The United States has implemented laws and policies, such as the soon-to-be-activated FATCA legislation, which have redounded to the expense of Caricom territories. The Caribbean regional integration project is often described and criticised almost entirely on the uneven benefits of trade to member countries. But, important as it is, there… – Continue reading
Dubai – Cyprus’ recently revised taxation framework make sit the only citizenship-by-investment program in Europe to offer non-domiciled investors tax free profits. Will this new tax regime and business incentives attract more foreign direct investment (FDI) into the country? Henley & Partners, the global leaders in residence and citizenship planning… – Continue reading
Management and procurement services not taxable as “fees for technical services” under the India-UK income tax treaty: India’s Authority for Advance Rulings concluded that services rendered by a group director to its group company in India were “managerial services” that, as rendered by the UK procurement team, did not make… – Continue reading
Amit Ramnani, director of Ipanema Wealth, an independent financial consultancy firm, discusses the key issues facing U.S. expatriates. RIO DE JANEIRO, BRAZIL – Many United States citizens living overseas are unaware of the potential tax liabilities they could be facing in near future. To help out the Rio-based firm Ipanema… – Continue reading
South African companies who do direct and indirect business with US organisations, whether in South Africa, Africa, Europe or further afield, must comply with the United States Foreign Account Tax and Compliance Act (FATCA,) or risk being excluded from lucrative markets the world over, reports the Cape Business News. This… – Continue reading
Introduction Individuals whose domicile of origin is outside United Kingdom Non-UK individuals with UK domicile of origin Consultation and legislation New inheritance tax rules for UK residential property held within offshore corporate envelopes Comment Introduction Individuals domiciled outside the United Kingdom might have been justified in thinking that they would… – Continue reading
FOR MANY YEARS countries around the world have been engaging in the automatic exchange of information in order to tackle offshore tax evasion and other forms of non-compliance. The Organisation for Economic Cooperation and Development (OECD) has been active in facilitating automatic exchange of information by creating the legal framework,… – Continue reading
IN THE LAST TEN YEARS the international community has tried to pressure Barbados into signing tax information exchange agreements. Successive administrations, however, have resisted by continuing to show preference for double taxation treaties. That has not stopped the pressure, and some would argue that in some ways the global players… – Continue reading
International finance centers play a significant role in Russian foreign direct investment (FDI). For example, in 2012 it was observed that 11 of the 40 main recipients of Russian FDI were IFCs. Of these finance centers, the largest recipients were the BVI, the Cayman Islands and Cyprus. Despite the popularity… – Continue reading
In May of 2012, and soon before Facebook’s IPO, Eduardo Saverin renounced his U.S. citizenship. Saverin was a co-founder of the social-networking site, and the consensus was that he gave up his citizenship to avoid U.S. taxes that would be levied after the offering. Saverin was widely denounced for his… – Continue reading
The following article by Dr Monica Galea John, partner in the Financial Services Department, analyses the manner in which the Fourth EU Anti Money Laundering Directive (the “Directive“) which has just made its way through the EU’s legislation, obliges, for the first time, EU member states to maintain central registers… – Continue reading
In short… The current balance of competences between the EU and the UK on tax is quite intricate, with a tension between member states’ desire to determine their own tax systems and the EU-led aim of a level playing field. The EU most obviously influences member states’ indirect taxation (particularly… – Continue reading
The Internal Revenue Service has issued additional informal guidance regarding implementation of the Foreign Account Tax Compliance Act (FATCA). First, the IRS published a new “Frequently Asked Question” on its website addressing form and documentary evidence received by facsimile or email. The text of the guidance, which states that withholding… – Continue reading
ABU DHABI, Aug. 16 (Xinhua) — A current visit by Indian Prime Minister Narendra Modi to the United Arab Emirates (UAE) is a proof of growing cooperation between India and the Gulf state, UAE Minister of Foreign Affairs Sheikh Abdullah bin Zayed Al-Nahyan said on Sunday. In a statement carried… – Continue reading
Luxembourg currently has 76 income tax treaties in force, and there are 29 treaties under negotiation. Tax treaties can provide a legal framework not only for the avoidance of double taxation and fiscal evasion, but also for international administrative cooperation between Luxembourg and its treaty partners in terms of mutual… – Continue reading
Americans who believe the region is a safe tax haven to hide money and investments overseas should think twice as Caribbean trade bloc countries are moving to full comply with a new U.S. law designed to catch tax dodgers who stash assets in foreign destinations. The Foreign Account Tax Compliance… – Continue reading
The U.S. and China enjoy increasingly strong connections. Yet virtually no Chinese family or business relishes dealing with the Internal Revenue Service (IRS). American tax laws are famously complex, and dealing with the IRS can be like quicksand. Of course, whether they like it or not, U.S. citizens and green… – 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
Artisan goods marketplace Etsy Inc., which promised to be a beacon for transparency as a public company, recently implemented a strategy that shrouds its offshore tax-cutting arrangements in secrecy. Because of a change in how its Irish subsidiary is registered, Etsy no longer needs to publicly disclose basic financial information… – Continue reading
U.S. COMPANIES HOLDING CASH ABROAD WAITING FOR TAX REFORM. The high U.S. tax rate continues to encourage companies to stash cash and profits offshore while executives wait for tax reform. The Street has an interview with computing giant Cisco’s CFO Kelly Kramer on the company’s plans for more the more… – Continue reading
In his summer budget the first exclusively Conservative one in 19 years British Chancellor George Osborne outlined several key changes for non-domiciled individuals or non-doms, reports MENAFN. These major modifications coming into effect in April 2017 arguably represent the biggest shake-up to the non-dom status since it was first introduced… – Continue reading
A new income tax treaty between the Bulgaria and the United Kingdom was signed in March 2015. The treaty, once it is ratified and enters into force, will replace the existing income tax treaty (1987). The new income tax treaty includes measures that differ from the provisions under the current… – Continue reading
A clarifying statement agreed by the UK Treasury and the Ministry of Justice about Guernsey’s position within the OECD bolsters the island’s attractiveness as a fund domicile, according to Guernsey Finance, the promotional agency for the island’s financial services industry. Representatives of Guernsey’s Government, the regulator, and industry bodies have… – Continue reading
Returning expatriates and new migrants who have transferred foreign pension schemes to New Zealand face potential tax penalties if they fail to take advantage of an Inland Revenue Department (IRD) amnesty on non-compliant returns. “We’ve seen a lot of Bay of Plenty people falling into the category and often it’s… – Continue reading
MUMBAI: High net-worth individuals who have invested in residential properties in the UK, will now have to deal with the issue of inheritance tax, which their heirs are unlikely to escape from. In its budget introduced in Parliament in June, the UK plugged a loophole that enabled foreign property buyers… – Continue reading
The Polish Ministry of Finance has published the text of the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income as concluded on July 13, 2015 between The Republic of Poland and the Federal Democratic Republic of Ethiopia (Hereafter: the… – Continue reading
The rise of Islamic finance and sukuk issuances have brought with it a growing phenomenon: Shariah banking is increasingly taking advantage of offshore banking jurisdictions, and this for a number of reasons, reports the Gulf Times. Many offshore centres around the world meanwhile offer a wide range of features allowing… – Continue reading
The Danish government is hopeful ratification of the convention for avoidance of Double Taxation agreements (DTA) with Ghana — and the Prevention of Fiscal Evasion with respect to taxes on income and capital gains between the two countries — will help to double Denmark’s investment in the country. This brings… – Continue reading
LONDON (Reuters) – Greek shares rose on Tuesday after the indebted euro zone country clinched a multi-billion euro bailout agreement with its international lenders. The latest bailout deal for Greece also resulted in the country’s sovereign borrowing costs falling back. Athens’ benchmark ATG equity index rose 1.2 percent, while the… – Continue reading
FATCA refers to provisions contained in the Hiring Incentives to Restore Employment Act (the ‘HIRE’ Act) signed into law on 18 March 2010 in the United States. The main purpose of FATCA is to identify and gather information on US persons who may be evading tax through the use of… – Continue reading
In his summer budget the first exclusively Conservative one in 19 years British Chancellor George Osborne outlined several key changes for non-domiciled individuals or non-doms, reports MENAFN. These major modifications coming into effect in April 2017 arguably represent the biggest shake-up to the non-dom status since it was first introduced… – Continue reading
The Senate’s No. 2 Democrat is calling on an American fertilizer company to keep its official address in the U.S. CF Industries, now based in Deerfield, Ill., announced last week that it would buy a range of facilities from a Dutch competitor, OCI, in an $8 billion deal. As part… – Continue reading
Surprising as it may seem, most of the advantages of the Cypriot Tax Regime were, up until recently, mostly directed to non- Cypriot Tax residents. This effectively meant that in order to enjoy the full benefits of the Regime one had to be a non-resident. The idea behind this was… – Continue reading
A new income tax treaty between the Bulgaria and the United Kingdom was signed in March 2015. The treaty, once it is ratified and enters into force, will replace the existing income tax treaty (1987). The new income tax treaty includes measures that differ from the provisions under the current… – Continue reading
Cayman Islands Tax Information Authority v 1. MH Investments, 2. JA Investments – CICA No. 31 of 2013; G391/2012 The Court of Appeal in rejecting the appeal of the Tax Information Authority against the decision of Mr Justice Quinn in MH Investments Ltd and JA Investments Ltd1 has confirmed in… – Continue reading
On July 29, 2015, Charles Boustany (R-LA) and Richard Neal (D-MA) released a bipartisan discussion draft of proposed Internal Revenue Code (the “Code”) amendments that would cut the United States income tax rate on corporate profits generated from patents and certain other intellectual property to approximately 10% (the “Tax Rate… – Continue reading
After its ratification by all EU member states, the EU-Ukraine Association Agreement will constitute a solid base for comprehensive reforms in Ukraine. The agreement, which includes a deep and comprehensive free trade area, is a pioneering document which will not only open up our markets further but also address competitiveness… – Continue reading
The $100 billion is flowing across borders in search of takeovers and start-up ventures. Developing countries are losing around $100 billion a year in revenues because foreign investors are channelling profits through offshore zones to avoid tax, a study by U.N. think-tank UNCTAD said. “Tax avoidance practices therefore are responsible… – Continue reading
On August 7, 2015 the OECD published a Common Reporting Standard Implementation Handbook (Hereafter: the Handbook). According to the introduction included in the Handbook, the purpose of the Handbook is to assist government officials in the implementation of the Standard for the Automatic Exchange of Financial Account Information in Tax… – Continue reading
In a new update on the financial status of the UAE, the International Monetary Fund (IMF) has advised additional taxation among several options for the UAE government to further strengthen its revenue base in order to minimise dependence on the fluctuating global oil price, reports the Emirates 24/7. The UAE… – Continue reading
SEOUL, Aug. 6 (Yonhap) — The top court ruled Thursday against an oil company of the United Arab Emirates, headed by a member of the Abu Dhabi royal family, saying that it must pay millions of dollars in stock trading tax to South Korea. IPIC International B.V. (IPIC), a state-run… – Continue reading
The Labuan International Business and Financial Centre is attempting to encourage more Indonesian companies to register in the jurisdiction to take advantage of its low-tax regime and trading and investment links with key economies in the Asia-Pacific region. The Labuan IBFC held the Jakarta chapter of its ASEAN (Association of… – Continue reading
A judge’s ruling that the Cayman Islands Tax Information Authority acted unlawfully when it handed over a trove of documents on two Cayman-registered companies to Australian tax authorities has been upheld by the Court of Appeal. The court ruled that the decision to provide documents, requested as part of an… – Continue reading
SINGAPORE’S easiest days as a financial hub are over. The city remains a gateway to Asia, a great base for basing multinationals, settling lawsuits and parking money. But elsewhere, the city is being sidelined; the worry is that is a sign of things to come. In just 50 years, the… – Continue reading
Muscat – H E Christian Winter, Switzerland’s Ambassador to Oman has said that the recently signed Double Taxation Agreement (DTA) between his country and the sultanate reflects the broader ties Switzerland seeks with GCC. “The conclusion of the agreement takes into account the growing economic and political importance of the… – Continue reading
Since 2013, investment institutions have started to increase their investments in private healthcare institutions in mainland China. Though there hasn’t been a real local healthcare group, the modes of investment have become diversified, including the acquisition of healthcare institutions, the establishment of new healthcare institutions and the transformation of public… – Continue reading
Tax evasion by Canadian companies using offshore havens promises to become election issue Canadian corporations that use tax havens like Switzerland and the Cayman Islands to reduce the taxes they pay at home have good reason to worry. The Canada Revenue Agency (CRA) has been stepping up its scrutiny of… – Continue reading
HMRC has won £45 million in a second tax avoidance case against Abbey National Treasury Services, a subsidiary of Santander. The tribunal ruling means £45 million is now liable to taxation in addition to another £40 million in a second case that will be decided by this ruling. The scheme… – Continue reading
The Davis Tax Committee’s First Interim Report on Estate Duty (“DTC Report”) was released for public comment on 13 July 2015. In essence, the DTC Report proposes that “a highly progressive tax that patches loopholes, helps provide equality of opportunity and reduces the concentration of wealth, must be implemented”. The… – Continue reading
A challenge by way of judicial review to notices issued by HM Revenue & Customs (HMRC) requiring “accelerated payment” of tax pending the outcome of a tax dispute has been dismissed by Mrs Justice Simler DBE in the High Court.04 Aug 2015 Tax Disputes and Investigations Litigation & International Arbitration… – Continue reading
