Category: Activity

Budget 2015: With BEPS on the anvil, GAAR may be an overlap

The economic downturn across the world and rising public debt seems to have led various governments, globally, to focus on curbing erosion of the tax base by shifting profits to overseas jurisdictions. Several revenue authorities, globally, were of the view that companies have structured their intra-group contractual arrangements in a… – Continue reading

What Indo-U.S. Bilateral APAs Entail For U.S. Investors

India’s decision to negotiate bilateral advance pricing agreements (APAs) with the U.S. is a welcome move. Prospectively, negotiations will increase certainty and uniformity in the application of India’s transfer pricing laws to related-party transactions carried out by U.S. multinational corporations (MNCs). In this article, we discuss some of the important… – Continue reading

Dubai tax haven: Dar transferred $4m to his son to avoid taxes, says PTI

ISLAMABAD: The Pakistan Tehreek-e-Insaf (PTI) on Thursday reiterated its allegations of money laundering against Finance Minister Ishaq Dar, saying he has transferred $4 million to his son in Dubai to avoid taxes. “The biggest investor in this case is our very own Finance Minister Ishaq Dar. He has on record… – Continue reading

Company bosses are held to account on their tax affairs BCA tells inquiry

The Business Council of Australia says that the Tax Office is holding company directors and management to account about their tax affairs, despite there only being one company in the nation with a top risk rating. “There is ongoing [Australian Taxation Office] scrutiny of corporate boards,” the BCA said in… – Continue reading

Revealed: Top firm funding Labour is the one savage for promoting tax avoidance!

Labour took £386,000 from PricewaterhouseCoopers in last quarter of 2014 Accountancy company accused of helping clients slash tax bills Former Labour minister says it was ‘inappropriate’ to accept donation Ed had said donors accused of tax avoidance not allowed on his watch Labour was accused of hypocrisy last night as… – Continue reading

Warwick Bartlett on tax – The Only Way is Up

Warwick Bartlett, CEO of Global Betting and Gaming Consultants, discusses how government’s approach taxation means that rates are more likely to go up than down. The most pleasing sight at ICE 2015 was to see some of the younger companies which two years ago took the smallest booths are now… – Continue reading

HSBC whistle-blower: You have to know how banks work to understand the size of this scandal

Hervè Falciani, the former HSBC employee who became a whistle-blower by handing over details of client bank accounts to French authorities, triggering investigations into money laundering and tax evasion, believes many other banks are involved in similar practises. In an interview with the Italian newspaper La Stampa, Falciani said that… – Continue reading

Caterpillar Hit With $1 Billion Demand From IRS

Caterpillar, Inc. (CAT), the heavy equipment maker is now under scrutiny as the IRS now demands $1 billion in taxes and penalties. This should come as no shock after the company faced Senate scrutiny in 2014 over its tax plans. Tax Woes The company deals in the designing, manufacturing and… – Continue reading

DFID-HMRC mission likely to hold meeting with FBR in first week of March

ISLAMABAD: A delegation of British Department for International Development (DFID) and Her Majesty Revenue & Customs (HMRC) will hold dialogue with the Federal Board of Revenue (FBR) on future course of action to further strengthen bilateral cooperation. The DFID is a department of the British government that leads the UK’s… – Continue reading

South Africa: Imminent Changes To Transfer Pricing Documentation Requirements In South Africa

On 17 July 2013 the Minister of Finance appointed a tax review committee, headed by Judge Dennis Davis (the “Davis Committee”) to make recommendations for possible tax reforms in South Africa (“SA”). The Davis Committee was required to take into account recent international developments and, in particular, to address concerns… – Continue reading

Offshore decumulation opportunities with Old Mutual International

David Denton, technical expert at Old Mutual International, explores the new decumulation opportunities which are emerging in the offshore market, looking at how they compare to traditional drawdown or annuity options. International annuities targeted at retail investors are emerging in the offshore market which allow QROPS or QNUPS when crystallized… – Continue reading

Clarity In Tax Matters

The Government of India brought in a retrospective amendment in 2012 to nullify the Supreme Court judgement in the case of Vodafone International Holdings B.V. to tax capital gains arising from transfer of shares or interest in a foreign company deriving its value ‘substantially’ from Indian assets. However, the Government… – Continue reading

Singapore, France sign pact for Avoidance of Double Taxation

PARIS: Singapore and France signed an amended Agreement for the Avoidance of Double Taxation (DTA) to lower withholding tax rates for dividends and new anti-abuse provisions. The most notable changes are the following: Withholding tax rate for dividends is reduced to 5 percent (from 10 percent previously) if the beneficial… – Continue reading

Private equity chiefs using “government-sponsored tax avoidance”, to save £700m a year, investigation finds

Research highlights the money pipeline between political parties and private equity houses A tax loophole is being used by the executives at private equity firms to save huge amounts on their personal income tax, according to research published today. An investigation, published by campaign group 38 Degrees, uncovers the private… – Continue reading

EU seeks to force firms pay tax where profits earned

A fresh drive by the European Commission to ensure companies pay their tax where they make their profits could have far-reaching consequences for Irish corporate tax revenue. Some new pieces of legislation will be presented over the next few months, but one of the biggest could be the revival of… – Continue reading

EC launched its ambitious agenda to combat tax avoidance

The European Commission launched its work on its ambitious agenda to combat tax avoidance and aggressive tax planning. The College of Commissioners held a first orientation debate on possible key actions to ensure a fairer and more transparent approach to taxation in the EU.President Jean-Claude Juncker has made the fight… – Continue reading

Ukraine suddenly 40% more interested in UK tax info – HMRC

Growing trend of chasing ‘high net worth foreign nationals’? Cooperation between HM Revenue and Customs (HMRC) and foreign tax authorities will only increase as more countries sign up to automatic tax information exchange agreements. This is according to Pinsent Masons, the law firm behind Out-Law.com, which obtained figures showing a… – Continue reading

Jump In Foreign Requests For UK Tax Information

The number of requests from foreign governments for tax information from the UK rose by 45 percent in 2013, according to international law firm Pinsent Masons. 2,466 requests were received by HM Revenue and Customs (HMRC) in the year to December 31, 2013, up from 1,701 recorded in 2012. James… – Continue reading

China’s tax administration issues new rules governing taxation of offshore indirect transfers

On February 3, 2015, the PRC State Administration of Taxation (“SAT”) released the Announcement of SAT Concerning Several Matters Relating to Corporate Income Tax on Indirect Transfer of Properties by Non-tax Resident Enterprises, Announcement [2015] No. 7 (国家税务总局关于非居民企业间接转让财产企业所得税若干问题的公告, 国家税务总局公告2015年第7号; “Announcement 7”). Below is a brief summary and discussion of the… – Continue reading

Tax Policy Update

NUMBER OF THE WEEK: 3,415. The number of people who renounced their citizenship in 2014 according to IRS data. This is one of the five highest totals on record since the U.S. Congress passed the Foreign Account Tax Compliance Act in 2010. In the past five years, more than 10,000… – Continue reading

Le Perigord owner pleads guilty in tax case

NEW YORK â?? A founder of famed New York City restaurant Le Périgord faces a potential three-year prison sentence that could take him away from the paragon of traditional French cuisine after he pleaded guilty to hiding income in offshore bank accounts. Georges Briguet, 77, admitted during a Brooklyn federal… – Continue reading

Bull and bear cartels in stock market misuse for black money

Mumbai: As a probe continues into the misuse of stock markets for evading taxes and laundering black money, 4-5 cartels of market operators have been identified for making illicit gains or showing fictional losses of several thousands of crores of rupees over last 2-3 years. According to sources, both ‘bull’… – Continue reading

EU launches drive to stop tax evasion by multinationals, plans for new rules next month

BRUSSELS (AP) — The European Union has launched a drive to combat tax evasion following a series of probes into rules that allow multinationals to slash their bills in Luxembourg, Ireland and the Netherlands. The EU’s executive commission said Wednesday that it will propose new tax legislation next month, including… – Continue reading

Worldwide: Asia Tax Bulletin – January 2015

CHINA China Releases GAAR Administrative Measures Courtesy of Mr Glen Wei, an attorney at law, certified tax adviser, and CPA based in China.China’s State Administration of Taxation (SAT) on December 12 issued Decree 32 (dated December 2) introducing administrative measures for applying the domestic general anti-avoidance rule to special tax… – Continue reading

Mumbai ITAT: Outsourced Functions ≠ PE

This Tax Alert by EY summarizes a recent ruling of the Mumbai Income Tax Appellate Tribunal (Tribunal) in the case of Swiss Re-Insurance Company Ltd. (Taxpayer). The Tribunal ruled that the Taxpayer’s wholly-owned Indian subsidiary (ICo) engaged in carrying out risk assessment services, marketing insurance and providing administrative support for… – Continue reading

Vern Krishna: Corporate barons vote with their feet

The abolition of unfair taxes was one of the foundational principles of Magna Carta, a document that King John assented to on June 15, 1215 at Runnymede, England. Taxation must be fair, and requires the consent of the people. There is no more unfair aspect of fiscal law than retroactive… – Continue reading

1ST LEAD Swiss prosecutors search HSBC in money laundering probe By Albert Otti and Thomas Burmeister, dpa

Basel, Switzerland (dpa) – Swiss prosecutors searched HSBC‘s private bank in Geneva Wednesday after launching an investigation into aggravated money laundering against the financial institute. The Geneva prosecution office said it was reacting to last week‘s media reports, which alleged that the Swiss branch of the major British lender helped… – Continue reading

Origi, son of former Harambee Stars striker Mike Okoth is among players being investigated by Belgium tax authorities for operating off-shore accounts

Divock Origi is among top European players who have been named for allegedly evading tax in Belgium. According to Sport24, Origi, son of former Harambee Stars goalkeeper turned striker Mike Okoth and who has been loaned to French side Lille, is among players being investigated by Belgium tax authorities for… – Continue reading

Nova To Hold Quantum SRS Breakfast Briefing

Nova Ltd. is geting set to host a breakfast briefing at the Argus Building, in the Spirit of Bermuda conference room, on February 24, 2015 from 8.30am to 10.00am. A spokesperson said, “The briefing will cover how their unique share registry solution, called Quantum Share Registry Solution [Quantum SRS], can… – Continue reading

International tax cheats in ATO’s sights

The Government may have retreated on its promises to crack down on multinational IT companies avoiding tax, but the Australian Tax Office says it’s on the case. Less than a year ago the ATO appointed Andrew Mills, a tax lawyer from outside the government bureaucracy, to the important role of… – Continue reading

Treaty shopping and BEPS considerations in the M&A context

Every acquisition requires careful tax planning early on in the process, especially when dealing with cross border acquisitions. One important consideration when a foreign company plans to acquire a Canadian company is the impact of any tax treaties that currently exist between the two jurisdictions. Tax treaties effectively reduce tax… – Continue reading

Shire structure puts spotlight on tax

Drug firm has come out fighting after allegations it engaged in tax avoidance on an industrial scale Ireland’s largest drug company has come out fighting following allegations that, with its tax adviser PricewaterhouseCoopers, it has engaged in tax avoidance on an industrial scale – as alleged by the public accounts… – Continue reading

Singapore and France revise their tax convention

Singapore and France signed a revised Agreement for the Avoidance of Double Taxation (DTA) on 15 January 2015, which is not yet in force. The new DTA provides for lower withholding tax rates for dividends and new anti-abuse provisions. The most notable changes are the following: 1. Withholding Tax Withholding… – Continue reading

Multinationals yearn for better service

Firms need clear rules, certainty to remain in compliance with tax law, says expert Heightened scrutiny of foreign companies’ tax practices is a sign of China’s effort to modernize its taxation system to keep up with the fast-changing international business environment, but there is another dimension that concerns the foreign… – Continue reading

Spain Tipped Off Almost 700 HSBC Account Holders in ‘Tax Evasion Amnesty’

Madrid’s public prosecution has accused two high-level tax officials under former prime minister José Luis Zapatero’s administration of helping hundreds of suspected tax dodgers implicated in the HSBC scandal to avoid possible jail sentences, according to Spanish daily newspaper El Pais. María Dolores Bustamante, the former director of tax management… – Continue reading

BoB takes over Kingdom bank

The Bank of Botswana (BoB) on Friday took over management of troubled offshore bank, Kingdom Bank Africa Limited (KBAL). The bank is reeling from liquidity constraints, which have seen depositors fail to withdraw their monies while workers haven’t received regular salaries for the past three months. In a statement released… – Continue reading