Category: Activity

Brazil eyes offshore cash in bid to boost gov’t revenue

PSDB amendment in Lower House cuts Speaker Cunha out of deal, but Senate still has final say BRASILIA — The Lower House of Brazil’s Congress has approved a controversial amnesty bill for undeclared offshore assets, despite criticism from opposition lawmakers who say it would allow the laundering of illegally gained… – Continue reading

African leaders reject EU ‘charity’ over ‘investment’

Macky Sall, the Senegalese president, tells journalists on the sidelines of the Malta migrants summit that Africa would have no need of handouts if wealthy governments stopped multinationals avoiding legitimate taxation in their countries African leaders have rejected a European Union bid to curb migration with aid payments as “not… – Continue reading

A Wale(s) of a Tax Strategy

Companies such as Apple, Starbucks, and Amazon are well known for legally using international law to their advantage when it comes to tax. Now a small Welsh town is mimicking their tactics. Independent traders in Crickhowell are moving their businesses “offshore” to avoid paying tax. The local businesses – including… – Continue reading

Financial Sector Must Be Vigilant, PM Harris Says to Banking Sector

Basseterre, St. Kitts, November 13, 2015 (SKNIS): The Caribbean Association of Banks (CAB) 42 Conference and Annual General Meeting (AGM) was deemed as important and should not be underestimated, especially at a time when the industry continues to be under increased scrutiny, said Prime Minister and Minister of Finance, Dr…. – Continue reading

U.S. Implementation of BEPS Changes Begins

As at least the first phase of the OECD’s BEPS project1 wound down with the October release of the “final” BEPS deliverables, questions remained regarding how much of the recommended changes would be implemented in the United States in the near term. Because many of the recommendations require legislative changes… – Continue reading

G-20 summit At Turkey: India has a lot to learn and deliver

The group, as a whole, will have to contend with adopting the BEPS framework and fulfilling the commitments made under the Brisbane Action Plan 2014 The tenth G-20 meeting at Antalya, Turkey, (that starts day after tomorrow) is gaining momentum. The challenges before the G-20 nations are many and varied…. – Continue reading

Canada to join G20 effort to limit ‘profit shifting’ by multinationals

Canada is expected to join other G20 countries to sign off on an international deal in Turkey aimed at cracking down on “profit shifting” by large multinational companies seeking to reduce their tax bills. The changes, which are also aimed at exposing the corrupt use of tax havens to launder… – Continue reading

Opening Bell: Ireland told not to rely on low taxes to grow, NAMA’s dispute with Dunnes, Draghi’s statement on Ireland

The Organisation for Economic Co-operation and Development’s (OECD) chief economist has warned that Ireland cannot rely on low corporation taxes to fuel growth. “Ireland is going to have to seek real investment based on comparative advantages other than tax,” Prof Catherine Mann told a conference hosted by the Irish Department… – Continue reading

OECD Warns Ireland That Growth Will Take More Than Just Low Taxes

Ireland has among the lowest taxes in Europe. However, the Organization for Economic Cooperation and Development (OECD) is not impressed. They warned Ireland that it will have to spend more time selling itself in the new era of global tax transparency if it wants to experience meaningful economic growth. OECD… – Continue reading

Modi, Obama unlikely to meet during G20 summit in Turkey

Both leaders recently discussed key bilateral issues on the new ‘hotline’ NEW DELHI, NOVEMBER 12: In a major deviation from earlier times, the much-publicised bilateral meeting between Prime Minister Narendra Modi and US President Barack Obama is unlikely to happen on the sidelines on the 10th G20 summit in Turkey…. – Continue reading

Report: Canada among biggest G20 losers in tax evasion

Ahead of a G20 meeting in Turkey this weekend that will tackle, among other issues, the GDP lost to global tax havens, the anti-poverty organization Oxfam is warning that it’s not just poor countries that suffer when corporations evade taxes. Julie Delahanty, Oxfam Canada’s executive director, says the only people… – Continue reading

LUXEMBOURG: “DAC 2” LEGISLATION INTRODUCED; CRS-LIKE REGIME

A bill submitted to the Luxembourg Parliament in November 2015 would transpose, into Luxembourg domestic law, an EU directive amending a 2011 directive for administrative cooperation and concerning the exchange of information on request. The directive (2011/16/EU) as amended, is referred to as “DAC 2” (the updated “directive on administrative… – Continue reading

INDIA: NO TRANSFER PRICING ADJUSTMENT WHEN TAX AVOIDANCE NOT POSSIBLE

The Mumbai Bench of the Income-tax Appellate Tribunal held that an Assessing Officer cannot “mechanically” refer a taxpayer’s international transactions to a Transfer Pricing Officer for a determination of the arm’s length price, but must first independently conclude that the taxpayer did not determine the arm’s length price or did… – Continue reading

Transparency International: G20 failing on corruption

Corporate corruption is still prevalent in rich Group of 20 nations despite their pledges last year to close loopholes, according to Transparency International. It has listed Brazil, China and the US among the offenders. Transparency International on Thursday labeled this weekend’s G20 summit in Turkey as a mere “photo opportunity,”… – Continue reading

MULTINATIONALS HIDING BILLIONS, SAYS REPORT

Tax: Luxembourg among countries helping US firms cut their tax bills by more than a quarter, campaigners say. The abuse of holding company structures in the Grand Duchy, and fiscal regimes in several other countries, allows American firms to avoid paying billions of dollars in corporate profit taxes, two NGOs… – Continue reading

Senegal president calls on West to fight tax evasion in Africa

VALLETTA) – Senegalese President Macky Sall called Thursday for multinationals to pay their fair share of taxes following a summit with EU leaders aimed at curbing the poverty fuelling mass migration to Europe. Sall also said Africans should receive a a fair price for their natural resources when he addressed… – Continue reading

Low taxes alone not enough for growth, says OECD

Chief economist says clampdown on tax avoidance will be ‘negative for Ireland’ Ireland will have to sell itself as more than just a low-tax destination in the new era of global tax transparency, OECD chief economist Catherine Mann has said. She said moves to better align taxable profits with real… – Continue reading

UK: Proposed Revisions To The US Model Income Tax Treaty

The US Treasury Department released proposed revisions to the US Model Income Tax Treaty (the ‘Model Treaty’); the proposed changes are intended to combat treaty abuse and deny treaty benefits in certain situations. The revisions to the Model Treaty include: (i) changes to the Limitation on Benefits provision which most… – Continue reading

Brazil lower house passes amnesty for unreported offshore assets

BRASILIA, Nov 11 (Reuters) – The lower house of Brazil’s Congress approved amnesty for undeclared offshore assets on Wednesday despite criticism from opposition lawmakers who said it would allow the laundering of illegally gained money. To reduce its budget deficit, President Dilma Rousseff’s government is hoping to raise 11 billion… – Continue reading

Green card may no longer be a valuable asset for NRIs as Fatca sword hangs over their heads

MUMBAI: A US passport doesn’t look like such a priced possession anymore. Some Indians even want to surrender their hard-won green cards. India and the US are set to freely exchange financial information about their citizens, leaving no asset concealed. This could mean US tax officials imposing punitive levies on… – Continue reading

Big Pharma’s deal-making zeal could be on the wane

A rout in pharmaceutical and biotech stocks has altered the equation for chief executives thinking about big-ticket mergers and acquisitions. On one hand, target companies are much cheaper than they were: roughly $130 billion has been wiped off the Nasdaq biotech index since Hillary Clinton, the Democratic presidential front-runner, pledged… – Continue reading

Becoming An Ex-American

According to the Star Spangled Banner, the United States is the land of the free and the home of the brave. So how come the number of Americans renouncing their citizenship is hitting new heights? More than three thousand people have given up their US nationality so far this year…. – Continue reading

UK: Common Reporting Standards: The Governments Want Even More Information– Is It Just Another Form Or Something More Sinister?

Some time ago we wrote an article on the Foreign Account Tax Compliance Act (‘FATCA’) which says that although the FATCA tentacles are fairly intrusive, at the end of the day, it represents just another form for tax payers to complete. Rather to my surprise this article elicited a threat… – Continue reading

BEPS and real estate investment funds: What are sponsors to do?

The final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) project were issued on 5 October (the “Reports”) after a two-year consultation period during which 62 countries and many other stakeholders (such as the World Bank, the IMF, and many trade associations) participated. These Reports, split into 15… – Continue reading

FATCA Reporting: Clients Using BearingPoint’s FiTAX Solution Successfully Reported All Around the World

Thanks to the FiTAX tax reporting solution, some 2,000 financial institutions successfully met the reporting requirements of tax authorities. FiTAX FATCA covers more than 45 countries. ZURICH, SWITZERLAND—(Marketwired – Nov. 12, 2015) – 2015 marks a turning point in the FATCA timeline: for the first time, Financial Foreign Institutions (FFIs)… – Continue reading

The Proposed Australian Multinational Anti-Avoidance Law — Leapfrogging the OECD’s BEPS Process to Devise a New Nexus Rule for Remote Sales

On September 16, 2015, the Australian government introduced into Parliament Tax Laws Amendment (Combating Multinational Tax Avoidance) Bill 2015, which contains, among other items (including the implementation of country-by-country reporting), the proposed legislative language to implement Australia’s version of the United Kingdom’s diverted profits tax. The bill was accompanied by… – Continue reading

Reforms to taxation of non-domiciled individuals: consultation published

Introduction On September 30 2015 Her Majesty’s Treasury published its long-awaited consultation on two of three proposed changes to the taxation of individuals domiciled outside the United Kingdom. The three measures – announced by Chancellor George Osborne in the 2015 Summer Budget published on July 8 – are intended to… – Continue reading

ANDY: IS OUR “ECONOMIC RECOVERY” BASED ON A SILICON BUBBLE?

Irish corporation tax returns are behaving oddly: the Department of Finance estimates that they are running €2 billion (74 percent) ahead of forecast for the year. Economist Seamus Coffey has described these figures as “very strange”. Coincidentally (or perhaps not) the global accounts of the Apple corporation revealed an increase… – Continue reading

Motor racing legend Alan Jones linked to serial conman Peter Foster

Australian motor racing legend Alan Jones has become embroiled in the collapse of an online gambling company operated by notorious conman Peter Foster which owes $11.5 million to about 150 investors. The 69-year-old former winner of the Formula One Drivers’ Championship was named in a writ to be lodged in… – Continue reading

Transfer pricing — the global phenomenon

THE world appears to be getting much smaller. Rapid technological advances, increased people mobility, and changes in the international political climate have all helped to break down many of the traditional barriers to global and regional trade. For dynamic, fast-growing businesses, this increased globalisation represents an excellent opportunity for businesses… – Continue reading

FATCA to promote tax transparency between India and US

Hyderabad: Customers of several public and private sector banks across the Telangana and Andhra Pradesh are finding fault with their bankers for asking to fill up more forms under Foreign Account Tax Compliance Act (FATCA), and Common Reporting Standard (CRS). The new rules have come into effect from November 1,… – Continue reading

Senior Tax Officials Meet To Discuss BEPS Project

On November 3-4, 2015, more than 260 senior tax officials from 102 jurisdictions and international organizations met to discuss the tax treaty-related outcomes of the OECD’s base erosion and profit shifting project. Participants at the 20th Annual Global Forum on Tax Treaties welcomed the tax treaty-related measures agreed upon in… – Continue reading

St Kitts & Nevis pursuing quiet diplomacy to recalibrate international relationships – PM Harris

The nine-month old Team Unity administration has been pursuing quiet diplomacy to recalibrate international relationships for the benefit of the people of St. Kitts and Nevis, reports SKN Vibes. So said St. Kitts and Nevis Prime Minister Dr. the Hon. Timothy Harris at last week’s press conference at government headquarters…. – Continue reading

Apple confident ahead of European Union tax judgement

Apple chief executive Tim Cook said he was feeling “pretty good” ahead of the European Union’s judgement on its Irish tax arrangements, as the company announced 1,000 new jobs in Ireland on Wednesday. Ireland’s tax arrangements with the US tech giant are under investigation by the EU to see if… – Continue reading

The Netherlands: Decree published approving an adjustment period for certain Advance Tax Rulings that will lose their validity because of a law change implementing the changes in the Parent Subsidiary Directive

On November 11, 2015 in the Dutch Staatscourant a Decree from the Dutch State Secretary for Finance containing an approval regarding an adjustment period for Advance Tax Rulings (ATRs) that will expire as a consequence of the entry into force of the Wet implementatie wijzigingen Moeder-dochterrichtlijn 2015 (Law implementing the… – Continue reading

EU calls corporations to account for low-tax deals

European Union lawmakers have called 13 multinational companies to a meeting next week to talk about the low-tax deals they have struck with EU jurisdictions, reports CBC News. Among the companies to be questioned on Nov. 16 will be Amazon.com, Disney, Coca-Cola Co, Anheuser-Busch InBev NV, HSBC Holdings, Ikea Group… – Continue reading

UK: CHANGES TO INTEREST DEDUCTIBILITY RULES, IMPLICATIONS FOR TRANSFER PRICING

Following the October 2015 release of the OECD’s base erosion and profit shifting (BEPS) deliverables, some consultations in the UK have already been opened—including one on the UK’s rules concerning the deductibility of corporate interest expense and how this treatment would be affected by BEPS Action 4 (which seeks to… – Continue reading

Anti-money laundering: NAEA awaits government response to call for action

The National Association of Estate Agents is awaiting a response from the government to its demand for four changes to sale and purchase processes in a bid to combat money-laundering. In one of the association’s first major statements on the issue since the Channel 4 From Russia With Cash documentary,… – Continue reading

Barbados, An “Ethical” Tax Haven?

The Caribbean island says its financial system is all aboveboard, yet it remains a gateway to less scrupulous offshore havens like the Cayman Islands. BRIDGETOWN — Is there “dirty” money strewn across the pristine sands of Barbados? Does something sinister hide beneath the glistening coral reefs of this former pirate… – Continue reading

The FATCA window

The implementation of the Foreign Account Tax Compliant Act is showing consistent progress with thousands of banks in over 150 countries agreeing to share financial accounts data of their US clientele with US taxation authorities. This clearly indicates the firm resolve of the US administration to make this initiative a… – Continue reading

International Tax Avoidance Still Problem

LONDON – Both developed countries and developing countries are loosing out on tax revenues due to a continued lack of progress in fighting international tax avoidance. Large multinational businesses are still using international tax rules to avoid paying taxes in the countries where they raise profits, according to information contained… – Continue reading

Transparency is best tonic for multinational tax avoidance

‘Special purpose’ approach by accountants hides corporate secrets Amid the maelstrom over the GST, the Senate last night passed what may be the most useful piece of legislation yet to combat multinational tax avoidance. The new law was not carried by the government, whose track record on tackling big tax… – Continue reading