“Luxembourg is famous for two things: its steel industry and its rose cultivation industry”. This quote from an Italian guidebook of the 1930s was uttered by Luxembourg’s Finance Minister Pierre Gramegna at the annual conference of the Luxembourg Directors’ Association on 17 June 2015[1]. The economic outlook of the tiny… – Continue reading
The Senate, on Friday (November 27), passed amendments to the Income Tax Act, which will empower the Government to prevent tax leakage through the transfer pricing system. Transfer pricing is used by multinational companies for sales and services within their corporate groups and by individuals in transactions with corporations under… – Continue reading
Some U.S. lawmakers on Tuesday used a pair of hearings in the Senate Finance Committee and the House Ways and Means Committee to showboat for corporate special interests and oppose a growing worldwide movement to crack down on international tax avoidance. Last month, leaders of the 20 largest economies in… – Continue reading
The 28 nations of the European Union lose up to $1 trillion per year in revenue thanks to multinational corporations that use a spider’s web of completely legal constructs to lower their taxes. Now, Europe’s law enforcers and lawmakers want to wipe away these intricate tax-avoidance systems. If they have… – Continue reading
Today, the Senate Finance Committee met to discuss the Organization for Economic Co-operation and Development’s (OECD) project on Base Erosion and Profit Shifting (BEPS), a set of proposals on international tax policy approved earlier this fall that will place U.S. companies at a competitive disadvantage globally. Testifying with me today… – Continue reading
“It is not the strongest or the most intelligent who will survive but those who can best manage change”-Charles Darwin The Organization for Economic Co-operation and Development (OECD) released its final recommendations on the Base Erosion and Profit Shifting (BEPS) Project on October 5, 2015. The BEPS project consist of… – Continue reading
Looking back at tax developments over the past year, we’ve seen some promising incentives granted by the government and other developments that have caused taxpayer anxiety. One contentious issue involved transfer pricing, which we discussed in a previous column (“Transfer Pricing Loopholes Likely to be Closed Soon”, June 2). The… – Continue reading
Tax authorities in Britain will be given new powers to demand personal financial details from Bermuda, reports the Royal Gazette. The Island is one of 90 countries that will begin to share the financial details of British residents with HM Revenue & Customs (HMRC) from January under new plans to… – Continue reading
The House and Senate held hearings Tuesday on the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting action plan, also known as OECD BEPS, for combating tax avoidance by multinational corporations. A number of the lawmakers expressed a skeptical view of the international tax reforms. “The OECD’s… – Continue reading
Pension schemes should review their holdings in infrastructure heading into 2016, with the dual threat of incoming regulation and high prices potentially threatening returns, Kames Capital has said. Infrastructure has been an increasingly popular asset class for many schemes since bond yields tumbled in the wake of the financial crisis,… – Continue reading
The Ho Chi Minh City tax department has set up an anti-transfer pricing task force and is calling for a probe to be launched into alleged transfer pricing practices at Coca-Cola Vietnam, an official said on Monday. The new force is tasked with watching businesses that show signs of the… – Continue reading
The current international tax regime was developed in the last century when the internet was not yet invented. At that time, a foreign company would typically require a substantial physical presence in Australia before it could be in a position to earn significant amount of income from Australian customers. This… – Continue reading
EU committee to vote on plans to curb tax avoidance EU countries should be compelled to inform other member states in advance of plans to introduce tax initiatives that could affect their own or another country’s effective tax rate, according to a report to be considered by the European Parliament’s… – Continue reading
Sean Connery has not played James Bond for years, but is still a public figure prosecutors might like to attack. He was cleared, but Mr. Connery’s wife, Micheline Roquebrune, has been charged with taking part in an alleged plot to defraud the Spanish treasury of millions in taxes. It is… – Continue reading
KPMG, PN leader warn that proposals recently approved by European Parliament could threaten Malta’s booming financial services industry New European initiatives could threaten Malta’s sovereignty over its own fiscal affairs, KPMG partner Juanita Bencini warned. “There are dark clouds on the horizon and a closer European union may not necessarily… – Continue reading
The Organization for Economic Co-operation and Development (OECD) common reporting standard (CRS) is a standard that provides for the automatic exchange of financial account information between participating governments. The requirements under this standard are in addition to any Foreign Account Tax Compliance Act (FATCA) requirements. The Cayman Islands has recently… – Continue reading
The Australian Board of Taxation has released for public comment a discussion paper on the implementation of the anti-hybrid rules developed by the Organisation for Economic Co-operation and Development (OECD). As part of the 2015 Budget, on May 12, 2015, Australian Treasurer Joe Hockey wrote to Michael Andrew, Chair of… – Continue reading
The number of M&A transactions involving Private Equity [PE] investment in Bermuda in the first three quarters of this year has already eclipsed that seen in all of 2014, according to a report released today [Nov 30] by Appleby. “Bermuda was also the offshore jurisdiction to see the largest total… – Continue reading
Mauritius plans to launch a trading platform to hedge African currencies against the US dollar, part of a bid to expand its role as a financial hub for the continent, the financial services minister said. The Indian Ocean island is also in talks to boost ties with stock exchanges in… – Continue reading
New Article 76-A of the Income Tax Law was published in the Federal Official Gazette on November 18, 2015, establishing three new transfer pricing information returns: Master File, Local File and Country-by-Country Report. Background These measures arise in response to the commitment assumed by Mexico before the Organization for Economic… – Continue reading
WELCOME to Switzerland. A mountainous country where nothing comes cheap but many of the world’s filthy rich come to grow their fortunes. The ongoing relationship between the wealthy and Switzerland looks set to only strengthen as the super rich get richer, according to a report released on Friday. That’s despite… – Continue reading
Multinationals operating in Kenya, Tanzania and Uganda will be among the first in Africa to feel the impact of new measures to be adopted in January to curb tax losses caused by manipulation of contracts between related companies. The three countries together with Nigeria, Ghana, Burkina Faso, Senegal, Botswana and… – Continue reading
Effective November 1, 2015, all new investors who wish to purchase units of mutual funds have to provide additional KYC related information required for Foreign Account Tax Compliance Act (FATCA)/CRS compliance. From January 1, 2016 even existing investors who wish to make fresh purchases, need to complete the additional KYC… – Continue reading
The new Income and Capital Tax Treaty between Switzerland and Argentina entered into force on 27 November 2015. The new treaty generally applies from 1 January 2015 for withholding taxes and from 1 January 2016 for other taxes and article 25 (Exchange of information). The new agreement will replace the… – Continue reading
KUWAIT CITY, Nov 29: “The world of taxation has changed tremendously impacted by FATCA, transfer pricing, Base Erosion and Profit Sharing, and others which require dramatic changes in existing operating models and structures,” remarked Fouad Douglas, PwC Country Senior partner, at a tax seminar organised by the PwC in conjunction… – Continue reading
(OECD) In Paris on the occasion of the COP21, the Honourable Billy Graham Talagi, Minister for Ministry of Natural Resources of Niue signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters in the presence of Deputy Secretary General Rintaro Tamaki. Developed by the OECD and the Council of… – Continue reading
(CNS Business): A new report released by a coalition of NGOs, including Transparency International UK, has described some of the British overseas territories (BOTs) as “some of the most notorious purveyors of financial secrecy”, despite promises about more transparency. The authors say a World Bank study found that BOTs are… – Continue reading
Santo Domingo.- Internal Taxes (DGII) director Guarocuya Feliz on Sunday agreed with Institutional and Justice Foundation (FINJUS) vice president Serbio T. Castaños that large fortunes need to be investigated over tax evasion. “This position is in line with the work the institution carries out to eliminate banking secrecy to ensure… – Continue reading
NEW DELHI: With a view to weed out commercial activities under the garb of charity, the tax department has said any general public service that involves trade, commerce or business for a consideration will not be treated as Charity under the Income Tax act. Issuing ‘Explanatory Notes to the Provisions… – Continue reading
Barely a week goes by without Deutsche Bank featuring in the news for some reason, usually a bad one. This time, it’s tax avoidance. The FT reports that Deutsche Bank “has been devising complex tax avoidance strategies for some of its largest corporate clients”. Not that this is illegal, of… – Continue reading
Edward Snowden is not in jail, but his namesake soon could be. Switzerland has sentenced Hervé Falciani, a former HSBC Swiss bank employee, to five years in prison. He is the whistleblower and leaker often called the “Edward Snowden of tax evasion.” Leaks bank records and tax documents has helped… – Continue reading
Charities remind Cameron of pledge to ‘continue to lead world on tax and transparency’ before meetings with leaders of overseas territories Campaigners are urging David Cameron to use a meeting with leaders of Britain’s overseas territories this week to demand a crackdown on tax dodging, corruption and money laundering. Leading… – Continue reading
Tax Justice Network’s biannual Financial Secrecy Index revealed United States as one of the tax havens for foreign businesses despite its Foreign Account Tax Compliance Act (FATCA). The Huffington Post noted Nov. 2 that the US landed the third spot behind Hong Kong and Switzerland as the tax havens for… – Continue reading
While the U.S. is plagued by inertia when it comes to tax policy, the rest of the world hasn’t been standing still. The biggest change of late has been the completion of the Organization for Economic Cooperation and Development’s (OECD) Base Erosion and Profit Shifting Project, or BEPS, a multiyear… – Continue reading
Legislative Activity Tax-Writers Begin to Focus on BEPS, Tax Extenders Still Remain Though international tax reform negotiations may have fallen apart for 2015, tax-writers this week will hold their first hearings to address efforts by the Organisation for Economic Co-operation and Development (OECD) to counter corporate tax avoidance as part… – Continue reading
The law, at present, is replete with a complex web of cross-references, often causing confusion The clamour for simplifying tax legislations gets louder as a new government, in its interaction with businesses and the civil society, holds out a promise of a non-adversarial tax regime. The reform of indirect taxes… – Continue reading
AFIP tax bureau will charge between three and eight percent as a penalty for evasion Amid a shortage of dollars and decreasing foreign-currency reserves at the Central Bank, president-elect Mauricio Macri will try to entice Argentines with undeclared assets and foreign currency to take part in a new tax amnesty… – Continue reading
Government officials say multinational technology giants are reluctant to pay anything The Korean affiliates of Microsoft (MS) and Oracle are under increasing pressure to pay taxes here, with government officials saying the two multinational technology giants were reluctant to pay anything, although they generated huge a lot of money from… – Continue reading
Action Plan 10 of the Base Erosion and Profit Shifting (BEPS) project of the Organisation for Economic Co-operation and Development (OECD) seeks to align transfer pricing (TP) outcomes with value creation by clarifying the conditions under which transactions between related parties can be re-characterized. It also sheds light on how… – Continue reading
What is the whole point of the 15 actions in the Base Erosion and Profit Shifting (BEPS) code? How will they curb tax dodging and make taxation of multinationals more transparent? Historically, the interaction of different tax policies lead to instances where taxes paid are not commensurate to economic value… – Continue reading
East African countries expect to collect more revenue under a new code drawn, by the world’s richest economies to stop foreign multinationals from dodging taxes in host countries. The new code — Base Erosion and Profit Shifting (BEPS) — adopted by G20 at its meeting in Turkey two weeks ago,… – Continue reading
Tech titans powering the economy shelter money through insane tax-avoidance havens. It’s wrong — and adding up Offshore tax havens enable not only individuals to dodge taxes—they also enable multinational corporations to do so. Often this tax avoidance is done within the letter of the law: multinational groups exploit the… – Continue reading
World Bulletin / News Desk Herve Falciani, the former HSBC employee whose disclosures uncorked the “Swissleaks” scandal on bank-supported tax evasion, was sentenced in absentia on Friday to five years in prison, Switzerland’s ATS news agency said. Falciani, who worked as an IT specialist with HSBC, was convicted of industrial… – Continue reading
When it comes to planning for tax season, corporate tax reporting should be considered as part of Enterprise Performance Management. As Margaret Mitchell exclaimed in the classic novel, Gone with the Wind: ‘Death, taxes and childbirth! There’s never any convenient time for any of them.’ And while I hope that… – Continue reading
Last summer, a client received a letter from their bank, a major German bank in which it was asked to indicate “whether you are a US tax or not” and also in the form of an affidavit (“Under penalties of perjury”) in to make English more detailed information about himself… – Continue reading
(CNS): The UK’s overseas territories minister has told the Cayman Islands premier that the British government wants direct access to companies registered here for all of their law enforcement agencies, but the Cayman leader has so far refused. As the dispute between the UK and its territories continues, the return… – Continue reading
Uncertainty over the US Federal Reserve’s rate hike decision caused lower returns for offshore investments by local pension schemes during the third quarter of the year, new data show. The Alexander Forbes Consulting Actuaries Schemes Survey for the period ending September 2015 covering 380 schemes indicates earnings by pension schemes… – Continue reading
The Treasury Department and the IRS released Notice 2015-79 (the “2015 Notice”) on November 19th to further limit expatriation transactions and to supplement the anti-inversion guidance issued by them on September 22, 2014 (the “2014 Notice”). The 2015 Notice states that Treasury and the IRS will issue Treasury regulations to… – Continue reading
On October 7 2015 the South African Revenue Service (SARS) released Binding Private Ruling 207, which dealt with the merger of two controlled foreign companies (CFCs) for purposes of Section 9D of the Income Tax Act (58/1962). Facts The applicant, a South African-incorporated and resident company, had two subsidiaries that… – Continue reading
As Common Reporting Standard (CRS) comes into operation. OHANNESBURG – South Africans with undeclared offshore funds may only have a few months to get their affairs in order or risk facing significant penalties and even criminal prosecution as revenue authorities start the automatic exchange of information. The Common Reporting Standard… – Continue reading
