The Indian Government has accepted the recommendation of the Shah Committee that the Income Tax Act 1961 be amended to clarify that minimum alternate tax (MAT) does not generally apply to foreign institutions investors (FIIs) and foreign portfolio investors (FPIs). The Committee proposed that Section 115JB of the Income Tax… – Continue reading
Explosives maker Orica will take a $36 million hit to its bottom line after the Federal Court found it had avoided tax by using “round robin” financing arrangement it put in place a decade ago to boost its profit and ward off takeover bids. BusinessDay revealed Orica’s battle with the… – Continue reading
Yahoo has reportedly abandoned its plan to spin off its stake in Alibaba. Yahoo’s proposed spinoff had been driven by tax concerns. In a world without taxes, Yahoo could have simply sold its Alibaba shares and distributed the proceeds to shareholders. Yahoo will now concentrate on other strategic options, including… – Continue reading
INTRODUCTION The Taxation Laws Amendment Act, 2015 and the Tax Administration Laws Amendment Act, 2015 have both now been passed by Parliament, but await signature by the President. Once again, and now for the second year running, the number and scope of the changes to the various fiscal Acts (mainly… – Continue reading
With a new tax on company dividends coming into force from April 2016, a financial planner explains how Britons overseas will be affected, and what steps they should take Investors who receive more than £5,000 from company dividends held outside tax-efficient plans such as Isas will pay more tax from… – Continue reading
The Circular of the State Administration of Taxation on Strengthening the Administration of Corporate Income Tax on Incomes of Equity Transfers of Non-Resident Enterprises (“Circular 698”) was issued in 2009 to regulate tax treatment of indirect transfers of equity interest in a domestic Chinese company by non-residents. Circular 698 empowered… – Continue reading
The Circular of the State Administration of Taxation on Strengthening the Administration of Corporate Income Tax on Incomes of Equity Transfers of Non-Resident Enterprises (“Circular 698”) was issued in 2009 to regulate tax treatment of indirect transfers of equity interest in a domestic Chinese company by non-residents. Circular 698 empowered… – Continue reading
INTRODUCTION In the context of changes in the international system of taxation of the company in the choice of jurisdiction for the implementation of operational activities closely fit to the question of economic feasibility, to protect their interests. The strategic location of Cyprus, the presence of the country’s full membership… – Continue reading
WASHINGTON — Hillary Clinton on Wednesday will unveil a proposal for a new “exit tax” aimed at cracking down on corporate inversions, a practice that permits U.S. companies to merge with corporations overseas to lower their tax bill. The new tax would be part of a broader effort to target… – Continue reading
Mark Zuckerberg has defended the structure of his new philanthropic organisation after critics suggested he was avoiding paying tax on the sale of his shares. Zuckerberg and his wife Priscilla Chan launched the organisation, the Chan Zuckerberg Initiative, this week to honour the birth of their daughter, Max. The couple… – Continue reading
France and Luxembourg failed to ratify a protocol changing the France-Luxembourg double tax treaty by 30 November, which means that a change which will affect real estate structures cannot come into force until 1 January 2017, at the earliest, for companies whose fiscal year is based on a calendar year…. – Continue reading
Company changed tax address from U.S. to Ireland this year CEO says 40 percent of cash still located outside U.S. Medtronic Plc’s decision to move its tax address out of the U.S. is already starting to pay dividends. The medical device company used a deal with Covidien Plc this year… – Continue reading
Some of the DTAAs entered into by India with other countries allow taxation of capital gains on shares only in the country of which the taxpayer is a resident. The government on Friday told the Lok Sabha that it has started negotiations with some countries to amend provisions on capital… – Continue reading
Only time will tell whether the benefit of enhanced compliance and effective enforcement will outweigh the costs. The Common Reporting Standard (CRS) is a new international system for the automatic exchange of tax information promoted by the Organisation for Economic Cooperation and Development (OECD) and modelled on the United States’… – Continue reading
The Government of India is aware of the potential loss of revenue from tax avoidance, and has been taking all necessary measures for preventing it. As a part of these measures, India has actively participated n the Base Erosion and Profit Shifting (BEPS) project undertaken by the OECD and G-20… – Continue reading
Taxes levied on foreign stock dividends can be recouped, but it makes most sense for high-net-worth clients with multimillion-dollar positions Advisers could be missing out on a way to maximize returns on their clients’ foreign investments. Americans investing in non-U.S. stocks could be earning less of a return than they’d… – Continue reading
Taxes levied on foreign stock dividends can be recouped, but it makes most sense for high-net-worth clients with multimillion-dollar positions Advisers could be missing out on a way to maximize returns on their clients’ foreign investments. Americans investing in non-U.S. stocks could be earning less of a return than they’d… – Continue reading
In a previous article we have discussed that you might be entitled to reclaim withholding tax on your foreign investments in Russia (including ADRs, GDRs). For transactions where the ultimate beneficial owner is not declared prior to the payment of income, local Russian custodians apply 30% withholding tax on dividends1… – Continue reading
“Luxembourg is famous for two things: its steel industry and its rose cultivation industry”. This quote from an Italian guidebook of the 1930s was uttered by Luxembourg’s Finance Minister Pierre Gramegna at the annual conference of the Luxembourg Directors’ Association on 17 June 2015[1]. The economic outlook of the tiny… – Continue reading
Police last week raided the Nicosia offices of the law firm representing the Hermitage Fund, embroiled in the largest fraudulent tax rebate case in Russian history, the Cyprus Mail has learned. On Friday, two senior Russian interior ministry officials along with local police officers searched the Nicosia offices of a… – Continue reading
The number of M&A transactions involving Private Equity [PE] investment in Bermuda in the first three quarters of this year has already eclipsed that seen in all of 2014, according to a report released today [Nov 30] by Appleby. “Bermuda was also the offshore jurisdiction to see the largest total… – Continue reading
Mauritius plans to launch a trading platform to hedge African currencies against the US 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 boost ties with stock exchanges in… – Continue reading
The law, at present, is replete with a complex web of cross-references, often causing confusion The clamour for simplifying tax legislations gets louder as a new government, in its interaction with businesses and the civil society, holds out a promise of a non-adversarial tax regime. The reform of indirect taxes… – Continue reading
Tech titans powering the economy shelter money through insane tax-avoidance havens. It’s wrong — and adding up Offshore tax havens enable not only individuals to dodge taxes—they also enable multinational corporations to do so. Often this tax avoidance is done within the letter of the law: multinational groups exploit the… – Continue reading
On October 7 2015 the South African Revenue Service (SARS) released Binding Private Ruling 207, which dealt with the merger of two controlled foreign companies (CFCs) for purposes of Section 9D of the Income Tax Act (58/1962). Facts The applicant, a South African-incorporated and resident company, had two subsidiaries that… – Continue reading
The new provisions of the 4th Amendment to the France/Luxembourg double tax treaty on profits deriving from sale of real estate assets signed on September 5, 2014 will not be applicable in 2016. Currently, the right to tax the capital gains realized by a Luxembourg company upon the transfer of… – Continue reading
Teddy Sagi still owns a 30 per cent stake in Playtech, the gambling software firm The Israeli billionaire Teddy Sagi’s £460m takeover of Plus500, the financial trading firm, was torpedoed yesterday due to “concerns” raised by the Financial Conduct Authority watchdog. Mr Sagi is the founder of the gambling software… – Continue reading
In order to encourage the growth of international trade including that of financial services, successive Maltese governments have sought to conclude double tax treaties with important trading partners as well as with emerging countries. This policy is expected to continue in the future. To date, treaties are in force with… – Continue reading
The latest Tax Reform Business Barometer survey, issued by The Tax Council and Ernst & Young, found that tax professionals expect Congress to approve tax reform legislation no earlier than 2017, with most congressional leaders having all but given up hope that tax reform is achievable in the remainder of… – Continue reading
Earlier we already reported that Malta and Curaçao had signed a DTA. When we wrote our earlier article we had not yet been able to locate the text of the DTA. Now however, the English version of the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal… – Continue reading
SARS may now impose a dividends tax on dividends paid by a South African company to a Cypriot shareholder as provided for in the Protocol to the current agreement for the avoidance of double taxation between South Africa and Cyprus. In terms of the current agreement for the avoidance of… – Continue reading
Following a ruling by the Swiss Federal Tax Administration, payments of interest under the DDM Treasury SEK 300 million Senior Secured Notes with ISIN SE0005280831 (the “Notes”) are subject to Swiss withholding tax since the refinancing executed in June 2015. On 23 June 2015 certain amendments to the documentation in… – 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
A pending Protocol, that would amend the income tax treaty between Luxembourg and France, may not be effective until 2017. RATIFICATION PENDING The Luxembourg Parliament passed a bill to ratify the fourth Protocol to the income tax treaty (1958) between Luxembourg and France. However, it currently appears that the ratification… – Continue reading
The European Commission has requested that the Netherlands amend the limitation on benefits clause in its double tax treaty with Japan. The Commission said that, on the basis of previous cases such as Gottardo (C-55/00) and Open Skies (C-466/98), a member state concluding a treaty with a third country cannot… – Continue reading
The Chancellor could target capital gains tax for extra revenue when he delivers his Autumn Statement next week as gains from investors and landlords hit their highest on record in the past financial year, accountants suggest. George Osborne, who will unveil his spending plans for Britain next Wednesday, is under… – Continue reading
On November 19, 2015 the European Commission published the key decisions of its November infringement package. One of the key decision mentioned is the Commission’s decision to request the Netherlands to amend the Limitation on Benefits (LOB) clause in the Dutch-Japanese Tax Treaty for the Avoidance of Double Taxation, which… – Continue reading
Fed decision due after December 15-16 meeting Hong Kong and mainland Chinese stocks both closed significantly higher on Thursday, adding to a global stock rally after minutes from the US Federal Reserve’s October meeting sent a stronger signal about a possible December rate increase. The Hang Seng Index advanced 1.4… – Continue reading
Markets finished close to unchanged on Tuesday, but these stocks soared. Find out why. After big gains to start the week, the stock market treaded water on Tuesday, with most major benchmarks finishing close to the unchanged level. Yet for Airgas (NYSE:ARG), Nuance Communications (NASDAQ:NUAN), and Syngenta (NYSE:SYT), the day… – Continue reading
Perhaps in theory there are ways to fix tax avoidance, but they aren’t politically feasible. Libertarian anarchists used to say “taxation is theft.” New research by economist Gabriel Zucman suggests that there is some truth to this—when tax havens are taken into consideration. In his new book The Hidden Wealth… – Continue reading
BearingPoint’s FiTAX catches on while a FATCA critic says that more Americans are renouncing their citizenship because of the controversial tax law. While controversy swirls around the Foreign Account Tax Compliance Act (FATCA), management and technology consultancy BearingPoint reports that between March and August 2015, more than 2,000 financial institutions… – Continue reading
Under Indian foreign exchange regulations, Indian companies having foreign investment participation are generally categorised either as Indian owned and controlled company (IOCC), or foreign owned or controlled company (FOCC). An Indian company in such cases is considered as IOCC where they are owned and controlled by resident Indian citizens and/or… – Continue reading
Notwithstanding the NDA’s election promise to end tax terrorism the dynamics on the ground belie easy fixes The National Democratic Alliance (NDA) government is seeking to prepare a road map to reduce existing tax litigation and look into increasing pecuniary threshold limits to discourage tax departments from launching new cases…. – Continue reading
Amazon, Facebook and Google in line of fire after committee backs proposals to force multinational corporations to pay tax where they make their sales MEPs have launched a scathing attack on Facebook, Google and Amazon in the European parliament, accusing them of diverting profits worth billions of pounds to low… – Continue reading
* G20 leaders say they will deliver on vow to lift global growth * G20 promise not to surprise markets with policy decisions * World leaders agree to tackle tax dodgers, pledge to cooperate on migrants (Adds details, background) BELEK, Turkey, Nov 15 The heads of the world’s 20 largest… – Continue reading
Normative Instruction no. 1.474, of June 20, 2014, excluded Switzerland from the list of Jurisdictions with Favoured Tax Treatment (JTF) and included it in certain cases within the concept of privileged tax regime (RFP). The matter is now governed by Law no. 11.727 which, as well as widening the concept… – Continue reading
Pfizer Inc.’s buyout bid for Allergan Plc has financial markets on edge over a possible new move by the U.S. Treasury Department against tax-inversion deals, but the outlook for any such steps was still unclear. For months, Treasury has offered no fresh guidance on the inversion issue, leaving tax experts… – Continue reading
Telecoms giant MTN Rwanda is in talks with the revenue authority to settle a Rwf9 billion ($12 million) tax dispute out of court. In a case that has lasted over two years, the Rwanda Revenue Authority dragged MTN Rwanda, the country’s largest mobile phone services provider by market share, to… – Continue reading
An ED officer said, “In spite of earning a profit in the first few IPL seasons, Shah Rukh failed to provide any satisfactory explanation for selling the equity shares within a year, that too to a company situated in a tax haven”. Mumbai, November 11 (PTI): The Enforcement Directorate has… – Continue reading
ANZ Banking Group has paid an instalment on its 2016 financial year company tax in order to get enough credits to maintain a fully franked final dividend in 2015, raising the spectre of future ANZ dividends being only partially franked or the dividend payout ratio falling to reflect the growing… – Continue reading
