The German Fiscal Code provides for the possibility of a voluntary self-disclosure of tax evasion. Taxpayers are able to correct or complete their own incorrect tax returns or furnish relevant information previously omitted. In such cases, the taxpayer will be exempt from criminal prosecution for tax evasion in respect of… – Continue reading
Under Kazakhstan law, generally, both resident and non-resident legal entities may own shares in a Kazakhstan bank. National Bank Pre-Transaction Consent. Generally, there are two thresholds entailing the necessity to obtain the National Bank of Kazakhstan (the ‘NBK’) (financial regulator) pre-transaction consent: (i) “large participant”, whereby an entity controls ≥10%… – Continue reading
MOSCOW, January 13 (RAPSI) – The Russian Government has submitted a bill to the State Duma that would ban state procurement from companies registered in offshore jurisdictions, TASS reports on Tuesday. The provisional bill stipulates that a legal entity registered in a state that provides tax exemptions and does not… – Continue reading
Americans residing in Canada may not realize the extent to which the U.S. government’s tax-filing rules for non-resident citizens hit home. There’s been a lot of attention in recent years on how U.S. citizens in Canada are being targeted by the Internal Revenue Service. Lost in all the commotion is… – 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
The US Foreign Account and Tax Compliance Act is a complex piece of legislation that has, unsurprisingly, triggered a number of enquiries in recent months from advisers seeking to understand the implications for them and their clients. So, what do you need to know? Fatca is a US Internal Revenue… – Continue reading
An announcement is expected imminently on the terms of the long-awaited revised tax treaty between Italy and Switzerland, reports say. According to a report from the ANSA news agency, the push to complete the treaty follows the parliamentary approval of Italy’s new voluntary disclosure program, which allows Italian residents to… – Continue reading
SPECIAL REPORT: IS AMERICA LOSING IT’S CORPORATE SECTOR? Corporate inversions have been the dominant tax issue over the last year and have forced a serious evaluation of the U.S. corporate tax system. While there is widespread agreement that the U.S. corporate tax code is out of step with our global… – Continue reading
South Africa has lost out on billions in tax revenue in the past decade as large corporations, wealthy individuals and criminal syndicates slipped nearly R1-trillion out of the country. A Washington DC research and advocacy group, Global Financial Integrity, believes South Africa suffered “illicit financial flows” totalling more than $122-billion… – Continue reading
Kenya, India to ratify double taxation agreement NAIROBI, Feb. 10 (Xinhua) — Kenya and India will soon ratify an agreement on the avoidance of double taxation, officials said on Tuesday. India’s Deputy High Commissioner to Kenya Sushil Singhal told Xinhua in Nairobi that the ratification of the agreement signed in… – Continue reading
Business editor Duncan Foulkes quizzes three prominent Isle of Man businessmen on their thoughts ——————– Chris Eaton, Chief Executive Officer, The ILS Group There is no one major issue or initiative that faces the CSP and TSP sectors in 2015. Rather, they face more of a continued barrage of supra… – Continue reading
CBDT to make provisions for MAT and reduce tax liability on Reits Jayshree P Upadhyay | New Delhi January 9, 2015 Last Updated at 00:50 IST Real estate investment trusts (Reits), notified last year, have so far found few takers due to taxation-related issues. To address this, the Central Board… – Continue reading
The UK is proposing to introduce a unilateral, non-OECD co-ordinated anti-BEPS provision, referred to in the media as the “Google Tax”, with effect from 1 April 2015. The draft provision is very complex, and it will be time consuming to assess its potential impact on many common cross-border business structures…. – Continue reading
2014 marked a significant increase in the enforcement efforts by the IRS and Department of Justice against non-compliant U.S. taxpayers who failed to report their off-shore bank accounts and earnings. Grand Jury proceedings have been in full force and various criminal proceedings have been instituted. IRS investigations continue to increase… – Continue reading
India enacted transfer pricing rules in 2001, which require companies to conclude international transactions with associated enterprises at an arm’s length. The legislation is primarily targeted at large business groups who engage in base erosion and profit shifting to avoid paying corporate income tax in India. This article is the… – Continue reading
On December 28, 2014 Ukrainian Parliament has adopted the Draft law No. 1264-1 “On amending the Tax Code of Ukraine regarding improvement of tax control over transfer pricing” as of 22.12.2014 (the Draft Law). In order to become effective, the Draft law has to be signed by the President of… – Continue reading
The Cayman Islands government announced it will not implement a central register of beneficial ownership information, but will continue its current method of providing this type of information to law enforcement, tax and regulatory authorities. At the same time, government proposes to enact new legislation that will improve access to… – Continue reading
The Cayman Islands has published a new report stating that, while it will not introduce a central registry of information on the beneficial ownership of companies, it will tighten up its beneficial ownership regime in other areas. The report follows industry consultation between November 2013 and February 2014 and broadly… – Continue reading
Multinationals told to be more cautious about intra-group transactions as Beijing imposes stiff measures against avoidance and evasion Multinationals have been advised to take notice of Beijing’s New Year resolution to crack down on tax avoidance and evasion, especially after the announcement of the general anti-avoidance rule (GAAR) and new… – Continue reading
India is considering removing Cyprus from the blacklist of countries that do not share details about tax evaders after examining information given the island nation, reports from New Delhi have suggested. India had blacklisted Cyprus in 2013 for not sharing information about tax evaders. “They (Cyprus) have given some information…. – Continue reading
The Cayman Islands Government today issued a report stating that it will continue its current method of providing beneficial ownership information to law enforcement, tax and regulatory authorities, as the method adheres to global standards. As explained in its Consultation Report on Maintenance of Legal and Beneficial Ownership Information, Government’s… – Continue reading
In recent court filings made in various federal district courts in Washington and California, the Internal Revenue Service is seeking to enforce testimonial summonses issued to current or former Microsoft employees, including former CEO Steven A. Ballmer. The summons had been issued earlier this fall. Microsoft’s outside tax counsel responded… – Continue reading
On 8th December 2014, the British Virgin Islands Financial Services Commission (FSC) launched the electronic delivery of certificates of good standing for the benefit of users. The digital certificates will have the same security features as the original hard copy and issuers can authenticate these directly via the authentication service… – Continue reading
The Internal Revenue Service has sued former Microsoft CEO Steve Ballmer and a slate of other former and current executives, seeking to compel them to testify in a long-running investigation into how the company’s sales through subsidiaries affected its taxable income. The Internal Revenue Service has sued former Microsoft Chief… – Continue reading
The Budget pensions overhaul has hit the overseas pension market as new rules have been proposed which would remove the requirement for qualifying recognised overseas pension schemes (Qrops) to provide an income in retirement. Current rules around Qrops require that 70% of the amount transferred from a UK scheme has… – Continue reading
Japan has remained a cornerstone of Pakistan’s economy for the past many years. Japanese Companies have invested in all sectors across Pakistan. Be it auto, trading, manufacturing, infrastructure development, packaging, steel manufacturing, indenting, etc a large number of Japanese Companies have a strong presence in Pakistan. Pakistan’s Investment and Corporate… – Continue reading
WASHINGTON, D.C. (WDAM) – This is a news release from the U.S. Senate Finance Committee In a new policy paper, Republican staff of the Senate Finance Committee have proposed major changes to the way the United States taxes its citizens overseas. According to the report, “The United States needs to… – Continue reading
Bravura Solutions reflects on a year of reform and looks forward to 2015. The Chancellor’s Autumn Statement last week didn’t deliver anything as revolutionary as the reforms announced in his March budget, but there were a few early Christmas crackers around ISA rules. After a monumental year, let’s look at… – Continue reading
Transfer pricing has been an area of high importance for years. We are seeing that multinational companies operating in Germany are being increasingly examined by tax auditors. The level of transfer pricing expertise of the tax auditors is also increasing. Therefore, the transfer pricing environment in Germany is getting more… – Continue reading
The New York State Department of Taxation and Finance (the Department) has backed off from an aggressive position that it has been taking in cases involving New York residence issues. Under New York law, a person who is not domiciled in the state can be treated as a resident for… – Continue reading
Heading into the G20 in Brisbane last month, Treasurer Joe Hockey thundered that multinational companies who avoided paying tax were akin to “thieves” whose actions rendered it harder for governments to tackle poverty. Sadly however the government’s actions have failed to match its rhetoric. This week’s crafty back-down on Section… – Continue reading
The German government must revise rules that allow families to transfer companies from one generation to the next without paying estate tax after the country’s top court ruled the current exemption is unconstitutional. The inheritance law gives an unfair advantage to family-owned businesses over individuals passing on non-company assets, the… – Continue reading
Companies will be forced to disclose their ultimate owners on national registers in European Union nations as the bloc seeks to clamp down on tax dodging, money laundering and terrorism financing. European Parliament legislators and representatives of 28 EU national governments struck a deal late yesterday to upgrade the bloc’s… – Continue reading
HM Revenue and Customs (HMRC) has secured almost all of the disputed tax due from the first group of tax avoidance scheme users to receive the controversial Accelerated Payment notices. About 30 scheme users were told in late August they had 90 days to pay a total of around £29… – Continue reading
Last March MEPs voted overwhelmingly to introduce a new transparency disclosure rule that would compel all 28 European states to make publicly accessible the real owners of companies and trusts. The decision was hailed as a major breakthrough by anti-corruption campaigners fighting financial crime and tax abuse. Lawyers working for… – Continue reading
Bermuda’s Minister of Finance, Bob Richards, has snubbed the UK Prime Minister David Cameron’s plan to create public registers of beneficial owners of companies incorporated in Bermuda. His reasoning behind this update was that this move would be damaging to the economy as Bermuda would lose it’s competitive advantage. He… – Continue reading
Indian State Supreme Court (Bombay High Court) has issued two important verdicts concerning Vodafone and Shell. Case one: Vodafone India Services (P.) Ltd. Vs Union of India [2014] (Bombay High Court) Vodafone India issued certain equity shares to its Mauritius holding company at a premium of INR 8,509 ($134) per… – Continue reading
(CNS Business): There were 5,391 new company registrations in the Cayman Islands in the first half of 2014, a 17% increase over those incorporated in the jurisdiction in the preceding six months, a report by offshore law firm, Appleby, revealed. The Cayman Islands experienced the greatest percentage increase in new… – Continue reading
The government’s plans to implement a Diverted Profits Tax (DPT) have been questioned by the Association of Chartered Certified Accountants (ACCA). Chas Roy-Chowdhury, head of taxation at the body, said nobody wants profits that should be subject to UK tax “escape the net”. As a result, he believes it is… – Continue reading
Former PricewaterhouseCoopers auditor charged with theft and violating trade secrets in wake of LuxLeaks scandal speaks out A 28-year-old former PricewaterhouseCoopers auditor charged with theft and violating trade secrets in Luxembourg in the wake of the LuxLeaks tax avoidance scandal has revealed his identity and claimed he acted out of… – Continue reading
At its Fall Meeting in Nashville, Tennessee on December 11-12, the MTC’s Executive Committee voted to formally contact states to solidify whether there is sufficient financial commitment to fund any potential MTC transfer pricing program. The MTC also formally announced that Iowa, Pennsylvania and Rhode Island will join the MTC… – Continue reading
HM Revenue & Customs’ (HMRC) plan to make undeclared taxable offshore income a criminal offence has suffered a blow as it has been omitted from draft legislation. The draft Financial Bill, published earlier this week, extended the scope of civil penalties for tax evasion but there was no reference to… – Continue reading
While some Owners create their own bespoke site to publicise their Local Lodging offering, most rely on the major websites that have become popular in recent years. However, not all Operators work in the same way. The nature of their business can influence the way the activity is classified by… – Continue reading
Do trustees need to register with the US Internal Revenue Service (the “IRS”) before 1 January 2015? Does registration need to be made in respect of a trust? These questions need to be given due consideration by Cayman Islands and British Virgin Islands (“BVI”) trustees and the trusts in respect… – Continue reading
Maples and Calder Michael Gagie, Richard Grasby, Tim Clipstone, Christopher Capewell, Jon Fowler and Tim Frawley Do trustees need to register with the US Internal Revenue Service (the “IRS”) before 1 January 2015? Does registration need to be made in respect of a trust? These questions need to be given… – Continue reading
Malta continues to receive glowing reviews internationally as a stable financial services centre of repute within the European Union. Over the past fifteen years, Malta has moved seamlessly from being an offshore to an onshore jurisdiction, through the implementation of several legal, tax and regulatory rules intended to stimulate domestic… – Continue reading
Some statistics rank London as the fourth largest ‘French’ city by population, and the number of French individuals moving to the UK is growing. This is not surprising – the UK offers a highly favourable tax regime for ‘non-domiciled’ individuals moving to the UK, while entrepreneurs, professionals and high net… – Continue reading
The House of Commons Public Accounts Committee on Monday held a hearing on the role of accountancy firms in tax avoidance and PwC (PricewaterhouseCoopers), the Big 4 accounting firm, was represented by Kevin Nicholson, PwC head of tax in the UK and former HMRC (HM Revenue & Customs) tax inspector,… – Continue reading
The Australian Tax Office is auditing 10 multinational corporations and the government will consider introducing new laws aimed at targeting tax avoidance, Joe Hockey has said. The treasurer said on Tuesday the ATO was “embedded in the offices” of multinationals operating in Australia to closely scrutinise whether those companies were… – Continue reading
Padoan : “it will enable member states to better fight aggressive tax planning by groups of companies” The Council approved an amendment to an EU directive with the aim of preventing tax avoidance and aggressive tax planning by corporate groups. To this end, it agreed that it would introduce a… – Continue reading
