Category: Activity

Malta: Malta’s Double Tax Treaties – November 2015

In order to encourage the growth of international trade including that of financial services, successive Maltese governments have sought to conclude double tax treaties with important trading partners as well as with emerging countries. This policy is expected to continue in the future. To date, treaties are in force with… – Continue reading

European Union: The End Of Financial Privacy?

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

KPMG releases new global tax survey; economic and social pressures expected to impact global tax system

Taxpayers in Romania and throughout the world can expect to pay more tax in the years ahead as governments expand their tax systems to repay debt and pay for increased social welfare, and international efforts to update tax legislation for the 21st century take hold. These are the conclusions of… – Continue reading

Americans In Costa Rica Advised To Ensure US Tax Compliance

QCOSTARICA via Tax-news.com – The inclusion of a passport revocation provision to fund part of the proposed US highway bill would “disproportionately” affect American citizens living overseas, like in Costa Rica, according to a recent release from the deVere Group, a financial consultancy. The provision, which would be effective from… – Continue reading

State may gain up to €620m in Pfizer’s Allergan deal

Pfizer $160bn purchase of Allergan will see firm move HQ to Dublin Ireland’s exchequer is in line for an annual boost of up to €620 million following the announcement that Pfizer is buying rival Allergan in a $160 billion (€151 billion) deal. The takeover will see Pfizer move its corporate… – Continue reading

Wanted: central bank boss to fix 1,700-year-old European tax haven

MILAN (Reuters) – San Marino is looking for a new central bank governor to clean up its banks – traditional havens for tax dodgers – and fix their badly damaged balance sheets. Big problems for the micro-state began in 2009 when Italy, hit hard by the global financial crisis, added… – Continue reading

Previewing US Tax Reform

The latest Tax Reform Business Barometer survey, issued by The Tax Council and Ernst & Young, found that tax professionals expect Congress to approve tax reform legislation no earlier than 2017, with most congressional leaders having all but given up hope that tax reform is achievable in the remainder of… – Continue reading

Preferential multinational tax agreements under fire – European Parliament

A European Parliamentary debate this afternoon discussed measures that would lead to the curtailing of tax evasion and avoidance. A debate was sparked last year when it was revealed that Luxembourg had struck preferential multi-billion dollar tax deals with some of the world’s largest multinational corporations. This debate has been… – Continue reading

I-T Dept inks 11 agreements to solve transfer-pricing issues

Of these, one advance pricing agreement has a ‘rollback provision’ The government has concluded 11 agreements to tax multi-national companies via the transfer-pricing mode. Of these, one advance pricing agreement (APA) has a ‘rollback provision’, which means those relating to previous years. The government has signed 22 APAs so far… – Continue reading

Finance Ministry to clean-up trade transfer pricing norms to make doing business easy

NEW DELHI: India proposes a major clean-up of decade-and-a-halfold rules that govern the prices of imports by related parties – such as arms of multinationals from their parent – in an attempt to reduce delays and disputes and make it easier to do business. The finance ministry is not just… – Continue reading

Indian infrastructure firms seek to diversify debt with masala bonds

The global rupee bonds would be used to refinance costly loans or raise capital for new projects with little currency risk Mumbai/Singapore: Some of India’s most indebted infrastructure and steel groups are considering so-called masala bonds to diversify their funding options as local banks tighten lending, investment banking sources with… – Continue reading

The offshore financial industry shows resilience as demand stays robust

The offshore industry is poised for growth, as the industry insiders see the demand for offshore financial and corporate services likely to increase in the coming years, according to an industry survey conducted by OIL, a corporate service provider specializing in international incorporations. The industry has been battling negative perceptions… – Continue reading

The offshore financial industry shows resilience as demand stays robust

The offshore industry is poised for growth, as the industry insiders see the demand for offshore financial and corporate services likely to increase in the coming years, according to an industry survey conducted by OIL, a corporate service provider specializing in international incorporations. The industry has been battling negative perceptions… – Continue reading

Wealth inequality and tax justice

Wealth inequality is a scourge of many countries. Last year, Credit Suisse reported that the richest 0.7% of adults in the world owned 44% of global wealth. Closer to home, earlier this year, the Lien Centre for Social Innovation’s ‘A Handbook on Inequality, Poverty and Unmet Social Needs in Singapore‘… – Continue reading

The English version of the DTA as concluded between Malta and the Kingdom of The Netherlands in respect of Curaçao has been published

Earlier we already reported that Malta and Curaçao had signed a DTA. When we wrote our earlier article we had not yet been able to locate the text of the DTA. Now however, the English version of the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal… – Continue reading

Turkey launches golden visa residency scheme

Turkish Economy Minister Nihat Zeybekci says the country is set to follow in the footsteps of Spain, Portugal and Cyprus and launch its own Golden Visa scheme to grant citizenship to those foreigners who invest from €500,000-€1m in property, reports Property Showrooms. Leading Istanbul agent, Universal21, says the move could… – Continue reading

Wolters Kluwer Financial Services Warns Industry to be Braced for Further FATCA and GATCA Complexity

Complexity of regulations means first adopters will gain competitive advantage, newly released white paper notes The banking industry should be braced for further complexity when it comes to the US Foreign Account Tax Compliance Act (FATCA) and the looming Global FATCA (GATCA). And those institutions that move more quickly to… – Continue reading

Amendments to CFC diversionary income rules

On July 22 2015, National Treasury released for comment the Draft Taxation Laws Amendment Bill, 2015 (DTLAB 2015), the Draft Tax Administration Laws Amendment Bill, 2015 (DTALAB 2015), and related Explanatory Memoranda. Section 9D currently provides for diversionary income rules which seek to impute into the income of South African… – Continue reading

Taxation of dividends payable by a South African company to a Cypriot shareholder

SARS may now impose a dividends tax on dividends paid by a South African company to a Cypriot shareholder as provided for in the Protocol to the current agreement for the avoidance of double taxation between South Africa and Cyprus. In terms of the current agreement for the avoidance of… – Continue reading

DDM Holding AG: Swiss withholding tax applies in respect of interest payments to holders of the DDM Senior Secured Notes

Following a ruling by the Swiss Federal Tax Administration, payments of interest under the DDM Treasury SEK 300 million Senior Secured Notes with ISIN SE0005280831 (the “Notes”) are subject to Swiss withholding tax since the refinancing executed in June 2015. On 23 June 2015 certain amendments to the documentation in… – Continue reading

Better global rankings underline India’s potential

The World Bank has placed India twelve notches higher than last year in its Ease of Doing Business rankings for 2016. This comes close on the heels of the country’s sixteen place leap on the World Economic Forum’s Global Competitiveness index. These rankings underline the impact of the recent spate… – Continue reading

Hong Kong Adapts To Global Tax Developments

Hong Kong’s Secretary for Financial Services and the Treasury, K C Chan, has emphasized that the Government is committed to complying with the latest international tax developments, including on tax transparency and tackling base erosion and profit shifting. In his speech to the Taxation Institute of Hong Kong 2015 CTA… – Continue reading

Why incorporate a startup in the British Virgin Islands?

As the founder of a startup company, one of the first questions you need to consider is “where should I incorporate my company?” Investors are drawn to the British Virgin Islands (BVI) for its flexible and modern corporate regime, tax neutrality, respected legal system, political stability and effective regulatory framework…. – Continue reading

Sinarmas Land eyes Reit to unlock value of Indonesian investments

SINGAPORE-listed Sinarmas Land is looking to unlock the value of its investment properties in Indonesia by spinning them into a real estate investment trust (Reit) but has not decided on whether to list in Singapore or Jakarta, with tax benefits on offer likely to be a key determinant. “The unlocking… – Continue reading

PwC Makes UK Autumn Statement Predictions

Professional services firm PwC has predicted that UK Chancellor George Osborne will introduce an “apprenticeship levy” and seek to lessen the impact of tax credit cuts when he delivers his Autumn Statement on November 25. In his Summer Budget, Osborne pledged that the Government would “introduce an apprenticeship levy on… – Continue reading

OECD: TREATY-RELATED MAP STATISTICS FOR 2014 REPORTING PERIOD

The Organisation for Economic Cooperation and Development (OECD) today released annual statistics on the mutual agreement procedure (MAP) caseloads of all its member countries and of non-OECD economies that agree to provide such statistics for the 2014 reporting period. Today’s OECD release explains: The MAP statistics correspond to the 2014… – Continue reading

LUXEMBOURG: STATUS OF RATIFICATION OF PROTOCOL WITH FRANCE

A pending Protocol, that would amend the income tax treaty between Luxembourg and France, may not be effective until 2017. RATIFICATION PENDING The Luxembourg Parliament passed a bill to ratify the fourth Protocol to the income tax treaty (1958) between Luxembourg and France. However, it currently appears that the ratification… – Continue reading

Denmark introduces a legislative proposal in order to implement BEPS Action Point 13

On 10 November 2015, the Danish Ministry of Taxation introduced a draft bill (bill no. L46) including an amendment to section 3B of the Danish Tax Control Act (skattekontrolloven). The purpose of the proposed amendment is to implement Action Point 13 of the BEPS Initiative (Guidance on Transfer Pricing Documentation… – Continue reading

New PE Language for BEPS Scales Back Earlier Drafts

Through tweaks to the Model Tax Convention, the OECD believes its work on profit shifting will stem elaborate structures, such as commissionaire arrangements, used by large multinationals to avoid the creation of a permanent establishment. The Organization for Economic Cooperation and Development, however, responded to concerns from taxpayers by narrowing… – Continue reading

U.K., U.S. Differ on Approaches to Implement BEPS

The U.K. and the U.S. governments will adopt different approaches to implementing the OECD’s final package of measures to tackle base erosion and profit shifting, panelists at a London forum said. The U.K. government considers an inclusive, multilateral instrument to upgrade bilateral tax treatments as the “best way” for countries… – Continue reading

Praise for Gibraltar government from Washington D.C.

DESPITE repeated allegations from the Spanish government that Gibraltar is a tax haven, news is regularly received that suggests this is far from the case, and that the government has been doing all that it can to ensure that it complies as fully as possible with international standards, whilst generating… – Continue reading

FATCA – correlation of the global economy with the US economy

Already from December 1, 2015 come into force provisions requiring all financial institutions calling their clients to make statements about their residence tax (FATCA – Foreign Account Tax Compliance Act). It is the first significant action since records to OPF. FATCA imposes on foreign institutions, including the Polish reporting obligations… – Continue reading

Ethical Investors Should Shun Firms Avoiding Tax

Big name companies have faced a lot of criticism from the media about the low taxes they pay in some countries. Lately, the Organisation of Economic Cooperation and Development (OECD) has finalised a set of recommendations to stop base erosion and profit shifting (BEPS). The rules are aimed at curbing… – Continue reading

Americans in Hong Kong, Asia could lose their passports for unpaid taxes

The eight million Americans living overseas, including In Hong Kong and the rest of Asia, should “ensure their financial affairs are in order and compliant” before the New Year, or face having their passports revoked, warns the boss of one of the world’s largest independent financial advisory organizations. Nigel Green,… – Continue reading

Tax of billions evaded, black money whitened every year

ISLAMABAD: In a major scam tax evasion of hundreds of billions of rupees and whitening of black money worth trillions of rupees take place every year with the government authorities facilitating the extremely undervalued sales and purchases of thousands of residential and commercial properties throughout the country every day. While… – Continue reading

Country-by-Country Plan May Be Project’s Greatest Legacy

The OECD’s final report on Action 13 under the base erosion and profit shifting project—which calls for countries to adopt a country-by-country reporting template, master file and local file—has the potential to be one of its “greatest legacies.” Marlies de Ruiter, head of the Organization for Economic Cooperation and Development’s… – Continue reading

Ambassador Hull: Region should not be strong-armed into becoming tax collectors for the US government

LK Hewlett St. Kitts-Nevis Permanent Representative to the OAS, Dr. Everson Hull has expressed strong views on the impact of FATCA on the region’s banking system. Delivering a presentation to over 200 banking executives and other stakeholders in the financial services sector from across the Caribbean at the recent Caribbean… – Continue reading

IRS Updates FATCA Registration Website

The IRS has upgraded the Foreign Account Tax Compliance Act (FATCA) Online Registration System, enabling sponsoring entities to register their sponsored entities to obtain a global intermediary identification number. The upgraded system also will allow users to update their information, download registration tables and change their financial institution type. The… – Continue reading

Curaçao Attended The STEP Latin America Conference 2015

WILLEMSTAD – A 20-member delegation from Curaçao participated in the STEP Latin America Conference (STEPLatAm) 2015, which was held on the 22nd and 23rdof October at the Renaissance Hotel in Sao Paulo, Brazil. The STEPLatAm conference is a leading conference for wealth structuring and trust and estate practitioners. During the… – Continue reading

‘Dr Ageless’, Shane Charter, chasing missing millions in Cayman Islands

EXCLUSIVE The self-styled biochemist known as “Dr Ageless”, Shane Charter, appears to have shrugged off the Essendon supplements scandal and is pursuing a new business venture — chasing more than $11 million hidden in offshore tax havens by notorious conman Peter Foster. Mr Charter has been negotiating for several months… – Continue reading

Insider blows the whistle on multi-million pound tax avoidance ‘factory’

Failed tax avoidance business Welbeck hired young actors to push schemes onto City big earners, and reaped millions in commissions that fuelled lifestyles of fast cars and exotic holidays, according to a whistleblower who worked at the firm. Welbeck Solutions sold pensions and financial products, but it specialised in tax… – Continue reading