African governments should embrace meaningful bilateral investments agreements to foster sustainable economic growth on the continent. The call follows a report by the UN Economic Commission for Africa (ECA) on investment policies and bilateral investment treaties by Africa, indicating a huge gap between most of signed treaties and their actual… – Continue reading
United Kingdom Budget The United Kingdom (UK) Budget: was handed down on 16 March 2016. Some of the key measures announced include: a reduction in the corporation tax rate to 17 per cent by 2020 (previously due to fall to 18 per cent) more details on the implementation of Base… – Continue reading
The number of multinational companies warning investors about the risk of higher taxes doubled in the past year, according to analysis by the Financial Times. Nearly a fifth of the US companies who warned on taxes were technology companies, the Financial Times found in a study of company filings. A… – Continue reading
The tax world is clearly becoming more interconnected and globalized with countries exchanging financial information about each other’s citizens through FATCA or the upcoming Common Reporting Standard (CRS). Every international decision a taxpayer makes – whether or not he or she is residing in the U.S. – can trigger something,… – Continue reading
Investors alerted to risks of higher payments as crackdown closes loopholes A global crackdown on tax avoidance has forced a surge of warnings by multinational companies that higher payments are set to hit their earnings. A Financial Times analysis of company filings revealed that more than twice the number of… – Continue reading
The first Budget tabled by Canada’s new Liberal Government provides for a major crackdown on tax evasion and avoidance, and streamlines the domestic tax credits system. The Budget was delivered by Finance Minister Bill Morneau on March 22, 2016. He told Parliament: “Today, we begin to restore hope for the… – Continue reading
Multinationals with turnover of more than €750 million would have to publish profit and tax details on their websites under new European Commission plans, the Financial Times has reported. According to plans seen by the Financial Times, the Commission would impose the requirement on companies with subsidiaries in Europe as… – Continue reading
The Finance Act 2015 introduced certain gateway conditions for the new exemption from UK withholding tax on interest payments for “qualifying private placements.” The Qualifying Private Placement Regulations 2015 setting out the detailed conditions for relief have now been made. While January 1, 2016 was appointed as the effective date,… – Continue reading
The second Protocol to the double tax agreement between Singapore and the United Arab Emirates entered into force March 16, 2016, and will become effective from January 1, 2017, lowering withholding tax rates and amending permanent establishment rules. The protocol, which was signed in October 2014, revises the terms to… – Continue reading
Private equity (PE) populism looks to be in the news again – though in a context that’s unlikely to win too many votes for the instigators. This time it’s the UK, and Chancellor George Osborne’s latest budget. The UK Budget 2016 (the Budget) includes a significant reduction in the UK… – Continue reading
The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast. VIRGINIA CORPORATE INCOME TAX Conformity with Internal Revenue Code. Virginia Governor Terry McAuliffe signed emergency legislation on February 5, 2016 that advances the state’s… – Continue reading
Summary The pace of change in international tax is dramatic. Each month brings new initiatives and developments at both national and supra-national levels. In this update, we focus on recent changes which are relevant to our clients. The OECD Base Erosion and Profit Shifting (“BEPS”) reports were finalised in October… – Continue reading
The amount people can earn before being hit by income tax will rise to £11,500 in April 2017, benefiting millions of workers. The move will cut taxes for 31 million people, according to the Treasury, and will mean 1.3 million low-wage workers are taken out of paying income tax altogether…. – Continue reading
Ban on tax haven land rejected in favour of ‘transparency register’ PROPOSALS TO OUTLAW the ownership of land in offshore tax havens were rejected by the Scottish Parliament today [Wednesday 16 March] on the basis of private legal advice. Estimates that 750,000 acres of Scotland are owned in tax havens… – Continue reading
The offshore yuan was set for the biggest two-day decline in six weeks after China’s central bank reduced the currency’s reference rate and policy makers were seen preparing a levy on foreign-exchange transactions. The monetary authority has drafted rules for a so-called Tobin tax in an effort to curb currency… – Continue reading
A record high 1,163,229 Report of Foreign Bank and Financial Accounts (more commonly, FBARs) were filed in 2015, up more than 8% from the prior year. That growth, however, is nothing new: FBAR filings have grown on average by 17% per year during the last five years , according to… – Continue reading
New tax regulations dealing with the issue of BEPS (Base Erosion and Profit Shifting) may have a disproportionate impact on the real estate development sector as they are implemented in the UK. The concept of BEPS originates from the OECD and the G20 nations. The intention is to deal with… – Continue reading
A new bill proposed by City Council President Darrell Clarke last week would ban city government from doing business with companies who move abroad to avoid paying U.S. taxes. Corporate tax inversion might not have a sexy ring to it, but it has been a topic on the minds and… – Continue reading
A tax treaty between Liechtenstein and Switzerland has been approved by the Liechtenstein government and transmitted to Parliament for consideration, the Liechtenstein government announced March 9. The government said that the treaty, which would replace a 1995 agreement between the countries, has also been approved by the Swiss Federal Council… – Continue reading
It’s not just the Indian banks that business tycoon Vijay Mallya has taken for a ride. The chairman of United Breweries (UB) group and promoter of now defunct Kingfisher Airlines also concealed in his election affidavit, filed before the Rajya Sabha, his business interests in offshore tax havens elsewhere. dna… – Continue reading
Colorado House Democrats succeeded Wednesday for a second straight year in sending a bill to the Senate that would generate more tax revenue from some international companies — but only after a lengthy and very pointed debate that often sought to pit big businesses against small companies and average Colorado… – Continue reading
Federal authorities demanded secrecy in no-penalty, no-prosecution deal to high net worth Canadians The Canada Revenue Agency offered amnesty to multi-millionaire clients caught using what’s been called an offshore tax “sham” on the Isle of Man — a reprieve that was supposed to remain secret and out of the public… – Continue reading
It is now time for Australian financial institutions to move on CRS. Australian implementing legislation has been finalised. You need to be prepared by 1 July 2017. The scope of CRS and applicable penalties have been expanded The next FATCA reporting deadline is 31 July 2016. The uncertainty around listed… – Continue reading
A move to check arbitrary decisions by the tax authorities may result in a huge fine for minor transgressions or mistakes while reporting tax, experts fear. In this year’s budget fine-print, the finance ministry has inserted a “new Section 270A (which) provides for levy of penalty in cases of under-reporting… – Continue reading
Debt planning and restructuring is a common mechanism to minimize taxable income by increasing deductions among different entities in a multinational group of companies. As interest on debt is generally a deductible expense of the payor and taxed in the hands of the payee, groups may create intercompany loans to… – Continue reading
NEWARK, NEW JERSEY (BLOOMBERG) – The US Internal Revenue Service (IRS) sought to make UBS Group turn over records on an account in Singapore held by a US citizen, setting up a showdown with the city-state over its bank-secrecy laws and potentially opening a new front against offshore tax evasion… – Continue reading
Even employees earning below Rs 15,000 a month will be impacted if the Centre sticks to the plan of taxing 60% of EPF withdrawals The Budget has proposed significant changes on taxation of Employees’ Provident Fund (EPF). Given that EPF is at the core of the Indian social security system… – Continue reading
While equalisation levy appears to be a step to counter double non taxation and protect India’s share of taxation, in its current form it may impact an Indian taxpayer more than foreign MNCs The growth of digital economy entails many benefits, but also poses various tax challenges. These include the… – Continue reading
BJP MPs are upset over the Budget proposal to tax EPF corpus at the time of withdrawal, a move they fear will antagonise the party’s core support base of the middle class. A day after he made the announcement, Finance Minister Arun Jaitley explained to party parliamentarians and allies that… – Continue reading
The South African Revenue Service (SARS) has issued final regulations that require certain financial institutions (FIs) to report on accounts held or controlled by foreign residents from March 1, 2016. The OECD’s automatic tax information exchange standard, the Common Reporting Standard (CRS), which the regulations are in response to, obliges… – Continue reading
Another form of taxation that has gotten greater attention during the last two presidential election campaigns is the flat tax. A flat tax is a plan that will apply the same rate to every taxpayer, regardless of the income they have earned. At present, federal taxes are calculated on a… – Continue reading
Before conducting business outside of the U.S. for the first time, a company must establish the business case for doing so. That means looking beyond just the profit potential on the product or service to the other costs that can be involved, of which there are many. “The culture of… – Continue reading
The US Internal Revenue Service (IRS) has updated Publication 515, Withholding of Tax on Nonresident Aliens and Foreign Entities, which covers the obligations of the persons responsible for withholding tax (withholding agents). It is specified that the Publication is for withholding agents who pay income to foreign persons, including nonresident… – Continue reading
Pakistan and Czech Republic have implemented a convention to avoid double taxation and prevent tax evasion, the Federal Board of Revenue notified on Monday. An official said the convention on avoidance of double taxation will come into force on July 1. “This is an epoch-making event in the consolidation of… – Continue reading
The federal government of Nigeria and Qatar have signed an agreement for the avoidance of double taxation on income and capital gains for investments between the two countries. In addition to the elimination of double taxation on business income, similar treaties between Nigeria and other countries provide for a lower… – Continue reading
That the collection of the taxes levied on citizens becomes an exceedingly difficult task in the absence of a moral sense of tax responsibility on the part of the taxpayers is well known. The readiness to tolerate taxes is reinforced or undermined by two primary factors: The sense taxpayers have… – Continue reading
A “controlled foreign company” (CFC) is, as the name implies, a foreign company or subsidiary owned by a parent company which is situated in a country different from the parent company’s country of residence. The tax laws of many countries, including the Philippines, do not tax the CFC’s parent company… – Continue reading
When a rock-star French economist comes to our country to tell us that the surest way to fix inequality is to tax the hell out of the privileged, they are guaranteed a sympathetic audience. And so we will partly have Thomas Piketty to thank when Pravin Gordhan introduces tax hikes… – Continue reading
It’s unlikely anybody was particularly surprised when Finance Minister Pravin Gordhan announced a number of initiatives to increase the amount of tax revenue; from sugar tax to a “tyre levy” to an increase in a number of existing sin taxes. But it’s perhaps the relaxing of voluntary disclosure rules that… – Continue reading
On February 23, US House of Representatives Ways and Means Committee Ranking Member Sander Levin (D – Michigan) and Budget Committee Ranking Member Chris Van Hollen (D – Maryland) introduced legislation aimed at reducing the number of corporate tax inversions by limiting the use of “earnings stripping.” Tax inversion techniques… – Continue reading
Double tax treaties enable competent authorities of the treaty partners to exchange important tax information necessary for implementing the treaty or the domestic laws on taxes of every kind and description imposed. For instance, exchanges of information may be made regarding tax avoidance by companies of the contracting states.Nevertheless information… – Continue reading
Over the last two decades, an increasing number of companies have set up subsidiaries in offshore financial centres. So why don’t they move the entire business, and establish headquarters there too? While it seems prestigious—and tax-savvy—to be based in the Cayman Islands or Luxembourg, companies that choose to do so… – Continue reading
On February 15, 2016 the President of the Russian Federation signed Federal Law No. 32-FZ on Amendments to Parts One and Two of the Russian Federation Tax Code (Regarding Taxation of Profits of Controlled Foreign Corporations and Income of Foreign Entities) (the “Law”). The Law introduces a number of amendments… – Continue reading
Earlier this week the State Department released its latest statistics for people who have renounced their US citizenship. 2015 was another record year, with 4,279 people divorcing themselves from the US government and heading to greener pastures elsewhere. This was the third year in a row that broke the previous… – Continue reading
As if the mental harassment of delayed delivery of a house is not bad enough, you could also be losing 85% of the tax benefit on your home loan, for no fault of yours. A tax deduction of Rs 2 lakh per year is allowed against payment of interest on… – Continue reading
Voluntary Disclosure & CRA Annual Report to Parliament – General Information CRA has provided the latest statistics about the tax amnesty or voluntary disclosure program (VDP) for the previous fiscal year. CRA provides an annual report to parliament that provides a wealth of information about its activities over the past… – Continue reading
To search for a tax haven to free yourself from tax burden, you need not have to go to Bermuda, Isle of Man, Cayman Islands, Dubai, Switzerland, Mauritius or any other country. It is just right here in India where we are living, hidden in various sections of our Income… – Continue reading
As part of what it describes as a ‘relentless’ effort to crack down on tax avoidance, HMRC has put out two publications highlighting problems with contractor loan schemes and misleading claims from scheme promoters, in a bid to deter taxpayers from any involvement In its Spotlight 29 document, HMRC says… – Continue reading
In the first part of this article, we talked about provisions of the Organisation for Economic Co-operation and Development’s (OECD’s) final report on Base Erosion and Profit Shifting (BEPS) Action Plan 14, which reflects the commitment of participating countries to implement substantial changes in their approach to dispute resolution in… – Continue reading
The OECD’s final reports on the Base Erosion and Profit Shifting (BEPS) Project aim to target aggressive tax planning strategies which have the effect of shifting profits from high tax jurisdictions to low tax jurisdictions. The BEPS Project has been divided into 15 Actions, of which one of the most… – Continue reading
