MULTINATIONAL corporations (MNCs) in Malaysia will soon be seeing more tax law changes coming their way as the authorities get down to tackling base erosion and profit shifting (BEPS). This follows efforts by the Organisation for Economic Co-operation and Development (OECD), approved by G20 leaders, to formulate a 15-step action… – Continue reading
The Federal Court of Canada has ruled that the Canadian Revenue Agency may not conduct further in-person interviews with representatives from a multinational corporation concerning its transfer pricing affairs, having already discussed earlier tax years. Cameco Corporation declined to produce approximately 25 personnel for oral interviews in relation to an… – Continue reading
The Internal Revenue Service has extended the deadline for foreign financial institutions to have renewed their FFI Agreements, it has emerged. As reported, the original deadline was 31 July. However, accounting industry sources have flagged up the fact that the Internal Revenue Service is now stating that the deadline for… – Continue reading
The Treasurer has recently released exposure draft legislation (Treasury Laws Amendment (Housing Tax Integrity) Bill 2017) in relation to removal of the CGT main residence exemption for foreign residents. The changes are part of the Commonwealth Government’s ‘housing affordability’ reforms announced in the 2017-18 Budget. This will affect both Australian… – Continue reading
African nations will have more resources at their disposal to meet the Sustainable Development Goals if their national revenue authorities can boost tax collection. The United Nations Economic Commission for Africa estimates that the continent loses more than $50 billion through illicit financial outflows per year, much of this linked… – Continue reading
PERTH (miningweekly.com) – US oil and gas major Chevron has withdrawn its High Court appeal over a A$340-million bill from the Australian Taxation Office (ATO). The withdrawal means that the Full Federal Court decision of April is now final. The company in May turned to the High Court after a… – Continue reading
Bizlive cited a report from the Foreign Investment Agency (FIA) as showing that the British Virgin Islands alone registered $1 billion worth of FDI in the first seven months of the year, raising its total accumulative investment capital to $21.4 billion, ranking fifth among countries and territories with the highest… – Continue reading
Banker’s Toolbox, Inc., the leader in Bank Secrecy Act anti-money laundering compliance solutions for financial institutions, announced today the launch of its Due Diligence Manager solution for Beneficial Ownership. This extension of the existing BAM+ platform delivers exciting and holistic features including a completely flexible question builder and automated periodic… – Continue reading
Mexico has introduced new substance-over-form procedures that change the country’s formal approach into one more compliant with the BEPS Project. Taxpayers should take note of these developments as they may impact tax disputes, writes Bernardo Ramírez and Valentín Ibarra of Chevez, Ruiz, Zamarripa y Cía. Resulting from a G20 world… – Continue reading
INTRODUCTION HMRC have successfully challenged the offshore residence of Jersey companies holding UK real estate. In the case of Development Securities, the First Tier Tribunal held that Jersey companies set up to hold UK real estate were resident in the UK for tax purposes. This case serves as a timely… – Continue reading
This article is the third of a series of articles that examines tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors in other offshore financial centres…. – Continue reading
Ireland has published guidelines for requesting Mutual Agreement Procedure (MAP) assistance. The guidelines, issued in early August, set out the legal basis for requesting MAP assistance as well as: the process through which taxpayers can request assistance from Ireland’s Competent Authority (the Revenue) the possible outcomes resulting from a request… – Continue reading
The UK tax authority, HM Revenue and Customs (HMRC), has warned taxpayers to avoid disguised remuneration schemes that attempt to recharacterize loan arrangements to avoid the 2019 loan charge on disguised remuneration. “HMRC is aware of schemes that claim to avoid the 2019 loan charge on disguised remuneration. These schemes… – Continue reading
The Irish Government is said to be nearing a deal with Apple that would protect the state from any losses that could arise while it holds in escrow the “state aid” money the EU has ordered the tech giant to pay back. Bloomberg reported that an individual familiar with the… – Continue reading
America has formally agreed to share detailed information of companies with the Australian government’s Tax Avoidance Taskforce. This means authorities get access to additional intelligence to track down US-based multinationals. This month, US authorities signed a country-by-country report exchange deal with Australia. It seeks to give authorities a broader picture… – Continue reading
The Budget Advocacy Network (BAN) has called on the country’s revenue authority to push for better taxation not more taxation. In its Transfer Pricing Report, BAN identified that such efforts hold the potential to stimulate further growth and investment whilst also allowing for increased levels of tax collection. The huge… – Continue reading
Bill would require private companies with more than $100m in turnover to publicly release tax information Six hundred of Australia’s biggest private companies could finally be forced to publish their high-level tax information, under a new push by Labor to repair a notorious piece of legislation. Labor will introduce a… – Continue reading
Brazilian football star Neymar is willing to pay a fine of £1.9 million to settle tax evasion allegations in his country, his lawyer said Friday. The 25-year-old wants to leave the fight with Brazilian authorities behind him as he prepares for a new professional life with Paris Saint-Germain after his… – Continue reading
I am a trustee of an offshore trust settled by a UK resident, non-UK domiciled settlor (with no UK origins) for the benefit of himself and his family. He previously opted to be taxed on the remittance basis. The trust holds only offshore investments. The settlor lent monies to the… – Continue reading
Luxembourg Finance Minister Pierre Gramegna has introduced legislation into parliament that would establish a new intellectual property tax regime in Luxembourg. The bill was submitted to the Chamber of Deputies on August 4, 2017, and is designed to be aligned with the “modified nexus” approach to special IP tax regimes… – Continue reading
The Government of Hong Kong has said that it will introduce legislation into the Legislative Council by the end of this year to implement the minimum standards proposed by the OECD as part of its base erosion and profit shifting project. The BEPS framework, proposed by the OECD at the… – Continue reading
Revenue Minister Judith Collins has welcomed a second round of negotiations between China and New Zealand tax officials aimed at updating the current double tax agreement signed between the two countries in 1986. “The aim is to agree a new treaty, adopting modern treaty language and concepts, including agreed measures… – Continue reading
On August 3, 2017, the Irish Revenue published Revenue e-Brief No. 74/17, which contains guidance for taxpayers on complying with Ireland’s transfer pricing documentation requirements. The guidance notes that companies are legally required to maintain transfer pricing documentation. However, there is no requirement for documentation to be kept in a… – Continue reading
Contrary to calls from businesses from the regulation’s withdrawal, the Institute on Taxation and Economic Policy has called on the US Treasury to fully implement and strengthen its final Section 385 anti-earnings stripping debt-equity regulations, designed to reduce the benefits of corporate tax inversions. The final regulations, released in October… – Continue reading
Global consultancy EY among firms now offering advanced services that redefine how companies face new developments in tax, audit and compliance Rigid new global initiatives to increase transparency of business data are giving rise to more advanced professional tax services, which employ innovative tools that include cloud computing, financial technology… – Continue reading
Israel’s $41 million tax demand from the Coca-Cola Co. on royalties from its Israeli licensee could mark the start of a wave of claims against U.S. and other multinationals with similar business operations in the country. That could lead to a conflict with U.S. and other authorities about which country… – Continue reading
The Swiss Federal Council has announced that an information exchange amendment to the double tax agreement with Belgium has entered into force. On August 7, the Council said the additional agreement to amend the DTA had entered into force on July 19. It contains an administrative assistance clause in accordance… – Continue reading
In an effort to create a ‘level playing field’, Asian economies are committing to new standards of transparency At the risk of losing some foreign investors, Asian jurisdictions are stepping up efforts to combat corporate tax avoidance to meet new global transparency standards. More than a dozen Asia-Pacific jurisdictions have… – Continue reading
Stock analysts in South Korea played down the possible impact of the government’s decision Wednesday to impose taxes on foreign investors holding over 5 percent of a company, but warned of widening volatility prompted by foreign investors’ sell-offs over the past couple of weeks. Starting January 2018, a broader scope… – Continue reading
The current plan for US tax reform would disproportionately benefit the wealthy, the International Monetary Fund has said, recommending more support for low-income taxpayers and higher indirect taxes. On the need for tax reform, the IMF said in its Article IV consultation for the United States that “the US personal… – Continue reading
The International Revenue Service’s Criminal Investigation unit is readying two new programs focusing on data investigations and international tax enforcement. The data initiative will tie together the information uncovered by the IRS’s field offices around the country with headquarters in Washington, D.C. “We are standing up a nationally coordinated data… – Continue reading
APAs were recently implemented in the Croatian tax legislation. Our Transfer Pricing team briefly presents the main points of the Croatian legislation related to an APA. Transfer pricing legislation was introduced in Croatia by way of the Corporate Income Tax Act (CIT) on 1 January 2005. However, the Croatian tax… – Continue reading
The Act currently provides for income taxable as ‘capital gains’ to be computed after taking into account the full value of consideration received or accrued on transfer of a capital asset “A person doesn’t know how much he has to be thankful for until he has to pay taxes on… – Continue reading
Representatives of most multinational companies believe that there is a radical global change in both tax and tax control. Accordingly, the global tax model is undergoing a process of alignment with other principles, and the approach of the tax authorities during controls becomes stricter, a survey by Deloitte published in… – Continue reading
The UK will not engage in aggressive tax competition to attract business post-Brexit, Chancellor Philip Hammond has said. He added that the country’s economy will remain aligned with the European model after leaving the EU. “It is often said that London would consider launching into unfair competition in terms of… – Continue reading
BEIRUT: The Association of Banks in Lebanon and other private sector leaders are weighing the few options open to them as recently approved new tax measures, poised to be implemented soon, threaten to have a detrimental effect on their businesses and the overall economy. The few available options include trying… – Continue reading
US Ambassador Allan Mustard and Turkmenistan’s Minister of Finance Gochmyrat Myradov signed an Intergovernmental Agreement (IGA) to implement the provisions of the Foreign Account Tax Compliance Act (FATCA), said the US Embassy in Ashgabat. The agreement underscores growing international cooperation to curb offshore tax evasion and marks a step forward… – Continue reading
The change converts tax-deductible interest payments employed by the schemes into taxable stock dividends. The U.S. government on Friday gave companies an extra year to comply with an Obama-era regulation meant to crack down on corporations that try to minimize their U.S. tax bills by shifting profits abroad to countries… – Continue reading
Federal income tax reform is by far the biggest concern of corporate tax executives, a new survey from Bloomberg BNA reveals. Survey of Corporate Tax Departments 2017 spotlights several key tax issues, and “corporate tax professionals are facing a wealth of challenges as they look to prepare their businesses for… – Continue reading
The Department of Finance (DOF) on Wednesday asked the Senate to support the proposal relaxing the country’s bank secrecy law as it would allow the Bureau of Internal Revenue (BIR) to conduct the proper audit in tax fraud cases. Absolute bank secrecy is one of the “major” issues that need… – Continue reading
Computer scientists have worked to uncover the way the Netherlands, the UK, Ireland, Singapore and Switzerland, in particular, are used by multinationals to channel investments onto well-known offshore centres (OFCs). According to the research which was first reported by online journal Quartz, the five countries are used by multinationals to… – Continue reading
France intends to appeal against a recent court decision in favor of Google in a major tax avoidance case, but is open to settling the dispute outside of court, a government minister has said. In an interview with Les Echos, Minister of Action and Public Accounts, Gerald Darmanin, said that… – Continue reading
Business group Ibec has said that the Irish Government must “Brexit proof” its 2018 Budget, improve its foreign direct investment model, and implement a range of tax reforms to compete with the UK. Publishing the group’s pre-Budget submission, Ibec Director of Policy and Public Affairs, Fergal O’Brien said: “The Irish… – Continue reading
Tax avoidance by multinationals is better dealt with by an international treaty than harsher measures brought in by Australia and the United Kingdom, Revenue Minister Judith Collins says. In an interview with TV3’s The Nation, the minister said she had not ruled out the idea of diverted profit tax, which… – Continue reading
The Australian Government has unveiled a package of housing tax breaks, including a new scheme for first-time buyers, a superannuation incentive for downsizers, and tighter rules for foreign residents. In a joint release, Treasurer Scott Morrison and his Assistant Minister, Michael Sukkar, said: “Housing affordability is a major issue affecting… – Continue reading
THE BENEFITS OF NON-DOMICILE STATUS An individual who is resident but not domiciled in the UK does not pay tax on overseas income and gains, as long as they are kept outside the UK and are not used to provide benefits in the UK. This is called the remittance basis… – Continue reading
The Australian Government has moved to clarify the tax treatment of foreign investors, following concerns over the practical operation of the Investment Manager Regime (IMR) and the new tax system for managed investment trusts (MITs). The aim of the IMR is to attract foreign investment to Australia and the promote… – Continue reading
Canada and dozens of other countries will automatically share banking information of non-residents Canadians with secret overseas bank accounts could soon find themselves at risk of being exposed by a new international agreement designed to help catch tax cheats. Under the Common Reporting Standard, dozens of countries will share information… – Continue reading
Labour is threatening to crack down on multinational companies that are dodging paying their fair share of tax in a move it believes will net $200 million a year in extra tax for the Government. Leader Andrew Little said according to Inland Revenue, New Zealanders were missing out by hundreds… – Continue reading
The European Commission launched legal proceedings against Portugal, Bulgaria, and Cyprus for not adopting, in their national laws, European Union legislation requiring all EU countries to exchange tax rulings granted to multilateral companies. The legislation was adopted in the wake of the 2014 LuxLeaks scandal that revealed more than 100… – Continue reading
