Indian entities will do a reciprocal information sharing about Americans The Finance Ministry today said it has received information from the US under the financial information exchange pact FATCA in the last two months and it is being analysed. The Foreign Account Tax Compliance Act (FATCA) came into effect from… – Continue reading
He said steps are being taken to put in place a robust information security mechanism in the Income Tax department Non-disclosure of overseas assets will become a “very risky affair” from 2017 as government will by then start getting information on them from foreign countries, Minister of State for Finance… – Continue reading
Right to levy capital gains tax by India is also part discussions, he said India is engaged in “positive talks” with Mauritius on revision of bilateral tax treaty as some issues still need to be sorted out, an official said today. “Negotiations have been going on. Talks with Mauritius have… – Continue reading
Corporate taxes continued to flood into the exchequer’s coffers last month, compounding a mystery about their source and raising doubts about whether a future government can rely on the company receipts after the election. The Revenue Commissioners and the Department of Finance have moved in recent weeks to dampen down… – Continue reading
A blockbuster tax cut deal, with a 10-year cost of $889 billion and counting, is deep into negotiations on Capitol Hill, proving that Congress doesn’t care about the deficit as long as the right groups get the giveaways. Virtually every year, Congress packages a series of over 50 tax breaks… – Continue reading
AB Bank Limited and Social Islami Bank Limited (SIBL) have tendered their “unconditional apology” after a Bangladesh Bank (BB) investigation revealed irregularities in buyer’s credit issued to some business houses by their offshore banking units. It was found that some debtors had shirked loan repayment, while yet others had utilised… – Continue reading
On 23 November 2015 Guernsey issued regulations to implement the Common Reporting Standard (“CRS”) under Guernsey’s domestic law. The regulations follow on from the commitment made on 29 October 2014 by Guernsey, along with the other Crown Dependencies and a number of other jurisdictions, to start exchanging information under the… – Continue reading
Tax cheats can breathe a little easier. The gun-toting Internal Revenue Service investigators who send felons to prison are retiring in droves and there’s no one to replace them. IRS Criminal Investigation agents are the elite special forces in the never-ending war on tax evasion. They are feared among criminals… – Continue reading
MUMBAI: Indian banks and mutual funds have in the past fortnight started warning NRIs who hold an American passport or are working in the US that their accounts could be frozen unless they get a tax-compliant certificate from US authorities, thanks to a treaty signed by New Delhi and Washington…. – Continue reading
Australians hiding funds and investments offshore to avoid paying tax have been put on notice. The federal government on Thursday introduced to parliament legislation to enable the tax office to crack down on taxpayers hiding funds overseas. It implements an OECD scheme allowing the sharing of information between foreign tax… – Continue reading
Leaders from the Group of 20 largest economies (G20) met in Turkey last month to put their final stamp of approval on a major overhaul of the international rules governing corporate taxes. The vote was the icing on a cake that the Organization for Economic Cooperation and Development (OECD) has… – Continue reading
A lengthy and yet complex investigation by The Botswana Gazette into financial affairs of the company in the shady tax haven of Bermuda blows the lid off the dealings amounting to P29 million with a mailbox sister company that has no office, employees or any legitimate business activities. Not only… – Continue reading
The Organisation for Economic Co-operation and Development (OECD) sees treaty shopping as an important source of Base Erosion and Profit Shifting (BEPS). In this context, it identified the prevention of treaty abuse as one of fifteen issues or “actions” in respect of which recommendations were to be formulated as part… – Continue reading
Michael Dunkley has hit back at calls for Bermuda to make its beneficial ownership information public, claiming that critics are “attempting to solve a problem that does not exist”. After three days of meetings in London, the British Overseas Territories agreed to put information on the people who ultimately own… – Continue reading
On November 30, 2015, the UK tax authorities at HM Revenue and Customs (HMRC) reached an agreement with Jersey about the interpretation of the company residence tie-breaker provision of the Jersey-UK income tax treaty. After reviewing other income tax treaties that contain similar provisions, HMRC will now take the view… – Continue reading
The Greens have been labelled “tax transparency traitors” by Labor for agreeing to pass the Government’s multinational tax avoidance laws, but the deal is also causing friction within Coalition ranks. Under the deal, multinational companies with a global turnover of $1 billion or more will have to prepare “general purpose”… – Continue reading
Amid all the diplomatic comings and goings on Syria and how to tackle Islamic State, an important but little-noticed high-level gathering has been taking place in London. The Overseas Territories were holding the fourth meeting of their Joint Ministerial Council at Lancaster House. Leaders from Anguilla, Bermuda, British Virgin Islands,… – Continue reading
HONG KONG, Dec. 2, 2015 /PRNewswire — Demand for asset protection, wealth planning and funds by high net worth individuals in Asian countries will drive continued growth in the offshore industry, according to OIL’s sixth “Offshore 2020” annual market research study. OIL, the leader in international incorporations and corporate services… – Continue reading
The reporting deadline for Portuguese financial institutions to communicate information required under the FATCA regime to the Portuguese tax authorities has been extended to 31 December 2015. The FATCA deadline was extended by a 30 November 2015 order. This is the second time that the FATCA reporting deadline has been… – Continue reading
Within days, the IRS will be able to revoke your passport for unpaid taxes. This bad idea has been kicking around for several years. This time, it is buried within 1300 pages of highway legislation. The government will surely see it as a nice complement to FATCA, the Foreign Account… – Continue reading
We are all aware of “base erosion and profit shifting” or “BEPS”. On 5 October 2015, the OECD released its final reports in connection with its BEPS Action Plan including its final report on Action 15 dealing with the development of a multilateral instrument to modify bilateral tax treaties (“Final… – Continue reading
Corporation tax receipts for the year came to €4.6bn in 2014. By October this year, receipts had already exceeded that, with the expectation that the full-year receipts will be around €6.5bn with the Budget projecting growth in receipts in 2016 of 10 per cent. In a little over a year,… – Continue reading
Royal Decree 1021/2015, of November 13, establishing the obligation to identify the tax residence of persons who hold or control certain financial accounts and to provide information concerning them in the area of mutual assistance. On November 17 last the above-mentioned Royal Decree was published in the Official State Gazette…. – Continue reading
Lawmakers seek late deal to scale back ‘Cadillac tax’ Lawmakers are making a late push to repeal or scale back Obamacare’s “Cadillac tax” by the end of the year, eying inclusion of changes in a broader tax package, wrote Peter Sullivan of The Hill. But lawmakers in both parties say… – Continue reading
The U.S. multinational will likely be investigated for evading taxes with Luxembourg’s help, following a report by trade unions earlier this year. McDonald’s is under investigation by European Union regulators for illegal tax deals with Luxembourg, according to sources close to the inquiry. The multinational—joining a list of EU tax… – Continue reading
The Government has recently launched a consultation on amending the UK’s interest deductibility rules for companies. The consultation follows the OECD’s recommendations as part of the Base Erosion and Profit Shifting (BEPS) project. In line with those recommendations, it is proposed that a company’s net interest deductions be limited to… – Continue reading
An EU deal with Liechtenstein, which will make it harder for EU citizens to hide cash from the tax man in bank accounts there, was endorsed by Parliament in a vote on Wednesday. Under the deal, the EU and Liechtenstein will automatically exchange information on the bank accounts of each… – Continue reading
Thailand’s vote this past May to implement a new transfer pricing law is expected to come into effect in the early part of the new year. Transfer pricing refers to the sale of goods or services between branches of a company or subsidiary companies to a parent enterprise, and most… – Continue reading
Swiss Senate has sealed the end of banking secrecy for foreign clients, following the House of Representatives in accepting the legal groundwork for the automatic exchange of information. The decision paves the way for a “decorous funeral for tax secrecy,” as senator Roberto Zanetti of the leftwing Social Democrats put… – Continue reading
Inland Revenue is looking at the tax treatment of hybrid debt and equity instruments and the use of related party loans funding local subsidiaries as part of a global clamp-down on tax avoidance. Acting deputy commissioner of policy and strategy David Carrigan told Parliament’s finance and expenditure select committee that… – Continue reading
The US Internal Revenue Service (IRS) reports no new registrations under Foreign Account Tax Compliance Act (FATCA) rules in November. The list stays at 177,147 institutions in 226 financial jurisdictions. The list details which overseas financial institutions have agreed to pass personal and financial information about accounts and investments controlled… – Continue reading
Members of the European Parliament have tasked the EU Commission to table measures to improve corporate tax transparency, coordination, and EU-wide policy convergence, in legislative recommendations passed by the Economic and Monetary Affairs Committee on December 1, 2015. The recommendations build on the work of EU Parliament’s Special Committee on… – Continue reading
Republicans in both chambers of Congress said international tax reform is necessary to retain companies in the United States following pharmaceutical giant Pfizer’s announcement it is moving its headquarters overseas after its merger with Ireland-based Allergan, citing the country’s high corporate tax rates. During hearings in the House Ways and… – Continue reading
Taxes levied on foreign stock dividends can be recouped, but it makes most sense for high-net-worth clients with multimillion-dollar positions Advisers could be missing out on a way to maximize returns on their clients’ foreign investments. Americans investing in non-U.S. stocks could be earning less of a return than they’d… – Continue reading
Congress tightens the tax abuse of Americans who live and work abroad Doubling down on Americans living and working abroad is a way for the Internal Revenue Service to squeeze the turnip a little harder in pursuit of a little more blood. The Obama administration, which has never met a… – Continue reading
Things are heating up in the economic substance doctrine area, which could lead to a U.S. Supreme Court review of the IRS’s aggressive arguments for the doctrine. Certiorari Petitions Salem Financial Inc. and Bank of New York Mellon Corporation have both petitioned for Supreme Court review of the Federal Circuit… – Continue reading
The European Commission’s use of state aid rules to challenge corporate tax agreements is causing uncertainly for businesses in Europe, Luxembourg finance minister Pierre Gramegna has said. Gramegna told the Financial Times this week that the situation “raises so many issues about predictability and certainty”. The Commission announced in October… – Continue reading
Taxes levied on foreign stock dividends can be recouped, but it makes most sense for high-net-worth clients with multimillion-dollar positions Advisers could be missing out on a way to maximize returns on their clients’ foreign investments. Americans investing in non-U.S. stocks could be earning less of a return than they’d… – Continue reading
This statistic might even make the 1% feel humbled. America’s 20 wealthiest people — a group that could fit in one Gulfstream G650 jet — are now worth $732 billion, which means they have more wealth than the 152 million people who make up the least wealthy 50% of U.S…. – Continue reading
Holiday home owners and others who inadvertantly break new tax rules could be ‘criminalised’ Holiday home owners who miscalculate tax owed, and those inheriting offshore money, face having their income wiped out entirely due to new penalties and punishments being introduced in the New Year. HM Revenue & Customs has… – Continue reading
A new international framework is targeting tax avoidance—and it has implications for captive insurers. Jenny Coletta of Ernst & Young explains In recent years, tax authorities around the world have been increasingly scrutinising captive insurance arrangements, focusing on questions relating to commercial purpose, pricing and substance. In what is likely… – Continue reading
Former UBS bank executive Raoul Weil believes the United States tried to use him to batter down Swiss banking secrecy by having him arrested and placed on trial last year. In an interview with the Tages-Anzeiger newspaper on Wednesday, Weil said the US Department of Justice intended to “lead me… – Continue reading
On 17 September, 2015, China State Administration of Taxation (“SAT”) released the Discussion Draft of Implementation Measures for Special Taxation Adjustments (“Discussion Draft”), as a complete revamp to the existing trial version of the Implementation Measures, i.e., Circular 2. Circular 2 has been serving as a backbone transfer pricing (“TP”)… – Continue reading
For the sixth consecutive year, the British Virgin Islands (BVI) has been named the most important offshore financial services jurisdiction by OIL’s annual Offshore 2020 report. The report is based on the opinions of 300 global financial services industry professionals and explores key trends and issues facing the industry. Martin… – Continue reading
The Common Reporting Standard (CRS) is the standard for automatic exchange of financial account information produced by the Organisation for Economic Cooperation and Development (OECD) which provides for systematic and periodic automatic exchange of information between signatory jurisdictions. At its heart is a requirement for financial institutions, including British Virgin… – Continue reading
Following a directive proposal put forward by the European Commission as part of a package of measures in March, the European Council reached political agreement on a directive amending the text of 2011/16/EU directive on administrative cooperation in the field of taxation. EU member states will be required to automatically… – Continue reading
The Channel Islands (Jersey and Guernsey) have long been known as leading offshore centres for the establishment of investment funds and other investment structures. In particular, Channel Island vehicles are often used for alternative investment structuring – including private equity, infrastructure and real estate. This article explains the trends in… – Continue reading
Amazon Anonymous van drove through central London emblazoned with the line: ‘Enjoy unlimited instant tax dodging subsidised by government hand-outs. Anywhere, anytime’ Anti-Amazon campaigners drove a van through central London yesterday that was emblazoned with a crowdfunded, fake Amazon advert attacking the online retailer’s alleged tax avoidance. Booksellers have championed… – Continue reading
In a previous article we have discussed that you might be entitled to reclaim withholding tax on your foreign investments in Russia (including ADRs, GDRs). For transactions where the ultimate beneficial owner is not declared prior to the payment of income, local Russian custodians apply 30% withholding tax on dividends1… – Continue reading
The new Income Tax Treaty between the Netherlands and Germany has entered into force today, 1 December 2015. The new Treaty generally applies from 1 January 2016 and replaces the old treaty of 1959. In accordance with the new treaty, the following withholding taxes will apply: Dividends: 5% if the… – Continue reading
