Not only is Dec. 31 the deadline for any last-minute, year-end tax planning you may be contemplating, but it may also be the last day to come clean to the tax man if you still have an undisclosed Swiss bank account. If that’s you, consider getting your act together and… – Continue reading
Where it happens does not matter. Portugal or overseas, whether its rental income, bank interest, bond yields, dividends, or even gains from the sale of a property, such personal financial information will be automatically shared from 1st January 2016. For many who have undergone financial planning, or have been involved… – Continue reading
Tax disputes are to no longer form a part of a Bilateral Investment Treaty (BIT) signed by the government with another country, the Union Cabinet decided on Wednesday, clearing a revised model text The idea is that foreign companies finding themselves in a tax row with the government will not… – Continue reading
Where it happens does not matter. Portugal or overseas, whether its rental income, bank interest, bond yields, dividends, or even gains from the sale of a property, such personal financial information will be automatically shared from 1st January 2016. For many who have undergone financial planning, or have been involved… – Continue reading
On December 8, there was a brief note in the media about the fact that Malta had managed to include a reference to flexibility into a European Council communiqué on taxation. You would be forgiven for overlooking it, assuming it was just a pedantic attempt to score political points. Think… – Continue reading
Why raise the limit for quoting PAN in cash deals? Though the government’s one-time black money compliance window for money stashed overseas garnered a mere Rs 3,770 crore, getting rid of black money remains a focus area. While it is understandable that industry’s protests over the General Anti-Avoidance Rules (GAAR)… – Continue reading
According to a research report titled “Illegal Financial Flows from Developing Countries: 2004-2013”, recently published by the Washington based research institute Global Financial Integrity (GFI), Bangladesh stands 26th in the list of 149 developing nations, in terms of flight of capital including money laundering (The Daily Star, December 10, 2015)…. – Continue reading
Initiated by the Organisation for Economic Cooperation and Development in 2013 and endorsed by the G-20, the OECD’s “Action Plan to Address Base Erosion and Profit Shifting (BEPS)” includes 15 key areas to encourage more transparency, better reporting and more cooperation between countries in which multinational companies operate. On October… – Continue reading
IP regime To comply with the OECD’s BEPS reports and more specifically its action plan n° 5 regarding harmful tax practices, the Luxembourg intellectual property (“IP“) regime under article 50bis of the Luxembourg income tax law (“ITL“) will be repealed as from 1 July 2016. As such, the Luxembourg 80%… – Continue reading
China has become the 77th party to an OECD agreement enabling the automatic annual exchange of tax-related information. The country signed up to the Multilateral Competent Authority Agreement (MCAA) yesterday, which specifies which information will be exchanged and when, and renewed a co-operation agreement between the OECD and the Chinese… – Continue reading
In the wake of the final OECD BEPS reports issued in October, the European Council adopted amendments to Directive 2011/16/EU providing for the automatic exchange of information concerning advance cross border rulings (ACBR) and advance pricing arrangements (APA) between Member States. The amendments, which will come into force from 1… – Continue reading
It has been a tough year for Russian businesses. The latest monthly forecast of the Economist Intelligence Unit (EIU) predicts a contraction in Russian real GDP of 3.8% in 2015 and another 0.5% in 2016. “Structural weaknesses will keep trend GDP growth below 2% a year in the medium term,”… – Continue reading
ISLAMABAD: The World Bank says tax regulations in Pakistan are frequently altered, and unpredictable tax rules worsen the business climate and may deter potential investment. The report “Towards a more friendly tax regime: Key challenges in South Asia,” points out that South Asia’s tax regulations are complex and difficult to… – Continue reading
The yuan rebounded from early losses in Hong Kong’s offshore market, spurring speculation Chinese policymakers are propping up the currency after its discount to the onshore spot rate doubled. The yuan was trading 0.13 percent stronger at US$6.5227 as of 11:45am in Hong Kong, after sliding as much as 0.19… – Continue reading
As the UK government continues its quest to grab upwards of £500 million in overdue taxes on undeclared overseas bank accounts, the subjects of tax avoidance and tax planning are in the headlines. While many people may be slightly confused as to the difference between tax avoidance and tax planning… – Continue reading
Fifty-three jurisdictions have agreed to automatic exchange of tax information beginning in 2017, under the OECD’s Common Reporting Standard. Over 40 others have committed to exchange information by 2018. Another wave of global tax information is about to take place, and financial institutions everywhere are in a race to prepare… – Continue reading
In the context of a series of recent developments on the tax treatment of cross border services payments from Brazil, the Superior Court of Justice (STJ) recently ruled that payments for services performed by a Spanish company without permanent establishment in Brazil are not subject to withholding income tax in… – Continue reading
Given that the latest treaty was signed on 15 November 1967, the two countries felt it was appropriate to revise it in full. The new treaty, signed on Tuesday by the Spanish Ambassador to Finland, María Jesús Figa, and the Finnish Minister for Finance, Alexander Stubb, seeks to enable tax… – Continue reading
On 7 December 2015 the Cayman Islands Tax Information Authority (the “TIA”) published a list of 95 participating jurisdictions (see Schedule below) pursuant to The Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations, 2015 (the “Regulations”) and the Cayman Islands FATCA/CRS Working Group (the “Working Group”) distributed self-certification… – Continue reading
Over 90 jurisdictions have committed to the OECD’s Common Reporting Standard (CRS), creating comprehensive global automatic information exchange for financial assets and the entities through which such assets may be held. Over 70 jurisdictions have signed the OECD’s Multilateral Competent Authority Agreement, which implements the CRS. The CRS is scheduled… – Continue reading
Draft 2015 Instructions for Form 8966. IRS has published a draft version of the instructions to the 2015 Form 8966 (FATCA Report), which certain foreign financial institutions (FFIs) and others use to report information with respect to U.S. accounts under the Foreign Account Tax Compliance Act (FATCA). The instructions reflect… – Continue reading
16/12/2015 – Today the People’s Republic of China became the 77th jurisdiction to sign the Multilateral Competent Authority Agreement (MCAA), which allows it to move forward with plans to activate automatic exchange of financial account information in tax matters and commence exchanges with other countries in 2018. The G20 Leaders… – Continue reading
The common reporting standard framework was first released by the Organisation for Economic Co-operation and Development (the “OECD”) in February 2014 as a result of significant political will demonstrated by the G20 members to endorse a global model of automatic exchange of information and increase international tax transparency. On 21… – Continue reading
AKARTA, KOMPAS.com – Deputy for International Economic Cooperation CMEA Rizal Afandi Lukman suspect there Base Erotion and Profit Shifting (BEPS) among multinational companies. The reason, he saw the discrepancies between the income tax with revenues of GDP. “During this time the tax ratio we always low, even up to 12… – Continue reading
Summary In the March 2015 Budget the Chancellor announced tough new sanctions for tax evasion, intended to have a deterrent effect. After a period of consultation, the intention to proceed with these measures was confirmed in the 2015 Autumn Statement. In summary, the measures to be implemented are: A new… – Continue reading
RIGA – The Latvian Financial and Capital Markets Commission (FCMC) on Dec. 11 imposed a record 2-million-euro fine on Ukrainian-owned A/S Privatbank and ordered the dismissal of its CEO and managing board for violations of money laundering and other banking regulatory laws in connection with the alleged plundering and collapse… – Continue reading
On the 29th of September of this year, one of the most important and controversial norms of the tax reform: the general anti-avoidance rule came into effect. This norm intends to cutback aggressive tax planning providing new faculties to the Chilean IRS. Indeed, this norm has incorporated what is widely… – Continue reading
Mexico has recently gazetted new transfer pricing documentation requirements, which will be effective from the 2016 tax year. The legislation was submitted to Congress by the Government on September 8, 2015, and published in the Official Gazette at the end of November. It will introduce the country-by-country (CbC) reporting framework… – Continue reading
The European Commission has extended its investigation into a tax ruling provided by the Irish Government to Apple. The Commission has asked the Irish authorities for additional information on the case. Irish media reports that the Government does not anticipate a decision until 2016. In late November, Finance Minister Michael… – Continue reading
A review of the application of EU State Aid rules is crucial for determining if a national tax incentive scheme for IPs is being implemented lawfully. The result of such a compatibility analysis is not certain. In some decisions, the Commission considered ‘Tax Box’ regimes as not being State aid… – Continue reading
Re-launching the Common Consolidated Corporate Tax Basis (CCCTB) Corporate taxation in the EU needs to be fundamentally reformed. Today’s corporate tax systems in EU Member States were conceived in the 1930s, when cross-border trade was more limited, business models were simpler and products were tangible. But as business evolves, so… – Continue reading
Action on tax avoidance could see €600m go from the pharma sector, says report International moves on multinational tax could threaten Ireland, with a potential annual loss of corporate tax revenue of €600 million or more from the pharma sector alone, according to a new report from Chartered Accountants Ireland…. – Continue reading
India and Korea on December 9 agreed to suspend collection of taxes during the pendency of Mutual Agreement Procedure (MAP). This MoU will relieve the burden of double taxation for the taxpayer in both the countries. Two days later, India and Japan signed a protocol for amending the existing convention,… – Continue reading
WHETHER he is being straitjacketed by the International Monetary Fund (IMF) or it’s a case of his own ignorance of how economies work, Dr Peter Phillips is recklessly betraying the cause of Jamaican businesses. The finance minister, with the tacit support of the Cabinet – and his self-serving cabal –… – Continue reading
On 22 December 2014, the Italian Parliament approved the Budget for 2015.40 Among other measures, the Law introduces the possibility of an exemption from corporate income tax (IRES, generally levied at 27,5%) and local tax (IRAP, generally levied at 3,9%) on income derived from qualifying intangible assets (such as patents,… – Continue reading
Nokain Tyres is appealing a tax adjustment for 2007-2010 that requires the tiremaker to pay an extra 87 million euros. The adjustment includes an additional 55 million euros in additional taxes and 32 million in punitive taxes that must be paid by January 2016, Tyres and Accessories reported. Nokian described… – Continue reading
(MENAFN – Qatar News Agency) The Ministry of Finance attain several achievements during the past year, most notably the issuance of Law No. 2 of 2015 on the financial system of the State, which included provisions for preparing and implementing the general budget and the final account of the State…. – Continue reading
A vote taken in the European Parliament could effectively rob Malta of its ability to attract multinational companies and their millions of Euros in taxation revenue. A vast majority of MEPs, spanning across all political groups showed their support for a resolution, prepared in Parliament’s Economic and Monetary Affairs Committee…. – Continue reading
Provide high-net-worth individuals with (further) incentives to relocate to Cyprus. This is one of the objectives of the introduction of the non-domicile rules (voted on the 9th of July 2015, among other tax reforms) that came into force on the 17th of July 2015 (date of the publication in the… – Continue reading
The $160bn (€146.5bn) merger of US pharmaceutical giant Pfizer with Dublin-based Allergan is an “opportunity” for Ireland, according to IDA chief executive Martin Shanahan. Last month Pfizer, the world’s largest pharmaceutical company, announced plans to merge with Botox manufacturer Allergan in a deal that will create the world’s biggest drug… – Continue reading
Latvian President Raimonds Vejonis on December 15th accepted the credentials of the Japanese Ambassador to Latvia, Mariko Fujii, and noted an increase in Latvia-Japan trade recently but said there was still room for growth in economic cooperation, the Latvian president’s press service reported LETA. He said that a treaty for… – Continue reading
Tax payers are more concerned about the invasion of their privacy rather than an investigation into their tax affairs Tax payers have just over a fortnight left to voluntarily utilise the favourable terms of the Lichtenstein Disclosure Facility (LDF) before it is closed on 31 December 2015. It will be… – Continue reading
The tax commission of the ruling coalition (the Liberal Democratic Party and New Komeito) on 10 December 2015 reached an agreement for a draft outline of tax reform proposals for 2016. Among the items in the draft outline are proposals for transfer pricing documentation rules based on Action 13 (Transfer… – Continue reading
An article in today’s edition of Sri Lanka’s Mirror newspaper draws attention to that island’s plans to develop an offshore financial centre in Colombo. According to the article the proposal is modelled on the Dubai International Financial Centre, a notorious centre for moneylaundering and illicit financial flows. Now this doesn’t… – Continue reading
On 10 December 2015, the Belgian Parliament voted – in plenary session – the bill “on the communication of information relating to financial accounts, by Belgian financial institutions and the Federal Public Authority of Finance, within the framework of an automatic exchange of information at international level for tax purposes”…. – Continue reading
Journal: The EU’s ongoing investigation into Luxembourg’s tax agreements with multinational corporations is threatening to leave a black mark on the Grand Duchy at the end of its six-month European presidency. Luxembourg’s finance ministry could face legal action from the European Commission, as the EU authority continues its probe into… – Continue reading
For the Socialist Senator Roberto Zanetti, the reform is an open-heart surgery, which must be done with great accuracy. Under pressure from the EU, G20 and the OECD, also Switzerland is obliged to give up his special tax regimes for holding companies and management companies. After years of negotiations with… – Continue reading
The Belgian Minister of Finance has just shared new insights on how Belgium will be addressing the outcome of the OECD/G20 project in relation to Base Erosion and Profit Shifting (“BEPS”). He opted to do so via the “Plan to combat tax fraud”. The title of his policy note is… – Continue reading
Provisions under new article 76A of Mexico’s tax law reflect certain items of the OECD’s base erosion and profit shifting (BEPS) project—in particular expanded transfer pricing disclosure requirements that will apply for the 2016 tax year. Background The Mexican government’s 2016 federal budget, presented 8 September 2015, included proposals for… – Continue reading
There are a number of ways to structure your offshore fund and the best option for you will depend largely on the location of the manager, your investor base and the type of investments that the fund will make. I have set out a summary of the three most common… – Continue reading
