U.S. Ambassador to Armenia Richard Mills on Tuesday confirmed reports that a U.S.-Armenia Trade and Investment Treaty will be signed during President Sargsyan’s working visit this week to Washington, DC, the final step in the negotiation of a bilateral economic accord long sought by the Armenian National Committee of America… – Continue reading
The Davis Tax Committee (“DTC”) recently addressed the issue of base erosion and profit shifting (“BEPS”) in South Africa. The international importance of transfer pricing was once again emphasized when 4 out of the 15 actions identified in the OECD Action Plan on BEPS related to transfer pricing. The 15… – Continue reading
A guide to Spanish taxation in 2015 for expats, with up-to-date information on income tax, VAT, property tax and other taxes for residents and non-residents in Spain. If you are living and working in Spain, you will be liable to pay Spanish taxes on your income and assets and will… – Continue reading
Thailand is expected to introduce new transfer pricing (TP) laws in the near future, which will apply to all companies in the Kingdom with related-party transactions. At a recent Deloitte seminar on “Thailand TP Developments”, with participation from senior officials from the Revenue Department, we shared some valuable insights on… – Continue reading
The IRS, the most powerful and least accountable agency of the federal government, is an admitted criminal enterprise. To deal with this, Republican candidates for president are placing tax reform at the top of their agendas. You will have to guess why the Democrats seem not to care. Sen. Ted… – Continue reading
Mauritius and Singapore are both examples of countries with Double Taxation Avoidance Agreements (DTAAs) with India, meaning dividends from corporations that are paid out to shareholders are not taxed further, having already been taxed at the corporate level. This legislation has meant that such countries have been used to “round-trip”… – Continue reading
The patent box regime, adopted at the end of 2014 with Italy’s Stability Law, was recently modified by the Investment Compact Decree and implemented into law at the end of March 2015. A distinctive feature of the Italian regime is that the measure now also covers trademarks and designs. A… – Continue reading
The Tax Foundation released its inaugural “International Tax Competitiveness Index” (ITCI) on September 15th, 2014. The United States was ranked an abysmal 32nd out of the 34 OECD member countries for the year 2014. (See accompanying Table 1.) The European welfare states such as Norway, Sweden and Denmark, with their… – Continue reading
On 21 April 2015, the Danish Parliament adopted a bill, which sets out to deal with certain potential abuses recently encountered by the tax authorities as well as the Danish enactment of the general international anti-abuse initiatives currently considered at EU and OECD level. The new Danish GAAR will take… – Continue reading
A Netherlands-based company threatened to sue the South Korean government for inflicting more than 183 billion won in losses through double taxation during its sale of Hyundai Oilbank shares five years ago, it was revealed Saturday. If a lawsuit is filed, it will mark the second time for South Korea… – Continue reading
Taipei, May 2 (CNA) Taiwan has reached an agreement with Canada on the avoidance of double taxation at an annual bilateral economic consultation, the Ministry of Economic Affairs (MOEA) said Saturday. The double taxation avoidance pact, which will be signed very soon, will be favorable to Taiwan businesses because it… – Continue reading
MUMBAI: Five Foreign Portfolio Investors (FPIs) on Thursday mainly from the US and the UK have dragged the Indian government and the Income Tax department to the court for levying Minimum Alternate Tax (MAT) on their capital gains for the year 2011-12. The five FPIs — National Westminster Bank Plc,… – Continue reading
The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project is changing the international tax landscape by building a new international consensus on how to tackle BEPS. In September 2014, the first seven of the deliverables under the 15-point BEPS Action Plan were presented to G20 Finance Ministers when they met… – Continue reading
A committee set up by the finance ministry to address industry’s tax concerns has invited trade and industry for talks on the issue. Experts, however, say Finance Minister Arun Jaitley should have in his reply to a debate on the Finance Bill 2015 provided clarity on minimum alternate tax (MAT)… – Continue reading
Iran and the Czech Republic have signed an agreement which allows the two countries’ companies to avoid paying double tax on their trade activities. The agreement was signed on Thursday by Iran’s Minister of Economic Affairs and Finance Ali Tayyebnia and his Czech counterpart, Andrej Babiš, in the Czech capital… – Continue reading
During 2014, Barbados again produced strong evidence of the underlying strength of its financial system. All of the financial stability indicators and stress tests performed for the financial system strongly indicate that the system remains stable with the capacity to withstand a wide variety of severe economic shocks. It is… – Continue reading
The European Union (EU) needs an “ambitious blueprint for taxation,” Tax Commissioner Pierre Moscovici has said. Speaking at a recent conference, Moscovici said: “The European Union needs an ambitious roadmap to put an end to the distortionary nature of its tax policy and regulatory framework. In my view, the way… – Continue reading
The Supreme Court of Canada has dismissed Conrad Black’s bid to have his multi-million-dollar battle with the Canada Revenue Agency over back taxes heard by the country’s highest court. The Supreme Court of Canada has dismissed Conrad Black’s bid to have his multi-million-dollar battle with the Canada Revenue Agency over… – Continue reading
The Tax Office is cracking down on what it’s described as “contrived arrangements” that allow hundreds of wealthy individuals with self-managed superannuation funds (SMSFs) to pay no tax on income from shares. Cases are still being reviewed and it’s unclear how much tax revenue may be at stake. But the… – Continue reading
Autumn Statement 2014, Budget 2015 and Finance Act 2015 The UK Chancellor delivered his Autumn Statement on 3 December 2014 and his Budget speech on 18 March 2015. For an overview of some of the key announcements, please see our Autumn Statement 2014 briefing and Budget 2015 briefing. The UK’s… – Continue reading
TEHRAN, Apr. 29 (MNA) – Leading a high-ranking delegation of officials, Iran Minister of Economic Affairs and Finance departed for Prague this morning. Ali Tayyeb Nia is scheduled to hold meetings with his Czech counterpart and Czech vice-president of the Republic Parliament. Discussing development of ties and singing the MoU… – Continue reading
Most people have heard of the Organisation for Economic Co-operation and Development (OECD) and are probably aware it wants to make the world a “better” place. Its work is probably of little interest to most companies based in the UK. But this would change if constitutional arrangements between Scotland and… – Continue reading
There has been a lot of uncertainty with regard to withholding taxes imposed by the South African Revenue Service (SARS) on cross-border payments made by South Africans to offshore recipients, and the ambiguous administrative and compliance procedures relating thereto. Based on the information available directly from SARS, any amounts received… – Continue reading
The Italian Minister of the Economy and Finance, Pier Carlo Padoan, has confirmed that he expects additional tax revenue from Italian citizens with undeclared investments in San Marino from the Italian voluntary disclosure program. In a television interview in San Marino, he noted that Italy had definitively removed San Marino… – Continue reading
State Representative Natalie Manley (D-Joliet) is sponsoring legislation that would prohibit Illinois from double taxing income that is earned in another state when the taxpayer’s home office is based in Illinois. “Right now Illinois residents are taxed on most income received in other states, rather than just income earned in… – Continue reading
Starting with 1 June 2015, non-resident taxpayers earning interest income from Romania are allowed to apply the same tax treatment as resident taxpayers. The change in the law results from a European Commission infringement procedure against Romania regarding the discriminatory treatment applied to non-resident legal entities compared to resident taxpayers…. – Continue reading
The convention for the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income was signed at the Ministry of Foreign Affairs of Portugal yesterday between the Government of Oman and the Government of Portugal, reports the Oman Observer. The convention was signed on… – Continue reading
The Income Tax department has directed its officers that cases of foreign institutional investors (FIIs) seeking tax exmption under the Double Taxation Avoidance Agreements (DTAAs) with other countries must be decided within a month of claim filing, reports the New Kerala. “It has been decided that in all cases of… – Continue reading
Although you may be working in China, does the ATO still consider you an Australian resident? It’s just one of the things you need to get absolutely right. The tax requirements for Aussies working overseas vary from region to region. Aussies working in Hong Kong will find last month’s tax… – Continue reading
India’s rupee rose for a second day as the dollar weakened and global funds resumed purchases of local bonds after the government sought to clear uncertainties over a retrospective tax on capital gains. Overseas funds bought a net $130 million of local-currency notes on April 24, the latest figures show,… – Continue reading
ISLAMABAD: Commerce Minister Khurram Dastgir Khan informed the National Assembly on Monday of what he called major steps taken by the government to facilitate the oft-troubled Afghan transit trade, which he said he had also conveyed to Kabul during a visit there earlier this month. The move, he said in… – Continue reading
The Shareholders Association is making “strenuous representations” to the Inland Revenue Department over what it says is an unfair tax facing possibly thousands of New Zealand investors as a result of a proposed demerger of Anglo-Australian mining giant BHP Billiton. In an effort to simplify its business, Melbourne-based BHP is… – Continue reading
A 15-strong delegation of Bermuda industry, government and regulator representatives will take part in a Canada roadshow next week, targeting top-level executives and touting the corporate benefits of setting up a captive insurance company in Bermuda, reports the Bermuda Business Development Agency. Led by Bermuda’s Economic Development Minister Dr. Grant… – Continue reading
In brief: At the recent G20 meeting in Washington, Treasurer Joe Hockey announced the establishment of a working group between Australia and the UK to develop initiatives to address so-called diverted profits involving multinational enterprises. What are the implications for multinationals doing business in Australia? Partner Martin Fry (view CV)… – Continue reading
One million American citizens in Canada face double tax troubles. Max Reed explores these challenges in a spring series. The United States has two tools with which to collect information on accounts held by its citizens, FATCA and FBAR. Lots of attention has been paid to FATCA, less so to… – Continue reading
Hong Kong’s Government has launched a consultation on proposals to apply, with certain adaptations, new international standards on the automatic exchange of account information (AEOI) in tax matters. The Government’s AEOI proposals would alter the definition of financial institutions (FIs), the information FIs would be required to secure from account… – Continue reading
An OECD initiative on tax evasion is causing ripples around the world While a host of topics — from the necessity and the proposed scope of corporate tax reform, to corporate rate reduction and corporate inversions — are of major concern to those engaged in international tax, the overriding issue… – Continue reading
Yesterday afternoon, the Canadian government tabled the 2015 Canadian Federal Budget. Two measures are particularly relevant to certain employers. Withholding Relief for Non-Resident Employers and Employees To take effect next year (if the measure is enacted), Budget 2015 proposes an exemption from certain withholding requirements on payments from “qualifying non-resident… – Continue reading
A senior partner in the tax firm of Ikata, Ikata and company, Mr. Iduonku Ikata, has called for an aggressive tax collection system to stem the tide of evasion in the country. Ikata, who stated this while speaking to our correspondent in Port Harcourt recently said this could be achieved… – Continue reading
Island Delegation to Tout Jurisdiction as Risk Capital and Potential e-Commerce Hub HAMILTON, Bermuda, April 27, 2015 (GLOBE NEWSWIRE) — A 15-strong delegation of Bermuda industry, government and regulator representatives will take part in a Canada roadshow next week, targeting top-level executives and touting the corporate benefits of setting up… – Continue reading
MUMBAI: The 1607-point decline on the Sensex in the past two weeks has unnerved many investors, but there could be more pain in store. May has historically been a bad month for stocks -in the past 24 years, the average monthly return of the Sensex has been a niggardly 0.24%…. – Continue reading
What exactly is the point of a Coalition government if it offers the same sort of tax increases as voters expect from Labor and the Greens? It’s disturbing how quickly the Abbott government has turned its attention to boosting government revenue rather than reducing government spending. It’s only been in… – Continue reading
Benchmarks are poised just above their 200-day moving average — a long-term support April 25, 2015: Both the Sensex and the Nifty are very tantalizingly poised just above a long-term support level. This adds zing to next week’s trading that is expected to be full of action thanks to the… – Continue reading
FPIs are battling it out with the income-tax department, which has issued notices demanding that they pay MAT to the tune of Rs40,000 crore New Delhi/Mumbai: Despite the government affirming that foreign portfolio investors (FPIs) can use tax treaties to fight tax demands on past capital gains, a majority of… – Continue reading
However, OECD being persuasive may not help funds based out of nations whose treaties do not give specific exemption The Indian government’s clarification that it would honour tax treaties while making a demand of Minimum Alternate Tax (MAT) at the effective rate of 20 per cent came as a relief… – Continue reading
Hong Kong (HKSAR) – The Government today (April 24) launched a consultation exercise to gauge views on proposals to apply, with adaptations for Hong Kong, the prevailing international standards on the automatic exchange of financial account information in tax matters (AEOI). On the basis of the Organisation for Economic Cooperation… – Continue reading
Chinese investors in Kenya have asked the East African Community to implement a double taxation agreement (DTA), saying the current regime has hurt their expansion plans. The investors with interests in construction, trade, service industry, manufacturing and real estate sectors said they currently face a heavy burden paying the same… – Continue reading
Georgia and Belarus are stepping up their bilateral cooperation in taxation, customs affairs, and a number of other avenues. Representatives of both countries today signed a cooperation agreement on avoidance of double taxation, prevention of evasion of income and capital taxes, which would act as a basis for further talks…. – Continue reading
Switzerland is to amend federal tax legislation to prevent the double taxation of certain permanent establishments (PEs) located in the country. The planned reform is the result of a consultation on the application of the flat-rate tax credit. It will affect PEs in Switzerland that have their registered office in… – Continue reading
The Federal Court has found that copyright does not exist in a digital data signal (Seven Network Limited v Commissioner of Taxation [2014] FCA 1411). Clayton Utz acted for Seven in the proceedings. The rights to broadcast the Olympic Games Seven Network Limited held the exclusive rights to broadcast certain… – Continue reading
