The GAAR guidelines should make it clear that it should be only used as a deterrent against tax avoidance schemes, and not a revenue gathering weapon in the hands of the tax officer. Accordingly, the guidelines should make it explicit that GAAR will be applicable only to artificial, abusive and… – Continue reading
The National Board of Revenue (NBR) has issued a guideline asking its income tax offices across the country to start ‘scrutiny assessment’ of the tax returns submitted for the tax year 2015-16. As per the guideline, the taxmen have to complete the scrutiny assessment known as ‘return process’ by December… – Continue reading
The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast. VIRGINIA CORPORATE INCOME TAX Conformity with Internal Revenue Code. Virginia Governor Terry McAuliffe signed emergency legislation on February 5, 2016 that advances the state’s… – Continue reading
On March 16, South Korean National Tax Service (NTS) Commissioner Lim Hwan-soo and Wong Kuen-fai, Commissioner of the Inland Revenue Department (IRD) of Hong Kong, met with each other and agreed to share their tax information immediately after their tax treaty becomes effective. The two countries’ negotiations for the treaty… – Continue reading
The Government of St. Kitts and Nevis, through its Inland Revenue Department has gone live with Vizor Software’s FATCA & AEOI solution, the FATCA Reporting Portal. Ottawa, Canada (PRWEB) March 17, 2016 Today, Vizor Ltd. announced that the Government of St. Kitts and Nevis has gone live with the Vizor… – Continue reading
Botswana and Malawi have signed an Agreement for the Avoidance of Double Taxation that aims to facilitate closer cooperation tax issues and allow for the exchange of information between their revenue authorities.Speaking at the signing ceremony on Wednesday, Botswana’s Finance Minister Kenneth Matambo said it was also pleasing that the… – Continue reading
Summary The pace of change in international tax is dramatic. Each month brings new initiatives and developments at both national and supra-national levels. In this update, we focus on recent changes which are relevant to our clients. The OECD Base Erosion and Profit Shifting (“BEPS”) reports were finalised in October… – Continue reading
Amazon’s Italy chief tells Bloomberg the company is cooperating with the authorities European Union member states continue their crackdown on American companies that they believe have avoided tax payments. Amazon.com, Inc. (NASDAQ:AMZN) is the latest company under investigation for its tax dealings in Italy, the company’s chief for Italy and… – Continue reading
THAILAND HAS no plan to adopt any time soon the three-tiered approach to transfer-pricing documentation recommended by the Organisation for Economic Cooperation and Development. However, large Thai multinational enterprises (MNEs) with subsidiaries operating in countries that are members of the OECD and/or Group of 20 will find that they will… – Continue reading
The Isle of Man Government has struck a new VAT deal with the UK. Treasury Minister Eddie Teare MHK has this morning informed Tynwald that a new agreement has been reached involving a revision of the formula that governs the sharing of joint indirect tax revenues under the 1979 Customs… – Continue reading
President Barack Obama is heading to Cuba next week. When Air Force One lands on that island nation on March 20, Obama will become the first U.S. commander in chief to visit Cuba in 88 years. In advance of that historic visit, which the administration hopes will eventually lead to… – Continue reading
The UK has been slammed over its failure to crackdown on British-controlled tax havens, with a new report claiming that the wealthiest one percent of the UK’s population have captured more than US$1.4 trillion of the country’s national growth since 2000. The report from Oxfam called on UK officials to… – Continue reading
Only the little people pay taxes. For a small, select cohort of rich Australians, the famous quote of New York property billionaire Leona Helmsley rings not as an outrage but as an inspiration. In the most recent documents released by the Australian Tax Office, there were 55 people who had… – Continue reading
In the final session of the two day Global Tax Conference at Dublin Castle yesterday, a senior Canadian tax advisor used the analogy of children playing football to describe the relationship between multinationals and government when it comes to tax. In a kids football match, he said, when the ball… – Continue reading
Mauritius plans to sell itself as a world class financial-services hub to investment companies in Asia and the Far East to win new business, an official said. The island-nation’s Financial Services Promotional Agency plans to market the country as an international financial center, or IFC, and is already collaborating with… – Continue reading
The amount of tax multinational companies pay – and the amount they don’t pay – has become highly controversial, writes RTÉ’s Economics Correspondent Sean Whelan. This is mainly as a result of public outrage over legal tax avoidance schemes that big companies can use to shelter vast amounts of money… – Continue reading
Fortune 500 firms may be avoiding $695 billion in U.S. income taxes on $2.4 trillion held offshore. What do Bernie Sanders and Donald Trump have in common? Both seek an end to the use of offshore tax havens by corporate America. Bernie Sanders’ plan ends the ability of corporations to… – Continue reading
Offshore schemes operated by Swiss bank UBS and Germany’s Deutsche Bank in a bid to avoid paying income tax on bankers’ bonuses are not exempt from tax, the Supreme Court in London ruled Wednesday. British tax authorities, who brought the court action, said the schemes set up by the Swiss… – Continue reading
EU countries will exchange information on the tax affairs of multinational companies under new rules backed by EU finance ministers aimed at stopping big companies avoiding paying their fair share into government coffers. The rules, that should take effect later this year, are a response to growing concerns about corporate… – Continue reading
Colorado House Democrats succeeded Wednesday for a second straight year in sending a bill to the Senate that would generate more tax revenue from some international companies — but only after a lengthy and very pointed debate that often sought to pit big businesses against small companies and average Colorado… – Continue reading
Federal authorities demanded secrecy in no-penalty, no-prosecution deal to high net worth Canadians The Canada Revenue Agency offered amnesty to multi-millionaire clients caught using what’s been called an offshore tax “sham” on the Isle of Man — a reprieve that was supposed to remain secret and out of the public… – Continue reading
Fenergo offers Nikko Securities America, Inc. end-to-end Client Lifecycle Management with a regulatory focus on AML, KYC and FATCA Fenergo, the leading provider of Regulatory Onboarding and Client Lifecycle Management software solutions for investment, corporate and private banks, has announced a new deal to provide Nikko Securities America, Inc. with… – Continue reading
A move to check arbitrary decisions by the tax authorities may result in a huge fine for minor transgressions or mistakes while reporting tax, experts fear. In this year’s budget fine-print, the finance ministry has inserted a “new Section 270A (which) provides for levy of penalty in cases of under-reporting… – Continue reading
For several years now Google has been facing what appears to be a case of tax avoidance in the UK, at some point in time, the company went as far saying it did not make any money from business in the UK all in a desperate attempt to pay less… – Continue reading
Debt planning and restructuring is a common mechanism to minimize taxable income by increasing deductions among different entities in a multinational group of companies. As interest on debt is generally a deductible expense of the payor and taxed in the hands of the payee, groups may create intercompany loans to… – Continue reading
NEWARK, NEW JERSEY (BLOOMBERG) – The US Internal Revenue Service (IRS) sought to make UBS Group turn over records on an account in Singapore held by a US citizen, setting up a showdown with the city-state over its bank-secrecy laws and potentially opening a new front against offshore tax evasion… – Continue reading
Retrospective amendments to domestic laws cannot override international treaties In a judgment that will have a far-reaching impact on double taxation issues, the Delhi High Court has held that Parliament cannot change the terms of an international treaty by bringing in amendments in the domestic law, and any such executive… – Continue reading
While equalisation levy appears to be a step to counter double non taxation and protect India’s share of taxation, in its current form it may impact an Indian taxpayer more than foreign MNCs The growth of digital economy entails many benefits, but also poses various tax challenges. These include the… – Continue reading
Facebook has caved to the tax pressure. The company is likely to pay millions more in U.K. taxes after making changes to its corporate structure that will stop revenue earned in the U.K. from being routed through Ireland. Facebook had been accused of “profit shifting,” a common practice for multinational… – Continue reading
The Federal Board of Revenue (FBR) has notified a new convention inked between Pakistan and the Czech Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to taxes on income of citizens of both countries. Sources said that the FBR has issued an S.R.O.1322(I)/2015… – Continue reading
The US government, in an effort to reduce offshore tax evasion, has taken extraordinary steps to implement FATCA, the Foreign Account Tax Compliance Act. This includes the hiring and training of over 3,000 IRS examiners newly tasked with process verification and tax audit efforts. The implications for US businesses can… – Continue reading
In its departmental plan for 2015-2020 published last month, HMRC set out it’s role “to help the honest majority to get their tax right and make it hard for the dishonest minority to cheat the system”. One of the headline objectives for this period is: “maximise revenues due and bear… – Continue reading
NEW DELHI: Terming the financial information exchange pact FATCA between India and USA as an ‘inequitable system’, the Finance Ministry today said it has received written commitment from the US that they will move towards full reciprocity. “We should look at FATCA as very a special case. It’s a law… – Continue reading
The South African Revenue Service (SARS) has issued final regulations that require certain financial institutions (FIs) to report on accounts held or controlled by foreign residents from March 1, 2016. The OECD’s automatic tax information exchange standard, the Common Reporting Standard (CRS), which the regulations are in response to, obliges… – Continue reading
For now… corporations, as responsible global citizens, should endeavour to pay their fair share of taxes to avoid threats to their own long term sustainability. Multinational companies like Google, Starbucks, Facebook, Amazon and other global corporations are constantly coming under public fire for avoiding taxes on their British sales. For… – Continue reading
Before conducting business outside of the U.S. for the first time, a company must establish the business case for doing so. That means looking beyond just the profit potential on the product or service to the other costs that can be involved, of which there are many. “The culture of… – Continue reading
The US Internal Revenue Service (IRS) has updated Publication 515, Withholding of Tax on Nonresident Aliens and Foreign Entities, which covers the obligations of the persons responsible for withholding tax (withholding agents). It is specified that the Publication is for withholding agents who pay income to foreign persons, including nonresident… – Continue reading
Outstanding issues relating to the existing Double Taxation Avoidance Agreement (DTAA) are under negotiation between India and Mauritius through the mechanism of Joint Working Group (JWG), Parliament was informed today. “India has proposed changes in the existing DTAA to address concerns relating to treaty abuse, around tripping of funds, double… – Continue reading
Maltese individuals resident and domiciled for tax purposes, that is people whose permanent residence is in Malta, are required to pay tax in Malta on their worldwide income, according to the Income Tax Act. This essentially means that Minister Konrad Mizzi is required to pay tax on foreign earnings. However… – Continue reading
Pakistan and Czech Republic have implemented a convention to avoid double taxation and prevent tax evasion, the Federal Board of Revenue notified on Monday. An official said the convention on avoidance of double taxation will come into force on July 1. “This is an epoch-making event in the consolidation of… – Continue reading
In Shanghai, Wolfgang Schäuble is urging his fellow G20 countries to put new rules to tackle tax avoidance into law. Back home, business leaders worry that German companies could be left exposed by the new rules if they are introduced unilaterally or go too far. The finance ministers of the… – Continue reading
France is seeking €1.6 billion in back taxes from Google, criticised for its use of aggressive tax optimisation techniques, a source at the finance ministry has said. “As far as our country is concerned, back taxes concerning this company amount to €1.6bn,” the official, who spoke on condition of anonymity,… – Continue reading
THE withdrawal of a withholding tax on service payments to foreigners, decried by many as unworkable, has been widely welcomed. The Treasury acknowledged that the tax had introduced “unforeseen issues, uncertainty on the application of domestic law and taxing rights under tax treaties”. The withholding tax was introduced into legislation… – Continue reading
Tax function of an organisation was traditionally run from the tax director’s room. Transfer Pricing (TP) was governed by contracts between related parties and this at times resulted in profits moving to legal entities that had contractual rights but had no significant people functions. There were instances of IP Holding… – Continue reading
“It is tantamount to an economic blockade”. That’s how Antigua and Barbuda’s Prime Minister, Gaston Browne, described the current withdrawal from Caribbean indigenous and offshore banks of correspondent relationships by US banks. His sentiments were echoed by Dean Barrow and Freundel Stuart, the prime ministers of Belize and Barbados respectively…. – Continue reading
A new report from ActionAid titled ‘Mistreated’ released this week has revealed that Zambia has 13 restrictive tax treaties that dramatically restrict the government’s power to tax global companies doing business on our soil and therefore unfairly limit our country’s potential to collect tax revenue. The report also found that… – Continue reading
During a political season in which populist fury and anger at big business is running high, two presidential candidates want to eliminate the ability of multinational firms to keep earnings overseas and avoid U.S. taxes. They also just happen to be the two most surprising and disruptive candidates in the… – Continue reading
It’s unlikely anybody was particularly surprised when Finance Minister Pravin Gordhan announced a number of initiatives to increase the amount of tax revenue; from sugar tax to a “tyre levy” to an increase in a number of existing sin taxes. But it’s perhaps the relaxing of voluntary disclosure rules that… – Continue reading
In its time, the Irving empire has had plenty of federal contracts — all of them lucrative, many of them controversial. So it wasn’t a surprise to hear that a federal cabinet committee is reviewing Irving’s $26 billion sole-source (but still unsigned) contract to build a fleet of warships for… – Continue reading
Treaties limit the tax poorer nations can place on British companies doing business within their borders, says ActionAid. The UK has signed a high number of tax deals with some of the world’s poorest countries, potentially depriving those states of millions in tax revenues every year, according to an analysis… – Continue reading
