In a recent decision, the U.S. Court of Appeals for the D.C. Circuit unanimously affirmed a district court order compelling three Chinese banks (not currently identified) to produce financial records in response to subpoenas issued by U.S. federal prosecutors, including records that were unrelated to the banks' U.S. operations or U.S. correspondent accounts. ... - Continue reading
NRI taxpayer may choose to invest long-term capital gains in another house property or purchase capital gains bonds to prevent taxation of capital gains ... - Continue reading
French President Emmanuel Macron today confirmed that the US and France have reached a compromise agreement which requires France to refund all digital services tax (DST) paid by multinationals once a new international system for taxing multinationals in the digital sector is in place. ... - Continue reading
The Directorate General of International Taxes of the Federal Board of Revenue (FBR) has started analysing a few potential multinational companies’ cases of transfer pricing where companies are directly involved in shifting their profits outside the country without payment of any taxes. In this regard, Directorate General of International Taxes… – Continue reading
ISLAMABAD: The government has kicked off a far-reaching crackdown against benami assets directing the departments concerned at the federal level and the provincial governments to track benami properties, harvesting the Benami Act, 2019 in the national and global contexts. Prime Minister Imran Khan chaired a meeting on August 20 on… – Continue reading
A new law introducing mandatory transfer pricing documentation in Bulgaria was officially published in the State Gazette in early August. ... - Continue reading
When it comes to risk management, the adage "Failing to plan is planning to fail", rings truer than most. Risk management is vital in any business, and when a more cost-efficient and customisable alternative to outright insurance purchase is sought, captive insurance ticks all the right boxes. ... - Continue reading
Federal tax law has permitted U.S. businesses to form so-called "captive" insurance companies for many years, and numerous large companies have done so. ... - Continue reading
The Cayman Islands has published a set of frequently asked questions detailing a law requiring that companies with geographically mobile activities have economic substance for tax purposes. ... - Continue reading
ZAGREB, August 21, 2019 – Computer gaming is the most propulsive segment of the IT industry worldwide, and this trend is present in Croatia, too, where local gaming companies export all their products, however the biggest challenge in doing business is the absence of a Croatia-USA double taxation avoidance agreement,… – Continue reading
German Minister for Economic Affairs and Energy Peter Altmaier had developed a strategy for the “Mittelstand” or small and medium-sized enterprises (SMEs), the newspaper Handelsblatt reported on Wednesday. “In the eyes of foreigners, SMEs are Germany’s secret weapon and, unlike the Dax 30 companies, SMEs are proving to be extremely… – Continue reading
HMRC has yielded more than £13bn worth of tax collections from tax investigations in 2018/19, a 27% increase on the previous period, official figures reveal. The figures were partly driven by payments HMRC has received ahead of the loan charge being introduced in April 2019, and the results of HMRC’s… – Continue reading
On 19 July 2019, the Organisation for Economic Cooperation and Development (OECD) released its report on harmful tax practices across various jurisdictions. ... - Continue reading
In recent years there has been a major public outcry for governments to take action to force multinational groups to pay a fair share of tax in the jurisdictions where their economic activities take place and to stop shifting profits to offshore tax havens. ... - Continue reading
On August 13, Financial Crimes Enforcement Network ("FinCEN") Director Kenneth Blanco addressed the 12thAnnual Las Vegas Anti-Money Laundering Conference and provided insights on his agency's expectations for the ever-evolving gaming industry. ... - Continue reading
On 8 August, the draft law (the "draft law") implementing the EU Directive 2017/952 of 29 May 2017 ("ATAD 2") amending Directive (EU) 2016/1164 laying down rules against tax avoidance practices that directly affect the functioning of the internal market (the so-called Anti-Tax-Avoidance-Directive, "ATAD") was presented to Parliament. ... - Continue reading
SEN. Sherwin Gatchalian has called on the Senate to hold an inquiry on the uncollected taxes from registered and unregistered foreign workers, especially those in the Philippine Offshore Gaming Operators (POGOs) industry. n calling for an investigation, Gatchalian stressed that taxes properly collected are essential since revenues enable the government… – Continue reading
A US federal appeals court on Friday affirmed the Tax Court’s decision in Amazon, ruling that cost sharing buy-in payments made by Amazon’s Luxembourg subsidiary in exchange for Amazon’s transfer of intangible property should not include compensation for transferred residual business assets such as workforce in place, goodwill, and going concern value. ... - Continue reading
Luxembourg corporate income taxpayers, including Luxembourg permanent establishments of foreign entities, will be subject to the Draft Law as from 1 January 2020. In addition, provisions targeting reverse hybrid mismatches will be applicable to Luxembourg transparent partnerships that would be treated as opaque by their nonresident owners as from 1 January 2022. ... - Continue reading
The news is replete with discussions on the refiling of the proposed bills for the other TRAIN Packages with the 18th Congress. However, there seems to be no discussion yet on any proposed amendment to the Bank Secrecy Act, Republic Act (RA) 1405, as amended, particularly the proposed amendments to… – Continue reading
Banks in France have warned that they could be forced to close up to 40,000 accounts belonging to US citizens because of ongoing difficulties with the Foreign Account Tax Compliance Act (FATCA). ... - Continue reading
In February and March of 2019, the OECD organized a public consultation process, releasing a consultation document on February 13, 2019, inviting public comments up until March 6, 2019, and holding a conference where industry experts presented key issues on March 13 and 14, 2019. ... - Continue reading
There are provisions under different sections of the Income-tax Act that can help you save on LTCG tax ... - Continue reading
This was revealed by the Organisation for Economic Cooperation and Development (OECD) last Friday in an announcement made on its website. ... - Continue reading
THE director of the Financial Intelligence Centre, Leonie Dunn, says the centre did not turn a blind eye to the disappearance of around N$350 million from the now-defunct SME Bank. ... - Continue reading
In 2016, Costa Rica’s economy grew at a good 4.2% of GDP, but this year this figure is comparable to Ukrainian tortoise runs (we have 2.7% they have 2.9%). The success recipes of highly developed countries are in many cases not applicable to low-income countries such as Ukraine. Therefore, it… – Continue reading
Uber is moving its intellectual property arm from Bermuda to the Netherlands to save $6.1bn from its tax bid, Bloomberg reported on Friday. ... - Continue reading
CIAT’s BEPS Monitoring Database has been updated to reflect advancements made by Angola, Argentina, Bermuda, Brazil, Chile, Colombia, Costa Rica, Honduras, India, Jamaica, Mexico, Panama, Paraguay, Spain, and Uruguay. ... - Continue reading
The Australian government on August 9 published the synthesized texts of Australia’s bilateral tax treaties with France, Finland, and Malta as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). ... - Continue reading
The European Union has added further impetus to its objective of enhancing transparency against harmful tax practices with the amendment to Directive 2011/16/EU, commonly referred to as DAC6. ... - Continue reading
The OECD today announced that Albania has become the 133rd nation to join the “Inclusive Framework on BEPS.” ... - Continue reading
In early July, the Israeli Tax Authority (ITA) issued an update to Form 1385 - "Declaration of International Transaction.” ... - Continue reading
WELLINGTON, Aug. 8 (Xinhua) — Opportunities to dodge tax are shrinking with the completion of a new tax agreement between New Zealand and Switzerland, New Zealand’s Revenue Minister Stuart Nash said on Thursday. Nash and Swiss Ambassador to New Zealand David Vogelsanger signed documents to update the Double Tax Agreement… – Continue reading
Ukraine today deposited with the OECD legal documents ratifying a multilateral tax treaty called the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). ... - Continue reading
BEIJING, Aug. 6 (Xinhua) — China’s State Council, or the cabinet, has issued an overall plan for the new Lingang area of the China (Shanghai) Pilot Free Trade Zone. The new area will be set up to the south of Dazhi River, east of Jinhui Port, and south of Xiaoyangshan… – Continue reading
Mauritius leaks latest reminder of how much we lose to tax havensA report by Canadians for Tax Fairness Bay Street and Tax Havens revealed how over 90% of Canada’s largest corporations have subsidiaries in tax havens. Ottawa (06 Aug. 2019) — Last month Canadians for Tax Fairness reported that, while… – Continue reading
The US IRS will once again examine allocations between group members of employee stock-based compensation in cost-sharing arrangements for transfer pricing purposes. ... - Continue reading
For over 20 years the Argentine Republic has adhered to the "OECD Guidelines for Multinational Companies" ("Guidelines"), through the "Declaration on International Investments and Multinational Companies" of the Organization for Economic Cooperation and Development ("OECD"). ... - Continue reading
On the sidelines of the Bureau of Internal Revenue’s anniversary celebration, Finance Secretary Carlos G. Dominguez III emphasized that the first 18 months of the current Congress is crucial for the Duterte administration’s comprehensive tax reform program (CTRP). According to Dominguez, lawmakers traditionally have the tendency to focus “on something… – Continue reading
The government of Singapore has announced that amendments made to the Singapore-Luxembourg tax treaty as a result of the two countries’ ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into effect on August 1. ... - Continue reading
Statistics published earlier this week by the European Commission on member state advance pricing agreement (APA) and mutual agreement procedure (MAP) programs suggest that the OECD/G20 base erosion profit shifting (BEPS) project has increased the scope for differences of opinion between tax authorities of different countries. ... - Continue reading
While considering moving a business into a new market, one of the key consideration is that country's tax regime. What are the incentives that would attract foreign investment? Are there any double tax treaties in place? What is the rate for corporate tax? ... - Continue reading
The latest proposed amendments will see, inter alia, some relief for taxpayers in relation to the Controlled Foreign Company ("CFC") rules and the scope of an "Affected Transaction" as defined in section 31 of the Income Tax Act 58 of 1962 ("the Act") to be extended. ... - Continue reading
The proposal intends to tax gift of money exceeding ₹50,000 made by residents to non-residents that were earlier claimed to be outside the ambit of India taxation ... - Continue reading
The UAE Ministry of Finance on 30 April issued new tax rules setting out country-by-country reporting compliance obligations for multinational corporation groups effective for financial years beginning on or after 1 January 2019. ... - Continue reading
Proposals made by Nirmala Sitharaman at G20 Summit could alter the stasis between large corporations and tax havens. ... - Continue reading
The OECD today announced that Norway has deposited its instrument ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). ... - Continue reading
The OECD on July 26 announced the that southern Africa nation of Eswatini has joined the inclusive framework on BEPS. ... - Continue reading
