon Data, Zipdial and Mobikon have made the city-state their incorporation destination. To assist… – Continue reading

Japan, Qatar to launch tax treaty talks

TOKYO, Dec 5 (KUNA) — Japan will launch negotiations for bilateral tax treaty with Qatar aimed at helping businesses and investors avoid double taxation involving the two countries, the Foreign Ministry announced Friday. The first round of talks will be held here on December 8, the ministry said in a… – Continue reading

North America leads global increase in MAP uptake

The US and Canada are at the forefront of a global increase in new mutual agreement procedures (MAPs) being initiated, OECD figures show. There were 1,910 new MAPs in 2013, a 14% increase from 2012, when there were 1,678 new MAPs. North America accounted for most of this growth, with… – Continue reading

Govt guidelines to clarify ‘arm’s length’, ‘ordinary course of business’ definitions

To minimise confusion and litigation, the government will bring fresh guidelines to clearly explain the meaning of terms “arm’s length basis” and “ordinary course of business”, used in the Companies Act, 2013. “After understanding the significance of these two terms for our industry, we have decided to bring fresh guidelines,”… – Continue reading

Swiss envoy: Can’t work with stolen data, fishing expeditions

Swiss Ambassador to India Linus von Castelmur on Wednesday said it would not be possible for his government to work with stolen data and entertain “fishing expeditions” while dealing with the issue of tracing Indian black money holders. “We signed a double tax avoidance treaty with India in 2011 that… – Continue reading

Global tax war looming and US won’t be backing down

The United States won’t give up its right to tax multinationals, and nations will go to war soon with countries like China on taxing rights, a US tax head says. Grant Thornton’s national managing partner of tax in the United States, Randy Robason, is in Australia this week for a… – Continue reading

New British envoy to concentrate on UK-UAE commercial ties

Former head of counter-terrorism department in London Philip Parham says there are very big opportunities in the UAE. The new British Ambassador to Abu Dhabi, Philip Parham, is planning to concentrate his efforts in further growing the commercial ties between UK and UAE. “On the commercial side, there are very… – Continue reading

Taxation of Esops when on a foreign assignment

Stock award is a popular method of rewarding talented and industrious employees. However, employees who render services across different jurisdictions may trigger a taxable presence in two or more jurisdictions. Such employees at times need to deal with the issue of double taxation on such benefits. A normal stock incentive… – Continue reading

Out of 627, 427 black money account holders identified: Arun Jaitley

With the Opposition targeting the government on the black money issue, Finance Minister Arun Jaitley told the Rajya Sabha on Wednesday that the identity of 427 foreign account holders has been established, of which 250 have admitted to having these accounts. Replying to a debate on the issue, Jaitley said… – Continue reading

Applying for DTA Benefits in China

For foreign investors doing business in China, securing benefits under a double taxation avoidance (DTA) agreement is an important measure for reducing their tax burden as stipulated by Chinese tax law and thereby maximizing profit. In addition to satisfying the specific requirements of a relevant DTA, certain administrative procedures must… – Continue reading