Introduction Tax avoidance, however legitimate its mechanism, has become the new focus for public opprobrium in parts of the world. High-profile cases and media attention examining the tax strategies of major global companies operating primarily in the digital economy have all contributed to this shift of focus. How are the… – Continue reading
(Special) — The recent slump in oil prices is causing many Canadian investors to move their money from energy-weighted markets at home to foreign markets for better yields. While this may be a profitable investment strategy, it also can create its own set of problems because many investors may not… – Continue reading
Ruling opens door for HM Revenue & Customs (HMRC) to recoup losses from other firms which used rate-booster schemes High street retailer Next has been hit with a £22.4m tax bill after a court found that it diverted profits made in the UK to offshore havens to avoid paying tax…. – Continue reading
In July 1997, Tyco International (with then Wall St darling Dennis Kozlowski at the helm) was “acquired” by a relatively small provider of home security services, known as ADT Inc. The deal arguably exploited some strategic synergies between the two companies, but far and away the biggest benefit to Tyco… – Continue reading
The advantages of off-shore investments Two of the top reasons that South African investors are given to encourage offshore investments are that going offshore diversifies your portfolio and that it gives you access to sectors you could never find on the resource-heavy JSE. “While those are not reasons to be… – Continue reading
Georgia’s freshman Senator David Perdue is a big advocate of the Fair Tax – a proposal long linked to the Peach State that calls for replacing federal income taxes with a national sales tax on all goods and services. Perdue talked up the plan in the GOP primary and general… – Continue reading
SEOUL – Tax authorities in Korea are aiming to stamp out tax evasion by requiring taxpayers to declare all of their overseas investments. On May 18th the National Tax Service of Korea issued a statement announcing that taxpayers will now be required to submit detailed information about investments or properties… – Continue reading
THE BJP-led National Democratic Alliance government, which had made a lot of noise about black money and the illegal stashing of funds abroad in the run-up to general elections last year, finally got down to some serious work to tax ill-gotten wealth and curb its growth. Last week, the government… – Continue reading
This note is intended as an introduction to inheritance tax (IHT) issues that need to be covered where a “non-dom” (an individual domiciled outside the UK) is planning on becoming resident in, or is already resident in, the UK. It should be emphasised that this is a complex subject, and… – Continue reading
SEOUL, March 17 (Yonhap) — The South Korean business community on Tuesday called for easing the tax audit burden and more deductions for corporate entertainment outlays to better reflect the rise in overall expenses. In a meeting with National Tax Service Commissioner Lim Hwan-soo in Seoul, companies belonging to the… – Continue reading
SEOUL, March 17 (Yonhap) — The South Korean business community on Tuesday called for easing the tax audit burden and more deductions for corporate entertainment outlays to better reflect the rise in overall expenses. In a meeting with National Tax Service Commissioner Lim Hwan-soo in Seoul, companies belonging to the… – Continue reading
The big miners were sprung for their Singapore profits sling, and the United States tech giants shown up for their Byzantine tax structures, but there was little time left to spend on other sectors where multinational tax chicanery was rife. When the Senate Inquiry into Corporate Tax Avoidance reconvened to… – Continue reading
ISLAMABAD: As corridors of power struggles to enhance tax collection, the state is taking a proposal that could see levy of 10% tax on profit made on foreign remittances put in savings accounts. The offer appears as the government doubts that the amount sent through remittances could be black money… – Continue reading
Subsidies that make borrowing irresistible need to be phased out THE way that black holes bend light’s path through space cannot be smoothed out by human ingenuity. By contrast, a vast distortion in the world economy is wholly man-made. It is the subsidy that governments give to debt. Half the… – Continue reading
Introduction to FATCA On December 16 2013 Malta and the United States entered into an intergovernmental agreement (IGA) to implement rules and regulations under the Foreign Account Tax Compliance Act (FATCA). FATCA, enacted in 2010 by the United States, requires US taxpayers and financial institutions to report financial information to… – Continue reading
AUDITED ACCOUNTS – 30 JUNE 2015 FUND ANNUAL RETURN – 30 JUNE 2015 US FATCA – 30 JUNE 2015 RECORD KEEPING – IMMEDIATE TIGHTENING ATTITUDE OF THE COMMISSION TO LATE FILINGS Over the last six months we have seen that the British Virgin Islands (“BVI”) Financial Services Commission (the “Commission”)… – Continue reading
The minimum alternate tax row has damaged the credibility of government promises to enforce an investor-friendly tax regime and made the Indian stock market Asia’s worst performer this year New Delhi/Mumbai: Castleton Investment Ltd, a unit of GlaxoSmithKline Plc (GSK), in 2012 asked an arm of the Indian finance ministry… – Continue reading
House Foreign Affairs Committee Chairman Ed Royce (R-CA) and Congressional Armenian Caucus Co-Chair Frank Pallone (D-NJ) were among the first Congressional leaders to welcome the May 7th signing of the U.S.-Armenia Trade and Investment Framework Agreement (TIFA), a longstanding policy priority for the Armenian National Committee of America (ANCA). Chairman… – Continue reading
FOR NRIs wishing to invest in property in India, there are a variety of factors to be considered. A NRI can transfer any immovable property held to an Indian resident. However, he can transfer the property in India (other than agricultural land, plantation property and farm house) to a person… – Continue reading
Saudi Arabia is interested in increasing the trade turnover with Azerbaijan, Minister of Commerce and Industry of Saudi Arabia Tawfiq bin Fawzan Al Rabiah said at the Azerbaijani-Saudi Arabian business forum in Baku May 15. “Although Azerbaijan and Saudi Arabia signed the intergovernmental agreements on elimination of double taxation and… – Continue reading
HE Obaid Humaid Al Tayer, Minister of State for Financial Affairs, received HE Philip Parham, UK ambassador to the UAE at the Ministry of Finance (MoF) premises in Abu Dhabi. The two parties discussed the bilateral economic relations between the countries and the latest development regarding the rounds of negotiations… – Continue reading
India is well on its way towards achieving meaningful financial sector reform and development, and time is of essence. Last month, the International Monetary Fund (IMF) stated that India will overtake China as the world’s fastest growing economy in 2015, buoyed by a rising middle-class, a young population, and competitive… – Continue reading
A Protocol amending the Agreement for the Avoidance of Double Taxation and Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital between South Africa and Cyprus was signed on the 1st of April 2015. According to the Protocol, Article 10 (“Dividends”) of the Double Tax Treaty… – 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
FATCA reporting commences In our March client briefing we noted that the Tax Information Authority in the Cayman Islands (“TIA”) had launched its online portal for the automatic exchange of tax information (the “AEOI Portal”), which can be accessed from its website (www.tia.gov.ky). The deadline for reporting Cayman Islands financial… – Continue reading
“Uruguay has now definitely earned its long-time nickname — the Switzerland of Latin America.” That’s what I wrote several months ago during my first visit to this small, south Atlantic costal country wedged between Brazil and Argentina. For the last week, I have been enjoying my second visit to Uruguay,… – Continue reading
On May 11, 2015, the Cayman Islands announced the extension of its FATCA registration and reporting deadlines, as follows: Registration Each Cayman Islands investment entity that has been classified as a “Reporting Cayman Islands Financial Institution” for purposes of FATCA (or its “sponsoring entity,” if applicable) should register with the… – Continue reading
Glencore is under audit by the Australian Taxation Office for the low level of taxes it pays, claiming billions in “losses” overseas and resorting to low-tax or no-tax nations such as Bermuda, Singapore and the Cayman Islands. The Swiss-based mining giant revealed it was being investigated by the ATO in… – Continue reading
Current international tax rules are based on principles that have not kept up with globalisation and the rise of the digital economy. Over the years the rules have been patched up but, almost two years ago, the Organisation for Economic Co-operation and Development (OECD), acknowledging that a substantial overhaul was… – Continue reading
Georgia is stepping up cooperation in taxation, customs affairs and a number of other avenues with Cyprus, Liechtenstein and Iceland. Finance Ministers of Cyprus, Liechtenstein and Iceland signed a cooperation agreement with Georgia on avoidance of double taxation, prevention of evasion of income and capital taxes in Tbilisi today. Georgia’s… – Continue reading
In 2014, Canadian corporations sent nearly $200 billion offshore, costing us nearly $8 billion in tax revenue. Ottawa (12 May 2015) — Figures released by Canadians for Tax Fairness (CTF) (link is external) show that the amount of money Canadian corporations are keeping in tax havens has jumped to record… – Continue reading
President Putin coined a new word in his state of the nation address at the end of 2012, when he called for new measures for the “deoffshorisation of our economy”, reports the International Business Times. This was to become a major addition, not just to the Russian vocabulary but to… – 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 Chinese government has been paying close attention recently to the effects of offshore entities having ownership or control of Chinese companies or assets. Following the release of the draft Foreign Investment Law in January 2015, the State Administration of Taxation (SAT) issued a Bulletin on the tax treatment of… – Continue reading
The Ministry of Finance (MoF) recently organised a consultative meeting at its premises in Abu Dhabi; which was attended by key UAE foreign investment partners at a federal and local level. The meeting covered future plans to grow the UAE’s network of double taxation avoidance as well as protection and… – Continue reading
I. VAT and Customs In many cases, the principal in the contract manufacturing relationship owns some or all of the raw materials, work-in-process and finished goods throughout the manufacturing process. The principal and many of the suppliers are typically outside of the manufacturing jurisdiction. 1. Generally Speaking, What Are The… – Continue reading
Efforts by the Australian government to combat money laundering could have a highly impact effect upon the huge revenues its reaping from foreign purchases of domestic property. Regulators have recently come under fire for failing to adequately monitor foreign acquisitions of Australian real estate and ensure that they are in… – Continue reading
On 5 May 2015 the Federal Supreme Court rendered its long awaited decision on a withholding tax (WHT) reimbursement claim related to Total Return Swaps. The case was based on essentially the following facts: a Danish bank entered into swap contracts with clients in England, Germany, France and the US…. – Continue reading
On 1 April 2015 the British Virgin Islands (BVI), Cayman Islands and 19 other jurisdictions were removed from Italy’s blacklist of jurisdictions. As a result it will now be easier for Italian individuals and companies to engage in business with those based in the Cayman Islands and the BVI. The… – Continue reading
South African companies are unable to compete with multinationals selling goods and services online in the country, partly as a result of tax laws. This is according to financial services group PwC, which argues that the country has not kept pace with the changing global economy. “Currently, multinationals in the… – Continue reading
JAKARTA: Indonesia is considering cutting its corporate tax rate to as low as 17.5 per cent from 25 per cent to attract more investment from companies that are operating in the region, a tax ministry official said on Monday. Indonesia, which posted the weakest economic growth since 2009 in the… – Continue reading
A mixed bag of topics for this week’s edition of Lifelines: ‘Gaijin card’ deadline looms First up are the new residence cards, which have replaced the old alien registration cards (aka gaijin cards) for foreign residents. If you are still using your old card, be aware that the deadline for… – Continue reading
The government should stop looking for more borrowed money and take immediate steps for resource mobilisation to overcome fiscal deficit Taxation is a lot like sheep shearing. As long as you shear a sheep, it will continue to produce a new crop of wool but you can skin the animal… – Continue reading
After finding them guilty of manipulation in the stock market for making illegal gains, Sebi has restrained the 178 entities, including Pine Animation, from accessing the securities market. In a fresh clampdown on misuse of stock market platform for suspected money laundering activity, Sebi today banned Pine Animation and 177… – Continue reading
ISLAMABAD: As authorities struggle to increase tax collection, the state is considering a proposal that could see a levy of 10% tax on profit made on foreign remittances placed in savings accounts. The proposal comes as the government suspects that the amount sent through remittances could be black money being… – Continue reading
It may be time for another letter from Tom Cotton. Cotton, the Republican senator from Arkansas, had been in office only a few weeks back in March when he got 46 senators to sign on to an open letter to the leadership of Iran. The letter pointed out that agreements… – Continue reading
THE THAWING OF RELATIONS between the United States (US) and Cuba will open up the opportunity for Barbados to “serve as an intermediary for investment into Cuba”. But two prominent American lawyers, including one who advises Government, have warned that the “on paper” advantage Barbados has under its double taxation… – Continue reading
New Delhi: Market regulator Securities and Exchange Board of India (Sebi) has asked bourses to take immediate action against entities involved in misuse of stock exchange system for tax evasion, Parliament was told Friday. Preliminary enquiries conducted by the regulator in the recent past, inter alia, indicate that certain persons/companies… – Continue reading
Two roadshow events in Canada to promote Bermuda as the jurisdiction of choice for captive insurance companies and e-commerce business have been hailed a success. The Bermuda Business Development Agency (BDA) hosted the sessions in Toronto and Calgary this week. It was standing-room only at the first event, in Toronto… – Continue reading
The BSE Sensex dropped over 750 points in intraday trade on Wednesday, its biggest fall since January 6 this year, when the Sensex had plunged over 900 points on global triggers. The Nifty is now firmly below the 200 day moving average, and there’s a big chance that it will… – Continue reading
