Category: Activity

BEPS Action 8: OECD proposes introducing hindsight into the transfer pricing of hard-to-value-intangibles

On 4 June, the Organisation for Economic Co-operation and Development (“OECD”) published a discussion draft on “hard-to-value-intangibles” in terms of which the OECD proposes revising its Transfer Pricing Guidelines. In particular, it is proposed that tax authorities will be allowed to use ex post “evidence”, (i.e. hindsight), to assess the… – Continue reading

US and UK FATCA – British Virgin Islands Self-Certification on Account Holders

The International Tax Authority (ITA) of the British Virgin Islands has released templates for Individual and Entity Self-Certification Forms under US and UK FATCA. Copies can be found on the BVI Government’s website. The templates have been issued to assist BVI Reporting Financial Institutions (FFIs) – they can be used… – Continue reading

Tax information agreements burdensome to financial industry

The implementation of tax information reporting agreements is costing the financial services sector a pretty penny. Financial Services Councillor Roy McTaggart told Cayman 27 the industry has spent time and money making sure their systems are compatible with government’s recently established reporting portal, which ultimately transmits the information to the… – Continue reading

AirAsia X wants SC action against GMT Research’s ‘misleading statements’

SEPANG: AirAsia X Bhd (AAX) has lodged an official complaint with the Securities Commission (SC) against GMT Research and seeks the regulator’s appropriate action against the research house for various misleading statements and allegations. AAX said GMT had accused the long-haul budget carrier, among others, of practising or allowing profit… – Continue reading

Italy Ratifies FATCA Agreement with US

Italy has ratified the inter-governmental agreement top facilitate compliance with the United States Foreign Account Tax Compliance Act. FATCA, enacted by the US Congress in 2010, is intended to ensure that the US obtains information on accounts held abroad at foreign financial institutions (FFIs) by US persons. Failure by an… – Continue reading

End capital gains tax exemption to curb money laundering: BSE

MUMBAI: The Bombay Stock Exchange (BSE) today called for ending exemption of capital gains tax on securities to contain various entities using capital markets to evade taxes and launder money. The government should re-think the exemption on capital gains taxes on traded securities, which listed companies enjoy, in order to… – Continue reading

Australia To Introduce Foreign Resident Capital Gains WHT

The Australian Government will introduce a withholding tax obligation to ensure that foreign investors comply with Australia’s tax laws. The Government has released exposure draft legislation that provides for the application of a ten percent non-final withholding obligation on the disposal by foreign residents of taxable Australian property. If passed,… – Continue reading

IMF Executive Board Concludes 2015 Article IV Consultation with Panama

The FINANCIAL — On June 10, 2015, the Executive Board of the International Monetary Fund (IMF) concluded the Article IV consultation with Panama. Panama’s economic performance is expected to remain strong. Real GDP slowed to 6.2 percent in 2014, reflecting a slower pace of public investment, continued weakness in Colon… – Continue reading

George Osborne’s family reportedly ‘struck a £6m property deal’ with firm based in tax haven

George Osborne’s family business struck a £6m deal with a property developer based in an offshore tax haven, it has been reported. The upmarket wallpaper firm Osborne & Little is claimed to have linked up with a corporation in the British Virgin Islands to turn its former headquarters in an… – Continue reading

Budget boost for HMRC in new push on tax evasion

Around £60m earmarked for serious and complex tax-crime investigations, while £300m will target small businesses, public bodies and affluent individuals Stretched HMRC tax investigators are to be armed with £800m of extra funding over the next five years to combat tax evasion and non-compliance, the chancellor has promised, as part… – Continue reading

Serial tax avoiders to be ‘named and shamed’, Osborne reveals

The UK’s chancellor of the exchequer has said serial users of tax avoidance schemes will be ‘named and shamed’ as he promised to introduce further measures to tackle evasion, avoidance and aggressive tax planning in his Summer Budget. This move is part of a plethora of changes which chancellor George… – Continue reading

Horizon launches $3bn hostile bid for Depomed

Ireland’s Horizon Pharma has launched a hostile takeover bid for Depomed of the US after being frustrated in its efforts to enter negotiations about combining the two companies. Horizon was a US company until September 2014 when it closed a $660m takeover of Irish company Vidara Therapeutics just days before… – Continue reading

Report highlights Jersey as a conduit for FDI

Jersey has attracted foreign direct investment worth more than US$65bn and distributed FDI worth more than US$75bn, according to a new report, which highlights the territory’s contribution to the global economy, reports Tax News. The report, “Jersey’s Contribution to FDI,” was produced by global management advisory firm Investment Consulting Associates… – Continue reading

ATO warns multinationals over use of Singapore, Swiss and other offshore hubs

The Australian Taxation Office has warned companies it will be focusing on money attributed to offshore marketing hubs and will use its stronger transfer pricing powers to go after them, reports the Sydney Morning Herald. Australian companies sent more than AU$100 billion to related parties in the low-tax nation of… – Continue reading

American Companies Dodge U.S. Taxes, Yet U.S. Government Still Awards Them Massive Contracts

“American” corporations that “invert,” or establish offshore domiciles in order to avoid payment of U.S. taxes, are still feeding at the government trough. They have benefited from American laws, courts and infrastructure, becoming obscenely wealthy – yet refuse to return the favor to We The People. And who and what… – Continue reading

Bipartisan Senate Plan Confuses Real Tax Reform with Tax Cuts for Multinational Corporations

Sens. Rob Portman (R-Ohio) and Chuck Schumer (D-NY) today released a long-awaited tax reform plan that reads like a wish list for multinational corporations. The Senate Finance Committee working group’s report provides recommendations for restructuring the federal government’s international corporation tax rules. The plan is long on misguided ideas and… – Continue reading

Liechtenstein FATCA Reporting Deadline Extended

The Liechtenstein tax authorities have announced that the FATCA reporting deadline in Liechtenstein has been extended to 31 July 2015 (from 30 June 2015). FATCA seeks to obtain information on accounts held by U.S. taxpayers in other countries. It requires U.S. financial institutions to withhold a portion of certain payments… – Continue reading

Cayman will implement OECD automatic exchange this year

The ministry of financial services has announced that Cayman will implement the OECD common reporting standard later this year. The CRS standardizes the global automatic exchange of information for tax purposes. Automatic exchange of information will ultimately lead to the transmission of large amounts of data, such as the investment… – Continue reading

Japan MoF names Masatsugu Asakawa as top financial diplomat

Japan’s Ministry of Finance said international policy veteran Masatsugu Asakawa will become the country’s top financial diplomat, whose tasks include co-ordinating with other nations and the IMF as well as arranging currency interventions. Asakawa’s broad network with policymakers both inside and outside Japan puts him in an ideal position to… – Continue reading

Tax Inspectors Shrug Off Borders to Track Multinational Evasion

Step aside, Doctors Without Borders. A new class of professionals is ignoring national frontiers to come to the aid of economically struggling nations. A team called Tax Inspectors Without Borders will begin helping developing countries deal with the flood of income to low-tax jurisdictions once it’s established next week by… – Continue reading

How non UK residents should buy or own residential property

How should non resident or non domiciled buyers of UK residential property own or hold residential property? Overseas buyers or owners of UK residential property above £1m in value need to consider carefully in what name or legal structure they should buy or hold property for their protection and to… – Continue reading

Planning For Qualified Dividend Income When Taking Foreign Companies Public – Tax Update Volume 2015, Issue 2

Where Qualified Dividend Treatment Is Important, Serious Consideration Should Be Given to Ensuring the Company Is Eligible for Treaty Benefits Before Taking It Public. Dividends generally are taxed at ordinary income rates (up to 39.6 percent for individuals). Qualified dividends derived by individuals, however, are taxed at the preferential rate… – Continue reading

Abuse of tax treaties must end

Agreement with Mauritius to be renegotiated. National Treasury says the abuse of double tax agreements by multinational companies is the main reason why the agreement with Mauritius has been renegotiated. National Treasury head of tax and financial sector policy Ismail Momoniat says companies have often used dual tax residence structures… – Continue reading

Sixty-four per cent of Insurance CEOs see increasing tax burden as a threat to their growth prospects

The FINANCIAL — Tax is firmly under the spotlight and in the global insurance industry, the ramifications for finance and tax teams will be felt in both a new set of business demands and an overhaul of how these functions interact and operate. However, a new report from PwC says… – Continue reading

FATCA and Cayman Funds

With the first round of US FATCA reporting completed on Friday, 26 June, Cayman Islands Reporting Financial Institutions (RFIs) can now begin their summer relaxation in earnest, having successfully navigated the complex notification and reporting processes. For many, the process has been all-consuming since 1 January, when FATCA went live,… – Continue reading

Government plans to crack down on domestic money laundering, issues answers to FAQs

NEW DELHI: India said it was cracking down on attempts to launder black money locally and told people with unaccounted assets abroad that it will become increasingly difficult to conceal these, urging them to make use of a window that shuts on September 30. The government will start receiving financial… – Continue reading

India likely to sign US tax compliance law FATCA on Thursday

NEW DELHI: India is likely to sign the inter-governmental pact for the US tax compliance law FATCA on Thursday, a move that will help it fight tax evasion. Foreign Account Tax Compliance Act (FATCA) is aimed at combating possible tax evasion by Americans through financial entities of other countries. The… – Continue reading

France: French Tax Update – Recently Published Noteworthy Decisions – July 2015

The present French Tax Update will focus on an overview of several noteworthy French tax court decisions issued during the past few months. BUYBACK AND CANCELLATION OF OWN SHARES The tax treatment of buybacks, from the shareholders’ point of view, has now been simplified through a change of legislation, i.e.,… – Continue reading

Private Equity Newsletter – Summer 2015 Edition: Indian Private Equity: Taxation and Trends

With a new government at India’s center and positive macroeconomic fundamentals working in its favor, the private equity industry is expected to invest more actively into India over the short to medium term. In the past year, inflation has steadily tapered, the fiscal deficit has been reduced, domestic demand has… – Continue reading

London estate agents caught on camera dealing with ‘corrupt’ Russian buyer

Channel 4 documentary shows agents in wealthy districts agreeing to continue with purchase to be made with ill-gotten gains from Russian health budget Top estate agents in Britain’s wealthiest postcodes are willing to turn a blind eye to apparent money laundering by corrupt foreign buyers, according to an investigation by… – Continue reading

Possible legislation restricting interest deductions in Finland for tax purposes

Industrial & Manufacturing groups which have operations in Finland, should review their funding arrangements to ensure they remain tax effective following a recent case in Finland which may now be put on a statutory footing. The Finish tax authorities treated a hybrid instrument as equity and the related interest expense… – Continue reading

United Kingdom: Overview of Tax Regime

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

Corporate group: WH tax proposals off base

A corporate tax reform coalition blasted President Obama’s international tax proposals on Tuesday, saying they would accelerate the sort of offshore maneuvers that Democrats want to eliminate. The Alliance for Competitive Taxation said that the White House’s proposal to impose a minimum tax on multinational corporations’ foreign earnings would only… – Continue reading

Bridgepoint To Snap Up Offshore Trust Giant

Booming demand for offshore tax services will trigger a £240m takeover deal involving a unit of Appleby Global, Sky News learns. The booming demand for offshore trust and fund administration services will be underlined in the coming days by a $370m (£238m) takeover deal involving Bridgepoint, the London-based buyout firm…. – Continue reading

Cabinet to remove Austria from list of risky countries for transfer pricing on August 1, 2015

Ukraine’s Cabinet of Ministers will remove Austria from the list of countries transactions with whose counterparties are subject to control under the law on transfer pricing on August 1, 2015. This is stipulated in Cabinet resolution No. 677 dated July 1, 2015, which is available on the government website on… – Continue reading