Category: Tax treaties

FactCheck: Christie’s tax dodge

He has distorted the facts about the nation’s current tax system. Chris Christie repeatedly has said that U.S. corporations are taxed twice on income earned abroad, claiming in one speech that IRS officials “don’t recognize the tax you paid to a foreign country.” That’s false. It’s true that the U.S…. – Continue reading

Russian Federation: Russian De-Offshorisation Legislation And Voluntary Disclosure: Which Way Now?

The new law on the taxation of controlled foreign companies (the ‘CFC’ law) and other anti-offshore measures effective as of 1 January 2015 have raised a number of questions for clients and advisers. A number of changes to the new laws were long anticipated and have now been passed by… – Continue reading

China and Chile sign DTA

On May 24, Premier Li Keqiang and a delegation of Chinese senior officials arrived in Chile. During the visit, China and Chile signed a double taxation avoidance agreement (DTA), updated their Free Trade Agreement and agreed on setting up an RMB clearing center in Chile, reports China Briefing. China and… – Continue reading

Bermuda: Minister Richards examines global tax threats

Speaking at the Insurance Day 2015 Summit on 10 June 2015, Minister of Finance Bob Richards told attendees that “the more we drive home that the insurance sector in Bermuda is not a stereotypical tax haven gimmick to key onshore decision makers the less the threat from IRS and other… – Continue reading

G7 to Clamp Down on Tax Avoidance Via Transfer Pricing

Multinational firms said to be ‘cheating’ African countries out of billions of dollars that could be used for health care and education. G7 leaders Monday pledged to reform the international tax system by minimizing transfer pricing, according to Public Finance International. Transfer pricing involves internal transactions between a large company’s… – Continue reading

Update: key ruling affecting Maryland taxpayers with out-of-state income – tax refund opportunity now available

Maryland residents who pay income tax to other states may be entitled to a refund of local income taxes paid in prior tax years. The U.S. Supreme Court in Comptroller of the Treasury of Maryland v. Wynne et ux. recently affirmed a Maryland Court of Appeals ruling that the state’s… – Continue reading

G7 leaders move toward automatic exchange of tax information

Heads of state meeting at the G7 Summit in Bavaria, Germany committed to promoting automatic exchange of tax information and tax rulings to discourage multinational companies from shifting profits from country to country to avoid taxes, reports Accounting Today. In a joint declaration, the G7 leaders reaffirmed their commitment to… – Continue reading

Hong Kong needs to catch up with latest global tax standards

Hong Kong, as a world financial centre, will undertake legislative changes to implement automatic exchange of information of account holders Exchange of information is a recognised tool to enhance tax transparency and combat cross-border tax evasion. As a major financial centre, Hong Kong is committed to following global standards. While… – Continue reading

ETVEs (Spanish foreign-securities holding companies)

A special scheme is provided for foreign-securities holding companies or ETVEs (Entidades de Tenencia de Valores Extranjeros) in the Corporate Income Tax (“CIT”) Act 27/2014. ETVEs are regular limited liability companies (S.L., S.A. or other company forms), subject to the normal CIT on its income, but exempt from taxation on… – Continue reading

Recent Tax Treaty Developments In Cyprus

Proposed Amendments To Cyprus’s Assessment And Collection Of Taxes Law The Cyprus Government has published a draft law amending the Assessment and Collection of Taxes Law (Law 4 of 1978) in order to facilitate implementation of agreements for automatic exchange of information with other countries. When it is enacted, the… – Continue reading

Tax consequences of foreign companies rendering services in South Africa

Where a foreign company renders professional services to a South African company, it is important that the foreign entity considers whether, as a result of rendering such services, the foreign company will create a permanent establishment in South Africa. The reason why this becomes important is that where a foreign… – Continue reading

Govt aims at documentation of economy

ISLAMABAD: The government has proposed several provisions in the Finance Bill 2015 for documentation of economy. The bill empowers the government to obtain or render information related to transactions undertaken in and outside Pakistan regarding both resident and non-resident taxpayers. Legal cover has been provided to allow government to enter… – Continue reading

The New Rules of Offshore Accounts

Crucial deadlines are approaching for millions of U.S. taxpayers who live abroad or have offshore financial ties. For expatriates, the annual income-tax filing deadline is normally June 15, instead of April 15. In addition, all U.S. taxpayers with offshore accounts totaling more than $10,000 in 2014–regardless of where they live–have… – Continue reading

London based Investment Association, ASIFMA seeks to be party in Castleton case over MAT

MUMBAI: Two associations representing foreign portfolio investors are seeking to join the battle over minimum alternate tax in the Supreme Court, although analysts are unclear if entities without a tax treaty will benefit. Investment Association, based in London, and Hong Kong-based Asia Securities Industry & Financial Markets Association (ASIFMA) plan… – Continue reading

FATCA is an attack on Canadian sovereignty

Retired Canadian lawyer Ginny Hillis has a message for the U.S. Congress. “They have no rights over me. None.” Hillis detests the “arrogance” of Congress for “imposing their laws on a sovereign nation with the complicity of that sovereign nation’s government.” America’s Foreign Account Tax Compliance Act (FATCA) “should embarrass… – Continue reading

Preventing Double Taxation of Interstate Income: Supreme Court’s “Wynne” Decision is a Win for Taxpayers

In a five-to-four decision, the United States Supreme Court held that the dormant commerce clause protects in-state residents from the double taxation of their interstate income. This is a complicated decision and the margin favoring the taxpayers was razor-thin, one vote. The decision is complicated because the tax involved was… – Continue reading

Bonus shares: SECP suggests FBR to withdraw 5 percent tax, apply 12.5 percent CGT

The Securities and Exchange Commission of Pakistan (SECP) has proposed to the Federal Board of Revenue (FBR) to withdraw 5 percent tax on bonus shares and apply current capital gains tax (CGT) rate of 12.5 percent irrespective of its holding period. According to the budget proposals of the SECP received… – Continue reading

Accord to Avoid Double Taxation with Norway Now Before Bulgarian Parliament

Bulgaria’s government has proposed to parliament to ratify the agreement with Norway to avoid double taxation of income. The agreement was signed in July of last year to update the regulation framework governing the bilateral economic relations, the cabinet said in a statement on Wednesday. The previous agreement had been… – Continue reading

Income Tax return: No relief for Indian citizens with foreign assets

The Income Tax Department will retain the detailed questions on foreign assets and income of resident Indian citizens… The Income Tax Department will retain the detailed questions on foreign assets and income of resident Indian citizens in the revised tax return forms, to be issued shortly. The relaxation announced by… – Continue reading

Black money: Keep foreign information strictly secret, CBDT tells its officials

NEW DELHI: CBDT has issued fresh instructions to the taxman to ensure that information on individuals holding black money abroad is strictly kept secret as it stressed that any “careless” act could give an excuse to the data supplying country for not helping India in the future. “In many countries,… – Continue reading

Business group warns on offshore tax measures

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

United States: U.S. Treasury Department Releases Proposed Model Treaty Provisions

On May 20, 2015, the U.S. Treasury Department released for public comment draft updates to the U.S. model income tax convention and its accompanying Technical Explanation (collectively, the “Model Treaty”), which was last updated in 2006. The Model Treaty is the template that Treasury uses as its starting point in… – Continue reading

Asia: Tax & Trust Developments Taking Center Stage

Developments in Asia over the last year have been continuous with the biggest generic development relating to the exchange of information. Asian countries have put their FATCA reporting systems in place (even though not all have yet signed an inter-governmental agreement with the US IRS), and most have now committed… – Continue reading

Hong Kong: Will The Very Efforts Designed To End The Offshore Industry Finally Legitimise It?

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

French tax updates – recently published noteworthy publications

The present French Tax Update will focus on an overview of several noteworthy French tax court decisions issued during the past few months, in particular in relation with double tax treaty conditions to benefit from a tax credit, abuse of law challenges, increased amortization rates, and priority preliminary ruling requests… – Continue reading

New Argentina­Chile tax treaty creates fresh structuring opportunities

Argentina and Chile have signed a new double tax treaty to replace the treaty unilaterally terminated by Argentina in 2012. Ignacio Rodriguez and Andres Edelstein of PwC in Argentina outline the new structuring opportunities that are available for taxpayers. Argentina and Chile signed a new double tax treaty on May… – Continue reading

What Nigeria, Singapore stand to gain from investment promotion, protection pact –Ambassador Rajis-Opara

From today, negotiation on the Investment Promotion and Protection Agreement (IPPA) between Nigeria and Singapore will start in Abuja, aimed at enhancing business between the two countries. Revealing this in an interview with the African Independent Television (AIT), Nigerian High Commissioner to Singapore. Mrs. Nonye Rajis-Opara, said there would be… – Continue reading

Gibraltar Meets With New EU Tax Ruling Commitee

Gibraltar’s Chief Minister, Fabian Picardo, has met with the new TAXE committee of the European Parliament and defended the territory’s tax ruling regime. The TAXE Committee was established earlier this year in the wake of the leak of confidential tax rulings provided by EU member states to certain multinationals. The… – Continue reading

Switzerland, Italy Talk Tax Cooperation

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

After Switzerland, government talking to other havens

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

Tax Planning And Portugal’s Non Habitual Residence Scheme

Portugal can be a very attractive country to live in from a tax point of view. The inheritance tax regime is very benign here, and there is no wealth tax. Tax efficient arrangements can lower tax liabilities on your investment and pension income. And if you are a new resident,… – Continue reading

Oman: Taxpayers set to face more scrutiny

Muscat: Taxpayers across the globe, including Oman, are facing increased scrutiny of their tax returns and positions taken as the pressure on governments increases to raise revenues from taxes, says an expert at KPMG. Ashok Hariharan, partner and head of tax for KPMG in the Middle East and South Asia… – Continue reading