The UK Government’s goal is to make the UK the best place in the world to locate an international business; it has one of the most open economies globally, a highly skilled workforce, access to capital markets, a first-class infrastructure, and a highly competitive corporate tax system. UK tax policy… – Continue reading
STELLAR Capital Partners, the newly constituted investment company aligned to retail tycoon Christo Wiese, will acquire an influential stake in industrial supplies and services business Torre for R690m. According to a Stock Exchange News Service (SENS) announcement released on Monday night, an unidentified vendor consortium will sell 133-million Torre shares… – Continue reading
(Newsroom America) — Gregg R. Mulholland, a dual U.S. and Canadian citizen, has been arrested at Phoenix International Airport during a layover of his flight from Canada to Mexico on charges of securities fraud conspiracy and money laundering conspiracy for fraudulently manipulating the stocks of numerous U.S. publicly-traded companies and… – Continue reading
Abstract Over the past 25 years, Cyprus has become the portal of choice for investment into and out of Russia and Central and Eastern Europe. The new Russian de-offshorization law, which took effect on 1 January 2015, will have significant implications for users of overseas structures. This article examines the… – Continue reading
In a note to investors published today, Bernstein analyst Toni Sacconaghi weighed in on why Apple Inc. (NASDAQ:AAPL) has chosen to keep a large offshore cash balance and not repatriate to the US. Mr. Sacconaghi noted activist investor Carl Icahn’s notion that Apple’s real tax rate is roughly 20% below… – Continue reading
The Securities and Exchange Commission of Pakistan (SECP) has proposed to the Federal Board of Revenue (FBR) to withdraw 5 percent tax on bonus shares and apply current capital gains tax (CGT) rate of 12.5 percent irrespective of its holding period. According to the budget proposals of the SECP received… – Continue reading
SHARES in the health outsourcing firm Synergy Healthcare saw sharp losses yesterday as reports circulated that US authorities were going to block its proposed takeover by Steris, a rival American company. The FTSE 250 company’s shares finished the trading day down 15.8 per cent, to 1,822p, having recovered slightly from… – Continue reading
At the heart of the case is the Ecclestone family’s Bambino trust, which is based in the offshore tax haven of Liechtenstein Bernie Ecclestone is taking legal action against HM Revenue & Customs over claims that he owes the tax authority more than £1bn after it tore up a settlement… – 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
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
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
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
AMP has reassured shareholders at its annual general meeting that it’s not involved in tax avoidance. Wealth management giant AMP has told its shareholders that it’s not aggressively avoiding tax. The company was responding to a question at its annual general meeting during which it also released quarterly results that… – Continue reading
The Australian Taxation Office said more than $100 million worth of tax benefits dished out to shareholders as big companies raised money may have been tax avoidance. In its second crackdown in a week on franking credits, the ATO is going after companies that are raising capital to make franked… – Continue reading
A draft law empowering shareholders to vote on directors’ remuneration, so as to ensure proper transparency and tie their pay more closely to their performance, was backed by Legal Affairs Committee MEPs on Thursday. Some large companies should also be required to disclose, country by country, information on tax rulings,… – Continue reading
The Companies Act 2014, which comes into force on 1 June 2015, represents the most significant reform of company law since 1963. The new legislation creates two new and distinct types of private limited company, and existing companies must choose which of these they will convert to. The new legislation… – Continue reading
HSBC’s pre-tax profits rose 4 per cent to a better-than-expected $7.06bn (£4.66bn) in the three months ending 31 March HSBC chief executive Stuart Gulliver admitted that the company’s Swiss banking scandal has hit morale across the group even as profits beat City forecasts during the first quarter of the year…. – Continue reading
(Reuters) – U.S. bank JPMorgan Chase (JPM.N) has been placed under formal investigation in France as part of a probe into alleged tax evasion by senior managers at investment firm Wendel (MWDP.PA), a court official said on Wednesday. A Paris-based spokesman for JPMorgan declined to comment on the move, part… – Continue reading
UK funds invested in India could face demands for tax from which they thought they were exempt. Minimum alternate tax (MAT), a tax on the book profit of a company, has been in existence in India in its current form since 2001 and is levied at 18.5 per cent. Because… – Continue reading
The Central Board of Direct Taxes [CBDT] on 26th March 2015 issued a Circular no. 4/2015 wherein they have clarified that while interpreting the provisions of Section 9(1)(i) of the Income Tax Act, 1961 [herein after referred to as ‘Act’] read with Explanation 5 inserted to the said section by… – Continue reading
HM Revenue & Customs (HMRC) is set to take two banks to the Supreme Court over using alleged tax avoidance schemes to avoid paying big tax bills on bonuses for its staff. HMRC has previously lost two court cases against UBS and Deutsche Bank over the two schemes which operated… – Continue reading
A Netherlands-based company threatened to sue the South Korean government for inflicting more than 183 billion won in losses through double taxation during its sale of Hyundai Oilbank shares five years ago, it was revealed Saturday. If a lawsuit is filed, it will mark the second time for South Korea… – Continue reading
FORMER treasurer Peter Costello says changing or ending tax credits for shareholders who get dividends would see investors send their money offshore. The financial system inquiry (FSI) last year questioned the wisdom of dividend imputations, where shareholders get a tax credit for the profits a firm shares with investors via… – Continue reading
The Tax Office is cracking down on what it’s described as “contrived arrangements” that allow hundreds of wealthy individuals with self-managed superannuation funds (SMSFs) to pay no tax on income from shares. Cases are still being reviewed and it’s unclear how much tax revenue may be at stake. But the… – Continue reading
Autumn Statement 2014, Budget 2015 and Finance Act 2015 The UK Chancellor delivered his Autumn Statement on 3 December 2014 and his Budget speech on 18 March 2015. For an overview of some of the key announcements, please see our Autumn Statement 2014 briefing and Budget 2015 briefing. The UK’s… – Continue reading
Although you may be working in China, does the ATO still consider you an Australian resident? It’s just one of the things you need to get absolutely right. The tax requirements for Aussies working overseas vary from region to region. Aussies working in Hong Kong will find last month’s tax… – Continue reading
The Shareholders Association is making “strenuous representations” to the Inland Revenue Department over what it says is an unfair tax facing possibly thousands of New Zealand investors as a result of a proposed demerger of Anglo-Australian mining giant BHP Billiton. In an effort to simplify its business, Melbourne-based BHP is… – Continue reading
(Reuters) – Some of Britain’s biggest political donors, including a dozen senior lawmakers, have benefited from a little-noticed loophole that lets them avoid tax on millions of pounds in donations to political parties, a Reuters analysis has found. Reuters is the first to measure the loophole, which offers political parties… – Continue reading
Section 55 of the Income Tax Act (Canada) (the “Tax Act”) contains an anti-avoidance rule that prevents a corporation from converting what would otherwise be a taxable capital gain into a tax-free intercorporate dividend. Section 55 deems a dividend not to be a dividend, but rather a capital gain, where… – Continue reading
The former head of parliament’s public accounts committee – and a fierce critic of tax avoidance and “secretive” offshore funds – has received more than £1.5m in shares from the tax haven of Liechtenstein, according to a report. The money came through a controversial scheme that lets wealthy Britons move… – Continue reading
LONDON (Reuters) – HSBC shares have rallied after the bank said it was reviewing whether to move its headquarters out of Britain and potentially back to its former home in Hong Kong. The following are some of the regulatory issues raised if Europe’s biggest bank were to relocate to Hong… – Continue reading
International finance centres (IFCs) are frequently used to structure Russian inward and outward investment and it has been observed that in 2012, 11 of the 40 main recipients of Russian FDI were IFCs1. The BVI is at the forefront of offshore investment into Russia, and the share of outward FDI… – Continue reading
Company accounts provide insight into Parlesse Investments A Larry Goodman company based in Luxembourg made a profit of €52.6 million in 2013 and paid just 0.4 per cent tax, according to accounts in the tiny EU member state. The company, Parlesse Investments Sarl, began operations in 2010 and had accumulated… – Continue reading
A company announcement on the Malta Stock Exchange website announced on Tuesday that Arun Shankardass and Oumeshing Sookdawoor have tendered their resignation from the office of director of the company with effect from 17 April. Mr Shankardass will also be stepping down as chairman of the Audit Committee of the… – Continue reading
The “Hound of Hounslow” day trader accused of helping trigger a Wall Street “flash crash” made more than £30 million profit dealing from his parents’ home in four years, the Evening Standard can reveal. FBI agents are investigating claims that Navinder Sarao, 36, transferred as much as £26 million to… – Continue reading
The true cost of the debt that China’s real estate developers peddled to eager international investors during a five-year property boom is now becoming clear. Having found themselves shut out of local bond and loan markets seven years ago, a band of developers began looking elsewhere for funds. First an… – Continue reading
Mumbai: The equity markets snapped their five-day losing streak following a late hour surge in buying of blue-chip stocks on reports that the minimum alternate tax (MAT) would not be levied on overseas investors coming through those jurisdictions with which India has a double taxation avoidance agreement (DTAA). After trading… – Continue reading
Arris Group Inc. agreed to buy British set-top box maker Pace Plc for about $2.1 billion and incorporate in the U.K. in a deal designed to save on taxes. Shares in Pace, one of Britain’s few global technology companies, rose as much as 44 percent. The acquisition will combine two… – Continue reading
While the government has stood its ground on the applicability of minimum alternate tax (MAT), saying that foreign institutional investors (FPIs) ought to consider judicial appeal for the retrospective tax demand, increasing number of foreign brokerages are red flagging the issue as a risk for the Indian equity market. Even… – Continue reading
1 General news 1.1 HMRC organisation chart HMRC has published its latest organisation chart showing the names of senior management. One point to note is the number of senior people now in roles such as change management as opposed to being in pure technical roles. This clearly demonstrates the direction… – Continue reading
The Minister of Finance (Canada), the Honourable Joe Oliver, presented the Government of Canada’s 2015 Federal Budget (“Budget 2015”) on April 21, 2015 (“Budget Day”). Budget 2015 contains several significant proposals to amend the Income Tax Act (Canada) (the “ITA”) while also providing updates on previously announced tax measures and… – Continue reading
Minister of Finance Joe Oliver today tabled the 2015 Federal Budget (the “Budget”), his first budget as Minister of Finance, entitled “Strong Leadership: A Balanced-Budget, Low-Tax Plan for Jobs, Growth and Security”. We are pleased to provide our summary of tax measures contained in the Budget. The Budget proposed no… – Continue reading
As has been widely predicted, today’s federal budget (Budget 2015) delivered a handful of tax “goodies” in the lead-up to the coming election. It also includes a number of important proposed changes to the corporate tax rules. They are noteworthy, although not as extensive as the corporate tax changes proposed… – Continue reading
The Cyprus Investment Promotion Agency (CIPA) is urging parliament to expedite a batch of bills aimed at facilitating much-needed foreign investment in Cyprus. Chief among the proposals are the establishment of foreign leasing companies and cell companies, opening up the professional provident fund business to foreign concerns, and updating company… – Continue reading
Finance Minister Joe Oliver faced formidable challenges, both economic and political, in delivering his first Budget. In a time of depressed oil prices, and mere months ahead of the next federal election, it appears he felt it was imperative to follow through with prior commitments to balance the budget, provide… – Continue reading
1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins The legal system of the Republic of Ireland is a common law system. In order to ensure consistency, a legal principle developed whereby courts were generally required to follow earlier relevant decisions. This doctrine of… – Continue reading
Mylan NV Executive Chairman Robert Coury made $22.7 million, including $1 million for his personal use of the drugmaker’s two corporate jets, in 2012 and 2013. At Israeli rival Teva, shareholders in 2012 balked at raising the chairman’s salary to $900,000 a year. The contrast highlights the sharp differences that… – Continue reading
The Finance Minister has failed to assuage markets’ fears on the issue of retrospective tax Markets are getting jittery each time the finance minister or his ministry utters the T word. Finance Minister Arun Jaitley reminds the market of UPA’s finance minister Pranab Mukherjee, who introduced the now-dreaded retrospective tax…. – Continue reading
Singapore Telecommunications Ltd (Singtel), has announce the intent to delist from the Australian Securities Exchange, due to what it described in official statements as “low trading interest”. Singtel shares have been listed on the ASX as CHESS Depositary Interests (CDIs). This has enabled foreign companies to trade on the Australian… – Continue reading
With regard to the First Financial case, the debarred entities include this company itself, its seven promoters and directors, 80 ‘preferential allottees’, 57 First Financial Group entities, as also seven others suspected to be related entities. Sebi has allowed First Financial, which has been barred from the capital market for… – Continue reading
