Category: Activity

FRANCE: STATUS OF TRANSFER PRICING DOCUMENTATION, COUNTRY-BY-COUNTRY REPORTING

Legislative proposals being considered in France would require the automatic filing of transfer pricing documentation and, as part of this documentation, country-by-country reporting. STATUS OF PROPOSALS The Finance Committee of the French National Assembly has started its consideration of tax provisions relating to the second part of the Finance Bill… – Continue reading

Implementation problems in connection with the FATCA Agreement

The BMF has application letter sent to the chief financial authorities of the countries associated with the between the Federal Republic of Germany and the United States of America concluded by 31.5.2013 FATCA Agreement. Background Background of extensive, comprehensive 71 pages, application letter from the Federal Ministry of Finance on… – Continue reading

Congressman Introduces Bills to Curb Corporate Tax Inversions and Deferrals

Rep. Mark Pocan, D-Wis., has introduced two pieces of legislation to combat corporate tax inversions and tax deferral. The Corporate Fair Share Tax Act and the Putting America First Corporate Act would prevent corporations from using “tax inversions” to reduce a company’s U.S. tax burden and hide profits overseas. Corporate… – Continue reading

Countries Agree Common VAT Rules For Digital Services

Representatives from more than 100 countries and jurisdictions have endorsed new OECD International VAT/GST Guidelines, which are intended to establish international standards for the “coherent and efficient” application of value-added tax (VAT)/goods and services tax (GST) to the international trade in services. The countries endorsed the new guidelines at the… – Continue reading

Gov’t approves support for SMEs until 2020

Transportation and other issues also taken up by the Cabinet Prague, Nov 9 (ČTK) —The Czech government today approved the Industry and Trade Ministry’s program Expansion, under which Kč 9.5 billion (€350 million) should be provided in support of small and medium-sized enterprises until 2020, Deputy Prime Minister Pavel Bělobrádek… – Continue reading

Democrat targets corporate tax-avoidance deals in U.S. Congress

Tax-driven “inversion” deals that let companies flee the U.S. tax system by relocating abroad, if only on paper, would be curbed under legislation introduced in Congress, as Pfizer Inc (PFE.N) pursues such a deal with rival Allergan Plc (AGN.N). Wisconsin Democratic Representative Mark Pocan’s bills likely have little chance of… – Continue reading

deVere Group CEO Slams FATCA, “Fiscal Imperialism”

The chief executive of one of the world’s largest independent financial advisory organizations unambiguously condemned the Foreign Account Tax Compliance Act in a recent series of comments. deVere Group CEO Nigel Green likened the act, which went into effect in July 2014, to a “masterclass in fiscal imperialism and the… – Continue reading

How to Curtail Offshore Tax Avoidance

In a time of fiscal austerity, it is breathtaking to learn that Congress has allowed Fortune 500 companies to avoid an estimated $620 billion in federal taxes on earnings they are holding offshore. While the inaction by lawmakers on this issue may create the impression that there is nothing to… – Continue reading

Billionaire Dart Reinvents Himself as Cayman Islands Land Baron

Two decades after Ken Dart renounced his U.S. citizenship and took his tax attorney with him to the Caribbean, the billionaire bond investor and local kingpin is reinventing himself as the Cayman Islands’ biggest real estate owner. In a rare glimpse into Dart’s holdings, Mark VanDevelde, chief executive of the… – Continue reading

Taka continues to fall against dollar

The taka has continued to fall against the dollar for two weeks now after nearly one year of an unchanged exchange rate, according to data from the Bangladesh Foreign Exchange Dealers’ Association. “Market forces are determining the exchange rate,” said Kazi Sayedur Rahman, general manager of Bangladesh Bank’s foreign exchange… – Continue reading

Former Manchester United and Arsenal stars ‘face ruin’ after failed investments reaching £100m

The company at the centre of the revelations denied any wrongdoing Some of the best-known names in British football face losing millions of pounds after being allegedly advised to invest in “risky” projects that have subsequently failed or were hit with tax bills. Rio Ferdinand and Andy Cole, both former… – Continue reading

Deloitte Poll: US Business Executives Cite Concerns and Priorities for OECD’s Final BEPS Package

NEW YORK, Nov. 9, 2015 /PRNewswire/ — Business executives cited an increased compliance burden as their biggest concern with the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting initiative (37.7 percent), according to an October Deloitte poll. Other concerns included double taxation of income (17 percent) and… – Continue reading

Transfer pricing drains us of tax blood

Transfer pricing by multinationals has cost South Africa an estimated R250 billion over three years and, with it, lost tax revenue. This is according to Sunia Manik, group executive for the large business centre at the SA Revenue Service (Sars), adding that it was being done through “service payments” made… – Continue reading

The ‘end’ of tax evasion

The UK is one of several countries to introduce voluntary disclosure schemes. More people are coming forward to regularise their affairs as they realise there is nowhere left to hide in this new world of tax transparency. Tax authorities and financial institutions are gearing up for the new automatic exchange… – Continue reading

Full faith in India on tax treaty revision: Mauritius

NEW DELHI: Dismissing apprehensions of Mauritius being used to route black money as “misconception”, its Prime Minister Anerood Jugnauth has termed the issue as an aberration in the “very special” ties with India and hoped that revision of their tax treaty won’t harm its interests. Stating that Prime Minister Narendra… – Continue reading

Cash-strapped small firms may get slice of the patent box action

Small and medium-sized businesses that don’t have the resources to patent intellectual property may still be able to benefit from the Knowledge Development Box (KDP) under plans being considered by the Government. The Department of Finance is looking at allowing SMEs with patentable assets, but without the resources to get… – Continue reading

Europe May Not Be a Tax Haven for U.S. Multinationals Much Longer

FRANKFURT (The Street) — Europe’s allure as a tax haven for U.S. multinationals may be coming to an end. That’s because European Union regulators are closing up tax loopholes that U.S. companies have been enjoying for years. The first two to feel the heat are Starbucks (SBUX – Get Report)… – Continue reading

Clubs Australia and AGA Partner Against Illegal Gambling

Clubs Australia and the American Gaming Association (AGA) to Join Forces to Table Illegal Online Gambling Trade Association Clubs Australia made recent headlines releasing a statement that confirms its partnership with the American Gaming Association to tackle an ongoing problem that has created an analogous situation with the ‘Wild West’…. – Continue reading

Tax-avoidance Gibraltar firm behind anti-EU campaign group

Leave.EU, supported by Ukip and financed by a multimillionaire, vies to lead Britain’s exit from Europe A leading campaign group seeking to take Britain out of the European Union was set up by an offshore company that offers tax avoidance services to “high net worth individuals”, the Observer can reveal…. – Continue reading

Poor Oversight Fuels Corruption in Sports Federations – Transparency Int’l

The opaque governance structure of sports federations makes them less accessible to independent oversight and therefore more prone to corruption, the deputy managing director at Transparency International, a global anti-corruption movement, told Sputnik. ST. PETERSBURG (Sputnik) – Earlier this year, separate investigations by US and Swiss prosecutors uncovered deep-rooted corruption… – Continue reading

Tax system slow to adapt to digital economy’s rise

LOST REVENUE:A lack of regulations on taxing cross-border Web-based content and services providers puts their local peers at a disadvantage, Ernst & Young said The nation’s tax system is relatively behind developed markets in adapting to the proliferation of the digital economy, which has resulted in lost revenues for the… – Continue reading

Canada: ACB Adjustments For Foreign Affiliate Shares Held Through Partnerships

Recent CRA comments at the May 2014 IFA international tax seminar1 and a subsequently released CRA technical interpretation2 highlight anomalies in the application of subsections 92(4) and (5) of the Income Tax Act (Canada) (the “Act“).3 These provisions address the situation where shares of a foreign affiliate are held by… – Continue reading

Commentary: In face of ‘tax haven’ attack, CARICOM must unite

No member state of the Caribbean Community (CARICOM) ranks among the top 20 jurisdictions worldwide for financial secrecy. The United States of America (at number 3), Germany (8), Japan (12) and Britain (15), all rate as bigger tax havens than any CARICOM jurisdiction, according to the Tax Justice Network (TJN),… – Continue reading

US fuss about Irish tax deals just election fever, says ex-Apple CEO

The recent corporation tax controversy highlighted by US presidential hopefuls Hillary Clinton and Donald Trump is not damaging Ireland’s reputation as a place to do business, said the former chief executive of Apple, John Sculley. According to Mr Sculley, the controversy is simply part of US election fever. Known as… – Continue reading

Notice 2015-66 is received with welcome relief

On September 18, 2015, the Internal Revenue Service (IRS) released Notice 2015-66 announcing its intention to amend certain of the regulations under Chapter 4 of the Code (the “FATCA regulations”), to extend the period of time that certain of the Foreign Account Tax Compliance Act (FATCA) transitional rules will apply,… – Continue reading

In face of ‘tax haven’ attack, CARICOM must unite | Sir Ronald Sanders

ST. JOHN’S, Antigua, Friday November 6, 2015 – No member state of the Caribbean Community (CARICOM) ranks among the top 20 jurisdictions worldwide for financial secrecy. The United States of America (at number 3), Germany (8), Japan (12) and Britain (15), all rate as bigger tax havens than any CARICOM… – Continue reading

Bleak growth exposes malaise of revenue shortfalls

First it was the scourge of public sector corruption, until now the mortifying spectacle of South Africa’s post-apartheid transition. Now, with the ground shifting beneath the world’s sclerotic economy – and the past few years have produced more tremors than ever in the 21 years of democracy – it’s a… – Continue reading

Minister Calle explains solidarity tax

MINISTER of finance Calle Schlettwein said yesterday that the solidarity tax will be introduced as an income tax for individuals according to their income scale. He said the tax will also be a flat amount levied from juristic persons (closed corporations, partnerships, trusts and companies), based on the average per… – Continue reading

Schroder Real Estate taps into hunger for offshore investment

Plans to list its European REIT on the JSE. Feeding South Africans’ seeming insatiable desire for rand-hedge stocks, Schroder Real Estate is planning to launch a European Real Estate Investment Trust (REIT), which will have a primary listing on the London Stock Exchange with a secondary listing on the Johannesburg… – Continue reading

POLAND: EXPANDED TRANSFER PRICING, COUNTRY-BY-COUNTRY REPORTING ENACTED

New law in Poland expands the requirements for transfer pricing documentation, and includes country-by-country (CbC) reporting. The new provisions essentially reflect the recommendations made in Action 13 the OECD’s base erosion and profit shifting (BEPS) project, and provide for CbC, master file and local file reporting. The legislation was passed… – Continue reading

OECD BEPS Heralds Big Changes for Tax Pros and Corporate Treasurers

The Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting action plan is likely to have a major impact on tax planning at multinational corporations by both tax professionals and corporate treasurers. Tom Driscoll, U.S. managing partner for international tax, transfer pricing, and indirect tax at Deloitte Tax… – Continue reading

Marco Rubio’s Billionaire Backer Likes to Sue Poor Countries and Put Profits in Tax Havens

Paul Singer has a good track record as a money manager. In 1995, he bought $20 million worth of Peruvian debt at a discounted price of $11.4 million, then forced Peru’s government, through lawsuits, to eventually pay nearly five times his initial investment — some $58 million. In 2002 and… – Continue reading

Victims of conman Peter Foster hunt missing millions

Exclusive More than 100 victims of notorious conman Peter Foster have moved to freeze funds held in offshore tax havens after more than $10 million was siphoned from his online gambling company Sports Trading Club. Fairfax Media can reveal Foster and at least eight associates have been served with freezing… – Continue reading

Germany: tax court prevents tax office from exchanging information with E6 countries in relation to digital economy

On September 7, 2015, the local tax court of Cologne (the “Court”) issued an injunction against the German Federal Central Tax Office (“FCTO”) to prevent the FCTO from conducting a coordinated exchange of information with the E6 countries Canada, Great Britain, France, Australia and Japan, which aimed at gathering intelligence… – Continue reading

BEPS and funds

On 5 October 2015 the OECD published the final package of recommendations to reform the international tax system – the “BEPS” Project. Base Erosion and Profit Shifting (BEPS) refers to tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations… – Continue reading

Abolition of Luxembourg IP box regime

On 14 October 2015, the Luxembourg Minister of Finance presented a bill to Parliament on the state budget for 2016. This bill contains several proposals affecting corporate taxpayers. One of the main proposals is the abolition of the intellectual property regime. Similar tax relief systems, known as “IP box” or… – Continue reading

Canada: Income And Other Taxes

In Canada, taxes are levied at the federal, provincial and municipal levels of government. At the federal level, the government generates most of its revenue by way of income taxes and excise taxes imposed on the distribution and consumption of goods and services in Canada. The provinces and territories also… – Continue reading

Knowledge Development Box – to encourage more innovation

Since Minister Noonan announced in October 2014 that Ireland would introduce a “best-in-class” Knowledge Development Box (“KDB” ), there has been a lot of speculation about ‘how low would he go’. Budget 2016 announced that the rate of tax which will apply for income qualifying under the new KDB will… – Continue reading

‘SA is bleeding billions’

JOHANNESBURG – South African has lost R250 billion in the form of service payments over a three-year period, highlighting the significant risk base erosion and profit shifting (BEPS) is posing to the country’s tax base, a South African Revenue Service (Sars) official has said. Almost R80 billion of this were… – Continue reading

GERMANY: FINAL GUIDANCE NOTES, IMPLEMENTING FATCA

Germany’s Federal Ministry of Finance on 3 November 2015 released final guidance notes for implementation of the FATCA regime. An intergovernmental agreement (IGA) signed by Germany and the United States follows the Model 1 IGA. Accordingly, financial institutions in Germany are required to report information concerning assets held by U.S…. – Continue reading

AUSTRALIA: ARE INVESTMENT ENTITIES EXCLUDED FROM “GROUP” FOR COUNTRY-BY-COUNTRY REPORTING?

A question being considered in Australia—concerning country-by-country (CbyC) reporting—is whether an investment entity is to be excluded from the “group” for CbyC reporting purposes. A preliminary position being advanced is when an entity is not required to prepare consolidated financial statements for financial reporting purposes, then it would be excluded… – Continue reading