NEW DELHI: Ahead of Prime Minister Narendra Modi’s visit to South Korea this month, the Cabinet today approved revising the double tax avoidance pact with Seoul to provide tax stability and facilitate flow of investment and technology between the countries. The Cabinet headed by the Prime Minister gave its approval… – Continue reading
The Financial Supervisory Commission (FSC, 金管會) said it is updating regulations on bank mergers for an announcement by the end of May. FSC Chairman William Tseng (曾銘宗) said the commission is studying bank merger regulations that could facilitate the formation of large-scale institutions that compete better in the Asia-Pacific region…. – Continue reading
Now that Costa Rica has been formally invited to go through the process of becoming a candidate nation worthy of joining the Organization for Economic Cooperation and Development (OECD), financial advisors and legal professionals are starting to ponder how their clients will be impacted by this new chapter in our… – Continue reading
Know-your-customer (KYC) obligations are placing increasing demands on banks as regulators continue the fight to stop money laundering, terrorist funding, and halt tax evasion. FX-MM’s Peter Garnham looks at how institutions are looking to utilities to make their systems more efficient without surrendering the control that would leave them facing… – Continue reading
“We will raise at least £5 billion from continuing to tackle tax evasion, and aggressive tax avoidance and tax planning, building on the £7 billion of annual savings we have delivered in this Parliament.” Conservative Manifesto “[We would raise] a further £6bn from tax dodgers.” Lib Dem press release, 19… – Continue reading
UK funds invested in India could face demands for tax from which they thought they were exempt. Minimum alternate tax (MAT), a tax on the book profit of a company, has been in existence in India in its current form since 2001 and is levied at 18.5 per cent. Because… – Continue reading
The Central Board of Direct Taxes [CBDT] on 26th March 2015 issued a Circular no. 4/2015 wherein they have clarified that while interpreting the provisions of Section 9(1)(i) of the Income Tax Act, 1961 [herein after referred to as ‘Act’] read with Explanation 5 inserted to the said section by… – Continue reading
Back when the Affordable Care Act was still a new concept—that is, before we found out that it has exceeded even our most optimistic expectations—more than a few prominent Americans were threatening to expatriate from the US if Obamacare was successfully signed into law. Well, disappointing though it may be,… – Continue reading
In retrospect, HSBC’s decision in 1993 to abandon Hong Kong for London’s Canary Wharf was one of modern history’s worst business moves. It seemed perfectly wise at the time, just four years ahead of Hong Kong’s return to China and amid the early stages of Europe’s common currency boom. When… – Continue reading
The Foreign Account Tax Compliance Act is meeting with some success in prompting foreign banks to disclose the holdings of U.S. taxpayers to the Internal Revenue Service, according to a former IRS official. FATCA was included as part of the HIRE Act of 2010 and requires foreign financial institutions to… – Continue reading
Dropbox has become the latest technology firm to skirt local tax rates after confirming it will bill its customers from a company set up in Ireland. In an email sent to users on the weekend, Dropbox confirmed it would bill its international users using the entity Dropbox Ireland from June…. – Continue reading
GENEVA, May 4 (Xinhua) — Thousands of accounts which have remained untouched for 50 years and which were opened before 1955 are being checked by Swiss banking establishments, according to an article published by German newspaper Welt am Sonntag on Monday. A Swiss Banking Association spokesperson confirmed the report, stressing… – Continue reading
The American Chamber of Commerce has warned that new Irish tax incentives may fail because they do not match the needs of multinationals, reports the Irish News. The chamber, which represents 700 US companies, has said the forthcoming Knowledge Development Box – which will replace the discredited Double Irish structure… – Continue reading
Saudi Arabia’s capital markets regulator said on Monday it has finalised rules ahead of the opening up of its $550 billion (Dh2 trillion) equity markets — equal to the size of Russia — for foreigners, reports Gulf News. Institutional investors with US$5 billion of assets under management will be allowed… – Continue reading
By Saeed Azhar SINGAPORE, May 5 (Reuters) – Singapore banks, which have enlarged their China credit exposure in recent years, were hit by a drop in billions of dollars of China trade financing deals as mainland borrowing conditions became easier while offshore interest rates grew more expensive. The premium of… – Continue reading
The deductibility of interest has for years been a contentious issue and this has been reaffirmed with the introduction of section 23M into the Income Tax Act No 58 of 1962 (the “Act”) with effect from 1 January 2015. A further addition to the interest sphere of income tax is… – Continue reading
In what may come as a relief to foreign portfolio investors (FPIs), the Bombay High Court has issued a stay on the tax department’s order seeking minimum alternate tax (MAT) from Aberdeen Global Emerging Markets. In what may come as a relief to foreign portfolio investors (FPIs), the Bombay High… – Continue reading
“Book Loss” and not “operating loss” a relevant indicator for determining persistent loss – Mumbai Tribunal Ruling in the case of Sumitomo Chemical India Private Limited Transfer pricing aims at establishing the arm’s length price of the controlled transactions using the most appropriate method. The success of transfer pricing lies… – Continue reading
Bipartisan legislation has been introduced into the House of Representatives to amend the Foreign Investment in Real Property Tax Act (FIRPTA) of 1980 that requires foreign investors to pay taxes on capital gains when selling commercial properties or real estate securities in the United States. To encourage foreign investment in… – Continue reading
The Romanian Government has approved a new law to introduce tax relief for foreign venture capitalists. The law aims to encourage start-up businesses and was passed by the Chamber of Deputies on April 29, 2015. It applies where a foreign individual, who was previously unconnected with the company in question,… – Continue reading
As discussed in our previous legal update The Tax Man Cometh: Not Only Long Awaited “Safe Harbor”, Notice No.7 is set to present a different income tax regime for non-tax resident enterprises (“Non-TRE”). In addition to the long awaited “Safe Harbor”, it is worth-noting that Notice No.7 has introduced new… – Continue reading
Cracking down on sweetheart tax deals with multinational corporations is proving more difficult than the European Commission had anticipated. Delays, uncooperative member states, and missed deadlines are among the frustrations highlighted Tuesday (5 May) by the EU’s competition chief, Margrethe Vestager. Speaking at a special committee on tax rulings at… – Continue reading
It’s a race against time for governments of the worlds’ largest economies seeking a coordinated plan to make it more difficult for multinational corporations to shield profits overseas. Some countries are preparing to act on their own. International finance leaders from advanced- and developing- economies are set to gather Wednesday… – Continue reading
VietNamNet Bridge – Metro Cash & Carry Vietnam, the German invested retailer, which repeatedly reported losses over the last 12 years in Vietnam, has engaged in transfer pricing to evade tax, according to the General Department of Taxation (GDT). It has asked the big retailer to reduce the reported loss… – Continue reading
Choosing the right location for the centralization and management of your IP is a very important strategic business decision. The ideal location to establish an IP structure is one that can serve the organization’s business strategies/model, safeguard and protect its IP and more important to contribute to its tax optimization…. – Continue reading
Jason Porter explores the tax regimes in Portugal, France, Malta and Cyprus – four of the most advantageous territories for UK ex-pat retirees People aged 55 and over are now entitled to their pension in the form of a lump sum, to be taxed at marginal rates applying in the… – Continue reading
Part Seven in our series comparing ASEAN business costs with China Singapore is the de facto financial and services hub for ASEAN, and as a city state with such a remit it is more pertinent to compare the dynamics of Singapore with Hong Kong rather than China as a whole…. – Continue reading
U.S. Ambassador to Armenia Richard Mills on Tuesday confirmed reports that a U.S.-Armenia Trade and Investment Treaty will be signed during President Sargsyan’s working visit this week to Washington, DC, the final step in the negotiation of a bilateral economic accord long sought by the Armenian National Committee of America… – Continue reading
In the 2015 Budget Speech presented to the National Assembly on 25 February 2015 the Minister of Finance announced that amendments will be proposed to change the rules for the digital economy in line with the latest guidance issued by the Organisation for Economic Co-operation and Development (“OECD”) in its… – Continue reading
BRUSSELS–The European Union won’t meet a self-imposed June deadline for deciding whether four multinational companies including Apple Inc. and Amazon.com Inc. benefited from illegal tax sweeteners, the bloc’s antitrust chief Margrethe Vestager said Tuesday. “We won’t meet the deadline we set ourselves [of] the end of the second quarter,” Ms…. – Continue reading
Canberra is planning a major assault on high-end financial crime through the establishment of a new Serious Financial Crime Taskforce drawing on the nation’s major law enforcement, business, and taxation regulators, and provided with $127.6 million over four years to secure criminal convictions. The move, which will be outlined in… – Continue reading
The Davis Tax Committee (“DTC”) recently addressed the issue of base erosion and profit shifting (“BEPS”) in South Africa. The international importance of transfer pricing was once again emphasized when 4 out of the 15 actions identified in the OECD Action Plan on BEPS related to transfer pricing. The 15… – Continue reading
Passing between tax administrations Polish and US information on accounts and income tax residents predicts signed by the president Bronislaw Komorowski law on ratification of the agreement with the USA on the use of so-called FATCA Act. As reported by the presidential office, in terms of the Act of 20… – Continue reading
A guide to Spanish taxation in 2015 for expats, with up-to-date information on income tax, VAT, property tax and other taxes for residents and non-residents in Spain. If you are living and working in Spain, you will be liable to pay Spanish taxes on your income and assets and will… – Continue reading
Thailand is expected to introduce new transfer pricing (TP) laws in the near future, which will apply to all companies in the Kingdom with related-party transactions. At a recent Deloitte seminar on “Thailand TP Developments”, with participation from senior officials from the Revenue Department, we shared some valuable insights on… – Continue reading
The CBDT has constituted a high- level committee to secure confidential tax data, obtained under mutual exchange with US authorities, as part of India’s compliance measures for signing the much awaited Foreign Account Tax Compliance Act (FATCA). The seven-member panel will be headed by the Member (Income Tax) of the… – Continue reading
The IRS, the most powerful and least accountable agency of the federal government, is an admitted criminal enterprise. To deal with this, Republican candidates for president are placing tax reform at the top of their agendas. You will have to guess why the Democrats seem not to care. Sen. Ted… – Continue reading
Mauritius and Singapore are both examples of countries with Double Taxation Avoidance Agreements (DTAAs) with India, meaning dividends from corporations that are paid out to shareholders are not taxed further, having already been taxed at the corporate level. This legislation has meant that such countries have been used to “round-trip”… – Continue reading
The parties to licenses of technology should consider tax issues with such licenses. The following is a summary of some of the tax implications that may arise with regard to technology licenses. Withholding Taxes. Where a license crosses an international border, withholding taxes may apply to any royalties payable. Under… – Continue reading
The patent box regime, adopted at the end of 2014 with Italy’s Stability Law, was recently modified by the Investment Compact Decree and implemented into law at the end of March 2015. A distinctive feature of the Italian regime is that the measure now also covers trademarks and designs. A… – Continue reading
The Tax Foundation released its inaugural “International Tax Competitiveness Index” (ITCI) on September 15th, 2014. The United States was ranked an abysmal 32nd out of the 34 OECD member countries for the year 2014. (See accompanying Table 1.) The European welfare states such as Norway, Sweden and Denmark, with their… – Continue reading
Bermuda is listed as 14th in a survey of the world’s biggest tax havens, by a US activist non-profit organisation. The Global Citizen organisation placed the Island just ahead of Guernsey in the Channel Islands to round its 15-strong list — well behind the US, UK and number one spot… – Continue reading
With a new candidate seemingly entering the race for president each week, national attention is understandably focused on American politics. But while Americans spare little mind for the goings-on of international organizations, their activities not only have significant impact around the world, but could also play a role in the… – Continue reading
NEW DELHI:Money makes the mare go, and it seems to have gone. From 2012 through 2014, overseas investment by Indians grew by an astonishing 700 per cent in the British Virgin Islands, a favourite tax haven for biz pashas with big bucks. After Narendra Modi — whose war was to… – Continue reading
Morgan Stanley veteran and former managing director Sridhar Sivaram told NDTV that the government’s decision to levy the contentious minimum alternative tax (MAT) retrospectively on foreign institutional investors (FII) for capital gains made during previous years, poses a hindrance to foreign fund flow into the country. “It’s very tough to… – Continue reading
The nation needs to talk about tax. That’s not a new proposition. Every incoming government seems to think it’s a good idea to conduct endless reviews, and the tax system is often at the top of the list. John Howard did it and actually came up with worthwhile reform with… – Continue reading
Monsanto announced that it has resumed possible merger talks with Syngenta, a Swiss-based agricultural chemical giant. The pair explored a merger in early 2014 before deciding against it. When the 2014 talks were going on, one of the principle attractions for the deal was the possibility of Monsanto buying Syngenta… – Continue reading
On April 21, 2015, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a Geographic Targeting Order (“GTO”) lowering reporting thresholds and triggering additional recordkeeping requirements for certain financial transactions in a move that is likely to have effects far beyond the 700 Miami-based electronics exporters that are specifically… – Continue reading
On 21 April 2015, the Danish Parliament adopted a bill, which sets out to deal with certain potential abuses recently encountered by the tax authorities as well as the Danish enactment of the general international anti-abuse initiatives currently considered at EU and OECD level. The new Danish GAAR will take… – Continue reading
Chapter 3 of the Internal Revenue Code requires payors (and recipients) of certain types of U.S. source income to withhold tax if the beneficial owner or recipient is a non-U.S. person for income tax purposes. Chapter 4 also imposes similar withholding under FATCA for payments to foreign financial institutions and… – Continue reading
