Large businesses require access to finances to fund on-going market development, regional expansion and mergers & acquisitions (M&A) to name a few. Conglomerates in particular have discovered that pooling together the different business units’ assets under treasury operations enables these to better manage the company’s liquidity as well as mitigate… – Continue reading
France has always been an attractive place to live but, there is a long-held perception that French taxes will eat up much of your income and savings, says Jason Porter, business development manager at Blevins Franks. Where annual income exceeds €1m (£729m, $1.1m), taxation at a rate of 75% (a… – Continue reading
An investment registration scheme launched by the government last year attracted a total of 1,469 valid registrations covering an aggregate of €455.8 million worth of eligible assets, The Finance Ministry told The Malta Independent. Of the total amount registered, €69.8 million or 15% of the total was repatriated following registration…. – Continue reading
Global entities liable to pay tax on yearly income if their place of effective management is India even for a single day Shell companies based abroad would have to pay taxes on their global income for a year if their place of effective management (POEM) is India even for a… – Continue reading
Working overseas can lead to tricky tax pitfalls, but seeking expert advice can keep you from paying up twice. Going overseas to work is a grand adventure for many young professionals. It offers the opportunity to experience a different culture, expand your work experience and enhance future career opportunities. But… – Continue reading
Foreign subsidiaries may now have to pay tax both in India and the country of their operations At present, a company incorporated outside India is considered a tax resident only if the control and management of its affairs is situated wholly in India. Photo: Pradeep Gaur/Mint New Delhi: A budget… – Continue reading
Under Article 185, § 2, B of the Belgian Code on revenue taxes, an international group may ask for its taxes to be reduced by so-called excess profits, which are registered in the account of the Belgian entity as a result of the benefits of being part of an international… – Continue reading
The art of taxation, declared King Louis XIV’s Minister of Finances Jean-Baptiste Colbert, is in “so plucking the goose as to obtain the largest amount of feathers with the least amount of hissing”. The Budgets of Singapore and Hong Kong – released two days apart this week – have thrown… – Continue reading
Minister of Finance Martin Dlamini said the proposed revenue measures would assist government in mobilising additional resources for protecting essential services while Southern African Customs Union (SACU) revenues fall in the medium term. He said these initiatives include an amendment of the Income Tax regulations, including removal of the tax… – Continue reading
After several rounds of revisions and consultations in the past few years, the State Administration of Taxation (“SAT”) has recently promulgated the Bulletin on Several Issues concerning the Enterprise Income Tax (“EIT”) on Indirect Asset Transfer by Non-Resident Enterprises (“Bulletin 7”)[1]. Tax matters occurred but have not been settled before… – Continue reading
The income tax department has scaled down its estimate of income suppression by multinational corporations in India in the 2014-15 audit of intra-group cross-border transactions to Rs 47,000 crore, a steep 22% decline from the extra taxable income the department had attributed to the firms in the previous audit. The… – Continue reading
ISLAMABAD: Transparency International (TI) has urged the National Accountability Bureau (NAB) to investigate evasion of tax, and call for information about the Pakistani investors who have succeeded to transfer Rs430 billion investment on the purchases of properties during the year 2013 and 2014. In a letter written to NAB chairman,… – Continue reading
In a February 20 letter to US Senate Majority Leader Mitch McConnell (R – Kentucky), the National Foreign Trade Council and other leading business organizations urged action on pending bilateral double taxation agreements (DTAs) and protocols. A coalition of ten business organizations, including the Business Roundtable, National Association of Manufacturers,… – Continue reading
Al Tamimi & Company – Advocates and Legal Consultants Surabhi Singhi Kataria Tax planning has always been a topic of international debate and adjudication. The borderlines between permitted tax planning/avoidance and unlawful tax evasion have occupied the centre stage across the globe with several modern economies emphasizing the need for… – Continue reading
The breathless conundrum for IP companies is four-fold: not only should royalties be taxed at a low rate in order to maximise profits; but also research and development (R&D) or acquisition costs should be considered as allowable expenses to the maximum possible effect, whilst also the jurisdiction where the IP… – Continue reading
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. This has led to heightened transfer pricing scrutiny from the Hong Kong Inland Revenue Department in recent years. In order… – Continue reading
The signing of a double taxation agreement (DTA) protocol between Switzerland and Italy, which includes a provision for the exchange of information upon request, has fueled an expectation that the Italian Treasury will be able to collect substantial additional tax revenue this year. While it could take up to two… – Continue reading
Mr. Akhilesh Ranjan, Joint Secretary Ministry of Finance, and also Competent Authority for the Government of India, spoke this past week at the Pacific Rim Tax Institute, February 19-20, reaffirming India’s commitment to a new non-adversarial tax regime to encourage foreign investment and fair treatment of taxpayers. Mr. Ranjan’s appointment,… – Continue reading
Pact on information exchange in tax treatment Paris, February 25 – An important tax treaty signed between Italy and Switzerland is evidence of the “change of a crucial paradigm,” in banking secrecy with global implications, Pascal Saint-Amans, director of the center for tax policy and administration at the OECD told… – Continue reading
Thanks in part to past concerns that globalization could lead to double taxation, corporations have numerous techniques at their disposal to reduce their tax bills, including the placement of subsidiaries and spinoff holding companies in low-tax jurisdictions. The Group of 20 wants to change that. The Organisation for Economic Cooperation… – Continue reading
As for the central message that an NRI/PIO want to hear from Modi’s most important budget of his term can be best summed by what he said during an event in central park New York “May the force be with you “Veni Vidi Vici!” he came, he saw and he… – Continue reading
Close to three dozen private equity firms which used investment entities based in Mauritius to route money into Indian portfolio companies have received income-tax notices for payment of Minimum Alternate Tax (MAT) on the capital gains accrued to them for sale of such shares, according to Business Standard. MAT is… – Continue reading
The amendment of matriculation tax law in 2013 signaled a relevant change for charter operations in Spain: the possibility for non EU flagged vessels to be licensed in the Balearics, this change will allow not only EU but Non EU flagged vessels to operate from the Balearic Islands. Alex Chumillas… – Continue reading
São Paulo, Brazil. International transfer pricing is able to take place in Brazil, outside of the OECD While Brazil is not a member of the OECD, many multinational groups there are able to successfully navigate international transfer pricing standards, yielding effective results The economic view of Brazil has always been… – Continue reading
Bahrain and India have signed agreements to increase co-operation in the areas of education, investment, defence and other sectors. It took place during the first meeting of the India-Bahrain High Joint Commission (HJC) in New Delhi, said a report in the Gulf Daily News (GDN), our sister publication. The Bahrain… – Continue reading
IRA plans can be excellent ways to save for retirement, but there are some investments to avoid if you want to take full advantage of IRA tax savings. Two that come immediately to mind are tax-exempt municipal bonds and high-yielding stocks from foreign countries with dividend withholding taxes. Tax-exempt municipal… – Continue reading
This is the time of the year for millions of Americans to begin the annual ritual of gathering information about income, taxes, charitable giving, health insurance, expenses and sundry other items, and prepare to send mountains of information to the IRS –and to those who prepare their tax returns. Overseas… – Continue reading
Switzerland and neighbouring Italy have revised a double taxation agreement which includes provisions for the exchange of information in line with the standards of the Organisation for Economic Development and Co-operation (OECD). The accord and a roadmap for the amendment of tax rules on cross-border workers as well as improved… – Continue reading
Switzerland and neighbouring Italy have revised a double taxation agreement which includes provisions for the exchange of information in line with the standards of the Organisation for Economic Development and Co-operation (OECD). The accord and a roadmap for the amendment of tax rules on cross-border workers as well as improved… – Continue reading
Tax collections, so maintains the Federal Minister for Finance Ishaq Dar, have improved significantly and he cited a healthy growth rate of around 13 percent in one of his recent press conferences. Sources within the Ministry of Finance, however, revealed to Business Recorder, but on condition of anonymity that the… – Continue reading
UK, US, Australia, Brazil, India- governments of developed and developing countries are battling profit shifting by MNCs such as Amazon, Google, Apple and Starbucks. The allegation- MNCs are shifting profits to jurisdictions where there is little or no tax to be paid. The solution- OECD’s BEPS action plan which, among… – Continue reading
Islamabad: Pakistan’s Finance Minister Ishaq Dar has rejected allegations by Pakistan Tehreek-e-Insaf (PTI) leader that he transferred $4 million to his son in Dubai to avoid taxes. In an open letter to the PTI chairman Imran Khan, the finance minister also refuted the claim that he has been dragging his… – Continue reading
The economic downturn across the world and rising public debt seems to have led various governments, globally, to focus on curbing erosion of the tax base by shifting profits to overseas jurisdictions. Several revenue authorities, globally, were of the view that companies have structured their intra-group contractual arrangements in a… – Continue reading
The Business Council of Australia says that the Tax Office is holding company directors and management to account about their tax affairs, despite there only being one company in the nation with a top risk rating. “There is ongoing [Australian Taxation Office] scrutiny of corporate boards,” the BCA said in… – Continue reading
It’s been tough for investors in the U.S. to get much income from their portfolios from traditional sources like fixed-income investments, and so dividend stocks have gotten a lot more popular in recent years. Although there are thousands of U.S. stocks that pay dividends, many international companies also have lucrative… – Continue reading
ISLAMABAD: A delegation of British Department for International Development (DFID) and Her Majesty Revenue & Customs (HMRC) will hold dialogue with the Federal Board of Revenue (FBR) on future course of action to further strengthen bilateral cooperation. The DFID is a department of the British government that leads the UK’s… – Continue reading
America is experiencing a significant issue with its number of corporations, with a recent report from the Tax Foundation showing that the number is the lowest it’s been in four decades. The report, titled “America’s Shrinking Corporate Sector,” points to recently released IR data showing there were 1.6 million C… – Continue reading
PARIS: Singapore and France signed an amended Agreement for the Avoidance of Double Taxation (DTA) to lower withholding tax rates for dividends and new anti-abuse provisions. The most notable changes are the following: Withholding tax rate for dividends is reduced to 5 percent (from 10 percent previously) if the beneficial… – Continue reading
Over the past few years we have seen the introduction of various withholding taxes to the South African tax system. We set out below a high-level summary of the various withholding taxes that are levied in terms of the Income Tax Act 58 of 1962 (the “Act”), their rates and… – Continue reading
Probes since 2001 into offshore accounts include €4.6m from Irish HSBC customers The Revenue Commissioners has collected just more than €1 billion since 2001 from various special investigations of offshore bank accounts held by Irish residents. This includes the €4.6 million received to date from the holders of offshore accounts… – Continue reading
CHINA China Releases GAAR Administrative Measures Courtesy of Mr Glen Wei, an attorney at law, certified tax adviser, and CPA based in China.China’s State Administration of Taxation (SAT) on December 12 issued Decree 32 (dated December 2) introducing administrative measures for applying the domestic general anti-avoidance rule to special tax… – Continue reading
This Tax Alert by EY summarizes a recent ruling of the Mumbai Income Tax Appellate Tribunal (Tribunal) in the case of Swiss Re-Insurance Company Ltd. (Taxpayer). The Tribunal ruled that the Taxpayer’s wholly-owned Indian subsidiary (ICo) engaged in carrying out risk assessment services, marketing insurance and providing administrative support for… – Continue reading
The abolition of unfair taxes was one of the foundational principles of Magna Carta, a document that King John assented to on June 15, 1215 at Runnymede, England. Taxation must be fair, and requires the consent of the people. There is no more unfair aspect of fiscal law than retroactive… – Continue reading
Police bosses have been accused of seeking to double tax residents through plans for communities to help fund community support officers. Norfolk Police and Crime Commissioner Stephen Bett yesterday defended his proposal that town and parish councils could contribute 50 per cent of the cost of a PCSO in their… – Continue reading
Every acquisition requires careful tax planning early on in the process, especially when dealing with cross border acquisitions. One important consideration when a foreign company plans to acquire a Canadian company is the impact of any tax treaties that currently exist between the two jurisdictions. Tax treaties effectively reduce tax… – Continue reading
Singapore and France signed a revised Agreement for the Avoidance of Double Taxation (DTA) on 15 January 2015, which is not yet in force. The new DTA provides for lower withholding tax rates for dividends and new anti-abuse provisions. The most notable changes are the following: 1. Withholding Tax Withholding… – Continue reading
Firms need clear rules, certainty to remain in compliance with tax law, says expert Heightened scrutiny of foreign companies’ tax practices is a sign of China’s effort to modernize its taxation system to keep up with the fast-changing international business environment, but there is another dimension that concerns the foreign… – Continue reading
Some of the biggest listed Irish firms have subsidiaries in so-called ‘tax havens’, like the British Virgin Islands, Jersey or Luxembourg. They say it’s not to reduce their tax bills – so why are they there? The subsidiaries are registered in well-known offshore tax havens, such as the British Virgin… – Continue reading
The UK Treasury Committee has said that the draft legislation on the diverted profits tax (DPT) is unwieldy and stressed that the Government’s unilateral policy response should not destabilize international tax reform efforts. The Committee’s response to the plans are included in its new report on the Autumn Statement 2014,… – Continue reading
February 13 2015 Following the entry into force of the double tax agreement between Spain and Cyprus (for further details please see “New double taxation agreement between Cyprus and Spain enters into force”), the Spanish Ministry of Finance has announced that Cyprus has been formally removed from the Spanish tax… – Continue reading
