Regulators in Europe and the US say that the value Amazon places on the technology behind user experience varies radically depending on which appraisal will lower its tax bill. Jeff Bezos’s relentless focus on user experience has helped him make Amazon the most valuable e-commerce company in the world. But… – Continue reading
Ireland has become a destination of choice for holding companies due to its capital gains participation exemption, generous foreign tax credit system, membership of the EU, ever expanding double tax treaty (“DTT“) network (72 signed, with 70 in effect), lack of controlled foreign companies legislation, thin capitalisation rules and the… – Continue reading
On August 22, 2016, Liechtenstein filed its instrument of ratification of the Multilateral Competent Authority Agreement on country-by-country (CbC) reporting. With the move, Liechtenstein will be able to share the information contained in the CbC reports with tax treaty partners that have implemented the necessary reporting standards. Liechtenstein was among… – Continue reading
The OECD is consulting on the mechanics of dealing with branch mismatch structures under Base Erosion & Profit Shifting (BEPS) Action 2, designed to neutralise the effects of hybrid mismatch arrangements as part of the wider anti-avoidance action plan The BEPs project has already released a report on Action 2,… – Continue reading
New research shows that financial institutions are generally confident about meeting existing and incoming automatic exchange of information obligations. However, the study also found that a significant proportion of the industry is facing higher costs and risking fines by being under-prepared for new compliance requirements. The research by Aberdeen Group… – Continue reading
THE OECD/G-20 Base Erosion and Profit Shifting (BEPS) Project is designed to provide solutions for governments to close the gaps in existing international rules that allow corporate profits to “disappear” or be artificially shifted to low or no tax environments, where companies have little or no economic activity. In February… – Continue reading
The UK’s crown dependencies and overseas territories are unlikely to suffer following the Brexit vote, and may even be a model for a post-EU UK says Richard Wilson QC Even before the UK’s decision to leave the EU, offshore jurisdictions faced a number of significant challenges: increased pressure to provide… – Continue reading
THE FINANCE DEPARTMENT will keep value-added tax (VAT) exemptions for three key sectors, but may opt to remove this benefit from senior citizens and others to arrive at a “fair” tax regime. Finance Secretary Carlos G. Dominguez III told reporters late last week that the government is looking to trim… – Continue reading
The U.K. government has been consulting on a proposed “Interest Restriction” rule which will limit the amount of interest expense U.K. companies will be allowed to offset against their income for tax purposes (to 30% of their taxable earnings before interest, tax and amortization). The second consultation phase on the… – Continue reading
Twenty of the nation’s largest companies have voluntarily signed up to a comprehensive new code to disclose more details of their tax affairs in their latest ¬annual accounts following a series of scandals involving local and offshore firms. In the May budget, the federal government announced it was committed to… – Continue reading
Democrats are likely to object to the House GOP’s and Donald Trump’s plans for sharply lower rates President Ronald Reagan once chided government’s approach to the economy as following this mantra: “If it moves, tax it.” Today’s Republicans are following Mr. Reagan’s ideas by trying the exact opposite approach. The… – Continue reading
Tanzania’s president, John Magufuli, has extended the e-tax system to all government bodies as he bids to slash fraud. Tanzania’s president, John Magufuli, has been in office for less than a year, but he is already making a name for himself as a staunch opponent of fraud and corruption. Magufuli… – Continue reading
Seeking better tax compliance, Union Finance Minister Arun Jaitley on Saturday said the government can usher in lower tax regime only when more and more people pay taxes and tax evasion is down. Responding to calls for keeping the good and services tax (GST) rates in 17- 18 per cent… – Continue reading
Finance Minister Colm Imbert and US Ambassador John Estrada yesterday signed an agreement that will pave the way for the implementation of the Foreign Account Tax Compliance Act (FATCA) enacted in the United States of America in 2010. Imbert signed on behalf of T&T, while Ambassador signed on behalf of… – Continue reading
Private equity (PE) investors and venture capital (VC) funds from Mauritius will have to pay capital gains tax on investments into quasi-equity in India, under the revised tax treaty, unless the conversion of investments into equity is not finalised before 1 April 2017. The government has notified the revised double… – Continue reading
The State of Kuwait has joined the Multilateral Competent Authority Agreement for swapping taxation information according to criteria of the Development and Economic Cooperation Organization (OECD), becoming the first Arab country to ink the relevant international treaty. Kuwait Finance Undersecretary Khalifa Hamada said in a statement that he led the… – Continue reading
Assessing the Hong Kong – Russia Double Taxation Agreement: Another Step Towards Amplifying China’s Eurasian Connection The long-awaited Comprehensive Double Taxation Agreement (CDTA) between Hong Kong and Russia entered into force on July 29, 2016. The agreement will take effect on April 1, 2017 in Hong Kong and January… – Continue reading
The Pakistani tax laws don’t allow the authorities to proceed against most, if not all, of those named in the Panama Papers, the Federal Board of Revenue (FBR) sources claim. They said the limitation clauses of the income tax laws bar the tax man from going beyond the last five… – Continue reading
An IRS official said the agency is continuing its work on a mechanism to allow voluntary filings of country-by-country reports for companies required to comply with both the U.S. rules and those in a foreign country with an earlier effective date. “Actually being able to accept CBC reports for the… – Continue reading
Apple is a major part of why the United States is the world’s leading innovator on new technologies, particularly those involving telecommunications and computers. The company has over 66,000 domestic employees, and a large percentage of its customers are here — at least 40 percent, according to its latest annual… – Continue reading
Commenting on today’s government consultation paper on ‘Strengthening Tax Avoidance Sanctions and Deterrents’, John Cullinane, Tax Policy Director of the Chartered Institute of Taxation, said: “This is the latest in a series of measures cracking down on those who profit from tax avoidance schemes. The Government need to be careful… – Continue reading
PESHAWAR: The Khyber Pakhtunkhwa government is likely to issue show cause notices to owners of about 20 industrial units for not paying infrastructure development cess, according to sources. They said that provincial government had levied one per cent infrastructure development cess on imported items. “Now majority of the businessmen have… – Continue reading
On June 7, AEI hosted two panels on how the US could reform the corporate tax code, the first focusing on business-level taxation and the second focusing on shareholder-level taxation. Christopher H. Hanna of the Senate Finance Committee delivered the symposium’s opening remarks, with a major focus on how the… – Continue reading
Companies doing business in Luxembourg will be required to file global tax information now that the nation has released draft legislation to implement new international tax reporting rules. The rules—known as country-by-country reporting—would require companies to submit a global blueprint outlining the location of their operations, taxes paid, income earned,… – Continue reading
Last Wednesday August 10 at Germany’s Federal Foreign Ministry Office, Costa Rica and Germany celebrated the ratification of the establishment of legal instruments as part of an agreement to eliminate double taxation of income and assets, stated Costa Rica’s Ministry of Foreign Relations in a press release Friday. The agreement… – Continue reading
Coles has urged its German rival Aldi to sign up to a new tax transparency code that will lead to more big businesses, particularly multinationals, releasing detailed information about the tax they pay. Aldi has yet to sign up to the Voluntary Tax Transparency Code, which targets more than 1500… – Continue reading
The U.S. has used judicial might to successfully pursue offshore tax cheats all over the world. A little-noticed new rule introduced by Barack Obama’s administration gets tough on U.S. states such as Delaware and Nevada, which are notorious for murky shelters often used for illicit purposes. But there is a… – Continue reading
Through Notification No. 68/2016, the Government of India has ratified a Protocol to its tax treaty with Mauritius. The protocol was signed on May 10, 2016, in Mauritius, in a bid to limit abuse of the India-Mauritius double tax avoidance agreement. The protocol provides India with the right to tax… – Continue reading
Indonesia has defined two islands near Singapore as its own tax havens to prevent taxpayers from keeping their assets offshore – in Singapore, for example. The two islands identified by Indonesia are Bintan and Rempang, according to a report on Monday in the Singaporean daily «Straits Times» and a story… – Continue reading
SCOTLAND has formally called on the UK to close a legal loophole that allows Scottish firms to be used as secret offshore tax shelters. Holyrood politicians have been demanding action on Scotland’s limited partnerships (SLPs) ever since some of the unique corporate arrangements were exposed as Eastern European money-laundering vehicles… – Continue reading
Four months since the so-called “Panama Papers” made global headlines, Panama continues a path of reform aimed at improving financial transparency and closing loopholes exploited by foreign tax cheats. Among our steps, we established an independent committee to examine Panama’s laws and regulations and make recommendations for strengthening them. While… – Continue reading
Greece intends to sign agreements with Bulgaria and Cyprus which will allow Athens to look into suspected tax evasion by Greek-owned companies registered in the two countries, Greek newspaper Kathimerini has reported. The closer inspection of Greek-owned companies registered in Bulgaria and Cyprus will aim to find out whether they… – Continue reading
Apple CEO Tim Cook struck back at critics of the iPhone maker’s strategy to avoid paying U.S. taxes, telling The Washington Post in a wide ranging interview that the company would not bring that money back from abroad unless there was a “fair rate.” Along with other multinational companies, the… – Continue reading
The Federal Government on Wednesday inaugurated an eight-man committee tor review and update the National Tax Policy document. The Minister of Finance, Kemi Adeosun, while inaugurating the committee in Abuja, said the government was committed to the continuous improvement of Nigeria’s tax system as part of the dynamic framework to… – Continue reading
“Maybe lower the income tax from 25 percent to 20 percent first, then 17 percent.” The government will once again provide the public with tax break following its tax amnesty program. It is currently reviewing a plan to lower income tax rates and the possibility of establishing a tax haven,… – Continue reading
In May 2016, the Cambodian and Singaporean government authorities signed a new agreement to avoid double taxation with respect to taxes on income and on capital. What are the objectives and benefits of a double taxation avoidance (DTA) agreement? The “big-picture” objectives of the DTA between Singapore and Cambodia are… – Continue reading
Salford Council has joined the other 14 councils from across the UK that have adopted motions to support ethical procurement. Moved by Labour and Co-operative councillor Jim King, the recent motion strengthens checks in the council’s procurement to exclude businesses that engage in tax avoidance. The initiative falls in line… – Continue reading
The Australian Taxation Office (ATO) has issued a series of taxpayer alerts that caution large companies against using contrived arrangements to avoid their tax obligations. The first alert concerns arrangements where Australian consolidated groups use offshore permanent establishments that have entered into intra-group transactions. Deputy Commissioner Jeremy Hirschhorn explained: “Through… – Continue reading
Budget 2016 introduced a new tax called Equalisation Levy (“EL”), aimed at taxing online transactions. EL was originally mooted by the OECD in Base Erosion and Profit Shifting (BEPS) Project Final Report on Action 1 – Addressing the Tax Challenges of the Digital Economy (the “Report”). We will examine Equalisation… – Continue reading
AN Intergovernmental Agreement (IGA) between Barbados and the United States will allow for greater co-operation under the Foreign Account Tax Compliance Act (FATCA). This is according to Julia Tonkovich, of the United States Treasury Department. Ms. Tonkovich stated that FATCA, which was in place since 2010, is part of the… – Continue reading
The implementation of the goods and services tax (GST) will reduce tax evasion and improve ease of doing business by engendering a common market throughout the country, finance minister Arun Jaitley said on Monday, as he moved the modified constitution amendment bill in the Lok Sabha. “GST will ensure one… – Continue reading
Despite Western opposition, the 134-member Group of 77 is continuing to pursue a longstanding proposal for an inter-governmental UN-affiliated tax body aimed at combating corporate tax dodging and curbing illicit financial flows, including money laundering and off-shore banking. The proposal has already been shot down twice by Western nations, first,… – Continue reading
The Section of Taxation of the American Bar Association (ABA) has written to the US Internal Revenue Service (IRS) saying that there is a pressing need for guidance from tax authorities due to the rapid growth of the cloud industry. The ABA noted that, although the Organisation for Economic Co-operation… – Continue reading
There is little that can be done about FATCA and the change has to come from within the U.S. Death and taxes, life’s two certainties according to Keynes, sometimes have a causal relationship. One dies and some taxes are often associated with that event. Alternatively, one encounters so much regulation… – Continue reading
The National Tax Service (NTS) Seoul Regional Office has been probing into a Korean processed food maker Paldo Company Ltd. since June on possible overseas tax evasion. According to the NTS Sunday, it has deployed international transaction investigators to investigate whether the instant food maker manipulated its transfer price to… – Continue reading
The Trinidad & Tobago government says it has prepared legislation aimed at compliance with the United States Foreign Account Tax Compliance Act (FATCA). FATCA is a 2010 federal law to enforce the requirement for United States national including those living outside the US, to file yearly reports on their non-US… – Continue reading
Countries pursuing billions in unpaid taxes push region’s wealthy to pull cash from accounts LONDON — Switzerland’s private bankers fear cash-strapped Latin American countries pursuing billions of dollars in unpaid taxes will push the region’s wealthy to pull cash from their Swiss bank accounts. For these banks, still recovering from… – Continue reading
Authorities in Greece have doubled their efforts to catch tax evaders over the last year. The Greek Finance Ministry’s General Secretariat for Public Revenue has issued an official statement asking citizens to help combat tax evasion by exercising their right not to pay for goods and services if they are… – Continue reading
Mauritius is looking to revive efforts to put in place a comprehensive economic cooperation pact with India, close on the heels of sorting out long-pending issues related to the bilateral tax treaty. The island nation, a major source of foreign direct investments coming into India, is also eyeing a preferential… – Continue reading
The intergovernmental agreement (IGA) between Curacao, a low-tax Caribbean territory, and the United States implementing the US Foreign Account Tax Compliance Act (FATCA) is now in force. FATCA, enacted by the US Congress in 2010, is intended to ensure that the US obtains information on accounts held abroad at foreign… – Continue reading
