Federal authorities demanded secrecy in no-penalty, no-prosecution deal to high net worth Canadians The Canada Revenue Agency offered amnesty to multi-millionaire clients caught using what’s been called an offshore tax “sham” on the Isle of Man — a reprieve that was supposed to remain secret and out of the public… – Continue reading
Fenergo offers Nikko Securities America, Inc. end-to-end Client Lifecycle Management with a regulatory focus on AML, KYC and FATCA Fenergo, the leading provider of Regulatory Onboarding and Client Lifecycle Management software solutions for investment, corporate and private banks, has announced a new deal to provide Nikko Securities America, Inc. with… – Continue reading
It is now time for Australian financial institutions to move on CRS. Australian implementing legislation has been finalised. You need to be prepared by 1 July 2017. The scope of CRS and applicable penalties have been expanded The next FATCA reporting deadline is 31 July 2016. The uncertainty around listed… – Continue reading
With American corporations keeping a record amount of profits offshore to avoid paying U.S. taxes, U.S. Sen. Sherrod Brown (D-OH) will introduce legislation requiring corporations to “Pay What You Owe Before You Go.” During a news conference call today, Brown will outline his bill that would require corporations to settle… – Continue reading
Following the release of the anti-tax-avoidance (ATA) package on January 28, 2016 by the European Commission, the Dutch Presidency of the Council of the European Union presented an EU-Base Erosion and Profit Shifting (BEPS) Roadmap (the Roadmap) to the Members of the High Level Working Party on Tax issues. The… – Continue reading
The International Chamber of Commerce (ICC) has expressed deep approval for the Organization for Economic Cooperation and Development’s (OECD) plan to allow all countries to participate in its Base Erosion and Profit Shifting (BEPS) plan. BEPS is an international policy proposal designed to counteract the negative effects of multinational companies’… – Continue reading
A move to check arbitrary decisions by the tax authorities may result in a huge fine for minor transgressions or mistakes while reporting tax, experts fear. In this year’s budget fine-print, the finance ministry has inserted a “new Section 270A (which) provides for levy of penalty in cases of under-reporting… – Continue reading
Debt planning and restructuring is a common mechanism to minimize taxable income by increasing deductions among different entities in a multinational group of companies. As interest on debt is generally a deductible expense of the payor and taxed in the hands of the payee, groups may create intercompany loans to… – Continue reading
Governments around the world want more tax income. There is a widely held feeling that many international companies are basing themselves in places like Luxembourg, Ireland, and the Netherlands to avoid tax. The world’s largest countries have a plan and things will change. What will be the effect on Luxembourg,… – Continue reading
NEWARK, NEW JERSEY (BLOOMBERG) – The US Internal Revenue Service (IRS) sought to make UBS Group turn over records on an account in Singapore held by a US citizen, setting up a showdown with the city-state over its bank-secrecy laws and potentially opening a new front against offshore tax evasion… – Continue reading
Even employees earning below Rs 15,000 a month will be impacted if the Centre sticks to the plan of taxing 60% of EPF withdrawals The Budget has proposed significant changes on taxation of Employees’ Provident Fund (EPF). Given that EPF is at the core of the Indian social security system… – Continue reading
Retrospective amendments to domestic laws cannot override international treaties In a judgment that will have a far-reaching impact on double taxation issues, the Delhi High Court has held that Parliament cannot change the terms of an international treaty by bringing in amendments in the domestic law, and any such executive… – Continue reading
Thailand and the United States signed an historic tax agreement today to promote tax transparency between the two nations. The Foreign Account Tax Compliance Act (FATCA), enacted in 2010, aims to combat offshore tax evasion and improve transparency on accounts held by US taxpayers in foreign countries. Under the agreement… – Continue reading
While equalisation levy appears to be a step to counter double non taxation and protect India’s share of taxation, in its current form it may impact an Indian taxpayer more than foreign MNCs The growth of digital economy entails many benefits, but also poses various tax challenges. These include the… – Continue reading
Facebook has caved to the tax pressure. The company is likely to pay millions more in U.K. taxes after making changes to its corporate structure that will stop revenue earned in the U.K. from being routed through Ireland. Facebook had been accused of “profit shifting,” a common practice for multinational… – Continue reading
The US government, in an effort to reduce offshore tax evasion, has taken extraordinary steps to implement FATCA, the Foreign Account Tax Compliance Act. This includes the hiring and training of over 3,000 IRS examiners newly tasked with process verification and tax audit efforts. The implications for US businesses can… – Continue reading
The European Commission has concluded that selective tax advantages granted by Belgium under its ‘excess profit’ tax scheme are illegal under EU state aid rules. The European Commission is looking at Member States to assess compliance with EU state aid rules in the context of aggressive tax planning by multinationals,… – Continue reading
In its departmental plan for 2015-2020 published last month, HMRC set out it’s role “to help the honest majority to get their tax right and make it hard for the dishonest minority to cheat the system”. One of the headline objectives for this period is: “maximise revenues due and bear… – Continue reading
Twenty Caribbean and Latin American nations have been named by the U.S. as “major money laundering” countries in the 2016 International Narcotics Control Strategy Report (INCSR) from the U.S. State Department released Wednesday, Mar. 2, 2016. A major money laundering is defined by statute as one “whose financial institutions engage… – Continue reading
MUMBAI: Centrum Wealth expects a flurry of dividends from corporates in the month of March. This is post the the government announcing an additional 10% tax for those earning an annual dividend income of more than Rs 10 lakh. Dividend income received by investors was already taxed through Dividend Distribution Tax…. – Continue reading
Switzerland and the US have agreed a new Foreign Account Tax Compliance Act (FATCA) exemption clause for accounts held by lawyers or notaries. Under the clause, inserted into the Swiss-US FATCA Agreement, accounts maintained for specific purposes by lawyers or notaries for their clients (i.e. accounts held in connection with… – Continue reading
NEW DELHI: Terming the financial information exchange pact FATCA between India and USA as an ‘inequitable system’, the Finance Ministry today said it has received written commitment from the US that they will move towards full reciprocity. “We should look at FATCA as very a special case. It’s a law… – Continue reading
BJP MPs are upset over the Budget proposal to tax EPF corpus at the time of withdrawal, a move they fear will antagonise the party’s core support base of the middle class. A day after he made the announcement, Finance Minister Arun Jaitley explained to party parliamentarians and allies that… – Continue reading
The South African Revenue Service (SARS) has issued final regulations that require certain financial institutions (FIs) to report on accounts held or controlled by foreign residents from March 1, 2016. The OECD’s automatic tax information exchange standard, the Common Reporting Standard (CRS), which the regulations are in response to, obliges… – Continue reading
The International Chamber of Commerce (ICC) welcomes the Organisation for Economic Co-operation and Development’s (OECD) plan to allow all countries to participate on an equal footing with OECD and G20 countries in the implementation of the OECD/G20 Base Erosion Profit Shifting (BEPS) plan. The framework announced by the OECD early… – Continue reading
Another form of taxation that has gotten greater attention during the last two presidential election campaigns is the flat tax. A flat tax is a plan that will apply the same rate to every taxpayer, regardless of the income they have earned. At present, federal taxes are calculated on a… – Continue reading
Before conducting business outside of the U.S. for the first time, a company must establish the business case for doing so. That means looking beyond just the profit potential on the product or service to the other costs that can be involved, of which there are many. “The culture of… – Continue reading
The US Internal Revenue Service (IRS) has updated Publication 515, Withholding of Tax on Nonresident Aliens and Foreign Entities, which covers the obligations of the persons responsible for withholding tax (withholding agents). It is specified that the Publication is for withholding agents who pay income to foreign persons, including nonresident… – Continue reading
Outstanding issues relating to the existing Double Taxation Avoidance Agreement (DTAA) are under negotiation between India and Mauritius through the mechanism of Joint Working Group (JWG), Parliament was informed today. “India has proposed changes in the existing DTAA to address concerns relating to treaty abuse, around tripping of funds, double… – Continue reading
Pakistan and Czech Republic have implemented a convention to avoid double taxation and prevent tax evasion, the Federal Board of Revenue notified on Monday. An official said the convention on avoidance of double taxation will come into force on July 1. “This is an epoch-making event in the consolidation of… – Continue reading
With the adoption of the BEPS package, OECD and G20 countries laid the foundations of a modern international tax framework under which profits would be taxed where economic activity and value creation occurs. It is now time to focus on implementation of the recommended changes in a consistent and coherent… – Continue reading
If you have made any investment in a fixed deposit or a mutual fund or even in shares, by now, you must have received a form in the mail requiring you to comply with FATCA regulations. What is this new compliance requirement exactly and what does it mean so far… – Continue reading
The pet project of Prime Minister Narendra Modi – the International Financial Services Centre (IFSC) – housed in the Gujarat International Finance Tec City – has received a boost in the Union Budget 2016/17. The long pending tax issue has been decided with 9 per cent minimum alternate tax (MAT),… – Continue reading
In Shanghai, Wolfgang Schäuble is urging his fellow G20 countries to put new rules to tackle tax avoidance into law. Back home, business leaders worry that German companies could be left exposed by the new rules if they are introduced unilaterally or go too far. The finance ministers of the… – Continue reading
A general anti-avoidance rule will most likely return to the Polish tax system in 2016. At the end of 2015 the Ministry of Finance published a draft of changes to the Tax Ordinance which would introduce a general anti-avoidance rule (GAAR) into the Polish tax system, to prevent creation and… – Continue reading
1. New double tax treaty between Germany and the Netherlands: tax authorities now bear burden of proof regarding tax- evading or tax-avoiding arrangements A new Double Tax Treaty (DTT) has been in place between Germany and the Netherlands since 01 January 2016. Art. 23 of the DTT introduces an important… – Continue reading
If a member of Congress told you that he was going to use some of your hard-earned tax dollars to support an international organization that demands that you pay higher taxes, what would you say? Unfortunately, the question is not hypothetical, because that is exactly what is now happening. Congress… – Continue reading
The federal government of Nigeria and Qatar have signed an agreement for the avoidance of double taxation on income and capital gains for investments between the two countries. In addition to the elimination of double taxation on business income, similar treaties between Nigeria and other countries provide for a lower… – Continue reading
That the collection of the taxes levied on citizens becomes an exceedingly difficult task in the absence of a moral sense of tax responsibility on the part of the taxpayers is well known. The readiness to tolerate taxes is reinforced or undermined by two primary factors: The sense taxpayers have… – Continue reading
Budget 2016 should rationalise entertainment tax, exempt newsprint from VAT and end double taxation on temporary transfer of movie rights to television channels, experts said. “Currently, entertainment industry players such as DTH and cable service operators are reeling under the heavy burden of multiple taxation and levies such as licence… – Continue reading
A “controlled foreign company” (CFC) is, as the name implies, a foreign company or subsidiary owned by a parent company which is situated in a country different from the parent company’s country of residence. The tax laws of many countries, including the Philippines, do not tax the CFC’s parent company… – Continue reading
France is seeking €1.6 billion in back taxes from Google, criticised for its use of aggressive tax optimisation techniques, a source at the finance ministry has said. “As far as our country is concerned, back taxes concerning this company amount to €1.6bn,” the official, who spoke on condition of anonymity,… – Continue reading
THE withdrawal of a withholding tax on service payments to foreigners, decried by many as unworkable, has been widely welcomed. The Treasury acknowledged that the tax had introduced “unforeseen issues, uncertainty on the application of domestic law and taxing rights under tax treaties”. The withholding tax was introduced into legislation… – Continue reading
Tax function of an organisation was traditionally run from the tax director’s room. Transfer Pricing (TP) was governed by contracts between related parties and this at times resulted in profits moving to legal entities that had contractual rights but had no significant people functions. There were instances of IP Holding… – Continue reading
Its official name is the global standard for automatic exchange of financial account information – these nine words are a simple distillation of an ambitious project to tackle global tax evasion. Known more regularly as the Common Reporting Standard (CRS), it will see government-to-government sharing of account holder information and… – Continue reading
“It is tantamount to an economic blockade”. That’s how Antigua and Barbuda’s Prime Minister, Gaston Browne, described the current withdrawal from Caribbean indigenous and offshore banks of correspondent relationships by US banks. His sentiments were echoed by Dean Barrow and Freundel Stuart, the prime ministers of Belize and Barbados respectively…. – Continue reading
A new report from ActionAid titled ‘Mistreated’ released this week has revealed that Zambia has 13 restrictive tax treaties that dramatically restrict the government’s power to tax global companies doing business on our soil and therefore unfairly limit our country’s potential to collect tax revenue. The report also found that… – Continue reading
The Rwanda Revenue Authority (RRA) has warned tax consultants who mislead or encourage clients to evade taxes, saying they will be apprehended and punished according to the law. The tax body said there are some consultants encouraging taxpayers to under declare their returns, manipulate systems, or even default altogether. Richard… – Continue reading
“We are clear. We will not stand for a minority of taxpayers continuing to seek out unacceptable ways to reduce the amount of tax they pay, and we will ensure HMRC has the tools to robustly tackle such activity.” So said David Gauke, Exchequer Secretary to the Treasury. A clampdown… – Continue reading
The OECD’s base erosion and profit shifting (BEPS) project – which is aimed at closing gaps and mismatches in tax laws that conspire to reduce corporate tax liability – is a game-changer for treasury planning. The final reports of the BEPS Action Plan, announced by the Organization for Economic Cooperation… – Continue reading
