The UK’s First-Tier Tribunal has ruled in favor of HM Revenue and Customs in a case involving a “rate-booster” tax avoidance structure. The FTT found that the scheme used by Next Brand Ltd (part of the Next group) artificially moved money around the group with the aim of claiming tax… – Continue reading
It’s been called mysterious, secretive, and shadowy, but when it comes to the so-called shell company created by former president Bill Clinton as a vehicle for the delivery of consulting services, there’s a whole lot less there than meets the eye. According to the Associated Press, in 2008, Clinton set… – Continue reading
Investments Derived From Structural Reforms The approved structural Reforms are an unprecedented opportunity for a transformational economic growth in Mexico, being the most relevant from an investment point of view the reforms related to Energy, Telecommunications and Antitrust, which have put Mexico in the radar of Multinational companies seeking to… – Continue reading
ISLAMABAD: An investment exhibition, inviting the crème de la crème of society to put their money in real estate opportunities in the Middle East, does not sound like the kind of place the government may want to raid. But the Federal Board of Revenue (FBR) – which has been worried… – Continue reading
Research shows corporation tax receipts from banks are lower than before crisis despite global tax payments staying constant Britain’s banks are paying far less in corporation tax to the Exchequer than before the crisis, despite their profits improving and global tax payments staying constant. Research from Cambridge Judge Business School… – Continue reading
A state-run United Arab Emirates (UAE) company and its Dutch subsidiary filed a request for arbitration Thursday, seeking compensation from the Korean government over taxation worth US$170 million five years ago, a civic group said Friday, reports the Korea Times. The Lawyers for a Democratic Society said the Abu Dhabi-based… – Continue reading
The objectives of the Southern African Development Community (SADC) Protocol on Finance and Investment include enhancing the productive capacity of the economies in the region and thereby increasing trade opportunities to eventually alleviate poverty. To achieve the objectives, various strategies can be employed, including, among others, improving the investment regime,… – Continue reading
Many states in our nation suffer the effects of over-taxation. Whether it’s high state income taxes pushing families to seek brighter economic climates or high corporate taxes compelling businesses to relocate their headquarters, taxes play a huge role in how state economies function. One of the most contentious and potentially… – Continue reading
As wealthy foreigners rush to get citizenship in Malta under a new programme, the residency requirement is taking many forms. Russians rent high-end villas, then stay in five-star hotels when they visit. An American financier plans to live in Switzerland but occasionally vacation in Malta. One Vietnamese businessman, eager to… – Continue reading
On May 20, 2015, the US Department of the Treasury released for public comment draft updates to the US Model Income Tax Convention, including provisions to deny treaty benefits to companies that change their tax residence via inversion transactions. The Treasury said other changes are intended to ensure that the… – Continue reading
Santiago de Chile, May 25 (Prensa Latina) Chile and China will sign several cooperation and trade agreements today in a ceremony at La Moneda Palace, in the presence of Chilean President Michelle Bachelet and Chinese Prime Minister Li Keqian. Li, who arrived in this capital yesterday afternoon, held a meeting… – Continue reading
On 22 May 2015, Switzerland and Oman signed an Income Tax Treaty. The treaty will come into force after the two countries exchange ratification instruments. The provisions of the treaty will have effect from 1 January of the calendar year next following that in which the agreement enters into force…. – Continue reading
PUTRAJAYA: Malaysia and Slovak today signed a protocol agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, here. The agreement was signed by Foreign Minister Datuk Seri Anifah Aman and Slovak Republic’s Deputy Prime Minister Miroslav Lajčák in conjuction with… – Continue reading
On May 18, the Supreme Court decided a Maryland case involving double taxation. Maryland’s tax code does not give full credit to residents who also pay taxes in states where they work. The Court sided with the taxpayers, and the decision may cost some states and cities millions of dollars…. – Continue reading
Hanocal Holdings, a Dutch subsidiary of the Abu Dhabi-based International Petroleum Investment Company, has filed a lawsuit against the South Korean government through the World Bank’s International Center for Settlement of Investment Disputes. This is the second time that Korea is facing international arbitration under the “investor-state dispute settlement” process…. – Continue reading
The Armenian National Committee of America has welcomed the signing of the US-Armenia Trade and Investment Framework Agreement (TIFA) but has said that a renegotiated double tax agreement is a priority in order to fully realize the two nations’ bilateral trade and investment potential, reports Tax News. The TIFA was… – Continue reading
Belgium and the Russian Federation announced in March 2007 that they would negotiate a new double tax treaty (the “Treaty”). Nearly seven years after discussions began on 20 November 2008, the Treaty was finally signed on 19 May 2015 in Brussels. This newsflash is based on an unofficial version of… – Continue reading
Located along the Northeast corridor of the United States, Rhode Island is a mere 180 miles from New York City. The small coastal state is known for its knowledge economy based on its elite universities and hospitals. In 2013, Rhode Island’s GDP was US$53.2 billion. The largest contributor to the… – Continue reading
The UK’s introduction of the diverted profits tax (DPT) has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) and in effect as of April 1, the DPT seemed intended to appease public anger at multinationals failing to pay their ”fair… – Continue reading
To staff their board of directors with the best and most diverse talent, multinational companies commonly elect boards with international representation. It is also common for companies to convene periodic board meetings outside the United States. This may be done, for example, to provide board members with an opportunity to… – Continue reading
Tax Treaty Details Become Available The details of the Income Tax Treaty between Mauritius and the Republic of Congo have become available. The treaty will come into force after the two countries exchange ratification instruments. The provisions of the treaty will have effect from 1 January of the calendar year… – Continue reading
Details of new Tax treaty Become Available The details of the new Income Tax Treaty between Netherlands and Germany have become available following its ratification by Netherlands on 15 May 2015. The new treaty was signed on 12 April 2012. Once in force and effective, the new treaty will replace… – Continue reading
The Treasury Department announced draft changes for the U.S. Model Income Tax Treaty — the baseline text used by the Treasury Department when it negotiates tax treaties. The current U.S. Model was last updated in 2006. The proposed changes in the draft provisions are intended to combat so-called Base Erosion… – Continue reading
President His Highness Sheikh Khalifa Bin Zayed Al Nahyan has issued a number of federal decrees ratifying a number of agreements concluded with the governments of friendly countries. The decrees have been published in the recent issue of the federal official gazette, reports the Gulf Today. Sheikh Khalifa issued Federal… – Continue reading
Georgia and Poland held negotiations in Warsaw this week over an agreement on avoiding double taxation on income and capital. At the bilateral meeting the sides initialed the renewal agreement, which is based on the OECD Model Convention 2014 and envisages the introduction of new standards of cooperation in taxation… – Continue reading
German tax law allows deferring the tax on certain disposal gains by transferring the hidden reserves in the disposed assets to similar newly acquired or newly produced assets (“Replacement Assets”). The tax deferral requires an allocation of the Replacement Assets to a German permanent establishment. The ECJ has recently ruled… – Continue reading
Egyptian tax on shares sold by non-residents In 2014, the Egyptian Income Tax law was changed to introduce a 10% Egyptian tax charge on the net gain realised on a disposal of shares in an Egyptian company. This tax charge is intended to apply to non-resident as well as resident… – Continue reading
BEIJING, May 21 (Xinhua) — China has signed agreements with 99 countries to avoid goods being taxed twice as they cross borders in order to benefit more domestic enterprises going global, said a senior taxation official on Thursday. Wang Wenqin, deputy director of the State Administration of Taxation’s international tax… – Continue reading
India has amended section 6 of the Income Tax Act to introduce place of effective management (POEM) as the test to determine the place of residence of companies in the country. The change was included Finance Act, 2015, which received the President’s assent on May 12, 2015. The change will… – Continue reading
Introduction Tax avoidance, however legitimate its mechanism, has become the new focus for public opprobrium in parts of the world. High-profile cases and media attention examining the tax strategies of major global companies operating primarily in the digital economy have all contributed to this shift of focus. How are the… – Continue reading
INTRODUCTION On May 5, 2015 the Swiss Federal Supreme Court held a public hearing about two cases relating to the reclaim of Swiss withholding tax (WHT) in connection with arbitrage cases and issued its long awaited decisions. Two Danish banks issued the question on treaty entitlement for the refund of… – Continue reading
A proposal to bar insurers from claiming a tax deduction for premiums ceded to offshore affiliates would cost the U.S. economy $1.35 billion in gross domestic product, with private sector losses estimated to run roughly four times as great as the tax revenues raised, according to a new report from… – Continue reading
The IRS’s scrutiny of tax avoidance in offshore locations has discouraged bidders from taking over reinsurers, potentially reducing the companies’ value. Montpelier Re Holdings Ltd. and Platinum Underwriters Holdings Ltd., both based in Bermuda, have each said in recent regulatory filings that potential suitors backed away last year because of… – Continue reading
(Special) — The recent slump in oil prices is causing many Canadian investors to move their money from energy-weighted markets at home to foreign markets for better yields. While this may be a profitable investment strategy, it also can create its own set of problems because many investors may not… – Continue reading
Ahead of their joint event on Deoffshorisation Compliance on 21 May, TMF Group’s Sub Regional Director for CIS and the Nordics Alex Medlock and Artem Toropov, Senior International Tax Associate at law firm Goltsblat BLP LLP (the Russian practice of Berwin Leighton Paisner), outline the key deoffshorisation/CFC compliance requirements and… – Continue reading
Maryland’s taxation policy violated the U.S. Constitution by taxing income that state residents earned in other states, the U.S. Supreme Court ruled on Monday. The nation’s apex said the state’s controversial policy imposed form of double taxation on residents. The court in its ruling said Maryland cannot impose form of… – Continue reading
Ruling opens door for HM Revenue & Customs (HMRC) to recoup losses from other firms which used rate-booster schemes High street retailer Next has been hit with a £22.4m tax bill after a court found that it diverted profits made in the UK to offshore havens to avoid paying tax…. – Continue reading
In 1934, a distinguished American jurist, Judge Learned Hand, famously opined that “one may so arrange his affairs so that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to… – Continue reading
In July 1997, Tyco International (with then Wall St darling Dennis Kozlowski at the helm) was “acquired” by a relatively small provider of home security services, known as ADT Inc. The deal arguably exploited some strategic synergies between the two companies, but far and away the biggest benefit to Tyco… – Continue reading
Georgia’s freshman Senator David Perdue is a big advocate of the Fair Tax – a proposal long linked to the Peach State that calls for replacing federal income taxes with a national sales tax on all goods and services. Perdue talked up the plan in the GOP primary and general… – Continue reading
THE BJP-led National Democratic Alliance government, which had made a lot of noise about black money and the illegal stashing of funds abroad in the run-up to general elections last year, finally got down to some serious work to tax ill-gotten wealth and curb its growth. Last week, the government… – Continue reading
NEW DELHI: The Justice Shah Committee, constituted to go into levy of MAT on FIIs, will look into all important “legacy” cases, Finance Minister Arun Jaitley said blaming conflicting judicial rulings for the controversy on the issue that has riled foreign investors. He also said that foreign investors had invited… – Continue reading
Tuesday, June 30th is the filing due date for the Report of Foreign Bank and Financial Accounts, known as the “FBAR.” A “U.S. person” is required to file an FBAR if: (1) the U.S. person has a financial interest in, or signature authority over, at least one financial account located… – Continue reading
This note is intended as an introduction to inheritance tax (IHT) issues that need to be covered where a “non-dom” (an individual domiciled outside the UK) is planning on becoming resident in, or is already resident in, the UK. It should be emphasised that this is a complex subject, and… – Continue reading
The I-T dept has received over 500 applications from MNCs for signing APAs. Income-tax department has set a target of 50 advance pricing agreements (APAs) to be sealed with multinational companies in the current fiscal that will exempt cross-border transactions by these firms from rigorous auditing to check income suppression…. – Continue reading
Smartly setting up trusts requires knowledge of state tax laws, not just federal rules. Consider Robert L. McNeil, a chemist and onetime Pennsylvania resident who amassed a fortune as the business brain behind Tylenol. McNeil established trusts for his family but chose to locate them in Delaware, for tax purposes…. – Continue reading
Following on from a press release issued by the Treasurer on May 11th, the government has released a draft bill containing a new limb to the general anti-avoidance provision, which is directed at foreign multinational groups who have global revenue exceeding $1 billion. The law will apply where: • the… – Continue reading
YEREVAN, 15 MAY, ARMENPRESS. On May 15, Minister of Foreign Affairs of the Republic of Armenia Edward Nalbandyan, who is on a working visit to Bratislava, met with Deputy Prime Minister of Slovakia, Minister of Foreign and European Affairs Miroslav Lajčák. As the Department of Press, Information and Public Relations… – Continue reading
The minimum alternate tax row has damaged the credibility of government promises to enforce an investor-friendly tax regime and made the Indian stock market Asia’s worst performer this year New Delhi/Mumbai: Castleton Investment Ltd, a unit of GlaxoSmithKline Plc (GSK), in 2012 asked an arm of the Indian finance ministry… – Continue reading
House Foreign Affairs Committee Chairman Ed Royce (R-CA) and Congressional Armenian Caucus Co-Chair Frank Pallone (D-NJ) were among the first Congressional leaders to welcome the May 7th signing of the U.S.-Armenia Trade and Investment Framework Agreement (TIFA), a longstanding policy priority for the Armenian National Committee of America (ANCA). Chairman… – Continue reading
