If the Davis tax committee’s recommendations are followed, tax avoidance could be effectively reined in. Zeroing in on the super-wealthy and tax reluctant remains at the top of the global agenda as budgets across the world grow increasingly hungry for extra revenues. Now a draft report from the Davis tax… – Continue reading
Feb 12 (Reuters) – Brazilian Trade Minister Armando Monteiro said on Thursday he does not see much chance of agreeing on a tax treaty with the United States in the short term. In an interview during a visit to Washington, his first overseas trip as minister, Monteiro said double taxation,… – Continue reading
NEW DELHI: The much-feared general anti avoidance rules (GAAR) could be deferred by about two years so that business sentiment is allowed to improve in India but will need to be rolled out in some form or the other by 2017, in sync with the international framework on preventing treaty… – Continue reading
SINGAPORE: Singapore has signed agreements with France and Uruguay for avoidance of double taxation (DTA). In the agreement with France, the revised DTA offers improved terms for businesses, such as lower withholding tax rates for dividends and includes anti-abuse provisions. The signing took place in Singapore between Singapore Deputy Prime… – Continue reading
In a recent letter to the Committee on Foreign Relations, the American Institute of Certified Public Accountants (AICPA) requested that the US Senate urgently approve all pending bilateral double taxation agreements (DTAs) and protocols. The AICPA pointed out that the full Senate has not approved any DTA or protocol since… – Continue reading
New Delhi: Top officials from IT, BPO and e-commerce sectors have requested Finance Minister Arun Jaitley to address certain issues related to taxation in the Budget for fiscal year 2015-16, and provide incentives for setting up data centres in the country. They also suggested that the minister look at ways… – Continue reading
Private Sector Key KUWAIT CITY, Feb 11: The Parliament on Wednesday approved the development plan for fiscals 2015/2016 to 2019/2020 in its first and second readings with 33 votes in favor, four against and one abstention. It also approved the 20th report of the Finance and Economic Affairs Committee on… – Continue reading
Allowance of bilateral treaty for advanced pricing agreement should help mitigate issues around double taxation of income, feels brokerage house Morgan Stanley Moneycontrol Bureau Clarity around definition of export turnover and total turnover for computation of tax exemption in the Budget will help resolution of tax-related disputes, says brokerage house… – Continue reading
“Well, Jon, the Government’s about to bring in a 1.5% corporate, or company, tax cut from the 1st of July. That’s something that obviously we support, because (the) corporate tax rate at 30% is not competitive with the rest of the region and we need to drive that down.” –… – Continue reading
Island’s History of Robust Regulation, Rule of Law, Global Tax Treaties and Lack of Bank Secrecy Laws Ought to be Recognised by UK Labour Party HAMILTON, Bermuda, Feb. 10, 2015 (GLOBE NEWSWIRE) — Bermuda’s well-documented financial services regulation, international partnership treaties, and lack of bank secrecy legislation ought to be… – Continue reading
The International Chamber of Commerce (ICC) joined discussions today with G20 Finance Ministers and Central Bank Governors to set priorities for continued economic growth during the Turkish G20 presidency. As part of Turkey’s G20 platform for inclusiveness, implementation, and investment – the three I’s of the government’s G20 2015 presidency… – Continue reading
Call it the pass-through revolution. The U.S. has been losing about 60,000 conventional corporations a year, according to the Tax Foundation. It’s lost 1 million since 1986, the foundation said. Meanwhile, the number of pass-through entities has exploded. “More than 60 percent of U.S. business profits are now taxed under… – Continue reading
On February 6, 2015, the Organisation for Economic Co-operation and Development (OECD) announced that it has reached agreement with the Group of Twenty (G-20) Finance Ministers on three key elements of its base erosion and profit shifting project. The three elements, which the OECD said will enable implementation of the… – Continue reading
Switzerland and Liechtenstein have concluded negotiations toward a new double tax agreement (DTA), which should enter into force from January 2017. Switzerland’s Federal Department of Finance (FDF) announced on February 5, 2015, that talks concluded on February 2. The FDF expects the deal to be signed this summer and, pending… – Continue reading
NEW DELHI, FEBRUARY 9: The “door for dialogue” with India remains open despite the current “difficult environment” on the tax-related information sharing front, the Swiss Finance Ministry has said. In a just released annual report on International Financial and Tax Matters 2015, Switzerland has admitted that its relations with India… – Continue reading
The nation’s largest organization of accounting and tax professionals is urging the Senate to approve income tax treaties between the U.S. and various countries. In a February 3 letter to Senator Bob Corker (R-Tenn.), chairman of the Senate Committee on Foreign Relations and Senator Robert Menendez (D-N.J.), the committee’s ranking… – Continue reading
Guest Post by Andrew Blair-Stanek, Assistant Professor of Law at University of Maryland Carey School of Law Patent owners routinely tell the IRS, under penalties of perjury, that their patents have little value. Litigators representing defendants should take advantage of these remarkable admissions. IP has become the world’s leading tax… – Continue reading
The Organization for Economic Co-operation and Development’s (OECD) Action Plan 6 on the Base Erosion and Profit Shifting (BEPS) initiative recognizes that countries need to incorporate sufficient safeguards in their tax treaties and domestic rules to protect against practices that take advantage of the differences in national tax systems and… – Continue reading
More than 100 tax disputes involving Indian associates of US companies such as IBM and Microsoft are set to be settled out of court by April this year with the income tax department and the US Internal Revenue Service identifying disputes in the contract research, IT and software sectors for… – Continue reading
The OECD will present the latest developments in the OECD/G20 project to combat base erosion and profit shifting (BEPS) by multinational enterprises during a G20 Finance Ministers meeting on early next week (9th/10th February) in Istanbul. OECD and G20 countries have agreed three key elements that will enable implementation of… – Continue reading
On 29 January 2015, the Hong Kong Inland Revenue Department (“IRD”) announced new, hard-line procedures for obtaining a certificate of Hong Kong resident status (“tax residence certificate”) for the purpose of Hong Kong’s comprehensive double taxation agreement (“DTA”) network. The new rules became effective on 1 February 2015. This Client… – Continue reading
G20 finance ministers will hear about the OECD’s three-pronged approach to implementation of the BEPS Action Plan at their meeting in Istanbul on Monday and Tuesday of next week (February 9 and 10). The OECD, which is leading the work, outlined today what has been agreed so far with the… – Continue reading
Government’s updated strategy aims to add 10,000 jobs to Dublin ’s international financial hub When the International Financial Services Centre began life in 1987 it had just three companies, employing 55 people. If a strategy drawn up for the Government comes to fruition, some 10,000 direct net new jobs will… – Continue reading
Two double taxation agreements (DTAs) involving Kenya, South Africa and Mauritius have been set back a year after Kenya failed to complete the final step in the proceeds. The DTAs between Kenya and South Africa and between Kenya and Mauritius had been signed by the three countries and were due… – Continue reading
The DTA between Cyprus and Iceland took effect on 1 January 2015 The new double taxation agreement between Cyprus and Iceland, which was signed on 13 November 2014, entered into force on 22 December 2014. The agreement is based on the OECD Model Convention for the Avoidance of Double Taxation… – Continue reading
A New Tax on doing business in or through the UK The UK is on course to enact a new tax (the “DPT”) with extraterritorial scope which will apply to profits arising on or after 1 April 2015 and will be applied at a rate of 25% (the UK’s main… – Continue reading
Croatia and the UK have signed an Agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital gains. The Agreement was duly signed on January 15th, 2015 and it shall enter into force when both countries complete their… – Continue reading
More than half of Australia’s trade is money being sent offshore by companies to their overseas arms – with almost a third going to Singapore and Switzerland. Australian companies sent more than $100 billion to related parties in the low-tax nation of Singapore and another $15.6 billion to “hubs” in… – Continue reading
The Indonesian Employers Association (Apindo) has welcomed the government’s plan to introduce a tax amnesty, a fiscal incentive expected to encourage individuals or corporation that have not fully paid their taxes to comply with tax regulations. The association’s deputy chairman Hariyadi Sukamdani said that the amnesty would be effective in… – Continue reading
Technology giants Apple and Google have said in their submissions to the federal inquiry into corporate tax avoidance that they support international changes to global tax rules to stop profit shifting, but have warned of the risk of Australia acting alone, saying it would cost heavily in local jobs and… – Continue reading
Though North Korean labor more expensive than previously thought – RFA The DPRK government made agreements promoting mutual investment and preventing double taxation for foreign investors, particularly highlighting cooperation with Russia, according to an article from the Korean Central News Agency (KCNA) published this week. Governments often form tax treaties… – Continue reading
Beijing is going after base erosion and profit shifting, and multinationals could get caught in the crosshairs. China is continuing to step up its efforts to curb what it sees as cross-border tax evasion by foreign-owned companies, announcing it will review how companies move money and allocate costs among their… – Continue reading
On February 2, the Obama Administration released its fiscal year 2016 budget (FY 2016 Budget). The hallmarks of the FY 2016 Budget are proposals that would impose (i) a minimum tax on the current foreign earnings of U.S. corporations and their controlled foreign corporations (CFCs) and (ii) a one-time 14%… – Continue reading
HONG KONG — China’s tax officials plan to step up efforts to collect taxes from multinational corporations in the latest of a series of moves in the last year, mostly against Western companies. The activities have included police raids on the headquarters of companies’ China operations and heavy fines under… – Continue reading
New Delhi, Feb. 4: The notification of a social security deal with Norway – often called totalisation agreements — may pave the way for a similar pact with the US that has been hanging fire for a decade. Under the pact, employees sent by Indian firms to Norway on a… – Continue reading
In 2014, China continued to develop its taxation system affecting domestic and crossborder transactions. This “Legal Flash – Special Edition 2014” highlights the most significant tax updates of the year. Please see our monthly legal flashes for more information and analysis here. Taking a step-forward on anti-avoidance provisions, the State… – Continue reading
Some 776 American citizens or long-time residents renounced their status in the third quarter of 2014, according to the Treasury Department. If that trend continues, the U.S. will see more than 3,000 renunciations this year-a record. Why are so many Americans forfeiting their citizenship? In 2010, Congress passed the Foreign… – Continue reading
NATIONAL Treasury Cabinet Secretary Henry Rotich has urged counties to make taxation systems business friendly. Speaking at Leisure Lodge resort in Kwale yesterday during a county government development forum, Rotich said investors face multiple taxation in some counties. “It is very clear what the national government and counties are supposed… – Continue reading
(Bloomberg) — The European Union is investigating Belgium’s tax deals with multinational corporations, potentially dragging dozens more companies into widening probes of sweetheart fiscal pacts handed out by national governments. Building on investigations of Apple Inc. in Ireland and Amazon.com Inc. in Luxembourg, the European Commission is targeting Belgium’s so-called… – Continue reading
The United Nations (UN) has plumped for greater cooperation among countries to put in place a set of safeguards and rules for tax reforms the world over in the bleak backdrop of extant rules and conditions, “particularly regarding illicit flows, as well as tax avoidance” often limiting what governments can… – Continue reading
Progress continues to be made in the BEPS project, with the release in September 2014 of the “2014 Deliverables” and a raft of discussion drafts published during the autumn. Here is a summary of all the recent developments. Within the framework of the BEPS (Base Erosion and Profit Shifting) action… – Continue reading
Business industry feedback on BEPS discussion drafts, including comments from BIAC, TEI, Reed Elsevier, Volvo and Siemens, suggests that the OECD has done little to quash taxpayer concerns over double taxation and dispute resolution. The OECD’s BEPS project was the TP topic of 2014 and will undoubtedly retain the top… – Continue reading
Weak governance means Africa loses more than $50bn each year in unpaid taxes and money laundering, a new report has found. The analysis, published jointly by the African Union and the United Nations Economic Commission for Africa, concluded that a lack of financial transparency and difficulties in obtaining systematic data… – Continue reading
MINSK, 2 February (BelTA) – Belarus and Georgia plan to step up cooperation in taxation, customs affairs, and a number of other avenues. These matters were discussed among other things during the session of the Belarusian-Georgian intergovernmental commission on economic cooperation in Minsk on 2 February, BelTA has learned. Participants… – Continue reading
The draft legislation published on 10 December 2014 (see here) devotes almost 30 pages to the new “diverted profits tax” (DPT), which from 1 April 2015 will introduce a new tax at a rate of 25% to profits generated by those multinational corporate groups who, in the eyes of the… – Continue reading
India and US reach common ground on Mutual Agreement Procedure (“MAP)” and break new ground on Advance Pricing Agreements (“APA”) Suchint Majmudar Just ahead of Obama’s momentous R-Day visit to India, the Competent Authorities of India and US reached a landmark breakthrough in cases involving mutual agreement procedure under the… – Continue reading
The present French Tax Update will focus on (i) the most salient features of the new double tax treaty signed by the People’s Republic of China (China) and France on November 26, 2013 (New DTT), (ii) the new double tax treaty signed by Singapore and France on January 15, 2015,… – Continue reading
With over 7 million Americans living abroad, many have complained about the rigorous IRS enforcement of global tax reporting, the risk of draconian FBAR penalties for reporting foreign accounts, and FATCA discrimination. FATCA, America’s global tax enforcement law, applies virtually everywhere. It is easy for the IRS to find you,… – Continue reading
NEW DELHI: Getting tough with investment proposals from tax heavens, FIPB has deferred 23 applications in its last three meetings apprehending “treaty abuse”. According to sources, the Department of Revenue has expressed doubt that a few foreign companies were evading tax by routing their investments through tax heaven countries with… – Continue reading
A double tax treaty (“DTT”) was signed between Cyprus and Lithuania in June 2013. The treaty which follows the OECD Model Convention for the avoidance of Double Taxation on Income and on Capital has been ratified by the two Contracting States and has entered into force as of 1 January… – Continue reading
