On Monday when the Centre revealed the names of Indians with bank accounts in Switzerland, a customary call to a chartered accountant made sense. Straight up, the question was how to make sure that a person be financially healthy and disciplined, without having back-of-the-mind worries of the tax man knocking… – Continue reading
Behind the step-by-step approach in the government’s disclosure of names of foreign bank account holders is the confidentiality clause under the Double Taxation Avoidance Treaty (DTAT) that prevents making public the identity of the account holders. Finance Minister Arun Jaitley had earlier said the names of persons would be disclosed… – Continue reading
The amendments see the addition of new provisions that were determined based on the Ministry of Finance’s suggestions Abu Dhabi: Obaid Humaid Al Tayer, Minister of State for Financial Affairs and Pierre Gramegna, Luxembourg’s Minister of Finance, today signed a protocol to amend the agreement on the avoidance of double… – Continue reading
NEW DELHI: Amid a growing clamour for naming of alleged black money holders, industry body Assocham today said the government should not prematurely disclose the names of such persons as it could hamper battle against this menace. “The double taxation avoidance treaties are important for the Indian residents and corporates… – Continue reading
Introduction The economy has come to the forefront of the Second U.S. House District race between incumbent Democrat Dave Loebsack and Republican challenger Dr. Mariannette Miller-Meeks. Loebsack’s campaign accuses Miller-Meeks of being in favor of “special tax breaks to outsourcing corporations” and claims she partnered with a company that sent… – Continue reading
With the announced end of banking secrecy for non-residents, the time has come to make use of favourable repatriation schemes, such as the voluntary disclosure regime in Italy. Despite increasing pressure for fiscal transparency and exchange of information, beneficial owners still have a choice: move the capital out (of Luxembourg),… – Continue reading
Since all economic theories – even Marxism and socialism – recognize that capital formation is a key to long-run growth, higher wages, and improved living standards, it obviously doesn’t make sense to penalize saving and investment. Yet that’s exactly what happens because of double taxation in the United States, as… – Continue reading
On October 14, 2014, the Irish Minister for Finance released proposals as part of the 2015 Irish Budget that would cause Irish incorporated non-resident (“INR”) companies to be treated as tax resident in Ireland beginning January 1, 2015. The goal is to shut down the use of so-called “Double Irish”… – Continue reading
India Blooms News Service New Delhi, Oct 24 (IBNS): Supreme Court advocate Ram Jethmalani, who was also an ex-BJP member, has written a letter to Finance Minister Arun Jaitley accusing him of not taking proper steps to bring back black money. n his letter, Jethmalani has slammed Jaitley’s stand that… – Continue reading
Star Business Report The National Board of Revenue is set to gather information on Bangladeshis who have bought properties abroad, its Chairman Md Ghulam Hussain said yesterday. The decision was taken to check whether the individuals have paid an appropriate amount of taxes to the state coffers, Hussain said during… – Continue reading
A week after a high-level delegation of the revenue department met Swiss authorities in a bid to persuade them to assist with details of the 700-odd Indians who are reported to have bank accounts with the HSBC Bank in Geneva, the NDA government is set to send the first batch… – Continue reading
Liechtenstein wants to lure wealthy Muslims to its private banks as it seeks to revive an industry hurt by the loss of the nation’s status as a tax haven. The principality of 37,000 people nestled between Switzerland and Austria will hold its first Islamic finance conference on Oct. 28 and… – Continue reading
Irish Finance Bill 2014: Last Sunday The New York Times in an editorial following the decision in Budget 2015 to eliminate the Double Irish tax dodge from 2021, said “Ireland, which for years used policies like the Double Irish to attract multinational businesses, appears uninterested in true reform. It will… – Continue reading
Business Standard October 23, 2014 Last Updated at 23:20 IST The Bombay High Court recently in the case of Vodafone India Services Private Limited (Vodafone) held that the foreign direct investment (FDI) received by the Indian company in the form of share capital cannot be taxed in India under the… – Continue reading
In a decision on June 11, 2014, the French Administrative Supreme Court held that a French national residing in Monaco may be subject to social taxes on property income (dividends, interest, property income, etc.) if the French national qualifies as French tax resident under French national law (Article 4 B… – Continue reading
LUXEMBOURG — On the first floor of a rust-colored building near the main railway station, Marius Kohl spent years engineering this country’s most valuable export: tax relief. As head of a federal agency called Societes 6, Mr. Kohl approved thousands of tax arrangements for multinational corporations, sometimes helping them save… – Continue reading
BERN/NEW DELHI: To comply with global norms, Switzerland today began consultation process for unilaterally amending bilateral tax treaties to allow exchange of information when there is a request from another country. Amid rising international pressure, including from India, Switzerland has been taking steps to share tax information as well as… – Continue reading
ITR Correspondent • • • The G20 and OECD’s Base Erosion and Profit Shifting (BEPS) project has rarely been out of the headlines during 2014. At the heart of the BEPS project is the assumption international tax rules make it possible for profits to be taxed in countries that are… – Continue reading
In determining the optimum gateway for investing into India, reliance on industry data may be the most prudent opening gambit. Data released by India’s Department of Industrial Policy & Promotion peg Mauritius and Singapore as the top two destinations through which foreign direct investment and private equity capital is routed… – Continue reading
NEW DELHI: Finance Minister Arun Jaitley said the government has never said that it will not reveal the names of Indians who have undeclared income parked in foreign bank accounts. “The Congress will be embarrassed by the names when we reveal them in court,” said Mr Jaitley in an exclusive… – Continue reading
Echegaray says account holders can take part in country’s fiscal amnesty If Argentines who hold 4,040 undeclared bank accounts in Switzerland don’t normalize their fiscal status and pay their debts, the AFIP tax bureau will file a complaint before the Office of Economic Crime and Money-Laundering (PROCELAC) requesting it investigates… – Continue reading
Lump sum taxation, the tailor-made measure tax regime designed to attract wealthy foreigners to Switzerland, is facing a crucial test as voters head to the polls on November 30 to decide whether or not to abolish the system for good. Proponents of the initiative say lump sum taxation is unfair… – Continue reading
Climate Change Law Practice Group Blog, Environmental, Energy and Resources Law The BC Government tabled Bill 6, the Liquefied Natural Gas Income Tax Act, on October 2, 2014. Bill 6 sets out the features of the new LNG tax regime. The LNG taxation proposals have been the subject of great… – Continue reading
Switzerland and Italy may agree amendments to their existing double tax agreement by spring 2015, Vieri Ceriani, Italy’s chief negotiator, has said. With the appointment of a new Government in Italy, Ceriani said that the provisions being sought by Italy, in particular on the division of taxes collected from Italian… – Continue reading
With the BJP government arguing that the Double Taxation Avoidance Agreement entered into with Germany in 1995 by the then Congress government was the constraining factor in disclosing details of black money stashed abroad, the Congress Saturday hit back saying over a dozen pacts with similar confidentiality clause were signed… – Continue reading
Dividend represents a share of the company’s post-tax profit that is divided among its shareholders. In other words, once corporate tax has been paid on profit, the remaining earnings are distributed amongst shareholders as dividend. So far, so good. Then, this dividend is characterised as income in the hands of… – Continue reading
On July 15th 2014, the OECD published its 2014 update of the Model Tax Convention (“2014 OECD Update”). This update is the outcome of the work accomplished between 2010 and the end of 2013. It does not however take into account the OECD conclusions of the “Action Plan on Base… – Continue reading
The revenue implications for South Africa of ‘base erosion and profit shifting’ by corporate taxpayers are firmly in the crosshairs of the Davis Tax Committee (DTC) and Judge Dennis Davis hinted on Monday that recommendations were being considered to “detect and deter” tax-avoiding financial flows. Speaking at a G20 study… – Continue reading
Switzerland took a step forward on implementing its double taxation agreement (DTA) with Argentina as the Federal Council adopted the dispatch on the deal and submitted it to parliament for approval. Meanwhile, in Argentina the agreement has already been passed by the Foreign Affairs and Budget Committees of the Lower… – Continue reading
New Delhi: Communist Party of India (Marxist) leader Brinda Karat on Saturday criticized the Prime Minister Narendra Modi-led NDA Government at the Centre for not disclosing the names of persons having money stashed away in safe havens abroad, and alleged that it exposed the utter hypocrisy and double standards of… – Continue reading
IrishTonnageTax – The Irish Maritime Development Office (IMDO) has released a report Irish Tonnage Tax: Opportunities for the International Shipping Industry. The Irish tonnage tax regime has been established for over 10 years and offers one of the most competitive on-shore corporate tax rates to international shipping companies. The tonnage… – Continue reading
Our Reaction The Irish Minister for Finance delivered his Budget 2015 (the “Budget”) speech this week. There was considerable domestic and international anticipation in advance of the Budget against a backdrop of significant recovery in the Irish economy and also international focus (including, in particular, under the OECD BEPS project)… – Continue reading
What is FATCA? The Foreign Account Tax Compliance Act (“FATCA”) is a complex reporting and withholding regime enacted by the U.S. government in March, 2010 that is expected to become operational on July 1, 2014. FATCA was designed to combat tax evasion by U.S. taxpayers holding assets through non-U.S. financial… – Continue reading
The visit of an Indian delegation to Switzerland to discuss tax issues has garnered a lot of media attention in both countries. While offering some concessions, Switzerland refused to budge on the issue of providing assistance on the basis of stolen bank data. On Wednesday, the Swiss State Secretary for… – Continue reading
A University of the West Indies Professor believes that the global attention being focused on offshore financial centres has come about because the international community remains concerned about money laundering and among other things, the financing of terrorism. Dr. Don Marshall who heads up the Sir Arthur Lewis Insitute for… – Continue reading
On July 21, 2014, the governments of Canada and the United Kingdom signed the fourth protocol (Protocol) amending the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading
Minister Findlay meets with Indian counterpart during trade mission to India DELHI, INDIA–(Marketwired – Oct. 15, 2014) – Canada Revenue Agency The Honourable Kerry-Lynne D. Findlay, P.C., Q.C., M.P., Minister of National Revenue, met today with Nirmala Sitharaman, India’s Minister of State for Commerce and Industry and Minister of State… – Continue reading
Monaco has become the 84th jurisdiction to commit to strengthen international tax cooperation through its participation in the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. Welcoming the signing by José Badia, Monaco’s Minister for Foreign Affairs and Cooperation, the Organisation for Economic Cooperation and Development’s (OECD’s) Secretary-General, Angel… – Continue reading
In this issue: An Introduction to Double Taxation Avoidance Qualifying for DTA Benefits in China Applying for DTA Benefits in China Rising operational costs in China mean that business owners must be alert to all possible means of maximizing the performance of their China-based investments. As one such measure, the… – Continue reading
It is said that Argentina faces an economic and political crisis every 10 years. Whenever a crisis arises, Argentinians’ right of ownership is at risk. Devaluation, asymmetric pesification and the current foreign exchange restrictions are a few examples of the challenges we face. What’s more, according to a recent OECD… – Continue reading
The NDA government is sending a high-level delegation to Switzerland in a bid to persuade them to assist with details of the 700-odd Indians who have bank accounts with the HSBC Bank in Geneva. This is being seen as the last-ditch attempt by the Indian government since the Swiss authorities… – Continue reading
Tax Justice Network Africa, which campaigns against harmful tax policies that favour the wealthy and perpetuate inequality, has moved to the High Court to stop a double-taxation treaty between Kenya and Mauritius. Mauritius is a popular tax haven for companies with multinational operations, tilting scales against countries that sign bilateral… – Continue reading
Say judge may find evidence inadmissible because it was supplied by a whistleblower As the AFIP tax bureau starts reviewing information it recently obtained from the French government on undeclared bank accounts held by Argentines in Switzerland, tax experts have warned that using the data might be harder than it… – Continue reading
A tax civil society has sued National Treasury Secretary Henry Rotich over an ‘illegal’ agreement signed with Mauritius, in a major litigation that could affect thousands of companies operating in Kenya. The suit filed at the High Court by Tax Justice Network-Africa (TJN-A) demands that Rotich withdraws a taxation treaty… – Continue reading
Introduction Action 1: the digital economy Action 2: hybrid mismatch arrangements Action 5: harmful tax competition Action 6: preventing tax treaty abuse Action 8: guidance on transfer pricing and intangible assets Action 13: transfer pricing documentation and country-by-country reporting Action 15: developing a multilateral legal instrument Next steps Introduction On… – Continue reading
The meeting took place at the official residency of the Egyptian ambassador, in Brasília, and focused on ways to further trade ties between Brazil and the Arab countries. Marcos Carrieri* marcos.carrieri@anba.com.br São Paulo – Ambassadors and chargés d’affaires from 18 Arab countries and the Arab League met last Thursday (9th)… – Continue reading
As a part of the OECD/G20 project to combat base erosion and profit shifting (“BEPS”), the OECD released the first set of reports and recommendations on September 16, 2014. These reports address seven of the actions described in the 15-point action plan to address BEPS published in July 2013 (the… – Continue reading
The taxman is willing to “negotiate and strike a balance” with multinationals being audited for transfer pricing misconduct, a drive it says has a potential to realise over Sh30 billion. The Kenya Revenue Authority told a workshop organised by the Association of Chartered Certified Accountants in Nairobi that this will… – Continue reading
In Starr International Company, Inc., v. United States, the taxpayer (“Starr International Company, Inc.” or “SICO”) filed a complaint in the United States District Court for the District of Columbia seeking a tax refund from the IRS of approximately $38 million. The refund is allegedly due to an overpayment of… – Continue reading
The relationship between the IRS and Canadians is not great. Groups like the Alliance for the Defense of Canadian Sovereignty want relief from the horrendous double filing and higher taxes Ameri-Canadians often face. Add to that the Canadian suit to block Canada’s FATCA deal with the U.S. It adds up… – Continue reading
