Category: Activity

Financial institutions must prepare for ‘FATCA on steroids’

Financial institutions around the world must ‘get their act together’ for the introduction of the OECD’s Common Reporting Standard (CRS) in seven months, Linedata has warned. Justin Hayes, product manager at the international software provider, dubbed the automatic exchange agreement between an initial 58 countries “FATCA on steroids’ and an… – Continue reading

FactCheck: Christie’s tax dodge

He has distorted the facts about the nation’s current tax system. Chris Christie repeatedly has said that U.S. corporations are taxed twice on income earned abroad, claiming in one speech that IRS officials “don’t recognize the tax you paid to a foreign country.” That’s false. It’s true that the U.S…. – Continue reading

Russian Federation: Russian De-Offshorisation Legislation And Voluntary Disclosure: Which Way Now?

The new law on the taxation of controlled foreign companies (the ‘CFC’ law) and other anti-offshore measures effective as of 1 January 2015 have raised a number of questions for clients and advisers. A number of changes to the new laws were long anticipated and have now been passed by… – Continue reading

APAs key to resolve transfer pricing disputes

Transfer pricing has emerged as a key focus area both globally and locally. From an international scene, the OECD/G20 venture — a club of advanced countries in Europe and North America, has been working on action plans to help tax administrations deal with Base Erosion and Profit Shifting (BEPS) project…. – Continue reading

China and Chile sign DTA

On May 24, Premier Li Keqiang and a delegation of Chinese senior officials arrived in Chile. During the visit, China and Chile signed a double taxation avoidance agreement (DTA), updated their Free Trade Agreement and agreed on setting up an RMB clearing center in Chile, reports China Briefing. China and… – Continue reading

Governments risk falling short of FATCA demands

Governments around the world could find themselves under-resourced when the Foreign Account Tax Compliance Act deadline for collecting information on US clients arrives in September, one expert has said. Ellen Zimiles, managing director, head of global investigations at US firm Navigant, said governments will be handed an “unprecedented” amount of… – Continue reading

IRS Reminds of June FBAR, FATCA Deadlines

The Internal Revenue Service Wednesday reminded taxpayers with offshore accounts of two important June deadlines related to Foreign Bank and Financial Accounts filings and the Foreign Account Tax Compliance Act. All taxpayers with a FBAR filing requirement must report their foreign assets by June 30, with those taxpayers living abroad… – Continue reading

Bermuda: Minister Richards examines global tax threats

Speaking at the Insurance Day 2015 Summit on 10 June 2015, Minister of Finance Bob Richards told attendees that “the more we drive home that the insurance sector in Bermuda is not a stereotypical tax haven gimmick to key onshore decision makers the less the threat from IRS and other… – Continue reading

G7 to Clamp Down on Tax Avoidance Via Transfer Pricing

Multinational firms said to be ‘cheating’ African countries out of billions of dollars that could be used for health care and education. G7 leaders Monday pledged to reform the international tax system by minimizing transfer pricing, according to Public Finance International. Transfer pricing involves internal transactions between a large company’s… – Continue reading

G7 fails to stop the dirty money trail, tax evasion

Dirty money resulting from crime, corruption and tax evasion is estimated to cost over one trillion dollars every year. It exacerbates poverty and inequality, and should be regarded as one of the most pressing issues globally. An Oxfam report found that G7-based companies and investors cheat Africa out of tens… – Continue reading

North-East is becoming dustbin for Scotland’s rubbish, MP warns

THE North-East is becoming a “dustbin” for Scottish rubbish because of devolution, one of the region’s MPs has warned. Kevan Jones, the North Durham MP, said a “commendable” Scottish initiative to boost recycling had backfired by sending waste across the border instead, sometimes illegally. And he warned the problem was… – Continue reading

New EU anti-money laundering rules to take effect from 26 June

A raft of reforms to EU anti-money laundering rules will come into force later this month after they were finalised and published in the official journal of the EU, reports Out Law. The fourth Anti-Money Laundering (AML) Directive will take effect from the 26 June. EU countries will have two… – Continue reading

Australia plans new law on tax avoidance

Sydney, 10 June (Argus) — The Australian government has released legislation to tighten rules governing corporate taxation such as the use of offshore tax havens. The bill is not aimed at any particular sector of the economy, but several resource and commodity companies have come under scrutiny following a Senate… – Continue reading

Bahamas: Financial services keeping up with international best practices claims Strachan

Minister of Financial Services the Hon. Hope Strachan said international best practices are evolving at a rapid pace, particularly as it relates to automatic tax exchange initiatives, tax transparency, anti-money laundering and financial crime, and e-commerce, reports the Bahamas Weekly. Making her contribution to the 2015 Budget Debate in the… – Continue reading

Diverted profits tax – just for Google or relevant to insurance?

The Diverted Profits Tax (DPT), known by many as the “Google Tax”, is intended to stop large groups diverting profits from the UK by seeking to avoid creating a UK permanent establishment or using arrangements or entities which lack economic substance to exploit tax mismatches. Tax mismatches occur where intra-group… – Continue reading

G7 leaders move toward automatic exchange of tax information

Heads of state meeting at the G7 Summit in Bavaria, Germany committed to promoting automatic exchange of tax information and tax rulings to discourage multinational companies from shifting profits from country to country to avoid taxes, reports Accounting Today. In a joint declaration, the G7 leaders reaffirmed their commitment to… – Continue reading

Swiss Bankers Losing Secrecy Helps Image Abroad, Finma CEO Says

Swiss banks that aren’t dependent on the country’s crumbling financial secrecy laws may find international expansion easier than those that sold hidden accounts in the past, according to Switzerland’s financial supervisor. “The shift away from businesses which rely on some elements of banking secrecy is changing the perception” of Swiss… – Continue reading

Hong Kong needs to catch up with latest global tax standards

Hong Kong, as a world financial centre, will undertake legislative changes to implement automatic exchange of information of account holders Exchange of information is a recognised tool to enhance tax transparency and combat cross-border tax evasion. As a major financial centre, Hong Kong is committed to following global standards. While… – Continue reading

Argentine Supreme Court rule on transfer pricing of commodity exporters

The Argentine Supreme Court ruling on Toepfer International, a commodity exporting firm, has finally been published, tw o months after the decision, providing lessons for BEPS action 10 (cross border commodity transactions). This case, AFIP v Alfred C Toepfer Internacional, belongs to the first group of three controversies, related to… – Continue reading

Israel: Renewing Your US Passport? The IRS Will Know About It

Individuals who renew their US passport need to take into consideration that their Social Security Number (SSN) and country of residency will be forwarded to the IRS. Since July 2014, the passport renewal instructions forms have dedicated a specific paragraph detailing this new procedure: “Section 6039E of the Internal Revenue… – Continue reading

ETVEs (Spanish foreign-securities holding companies)

A special scheme is provided for foreign-securities holding companies or ETVEs (Entidades de Tenencia de Valores Extranjeros) in the Corporate Income Tax (“CIT”) Act 27/2014. ETVEs are regular limited liability companies (S.L., S.A. or other company forms), subject to the normal CIT on its income, but exempt from taxation on… – Continue reading

Victor Ponta says he would face court as Romanian MPs uphold immunity

Prime minister says he has proof he is innocent of charges of money laundering and tax evasion while president calls for his resignation Victor Ponta, Romania’s prime minister, said on Tuesday that he was prepared to go to court to answer charges of money-laundering, forgery and tax evasion as the… – Continue reading

Swiss government wants banks’ extra care to avoid untaxed money

Switzerland’s government wants banks to toughen up checks to avoid accepting untaxed assets, possibly including a refusal to do business with a client who can’t show the money has been regularized, reports Bloomberg. For clients from countries that aren’t covered by automatic exchange of information agreements, banks will need to… – Continue reading

Recent Tax Treaty Developments In Cyprus

Proposed Amendments To Cyprus’s Assessment And Collection Of Taxes Law The Cyprus Government has published a draft law amending the Assessment and Collection of Taxes Law (Law 4 of 1978) in order to facilitate implementation of agreements for automatic exchange of information with other countries. When it is enacted, the… – Continue reading

Modi’s goal of a tax-friendly India faces the hurdle of manpower

New Delhi/Mumbai: India’s goal of a friendlier tax regime for global companies to help power China-beating economic growth is hitting a manpower hurdle. Fewer than 20 officials face the complex task of working with hundreds of multinational companies (MNCs) on pacts to avert tax rows, people familiar with the matter… – Continue reading

United States: International Tax Reform Heats Up

Top congressional lawmakers have ramped up discussions over international tax reform as the outlook for business and comprehensive reform has dimmed. The president has flatly rejected individual rate cuts, and efforts toward business-only reform have flagged as the pass-through community has rejected most proposals that would leave it out of… – Continue reading

Domestic Woes Drive Brazilian Wealth to Offshore Markets

The country’s affluent investors have roughly doubled their offshore investment, curbing growth at Brazil’s wealth management firms. Scandal, recession and weak oil prices have caused economic vitality to seep out of Brazil. Now the money is following. Wealthy Brazilians are sending more of their assets overseas because of concerns about… – Continue reading

OECD releases Implementation Package for BEPS country-by-country reporting

08/06/2015 – Pushing forward efforts to boost transparency in international tax matters, the OECD today released a package of measures for the implementation of a new Country-by-Country Reporting plan developed under the OECD/G20 BEPS Project. The Country-by-Country Reporting Implementation Package will facilitate a consistent and swift implementation of new transfer… – Continue reading

BEPS: The impact of the interest limitation rule on investment

OVERSEAS investment by Thai companies has been surging in recent years and this trend is almost certain to continue. One of the questions frequently asked by Thai investors when seeking to acquire foreign operating companies or establish overseas subsidiaries is what type of funding structure would be the most tax… – Continue reading

Fourth European Anti-Money Laundering Directive launches UBO-register

On 20 May 2015, the European Parliament increased the hunt for tax evaders, money launderers and terror financiers by adopting the fourth instalment of the Anti-Money Laundering Directive (“AMLD”). The main novelty of the new directive is the introduction of a central UBO-register, a public register which identifies the ultimate… – Continue reading

Tax consequences of foreign companies rendering services in South Africa

Where a foreign company renders professional services to a South African company, it is important that the foreign entity considers whether, as a result of rendering such services, the foreign company will create a permanent establishment in South Africa. The reason why this becomes important is that where a foreign… – Continue reading

Tax proposals for multinationals will have ‘massive impact’

OECD propose country-by-country reports on their financial affairs Proposed new obligations on multinationals to produce country-by-country reports on their financial affairs will have a “massive impact” on them, a leading member of the Organisation for Economic Development and Cooperation has said. Pascal Saint-Amans , director of the Center for Tax… – Continue reading

ICSS to hold special session on financial integrity and transparency

June 8 – With the international spotlight focused on corruption and money-laundering at FIFA and doping claims in athletics, the Qatar-based International Centre for Sport Security (ICSS) is laying on a specialist session in Geneva in September to explore how sport, governments and the wider stakeholder community can tackle the… – Continue reading