The Brazilian Federal Revenue – RFB and the General Attorney of the National Treasury – PGFN changed the understanding that they shared in regard to the applying of Withholding Income Tax (IRRF) over foreign remittances of remuneration of technical services supplied by non-residents in Brazil. Before that, the RFB1 and… – Continue reading
THE CABINET has approved the Finance Ministry’s proposal for more tax incentives to facilitate the creation of International Headquarters and International Trading Centres in Thailand. IHQs and ITCs in the Kingdom currently enjoy both tax and non-tax benefits, including complete income-tax exemption for out-out transactions, while in-out transactions will be… – Continue reading
Panamanian officials question declared payments for Enrique Iglesias, Julio Iglesias, Alejandro Sanz and other artists Enrique Iglesias, Alejandro Sanz and Julio Iglesias are among the artists named in an investigation by Panamanian tax authorities into possible tax evasion, concerning money they received for concerts in that country. According to an… – Continue reading
Evading and avoiding tax through the use of offshore structures and arrangements is the source of much tax loss, according to HM Revenue & Customs. No surprise then that the current Government (and the coalition before it) has been relentless in its crackdown on it, with a special focus on… – Continue reading
Executive summary A new bilateral Tax Arrangement between the Netherlands and Curaçao (TANC), which essentially functions as a tax treaty,1 was ratified by the Dutch Parliament and formally published on 9 October 2015. The TANC will apply to income received on or after 1 January 2016. This long-awaited TANC will… – Continue reading
The local implications for the Foreign Accounts Tax Compliance Act (FATCA) are far reaching. So said First Caribbean International Bank (FCIB) representative Norlan Gabriel, who was a panel member on NBC Radio’s “Views on Issues” programme last Sunday. The latest edition of the radio programme was aimed at disseminating information… – Continue reading
Facebook was last night accused of insulting British taxpayers as it emerged staff in London have been lined up for a £250million shares jackpot. The huge windfall will be paid out over the next three years if the US social media firm, which paid just £4,000 in corporation tax last… – Continue reading
On 17 September, 2015, China State Administration of Taxation (SAT) released the Discussion Draft for the Implementation Measures for Special Tax Adjustments (“Discussion Draft”), as a complete revamp to the existing trial version of the Implementation Measures, i.e., Circular 2. Circular 2 has been serving as a backbone transfer pricing… – Continue reading
The Chartered Institute of Taxation has criticized the UK Government for proceeding with plans for a strict liability criminal offense for failing to declare offshore taxable income or gains. Under the proposals, magistrates would be given the power to impose an unlimited financial penalty and a custodial sentence of up… – Continue reading
Australia’s new Serious Financial Crime Taskforce (SFCT) is to launch investigations into serious international tax evasion and “phoenix activity” over the next two years. The SFCT has been operational since July 1 and, as of October 14, there are eight matters under investigation. More than 580 tax audits have been… – Continue reading
KEY POINTS What is the issue? Guernsey will be required to gather data for the calendar year 2016 for reporting under the Common Reporting Standard (CRS) in 2017. What does it mean for me? Practitioners should be aware that due diligence and reporting procedures are set to be amended and… – Continue reading
The number of banks with deferred prosecution agreements with the U.S. government keeps growing. The subject is tax evasion involving American account holders. Today, under FATCA, banks everywhere want to know if you are compliant with the IRS. And the IRS keeps updating its list of foreign banks where offshore… – Continue reading
The rising wealth of Asia Pacific nations, including Singapore, means more and more people have looked internationally for opportunities to invest in overseas property markets. Recent stock market events have shown the importance of a diversified portfolio capable of riding out the storm when economic conditions put immense pressure on… – Continue reading
Concerned about the impact of tax havens, world powers are tightening the noose on multinationals seeking tax advantages. India wants changes to its tax treaty with Mauritius, forcing the island’s new government to re-examine its business model and focus elsewhere. There is debate in the new government, which took office… – Continue reading
HONG KONG: Pakistan and Hong Kong SAR signed a landmark agreement for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income on Friday, a statement said. The agreement once implemented by Pakistan and Hong Kong SAR would encourage investment and business between the… – Continue reading
The details of the recently signed Income Tax Treaty between Jersey and Rwanda have become available. The treaty was signed on 26 June 2015. The treaty will come into force after the two countries exchange ratification instruments. The provisions of the treaty will have effect from 1 January of the… – Continue reading
South Africa is allowing MTN potentially lucrative tax credits on money sent from its African operations to a letterbox company in Mauritius. Last week, amaBhungane and Finance Uncovered, a global reporting project, exposed how MTN’s African subsidiaries send billions in management fees to MTN International in Mauritius. The Mauritian entity… – Continue reading
The Internal Revenue Service (IRS) has released a revised October 2015 version of its Publication 597, which provides information on the United States-Canada double taxation agreement (DTA), reports Tax News. A number of DTA provisions that most often apply to US citizens or residents who may be liable for Canadian… – Continue reading
NEW DELHI: The Vodafone Group has started “preparatory work” for an initial public offering of its Indian unit, although no dates have been set yet, the British telecom company’s CEO said, expressing optimism about the emergence of a new India. Vodafone CEO Vittorio Colao, however, argued against the government’s proposal… – Continue reading
Golden visa EU citizens may freely register as residents in Portugal. However, non-EU citizens may also obtain residence in Portugal if they obtain a ‘golden visa’ by participating in investment activity and fulfilling certain requirements. Requirements Obtaining a golden visa requires one of the following types of investment: acquisition of… – Continue reading
Permanent Establishment Based on the new treaty the definition of permanent establishment also includes a building site or construction or installation project or any supervisory activities in connection with such site or project constitutes a permanent establishment only if it lasts more than 9 months. Dividends The withholding tax rate… – Continue reading
The Canada Revenue Agency (CRA) rents office space from a Vancouver-based property developer – a company that exploits offshore tax havens in Liechtenstein, the British Virgin Islands and Channel Islands. Larco Investments Ltd. owns three buildings in Montreal, Calgary and Edmonton where they rent office space to the CRA. Larco… – Continue reading
The Dutch government presented its Tax Bill 2016 on 15 September 2016. Three elements of this bill could specifically affect multinationals, international investors and investment funds with Dutch headquarters or group companies: The anti-avoidance rules in respect of non-resident taxation of foreign corporate shareholders and the dividend withholding tax treatment… – Continue reading
This summer brought some very significant amendments to the Cyprus tax laws, further enhancing Cyprus’ favourable tax regime. On 17 July 2015, the following laws were amended: The Special Defense for Contribution law No. 117(I) of 2002 as amended; The Income Tax Law No 118(I) of 2002 as amended; and… – Continue reading
HM Revenue and Customs (HMRC) has succeeded against a £200 million tax avoidance scheme which exploited the UK’s double taxation agreement with the Isle of Man, whereby people are not taxed on the same income in both the UK and the Isle of Man. Those who took advantage of the… – Continue reading
The chief of the generic drug company discussed her “counterintuitive” strategy for creating U.S. jobs. Mylan is one of a handful of U.S. companies that has recently completed a controversial tax inversion, as the generic drug company moved its official base to the Netherlands earlier this year. While the decision… – Continue reading
Individuals and families whose tax plans include trusts should take note of the recent decision of the Supreme Court of Newfoundland and Labrador in Discovery Trust v Minister of National Revenue (“Discovery Trust”)1 – the first case to deal with the issue of the residency of a trust for provincial… – Continue reading
A series of recent developments means that tax is now a key part of the Australian foreign investment regime and the foreign investment rules have significantly more bite. When determining whether a foreign investment proposal is “contrary to the national interest”, the Foreign Investment Review Board (FIRB) actively considers the… – Continue reading
The TIGTA audit was initiated to assess the IRS’s progress in implementing the FATCA. WHAT TIGTA FOUND TIGTA found that the IRS has taken steps to provide information to affected stakeholders that Tigtalogo explains the FATCA requirements and expectations. However, TIGTA identified improvements that are required to ensure compliance and… – Continue reading
FATCA was passed to prevent U.S. citizens from evading tax by focusing primarily on foreign financial institutions with U.S. account holders. The Foreign Account Tax Compliance Act (FATCA) was enacted as part of the 2010 Hiring Incentives to Restore Employment Act, and its provisions became effective as of 7/1/14. FATCA… – Continue reading
Labor has accused Prime Minister Malcolm Turnbull of not playing by the same rules as the rest of the country by investing in funds based in a notorious tax haven. The attack was launched by Labor senator Sam Dastyari who used parliamentary privilege to accuse the prime minister of inappropriate… – Continue reading
LOS ANGELES—The Armenian National Committee of America – Western Region (ANCA-WR) is expressing its appreciation to Congressman Ted Lieu for authoring a letter to U.S. Treasury Secretary Jacob Lew in support of a U.S.-Armenia Double Tax Treaty. The accord, if concluded, would, by limiting the prospect of double taxation, remove… – Continue reading
MUMBAI: The Central Board of Direct Taxes (CBDT) on October 13 signed four unilateral advance pricing agreements (APAs), including India’s second APA with a rollback provision. The nature of the transactions covered under these agreements varied from software development to share price valuation. According to government sources, the total number… – Continue reading
The Organization of Economic Cooperation and Development (OECD) released its final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) Project on Monday October 5th, 2015. The final package of BEPS measures includes new minimum standards on: country-by-country reporting, which for the first time will give tax administrations a… – Continue reading
Information on Completing the Form 8802, Application for United States Residency Certification Many U.S. treaty partners require the IRS to certify that the person claiming treaty benefits is a resident of the United States for federal tax purposes. The IRS provides this residency certification on Form 6166, a letter of… – Continue reading
No focus on stock markets and other money-laundering machines After all the noisy assertions, only Rs4,147 crore of unaccounted wealth was declared during the special 90-day compliance window of the The Undisclosed Foreign Income and Assets (Imposition of Tax) Act, 2015 (Black Money Bill). Of this, just Rs2,488 crore will… – Continue reading
Staff Correspondent The National Board of Revenue on Monday started negotiations with Bhutan to sign an agreement on avoidance of double taxation and prevention of tax evasion and capital flight from the country. A five-member delegation led by NBR chairman Md Nojibur Rahman has been carrying out the first round… – Continue reading
Ireland, whose corporate tax rate of 12.5 percent is already one of the lowest in the developed world, said it would cut that rate in half for a new tax category — one covering revenue pegged to companies’ patents and other intellectual property. The Irish government, long criticized by other… – Continue reading
Bangladesh is set to sign an agreement with Bhutan to avoid double taxation to boost investments, trade and facilitate information exchange between the two Saarc nations, the National Board of Revenue said in a statement. A team led by NBR Chairman Md Nojibur Rahman is now in Thimpu to take… – Continue reading
Israeli importers and exporters, hi-tech and trading groups will all be in the base erosion and profit shifting firing line. On October 5 the Organization for Economic Cooperation and Development published a final comprehensive package of measures aimed at multinational corporations, large and small, that engage in BEPS – base… – Continue reading
The tax world followed with great interest today´s launch of the final package of BEPS. Having the BEPS report finalized is indeed a great achievement and, as pointed out by Mr. Angel Gurría, OECD Secretary General, in his Twitter, “Agreement of #BEPS package is a historic day in our effort… – Continue reading
PwC welcomes this effort to update international tax system and boost transparency. The tax landscape has been transformed by the globalisation of business and the advent of the digital age. We believe the existing international tax rules need to be modernised to reflect how business is done today, and it… – Continue reading
An independent panel appointed by Bank Leumi Le-Israel Ltd. recommended that a former chairman and chief executive officer both return bonuses after the lender agreed to pay a fine to U.S. authorities in a tax probe. An insurer for the former bank officials will pay an additional $92 million. Leumi,… – Continue reading
During Sushma Swaraj’s visit, the nations also sign pacts on avoidance of double taxation and tax information exchange New Delhi: India and the Maldives have drawn up a new blueprint for bilateral ties that included closer economic and defence cooperation, pointing to a thaw in the relations following the Maldives’… – Continue reading
Ireland’s budget 2016 will be announced tomorrow, 13 October 2015, and it is expected that additional detail on the research and development (R&D) tax incentive known as the “knowledge development box” would be provided in the budget 2016 statement. The “knowledge development box” is a tax rate for income generated… – Continue reading
Hong Kong (HKSAR) – The Government will, in the light of stakeholders’ views collected during consultation, refine the legislative proposals for implementing in Hong Kong the new international standard on Automatic Exchange of Financial Account Information in Tax Matters (AEOI), a government spokesman said today (October 12). Hong Kong pledged… – Continue reading
EBENE, Mauritius, Oct 12 (Reuters) – Mauritius plans to launch a trading platform to hedge African currencies against the U.S. dollar, part of a bid to expand its role as a financial hub for the continent, the financial services minister said. The Indian Ocean island is also in talks to… – Continue reading
A blistering attack on major countries who brand offshore financial centres as tax havens has been launched by Bob Richards. The Minister of Finance warned that pressure on the offshore sector from abroad will continue into the foreseeable future. Mr Richards, speaking at the launch of a British Virgin Islands… – Continue reading
Historically, unlike UK residents who are generally liable to CGT on disposals of UK residential property (other than their principal residence), non-residents have been able to dispose of such property potentially free from UK CGT. The UK government sought to address this inconsistency by introducing a CGT charge in the… – Continue reading
A former head of Australia’s anti-money-laundering agency wants tough rules introduced to prevent the country from becoming a safe haven for foreign corrupt funds. Despite credible warnings that large volumes of illicit money leaving China are being laundered in Australia, an investigation by ABC programme Four Corners has found no… – Continue reading
