Orica has again found itself at odds with the Australian Taxation Office, this time over the circular financing arrangements the explosive maker put in place in 2002 to improve profits for the then struggling group. Orica has disputed the amended tax assessment from the ATO in relation to its “round-robin”… – Continue reading
(Bloomberg) — The People’s Bank of China is considering starting direct trading between the yuan and the Swiss franc, according to three people with direct knowledge of the matter. The Swiss franc would become the seventh major currency to be exchangeable directly for yuan in Shanghai, joining the U.S., Australian… – Continue reading
Ireland is growing as a global maritime business hub and its strengths in asset leasing could provide an alternative source of finance for shipping, according to a new report commissioned by the Irish Maritime Development Office and authored by tax advisors KPMG and legal firm Dillon Eustace, reports Splash. The… – Continue reading
With Medtronic being one of Ireland’s largest employers, analysts say there is a new incentive for the medical device maker to prioritize its Dublin headquarters for R&D. In the eyes of developed nations, Ireland has become notorious for baiting multinational firms to its land with the offer of friendly tax… – Continue reading
The Internal Revenue Service (IRS) has released a revised October 2015 version of its Publication 597, which provides information on the United States-Canada double taxation agreement (DTA), reports Tax News. A number of DTA provisions that most often apply to US citizens or residents who may be liable for Canadian… – Continue reading
In a summary judgment released on September 16, 2015, the Federal Court of Canada examined and disposed of the non-constitutional arguments in the Hillis and Deegancase[1] generally finding that the automatic data collection and disclosure of taxpayer information to the United States by Canada pursuant to the Canada-U.S. Intergovernmental Agreement… – Continue reading
Extensive use has been made of trusts in South Africa, both for tax planning and for the purposes of reducing (or eradicating) one’s estate duty liability upon death. As the use of offshore trusts as a estate and wealth planning vehicle increases, one needs to consider if and how offshore… – Continue reading
NEW DELHI: The Vodafone Group has started “preparatory work” for an initial public offering of its Indian unit, although no dates have been set yet, the British telecom company’s CEO said, expressing optimism about the emergence of a new India. Vodafone CEO Vittorio Colao, however, argued against the government’s proposal… – Continue reading
SOON, THAILAND will no longer have mere transfer-pricing guidelines in the form of Departmental Instruction Paw 113/2545, but will instead put into effect a transfer-pricing law, the draft of which was approved by the Cabinet in May. Taxpayers will of course be required to abide by the new law. There… – Continue reading
Golden visa EU citizens may freely register as residents in Portugal. However, non-EU citizens may also obtain residence in Portugal if they obtain a ‘golden visa’ by participating in investment activity and fulfilling certain requirements. Requirements Obtaining a golden visa requires one of the following types of investment: acquisition of… – Continue reading
Permanent Establishment Based on the new treaty the definition of permanent establishment also includes a building site or construction or installation project or any supervisory activities in connection with such site or project constitutes a permanent establishment only if it lasts more than 9 months. Dividends The withholding tax rate… – Continue reading
Finance professionals will play a key role in dealing with changes brought about by a global project to combat corporate tax avoidance. A GLOBAL effort to tackle the problem of companies that attempt to reduce their tax burden by exploiting loopholes in tax rules will impact the way global businesses… – Continue reading
The Canada Revenue Agency (CRA) rents office space from a Vancouver-based property developer – a company that exploits offshore tax havens in Liechtenstein, the British Virgin Islands and Channel Islands. Larco Investments Ltd. owns three buildings in Montreal, Calgary and Edmonton where they rent office space to the CRA. Larco… – Continue reading
The Treasury Inspector General for Tax Administration has generally praised the US Internal Revenue Service for its implementation of the Foreign Account Tax Compliance Act. To improve US taxpayer compliance in reporting foreign financial assets and offshore accounts, Congress passed FATCA in March 2010. FATCA is intended to ensure that… – Continue reading
In just over two months, thousands of U.S.-based financial institutions will face new requirements for sharing financial information. These businesses should get ahead of the deadline and start preparing for the impact these rules will have on their operations and bottom lines. The Organisation for Economic Co-operation and Development’s new… – Continue reading
MINSK, 15 October (BelTA) – The House of Representatives of the National Assembly of Belarus ratified the Belarus-Georgia intergovernmental agreement on avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and capital on 15 October, BelTA has learned. It is expected that the agreement… – Continue reading
The Dutch government presented its Tax Bill 2016 on 15 September 2016. Three elements of this bill could specifically affect multinationals, international investors and investment funds with Dutch headquarters or group companies: The anti-avoidance rules in respect of non-resident taxation of foreign corporate shareholders and the dividend withholding tax treatment… – Continue reading
This summer brought some very significant amendments to the Cyprus tax laws, further enhancing Cyprus’ favourable tax regime. On 17 July 2015, the following laws were amended: The Special Defense for Contribution law No. 117(I) of 2002 as amended; The Income Tax Law No 118(I) of 2002 as amended; and… – Continue reading
As Noonan moves to stimulate domestic growth we need to think about the global debate The Irish economy is now in better shape than at any time since the beginning of the financial crisis. After many years of tough austerity measures, last year’s budget marked a turning point where Minister… – Continue reading
The chief of the generic drug company discussed her “counterintuitive” strategy for creating U.S. jobs. Mylan is one of a handful of U.S. companies that has recently completed a controversial tax inversion, as the generic drug company moved its official base to the Netherlands earlier this year. While the decision… – Continue reading
Individuals and families whose tax plans include trusts should take note of the recent decision of the Supreme Court of Newfoundland and Labrador in Discovery Trust v Minister of National Revenue (“Discovery Trust”)1 – the first case to deal with the issue of the residency of a trust for provincial… – Continue reading
A series of recent developments means that tax is now a key part of the Australian foreign investment regime and the foreign investment rules have significantly more bite. When determining whether a foreign investment proposal is “contrary to the national interest”, the Foreign Investment Review Board (FIRB) actively considers the… – Continue reading
David Gauke, the Financial Secretary to the UK Treasury, has said that international agreement on the OECD’s base erosion and profit shifting (BEPS) reports “is just the start of the process of reform.” In a speech to EY’s 34th Annual International Tax Conference, Gauke said: “To ensure timely, effective implementation,… – Continue reading
Last week’s OECD release of the final package of measures for a coordinated international approach to the reform of the international tax system, under the OECD/G20 base erosion and profit shifting (BEPS) project, marks the end of the discussion and recommendation phase, and the start of the implementation and practical… – Continue reading
The TIGTA audit was initiated to assess the IRS’s progress in implementing the FATCA. WHAT TIGTA FOUND TIGTA found that the IRS has taken steps to provide information to affected stakeholders that Tigtalogo explains the FATCA requirements and expectations. However, TIGTA identified improvements that are required to ensure compliance and… – Continue reading
The Guernsey Association of Compliance Officers (GACO) October seminar covered the introduction of the Information Gateway Online Reporter (IGOR), an online portal for the purpose of collecting and exchanging Automatic Exchange of Information. https://igorforum.digimap.gg GACO chairman and Carey Olsen partner Mark Dunster said it is a key objective for the… – Continue reading
The Algeria and the United States signed Tuesday in Algiers an intergovernmental agreement on the sharing of tax information between the two countries and to promote financial transparency and the strengthening of bilateral and international fight against tax evasion. The agreement, first of its kind concluded by the US with… – Continue reading
Bern, 14.10.2015 – Today, the Federal Council adopted the dispatch on the new double taxation agreement (DTA) with Oman and submitted it to Parliament for approval. The agreement will promote bilateral economic relations and contains provisions on the exchange of information upon request in accordance with the OECD standard. Aside… – Continue reading
FATCA was passed to prevent U.S. citizens from evading tax by focusing primarily on foreign financial institutions with U.S. account holders. The Foreign Account Tax Compliance Act (FATCA) was enacted as part of the 2010 Hiring Incentives to Restore Employment Act, and its provisions became effective as of 7/1/14. FATCA… – Continue reading
Tax experts from the United States, United Kingdom, Canada, Brazil and Israel spoke at a two-day conference at Michigan Law about the challenges of the Foreign Account Tax Compliance Act (FATCA) and a multitude of other issues at the intersection of the law of taxation and citizenship. Panel discussions at… – Continue reading
On 15 September 2015, the Bulgarian Council of Ministers submitted to the Bulgarian Parliament a proposal to implement the US Fair and Accurate Credit Transactions Act (FATCA) through changes in the Bulgarian Social Security Code. The proposed changes will effectively lead to the creation of an automated system for transfer… – Continue reading
To facilitate the exchange of Foreign Account Tax Compliance Act (FATCA) data under the intergovernmental agreements (IGAs) with Australia and the U.K., the U.S. Competent Authority has signed Competent Authority Arrangements (CAAs) with the Competent Authority of each country, announced IRS officials on September 24. The CAAs are the first… – Continue reading
Labor has accused Prime Minister Malcolm Turnbull of not playing by the same rules as the rest of the country by investing in funds based in a notorious tax haven. The attack was launched by Labor senator Sam Dastyari who used parliamentary privilege to accuse the prime minister of inappropriate… – Continue reading
Central Board of Direct Taxes (CBDT) chairperson Anita Kapur today said that the new black money law, which is intended to be harsh, will help clear the menace that had not been able to address the problem for many years. Kapur, who inaugurated the 12th International Tax Conference organized by… – Continue reading
Thanks to an agreement between the Department of Revenue’s Tax Administration Service (SAT) from September 30, all information regarding Mexicans with bank accounts in the United States and American citizens with bank accounts in Mexico agreement is being mutually sent. During the monthly breakfast Coparmex, the tax lawyer Jorge Alberto… – Continue reading
MUMBAI: The Central Board of Direct Taxes (CBDT) on October 13 signed four unilateral advance pricing agreements (APAs), including India’s second APA with a rollback provision. The nature of the transactions covered under these agreements varied from software development to share price valuation. According to government sources, the total number… – Continue reading
Ireland will introduce a new lower tax on intellectual property to keep and win more overseas investment as the government phases out a controversial loophole known as the “Double Irish.”, reports Bloomberg. The new knowledge development box will tax profits from patented innovations such as technological and pharmaceutical developments at… – Continue reading
The use of tax havens is ubiquitous across America’s 500 largest companies. Collectively, they hold $2.1 trillion in offshore cash, according to a recent study by Citizens for Tax Justice and the U.S. PIRG Education Fund. Establishing foreign subsidiaries in places with little or no tax such as Bermuda or… – Continue reading
The Organization of Economic Cooperation and Development (OECD) released its final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) Project on Monday October 5th, 2015. The final package of BEPS measures includes new minimum standards on: country-by-country reporting, which for the first time will give tax administrations a… – Continue reading
The National Assembly member (NAM) for Foni Bintang Karanai constituency has said that during the recent annual general meeting (AGM) of African Parliamentarian Network on Illicit Financial Flows and Tax (APNIFFT) held in Entebbe, Uganda, African parliamentarians present had applauded the Public Accounts Committee and Public Enterprises Committee (PAC/PEC) of… – Continue reading
The number of letter box companies in the Netherlands continues to grow, despite both mounting criticism and tougher rules aimed at combating tax evasion, the Volkskrant said on Tuesday. The number of letter box firms – so called because they only exist on paper – rose 17% to 14,425 over… – Continue reading
MUMBAI: Several multinationals, including Indian companies with a global presence, have initiated impact assessments to identify and fix potential problems in their tax reporting when countries start implementing a new international standards to check tax avoidance by multinationals. The Organisation for Economic Co-operation and Development (OECD) last week released the… – Continue reading
x Australian Prime Minister Malcolm Turnbull announces his new federal cabinet during a media conference at Parliament House in Canberra, Australia, September 20, 2015. Australia got its fifth prime minister in as many years on Monday after the ruling Liberal Party voted to replace Abbott with former investment banker Malcolm… – Continue reading
No focus on stock markets and other money-laundering machines After all the noisy assertions, only Rs4,147 crore of unaccounted wealth was declared during the special 90-day compliance window of the The Undisclosed Foreign Income and Assets (Imposition of Tax) Act, 2015 (Black Money Bill). Of this, just Rs2,488 crore will… – Continue reading
In 2014, seven major tech groups in Spain Declared collective profits of € 48.2 million, on Which They paid € 18.3 million in taxes. These online giants Real Their reduced corporate profits-through complex legal structures and accounting techniques That allowed them to shift part of the profits from Spain to… – Continue reading
Companies around the world are scrambling to overhaul how they communicate with the public when it comes to how much tax they pay, according to professional services firm KPMG. While the Senate is currently investigating multinational firms such as Apple and Google over potential tax avoidance, other countries are also… – Continue reading
Ireland, whose corporate tax rate of 12.5 percent is already one of the lowest in the developed world, said it would cut that rate in half for a new tax category — one covering revenue pegged to companies’ patents and other intellectual property. The Irish government, long criticized by other… – Continue reading
The OECD has finally released its long-expected set of reports regarding its Base Erosion and Profit Shifting (BEPS) project. Reducing the number of action points from 15 to 13, the OECD presented recommendations and common responses to align international tax rules and tackle base erosion and profit shifting. All recommendations… – Continue reading
The Internal Revenue Service has made progress on implementing the Foreign Account Tax Compliance Act, including explaining the various requirements to the affected stakeholders, according to a new report. The report, from the Treasury Inspector General for Tax Administration, examined FATCA, which was included as part of the HIRE Act… – Continue reading
Israeli importers and exporters, hi-tech and trading groups will all be in the base erosion and profit shifting firing line. On October 5 the Organization for Economic Cooperation and Development published a final comprehensive package of measures aimed at multinational corporations, large and small, that engage in BEPS – base… – Continue reading
