Transfer pricing has been a favorite Canada Border Services Agency (CBSA) enforcement target for some time now. Payments made by importers because of income tax transfer pricing requirements can trigger obligations and liabilities under Canadian customs laws. This arises, for example, when CBSA seeks to assess duties and taxes on… – Continue reading
With the city-state revising its earlier avoidance of double taxation agreement with France and signing a new one with Uruguay recently, a boost in cross-border trade is inevitable. Singapore (PRWEB) January 22, 2015 In what can be termed as two important milestones in Singapore’s trade relations with Europe and Latin… – Continue reading
In the first of this two part article, we outlined what businesses must do to comply with India’s transfer pricing laws, while stressing the key reforms introduced by the new government to bring certainty to the domestic tax system. Here, we discuss if and how India should respond to the… – Continue reading
The US Foreign Account Tax Compliance Act (FATCA) is in the vanguard of a global movement towards the automatic exchange of information on tax matters. The US enacted FATCA in 2010 to tackle the problem of tax evasion by US citizens and residents who under-report or fail to report income… – Continue reading
MUMBAI: UK-based telecom company Vodafone Group will hold its board meeting in Delhi later this month, said two people aware of this. It will be the second such meeting in the country since Vodafone acquired its business in India. The meeting is an “ordinary” board meeting with “routine” agenda items,… – Continue reading
NEW DELHI: India and the US have finalised a framework to resolve transfer pricing cases, some of them pending for five years, in what could end tax trauma for more than 50 American MNCs such as Microsoft, IBM and Oracle by the fiscal year-end and send a strong signal to… – Continue reading
SINGAPORE (Jan 22): Keppel Corp posted a 6% rise in 4Q earnings to $726 million, or 39.9 cents per share. This was 6% above the $684 million recorded in 4Q13, led by higher pre-tax profit from most of its divisions. For the full year FY14, earnings fell 19% to $1.39… – Continue reading
The news that the government was considering to include fiscal offences like serious tax crimes/tax evasion into the ambit of money laundering under the proposed Anti-Money Laundering Act (AMLA) would appear to be quite strange for the business community and other taxpayers. This surprising piece of information was disclosed by… – Continue reading
Just as UK firms grasp the requirements of the US-led Foreign Account Tax Compliance Act (Fatca), China appears to be joining the ranks as another nation seeking to up its tax-take from citizens living abroad. China has announced plans to implement a law that is similar to Fatca. This legislation… – Continue reading
To comply with unconstitutional pseudo-treaties negotiated by the Obama administration without the consent of Congress or any semblance of constitutional authority, the IRS announced that it will be sharing private financial information on U.S. bank account holders with foreign powers. No warrant is needed for foreign governments or tyrants to… – Continue reading
The IRS has unveiled a secure web application, the International Data Exchange Service (IDES), for cross-border data sharing. IDES will allow Foreign Financial Institutions (FFIs) and tax authorities from other countries to transmit financial data on U.S. taxpayers’ accounts, via an encrypted pathway, to the IRS. The tool is part… – Continue reading
New Zealand First is concerned the Uber ride service and multinational companies like it are using elaborate tax shelters to rip off hard working Kiwi taxpayers. The Party will be closely following the government’s newly announced review of small passenger services. “Why is it when a multinational with a track… – Continue reading
Lobbyists representing firms including Google, Amazon and Apple claim ‘fundamental flaws’ in G20-led reforms The World Economic Forum in Davos, where Google, Microsoft and Facebook executives will discuss the digital economy on Thursday. Photograph: Fabrice Coffrini/AFP/Getty Images Lobby groups representing Google, Amazon and other powerful US tech multinationals have launched… – Continue reading
The Davis Committee has made certain recommendations relating to transfer pricing and documentation in its report on the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan. We are aware that the current transfer pricing practical guidelines, as contained in SARS’ Practice Note 7 (PN7), are not that clear and… – Continue reading
2014 was a year replete with new legislative and regulatory initiatives impacting federally regulated financial institutions. The key initiatives introduced or implemented in 2014 are outlined in our annual year in review. PRUDENTIAL REGULATION: GUIDANCE FROM OSFI Proposed New Bail-in Regime for Large Banks On August 1, 2014, the Government… – Continue reading
Today, the Scottish government revised its new Land and Building Transaction Tax (LBTT) rules. The LBTT is to replace stamp duty in Scotland from April, and its rates had been designed to be oddly punitive for those buying high-end houses. Anyone buying a house costing more than £250,000 was to… – Continue reading
President Vladimir Putin is pushing harder on Russia’s richest citizens to repatriate offshore assets amid a slump in the ruble and the imposition of sanctions by the US and the European Union, The Business Times said. Under new tax rules signed into law by a presidential decree in November, Russian… – Continue reading
Stakeholders in Real Estate Investment Trusts (REITs) have identified double taxation as challenge to investment in the sector, even as they clamour for enabling legislation. In order to make the Real Estate Investment Trusts (REITs) a tax-effi¬cient vehicle for invest¬ment, there is an urgent need for an enabling leg¬islation, they… – Continue reading
In his state of the union address last night President Obama urged U.S companies to repatriate all those profits hiding off-shore and away from the prying eyes of the IRS. Ed Mills, Managing Director at FBR Capital Markets summed it up in his morning note: The President called on Congress… – Continue reading
SUCCESSFUL INTERNATIONAL STRUCTURES in most cases begin with choosing the right jurisdiction to host a company that will form part of an international business. Depending on the company’s activities, the choice will depend on the range of double taxation treaties and the availability of tax reliefs followed by a host… – Continue reading
Chancellor George Osborne told MPs that allowing Scotland to vary air passenger duty could cost Newcastle 450,000 passengers Chancellor George Osborne has warned that Newcastle International Airport could lose 450,000 passengers if the region is made a guinea pig for air tax reform. Speaking to the Treasury Select Committee Mr… – Continue reading
On October 29, 2014, through the OECD “Global Forum on Transparency and Exchange of Information for Tax Purposes,” both the OECD and G20 countries endorsed a new Standard for Automatic Exchange of Financial Account Information in Tax Matter. 59 countries are so-called “early adopters” and are committed to undertaking their… – Continue reading
Democratic lawmakers Tuesday pushed legislation to stop U.S. companies from reincorporating overseas to reduce their tax bills, saying a wave of so-called inversions last year has nearly doubled the revenue the federal government will lose from those moves over the next decade. The bill would make it tougher for U.S…. – Continue reading
HONG KONG (Reuters) – Chinese property companies are having to turn to more expensive sources of finance as problems at developer Kaisa Group make it increasingly difficult for them to get credit in the offshore market. Kaisa’s failure this month to make an interest payment on a dollar bond has… – Continue reading
A person who is required to file an information return with the IRS must obtain your correct taxpayer identification number (TIN) to report, for example, income paid to you, payments made to you in settlement of payment card and third party network transactions, real estate transactions, mortgage interest you paid,… – Continue reading
In December 2014, the Canada Revenue Agency (CRA) issued a letter to a sample of taxpayers to remind them of the criteria for filing a T1135-Foreign Income Verification Statement and to review their income tax filings to ensure they have been properly reporting the relevant assets and income. All Canadian… – Continue reading
The thrust of the Indian government’s economic policy is encouraging, particularly the tax reform of proposed introduction of goods and services tax. NEW DELHI, JAN 20: Germany has made a case for ‘respecting the secrecy’ of any information shared with India for tax administration purposes. This stance assumes significance given… – Continue reading
President Obama reopened a fiscal can of worms with his proposal to increase the capital gains tax to 28 percent, a plan Republicans said they would not adopt. The administration has tried to paint it as a mainstream idea, noting that the rate was 28 percent under President Ronald Reagan,… – Continue reading
For as long as leaders from low-income countries are excluded from the solution, tax avoidance will inflict costly and sometimes life-threatening consequences on millions of individuals Politicians have been all-too-eager to label 2014 a milestone year for action on tax avoidance, with many of the world’s leading economies having introduced… – Continue reading
Voltaire wrote “If you see a Swiss banker jumping out of a window, follow him, there is sure to be a profit in it”. Following this train of thought India is seen to be ruined by a cartel of Swiss bankers, terrorists and corrupt industrialists. Unlimited black money is apparently… – Continue reading
Both the OECD and the EU are exploring options to change how digital businesses are taxed, while NGOs are stepping up their pressure on tax authorities to challenge large companies’ transfer pricing arrangements. No matter how robust your digital business’s transfer pricing arrangements appear to have been in the past,… – Continue reading
Outlook: The OECD’s work on corporate tax avoidance has proceeded at a faster rate than many expected According to Oxfam, on current trends the richest 1 per cent of the world’s population will have a greater share of its wealth than the remaining 99 per cent within two years. The… – Continue reading
On Dec. 12, 2014, Rep. John Delaney (D-MD) proposed a new version of his “repatriation holiday” tax plan. The latest version would require multinational corporations to pay a token amount of taxes on their accumulated offshore profits and exempt those profits from any further U.S. income tax. Delaney’s new plan… – Continue reading
Chancellor George Osborne has told MPs that new powers being handed to Scotland could result in a UK-wide competition over tax rates. The Tory minister was giving evidence to the Treasury select committee which is examining the Smith Commission plan. Mr Osborne said it would be up to Scotland to… – Continue reading
The Co-operative Bank has officially banned lending to companies involved in payday lending and those gambling and tax avoidance activities that it deems irresponsible as part of an effort to restore its ethical credentials. The troubled bank, which last year gave majority control to its lenders as part of a… – Continue reading
Costa Rica’s going under the magnifying glass for the next two weeks as international money laundering experts comb through the country’s books. President Luis Guillermo Solís declared the audit from the Financial Action Task Force of Latin America (GAFILAT) a subject of national interest in Monday’s edition of the official… – Continue reading
Voltaire wrote “If you see a Swiss banker jumping out of a window, follow him, there is sure to be a profit in it”. Following this train of thought India is seen to be ruined by a cartel of Swiss bankers, terrorists and corrupt industrialists. Unlimited black money is apparently… – Continue reading
The Tax Story in 2015: Myths, Misconceptions and Reality Checks by Aswath Damodaran, Musings on Markets Each of us believes that we pay our fair share in taxes and that it is other people that do not, and not surprisingly, we find evidence to back up our priors. I find… – Continue reading
After almost three years’ negotiations over untaxed Italian assets in Swiss banks, Switzerland and Italy have reached an agreement in principle on future cooperation in tax matters. The agreement between Switzerland and Italy was initialled on 19 December 2014 The two governments are currently preparing the signature of a Protocol… – Continue reading
Competition commissioner urging swift conclusion to open investigations The European Commission has said it will publish the result of its investigation into the Government’s tax arrangements with Apple by the spring. Speaking in Brussels, a commission spokesman said competition commissioner Margrethe Vestager “wants to focus on the four open in-depth… – Continue reading
Observers of offshore financial centres will know that post 2008 they have been weathering a perfect storm. Firstly, reduced transactional flows, simply because there is less money available for structured finance and investment generally. Secondly, a constant barrage of negative publicity, which deliberately seeks to conflate tax evasion and tax… – Continue reading
Kansas Governor Sam Brownback had championed the largest tax cuts in the state’s history, eliminating taxes on non-wage earnings for nearly 200,000 small businesses. Just like all Republicans these days, Brownback had made cutting taxes and shrinking government the centerpieces of his government. Now the great State of Kansas has… – Continue reading
Introduction Malta is increasingly becoming a financial services centre of repute looked at by a number of financial services operators as the ideal platform to set up their private pension schemes. Malta’s success is attributable to the flexible and prudent manner in which the industry is regulated, providing the desired… – Continue reading
Having abandoned its policy of capping the Swiss franc’s value versus the euros, the Swiss National Bank needs a Plan B for blocking the destructive, deflationary forces emanating from Switzerland’s struggling neighbors in the eurozone. Most likely, it will consist of allowing Swiss banks to charge negative interest rates to… – Continue reading
A recent clarification issued to Foreign Portfolio Investors (FPIs) clarified that fund managers of FPIs who are present in India would not be treated as permanent establishments in India, addressing the concern that the FPIs may be taxable in India to the extent attributable to permanent establishments. An extension of… – Continue reading
Jan 19 (Reuters) – A former Julius Baer banker was found guilty on Monday of breaching Swiss banking secrecy laws by handing over data about offshore clients to WikiLeaks, but will avoid jail time. Rudolf Elmer, 59, a former senior executive at Zurich-based Baer’s Cayman Islands’ office, was accused of… – Continue reading
Asia’s ultra-high-net-worth-individuals (UHNWIs) are expected to hang onto their wealth for longer, as succession planning becomes an increasingly pertinent issue among this investor demographic elsewhere in the world. According to a new report by consultancy Wealth-X, around US$16 trillion of global UHNWI wealth is expected to be handed over to… – Continue reading
Midlands businesses can still benefit from the Patent Box, according to international accountancy firm Mazars. It follows plans to amend it – resulting in a narrower focus on UK R&D. That is the verdict from Birmingham professionals Peter Jelfs, senior tax manager at international accountancy firm Mazars, and Nicholas Braddon,… – Continue reading
Italy and Switzerland have agreed an amendment to their double tax agreement to enhance tax information exchange provisions. It is hoped that the agreement will be signed before the March 2 deadline set by Italy’s new voluntary disclosure program to enable Switzerland’s removal from Italy’s “black list.” After three years… – Continue reading
No issue dominates this year’s legislative and regulatory agenda of the risk management and property/casualty insurance community as reauthorization of the federal terrorism insurance backstop did even several weeks ago. Extension of the program, which lapsed several days before Congress reinstated it in early January, united the industry around a… – Continue reading
