Category: Tax treaties

Why Malcolm Turnbull wants to charge Google and Facebook GST on Australian ad revenue

Multinational tech giants Google and Facebook could soon be charged goods and services tax on advertising booked by Australian companies if a proposal flagged by federal Communications Minister Malcolm Turnbull is adopted. While multinational corporations continue to come under fire for minimising their tax bills in Australia, Turnbull has floated… – Continue reading

Taxing times

– The Indian financial system needs to rethink its regulatory norms The role of the banking and financial service sector (BFS) in the process of economic development has always attracted attention. The framework of the Indian financial system needs a relook if we need to ensure unhindered credit availability to… – Continue reading

Rio Tinto says work to combat base erosion, profit shifting and tax avoidance could go too far and discriminate against multinational companies

Rio Tinto has warned that multinational companies could be discriminated against if moves to combat tax “base erosion and profit shifting” went too far. With Australia and the other 33 member nations of the Organisation for Economic Co-operation and Development ramping up efforts to prevent multinational companies avoiding tax, Rio… – Continue reading

IFS 2020 – Ireland’s new strategy for International Financial Services

The Irish Government has launched its strategy for Ireland’s International Financial Services Sector for the next five years (IFS2020), which seeks to consolidate and grow Ireland’s position as the global location of choice for specialist international financial services (IFS). The strategy includes a comprehensive overview of the existing strengths of… – Continue reading

Disparity between the US and Brazil’s approach to royalties increases risk of double taxation

TP Week As a result of Brazil’s unique policy to prevent erosion of the tax base, companies often face double taxation. The pending case before the US Tax Court (Docket 5816-13), 3M Co. et al. v. Commissioner, brings this issue into the spotlight. In this case the US Internal Revenue… – Continue reading

Pakistan and China renegotiate accord to avoid double taxation

Chairman Federal Board of Revenue (FBR) Tariq Bajwa has said that Pakistan and China are re-negotiating agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income. On the conclusion of Public Accounts Committee (PAC) at the Parliament House here on Thursday,… – Continue reading

Narendra Modi: India, Mauritius will work to avoid tax treaty abuse

Port Louis, March 12 : Prime Minister Narendra Modi on Thursday assured that India would work with Mauritius to avoid the “abuse” of the double taxation avoidance agreement and added that the destinies of both nations are “linked by the currents of the Indian Ocean”. Addressing the National Parliament of… – Continue reading

India offers $ 500 million credit to Mauritius, negotiations on tax treaty to continue

Port Louis: India offered US dollar 500 million concessional line of credit to Mauritius for key infrastructure projects even as the two countries agreed to continue negotiations on hammering out a revised double tax treaty to prevent its “abuse”. The two countries also signed five agreements, including one on developing… – Continue reading

Nowhere to hide

The call for tax transparency is being echoed around the globe, with ‘midshore’ centres like Bahrain and the UAE emerging as reputable, regulated and tax efficient jurisdictions A 2012 book entitled Offshore Apocalypse – The Collapse of the Tax Haven Industry, written by a team of tax-law academics, auditors, compliance… – Continue reading

double taxation european union investments latvia legislation oecd south korea

On 9 March 2015, the State Secretary of the Latvian Foreign Ministry, Andrejs Pildegovics, met with the members of the South Korean Parliament, Byun Jae Ill and Park Young-sun, who are visiting Latvia from 9 to 11 March in order to strengthen cooperation between the Latvian and South Korean Parliaments,… – Continue reading

The voters hate Google. Heeeeyyyy… how about a ‘Google Tax’?

You may have noted there’s an election in the offing Worstall on Wednesday As the tech news outlet of record has told us, UK chancellor George Osborne is preparing to bring in the “Google Tax”. Properly known as the Diverted Profits Tax, it is supposed to be a way of… – Continue reading

Canada: Case Study: Temporary Assignment Of An Employee From Canada To The United States

This article is the first in a series of four parts that will examine the Canadian and U.S. income tax implications when an employee employed by a Canadian entity is assigned temporarily to work in the U.S. This first article focuses on the importance of the determination of “residency” for… – Continue reading

Hungary and Luxembourg sign agreement to avoid double taxation

Representatives of the governments of Hungary and Luxembourg signed an agreement to eliminate double taxation on the sidelines of a meeting of EU finance ministers, the economy ministry said. The new agreement, signed by Economy Minister Mihály Varga and counterpart Pierre Gramegna, replaces an earlier one signed in 1990. It… – Continue reading

Project Wickenby’s seven-year hunt lifts lid on dubious trades

NEIL CHENOWETH The raids unfolded across the city at 8.40 on a Tuesday evening. Squads of federal police descended on Point Piper, Chatswood, city offices and the departure lounge of Sydney International Airport. Accountant Vanda Gould was up when police arrived to arrest him. Across town officers scooped up his… – Continue reading

EAC told to weigh pros, cons of single income tax rates

East African member states have been advised to make critical assessment of single income tax rates. A law expert, Anatoly Nahayo said recently in Dar es Salaam after launching his book titled “East African Community Tax Harmonisation.” He said the move will ease allocation of capital shares within EAC member… – Continue reading

French real estate holdings through Luxembourg vehicles may need to be revisited, says expert

Structures for investments from overseas investors in French real estate that involve Luxembourg vehicles may need to be restructured if an expected change to the double tax treaty between France and Luxembourg takes effect, an expert has said.09 Mar 2015 Property tax Property Tax Structured real estate Specialist property investment… – Continue reading

Barbados And Cyprus To Negotiate DTA

Barbados and Cyprus have announced that they are to begin negotiating a double taxation agreement (DTA) to strengthen economic relations between the two territories. Barbados Prime Minister Freundel Stuart noted that although diplomatic relations between the two countries were established in 1972, economic opportunities have yet to be fully explored…. – Continue reading

GUEST COLUMN: Protect your investments

Many business owners have substantial personal assets invested in their business. This can have significant implications, not only for you and your business, but also for your family’s financial security. To protect your investment, both business and personal, your business strategy should include carefully structured tax-planning components to ensure you… – Continue reading

Diverted profits tax and real estate – development propert

Introduction In the autumn statement the Chancellor of the Exchequer announced the introduction of a new Diverted Profits Tax (DPT). Against the context of international co-operation in the OECD led consultation on ways to ensure profits are taxed where they are generated (the Base Erosion and Profit Shifting project (BEPS),… – Continue reading

Guernsey: Taxing Times For Non-Resident Members Of Guernsey Section 150 Occupational Pension Schemes

With effect from 1 January 2015, The Income Tax (Guernsey) Law, 1975 was amended so that non-Guernsey residents will now be taxed on their pension benefits paid from an occupational pension scheme approved under section 150 of the Law, irrespective of whether they have performed services in Guernsey or not…. – Continue reading

China’s New General Anti-Avoidance Rules: An Overview

On December 2, 2014, the State Administration of Taxation (SAT), China’s highest tax authority, issued the Administrative Measures for the General Anti-Avoidance Rules (Trial) (GAAR), which went into effect on February 1, 2015. Prior to this legislation, China had no specific GAAR, only a few general anti-avoidance principles in various… – Continue reading

LAW & COMPLIANCE

NEW PACTS WITH AMSTERDAM AND TOKYO BOOST TRANSFER PRICING IN HONG KONG When combined with aggressive tax planning, Hong Kong’s onshore-offshore tax regime often results in a reduced tax burden for taxpayers that operate through Hong Kong companies by pricing intra-group transactions. The Advance Pricing Arrangement agreement with the Netherlands… – Continue reading

Backdating Taxes?

Double Tax Avoidance Agreement to be Applied to China Funds Investors no longer have to be worried about double taxation on China-based funds. On Mar. 4, the Korea Financial Investment Association told asset management firms to hand in documents for double tax avoidance agreement applications. Four months ago, when the… – Continue reading

India makes big strides: Pakistan seeks to follow new Swiss law on black money

India has made a major breakthrough with Swiss tax authorities, who have agreed to provide information in respect of cases independently investigated by IT department whereas first round of talks have reportedly taken place between Pakistan and Swiss government on revision of Convention for the Avoidance of Double Taxation agreement…. – Continue reading

Oregon Tax Haven bill targets 40 countries

Associated Oregon Industries Oregon’s largest business advocate The issue of “tax havens” garnered early interest from the House and Senate Revenue Committees as the Oregon Department of Revenue issued a new report outlining which additional countries should be considered “tax havens” for purposes of Oregon tax law. AOI testified in… – Continue reading

Hong Kong’s 2015/16 budget offers hope and risk for tax competiveness

Hong Kong Financial Secretary, John Tsang delivered his eighth budget speech on 25 February 2015. Key Points: >Expansion of tax exemption for certain offshore investment funds >Tax concession for treasury centre activities on the way >Full steam ahead with implementation of OECD automatic exchange of tax information standard >Addressing Hong… – Continue reading