The UK Government launched a consultation on 22 October 2015 regarding the UK corporate tax rules for interest deductibility. The consultation seeks views on the design of a general limitation for UK corporation tax deductions for interest and similar finance costs, imposing a capcalculated by reference to a fixed percentage… – Continue reading
Eight tax treaties and protocols were passed forward for a ratification vote by the full US Senate at a business hearing of the Committee on Foreign Relations on November 10, reports Tax News. The Committee approved the new US double taxation agreements (DTAs) with Chile and Hungary, and protocols to… – Continue reading
Across the globe, base erosion and profit shifting (BEPS) is making headlines and drawing the attention of not only governments and tax authorities but also non-government organizations, activists, lobbyists and the general public. As the public debate has spread to the Gulf Cooperation Council (GCC) countries, the focus now centers… – Continue reading
On October 6, 2015 Poland and Sri Lanka concluded a new Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (Hereafter: the DTA). When entering into force this new DTA will replace the existing Double Taxation Agreement (stemming from 1980)… – Continue reading
The voluntary disclosure is passing under the banner of the last kilometer. By November 30, the games will be made. One can already say that the operation is a success announced. Order of Chartered Accountants of Milan has estimated that the transaction will derive from the tax authorities at least… – Continue reading
Currently 15,980 foreign companies are operating in Korea. While hiring workers and producing goods and services, foreign investors encounter numerous difficulties and experience a variety of grievances. One particular grievance brought to our attention is that they suffer from a discrepancy between the value of imported goods assessed by the… – Continue reading
Amazon, Facebook and Google in line of fire after committee backs proposals to force multinational corporations to pay tax where they make their sales MEPs have launched a scathing attack on Facebook, Google and Amazon in the European parliament, accusing them of diverting profits worth billions of pounds to low… – Continue reading
Once again, a possible corporate inversion is making headlines and once again, the Obama administration has proven it does not understand the real reason inversions occur. In response to news that pharmaceutical firms Pfizer and Allergan are in merger discussions, the Obama Treasury department has suggested it would do its… – Continue reading
On November 13, 2015 the UK HM Revenue & Customs (HMRC) published a policy paper setting out planned negotiations on Double Taxation Agreements (DTAs) and Tax Information Exchange Agreements (TIEAs). According to the policy paper HMRC will begin negotiations on double taxation agreements with: • Nepal • Romania • Trinidad… – Continue reading
Facts A Peruvian company (Company A) offered its services in Chile and had a commercial relationship with a Chilean company (Company B). Both companies were under shared ownership. The Tax Administration decided to assess withholding taxes for services that Company A rendered for Company B, as it considered the latter… – Continue reading
In the first step towards boosting trade and investment between the two nations, Australia and Germany have signed a new tax treaty in Berlin. It also marks an attempt to improve the integrity of the tax system by pinning down on multinational tax evasion. The deal, which preceded the arrival… – Continue reading
By the very criteria set in the United States by the Multistate Tax Commission (MTC), several states in the US are “tax havens”. But, they have not been named in the legislation passed by the legislatures of Oregon, Montana and others. Among the MTC criteria for determining a tax haven… – Continue reading
Jakarta (ANTARA News) – The government step to offer cuts on income tax for firms willing to revaluate their assets, as promised in its economic policy package, has received positive responses from many companies. Finance Minister Bambang Brodjonegoro is convinced that numerous companies have been interested in conducting asset revaluations… – Continue reading
Companies such as Apple, Starbucks, and Amazon are well known for legally using international law to their advantage when it comes to tax. Now a small Welsh town is mimicking their tactics. Independent traders in Crickhowell are moving their businesses “offshore” to avoid paying tax. The local businesses – including… – Continue reading
As at least the first phase of the OECD’s BEPS project1 wound down with the October release of the “final” BEPS deliverables, questions remained regarding how much of the recommended changes would be implemented in the United States in the near term. Because many of the recommendations require legislative changes… – Continue reading
The Senate Foreign Relations Committee has approved, for a second time, the following income tax treaties and Protocols. 12 November 2015 Switzerland: A Protocol to amend the income tax treaty with Switzerland—the Protocol was signed in 2009. Luxembourg: A Protocol to amend the income tax treaty with Luxembourg—the Protocol was… – Continue reading
The US Treasury Department released proposed revisions to the US Model Income Tax Treaty (the ‘Model Treaty’); the proposed changes are intended to combat treaty abuse and deny treaty benefits in certain situations. The revisions to the Model Treaty include: (i) changes to the Limitation on Benefits provision which most… – Continue reading
In a surprising development, the US Senate Committee on Foreign Relations on November 10 approved without amendment eight pending US tax treaties and protocols. Proposed income tax treaties with Chile, Hungary, and Poland; proposed tax protocols with Japan, Luxembourg, Spain, and Switzerland; and a proposed protocol amending the multilateral mutual… – Continue reading
The Swiss Federal Council has adopted a dispatch on a protocol to the double tax agreement (DTA) with Albania. The protocol was signed on September 9 and the dispatch was adopted on November 11. Its aim is to bring the DTA into line with Switzerland’s current policy on tax agreements…. – Continue reading
The final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) project were issued on 5 October (the “Reports”) after a two-year consultation period during which 62 countries and many other stakeholders (such as the World Bank, the IMF, and many trade associations) participated. These Reports, split into 15… – Continue reading
On September 16, 2015, the Australian government introduced into Parliament Tax Laws Amendment (Combating Multinational Tax Avoidance) Bill 2015, which contains, among other items (including the implementation of country-by-country reporting), the proposed legislative language to implement Australia’s version of the United Kingdom’s diverted profits tax. The bill was accompanied by… – Continue reading
Introduction On September 30 2015 Her Majesty’s Treasury published its long-awaited consultation on two of three proposed changes to the taxation of individuals domiciled outside the United Kingdom. The three measures – announced by Chancellor George Osborne in the 2015 Summer Budget published on July 8 – are intended to… – Continue reading
According to the Brazilian FM Mauro Vieira, the country is in talks for an agreement to avoid double taxation in air transport with Egypt. The Arab country plans on creating the route once the deal is in place. Riyadh – The Egyptian carrier EgyptAir could launch a route to Brazil,… – Continue reading
THE world appears to be getting much smaller. Rapid technological advances, increased people mobility, and changes in the international political climate have all helped to break down many of the traditional barriers to global and regional trade. For dynamic, fast-growing businesses, this increased globalisation represents an excellent opportunity for businesses… – Continue reading
On November 3-4, 2015, more than 260 senior tax officials from 102 jurisdictions and international organizations met to discuss the tax treaty-related outcomes of the OECD’s base erosion and profit shifting project. Participants at the 20th Annual Global Forum on Tax Treaties welcomed the tax treaty-related measures agreed upon in… – Continue reading
On November 11, 2015 in the Dutch Staatscourant a Decree from the Dutch State Secretary for Finance containing an approval regarding an adjustment period for Advance Tax Rulings (ATRs) that will expire as a consequence of the entry into force of the Wet implementatie wijzigingen Moeder-dochterrichtlijn 2015 (Law implementing the… – Continue reading
Riyadh, Muharram 29, 1437, Nov 11, 2015, SPA — Dr. Ibrahim bin Abdulaziz Al-Assaf, Minister of Finance, signed here today an agreement of avoidance of double taxation and prevention of tax evasion with respect to taxes on income with Venezuelan Minister of People’s Power for Economy and Finance Rodolfo Marco… – Continue reading
The Caribbean island says its financial system is all aboveboard, yet it remains a gateway to less scrupulous offshore havens like the Cayman Islands. BRIDGETOWN — Is there “dirty” money strewn across the pristine sands of Barbados? Does something sinister hide beneath the glistening coral reefs of this former pirate… – Continue reading
Double Taxation Treaty Network UK’s Key Strength in Attracting Tax- Transparent Funds LONDON, Nov 11, 2015 (BUSINESS WIRE) — The value of UK Authorised Contractual Scheme (ACS) funds under management in the UK is likely to exceed GBP250 billion by 2017, according to a Northern Trust survey of UK based… – Continue reading
As the status of professional athletes is not regulated under Czech law, there is a need for legal interpretation on this matter. The Supreme Administrative Court has ruled that athletes’ work is of such a specific nature (e.g. the method of their pay, the amount of rest and other non-compliances… – Continue reading
The implementation of the Foreign Account Tax Compliant Act is showing consistent progress with thousands of banks in over 150 countries agreeing to share financial accounts data of their US clientele with US taxation authorities. This clearly indicates the firm resolve of the US administration to make this initiative a… – Continue reading
Presidency sent to Congress ratification of treaties with Jersey, Guernsey, the Cayman Islands and Uruguay; text follows the G20 guidelines The Presidency referred for evaluation of Congress four agreements for the exchange of tax information (TIEA, which stands for the English term “Tax Information Exchange Agreement”) entered into with Uruguay,… – Continue reading
Mexico and Argentina have signed an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital. The agreement allocates taxing rights to the two countries, to avoid taxation being levied twice on the same income from companies and individuals… – Continue reading
The New Zealand foreign trust regime – its use in international wealth planning The New Zealand “foreign trust” regime came into being over 25 years ago. It arose from a domestic initiative to make the use of offshore trusts for tax minimisation more difficult for New Zealand residents, by imposing… – Continue reading
To increase the scope of income tax laws, GCC countries are pursuing tax determinations with significantly broader interpretations of activities or actions that constitute doing business in-country. New concepts like Virtual Service Permanent Establishment and dependent agents are being used in Saudi Arabia and Kuwait to determine taxable presence or… – Continue reading
Key Points: The rejection of the Commissioner’s position on the relevance of credit rating agencies and the relevance of implicit support will give rise to uncertainty going forward, as it is unclear how an arm’s length interest rate can be practically determined. The Federal Court’s recent decision in Chevron Australia… – Continue reading
Moscow. November 10. The Finance Ministry has prepared proposals aimed to strengthen Amnesty of capital, which is now actually fails, reports the newspaper “Kommersant”. The law on the voluntary Declaration by individuals of assets and accounts, is known as the law on the legalization or Amnesty of capital, earned from… – Continue reading
A paradigm shift in the way business is conducted is taking place as new base erosion of profit shifting (BEPS) rules are aligned with tax systems, but more tax certainty and rules that suit specific African circumstances are needed, a Deloitte OECD Transfer Pricing Guidelines seminar heard on Wednesday, 04… – Continue reading
While proponents of the base erosion and profit shifting project claim it will facilitate appropriate taxing of global corporate profits, enforcement remains the elephant in the room, writes FX-MM’s Paul Golden. In October, the OECD presented the final package of measures for reform of international tax rules, stating that annual… – Continue reading
In February we wrote about a discussion draft of Action 6 of the Action Plan on Base Erosion (BEPS Action Plan) developed by the Organisation for Economic Co-Operation and Development (OECD) at the request of the G20. In October, the OECD published its final report on Action 6 of the… – Continue reading
Article by Patrick W Martin and Ashley Fife With a net worth of USD77.1 billion, Mexican telecoms businessman Carlos Slim Helú was ranked the second richest person in the world in a 2015 survey.1 At the end of 2014, 16 of Mexico’s citizens were on Forbes’ billionaires list.2 As for… – Continue reading
The dramatic expansion of international trade and development of new business strategies due to globalisation, converted the world into a large global market. In connection with that, companies have been using complex networks of subsidiaries and branches (e.g. permanent establishments) in order to continue most of their operations. The Multinational… – Continue reading
The BMF has application letter sent to the chief financial authorities of the countries associated with the between the Federal Republic of Germany and the United States of America concluded by 31.5.2013 FATCA Agreement. Background Background of extensive, comprehensive 71 pages, application letter from the Federal Ministry of Finance on… – Continue reading
NEW YORK, Nov. 9, 2015 /PRNewswire/ — Business executives cited an increased compliance burden as their biggest concern with the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting initiative (37.7 percent), according to an October Deloitte poll. Other concerns included double taxation of income (17 percent) and… – Continue reading
Transfer pricing by multinationals has cost South Africa an estimated R250 billion over three years and, with it, lost tax revenue. This is according to Sunia Manik, group executive for the large business centre at the SA Revenue Service (Sars), adding that it was being done through “service payments” made… – Continue reading
x The Kenya Revenue Authority (KRA) has slapped higher taxes on importers of second-hand vehicles ahead of a new duty that will push the prices up by Sh200,000. The revenue authority reviewed the current retail selling price of second-hand vehicles in October 15. This is the benchmark the taxman uses… – Continue reading
NEW DELHI: Dismissing apprehensions of Mauritius being used to route black money as “misconception”, its Prime Minister Anerood Jugnauth has termed the issue as an aberration in the “very special” ties with India and hoped that revision of their tax treaty won’t harm its interests. Stating that Prime Minister Narendra… – Continue reading
Small and medium-sized businesses that don’t have the resources to patent intellectual property may still be able to benefit from the Knowledge Development Box (KDP) under plans being considered by the Government. The Department of Finance is looking at allowing SMEs with patentable assets, but without the resources to get… – Continue reading
The South African Revenue Service (SARS) has issued an interpretation note to provide guidance on the term “place of effective management” for the purposes of determining the tax residence of a company in South Africa. SARS notes that, in general, a resident is liable to income tax on gross income… – Continue reading
The Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting action plan is likely to have a major impact on tax planning at multinational corporations by both tax professionals and corporate treasurers. Tom Driscoll, U.S. managing partner for international tax, transfer pricing, and indirect tax at Deloitte Tax… – Continue reading
