Category: Activity

G20 vows to push growth, backs India on International Monetary Fund reforms

“India’s concerns are known…there can be no compromise on the issue of terror…India’s longstanding position is that there is no good or bad terror and all forms of terrorism are unacceptable and must be fought by the global community as well as each and every country”, the source told reporters…. – Continue reading

Make note of new disclosure requirements

Towards compliance with tax information sharing laws put in place in recent times, all financial intermediaries are mandated to seek information from account holders. They are also obliged to share information of your account with relevant authorities. SEBI too has issued guidelines on identification of beneficial ownership and mandated all… – Continue reading

Northern Ireland’s 12.5pc corporate tax rate will pose threat to foreign direct investment in the South

The North will have its own 12.5pc corporate tax rate from 2018. This means that it will compete harder against the Republic for FDI projects, writes Dan White The 12.5pc company tax rate will no longer be confined to the southern part of the island. Last week’s ‘Fresh Start’ agreement… – Continue reading

Uncovering the Mysteries of Tax Optimization

Gabriele Galimberti and Paolo Woods make a complex and impenetrable subject palatable To do justice to the work undertaken by Paolo Woods and Gabriele Galimberti, requires thinking of them not as photographers, but as investigators. Their search for truth begins with a mystery, one embodied in Ian Fleming’s Dr. No…. – Continue reading

KPMG REPORT: INITIAL IMPRESSIONS OF NOTICE 2015-79 ON INVERSIONS

Notice 2015-79—released November 19, 2015, by the Treasury Department and IRS—announces their intention to issue regulations relating to inversion transactions and post-inversion restructuring transactions. Notice 2015-79 provides for rules that: Limit the ability of domestic companies to effect an inversion Limit the advantages of certain post-inversion restructuring transactions Clarify certain… – Continue reading

Ethiopia: Unmet Demands of the G20

The creation of the Group of Twenty (G20) was believed to serve as a remedy to the harsh realities of the world today. The initial formation of the Group of Seven G7 could do little to avert pertinent challenges both the developing and the developed nations face frequently. So a… – Continue reading

Osborne’s struggle to balance the books: Will the Chancellor target capital gains tax in the Autumn Statement?

The Chancellor could target capital gains tax for extra revenue when he delivers his Autumn Statement next week as gains from investors and landlords hit their highest on record in the past financial year, accountants suggest. George Osborne, who will unveil his spending plans for Britain next Wednesday, is under… – Continue reading

Welbeck Solutions: Whistleblower exposes secretive city firm at the heart of vast tax avoidance operation

Company used actresses including former Alan Partridge star to bombard financial sector workers with cold calls The grey Basinghall Street office building, in the heart of London’s City financial district, gives few clues about the frenzy of activity that was going on inside. But for years, this was the home… – Continue reading

IRS To Release Additional Rules On Corporate Inversions

This week, the IRS released Notice 2015-79, which describes intended regulations to cover inversions and related transactions. Colloquially, an inversion refers generally to a transaction in which a domestic corporation is acquired by a foreign corporation. I.R.C. §§ 367 and 7874 operate as the anti-inversion rules; § 367 deals with… – Continue reading

More Banks Spill Tax Evasion Secrets To Avoid Criminal Charges, Account Holders Beware

Lately, the IRS is warning offshore account holders to disclose before it’s too late. Under FATCA, banks everywhere want to know if you are compliant with the IRS. And the cost of compliance for many people is growing. The IRS updated its list of foreign banks where accounts trigger a… – Continue reading

Made bureaucracy accountable: Modi

NEW DELHI: Prime Minister Narendra Modi said his government had taken several steps to make the bureaucracy performance-oriented and accountable even as it was committed to ensuring probity and protecting public servants from frivolous allegations. He said the focus of his government was on providing system-based and policy-driven governance. “A… – Continue reading

The implementation of BEPS – how it may all come together

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

Advance payments by non-residents disposing of immovable property

Introduction Withholding obligation Proposed amendment Comment Introduction The 2015 Taxation Laws Amendment Bill proposes an amendment to Section 35A of the Income Tax Act (58/1962), dealing with withholding percentages from payments due to non-resident sellers of immovable property situated in South Africa. The proposed amendment raises interesting questions regarding compliance… – Continue reading

Clock Ticking for U.S. Holdouts as BNP Joins Swiss Tax Pact

The clock is ticking for American tax dodgers around the world after BNP Paribas SA’s Swiss unit and two other banks joined a U.S. program to avoid prosecution, revealing the exact methods of Swiss bankers’ legendary discretion. BNP agreed to pay $59.8 million in a program that has brought in… – Continue reading

Stricter norms likely for transfer pricing

MUMBAI: India’s forthcoming budget may draw from some of the recommendations, especially in the realm of transfer pricing, contained in the final package of ‘Base Erosion and Profit Shifting’ (BEPS) measures, rolled out in October. Certain anti-abuse measures, such as thin capitalization, which for tax purposes disallows interest payments beyond… – Continue reading

Swaziland to collect tax from US citizens, firms

Swaziland will implement the United States Foreign Accounts Tax Compliance Act FATCA 2010 by collecting tax from US individuals and companies operating in the country.APA learnt on Friday that the act, whose objective is the facilitation of the exchange of financial information between US and other countries where its citizens… – Continue reading

Main provisions of Patent Box regime

Introduction Tax exemptions Eligibility Trademarks Calculating tax benefits Eligible costs Introduction At the end of 2014, the government presented the 2015 budget, which introduced a ‘Patent Box’ tax regime in line with similar schemes adopted in other European countries. It applies to corporate income tax and regional tax on productive… – Continue reading

Govt to implement United States FATC Act of 2010

THE United States of America (USA) wants all companies of US origin, individuals and body corporates that are resident in Swaziland to report their financial information in their home country, the USA. This development is a result of Swaziland government announcing that it will implement the United States Foreign Account… – Continue reading

Interim tax in connection with non-resident beneficiaries

Introduction Facts Decision Introduction The European Court of Justice (ECJ) recently ruled that the system of interim taxation for Austrian private foundations does not comply with EU law.(1) A special feature of private foundations is the so-called ‘interim tax’ – a type of corporate income tax. Pursuant to Section 13(3)… – Continue reading

2015- The end of tax neutral jurisdictions

On 18 June 2013, the Progressive led government issued a press release titled, “Cayman’s Action Plan Includes Beneficial Ownership”. The press statement came on the heels of the UK taking over the Presidency of G8, at the 17-18 June 2013 G8 Summit in Northern Ireland. The most interesting part of… – Continue reading

Offshore land ownership secrecy blocks police investigation into wildlife crime

Ownership of Kildrummy Estate creates legal block for police investigators POLICE INVESTIGATIONS into wildlife crime failed in the face of a bureaucratic nightmare identifying the landowner behind a complex structure of offshore land secrecy. The conviction of gamekeeper George Mutch for wildlife crimes committed in 2012 on Kildrummy Estate opened… – Continue reading

India to make efforts to check Mauritius DTAA misuse: Official

NEW DELHI: Concerned over the misuse of double taxation treaty with Mauritius by certain entities, the government is working on measures to check such practices, a Finance Ministry official said today. The government is in the process of revising the Double Taxation Avoidance Agreement (DTAA) with Mauritius. Tax treaty amendments,… – Continue reading

UK non-dom changes unfair, unreasonable, disproportionate

Plans that would effectively end the UK’s non-domicile status for tax purposes have the potential to do more harm than good and could be contrary to EU law, according to the Institute of Chartered Accountants. The changes, announced by chancellor George Osborne in the 2015 summer budget, mean that non-UK… – Continue reading

The Offshore Wrapper: a week in tax justice #71

Now that’s what I call a Big Tax Case A long running court case that has become known as the ‘Big Tax Case’ appears to be reaching a conclusion. It involves Scottish football club Rangers, who went bust in 2012. After it failed, a new company was created. It bought… – Continue reading

Russia and Singapore sign a Protocol revising their existing DTA

On November 17, 2015 Russia and Singapore signed a Protocol revising the existing Agreement between the Government of the Russian Federation and the Government of the Republic of Singapore for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (Hereafter: the Protocol)…. – Continue reading

Finance Malta wants faster innovation

Malta recently ranked first for efficiency in transposing directives into national legislation – but the chairman of Finance Malta, Kenneth Farrugia, believes that the pace of innovation needs to accelerate. “We claim to be nimble, but we need to push it much more. Innovation needs to be much faster paced…. – Continue reading

Oil And Gas Contractors Face Tax Hikes And Job Losses

British oil and gas contractors are amid a huge financial upheaval as a combination of job cuts and tax changes threaten their well-paid lifestyle. Thousands of contractors in the oil and gas industry worldwide have lost their jobs as companies look to protect their cash by sacking staff. The oil… – Continue reading

CEE countries must share best practices better to successfully combat VAT fraud

Officials from the ministries of finance and economy of five CEE countries (Czech Republic, Hungary, Poland, Romania and Slovakia) have called for a joint approach to combat VAT fraud and increase VAT collection in a conference hosted by PricewaterhouseCoopers (PwC) in Budapest on Thursday. According to the EU Commission data,… – Continue reading

European Commission requests the Netherlands to amend the Limitation on Benefits clause in the Dutch-Japanese Tax Treaty for the Avoidance of Double Taxation

On November 19, 2015 the European Commission published the key decisions of its November infringement package. One of the key decision mentioned is the Commission’s decision to request the Netherlands to amend the Limitation on Benefits (LOB) clause in the Dutch-Japanese Tax Treaty for the Avoidance of Double Taxation, which… – Continue reading

CE + IT Multinationals Seek Talk With ATO As Avoidance Laws Near

CANBERRA – Several multinational companies have approached the Australian Taxation Office to negotiate before the Coalition Government’s tougher anti-avoidance laws take effect in January, tax commissioner Chris Jordan has said in opening remarks to the Senate inquiry into corporate tax avoidance. While not naming the companies, Jordan said he expects… – Continue reading

NIGERIA: IMPLICATIONS OF BEPS PROPOSALS

Nigeria’s tax authority—the Federal Inland Revenue Service—has incorporated into its tax audit procedures certain of the recommendations included in the OECD’s base erosion and profit shifting (BEPS) project. For instance, the tax authority is scrutinizing transactions between Nigerian subsidiaries and their foreign related parties, especially those related parties located in… – Continue reading

Tax functions need to fundamentally change the way they use and gather data

Employees in tax functions need to fundamentally change the way they use and gather data if they are to meet the growing demands on business of tax transparency, reform and technology enabled decision making. PwC’s latest research into the Tax function of the future – Unlocking the power of data… – Continue reading

Turkey: The Information Exchange Agreement Has Been Signed Between Turkey And USA Within The Scope Of Foreign Accounts Tax Compliance Act

It has been announced on the official website of the Directorate of Revenue Administration on July 30, 2015 that the “Agreement on Increasing International Tax Compliance through Extended Information Exchange” was signed in Ankara between Turkey and USA within the scope of Foreign Accounts Tax Compliance Act (“FATCA“). Under the… – Continue reading

Time for US to lead on international tax policy

In recent days, the new Speaker of the House Paul Ryan (R-Wis.) signaled a priority for international tax reform in 2016. And if the newest recommendations from the Organization of Economic Cooperation and Development (OECD) are any indication of what’s ahead on the global tax scene for American businesses, it… – Continue reading

Base erosion and profit shifting: limiting tax deductions for interest costs

Earlier this week the heads of state of the 20 largest global economies have agreed to adopt the 15 BEPS action points in their respective countries. Ample reason to take a closer look at the details and implications of one of the most far-reaching upcoming tax adjustments. Action 4 of… – Continue reading

United States: Tax Alert: G20 Leaders Approve OECD Proposals For Comprehensive Global Reform Of The International Tax System, Including Redefinition Of “Permanent Establishment”

Measures Will Impact Financial Services, Investment Fund, Aviation Leasing and Other Sectors G20 finance ministers last week finally approved the wide-ranging “BEPS” reforms to the international tax system. The measures include a proposed new OECD treaty definition of “Permanent Establishment” under which the mere negotiation of contracts could create a… – Continue reading

Govt in top gear: Coal India stake sale, Vodafone talks signs of a strong resolve to deliver

From FDI relaxations to gas pricing and now disinvestment and Vodafone talks, it is refreshing that the NDA government has gone on an overdrive to push measures to attain a high growth trajectory. The pace at which the NDA government is taking decisions after Bihar assembly election results is commendable… – Continue reading

A Delicate Balance: Tax Competition Versus Cooperation

Tax administrators want to maximise the amount of revenue collected without stifling the county’s competitiveness as a business destination. How should ASEAN countries navigate changing international conditions to meet this goal? By Rebecca Tan – As Benjamin Franklin once famously said, “In this world, nothing can be said to be… – Continue reading

Crackdown on Caribbean tax havens a surprise boon for Hong Kong

Hong Kong is tipped to become the world’s largest offshore corporate services centre by 2020, helped ironically, by the industry’s own struggles against reform demands coming from western governments and pressure groups. On notice after high profile money laundering and tax avoidance scandals, traditional offshore havens like the British Virgin… – Continue reading