Category: Activity

Chevron parents leave ATO an orphan

Premier Colin Barnett (left) and Chevron manager Colin Beckett at its LNG project on Barrow Island. Secretive oil major Chevron Corp has taken the art of tax avoidance to its ultimate form thanks to a scheme so aggressive that it goes beyond merely reducing exposure to income tax, but rather,… – Continue reading

I-T targets 50 APAs with MNCs in FY16

The I-T dept has received over 500 applications from MNCs for signing APAs. Income-tax department has set a target of 50 advance pricing agreements (APAs) to be sealed with multinational companies in the current fiscal that will exempt cross-border transactions by these firms from rigorous auditing to check income suppression…. – Continue reading

Black money: Switzerland may change laws, start sharing banking information

“We will have a black money discussion (with finance minister Arun Jaitley) to solve and clarify (the issue),” said Swiss economic affairs minister. Amid India enacting a law to deal with the menace of black money stashed abroad, Switzerland on Friday said that it is considering amendments in its domestic… – Continue reading

The great distortion

Subsidies that make borrowing irresistible need to be phased out THE way that black holes bend light’s path through space cannot be smoothed out by human ingenuity. By contrast, a vast distortion in the world economy is wholly man-made. It is the subsidy that governments give to debt. Half the… – Continue reading

In major anti-graft raid on Sabah, MACC freezes RM560m in 1,623 accounts

KUALA LUMPUR, May 15 ― The Malaysian Anti-Corruption Commission (MACC) today froze 1,623 bank accounts of companies and individuals involving over RM560 million in the first day of its “Operasi Bersepadu” in Sabah. The commission’s investigation division chief Datuk Mohamad Jamidan Abdullah said the operations were launched to crack down… – Continue reading

Green light for Telkom-BCX merger

JOHANNESBURG – A R2.6bn merger deal between telecoms firm Telkom and IT services company Business Connexion Group (BCX) has been approved with conditions. The Competition Commission (CompCom) on Thursday announced that it recommended to the Competition Tribunal that the merger be approved with conditions. “These are technical conditions relating to… – Continue reading

FATCA – implications for financial institutions

Introduction to FATCA On December 16 2013 Malta and the United States entered into an intergovernmental agreement (IGA) to implement rules and regulations under the Foreign Account Tax Compliance Act (FATCA). FATCA, enacted in 2010 by the United States, requires US taxpayers and financial institutions to report financial information to… – Continue reading

New anti-avoidance rule targeting large foreign multinational businesses

Following on from a press release issued by the Treasurer on May 11th, the government has released a draft bill containing a new limb to the general anti-avoidance provision, which is directed at foreign multinational groups who have global revenue exceeding $1 billion. The law will apply where: • the… – Continue reading

Unnerved by tax demands on capital gains, foreign funds flee for safety

The minimum alternate tax row has damaged the credibility of government promises to enforce an investor-friendly tax regime and made the Indian stock market Asia’s worst performer this year New Delhi/Mumbai: Castleton Investment Ltd, a unit of GlaxoSmithKline Plc (GSK), in 2012 asked an arm of the Indian finance ministry… – Continue reading

BEPS Analyses Possible Without New Disclosures: Stakeholders

The Organisation for Economic Co-operation and Development (OECD) has published stakeholders’ comments on its discussion draft on base erosion and profit shifting (BEPS) Action 11, on improving analysis of BEPS. Through Action 11, the OECD hopes to develop recommendations to better chart the scale and economic impact of BEPS issues,… – Continue reading

Nigeria: Lawmakers to Suggest Special Courts On Tax, Corruption to Buhari

Senators and members of the House of Representatives under the Anti-Money Laundering and Cyber Security Coalition are expected to meet and suggest to President-elect retired General Muhammadu Buhari the establishment of special courts that will deal with cases of tax evasion and corruption offences. Chairman of the coalition, Senator Aloysius… – Continue reading

Australia: Federal budget 2015-16: Quick guide – the big business measures

Last night, the Federal Treasurer, Joe Hockey MP, released the 2015-16 Federal Budget. After public self-evaluation of its last budget as over-reaching, the Government has gone back to basics whilst still focussing on repairing the budget deficit in the medium to long term. The budget deficit is projected to be… – Continue reading

Italian tax reform: facilitating inbound foreign investments

I. Introduction Following the approval by Parliament of Law No.23 of 11 March 2014 (hereinafter “Delega Fiscale”[1]), the Italian Government is now taking action and adopting the Legislative Decrees necessary to enforce this innovative tax reform. In fact, on 21 April 2015 the Council of Ministers has approved the drafts… – Continue reading

Italian tax reform: facilitating inbound foreign investments

I. Introduction Following the approval by Parliament of Law No.23 of 11 March 2014 (hereinafter “Delega Fiscale”[1]), the Italian Government is now taking action and adopting the Legislative Decrees necessary to enforce this innovative tax reform. In fact, on 21 April 2015 the Council of Ministers has approved the drafts… – Continue reading

Tax evasion fight ‘risks making life hard for all taxpayers’

The latest changes to VAT and profit tax legislation, implications of recent measures taken to fight fiscal evasion, changes to international tax reporting rules and the need to improve holding legislation were some of the topics discussed by participants in BR’s 14th Tax & Law conference which took place in… – Continue reading

Joe Hockey’s tax reform ‘too little, too early’, says Sam Dastyari

Treasurer Joe Hockey is facing criticism for both acting too quickly and not doing enough on tax avoidance by multinational ¬companies after tabling legislation on Tuesday night to stop companies shifting taxable profits out of Australia. An unnamed 30 multinational companies with more than $1 billion in revenue from Australia… – Continue reading

Commonwealth Bank faces ATO probe over R&D millions

The Australian Taxation Office is probing Commonwealth Bank over a nine-figure sum arising from tax breaks claimed by the nation’s largest company for research and development. In a hostile environment for tax minimisation by large corporates, CBA and the ATO are wrangling over an amount ¬believed to be in excess… – Continue reading

OECD BEPS rules to curb multinational profit shifting ready in November

The OECD plans to have international agreement on new tax rules developed as part of its project to tackle aggressive tax avoidance by multinationals through the Base Erosion and Profiting Shifting (BEPS) project by the next G20 summit in November, with implementation completed before 2020 ‘at the latest’ Pascal Saint-Amans,… – Continue reading

Russia’s Offshore Money Looks Set to Stay There

Russia is set to enact an amnesty on offshore assets next month, but disagreement and lack of clarity over the terms of the pardon threaten not only to render the measure impotent, but undermine the government’s very drive to lure overseas money back home. The capital amnesty, part of a… – Continue reading

Sean Foley,Global Leader, KPMG, says ‘India’s Transfer Pricing Rules Aggressive’

Even as the action plan to address Base Erosion and Profit Sharing (BEPS) is being worked out, multinationals are bracing for some turbulent times in India. For some time now, transfer pricing – the price of goods and services determined by a company when two of its subsidiaries transact –… – Continue reading

OECD attacks ‘aggressive tax plans’

Technology companies need to stop “extremely aggressive” tax planning, the man charged with reforming global tax rules has told the BBC. He says these “push the boundaries of what is legal”. Pascal Saint-Amans, who runs the OECD’s Centre for Tax Policy, said that new standards would require companies to pay… – Continue reading

Bahamas Releases Proposed FATCA Legislation & Guidance Notes For Industry Consultation

The Bahamas Ministry of Financial Services released draft copies of the FATCA Legislation and the FATCA Guidance Notes to meet the International Tax Compliance Requirements of the Model 1 FATCA Intergovernmental Agreement (IGA) between the Bahamas and the United States of America (US). The new FATCA Bill was drafted in… – Continue reading

Why dispute resolution between Germany and India is a lost cause

The worldwide transfer pricing landscape is in a state of flux and the need for sound and reliable dispute resolution mechanisms has never been more important for multinational enterprises. In particular, where aggressive tax administrations such as India are concerned, double taxation is a key concern for businesses. Mutual agreement… – Continue reading

FATCA, Tax Havens, American Competitiveness And Hypocritical Politicians

While the Bureaucrat Hall of Fame and Moocher Hall of Fame already exist, the Hypocrite Hall of Fame is just a concept. But once it gets set up, Congressman Alan Grayson of Florida will definitely be a charter member. Here are some passages from a column in the Tampa Bay… – Continue reading

Cyprus: A Protocol On The Double Tax Treaty Was Signed Between Cyprus And South Africa

A Protocol amending the Agreement for the Avoidance of Double Taxation and Prevention of Fiscal Evasion with respect to Taxes on Income and on Capital between South Africa and Cyprus was signed on the 1st of April 2015. According to the Protocol, Article 10 (“Dividends”) of the Double Tax Treaty… – Continue reading

OECD condemns Silicon Valley for “extremely aggressive” tax planning

Head of forum’s tax policy will push for reform to cut down on avoidance. The OECD has attacked the “extremely aggressive” tax planning of companies such as Google, Amazon and Apple as it pushes for reform of global tax rules to cut down on avoidance. Pascal Saint-Amans, who heads up… – Continue reading

OECD insists tax playing field will be level

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 Swiss Info. Grace Perez-Navarro, second in command at the OECD’s tax… – Continue reading

Cayman Islands: Cayman Islands Quarterly Update – May 2015

FATCA reporting commences In our March client briefing we noted that the Tax Information Authority in the Cayman Islands (“TIA”) had launched its online portal for the automatic exchange of tax information (the “AEOI Portal”), which can be accessed from its website (www.tia.gov.ky). The deadline for reporting Cayman Islands financial… – Continue reading

Uruguay – South America’s Best Kept Secret

“Uruguay has now definitely earned its long-time nickname — the Switzerland of Latin America.” That’s what I wrote several months ago during my first visit to this small, south Atlantic costal country wedged between Brazil and Argentina. For the last week, I have been enjoying my second visit to Uruguay,… – Continue reading