Business leaders are calling on Chancellor Philip Hammond to tackle anomalies in the tax system that see high street shops pay higher rates on small premises than online giants do for vast warehouses. The Institute of Directors said the Chancellor should use next month’s Budget to set up a New… – Continue reading
(Bloomberg Gadfly) — A referendum lost. Voters crying foul at cuts to public services. The threat of financial chaos and businesses sent packing. This isn’t Brexit Britain. It’s Switzerland. The country this weekend voted down a government plan to keep offering tasty tax breaks to multinational companies — while still… – Continue reading
Background Switzerland levies federal withholding tax at the rate of 35% on certain capital income, including dividend distributions of Swiss corporations. The federal withholding tax is fully refundable for Swiss resident recipients, provided that they (i) are beneficially entitled to and (ii) correctly declare respectively account for the taxable income…. – Continue reading
Following Moody’s Investors Service affirmation of Indonesia’s sovereign credit rating at Baa3 with a stable outlook in January 2016, there has been renewed interest in the international bond market for Indonesian credits. This bulletin seeks to summarise the regulatory changes in Indonesia over the last 24 months as well as… – Continue reading
A new paper that calls for the introduction of a US carbon tax has been released by a group of former Republican administration members and economic advisers and leading business representatives. Issued under the auspices of the Climate Leadership Council, the paper proposes that the tax might begin at USD40… – Continue reading
On 7 February 2017, the Minister of Finance of Ukraine and the US Ambassador to Ukraine signed a treaty on Ukraine’s performance of the US Foreign Account Tax Compliance Act (FATCA) (the Treaty). According to the Ministry of Finance of Ukraine, the Treaty is based on the Model 1B Intergovernmental… – Continue reading
Last Autumn, HMRC issued “Measuring Tax Gaps”, an annual report on the estimated UK tax gap. The tax gap being the shortfall in tax estimated by HMRC as being due in any one tax year from that which is eventually collected. In the accompanying press releases and in comments made… – Continue reading
Selection of Foreign Company as a tested party – practical considerations Introduction Transfer pricing regulations adopted by India are based on the arm’s length principle which revolves around the concept that the price or margin determined in a controlled transaction involving two Associated Enterprises (AE) should be commensurate with an… – Continue reading
MARTINSBURG — The Internal Revenue Service has started releasing this year’s top 12 scams targeting consumers known as “The Dirty Dozen.” The annually compiled list features a variety of scams the agency says are common and that taxpayers could encounter anytime, but especially during peak filing season. Phishing schemes lead… – Continue reading
A CAMPAIGN has been launched in Washington DC to repeal international tax regulations that lobbyists say have cost Jersey and other finance centres billions of pounds. The controversial Foreign Account Tax Compliance Act, which was introduced in 2010 by President Barack Obama, requires all finance firms outside the US to… – Continue reading
German banks support stricter beneficial ownership rules for companies and trusts, while the leading Scandinavian bank backed an offshore corporate economic substance test to help comply with EU laws against money laundering and tax evasion. Testifying before the European Parliament’s Panama Papers investigative committee, the Association of German Banks told… – Continue reading
The US taxes its citizens and permanent residents on their worldwide income regardless of where they live or how long they’ve lived outside of the US. There is only one other country in the world that operates like the US – Eritrea – an African nation. According to the IRS:… – Continue reading
After India’s banknote ban, private companies are using the country’s biometric database to bring financial services to millions For two years, Indian officials have been trawling the country, from city slums to unelectrified villages, zapping eyeballs, scanning fingerprints and taking photographs. Last month, Indian shoppers started to see the results…. – Continue reading
The Government has introduced the Diverted Profits Tax Bill 2017 and the 35 page Treasury Laws Amendment (Combating Multinational Tax Avoidance) Bill 2017 into Parliament to implement the Diverted Profits Tax (DPT), as one of its first Parliamentary items of business in 2017, indicating the priority attached to this measure…. – Continue reading
The Irish tax agency has updated its guidance on the automatic exchange of information on tax rulings between EU member states. Changes have been made to the Tax and Duty Manual to set out Revenue’s arrangements for implementing Council Directive (EU) 2015/2376 and the OECD’s framework for the compulsory spontaneous… – Continue reading
‘Private Banking’ is a term that usually conjures up images of secret banking transactions being carried out on behalf Royal families, the landed gentry and wealthy individuals. That’s how private banking started, but is not a fair reflection of private banking today. Today, it’s not your family tree that matters… – Continue reading
With the arrival of the new year, don’t be surprised if your bank asks for information about yourself and your accounts that you didn’t have to provide before. These questions signal an important development as banks in Hong Kong and around the world prepare to share certain information with tax… – Continue reading
The Foreign Account Tax Compliance Act (FATCA) United States of America Implementation and Enforcement of the Inter-Governmental Agreement was passed in Parliament without opposition, making it mandatory for Antigua & Barbuda’s banks to provide the banking information of US citizens to the Internal Revenue Service (IRS). The Act requires local… – Continue reading
Swiss voters will vote next week on whether to reform corporate tax and remove the reduced tax rates that Switzerland currently grants to multinational firms. Voters will be asked whether they accept the federal law that was adopted by Switzerland’s national council in June 2016 “with a view to enhancing… – Continue reading
The Conference of State Bank Supervisors (CSBS) and state regulators have developed a self-assessment tool to help banks and financial institutions identify, monitor and communicate Bank Secrecy Act/Anti-Money Laundering (BSA/AML) risk. The BSA/AML Self-Assessment Tool is a spreadsheet intended to reduce uncertainty surrounding BSA/AML compliance and support more transparency within… – Continue reading
Italy’s government intends to use value-added tax (VAT) as the fundamental lever to fight evasion estimated at €40 billion annually, double the average of other European Union countries. The measures being studied (which will not concern an increase in VAT rates, Economy Minister Pier Carlo Padoan has assured) will also… – Continue reading
WITH THE PROPOSED transfer-pricing law now under review by the Council of State, the landscape for transfer pricing is expected to undergo a major facelift once the law is enacted. One significant change would be the requirement for taxpayers to disclose their transfer-pricing information when they file their year-end tax… – Continue reading
Business Council of Australia is urging tax cuts to remain competitive but transparency report show members’ effective rate is 24.3% The members of the Business Council of Australia, who are leading the push to cut Australia’s corporate tax rate from 30%, already pay an effective tax rate five percentage points… – Continue reading
A Republican plan to overhaul the U.S. corporate income tax could put the dozens of existing U.S. double-tax treaties in limbo. U.S. companies doing business abroad may no longer be able to rely on the mechanisms in treaties for resolving cross-border tax disputes—overlapping claims on a company’s tax—or they may… – Continue reading
Multinationals owe responsibility to a wider group than their shareholders As the Apple tax case moves towards the European Union courts, €13 billion has been transferred to Ireland. The implications of the case will effect how multi-national companies implement taxes across Europe. has been accused of “bending the rules” in… – Continue reading
In a move that will facilitate ease of business, domestic transfer pricing provisions will apply only if one of the parties to a deal is availing of tax benefits. Traditionally, transfer pricing applied to international transactions entered into by a company in India with related parties, such as its foreign… – Continue reading
The Kuwait Ministry of Finance (MOF) has issued a ministerial resolution announcing that Deloitte & Touche, Al-Wazzan & Co in Kuwait has been certified with the ministry for the provision of Foreign Account Tax Compliance (FATCA) services. FATCA is a US legislation which aims to combat tax evasion by US… – Continue reading
Individuals who will be deemed UK domicile from 6 April 2017 should be considering their options with regard to offshore trusts as a matter of priority. On 5 December 2016, the UK Government published the Reforms to the taxation of non-domiciles: further consultation outcome, which provided clarity on the following… – Continue reading
The OECD made its end-November 2016 deadline to release the text of the multilateral treaty to give effect to the BEPS Actions which involve changes to tax treaties, see here. The 49 page treaty text, which is commonly referred to as the multilateral instrument or MLI, and 85 page explanatory… – Continue reading
SMUGGLING of petroleum products has been rampant in the last couple of years. The value-added tax (VAT) and excise-tax exemptions of free-port and economic zones (FEZs) are being abused by enterprising individuals. To curtail this problem, the Bureau of Internal Revenue in 2012 required the payment of VAT and excise… – Continue reading
Among other things, Union Budget 2017 will be remembered for two firsts – the introduction of secondary adjustment and thin capitalisation rules. Both are transfer pricing provisions which will have a far-reaching impact on corporates. Secondary Adjustment Since the concept of secondary adjustment is introduced for the first time in… – Continue reading
THE scope of the withholding tax — a tax imposed on non-residents for services rendered to Malaysia-based companies — has been widened. It is one of the major tax changes that came into effect on Jan 17 under the Finance Act 2017. Under the changes, non-residents must pay withholding tax… – Continue reading
The OECD is seeking taxpayer input on the tax treaty dispute resolution process in a second tranche of countries and is seeking comments on the mutual agreement procedure (MAP) in Austria, France, Germany, Italy, Liechtenstein, Luxembourg and Sweden. Improving the tax treaty dispute resolution process is identified as a priority… – Continue reading
Main residence exemption costing budget $61.5bn, almost double the $33bn lost to super concessions The federal government’s tax breaks for home owner-occupiers are dwarfing tax breaks for superannuation. New figures show the capital gains tax concession on the family home is now worth $61.5bn, almost double the $33bn lost to… – Continue reading
The Caribbean Association of Banks (CAB) has expressed concern about the number of countries in the region which have not yet put in place inter-governmental agreements (IGAs) with the United States on the Foreign Account Tax Compliance Act (FATCA). It said it was therefore renewing the call for Caribbean countries… – Continue reading
A key outcome of the Organisation for Economic Development and Co-operation’s (OECD’s) final Report on Action Plan 13 (Transfer Pricing Documentation and Country-by-Country reporting) is the commitment of OECD and G20 countries to introduce Country-by-Country (CbC) reporting along with the associated master file and local file documentation for large Multinational… – Continue reading
CROSS-border taxation in current times is poised for significant changes. Tax is key in foreign ventures. Absent tax strategies and foreign tax leakages would erode margins and return of investment. Although international tax-efficient strategies to mitigate capital gains tax (CGT), withholding tax (WHT) and the risk of creating a taxable… – Continue reading
The Stamp Duty (Amendment) Bill 2017, which implements a further stamp duty increase to cool Hong Kong’s housing market, was gazetted on January 27, and will be introduced into the Legislative Council on February 8. The Bill includes the demand-side management measure announced on November 4, 2016. With effect from… – Continue reading
Documents for thousands of Canadian residents transferred under controversial FATCA legislation Banking records of more than 315,000 Canadian residents were turned over to the U.S. Internal Revenue Service last year under a controversial information sharing deal, CBC News has learned. That is double the number transferred in the deal’s first… – Continue reading
The Trump White House favours a “flexible” border adjustment tax targeting countries with which the United States runs big trade deficits, including Mexico, China and Germany, the President’s top trade and industry adviser said. Peter Navarro, a sceptic of free trade, wants the US to entice advanced manufacturing production onshore… – Continue reading
The programme includes measures to combat base erosion and profit shifting, based on four main measures that can challenge exploitation of tax agreements, monitor developing international tax work rules, and ensure a more transparent environment. Egypt was chosen by the Organisation for Economic Cooperation and Development (OECD), in a conference… – Continue reading
In a significant step, Mauritius will soon start automatically sharing of tax information with India and other countries as part of global efforts to curb multinational companies from profit shifting activities. The development also comes months after the island nation, long perceived to be a jurisdiction for alleged illegal fund… – Continue reading
What GAO Found In 2015, the Organization for Economic Co-Operation and Development (OECD) issued revised guidelines, including 15 actions to help reduce base erosion and profit shifting (BEPS) of multinational enterprises (MNEs). One action focuses on transfer pricing guidance with the intent of aligning MNE profits with the location of… – Continue reading
The IRS has been using a John Doe summons to get access to taxpayers’ bitcoin information and is now using the same tactic to get debit card information. According to a report by Forbes, a federal court in Montana gave the IRS permission to serve Michael Behr of Bozeman, Montana,… – Continue reading
On January 19, Greece and the United States signed an intergovernmental agreement (IGA) to facilitate compliance with the US Foreign Account Tax Compliance Act (FATCA) by financial institutions (FIs) in Greece. FATCA is intended to ensure that the US Internal Revenue Service (IRS) obtains information on financial accounts held at… – Continue reading
A European leader in financial, tax and regulatory reporting for the banking and insurance sectors, Invoke is expanding its software range to meet CRS/AEoI cross-country tax reporting requirements. As part of the global fight against tax evasion, the G20 and OECD program for the exchange of tax payers’ financial information… – Continue reading
The OECD is seeking feedback on a draft toolkit designed to assist developing countries in work on transfer pricing, which specifically addresses the ways developing countries can overcome a lack of data on ‘comparables’, or the market prices for goods and services transferred between members of multinational corporations The toolkit… – Continue reading
China’s banking regulator issued guidelines on Wednesday calling for the country’s financial institutions to strengthen their control and management of funding for outbound investment. The guidelines are the latest new rules on overseas investment as Beijing moves to clamp down on cross-border capital outflows and halt questionable investments. The China… – Continue reading
Several countries in Latin America have established new transfer pricing documentation obligations associated with the OECD’s Base Erosion and Profit Shifting (BEPS) initiative. In this new year, Mexico, Colombia and Peru have included in their local legislation new documentation requirements that follow a three-tiered approach: country-by-country (CbC) report, master file,… – Continue reading
The most important task of the Finance Minister in the 2017-18 budget is to tame the “Indirect Transfer Provisions” monster born out of amendments to Section 9 of the Income Tax Act, 1961. In response to the Supreme Court’s judgement in the famous Vodafone case, the Finance Act, 2012 amended… – Continue reading
