Companies operating cross border through presence of Branch offices, Liaison and representative offices, appointed distributors and agents should closely watch the changes coming through in international tax norms. OECD and G20 countries adopted a 15 point action plan to address Base Erosion and Profit Shifting (BEPS) and Action Point 7… – Continue reading
The Queen’s jeweller has not paid corporation tax in five years, it is claimed, despite reported profits of £66million Demands are growing for a review of the royal warrant system after firms supplying the monarchy were criticised for moving profits overseas. The crest is a mark of British craftsmanship and… – Continue reading
Outgoing Deloitte Malta chairman and senior partner Andrew Manduca speaks to Anthony Manduca about the future of the financial services sector in Malta, his 36 years in the profession and the need for more accountants. Andrew Manduca is very confident about the future of Malta as a leading international financial… – Continue reading
On 5 October 2015 the OECD published its final package of 15 action plans designed to prevent tax base erosion and profit shifting. One of the actions, which could become relevant to Ukrainian companies in the near future, is changes to the permanent establishment (further — “PE”) concept. Why the… – Continue reading
The Central Board of Direct Taxes (CBDT) has recently entered into eleven (11) more Advance Pricing Agreements (APAs) with Indian subsidiaries for foreign companies. In a major push towards providing certainty to foreign investors in the arena of transfer pricing, the CBDT signed these APAs operating in various segments of… – Continue reading
Cash doesn’t flow directly from buyers’ pockets to Microsoft’s headquarters in Redmond, Wash. Instead, the company operates through three regional sales units, centered in Ireland, Singapore and Puerto Rico. These groups control the rights to profit from Microsoft products around the world. By conducting sales from places with small populations… – Continue reading
The asset servicing industry is likely to see a growth spurt driven by globalisation and regulatory change, according to an Ernst & Young (EY) report, reports the Asset Servicing Times. The report outlined six key drivers of growth: asset growth and breadth; globalisation; regulation; new products; platform extension and consolidation;… – Continue reading
As an NRI returning to India, you can retain all your overseas assets including properties, market investments, stocks etc, provided you acquired them when you were residing outside India With India becoming a hotbed of financial activity and economic growth, many non-resident Indians (NRI) are now migrating back to India…. – Continue reading
Temporary lapses of judgment can be corrected. Permanent mistakes are harder to fix. Congress is poised to offer very costly permanent tax giveaways to powerful corporations. It is also considering renewing more modest tax credits that encourage work and support millions of low-wage workers and their children. This is an… – Continue reading
After the LuxLeaks affair in November 2014, the European Parliament established a special committee “on tax rulings and other measures similar in nature or effect” (TAXE) in February 2015. The committee’s report was adopted in a plenary session of the European Parliament on 25 November 2015. The Conference of Presidents… – Continue reading
A review of Nigeria’s present fiscal and currency control regimes as they relate to commercial and industrial IP rights become imperative in order to give impetus to government’s efforts towards reviving and diversifying the country … Prior to the introduction of the Income Tax (Transfer pricing) Regulations on 2 August,… – Continue reading
Under Action 8 of the BEPS project (Base Erosion and Profit Shifting) – Aligning Transfer Pricing Outcomes with Value Creation – work was carried out which resulted in certain changes to the OECD guidelines on transfer pricing (Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations), with special emphasis on… – Continue reading
The Foreign Account Compliance Act (FACTA), while designed to “minimize tax cheats”, is making banking — and life in general — painfully difficult for millions of American expats, according to Mike Michelini, a Hong Kong-based business consultant withglobalfromasia.com. Here is his editorial. Under FACTA, all 8 million or so Americans… – Continue reading
Karl Samuda, a member of the parliamentary opposition, says he is against legislation that would “prevent a company from using its creativity to maximise its profit position”. The North Central St Andrew MP, who speaks on industry for the opposition, said that it is a bad thing to put in… – Continue reading
Data from the Canada Revenue Agency (“CRA”) confirms that voluntary disclosures (“VDs”) of offshore assets, gains and income hit record levels in 2015. This proliferation of VDs is attributable to various factors, including increased public awareness of: international tax compliance issues through media reports; the CRA’s Offshore Tax Informant Program;… – Continue reading
Outward remittances by Indians remained elevated for the third month in a row. The remittances under the liberalised remittance scheme (LRS) for resident individuals grew to $457.5 million in September 2015 from $408.4 million in August. In July 2015, outflows were $380.3 million, a sharp jump from $140.7 million in… – Continue reading
THE African Tax Administration Forum (ATAF) has come up with a draft document on avoidance of double taxation and prevention of fiscal evasion within the continent. The Zimbabwe Revenue Authority (Zimra), a member of ATAF, has said avoidance of taxation and prevention of fiscal evasion was with respect to taxes… – Continue reading
One of today’s most talked about tax topics is the Offshore Voluntary Disclosure Program of 2014 (OVDP) and the compliance of individuals, institutions, and governments with the Foreign Account Tax Compliance Act. However, it is vital for one to understand why the IRS provided the public with the opportunity represented… – Continue reading
India is expected to ink upto 40 Advance Pricing Agreements before the end of fiscal as the country looks to provide tax certainty to foreign investors. “The new momentum will go a long way in avoiding disputes,” a finance ministry statement said on Friday. As many as 22 APAs have… – Continue reading
INTRODUCTION The Taxation Laws Amendment Act, 2015 and the Tax Administration Laws Amendment Act, 2015 have now both been passed by Parliament, but await signature by the President. Once again, and for the second year running, the number and scope of the changes to the various fiscal Acts (mainly the… – Continue reading
Patent Boxes, Innovation Boxes, Intangible Property Boxes, Knowledge Development Boxes (IP Regimes) – countries may use different names, but all of these regimes are designed to allow a preferential rate of tax to be applied to income generated from intangible property (IP). There are a number of these regimes in… – Continue reading
There are a variety of benefits to moving offshore, yet few would argue the assertion that tax neutrality is paramount among them. As anyone familiar with the phrase “tax haven” would surely recognize, many countries offer strongly favorable tax terms as an incentive to draw new business. Written by CT… – Continue reading
The draft agreement is intended to settle the issue of taxation of business profit, property revenues, sea and air transportation earnings, passive revenues and individual income MOSCOW, December 10. /TASS/. The Russian Government approved the draft intergovernmental agreement with Hong Kong on avoidance of double taxation and prevention of tax… – Continue reading
An income tax treaty between Cyprus and Switzerland has entered into force, and will be effective 1 January 2016. 10 December 2015 The Cyprus-Switzerland income tax treaty does not include a limitation on benefits (LOB) clause. Withholding tax provisions The treaty includes the following withholding tax provisions: Dividend payments subject… – Continue reading
Firms over a certain threshold group turnover may be required to give detailed info of financials. MULTINATIONAL companies in India over a certain threshold group turnover may be required to make comprehensive disclosures relating to their revenues, taxes paid, staff strength and assets in different countries where they operate from… – Continue reading
The Organization for Economic Co-Operation and Development is keen on putting a stop to the revenue losses countries face from tax avoidance strategies employed by multinational companies. CNBC-TV18’s Navin Shetty and Aayush Ailwadi find out just how prepared India is, to adopt the new action plan. The Organization for Economic… – Continue reading
The Association of Retail Trade (ACDET), which is part of Walmart, defended the decision to the chain filed a lawsuit against the government and the law 72. Considers that the law is unconstitutional and arbitrarily penalize one company. “Since April we warn the people that the measures were being discussed… – Continue reading
The Cayman Islands Tax Information Authority (“TIA“) has issued an advisory addressing several points of note regarding the Common Reporting Standard (“CRS“) in the Cayman Islands. Updated Self-Certification Forms The TIA has published new entity and individual self-certification forms which address the account holder disclosure requirements under each of CRS,… – Continue reading
FATCA requires sponsored entities (including those governed by an IGA) to have their own Global Intermediary Identification Number (GIIN) for FATCA reporting and withholding purposes by 31 December, 2016. Under a transitional rule, it is possible for one FFI to act as a sponsor for a number of other FFIs…. – Continue reading
The Department of Justice announced today that Cornèr Banca SA (Cornèr) and Bank Coop AG (Bank Coop) reached resolutions under the department’s Swiss Bank Program. The Swiss Bank Program, which was announced on Aug. 29, 2013, provides a path for Swiss banks to resolve potential criminal liabilities in the United… – Continue reading
Global Financial IntegrityGlobal Financial Integrity (GFI) on 8 December 2015 released the Global Illicit Financial Flows Report 2015 entitled Illicit Financial Flows from the Developing Countries: 2004-2013. This study is GFI’s 2015 annual global update on illicit financial flows from developing economies. It is the sixth annual update of GFI’s… – Continue reading
A global law firm has today criticised HM Revenue & Customs’s (HMRC) recently announced plans for cracking down on tax avoidance by businesses, saying that parts of the proposals would make HMRC the “judge, jury and executioner.” Further details on legislation that would allow the UK tax authority to place… – Continue reading
As the EU prepares for country-by-country tax reporting requirements, businesses would do well to understand the minutiae of the upcoming regulations October 2015 was a busy month for announcements regarding base erosion profit shifting (BEPS) and country-by-country reporting. The OECD issued the last of the guidelines on BEPS, the various… – Continue reading
Companies will to scrutinise their R&D activity more closely under proposed changes to patent box regime BUSINESSES will to scrutinise their R&D activity more closely under proposed changes to the design of the UK Patent Box regime outlined by the government The government is making the changes in order to… – Continue reading
Samuda blasts Gov’t for transfer pricing policy Opposition spokesman on industry and commerce Karl Samuda addressing the transfer pricing policy in Parliament on Tuesday. KARL Samuda has described the transfer pricing regime, as well as the Government’s push to implement it retroactively, as unfriendly to business, and has predicted that… – Continue reading
Chisinau, 10 December /MOLDPRES/-The parliament today ratified a Moldovan-American intergovernmental cooperation agreement to facilitate the implementation of the provisions of the Foreign Account Tax Compliance Act (FATCA). According to the chairman of the parliamentary commission for international relations and EU integration, Valentina Buliga, the ratified document sees that U.S. authorities… – Continue reading
The Cayman Islands Tax Information Authority (“TIA“) has issued an advisory to confirm that the limited life debt investment entity (“LLDIE“) exemption established under FATCA has been extended in the Cayman Islands to the OECD Common Reporting Standard (“CRS“).1 As such, a Cayman Islands LLDIE has been designated as a… – Continue reading
Ukraine’s state budget next year may amount to only $38 billion. For perspective, that is less than half of the municipal budget of New York City, with eight million residents, compared to Ukraine’s 43 million people. But viewed another way, the spending represents 40 percent of the official gross domestic… – Continue reading
The financial crisis at Bolton Wanderers has become critical after Her Majesty’s Revenue and Customs issued a winding-up petition for unpaid PAYE tax and VAT, the club have confirmed. Bolton, who were in the Premier League for 11 years until relegation in 2012 , announced they could not pay their… – Continue reading
NEW DELHI: With India stepping up efforts to bring back illicit funds stashed abroad, Switzerland has said both sides have improved their cooperation on tax matters following several high-level meetings. Over the past few months, both countries have been working closely on mutual administrative assistance, according to the Swiss government…. – Continue reading
Jakarta. Indonesia’s tax office is considering a tax amnesty for financial crimes, in a move that could bring back at least 100 trillion rupiah ($7.5 billion) to the state coffers, the director-general of taxes said on Wednesday. Southeast Asia’s biggest economy is grappling with the weakest economic growth in six… – Continue reading
Hong Kong’s Financial Services Development Council (FSDC) has released a number of research reports, including one that addresses tax issues relating to open-ended fund companies (OFCs) and private equity (PE) investments, reports Tax News. One report entitled “A Paper on the Tax Issues on OFCs and Profits Tax Exemption for… – Continue reading
In 2013, the 39th G8 summit in Lough Erne committed to reform the international tax system. The G8 Lough Erne Declaration stated that such reforms would benefit developing countries. The G20 declaration in St Petersburg 2013 also stated specifically that “Developing countries should be able to reap the benefits of… – Continue reading
Germany and Australia signed a new income tax treaty that follows, in some instances, the OECD Model Tax Convention, but not in other instances. For example, the treaty includes definitions for installation permanent establishments (PEs) and agency PEs, with the latter defined with a view to the OECD’s base erosion… – Continue reading
Source: United Kingdom – Executive Government & Departments – Press Release/Statement: Headline: News story: Finance Bill 2016 paves way for even simpler tax system and tough offshore evasion regime The government has today (Wednesday 9 Wednesday) published draft tax legislation to implement policies published at Summer Budget 2015 and Autumn… – Continue reading
Changes to the tax law in Sweden reflect additions of anti-avoidance provisions to the EU Parent/Subsidiary Directive and are intended to bring Swedish tax law into compliance with the directive. The new anti-avoidance provisions will be effective 1 January 2016—which is also the timeframe for EU implementation of the directive’s… – Continue reading
Publican pays €3m in tax, interest, and penalties Two of the four largest published tax settlements in the last quarter were made by businesses in the Cork region. Revenue’s latest tax defaulters’ list for the three months to the end of September shows that a total of €13.99m was recouped,… – Continue reading
House Lawmakers to Vote this Week on Temporary Renewal of “Tax Extenders” Package – including Two Outrageous Offshore Tax Loopholes Costing Taxpayers $10 Billion Annually Some on Capitol Hill Push to Make Loopholes Permanent, but Media Reports Suggest Offshore Provisions Could Be Phased out as Part of Bigger Tax Deal,… – Continue reading
Akhilesh Ranjan, joint secretary (foreign tax), who led India’s initiative in the BEPS project, candidly shared his views on India’s plans for its implementation and what lies in the future. The fundamental principle of the BEPS project, is that income of MNCs should be taxed in that country where economic… – Continue reading
Policy will disrupt investment: Samuda THE Government fell back on its huge majority in the House of Representatives yesterday to approve the back tax provisions included in new transfer pricing regulations despite objections from the Opposition that the measure would strangle businesses and obstruct investments. The 21 Government members (excluding… – Continue reading
