Korean Gov’t to Tax Google, Facebook Like Domestic Companies orea is moving to impose taxes on foreign ICT giants such as Google, Apple, and Facebook. To this end, Ruling Saenuri Party lawmaker Hong Ji-man tabled revisions to the Income Tax Act and the Corporate Tax Act in December last year…. – Continue reading
February 4: The Luxembourg tax authorities this week released a draft version of a new administrative circular for implementing the FATCA regime. The new draft guidance concerns the file format to be used for the automatic exchange of information between the Grand-Duchy of Luxembourg and the United States.
Google has told the Australian parliament that it would prefer issues around taxation of multinational corporations to be dealt with by the G20 or the Organisation for Economic Co-operation and Development (OECD), rather than have individual countries attempt to go it alone. The Australian government is attempting to tackle profit… – Continue reading
Though North Korean labor more expensive than previously thought – RFA The DPRK government made agreements promoting mutual investment and preventing double taxation for foreign investors, particularly highlighting cooperation with Russia, according to an article from the Korean Central News Agency (KCNA) published this week. Governments often form tax treaties… – Continue reading
Jersey’s financial institutions are now able to register in Jersey in preparation for US FATCA, which commences this year. The Foreign Account Tax Compliance Act (FATCA) requires financial institutions outside the USA to report information on financial accounts held by their US customers to the Internal Revenue Service (IRS). A… – Continue reading
Emirates Investment Bank yesterday said its total assets under management jumped 81 per cent last year as the economy boomed and the UAE’s safe haven status continued to attract funds from politically troubled countries in the Middle East and other parts of the world. Total assets under management increased to… – Continue reading
The Confederation of British Industry (CBI) has warned the UK Government that significant changes are needed to its proposed diverted profits tax legislation, to ensure that the regime does not capture genuine commercial arrangements. In his 2014 Autumn Statement, Chancellor George Osborne announced plans to levy a 25 percent diverted… – Continue reading
Beijing is going after base erosion and profit shifting, and multinationals could get caught in the crosshairs. China is continuing to step up its efforts to curb what it sees as cross-border tax evasion by foreign-owned companies, announcing it will review how companies move money and allocate costs among their… – Continue reading
The US Internal Revenue Service (IRS) has clarified that a foreign financial institution must obtain a customer’s self-certification details when opening a new account, in a new addition to its Frequently Asked Questions on its Foreign Account Tax Compliance Act (FATCA) website. The IRS was asked: If a Reporting Model… – Continue reading
The US government is scrutinising UAE expats’ bank accounts in a bid to clamp down on tax evasion. Strict new rules that came into effect last year mean US expats who have retained dual nationality, and Gulf-based nationals born in the US or to an American parent, could be US… – Continue reading
On February 2, the Obama Administration released its fiscal year 2016 budget (FY 2016 Budget). The hallmarks of the FY 2016 Budget are proposals that would impose (i) a minimum tax on the current foreign earnings of U.S. corporations and their controlled foreign corporations (CFCs) and (ii) a one-time 14%… – Continue reading
HONG KONG — China’s tax officials plan to step up efforts to collect taxes from multinational corporations in the latest of a series of moves in the last year, mostly against Western companies. The activities have included police raids on the headquarters of companies’ China operations and heavy fines under… – Continue reading
EY is hosting two breakfast seminars this week to discuss how local businesses should be preparing for the next stages of FATCA (Foreign Account Tax Compliance Act) implementation – the identification of reportable accounts and the reporting process itself. Led by Wendy Martin, Executive Tax Director at EY in the… – Continue reading
Negotiations over the India-United States nuclear deal continued until “Air Force One landed in Delhi” carrying President Barack Obama. According to sources, the nuclear deal and other agreements announced during Mr. Obama’s visit to India for Republic Day were being finalised right down to the moment his plane touched down…. – Continue reading
The government is planning to devolve power over the corporation tax rate to the Northern Ireland assembly. This bold and unprecedented move is intended to enable Northern Ireland to compete with the Irish Republic’s headline rate of 12.5%, and follows the agreement that Scotland should set its own rate for… – Continue reading
THE European Union (EU) will not pursue a probe of national programmes that create tax breaks for research and development, giving a boost to drug and technology companies that generate revenue from patents. The EU’s hands were tied by a 2008 decision to approve a “patent box” tax break in… – Continue reading
In 2014, China continued to develop its taxation system affecting domestic and crossborder transactions. This “Legal Flash – Special Edition 2014” highlights the most significant tax updates of the year. Please see our monthly legal flashes for more information and analysis here. Taking a step-forward on anti-avoidance provisions, the State… – Continue reading
The European Commission has turned a blind eye to secretive tax deals that Ireland and other countries have been doing with multinationals for decades. Only after complaints from the US did it launch investigations into the most high-profile cases — Apple in Ireland, Starbucks in the Netherlands, and Amazon in… – Continue reading
The ultimate owners of firms would have to be listed in central registers in EU countries, accessible to people with a “legitimate interest”, such as investigative journalists and other concerned citizens, under a deal struck by Parliament and Council negotiators on a draft EU anti-money laundering directive on Tuesday. The… – Continue reading
Some 776 American citizens or long-time residents renounced their status in the third quarter of 2014, according to the Treasury Department. If that trend continues, the U.S. will see more than 3,000 renunciations this year-a record. Why are so many Americans forfeiting their citizenship? In 2010, Congress passed the Foreign… – Continue reading
(Bloomberg) — The European Union is investigating Belgium’s tax deals with multinational corporations, potentially dragging dozens more companies into widening probes of sweetheart fiscal pacts handed out by national governments. Building on investigations of Apple Inc. in Ireland and Amazon.com Inc. in Luxembourg, the European Commission is targeting Belgium’s so-called… – Continue reading
VADODARA: Ahead of the first Budget of Prime Minister Narendra Modi led NDA government, Gujarat Co-operative Milk Marketing Federation (GCMMF) that markets Asia’s largest milk brand — Amul — has demanded that the dairy sector be considered at par with the agriculture sector. GCMMF — the apex body of all… – Continue reading
Time is ticking for India to sign its inter-governmental agreement (IGA) with the US under the Foreign Account Tax Compliance Act (FATCA) after it received a one month extension on the original December 31 deadline. President Obama’s visit to India last week fuelled speculation that the IGA could be signed… – Continue reading
Samantha Cameron is creative consultant at the upmarket company Firm is is owned through a holding company in Luxembourg It is also linked to a secretive trust in the Channel Island of Guernsey David Cameron has often criticised companies who use tax havens David Cameron has often railed against big… – Continue reading
The United Nations (UN) has plumped for greater cooperation among countries to put in place a set of safeguards and rules for tax reforms the world over in the bleak backdrop of extant rules and conditions, “particularly regarding illicit flows, as well as tax avoidance” often limiting what governments can… – Continue reading
Progress continues to be made in the BEPS project, with the release in September 2014 of the “2014 Deliverables” and a raft of discussion drafts published during the autumn. Here is a summary of all the recent developments. Within the framework of the BEPS (Base Erosion and Profit Shifting) action… – Continue reading
The Internal Revenue Service (IRS) has released revised versions of its Tax Guide for Aliens, providing guidance for resident and nonresident aliens for use in preparing their 2014 tax returns, and of its Tax Guide for Individuals Receiving Income from the United States Possessions – American Samoa, Puerto Rico, the… – Continue reading
The IRS has one foot in the 21st century, and the other in the days of Camelot. The majority of taxpayers can file their federal income tax returns online. And those eager to see how soon they’ll get their refunds can even use the IRS’s mobile app. But thanks to… – Continue reading
The ARIA Investment Platform has launched a range of portfolio strategies on its investment platform aimed at US Investors caught by increasingly tough legislation. The Cautious Income Balanced and Adventurous Strategies are advised by Parala Capital, based on its Parala Macro Multi-Asset Allocation strategies, and are available on the ARIA… – Continue reading
On 30 January 2015 the Legislative Council passed certain changes to the Mandatory Provident Fund Schemes Ordinance (“MPFSO”). Such changes, when they come into force, will enable the withdrawal of benefits on the terminal illness of an employee, and also enable a phased withdrawal of accrued benefits. In addition, the… – Continue reading
Panellists at a Guernsey funds technical masterclass in London have praised the jurisdiction for its progressive nature in tackling international regulatory developments. Delegates were told that Guernsey’s response to initiatives such as the Alternative Investment Fund Managers Directive (AIFMD), Markets in Financial Instruments Directive (MiFID) II, the Foreign Account Tax… – Continue reading
Ireland has been ranked among the least complex business destinations for multinationals, and its appeal has improved as a result of recent international tax policy changes, according to a new study. The study from the TMF Group ranked 81 jurisdictions across Europe, the Middle East, Africa, Asia-Pacific, and the Americas… – Continue reading
Many wealthy foreigners considering their options for investment, permanent residency or citizenship in the US are concerned about the US tax policy. Many have heard of the US income tax on worldwide income, but in reality, astute advisors can mitigate or eliminate the additional expense. US Freedom Capital, the premier… – Continue reading
From 6 April 2015 any individual, whether UK-resident or non-UK-resident, owning property in the UK and abroad, will need to ensure they comply with the new rules if they are to benefit from the relief when selling their PPR On 15 December 2014 the Government issued draft legislation to implement… – Continue reading
Business industry feedback on BEPS discussion drafts, including comments from BIAC, TEI, Reed Elsevier, Volvo and Siemens, suggests that the OECD has done little to quash taxpayer concerns over double taxation and dispute resolution. The OECD’s BEPS project was the TP topic of 2014 and will undoubtedly retain the top… – Continue reading
Weak governance means Africa loses more than $50bn each year in unpaid taxes and money laundering, a new report has found. The analysis, published jointly by the African Union and the United Nations Economic Commission for Africa, concluded that a lack of financial transparency and difficulties in obtaining systematic data… – Continue reading
The National Taxpayer Advocate Nina Olson is a strong and vocal advocate for taxpayer rights. Her annual report to Congress castigates the IRS for its unfair application of offshore account penalties, and its disparate treatment of innocent Americans caught in reporting snafus. Some of the report asks the IRS to… – Continue reading
Guernsey’s forward-thinking approach to international regulatory requirements has aided the success of its funds industry and raising its profile as an international finance centre, according to a panel discussion at the Guernsey Funds Masterclass in London. Panellists discussed the implementation of regulations like such as the Alternative Investment Fund Managers… – Continue reading
Panellists at a Guernsey funds technical masterclass in London have praised the jurisdiction for its “progressive nature” in tackling international regulatory developments. Delegates were told that Guernsey’s response to initiatives such as the Alternative Investment Fund Managers Directive (AIFMD), Markets in Financial Instruments Directive (MiFID) II, the Foreign Account Tax… – Continue reading
GCC nationals with dual citizenship face IRS efforts to collect income tax from non-residents Thousands of Gulf States nationals could be US tax evaders and not even know it. According to Italian-Swiss lawyer Giovanni Rossi who works for a law firm handling many of similar cases, the number could reach… – Continue reading
SELF-assessment is a vital element of tax policy and is employed by many countries to collect taxes as it is considered more efficient and cost-effective. Pakistan adopted universal self-assessment for all taxpayers in 2002-03 to ensure voluntary compliance. Using the technique of ordinary least square regression and quarterly data for… – Continue reading
The draft legislation published on 10 December 2014 (see here) devotes almost 30 pages to the new “diverted profits tax” (DPT), which from 1 April 2015 will introduce a new tax at a rate of 25% to profits generated by those multinational corporate groups who, in the eyes of the… – Continue reading
New Delhi: Multinational companies operating in India will soon have to disclose details of their operations at the country of residence and their revenue income to the Income Tax authorities. The Budget for 2015-16 may contain provisions relating to the Global Base Erosion and Profit Shifting (BEPS) rules, which are… – Continue reading
Eleventh-hour legislation in December kept many tax breaks alive for the 2014 tax year, but they weren’t extended beyond that. (See chart on page 26.) So clients who want to take advantage of those breaks need to get with a knowledgeable practitioner—and quickly. “CPA firms nationwide face a staffing challenge… – Continue reading
India and US reach common ground on Mutual Agreement Procedure (“MAP)” and break new ground on Advance Pricing Agreements (“APA”) Suchint Majmudar Just ahead of Obama’s momentous R-Day visit to India, the Competent Authorities of India and US reached a landmark breakthrough in cases involving mutual agreement procedure under the… – Continue reading
The IRS issued two New Releases this week that restate its focus on offshore tax evasion. The first was January 29, 2015 which followed the First International Criminal Tax Symposium. “The Internal Revenue Service Criminal Investigation Division (IRS-CI) and Her Majesty’s Revenue & Customs (HMRC) co-hosted a three-day International Criminal… – Continue reading
The Internal Revenue Service announced in January that its International Data Exchange Service (IDES) is open for enrollment, and that financial institutions and host country tax authorities will be able to use IDES to securely send their information reports on financial accounts held by Americans to the IRS under the… – Continue reading
The Australian Tax Office is pushing ahead with a controversial plan to allow the country’s biggest corporations to audit themselves through their own private auditors, despite mounting public anger over corporate tax avoidance. An ATO spokesman said 56 public companies with a turnover of between $100 million and $5 billion… – Continue reading
Private companies often get away with tax evasion because they can afford better lawyers than government, former president Thabo Mbeki has said. “The problem is that private companies or large companies are able to mobilise much better skills with regards to lawyers, accountants, banking people and all that, so they… – Continue reading
NEW DELHI: Multinational companies operating in India will soon have to disclose details of their operations at the country of residence and their revenue income to the Income Tax authorities. The Budget for 2015-16 may contain provisions relating to the Global Base Erosion and Profit Shifting (BEPS) rules, which are… – Continue reading
