While preparing its bid for Tim Hortons Inc. last year, Burger King Worldwide Inc. initially wanted to set up the new parent company of Canada’s iconic supplier of double-doubles and maple-glazed doughnuts across the Atlantic in Britain, to avoid taxes. Miami-based Burger King’s first offer to buy the doughnut chain… – Continue reading
COLOMBIA: The Tax Authority (DIAN) clarified the withholding tax rate applicable to payments made abroad based on the provisions of Law 1739 of 2014 Article 28 of Law 1739 of 2014 set forth that revenue obtained by companies and foreign entities, that are not attributable to a branch or permanent… – Continue reading
On 9th July 2015, the Cyprus House of Representatives voted in favour of the introduction of a Notional Interest Deduction regime, aimed at encouraging investment into corporate structures, and thus reducing excessive debt financing. Such changes, aimed to further improve Cyprus’ growth prospects, will align the Republic’s system with that… – Continue reading
The Cyprus Tax Department announced that Financial Institutions which report information to the Cyprus tax authorities under the Cyprus – United States Foreign Account Tax Compliance Act (FATCA) Agreement will not be required to file nil returns. The FATCA Agreement between Cyprus and the United States was signed on 2… – Continue reading
In the wake of the recent arrests of stakeholders in the Maltese remote gaming sector, it seems that professional firms and the remote gaming authority did not carry out due diligence appropriately on ultimate beneficial owners of the companies they have registered and represented. This failure has seriously tarnished Malta’s… – Continue reading
In the midst of the Special Investigative Team (SIT) on undisclosed money flagging concern on participatory notes (p-notes), the Securities and Exchange Board of India (Sebi) says it is probing a case of alleged round tripping. The term refers to transactions between companies that bolster their revenue but, in the… – Continue reading
NEW DELHI: The government today said it’s taking effective steps to deal with black money and will focus on high-impact cases with a view to prosecuting offenders expeditiously for credible deterrence against tax evasion. “While focusing on non-intrusive measures, due emphasis has been given on enforcement measures in high-impact cases… – Continue reading
On July 17, 2015, the Internal Revenue Service (IRS) released three new “practice units,” each examining a particular type of transaction involving a controlled foreign corporation (CFC). The IRS develops practice units internally for use both as training materials and as job aids for examiners. Practice units are not formal… – Continue reading
Companies and govts have been playing the cat-and-mouse game for several decades on transfer pricing Only a naivete would think of Hilary Clinton’s proposal last week to scale up the rate of capital gains tax as a mere concept to streamline America’s tax rate structure. It is being perceived as… – Continue reading
The Foreign Account Tax Compliance Act (FATCA)[LR1] is generally associated with reporting requirements for foreign banks and foreign entities to disclose the names of U.S. individuals using such foreign vehicles to hide U.S. financial accounts. (See all three blog posts in this series on FATCA compliance.) However, there is an… – Continue reading
Governments that dole out tax subsidies to big companies shouldn’t be allowed to reap multibillion-euro windfalls if the European Union orders them to claw back the aid, lawmakers probing tax loopholes said. Instead, the EU should consider changing the law so that money is shared among neighboring nations that played… – Continue reading
July 29 — The Treasury Department has notified countries with early versions of agreements under the Foreign Account Tax Compliance Act that their banks can use the more favorable procedures for reporting new accounts available in later pacts. Treasury said July 27 that it had sent letters to 40 countries… – Continue reading
Tax savings drove the acquisition strategy of Valeant Pharmaceuticals International Inc. and led to Burger King’s move to Canada, according to a U.S. Senate committee report. Taxes appear to be much more important to the deals than the companies say, according to an advance copy of the report and testimony… – Continue reading
GOVERNMENT HAS TAKEN key steps to meet the requirements of the Foreign Account Tax Compliance Act Intergovernmental Agreement (FATCA IGA), which allows for the reciprocal exchange of information between the USA and Barbados. Minister of Finance, Christopher Sinckler, outlined the key steps as amending the Income Tax Act and putting… – Continue reading
MUMBAI: The identity of taxpayers who opt for an advance pricing agreement (APA) in the field of transfer pricing will continue to remain confidential. Such information cannot be made available under the provisions of the Right to Information Act (RTI), according to the Central However, responding to a second appeal… – Continue reading
If former Fiat Chrysler Australia boss Clyde Campbell goes down over allegations he misused tens of millions dollars of company money, he might just threaten to take the entire Australian operation of the global automaker and several executives with him. Mr Campbell on Wednesday opened the door for a tax… – Continue reading
There is an intimate relationship between art and finance. In the public sphere, the state plays a predominant role in funding and maintaining national art collections. The private sphere is dominated by private patronage. For example, artists in medieval Italy were funded by wealthy families such as the Medici, and… – Continue reading
Consultation on the ATO’s practical guide for offshore marketing hub arrangements is kicking off in August. The guide may also assist taxpayers with offshore intellectual property (IP) hubs. Here is what you need to know if you market Australian produced goods offshore or have centralised your IP offshore. Do you… – Continue reading
On 25 July 2015 the Cabinet of Ministers of Ukraine published an order on the conclusion of advance pricing agreements (“APA”) in respect of controlled transactions for transfer pricing purposes* (“the APA Order”). The APA Order replaces the former procedure for the conclusion of APAs which became outdated due to… – Continue reading
Multinationals should pay a withholding tax before moving their profits out of EU countries to ensure they are being taxed somewhere, according to a draft report from the European Parliament. The report, seen by the Irish Examiner, deals with the fallout from the Lux Leaks and follows the European Commission’s… – Continue reading
Just as every new government fiddles around with high school history text books, it also dabbles in Mauritius and P-notes. Both actions have a sharp, short-lived impact, leaving behind a trail of conspiracy theories. Mauritius and P-notes are ghosts that New Delhi and regulators could never quite exercise. They unfailingly… – Continue reading
These proposals can be implemented individually or as part of other reforms that may be in the pipeline PKF wishes to contribute its part towards the next budget implementation and for this purpose it has researched new areas which in its opinion warrant attention by the government during the public… – Continue reading
The Indian cabinet on Wednesday approved foreign investment in Alternative Investment Funds (AIFs), a category of pooled-in investment vehicles for real estate, private equity and hedge funds, reports Bloomberg. The move comes after Finance Minister Arun Jaitley promised in his Budget speech that rules will be liberalised to channel more… – Continue reading
The international press, especially the Italian one, has been filled these past days with stories of ‘Ndrangheta criminals who have been arrested in Italy and who seem to have links with online gaming companies in Malta which they may have been using for money laundering. This is bad news for… – Continue reading
Requiring the Land Registry to publish information about foreign companies that own property in England and Wales could ultimately speed up the recovery of money from fraudsters who have “hidden” victims’ money in a variety of corporate structures, an expert has said. UK prime minister David Cameron announced new measures… – Continue reading
As U.S. expats struggle with the IRS’s punitively strict tax reporting requirements, Canadian expats are now grappling with harsh government measures of their own. Ontario’s top court has ruled that Canadian expats who have lived abroad for five years should not be allowed to vote in federal elections because it… – Continue reading
The European Union (EU) doesn’t like the special tax deals that are offered to companies to entice them to set up in Switzerland. So the Swiss government is working hard to find a replacement. One element of their new plan is to offer patent boxes. A recent study by economists… – Continue reading
The Prime Minister took small bites as he tucked into the Indonesian street food alongside a local celebrity, singer and actress Maudy Ayunda. “London is not a place to stash your dodgy cash”. Transparency worldwide says shell companies are a common way for moving corrupt money around the world. Some… – Continue reading
Understanding FATCA and having a comprehensive FATCA compliance program is essential for financial firms to limit non-compliance risk and meet obligations with relevant IGA’s. The US has made inroads on the Exchange of Information front and tax havens like Switzerland have declared a willingness to meet or even exceed OECD… – Continue reading
An investor, who purchased shares of Silver Wheaton Corp. (USA) (NYSE:SLW), filed a lawsuit in the U.S. against Silver Wheaton Corp. in connection with certain allegedly false and misleading statements made between March 30, 2011 and July 6, 2015. Investors who purchased a significant amount of shares of Silver Wheaton… – Continue reading
Over the past year, a number of legislative measures have been adopted to ensure that the Cayman Islands remains the leading jurisdiction of choice for structured finance and capital markets transactions and for secured lending transactions generally. This article focuses on two recent key legislative developments. The first is the… – Continue reading
Over the past year, a number of legislative measures have been adopted to ensure that the Cayman Islands remains the leading jurisdiction of choice for structured finance and capital markets transactions and for secured lending transactions generally. This article focuses on two recent key legislative developments. The first is the… – Continue reading
The Mauritius Revenue Authority has extended the Foreign Account Tax Compliance Act (FATCA) reporting deadline to 31 August 2015. The FATCA Agreement between Mauritius and the United States was signed on 27 December 2013. FATCA seeks to obtain information on accounts held by U.S. taxpayers in other countries. It requires… – Continue reading
On June 22, 2015, the finance ministry issued Circular 96/2015/TT-BTC, guiding the corporate income tax regime in Decree 12/2015/ND-CP (“Decree 12”) of the government, dated February 12, 2015. Decree 12 provides the details for the implementation of the law that amends and supplements some articles of tax laws, tax decrees… – Continue reading
There is a rising trend that many start-ups incorporate their ultimate holding companies abroad, especially in Singapore for various reasons with tax being one of the top 3 factors for such decisions. Some of them have restructured the holding structures after few months of direct Indian holding to accommodate requests… – Continue reading
Kenya collected 1.001 trillion shillings ($10 billion) in the fiscal year to end-June, a 3.86 percent increase from the previous year, the Treasury said on Wednesday. Officials in East Africa’s biggest economy are aiming at increasing tax collections to fund several infrastructure projects, including a new railway, and pay for… – Continue reading
GOMA, DEMOCRATIC REPUBLIC OF CONGO—The Democratic Republic of Congo’s biggest-ever corruption probe was called off without an official explanation, according to both a Congolese lawmaker and a government spokesman. Investigators were looking into fraud that may have cost the government more than $3 billion. It was an investigation of alleged… – Continue reading
There has been much recent focus on tax structures employed by multi-national corporations. This has led to an initiative, spearheaded by the OECD, to combat “base erosion and profit shifting”, or BEPS. The shipping industry is likely to be affected both directly and indirectly by the BEPS initiative – directly,… – Continue reading
Introduction The Cyprus Government has announced a number of proposed tax incentives aimed at encouraging economic activity and attracting inward direct investment. It has also submitted a number of draft laws to the House of Representatives to implement the new provisions of the EU Parent-Subsidiary Directive, to simplify the tax… – Continue reading
Blaming foreigners for homegrown economic woes is a tradition of sorts in Washington. In recent years, the favored scapegoat has been China and its folkloric trade indiscretions. But, lately, some have taken to demonizing foreign companies for the sins of a broken U.S. corporate tax system. Given the importance of… – Continue reading
A U.S. Senate investigative subcommittee, which has used its power for more than a decade to scrutinize corporations and financial institutions for wrongdoing, is shifting its focus to keeping tabs on the government. The U.S. Senate Permanent Subcommittee on Investigations is slated to hold its first hearing under new leadership… – Continue reading
Foreigners must not be able to buy UK homes with “plundered or laundered cash” as part a global effort to defeat corruption, David Cameron has said. Speaking in Singapore, the prime minister vowed to expose the use of “anonymous shell companies” to buy luxury UK properties – often in London…. – Continue reading
Why stop at $221 billion? Drug companies are entering another round of dealmaking, after plowing past the global record. Teva Pharmaceutical Industries Ltd.’s $40.5 billion agreement Monday to purchase Allergan Plc’s generic-medicines business puts the mechanism in place to trigger more takeovers. For starters, the remaining Allergan company — with… – Continue reading
In the first 100% Conservative Budget in nearly two decades, chancellor George Osborne has introduced a raft of changes, including significant revisions to UK non-dom status. On 8 July, chancellor George Osborne delivered the first Conservative Government Budget for 19 years. Many headlines had already been flagged up in advance,… – Continue reading
None of the pharmaceutical companies that are accused of profit shifting have been taken to court, the Australian Taxation Office has said in written responses to the Senate inquiry into corporate tax avoidance. Earlier in July executives from the largest global pharmaceutical companies operating in Australia were hauled before the… – Continue reading
A litigation suit has been filed against the US federal government arguing the Foreign Account Tax Compliance Act (FATCA) is “unconstitutional” and violates privacy rights, with implications for Australian financial institutions. The controversial FATCA tax legislation – which was introduced by the Obama Administration in 2010 – requires foreign financial… – Continue reading
The Organisation for Economic Co-operation and Development’s (OECD’s) Parliamentary Group on Tax is meeting for the fourth time to discuss the implementation of the base erosion and profit shifting (BEPS) project. The meeting will take place in Paris on October 19, 2015. The timing has been carefully chosen to fall… – Continue reading
The Barbados Revenue Authority (BRA) will host a public seminar this week entitled “Implementing the Foreign Account Tax Compliance Act: Where Are We Now?” The event will provide representatives and employees of financial institutions who do business with US persons with an update on the US Foreign Account Tax Compliance… – Continue reading
The July 21 edition of the Brazilian Official Gazette contained provisional measure 685 (PM 685), which creates an obligation on taxpayers to formally report to tax authorities certain transactions that result in tax benefits. The requirement is supposedly in line with the OECD’s base erosion and profit shifting (BEPS) project… – Continue reading
FEW tax hikes have been timed so badly – and retracted so fast – as that imposed on mineral royalties by Zambia’s President Edward Lungu in January. After threats of divestment from major mining houses and an outcry from the country’s Chamber of Mines, the massive hike in royalty taxes… – Continue reading
