Revised rules affecting the way corporate debt and derivative contracts are taxed have now been drafted and are out for a brief consultation, in a bid to avoid double taxation and curb potential abuse HMRC has issued draft legislation for consultation following amendments to the Change of Accounting Practice Regulations… – Continue reading
Chances of tax evaders coming under the scanner is rising due to the implementation of the GST, greater use of technology and exchange of information between countries New Delhi: The noose is tightening around tax evaders. Be it the implementation of the goods and services tax (GST) or the greater… – Continue reading
Ireland, accused of being a tax haven for multinationals such as Apple to pay nearly zero tax on the bulk of its profits earned outside the United States, finds itself with a new adversary in the global fight against unfair tax practices — Brazil. As of October 1, Brazil will… – Continue reading
During his remarks at a September 26 meeting with Argentine Finance Minister Alfonso Prat-Gay in Buenos Aires, US Treasury Secretary Jack Lew disclosed that the two countries are to negotiate a comprehensive double taxation agreement, to include provisions for the exchange of tax information. “To accelerate the process of sharing… – Continue reading
Members of the European Parliament, September 27, have begun their investigation into the Panama Papers scandal, which exposed the sheer extent of rich people and companies using offshore tax havens to reduce their tax liabilities in EU member states. However, the latest probe comes on the back of another investigation… – Continue reading
A report by the Independent Commission for Aid Impact (ICAI) has criticised the Department for International Development’s (DfiD) approach to tackling tax avoidance and its alleged failure to achieve value for money on HMRC collaboration DfiD has failed in its efforts to fully include developing countries so that they benefit… – Continue reading
CANADA, ISRAEL SIGN AGREEMENT ON DOUBLE TAXATION As Prime Minister Justin Trudeau joined other world leaders in addressing the United Nations General Assembly, behind the glare of the camera lights, Foreign Affairs Minister Stéphane Dion met with Israel’s Finance Minster Moshe Kahlon on the sidelines to sign an agreement to… – Continue reading
The Zimbabwean government enacted a law last week to remove double taxation for individuals and firms doing business between Zimbabwe and China to boost economic cooperation between the two nations. Under the Statutory Instrument, investors in any of the two states would only be taxed in their country of operation… – Continue reading
The threshold could be R5,400 crore of annual consolidated group revenue for the purpose of country-by-country reporting Not more than 120 India-headquartered firms — along with their global associates — are likely to be impacted by the base erosion and profit shifting (BEPS) protocol once it is implemented, as the… – Continue reading
House Democrats have introduced legislation that would require multinational corporations to disclose more information about the taxes they pay in other countries. The bill, known as the Corporate Transparency and Accountability Act, aims to shine more light on corporate tax avoidance strategies, requiring the disclosure of country-by-country and pre-tax profit… – Continue reading
Switzerland’s Supreme Court has overturned the decision of a lower court preventing information on bank accounts held by Dutch citizens with UBS to be sent to the Netherlands tax authority. Upholding an appeal by a Dutch client of Swiss bank UBS in March 2016, the Federal Administrative Court blocked the… – Continue reading
Auditing and tax advisory firm KPMG is calling for establishment of the T&T Revenue Authority (TTRA) so there can be a structured way of collecting taxes. “The current main tax authority does not appear to have structured means, if any, of treating with businesses that conceal transaction to avoid tax… – Continue reading
With India re-working taxation treaty with Singapore, an influential grouping of overseas investors has said capital gains tax exemption should be retained in the pact for FPIs in listed securities as that would “greatly ease” concerns of foreign investors. Seeking elimination of capital gains tax on portfolio investments in listed… – Continue reading
Wales is to replace stamp duty with a land transaction tax as it moves towards devolved tax collection. The new tax on land transactions will be introduced from April 2018 alongside measures to tackle devolved tax avoidance, the Welsh government said. Land transaction tax is paid on the purchase or… – Continue reading
Mauritius, the island nation that accounts for the second-largest FDI, has sought a line of credit and more investments from India as it gets ready for implementation of the revised tax treaty from April 2017. Mauritian Minister of Finance and Economic Development Pravind Kumar Jugnauth yesterday met Finance Minister Arun Jaitley… – Continue reading
The Turnbull government will introduce a tax treaty between Australia and Israel to improve business relations between the two countries. The treaty is linked to the government’s plan to boost innovation in Australia as well as its push to further trade between the two countries as Israel’s technology sector booms…. – Continue reading
Apple Inc. may face double taxation on some of its profits if the European Commission’s Aug. 30 ruling inspires France to slap its own tax adjustment on the company, practitioners said. Apple could even face “triple taxation” if it repatriates profits from the European Union to the U.S., Laurent Leclercq,… – Continue reading
The following is a bolded checklist of important situations that may “trigger” a tax review by a skilled United States tax professional. Many of these situations also require a simultaneous review by a foreign tax professional. It is generally best practice for these tax professionals to work together to minimize… – Continue reading
The council will be chaired by Finance Minister Arun Jaitley and will make all the major decisions on the implementation of the new regime. The Union Cabinet on Monday notified and approved the formation of the Goods and Services Tax Council, the body that will oversee various issues regarding the… – Continue reading
A recent 2016 tax reform in Japan (“Reform”) has introduced stringent Japanese Transfer Pricing Documentation Requirements, which require the preparation/filing of: (i) a Master File, (ii) a Country-by-Country Report, and (iii) a Local File, as well as (iv) a “Notification of the Ultimate Parent Entity.” Any ultimate parent company (“Parent… – Continue reading
Top officials from India and Mauritius will meet in Port Louis this week to discuss revival of free trade agreement (FTA) negotiations that were suspended three years ago by New Delhi. The talks were suspended to build pressure on Mauritius to expedite the double taxation avoidance agreement. Deliberations on two-way… – Continue reading
Israel has signed on as a member of the OECD’s international tax treaty, and as a result the Tax Authority will automatically receive information about bank accounts held by Israelis abroad. Israel, meanwhile, will automatically release information about foreign citizens who have bank accounts here to the governments of countries… – Continue reading
The Special Administrative Region yesterday signed a Tax Information Exchange Agreement (TIEA) with Ireland, according to an announcement by the Financial Services Bureau. The agreement was inked by the Secretary for Economy and Finance, Lionel Leong Vai Tac and Ireland’s Ambassador to China, Paul Kavanagh. According to the Secretary, the… – Continue reading
Pakistan and Switzerland would exchange information on tax evasion once the contracting state exhausts all regular sources of information available under the internal taxation procedure. On August 31, 2016, the Federal Cabinet approved initialed draft for revision of the Convention between Pakistan and Swiss Confederation for the avoidance of double… – Continue reading
Potential slice of the Apple pie stems from Commission’s invitation to EU tax authorities. BRATISLAVA — The €13 billion clawback of unpaid taxes from U.S. tech giant Apple has piqued the interests of EU finance ministers, who have today asked the European Commission for more details on the potential share… – Continue reading
MUMBAI: Foreign portfolio investors (FPIs) are lobbying the government to resolve problems related to the India-Singapore tax treaty and general anti-avoidance rules (GAAR), worried about their investment in equities. FPIs fear after April 1, 2017, when both the renegotiated India-Singapore treaty and GAAR come into force, they will face challenges…. – Continue reading
President Joko Widodo remarked that Indonesia supports the implementation of automatic exchange of financial information in tax matters between countries. This, he said, would lead to enhanced income for the developing countries. “Indonesia encourages an international tax system that is fair and transparent,” President Joko Widodo said in his speech… – Continue reading
The G20 summit in China has stressed the need for international tax cooperation to achieve ‘a globally fair and modern international tax system’, after US President Obama warned of the risks if countries ‘race to the bottom’ in tax policies At a press conference at the conclusion of the summit,… – Continue reading
European Union countries should better coordinate tax rules to avoid hitting corporations too hard, the Slovak presidency of the European Union has proposed. This would be an effort to provide more balance to an EU campaign against tax avoidance by multinational companies. The proposal will be discussed at an informal… – Continue reading
Officials said around 192 requests had been sent to a number of countries, while another dozen were being processed as part of their investigation. The Income Tax Department on Sunday said it had invoked several tax information treaties and made around 200 requests to collect banking- and finance-related evidence on… – Continue reading
After state aid inquiries into Amazon and McDonald’s, EU looks again at Luxembourg The European Commission may open a fresh investigation into tax rulings offered by Luxembourg as early as this week, as EU competition commissioner Margrethe Vestager continues her clampdown against corporate tax avoidance. Luxembourg is already awaiting a… – Continue reading
India and Vietnam on Saturday inked a dozen of agreements, including protocol on double taxation avoidance agreement, to foster better ties between the two sides. India and Vietnam on Saturday inked a dozen of agreements, including protocol on double taxation avoidance agreement, to foster better ties between the two sides…. – Continue reading
The issue of tax havens is inherently international in scope. As a result, the government can use tax agreements to fight tax avoidance schemes. Unfortunately, tax agreements haven’t been used for that purpose. On the contrary, they have facilitated the outflow of Canadian money to offshore financial centres, and have… – Continue reading
Turkmenistan and Germany signed an agreement on avoidance of double taxation with respect to income and property taxes in Berlin, the Turkmen Dovlet Habarlary(TDH) state news agency reported. According to the message, the signing ceremony took place as part of the two-day working visit of Turkmen President Gurbanguly Berdimuhamedov to… – Continue reading
Pakistan will sign Multilateral Convention on Mutual Administrative Assistance in Tax Matters with OECD on September 14 as the Federal Cabinet formally approved this on Wednesday. Minister for Finance Senator Muhammad Ishaq Dar termed the decision a historic one while briefing a crowded press conference regarding decisions of Federal Cabinet… – Continue reading
A coalition of Silicon Valley tech companies has urged the Dutch Government against making changes to the most “attractive” features of its corporate tax regime, warning that it risks damaging its traditionally strong tax competitiveness by doing so. The Silicon Valley Tax Directors Group (SVTDG), which includes more than 80… – Continue reading
Recent developments in the global business environment which are characterized by intense competition and rapid growth of multinational enterprises have led to new business models and structuring of business operations in order to meet the increasing demands of expansion on a global scale. Agency arrangements, as a way for enterprises… – Continue reading
Disclosures under the MAP are aimed at improving dispute resolution mechanism and are part of global initiative on base erosion and profit shifting. India will soon disclose the number of disputes being negotiated under the mutual agreement procedures (MAP) of tax treaties as well as details of the time being… – Continue reading
For the last three years, the international debate on tax policy was all about consensus. Led by the Organisation for Economic Co-operation and Development, countries across the globe agreed that aggressive tax planning by multinational corporations which pushed profits into low-tax countries – or indeed took profits outside the charge… – Continue reading
Under EU rules it is illegal for countries to give financial help to some companies and not others in a way that distorts fair competition, writes Liza Lovdahl Gormsen. State aid rules were originally designed to protect the internal EU market and avoid retaliation among member states. The US Treasury,… – Continue reading
The US has warned the EU that it risks damaging international agreements on tax reform if it continues to act as a “supra-national tax authority”. The US Treasury Department “shares the European Commission’s concern with tax avoidance by multinational firms. The international community, including the EU and its member states,… – Continue reading
Talks have begun between the US and Irish governments about updating certain elements of the Double Tax treaty between the two countries. The existing treaty was signed in 1997 and a Protocol to the treaty was signed in 1999. The Department of Finance and the Revenue Commissioners are calling for… – Continue reading
Trade relations between Singapore and Africa are set to deepen, with several agreements signed on Wednesday (Aug 24) at the fourth edition of the Africa Singapore Business Forum. These include the signing of the Avoidance of Double Taxation (DTA) with Ethiopia, a bilateral investment treaty (BIT) with Mozambique and an… – Continue reading
The Union Cabinet on Wednesday gave its nod for signing of revised double taxation avoidance agreement (DTAA) with Cyprus, a popular tax haven. It is also learnt to have approved the removal of island nation as a non-cooperative jurisdiction for income-tax purpose. Cyprus was the only country to have been… – Continue reading
Ireland has become a destination of choice for holding companies due to its capital gains participation exemption, generous foreign tax credit system, membership of the EU, ever expanding double tax treaty (“DTT“) network (72 signed, with 70 in effect), lack of controlled foreign companies legislation, thin capitalisation rules and the… – Continue reading
The OECD is consulting on the mechanics of dealing with branch mismatch structures under Base Erosion & Profit Shifting (BEPS) Action 2, designed to neutralise the effects of hybrid mismatch arrangements as part of the wider anti-avoidance action plan The BEPs project has already released a report on Action 2,… – Continue reading
THE OECD/G-20 Base Erosion and Profit Shifting (BEPS) Project is designed to provide solutions for governments to close the gaps in existing international rules that allow corporate profits to “disappear” or be artificially shifted to low or no tax environments, where companies have little or no economic activity. In February… – Continue reading
Switzerland has informed Italy of its desire to sign the bilateral agreement on the taxation of cross-border commuters. The point was made by Didier Burkhalter, the head of Switzerland’s Federal Department of Foreign Affairs, during a meeting with the Italian Foreign Minister, Paolo Gentiloni. They discussed bilateral issues, Switzerland’s policy… – Continue reading
Twenty of the nation’s largest companies have voluntarily signed up to a comprehensive new code to disclose more details of their tax affairs in their latest ¬annual accounts following a series of scandals involving local and offshore firms. In the May budget, the federal government announced it was committed to… – Continue reading
Private equity (PE) investors and venture capital (VC) funds from Mauritius will have to pay capital gains tax on investments into quasi-equity in India, under the revised tax treaty, unless the conversion of investments into equity is not finalised before 1 April 2017. The government has notified the revised double… – Continue reading
