This is the time of year when financial advisers really earn their fees. In the run-up to the end of the tax year, advisers must work hard to make sure that their clients have made the best use of their allowances before they lose them as the new tax year… – Continue reading
The Government has introduced the Advance Pricing Agreement (APA) Scheme through Finance Act, 2012 and Income Tax (Tenth Amendment) Rules, 2012 notified vide S.O. 2005(E) with effect from 30th August, 2012. The APA Scheme endeavours to provide certainty to taxpayers in the field of transfer pricing through an agreement in… – Continue reading
On March 18, 2015, the European Commission presented a package of transparency measures aimed at tackling corporate tax avoidance and harmful tax competition within the European Union, reports Tax News. The transparency package is said to be “the first step in the Commission’s ambitious agenda for 2015 to fight tax… – Continue reading
The Federal Board of Revenue (FBR) has received a budget proposal of the Overseas Investors Chamber of Commerce & Industry (OICCI) regarding reduction in activation tax on mobile phones from Rs 250 to Rs 150 and withdraw sales tax on SIM card issuance and IMEI tax to avoid double taxation… – Continue reading
Where applicable, foreign landlords with property in Turkey are required to file tax returns to Turkish financial authorities by March 25 The tax treatment of income elements earned by foreigners from any source of income usually tops the international tax agenda and is extensively debated worldwide by experts, academics and… – Continue reading
Owning real property on both sides of the border can create a confusing tax situation. Consider this example. Stefan and Jane are married and live in Vancouver. Jane is a Canadian citizen while Stefan holds both U.S. and Canadian citizenship. In 1994, shortly after getting married, they bought a house… – Continue reading
Compliance departments are feeling increasingly challenged by higher regulatory expectations, coupled with staff shortages and technology concerns, according to a joint Dow Jones Risk & Compliance and Association of Certified Anti-Money Laundering Specialists (ACAMS) global survey. “This year’s survey once again highlights the issues and emerging trends that are shaping… – Continue reading
Rafal Mikulski of Dentons explains why Cayman Islands’ investment funds may be entitled to a tax exemption in Poland and to claim for overpaid tax from the Polish tax authorities The Agreement for the Exchange of Information Relating to Tax Matters signed on November 29, 2013, by and between the… – Continue reading
Tough tax disclosure laws introduced by the former Labor Government represent “an invasion of privacy and intrusion for Australian private companies,” Prime Minister Tony Abbott has said. Abbott made the comment during a joint press conference with the Assistant Treasurer Josh Frydenberg. The press conference followed a meeting of the… – Continue reading
In Ruling No. 27296, Italy’s Supreme Court rejected the tax authorities’ appeal against an Italian company’s transfer of goods and services to its German parent. The Supreme Court ruled that if there is no clear economic advantage for a company, simply proving a transaction is not at arm’s-length is insufficient… – Continue reading
U.S. Court of Appeals Rejects IRS Attempt to Apply Closing Agreement Retroactively to Support an Unrelated Proposed Adjustment to Tax SUMMARY From 2003 to 2006, U.S. corporations were entitled, in certain circumstances, to elect a one-time dividends-received deduction for dividends from controlled foreign corporations. BMC Software, Inc. made this election… – Continue reading
The government has moved to legislate in haste to close tax loopholes. But history suggests this is unwise. One legal figure to crop up in the chancellor’s budget statement published yesterday was the ubiquitous Sir Brian Leveson. The president of the Queen’s Bench Division receives a namecheck in the budget’s… – Continue reading
While the problems with our international tax system are complex, the solution is relatively simple: U.S. corporations should pay the same tax rate, at the same time, on their domestic and foreign profits. The ranking member of the Senate Finance Committee, Sen. Ron Wyden, made the case for this reform… – Continue reading
The Haryana Lokayukta, Justice Pritam Pal (retd), on Wednesday recommended, to the state government, that a criminal case should be lodged against the government officials, property developers, builders and others who are allegedly responsible for the Rs 10,000 crore tax evasion scam in the state. A Special Investigation Team (SIT),… – Continue reading
UK bank HSBC is the first non-Chinese bank to take advantage of new Shanghai Free Trade Zone (FTZ) rules designed to ease foreign currency borrowing and bring down funding costs. Shanghai FTZ allows corporates to use its free trade account to conduct foreign currency borrowing from offshore markets. People’s Bank… – Continue reading
The Organisation for Economic Cooperation and Development (OECD) has welcomed Switzerland’s recent moves towards greater tax transparency, admitting the country to phase 2 of the peer review process. Jacques de Watteville, head of Switzerland’s State Secretariat for International Financial Matters, said: “We are delighted about this decision. It is the… – Continue reading
GENEVA: Facing a global crackdown including from India on their ‘safe haven’ tag, Swiss banks today asserted that “bank-client confidentiality” will not disappear and ‘automatic information exchange’ is not the only solution to the black money menace. The assertion comes at a time when Switzerland is in the process of… – Continue reading
BENGALURU, MARCH 19: IT major Wipro has won a legal victory with the Karnataka High Court allowing it to save a significant amount in taxes from its overseas operations. The judgment is likely to have an impact on Indian companies that have overseas operations. US taxes In a ruling on… – Continue reading
Papua New Guinea’s central bank has moved to stop offshore foreign banks, which don’t operate in PNG, trading in the Kina.From this month, people and companies wanting to trade in Kina and foreign currencies will only be able to use one of six authorised dealers. Since July last year, after… – Continue reading
ACCA takes note of the publication of the first of two tax transparency packages promised by the EC and welcomes, in principle, the proposal to extend the automatic exchange of information on tax rulings with some reservations. As part of its announced agenda to tackle corporate tax fraud and harmful… – Continue reading
The Israel Tax Authority and Her Majesty’s Revenue and Customs are using powerful technologies to close in on tax dodgers. In Britain, the mix of politics, the upcoming elections, the budget deficit and public pressure has provoked a whirlwind of controversy around the issue of tax avoidance and tax… – Continue reading
(Bloomberg) — A steering committee representing Kaisa Group Holdings Ltd.’s offshore bondholders won’t agree to the company’s proposed debt restructuring by Friday’s early bird deadline. “We are working with the company to agree an acceptable and realistic timeline and process so that we can obtain for you a sensible revised… – Continue reading
Transfer pricing activities have faced increased scrutiny by tax authorities around the world and within the United States. As such, many companies are seeking more guidance on how to best manage their transfer pricing life cycle. The life cycle consists of four phases, which include planning, implementation, documentation and monitoring…. – Continue reading
The recent cases of FCT v Darling [2014] FAM CAFC 59 (Darling) and International Litigation Partners Pte Ltd v FCT [2014] FCA 671 (Litigation Partners) have cast the spotlight on the Commissioner of Taxation’s (Commissioner) ability to access information from the contents of Family Court files in order to assist… – Continue reading
Advisers could face criminal charges under new powers for HMRC following the Budget if they fail to prevent tax evasion by inherited clients, a lawyer has warned. HMRC is consulting on a new corporate criminal offence for firms failing to prevent tax evasion, which will implicate advisers who have clients… – Continue reading
MINSK, 18 March (BelTA) – Belarus and the United States of America signed an intergovernmental agreement to improve international tax compliance and to implement the U.S. Foreign Account Tax Compliance Act (FATCA), BelTA learned from the press service of the Belarusian Foreign Ministry. The signing ceremony took place at the… – Continue reading
The measure The Chancellor confirmed that the new diverted profits tax (DPT) will be introduced from 1 April 2015. DPT will apply in two distinct situations, being: Where a foreign company has artificially avoided having a taxable presence in the UK; and Where a UK company (or a UK permanent… – Continue reading
The OECD’s base erosion and profit-shifting project has dominated the international tax scene for over a year. Ever since the G-20 tasked the organization with finding solutions to the perceived problem of multinationals paying low effective tax rates, the international tax community has talked about little else. The OECD hoped… – Continue reading
New Delhi : The Delhi High Court has held that money spent by Indian subsidiaries of foreign companies on advertising, marketing and promotion (AMP) of their global brand here are international transactions and fall under the purview of transfer pricing rules, reports PTI. A bench of justices Sanjiv Khanna and… – Continue reading
(Bloomberg) — Luxembourg’s status as a fortress of wealth in the heart of Europe is in peril. The country transformed itself from a rural economy into the European Union’s richest in less than a century by swapping fields and steel mills for hedge funds and multinationals. That model may now… – Continue reading
Following a public consultation, the Inland Revenue Authority (IRAS) of Singapore has issued final regulations and an e-Tax Guide regarding the US Foreign Account Tax Compliance Act (FATCA) requirements for financial institutions (FIs) in Singapore. FATCA requires all FIs outside of the United States to submit regular information on financial… – Continue reading
European states including Ireland and Luxembourg will be compelled to share information on private tax deals they have granted to multinational businesses under proposals from Brussels to clamp down on corporate tax avoidance. The European Commission was due today to publish reforms aimed at bringing into line rogue member states… – Continue reading
The Abbott government is pushing ahead with a Labor budget measure to close a loophole that will stop giving offshore-based multinationals “systemic tax advantages” that are not available to Australian-owned companies. The loopholes in current law mean that multinationals can, with the use of subsidiaries, structure their affairs to avoid… – Continue reading
ISLAMABAD: The Natio¬nal Accountability Bureau (NAB) has forwarded several recommendations to the Federal Board of Revenue (FBR) to plug loopholes that are believed to be the cause of massive tax evasion and other irregularities. The recommendations were given on Tuesday by the NAB’s Prevention Committee on FBR in its first… – Continue reading
1.GENERAL QUESTIONS 1.1 Why is the Commission presenting a Tax Transparency Package? The Commission has made the fight against tax evasion and corporate tax avoidance a political priority, with a view to creating a socially and economically more efficient Single Market. While much has been done to advance this agenda… – Continue reading
(Bloomberg) — Switzerland has frozen $400 million of assets in more than 30 banks as the country’s attorney general probes money laundering related to Petroleo Brasileiro SA’s widening corruption scandal. Nine investigations have been opened since last April based on allegations of corruption involving eight Brazilian citizens, the Bern-based Federal… – Continue reading
The International Chamber of Commerce (ICC) has responded to announcements in the Budget speech by the UK Chancellor, George Osborne. On the new diverted profits tax, John Danilovich, ICC Secretary General, said: “We welcome the UK Government’s efforts to consult business on the introduction of a ‘diverted’ profits tax in… – Continue reading
Communist Party’s anti-graft agency reveals how hundreds of suspects and their offshore assets were brought back to the mainland A powerful mainland task force has revealed in detail for the first time how it tracked down allegedly corrupt fugitives abroad, bringing the suspects and their assets back to China even… – Continue reading
Russian Prime Minister Dmitry Medvedev has ordered the signing of a protocol to the Russian-Chinese agreement aimed to eliminate double taxation and prevent tax evasion, the government said on its website on Wednesday. “Under the sanctions imposed on Russia by the European Union, US and other countries, the signing of… – Continue reading
(Bloomberg) — The European Union launched a new salvo in its battle against tax evasion with a slate of proposals that would make it harder for companies to avoid taxes. Countries would need to share information on cross-border tax rulings every three months under one piece of the tax package,… – Continue reading
CIBC FirstCaribbean’s regional chief yesterday said commercial banks were “convenient targets” for increased taxes and scapegoating by politicians, warning that this slowed their bottom line recovery. Rik Parkhill, speaking ahead of its Bahamian subsidiary’s annual general meeting (AGM) last night, warned that the asset-based nature of the sector’s tax structure… – Continue reading
(Reuters) – European Union countries will have to share information on tax deals agreed with major corporations under European Commission plans to limit the ability of big business to avoid tax across the 28-nation bloc. EU members would from next year have three months to tell neighbors about new cross-border… – Continue reading
Azerbaijani and Sudanese officials have voiced readiness to further expand cooperation between the two countries. President Ilham Aliyev received a delegation led by Ali Ahmed Karti, Sudanese Foreign Minister on March 18. The head of the state expressed confidence that the visit of the Sudanese delegation will be fruitful and… – Continue reading
NEW YORK — Faced with the prospect of letting another deal slip through its fingers, Valeant Pharmaceuticals International substantially increased its bid for Salix Pharmaceuticals on Monday, putting a quick end to a bidding war with Endo International. Valeant said it would now pay about $11bn, or $173 a share,… – Continue reading
BELGRADE — Serbia and Portugal have “very good political and friendly relations” with Lisbon “strongly supporting” Serbia’s EU integration, it has been said in Belgrade. Portugal also supports Serbia’s bid to open accession negotiations chapters with the EU, the country’s Foreign Minister Rui Machete said during a joint news conference… – Continue reading
The agreement under the Foreign Account Tax Compliance Act will enable exchange of information on cases of tax avoidance through overseas entities The Cabinet on Tuesday approved the signing of an inter-governmental agreement between India and the US seeking to impose higher withholding tax on Indian companies on their US… – Continue reading
Two Calgary men have been convicted of defrauding the federal government of $14.1 million in taxes that should have been paid on registered retirement plans, in which the money was used for offshore investments. Steven Kendall and Christopher Houston were found guilty on Wednesday on one of four charges by… – Continue reading
UK financial institutions (FIs) that have no US-reportable accounts will not be required to submit annual ‘nil returns’ in order to ensure compliance with new rules designed to prevent tax evasion by US citizens, HM Revenue and Customs (HMRC) has confirmed. The change comes after the US Internal Revenue Service… – Continue reading
In the recent case of Herefordshire Property Company Ltd v HMRC1, the First-tier Tribunal (Tax Chamber) (“FTT”) allowed the taxpayer’s appeal against the imposition by HMRC of a penalty, which was based on an allegation of negligent implementation of a tax planning scheme by the taxpayer. Regular readers of our… – Continue reading
GRAND CAYMAN, Cayman Islands, March 18, 2015 /PRNewswire/ — DMS Offshore Investment Services Ltd., (DMS) the world’s largest fund governance firm, is expanding its International Tax Compliance Group to better serve private investment funds in meeting their compliance obligations under various international tax initiatives worldwide. DMS announces the recent addition… – Continue reading
