State agencies have had their reasons to keep the cases silent. However, this has angered the public and economists. Silence gives the public another reason to believe that many names on the black list of FIEs (foreign invested enterprises) conducting transfer pricing have not been exposed. Nguyen Duc Kien, deputy… – Continue reading
The Treasury Department announced draft changes for the U.S. Model Income Tax Treaty — the baseline text used by the Treasury Department when it negotiates tax treaties. The current U.S. Model was last updated in 2006. The proposed changes in the draft provisions are intended to combat so-called Base Erosion… – Continue reading
The Cayman Islands Department of International Tax Cooperation has extended the deadlines for Cayman Reporting Financial Institutions (RFIs) to provide notification and reporting and to the Tax Information Authority for U.S. FATCA Reportable Accounts. RFIs now have until Friday, May 29, 2015 to submit notifications. The new reporting deadline is… – Continue reading
The Inland Revenue Board (IRB) has informed Malaysian financial institutions (MYFIs) that their filing deadline in respect of the 2014 reporting year under the US Foreign Account Tax Compliance Act (FATCA) has been deferred from June 30, 2015. FATCA requires all FIs outside the United States to submit regular information… – Continue reading
The city’s most famous real-estate marketer has said he’s “leaning toward” supporting a levy on people who buy and then sell homes over a short period of time. “I suggest we look at a declining tax that sees a percentage of profits taxed if a home is sold—whether it’s three… – Continue reading
MUMBAI: The Central Board of Direct Taxes (CBDT) is taking a close look at 120 transfer pricing disputes with a view to settling them as the Narendra Modi government tries to rid India of the label that it’s overly aggressive on taxation. While the government aims to sign the 120… – Continue reading
Rio Tinto’s head of tax – who was recently hauled before the Senate inquiry into corporate tax avoidance about the lack of tax the miner pays – will now be also advising the Abbott government on how to improve the tax system and increase transparency in relation to the tax… – Continue reading
The ultimate owners of companies will have to be listed in central registers in EU countries, under new rules agreed by the EU Council and endorsed by the European Parliament yesterday. Access to the register is restricted but will nonetheless be open both to the authorities and to people with… – Continue reading
Georgia and Poland held negotiations in Warsaw this week over an agreement on avoiding double taxation on income and capital. At the bilateral meeting the sides initialed the renewal agreement, which is based on the OECD Model Convention 2014 and envisages the introduction of new standards of cooperation in taxation… – Continue reading
Canada’s health-care stocks are sizzling, as Concordia Healthcare Corp. and Valeant Pharmaceuticals International Inc.’s buy-and-streamline strategy has pushed the industry’s earnings and margins ahead of U.S. peers. The drugmakers are the two top-performing stocks in the Canadian equity benchmark this year, boosting total returns for the members of the Standard… – Continue reading
The ultimate owners of companies will have to be listed in central registers in EU countries, open both to the authorities and to people with a “legitimate interest”, such as investigative journalists, under new rules already agreed with the Council and endorsed by Parliament on Wednesday. The new anti-money laundering… – Continue reading
NUMBER OF THE WEEK: 40 percent. The average combined federal and state tax rate paid by most U.S.-based firms, according to a Wall Street Journal op-ed by James Freeman today, entitled “The Tax Takeover Craze.” Freeman claims this is “roughly double the average in Europe and Asia,” and is the… – Continue reading
It is quite clear that the more recent past has seen a notable shift in the debate from various supranational initiatives implemented over the years, designed to curtail the activities of smaller offshore financial centres, towards the real issues of tax transparency, regulatory cooperation and managing systemic risk in the… – Continue reading
AUGUSTA — A measure to prevent multinational corporations from evading Maine taxes by hiding profits in offshore tax havens won initial approval in the state’s Democratic-controlled House of Representatives on Thursday on an 81-67, party-line vote. The bill, LD 341, sponsored by state Rep. Ryan Tipping-Spitz, D-Orono, requires Maine companies… – Continue reading
OECD, G20 team up to plug loopholes that allow companies evade taxes in jurisdictions they operate to prevent tax base erosion There is now a serious global attempt to ensure that multinationals pay taxes in the jurisdiction in which they carry out their business. The attempt is being made keeping… – Continue reading
1. Global focus on transfer pricing There has been a recent surge in regulatory attention around the world towards pricing arrangements within multinational corporate groups. Regulators are concerned that these pricing arrangements may be used as a means of profit shifting and therefore tax avoidance. The price at which an… – Continue reading
In 2014, the Organization for Economic Co-operation and Development (“OECD”) began making recommendations to Member States for the implementation of certain actions aimed at limiting base erosion and profit shifting, known as “BEPS”. The project includes 15 actions, representing 15 areas of regulation that allow states to monitor data which… – Continue reading
German tax law allows deferring the tax on certain disposal gains by transferring the hidden reserves in the disposed assets to similar newly acquired or newly produced assets (“Replacement Assets”). The tax deferral requires an allocation of the Replacement Assets to a German permanent establishment. The ECJ has recently ruled… – Continue reading
Egyptian tax on shares sold by non-residents In 2014, the Egyptian Income Tax law was changed to introduce a 10% Egyptian tax charge on the net gain realised on a disposal of shares in an Egyptian company. This tax charge is intended to apply to non-resident as well as resident… – Continue reading
Bankrupt ex-billionaire Samuel Wyly won a judge’s approval to sell his family’s Colorado ranch, the site of six custom-built homes. The bankruptcy judge in Dallas Wednesday also said Wyly could provide a loan to pay for the ranch’s upkeep before it’s sold. The property will be listed for $50 million,… – Continue reading
By stopping bogus claims of residency, his idea would force foreigners to pay capital gains tax when they sell a home in Canada OTTAWA — Inspired by the legendary FBI ploy to nab a notorious gangster, a B.C. immigration lawyer suggests the Canadian tax system be used to discourage the… – Continue reading
Jean-Claude Juncker, President of the European Commission, just got a step closer to explaining his role in the Lux Leaks scandal. Speaking after an official visit to Luxembourg, German Member of the European Parliament, Fabio De Masi said: “It is becoming increasingly clear that powerful EU member states like Germany… – Continue reading
ALTHOUGH there is no conclusive evidence as to how much money South Africa is losing in terms of transfer pricing, the mining and extractive industries are responsible for R3.4bn of it. Dumisani Jantjies, financial analyst of the parliamentary budget office, singled out the mining industry as one of the biggest… – Continue reading
Cape Town – Arts and Culture Minister Nathi Mthethwa wants artists and performers to get a financial break and will ask the Davis tax committee to give them tax incentives. Mthethwa told journalists in Parliament on Tuesday, during a briefing on his budget vote, that the department would meet the… – Continue reading
BRUSSELS, May 20 (KUNA) ¬¬ The European Parliament Wednesday endorsed the new anti¬money laundering legislation to step up the fight against tax crimes and terrorist financing. The anti¬money laundering law will for the first time oblige EU member states to keep central registers of information on the ultimate “beneficial” owners… – Continue reading
IRS Rules That Policyholder Owns Mutual Fund Shares Under Nonqualified Deferred Annuity Contract The IRS ruled in Private Letter Ruling 201519001 on the tax treatment of a nonqualified deferred annuity contract issued by a life insurance company, finding that public mutual fund shares under the contract will be treated as… – Continue reading
The finance ministry will in the near future add Controlled Foreign Corporation (CFC) rules to the Income Tax Act in order to prevent the tax deferral that many Indian multinational companies resort to by not repatriating the profits of their foreign subsidiaries for long periods. The proposed rules will come… – Continue reading
Addis Ababa, 19 May 2015- (ECA) – Africa’s money that could be used to improve lives and reduce poverty is leaving the continent through illicit financial flows defined as money illegally earned, transferred and used. As the Chairperson of the High Level Panel on Illicit Financial Flows from Africa, the… – Continue reading
Introduction Tax avoidance, however legitimate its mechanism, has become the new focus for public opprobrium in parts of the world. High-profile cases and media attention examining the tax strategies of major global companies operating primarily in the digital economy have all contributed to this shift of focus. How are the… – Continue reading
INTRODUCTION On May 5, 2015 the Swiss Federal Supreme Court held a public hearing about two cases relating to the reclaim of Swiss withholding tax (WHT) in connection with arbitrage cases and issued its long awaited decisions. Two Danish banks issued the question on treaty entitlement for the refund of… – Continue reading
International fast-food giant McDonald’s avoided paying half a billion dollars of tax in Australia over a five-year period by shifting profits through the low-tax nation of Singapore, a new report by a global coalition of trade unions says. The report, which has been funded and commissioned by a coalition of… – Continue reading
(Special) — The recent slump in oil prices is causing many Canadian investors to move their money from energy-weighted markets at home to foreign markets for better yields. While this may be a profitable investment strategy, it also can create its own set of problems because many investors may not… – Continue reading
Ahead of their joint event on Deoffshorisation Compliance on 21 May, TMF Group’s Sub Regional Director for CIS and the Nordics Alex Medlock and Artem Toropov, Senior International Tax Associate at law firm Goltsblat BLP LLP (the Russian practice of Berwin Leighton Paisner), outline the key deoffshorisation/CFC compliance requirements and… – Continue reading
Differences in how new accounts are treated by the US, the UK and Canada under the Foreign Account Tax Compliance Act are raising tough questions for banks across many jurisdictions, practitioners told Bloomberg BNA. “This is not an insignificant issue,” said Alan Granwell, of counsel with Sharp Partners P.A. in… – Continue reading
The Cabinet of Ministers of Ukraine has added Austria, Turkmenistan, Hong Kong and Niue to the list of countries transactions with which are subject to control under the administration of the law on transfer pricing. Corresponding Cabinet decree No. 449 dated May 14 has been posted on the website of… – Continue reading
Maryland’s taxation policy violated the U.S. Constitution by taxing income that state residents earned in other states, the U.S. Supreme Court ruled on Monday. The nation’s apex said the state’s controversial policy imposed form of double taxation on residents. The court in its ruling said Maryland cannot impose form of… – Continue reading
Ruling opens door for HM Revenue & Customs (HMRC) to recoup losses from other firms which used rate-booster schemes High street retailer Next has been hit with a £22.4m tax bill after a court found that it diverted profits made in the UK to offshore havens to avoid paying tax…. – Continue reading
The Dubai Financial Services Authority (DFSA) and the Dubai International Financial Centre (DIFC), Registrar of Companies (RoC), jointly hosted an outreach workshop last week regarding the Foreign Account Tax Compliance Act (FATCA). FATCA is extra-territorial US legislation that affects Financial Institutions (FIs), particularly those which have accountholders who are US… – Continue reading
Authorities worldwide have increased scrutiny of tax-avoidance strategies in the past year, CFOs and finance directors of multinational clients told global tax consulting firm network Taxand. Sixty per cent of multinationals reported an increase in audits by tax authorities in the past year, and 70% said authorities had increased their… – Continue reading
OVER 50 judicial officers underwent a two-day training in emerging trends in tax law practice and administration organised by Uganda Revenue Authority (URA) to hone their skills in adjudication of revenue affairs. The training that closed last week was held at Lake Victoria Serena Resort, Kigo in Kampala. The training… – Continue reading
In 1934, a distinguished American jurist, Judge Learned Hand, famously opined that “one may so arrange his affairs so that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to… – Continue reading
Compliance costs for banks in the Middle East are soaring, as a global crackdown on money laundering and higher international capital requirements squeezes their resources, a new report from Thomson Reuters said, reports Gulf News. Four out of five financial services companies in the Middle East polled by Reuters said… – Continue reading
In July 1997, Tyco International (with then Wall St darling Dennis Kozlowski at the helm) was “acquired” by a relatively small provider of home security services, known as ADT Inc. The deal arguably exploited some strategic synergies between the two companies, but far and away the biggest benefit to Tyco… – Continue reading
The advantages of off-shore investments Two of the top reasons that South African investors are given to encourage offshore investments are that going offshore diversifies your portfolio and that it gives you access to sectors you could never find on the resource-heavy JSE. “While those are not reasons to be… – Continue reading
“Location, location, location” the well-known real estate mantra, is a notion that advisors of high- and ultrahigh-net-worth clients might also want take to heart. “Residency drives how much sophisticated wealth structuring and asset protection you can do,” says Merrill Lynch advisor Adam Katz. While the concept that it’s better to… – Continue reading
Georgia’s freshman Senator David Perdue is a big advocate of the Fair Tax – a proposal long linked to the Peach State that calls for replacing federal income taxes with a national sales tax on all goods and services. Perdue talked up the plan in the GOP primary and general… – Continue reading
Marcelo Vicentini of Standard Chartered in Brazil discusses the differences between OECD member countries and non-members when it comes to asset management transfer pricing. Brazil’s diversion from the OECD is well-documented and can make life difficult for transfer pricing managers when they are trying to apply a consistent policy across… – Continue reading
THE BJP-led National Democratic Alliance government, which had made a lot of noise about black money and the illegal stashing of funds abroad in the run-up to general elections last year, finally got down to some serious work to tax ill-gotten wealth and curb its growth. Last week, the government… – Continue reading
Short cuts, loopholes and other forms of skulduggery will not be tolerated when the automatic exchange of tax information comes into force, a top official from the Organisation for Economic Co-operation and Development (OECD) has promised Swiss bankers, reports FinFacts. Grace Perez-Navarro, second in command at the OECD’s tax policy… – Continue reading
This note is intended as an introduction to inheritance tax (IHT) issues that need to be covered where a “non-dom” (an individual domiciled outside the UK) is planning on becoming resident in, or is already resident in, the UK. It should be emphasised that this is a complex subject, and… – Continue reading
