The Organisation for Economic Cooperation and Development (OECD) – the leading international standards-setter for tax transparency and cooperation – has underlined Guernsey’s reputation as a cooperative jurisdiction, reports Guernsey Finance. Monica Bhatia, Head of the Secretariat of the OECD Global Forum on Transparency and Exchange of Information for Tax Purposes… – Continue reading
Royal Decree No. 26/2015 ratifies the Agreement on Delimitation of Maritime Boundaries (Borders) in Sea of Oman between the Sultanate of Oman and the Islamic Republic of Iran, signed in Muscat on May 26, 2015. Article (1) ratifies the above-mentioned Agreement. Article (2) states that this Decree shall be published… – Continue reading
Ukraine’s Cabinet of Ministers will remove Austria from the list of countries transactions with whose counterparties are subject to control under the law on transfer pricing on August 1, 2015. This is stipulated in Cabinet resolution No. 677 dated July 1, 2015, which is available on the government website on… – Continue reading
The business community has criticized the imposition of withholding tax on transactions over Rs 50,000 and urged the government to withdraw this immediately. They also warned if the government and FBR didn’t accept their demand, would compel to take extreme steps, even go for strike and launch protest campaign against… – Continue reading
Kenyans in the US will be protected from double taxation, the Kenyan ambassador to the US, Robinson Githae, has said. Mr Githae said he understood the concerns of Kenyans in the US after a provision of a federal law requiring US citizens and permanent residents (green card holders) to report… – Continue reading
Chancellor George Osborne needs to carry out an “ambitious” tax reform agenda in his Budget on Wednesday, the Institute of Directors (IoD) has said, reports the BBC News. Simplifying the “painfully complex” tax system would allow him to “deliver an investment-boosting Budget”, said IoD director Simon Walker. In May, a… – Continue reading
Taxes covered The agreement applies to taxes on income imposed by either country. In Bahrain these are currently the income tax payable under Legislative Decree No. 22/1979 (“the Oil Tax”); in Cyprus they are income tax, corporate income tax, Special Contribution for Defence (known as SDC tax) and capital gains… – Continue reading
Access to company data is vital if policymakers are to understand how changing regulatory requirements influence performance Much focus has recently fallen on the issue of tax avoidance, as research on the subject has increasingly shown that the global economy is losing out on billions of dollars to a byzantine… – Continue reading
Hong Kong (HKSAR) – The agreement constituted by the exchange of notes between Hong Kong and Japan regarding the Exchange of Information Article of the Comprehensive Avoidance of Double Taxation Agreement between the two jurisdictions has entered into force, a government spokesman said today (July 6). The notes were exchanged… – Continue reading
The taxable income might now be visibly de-linked from the accounting income Historically, enterprises have computed taxable income applying profits as per the financial statements as the starting point and making additions or deductions thereto, as required by the Income-tax Act. 1961 (I-T Act) for the purposes of annual income… – Continue reading
Calcutta, July 5: Singapore and Hong Kong, with their low corporate tax rates, have started to hove into view on the radars of multinational companies that are looking to lower their tax burdens through profit shifting. Profit shifting is a perfectly legal way of moving the earnings of an MNC… – Continue reading
The MoU is designed to give some insight into the process that will be adopted by the fiscal authorities of the two countries when assessing the tax residence of a ‘person’. International investors including South African businesses already use Mauritius as their base for their growth on the continent, but… – Continue reading
KARACHI: The Karachi Stock Exchange (KSE) Stockbrokers Association has lashed out at the Federal Board of Revenue (FBR) for causing ‘great anxiety’ among compliant taxpayers. In a statement issued on Friday, the association said the FBR has been sending show-cause notices and orders to members of the KSE, asking them… – Continue reading
MUMBAI: The Central Board of Direct Taxes has signed a taxation rate agreement with BNP Paribas India Solutions, the local arm of the European bank, as part of efforts to reduce disputes with foreign companies over tax-related issues. BNP Paribas Solutions is the first company in the information technology and… – Continue reading
ARBADOS’ CONTROVERSIAL BLACKLISTING by a group of European Union (EU) countries is “hypocritical” and “grossly discriminatory”, says outgoing Barbados International Business Association (BIBA) president Connie Smith. But Smith also thinks the time is right for “engaging in bilateral discussions which could hopefully conclude in double taxation agreements and bilateral investment… – Continue reading
The Ethiopian Investment Commission and Center for the Promotion of Investments in Cŏte ďIvoire (CEPICI) signed a Memorandum of Understanding (MoU) which would serve as a guideline to augment commercial exchanges,implement joint investment projects and boost economic cooperation among others, between the two countries. Speaking at Ethio-Ivorian Business and Investment… – Continue reading
New Zealand-Canada double tax agreement to help investors WELLINGTON, July 2 (Xinhua) — A new double tax agreement between New Zealand and Canada is set to facilitate investment and trade between the two nations, Revenue Minister Todd McClay said Thursday. The new agreement will lower withholding taxes on dividends, interest… – Continue reading
In an unexpected decision, the United Kingdom Supreme Court has held in Anson v Commissioners for Her Majesty’s Revenue & Customs [2015] UKSC 144 that a UK member of a Delaware limited liability company (“LLC”) was entitled to relief under the UK/US double taxation treaty (the “Treaty”) for United States… – Continue reading
Mauritius and India have reached consensus in the conclusion of the Double Taxation Avoidance Agreement (DTAA) which has been long awaited between the two countries following fruitful discussions yesterday between joint working groups of Mauritius and India, reports All Africa. The positive conclusion of the negotiations will open a new… – Continue reading
Washington, DC—(ENEWSPF)—July 2, 2015. The Department of Justice announced today that Privatbank Von Graffenried AG has reached a resolution under the department’s Swiss Bank The Swiss Bank Program, which was announced on Aug. 29, 2013, provides a path for Swiss banks to resolve potential criminal liabilities in the United States…. – Continue reading
Apart from placing full time expatriate employees in China, as an investor you may often need to send staff from the parent company to China to complete temporary projects. Common examples include quality control, engineering projects, training or consultancy. However, what many foreign investors don’t know is that such visits… – Continue reading
New York State is increasingly reliant on China as a consumer of services and manufactured goods. In 2014, New York exported approximately US$4 billion to China, making it the state’s sixth largest export market. The top five exports to China are transportation equipment, waste & scrap, machinery (except electrical), primary… – Continue reading
OECD and G20 Action Plan on Base Erosion and Profit Shifting (BEPS) was adopted in 2013. It consists of 15 actions including transfer pricing, taxation of controlled foreign corporations (CFC), digital commerce, hybrid instruments, international information exchange, tax treaty shopping etc. In 2013, OECD working group prepared draft documents regarding… – Continue reading
Action 3 of the OECD’s Base Erosion and Profit Shifting (BEPS) agenda promised to address how countries could use controlled foreign corporation (CFC) rules to combat BEPS. Unfortunately (or fortunately, depending upon one’s vantage point), as is pretty much universally agreed, the OECD’s draft report on CFC rules (the “draft”)1… – Continue reading
The German government has announced plans to incorporate Action 13 (guidance on transfer pricing documentation and country¬by¬country (CbC) reporting) of the OECD’s BEPS project into local legislation. The wording of the new law is being drafted and may be published some time in autumn of this year. It is the… – Continue reading
A private equity executive won his five-year legal battle with U.K. authorities to stop his fees from managing venture capital funds being taxed twice. George Anson, who has worked at Boston-based HarbourVest Partners for 25 years, faced a 67 pence levy on every pound earned from a Delaware company between… – Continue reading
OECD common reporting standard On 3 June 2015, the Treasurer announced that Australia had signed the Organisation for Economic Co-operation and Development’s (OECD) common reporting standard (CRS) Multilateral Competent Authority Agreement which enables automatic exchange of CRS information between countries. Australia proposes to implement the CRS from 1 January 2017,… – Continue reading
“There is much to be gained from the existing double taxation treaty between Trinidad and Tobago and the Kingdom of Spain,” said Spanish Secretary of State for International Co-operation and Latin America Jesús Gracia Aldaz in his address at the First T&T–Spain Partnership Forum at the Hyatt Regency in Port-of-Spain…. – Continue reading
Vaduz (ots / IR) – The government has decided in your meeting of 30 June 2015 to open negotiations on a double taxation agreement with the Principality of Monaco. As a basis for understanding the OECD Model Convention serves. The agreement should also include a clause on exchange of information… – Continue reading
1. Permanent Establishment 1.1. Subjects and activities that generate a PE Article 64 of the LISH provides that a PE is created whenever ever a resident abroad for tax purposes carries on with activities under the LH in Mexican territory or the exclusive economic zone over which Mexico has jurisdiction…. – Continue reading
A common mistake when analyzing the tax implications of a cross border transaction is to jump too quickly to the ramifications of a tax treaty without first having a clear handle on the tax implications under the Income Tax Act (Canada) (“ITA”). A related issue is that even though a… – Continue reading
We consider the retirement options for three top expat destinations – New Zealand, Bahrain and Singapore Retiring overseas is an aspiration for many expats, especially after they have spent much of their working life outside the UK. But while you may think you know what’s involved, there are many things… – Continue reading
The accusation that Hong Kong is a tax haven is unfounded and unfair, says Secretary for Financial Services and the Treasury Ceajer Chan Ka-keung. Chan wrote in his blog that the European Commission should review its inclusion of Hong Kong in the list of non- cooperative tax jurisdictions in mid-June…. – Continue reading
When it comes to the topic of offshore corporations, some people immediately think of illegal tax shelters, but that is not the case. Currently, the IRS is working tirelessly to track down U.S. citizens and residents with unreported offshore income or assets and the new FATCA regulations make it virtually… – Continue reading
The US Administration has put more of its hoped-for, but perhaps poltically difficult, tax reforms into the Fact Sheet that was issued after the 2015 United States-China Strategic and Economic Dialogue held in Washington on June 23-24. In the 2014 Fact Sheet, the Administration had merely stated that it was… – Continue reading
The UK’s Supreme Court has ruled that a KPMG scheme to enable dealer group Pendragon to recover VAT on demonstrator cars sold as used cars was “abusive” of the law. Its decision earlier this month has overturned a previous Court of Appeal ruling on the scheme, which Pendragon used on… – Continue reading
The Policy and Advocacy Manager of Tax Justice Network – Africa (TJN-A) has urged African governments to review tax incentives for free zone companies. “Tax incentives must apply to companies that have something to show. These companies must be able to create massive employment and other services to benefit the… – Continue reading
NEW DELHI: Anecdotes about the first Income Tax searches in the T-20 IPL cricket tournament and a letter by former Finance Minister P Chidambaram seeking information about alleged illegal accounts by Indians in Switzerland find place in a new book on black money. The recently launched book “It’s Raining Black!… – Continue reading
India and Thailand will sign a double taxation treaty and an MoU for setting up an Ayurveda Chair in one of the Thai Universities during the three-day visit of External Affairs Minister Sushma Swaraj beginning on Saturday. The Minister will be the guest of honour on Sunday at the inaugural… – Continue reading
NEW DELHI, India – Tanzanian President Jakaya Kikwete was recently in New Delhi at the invitation of Indian investors and to drum up more foreign investment for his country The interactive session was attended by several hundred businesspeople and organised by the Confederation of Indian Industries (CII). Kikwete said although… – Continue reading
NEW DELHI: Anecdotes about the first Income Tax searches in the T-20 IPL cricket tournament and a letter by former Finance Minister P Chidambaram seeking information about alleged illegal accounts by Indians in Switzerland find place in a new book on black money. The recently launched book “It’s Raining Black!… – Continue reading
MUMBAI: India 0 Vs Pakistan 1. It’s not the outcome of a ODI series between the traditional rivals but a progress card on reforms in the world of real estate. At a time Indian realtors and investors are struggling to roll out real estate investment trusts (REIT) amid regulatory complications… – Continue reading
A new treaty makes it more difficult for companies to take advantage of tax loopholes to avoid their financial obligations. Globally, initiatives are afoot to close tax loopholes and South Africa is one of the frontrunners – its new treaty with Mauritius removes the allure for tax-shy corporates doing business… – Continue reading
Ethiopia and Brazil concluded an agreement for the avoidance of double taxation on profits derived from international air and shipping transport on June 22, 2015 in Brasilia, according to Fana Broadcasting corporate. H.E Ambassador Sinknesh Ejigu, Special Envoy, Ambassador Extra ordinary and plenipotentiary of the Federal Democratic Republic of Ethiopian… – Continue reading
Qatar’s Emir, HH Sheikh Tamim bin Hamad Al Thani, ratified a draft agreement on avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income between Qatar and South Africa as well as its attached draft protocol, which were signed in Pretoria on March 6, 2015…. – Continue reading
ICC has welcomed a new World Customs Organization’s (WCO) Guide to Customs Valuation and Transfer Pricing which includes ICC proposals for more coherent tax and customs revenue collection. Released this week as part of a new WCO Revenue Package, the new guide provides concrete guidance on revenue collection to governments… – Continue reading
Taiwan and China might sign an agreement on the avoidance of double taxation later this year, the Ministry of Finance said yesterday. “Technical issues” led to a breakdown in negotiations in 2009 on such a pact, which could significantly lighten the tax burdens on companies and Taiwanese doing business across… – Continue reading
YEREVAN. – Armenia has renewed a treaty to exempt double taxation with Belarus during the Cabinet’s meeting on Thursday. In particular, the treaty envisages regulation of the residency of legal entities in the case of dual residency. The procedure for the exchange of information constituting bank secrecy has been specified…. – Continue reading
The biggest hurdle to stopping multinational tax evasion isn’t the companies themselves. It’s the governments behind them. As the OECD works swiftly on its plan to stop multinational tax evasion, the United States has already signalled it’s not happy with what’s being proposed. The US has always been clear on… – Continue reading
The verities of international tax law are no more. The days of strong residence-based rules of corporate taxation are numbered. The age of the Permanent Establishment (“PE”) as the central concept of international tax is drawing to a close. That seems to be the message from the OECD International Tax… – Continue reading
