On February 25, South Africa’s Minister of Finance, Nhlanhla Nene, presented a 2015 Budget that was said to be constrained by a slowing economy and lower-than-expected tax revenues. Nene indicated that the Government now has to rebalance its fiscal policy to reduce the “structural gap” that exists between spending on… – Continue reading
Despite hike, its personal income tax rates are still lowest in region Even with this week’s tax hike for top earners here, Singapore still has the region’s lowest personal income tax rates after arch-rival Hong Kong. Experts agree that even after this rise, the Republic will, for now, stay attractive… – Continue reading
Dmitry Rybolovlev reportedly lost tens of millions in an art scam allegedly carried out by a Swiss businessman The billionaire Russian owner of Monaco football club is believed to be one of several “high net-worth individuals” who are victims of alleged fraud by a Swiss businessman arrested in Monaco on… – Continue reading
MCC interviews three attorneys from Mourant Ozannes. Hayden Isbister is a partner and head of the Corporate practice in the Cayman firm. He specializes in investment funds, general corporate and commercial work. James Burch is a partner and leads the Structured Finance/Banks practice in the Cayman Islands, and Tim Dawson… – Continue reading
When combined with aggressive tax planning, Hong Kong’s onshore-offshore tax regime often results in a reduced tax burden for taxpayers that operate through Hong Kong companies by pricing intra-group transactions. This has led to heightened transfer pricing scrutiny from the Hong Kong Inland Revenue Department in recent years. In order… – Continue reading
The British Virgin Islands is the most popular offshore jurisdiction, with favourable business regulations, a prosperous economy and a stable political situation. British Virgin Islands IBC, is a limited liability company which conducts its trading and business outside the British Virgin Islands and is intended for offshore activities. It takes… – Continue reading
[NEW YORK] Citigroup Inc said additional government authorities have started probes of possible breaches of anti-money laundering laws at its Banamex USA unit. The Financial Crimes Enforcement Network, a unit of the US Treasury, and the California Department of Business Oversight have asked the company for information on its compliance… – Continue reading
Amid global efforts to combat profit shifting. PRETORIA – In line with international efforts to combat tax avoidance, National Treasury on Wednesday said it is taking further steps to curb financial leakage. With government under pressure to collect more revenue amidst dwindling economic growth, Finance Minister Nhlanhla Nene on Wednesday… – Continue reading
A country known for its clocks, chocolate and most importantly banks, the agreement by Switzerland’s government to share details of those super-secret bank accounts is one that will change the world at large. Gone are the days of the elusive Swiss bank account. The arrival of Common Reporting is upon… – Continue reading
INTRODUCTION 2015 is with us and looming is the 30 June 2015 deadline for the first reports of FATCA information under the reporting regimes that have been put in place in both Guernsey and Jersey to ensure compliance with the US/Guernsey and US/Jersey Intergovernmental Agreements regarding FATCA (“the US IGAs”)…. – Continue reading
CRA recently released a new Transfer Pricing Memorandum (TPM-15) giving detailed guidance on CRA’s audit approach to management fees and other charges for intra-group services, including on allocation keys for indirect chargebacks and markups on costs. The document expands considerably upon brief guidance on this topic in CRA’s main Information… – Continue reading
Mr. Akhilesh Ranjan, Joint Secretary Ministry of Finance, and also Competent Authority for the Government of India, spoke this past week at the Pacific Rim Tax Institute, February 19-20, reaffirming India’s commitment to a new non-adversarial tax regime to encourage foreign investment and fair treatment of taxpayers. Mr. Ranjan’s appointment,… – Continue reading
Pact on information exchange in tax treatment Paris, February 25 – An important tax treaty signed between Italy and Switzerland is evidence of the “change of a crucial paradigm,” in banking secrecy with global implications, Pascal Saint-Amans, director of the center for tax policy and administration at the OECD told… – Continue reading
The Bombay High Court, in its landmark judgments in the cases of Vodafone India and Shell India, held that issue of shares, being a capital transaction, does not attract transfer pricing (TP) provisions under the Indian income tax law. The court observed that investment in shares does not fall within… – Continue reading
Thanks in part to past concerns that globalization could lead to double taxation, corporations have numerous techniques at their disposal to reduce their tax bills, including the placement of subsidiaries and spinoff holding companies in low-tax jurisdictions. The Group of 20 wants to change that. The Organisation for Economic Cooperation… – Continue reading
It is estimated that there are at least 100,000 Greeks with American citizenship living in Greece. In addition, thousands of US citizens live and work in Greece, either on a short-term or permanent basis. According to US law, all of these citizens, with very few exceptions, are required to file… – Continue reading
As for the central message that an NRI/PIO want to hear from Modi’s most important budget of his term can be best summed by what he said during an event in central park New York “May the force be with you “Veni Vidi Vici!” he came, he saw and he… – Continue reading
Close to three dozen private equity firms which used investment entities based in Mauritius to route money into Indian portfolio companies have received income-tax notices for payment of Minimum Alternate Tax (MAT) on the capital gains accrued to them for sale of such shares, according to Business Standard. MAT is… – Continue reading
The government is set to make changes in the income tax rules to seek overseas operational details of multinational businesses that have a turnover of over R5,000 crore in India in order to decide which companies should be audited for income suppression, reports Gireesh Chandra Prasad in New Delhi. The… – Continue reading
Not long after the U.S. Department of Justice’s Tax Division (“DOJ”) made international headlines in 2009 for its bombshell announcement that it had entered into a deferred prosecution agreement with the United Bank of Switzerland (UBS), lawmakers in Washington, D.C. began reviewing the testimony of hundreds of UBS’s U.S. clients… – Continue reading
The major challenges facing the IRS today are its budget situation, which affects both service and enforcement, IRS commissioner John Koskinen told the Tax Section of the New York Bar Association. “No challenge is more critical than our budget situation,” he said. “Our funding has been reduced every year for… – Continue reading
The government has been able to instil a positive sentiment in the country. Various policy initiatives like Make-in-India, aimed to make India a manufacturing hub, and the Clean India campaign; updating age-old laws and tweaking the Goods and Services Tax to a more acceptable form, introducing greater clarity in the… – Continue reading
BRUSSELS, Feb. 23 (Xinhua) — Member states need to pay more heed to coordinating their efforts in corporate taxation to combat tax evasion, said economic and financial affairs commissioner Pierre Moscovici on Monday. Moscovici said the European Commission (EC) had actively supported European member states in their efforts to secure… – Continue reading
São Paulo, Brazil. International transfer pricing is able to take place in Brazil, outside of the OECD While Brazil is not a member of the OECD, many multinational groups there are able to successfully navigate international transfer pricing standards, yielding effective results The economic view of Brazil has always been… – Continue reading
JAKARTA, Feb 24 ― Indonesia will crack down on corporate tax avoidance via transfer pricing this year to try and recoup 200 trillion rupiah (RM56.6 billion) in lost state income mainly in the commodities sector, the new head of the tax office told Reuters. Under the transfer pricing method, an… – Continue reading
A repatriation holiday would have a minimal economic impact and would be the wrong way to pay for the Highway Trust Fund or any other project, according to a new report by the Heritage Foundation. There have been differing congressional proposals recently to change the tax treatment of the USD2… – Continue reading
An Alberta online bank is believed to be the first Canadian financial institution to deny service to Americans, citing the burden of complying with strict new U.S. tax rules. Canadian Direct Financial, a subsidiary of Edmonton-based Canadian Western Bank, is refusing to open new Internet accounts for U.S. citizens, even… – Continue reading
IRA plans can be excellent ways to save for retirement, but there are some investments to avoid if you want to take full advantage of IRA tax savings. Two that come immediately to mind are tax-exempt municipal bonds and high-yielding stocks from foreign countries with dividend withholding taxes. Tax-exempt municipal… – Continue reading
Transfer pricing policy in the United States is guided by Section 482 of the Internal Revenue Code (and by the Organization for Economic Cooperation and Development under its Base Erosion and Profit Shifting initiative), and its application is not limited to cross-border transactions. In fact, some states, such as New… – Continue reading
This is the time of the year for millions of Americans to begin the annual ritual of gathering information about income, taxes, charitable giving, health insurance, expenses and sundry other items, and prepare to send mountains of information to the IRS –and to those who prepare their tax returns. Overseas… – Continue reading
Attempt to plug every gap makes the system unworkable – Norton Rose Fulbright. JOHANNESBURG – A tax expert has warned against over-complicating tax legislation in an attempt to block every loophole or perceived underpayments of tax, as it makes the tax system “unworkable”. Andrew Wellsted, director at Norton Rose Fulbright,… – Continue reading
(Bloomberg) — Argentine tax authorities said Sunday they are seeking the arrest of money manager Miguel Abadi for alleged involvement in an offshore investment network designed to avoid paying taxes. The agency, in a statement, said it’s seeking information from tax agencies in the Virgin Islands, Uruguay and Bermuda about… – Continue reading
As disclosed recently in a bankruptcy court filing, on January 27, 2015, the Financial Crimes Enforcement Network (“FinCEN”) imposed a $10 million civil money penalty pursuant to the Bank Secrecy Act (the “BSA”) on Trump Taj Mahal Associates LLC. Trump Taj Mahal consented to the imposition of the penalty (subject… – Continue reading
The Economist reports that “”The number of Americans giving up their passports has shot up, from less than 1,000 a year in the late 2000s to a record 3,415 in 2014.” One of the main reasons has to do with aggressive efforts to collect taxes from Americans who earn money… – Continue reading
Not a single penny of what the treasury loses from tax avoidance is accidental Tax avoidance has rarely been the subject of as much attention as it is at present. That’s welcome. As a tax researcher and chartered accountant, I’ve estimated that it costs the UK at least £19bn a… – Continue reading
With so much attention on FATCA in recent times, the financial services industry could be forgiven for seeing it as the most obtrusive regulation ever to be imposed on them. This view will soon change. Once the Automatic Exchange of Information (AEOI) comes into force, financial institutions will have far… – Continue reading
When I consider what’s likely to have the most impact in tax this year, I keep coming back to the massive shift in attitude by tax authorities in the aftermath of the Global Financial Crisis (GFC). Usually changes in the tax world are incremental, but what is going on now… – Continue reading
Santo Domingo.- The US Internal Revenue Service (IRS) and Dominican Republic’s Internal Taxes Agency (DGII) have begun a process to exchange bilateral financial and tax information, as part of the on Foreign Accounts Tax Compliance Law (FATCA). A delegation of the IRS’ International Cooperation Program led by its senior manager… – Continue reading
American citizens residing in Malta as well as some Maltese migrants were urged to get their US tax affairs in order during an information session on the US FATCA legislation. Jonathan Phyall, Senior Legal & Compliance Officer at APS Bank explained that an agreement signed between the Malta and US… – Continue reading
Switzerland and neighbouring Italy have revised a double taxation agreement which includes provisions for the exchange of information in line with the standards of the Organisation for Economic Development and Co-operation (OECD). The accord and a roadmap for the amendment of tax rules on cross-border workers as well as improved… – Continue reading
Greece’s far-left government was last night thrashing out a new package of economic reforms that it claims will crack down on tax evasion and overhaul its bloated civil service. The stricken Mediterranean country has been given until today to unveil the measures after reaching an agreement with its creditors from… – Continue reading
According to Peter Willey, EY’s Channel Islands Head of Tax, the Channel Islands are likely to be impacted by decisions being made now in other jurisdictions. EY recently surveyed its tax policy leaders in 32 jurisdictions to ask them to forecast the tax policy outlook for 2015 in their jurisdiction…. – Continue reading
The Treasury Department’s crackdown on tax inversions last year has slowed but not stopped the movement of U.S. headquarters abroad as American businesses try to reduce tax bills and foreign firms seek to grow. Indeed, with U.S. companies now virtually barred from relocating overseas in order to trim taxes, the… – Continue reading
(Bloomberg) — Swiss prosecutors are scrambling to explain why they took seven years to probe suspicions of money laundering aroused by data stolen from HSBC Holdings Plc’s private bank in Geneva. Inspired by Feb. 8 disclosures by the Washington-based International Consortium of Investigative Journalists that HSBC did business with arms… – Continue reading
Following the financial crisis, dividend yields from American banks have remained below the level many income investors are looking for. While all four major American banks yield less than 3%, U.S. investors can still get fat bank dividends by looking abroad. The United Kingdom London has long been a financial… – Continue reading
UK, US, Australia, Brazil, India- governments of developed and developing countries are battling profit shifting by MNCs such as Amazon, Google, Apple and Starbucks. The allegation- MNCs are shifting profits to jurisdictions where there is little or no tax to be paid. The solution- OECD’s BEPS action plan which, among… – Continue reading
MUMBAI: The Securities and Exchange Board of India has banned 33 entities for allegedly misusing the stock exchange system to generate fictitious long-term capital gains of over Rs 1,800 crore and for converting their unaccounted income into legal money. Sebi said Kamalakshi Finance Corp (KFCL) made preferential shares to connected… – Continue reading
Investors seeking global diversification for their property portfolios are increasingly seeing New Zealand as an attractive investment option. Although our commercial and industrial property market is too small to attract the interest of giant global real estate investment trusts (REITs), our manageable size is regarded as an advantage by other… – Continue reading
Certainty and reduced litigation on transfer pricing (TP) issues will be the cornerstone of creating a non-adversarial tax regime in India. The authors believe that Budget 2015 ought to lay out a roadmap to achieve this goal for TP issues – Recent positive progress on the Advance Pricing Agreement (APA)… – Continue reading
Islamabad: Pakistan’s Finance Minister Ishaq Dar has rejected allegations by Pakistan Tehreek-e-Insaf (PTI) leader that he transferred $4 million to his son in Dubai to avoid taxes. In an open letter to the PTI chairman Imran Khan, the finance minister also refuted the claim that he has been dragging his… – Continue reading
