HONG KONG, Dec. 2, 2015 /PRNewswire — Demand for asset protection, wealth planning and funds by high net worth individuals in Asian countries will drive continued growth in the offshore industry, according to OIL’s sixth “Offshore 2020” annual market research study. OIL, the leader in international incorporations and corporate services… – Continue reading
UK tax authority HM Revenue and Customs (HMRC) has announced a change of view on the interpretation of the company residence articles in 16 double taxation agreements (DTAs), reports Tax News. The change was prompted by an agreement with Jersey on the interpretation of the company residence tie-breaker article in… – Continue reading
The Channel Islands (Jersey and Guernsey) have long been known as leading offshore centres for the establishment of investment funds and other investment structures. In particular, Channel Island vehicles are often used for alternative investment structuring – including private equity, infrastructure and real estate. This article explains the trends in… – Continue reading
UK tax authority HM Revenue and Customs (HMRC) has announced a change of view on the interpretation of the company residence articles in 16 double taxation agreements (DTAs). The change was prompted by an agreement with Jersey on the interpretation of the company residence tie-breaker article in their 1952 DTA…. – Continue reading
Greater China, Southeast Asia Seen as Global Leaders in Use of Offshore Vehicles, Drawn by Efficiency & Legal Frameworks Key Highlights: OIL’s sixth annual survey shows: The offshore industry will be a leaner, more resilient and confident member of the global economy by 2020, driven by demand from increasing numbers… – Continue reading
Hong Kong is tipped to become the world’s largest offshore corporate services centre by 2020, helped ironically, by the industry’s own struggles against reform demands coming from western governments and pressure groups. On notice after high profile money laundering and tax avoidance scandals, traditional offshore havens like the British Virgin… – Continue reading
The Italian Supreme Court overturned decisions of lower courts to conclude that two renowned Italian fashion designers were not guilty of tax evasion. The designers, however, could still be subject to civil penalties of about €343.3 million. BACKGROUND The designers had set up Luxembourg companies, to which they had transferred… – Continue reading
The offshore industry is poised for growth, as the industry insiders see the demand for offshore financial and corporate services likely to increase in the coming years, according to an industry survey conducted by OIL, a corporate service provider specializing in international incorporations. The industry has been battling negative perceptions… – Continue reading
As the founder of a startup company, one of the first questions you need to consider is “where should I incorporate my company?” Investors are drawn to the British Virgin Islands (BVI) for its flexible and modern corporate regime, tax neutrality, respected legal system, political stability and effective regulatory framework…. – Continue reading
Towards compliance with tax information sharing laws put in place in recent times, all financial intermediaries are mandated to seek information from account holders. They are also obliged to share information of your account with relevant authorities. SEBI too has issued guidelines on identification of beneficial ownership and mandated all… – Continue reading
Notice 2015-79—released November 19, 2015, by the Treasury Department and IRS—announces their intention to issue regulations relating to inversion transactions and post-inversion restructuring transactions. Notice 2015-79 provides for rules that: Limit the ability of domestic companies to effect an inversion Limit the advantages of certain post-inversion restructuring transactions Clarify certain… – Continue reading
MUMBAI: India’s forthcoming budget may draw from some of the recommendations, especially in the realm of transfer pricing, contained in the final package of ‘Base Erosion and Profit Shifting’ (BEPS) measures, rolled out in October. Certain anti-abuse measures, such as thin capitalization, which for tax purposes disallows interest payments beyond… – Continue reading
Hong Kong is tipped to become the world’s largest offshore corporate services centre by 2020, helped ironically, by the industry’s own struggles against reform demands coming from western governments and pressure groups. On notice after high profile money laundering and tax avoidance scandals, traditional offshore havens like the British Virgin… – Continue reading
The South African Revenue Service (SARS) has issued an interpretation note to provide guidance on the term “place of effective management” for the purposes of determining the tax residence of a company in South Africa. SARS notes that, in general, a resident is liable to income tax on gross income… – Continue reading
The Companies (Amendment) Law 2015 (the Law) has now come into effect in the Cayman Islands and will have potential application to all Cayman Islands companies. The Law amends sections 55 and 56 of the Companies Law (2013 Revision) which deals with appointments and notification of changes to directors. Previously,… – Continue reading
In Canada, taxes are levied at the federal, provincial and municipal levels of government. At the federal level, the government generates most of its revenue by way of income taxes and excise taxes imposed on the distribution and consumption of goods and services in Canada. The provinces and territories also… – Continue reading
A former finance minister yesterday slammed as “patently false” suggestions by a prominent tax advocacy group that the Bahamas is “disregarding the rules” and flouting global information exchange and transparency standards. James Smith, also an ex-Central Bank governor, hit out at the Tax Justice Network after its 2015 Financial Secrecy… – Continue reading
WASHINGTON—The United States is one of the world’s most secret financial jurisdictions, according to a watchdog group’s new global ranking. The Tax Justice Network, an international think tank based in the United Kingdom, on Monday unveiled the 2015 Tax Secrecy Index, which lists the countries that most allow financial secrecy… – Continue reading
Final recommendations about how multinational companies should be allowed to shift profits among different tax jurisdictions were issued this month, and the U.S. Congress has not yet indicated whether it will consider legislation in response to the proposals. Issued by the Organisation for Economic Cooperation and Development (OECD) on October… – Continue reading
David Cameron threw the proverbial cat among the pigeons in July when, with a steely glare at the UK property industry, he warned that the UK must not become “a safe haven for corrupt money from around the world” and that “there is no place for dirty money in Britain”…. – Continue reading
Multinational companies (MNCs) in India which have been evading tax on profits created due to a function carried out in the country by shifting contractual risk to some other location may soon find it difficult to escape the domestic tax net. Experts closely working with the government on how to… – Continue reading
The rogue regime in Banjul is on the verge of finalizing an Offshore Banking deal with some Hong Kong multi-million dollar companies, the Freedom Newspaper can reveal. Under the new deal, the Jammeh government is going to open an Offshore Bank in The Gambia, with the primary objective of helping… – Continue reading
The location of a holding company is a significant consideration in any international corporate structure. Choice of jurisdiction for a group holding company (‘Holdco’) is relevant both from the point of view of tax optimisation (maximising withholding tax free dividend, interest and royalty flow up through the group and minimising… – Continue reading
For many years international tax planning for Russian inbound and outbound investments, and wealth planning for Russian resident individuals, was rather straightforward. That was primarily due to relatively simple domestic tax rules and a degree of inexperience amongst the Russian tax and other interested authorities in relation to international tax… – Continue reading
Individuals and business wishing to establish a business in Canada need to familiarize themselves with the laws concerning forms of organization, FDI, competition, taxation, labor, privacy, the environment, and more. Canada has weathered the recent period of international uncertainty and volatility better than most other advanced industrialized nations. It is… – Continue reading
In 2013, the previous Belgian government introduced a new reporting obligation for individual founders and beneficiaries of so-called “legal arrangements” (i.e., trusts, foundations and certain tax haven companies). At the same time, the previous government also internally discussed a draft bill seeking to further discourage the use of such legal… – Continue reading
The Channel Islands (Jersey and Guernsey) have long been known as leading offshore centres for the establishment of investment funds and other investment structures. In particular, Channel Island vehicles are often used for alternative investment structuring – including private equity, infrastructure and real estate. This article explains the trends in… – Continue reading
Introduction In 1934 distinguished US jurist Judge Learned Hand famously opined that “one may so arrange his affairs so that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to… – Continue reading
On July 17, 2015, the Internal Revenue Service (IRS) released three new “practice units,” each examining a particular type of transaction involving a controlled foreign corporation (CFC). The IRS develops practice units internally for use both as training materials and as job aids for examiners. Practice units are not formal… – Continue reading
There is an intimate relationship between art and finance. In the public sphere, the state plays a predominant role in funding and maintaining national art collections. The private sphere is dominated by private patronage. For example, artists in medieval Italy were funded by wealthy families such as the Medici, and… – Continue reading
Tax avoidance tactics of multinational companies have angered Australians, but an Australian mining firm used such methods in Malawi. Tax avoidance tactics of multinational companies have angered the public and placed pressure on the Abbott government to prevent profits being exported offshore. But an Australian uranium miner is defending the… – Continue reading
The European Union 4th Anti-Money Laundering Directive has been officially published in the European Journal. The scope of the 4th Directive is wider than its predecessor and covers all gambling services, it will review and revamp the UK Money Laundering Regulations which were established 2007. The 4th Directive will, however,… – Continue reading
The Cayman Islands saw a 17 percent increase in new company registrations in 2014 over the previous year, according to a report released today by offshore law and fiduciary firm Appleby. In 2014, 11,010 new companies registered in Cayman, noted the firm’s latest ‘On the Register’ report, which provides insight… – Continue reading
Jersey experienced a 10% increase in new company incorporations in 2014 over the previous year, according to a report released today by Appleby, one of the world’s largest providers of offshore legal, fiduciary and administrative services. Last year also saw the total number of active companies on Jersey’s registry rise… – Continue reading
Registering a company in Singapore is as good as declaring that you have judged your options, made your preparations, and now that the time is right, you mean nothing but, business. Opening a company in Singapore is an act enough for the investors to gauge the depth of your intent… – Continue reading
The finance ministry, after due consultations with the SIT on black money and various financial probe agencies, has decided that a team of senior officials will hold bilateral meetings with foreign jurisdictions either in India or at the locations of their counterparts to thrash out issues quickly, reports the India… – Continue reading
Chairman of our Corporate Team, Paul Egan, gives an overview of the changes of which Irish companies should be aware on the commencement of the Irish Companies Act 2014. The Companies Act 2014 was enacted on the 23 December 2014 and its commencement is planned for 1 June 2015. The… – Continue reading
The Companies Act 2014, which comes into force on 1 June 2015, represents the most significant reform of company law since 1963. The new legislation creates two new and distinct types of private limited company, and existing companies must choose which of these they will convert to. The new legislation… – Continue reading
If you have been running your small business happily and without incident as a sole proprietorship, general partnership, or limited liability company (LLC), why would you want to incorporate? The answer could be that you do not want to incorporate, but there are valid reasons for you at least to… – Continue reading
“The business tax system today is inefficient, overly complex, and too riddled with loopholes,” said Mark Mazur, assistant secretary for tax policy at the U.S. Department of Treasury. So much so, in fact, that it can’t fulfill its function to be a world-class system, he noted. Mazur, speaking Tuesday at… – Continue reading
NEW YORK • When it comes to taxes, corporate America is getting a bit less corporate. And a bit less American. Fueled by a wave of inversions, a record 54 companies in the Standard & Poor’s 500 Index of leading U.S. firms are now at least partially exempt from the… – Continue reading
When it comes to taxes, corporate America is getting a bit less corporate. And a bit less American. Fueled by a wave of inversions, a record 54 companies in the Standard & Poor’s 500 Index of leading U.S. firms are now at least partially exempt from the corporate income tax…. – Continue reading
The Panama Government on its continuous interest of complying with the requirements of international organizations and global standards of highly reputable financial centers has decided to take measures to accelerate the entry into force of Act 47 of 2013, which establishes a regime for the immobilization of Bearer Shares, and… – Continue reading
In my practice, I have found that a majority of my clients who create significant wealth do so through ownership of a private business or a concentrated stock position in a publicly traded company. What that means for you is that if you haven’t yet started a business or taken… – Continue reading
The Revenue Department estimates it will miss its tax collection target by no more than 160 billion baht for fiscal 2015 after it was off target by 35 billion in the five months through February. The government’s largest revenue contributor has striven to collect new taxes such as those on… – Continue reading
Rather than installing a territorial tax system, the federal government should change U.S. securities rules, a law professor contends. Changing to a “territorial” tax system in the United States won’t ultimately stem the exodus of U.S.-based multinationals to lower-tax countries and could come at a significant cost in terms of… – Continue reading
If you have been running your business as a sole proprietor or are planning to be self-employed, you should probably give the idea of incorporating your business a serious thought. Since we are talking about incorporation from the point of view of taxation, you should know that it has its… – 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
The Companies Registry, Hong Kong has launched a full scale electronic filing system with effect from 15th February 2015 known as e-Registry. It is a 24 hour portal that allows electronic submission of applications for: Registration of Hong Kong companies Registration of non-Hong Kong companies 84 different specified forms under… – Continue reading
CDE Op-Ed CommentaryGiven the recent problems American trading companies are having in establishing bank accounts in Hong Kong, viable alternatives need to be found. These issues, which are directly related to the American IRS carrying out extensive investigations in Hong Kong concerning breaches of the new FATCA regulations, have made… – Continue reading
