With the adoption of the BEPS package, OECD and G20 countries, as well as all developing countries that have participated in its development, will lay the foundations of a modern international tax framework under which profits are taxed where economic activity and value creation occurs. Focus will now shift to… – Continue reading
Lawmakers on Tuesday complained of an ongoing ‘information blackout’ concerning the outflow of deposits in the midst of the 2013 banking meltdown. Politicians claim that, amid the confusion during the March 2013 haircut, companies and individuals whisked their deposits abroad, thus enabling them to avoid detection by tax authorities here,… – Continue reading
The Minister for Finance has announced that the Knowledge Development Box will be provided for in the Finance Bill. The measure was first signaled in Budget 2015. He said qualifying income would be subject to a reduced rate of corporation tax of 6.25%, half the regular corporate tax rate of… – Continue reading
AstraZeneca ($AZN) is not the first company to employ questionable tax-planning strategies, and it certainly won’t be the last. But the U.K.-based drugmaker is the latest poster child for tax avoidance. As The Guardian reports, AstraZeneca funneled billions of dollars into the Netherlands to get out of paying corporate taxes… – Continue reading
The tax world followed with great interest today´s launch of the final package of BEPS. Having the BEPS report finalized is indeed a great achievement and, as pointed out by Mr. Angel Gurría, OECD Secretary General, in his Twitter, “Agreement of #BEPS package is a historic day in our effort… – Continue reading
THE Government will introduce a new lower corporation tax rate in today’s budget in a bid to increase R&D investment and innovation. It is understood the new lower rate will only apply if a company agrees to a certain level of investment in research and development as part of the… – Continue reading
India and Israel will sign a double taxation avoidance pact and explore ways to ramp up engagement in diverse sectors during President Pranab Mukherjee’s three-day historic visit to the Jewish state, the first by an Indian Head of State, beginning tomorrow, reports NDTV. Ahead of his visit, Israel said the… – Continue reading
PwC welcomes this effort to update international tax system and boost transparency. The tax landscape has been transformed by the globalisation of business and the advent of the digital age. We believe the existing international tax rules need to be modernised to reflect how business is done today, and it… – Continue reading
A trial in Switzerland has been adjourned against Hervé Falciani, the former IT worker from the HSBC Private Bank in Geneva who leaked data about thousands of suspected tax evaders. Falciani, 43, now living in Spain, failed to appear in the Federal Criminal Court in Bellinzona in the canton of… – Continue reading
What has happened? On 5 October 2015, the OECD issued its final report on BEPS Action 4 – Limiting Base Erosion Involving Interest Deductions and Other Financial Payments (Paper). In this Alert we consider the main issues, recommendations and options for taxation reform raised in the Paper and consider the… – Continue reading
Authorities in China have been doubling their efforts since April to track down illicit assets exported overseas. The People’s Bank of China, the Ministry of Public Security, the Supreme People’s Court, the Supreme People’s Procuratorate, and the State Administration of Foreign Exchange have been working together in this operation. Chinese… – Continue reading
Swiss firms have bagged major business from global brands such as GSK, Novartis and Crédit Suisse this year, while their Asia ventures have come good. The legal minds behind the Glaxo-SmithKline and Novartis asset swap, global banking investigations, Schaeffler’s €2bn high yield bond issuance and Dufry’s £1.05bn takeover of Nuance… – Continue reading
Foreign companies entering the U.S. market for the first time will want to consider how their operations can be structured to minimize U.S. taxes. Although sales into the U.S. can be arranged in some cases to keep profits offshore, a sufficient presence ”on the ground” can pull sales income (and… – Continue reading
China has pledged to promote a plan to stop multinational companies from avoiding taxes by shifting profits to destinations with lower corporate tax requirements. The plan was endorsed by G20 finance ministers Friday during the annual meetings of the World Bank and the International Monetary Fund in Lima, Peru, reports… – Continue reading
The Government of India, Ministry of Finance had on August 7, 2015, in order to comply with the information reporting requirements of the US’ Foreign Account Tax Compliance Act (hereinafter referred to as ‘FATCA’), made amendments in the Income-tax Rules, 1962. WHAT IS FATCA’S BACKGROUND? FATCA is a broad set… – Continue reading
Developing countries must continue raising more in domestic taxes while taking advantage of wider efforts to combat tax evasion by multinationals, the IMF/World Bank annual meetings were told. Liz Ditchburn, director of policy at the UK’s Department for International Development, said initiatives such as BEPS (base erosion and profit shifting),… – Continue reading
The Greek Government has tabled the nation’s 2016 Budget, which includes measures agreed as part of the recently negotiated third bailout. A statement released by the Finance Ministry was vague about the measures proposed. However, it said that authorities will reform the VAT code, amend social security rates, raise corporate… – Continue reading
The US Internal Revenue Service has begun receiving data from foreign banks about US expats’ overseas bank accounts and is now sharing data with certain foreign tax authorities to also support their tax enforcement efforts. The first tax information exchanges on September 30, 2015, were facilitated by a platform put… – Continue reading
The Norwegian conservative government on 7 October 2015 published both the proposed state budget for 2016 and a “white paper” containing proposals for tax reform. The proposed tax reform in the white paper is a follow-up action from a report on tax reform, presented by the Tax Commission in late… – Continue reading
Ireland’s budget 2016 will be announced tomorrow, 13 October 2015, and it is expected that additional detail on the research and development (R&D) tax incentive known as the “knowledge development box” would be provided in the budget 2016 statement. The “knowledge development box” is a tax rate for income generated… – Continue reading
Group of Twenty (G-20) finance ministers have endorsed the final package of measures proposed by the OECD as part of its base erosion and profit shifting (BEPS) project. At a meeting on October 8, 2015, in Lima, Peru, the G-20 Finance Ministers said they remain commited to the rapid, widespread,… – Continue reading
Financial think tank and lobby group the New City Initiative has warned that regulation is destroying competition within the asset management industry. With several major regulatory changes due to be implemented in the next few years, the think tank has analysed the impact of the new rules on boutique asset… – Continue reading
KUWAIT: The Cabinet has called on ministers and senior officials of state bodies to submit their financial disclosure reports to the Anti-Corruption Authority as soon as possible. The call was made by the Cabinet during its customary weekly meeting held at Bayan Palace yesterday under chairmanship of HH the Prime… – Continue reading
Over 20 multinationals in Mexico should be paying tax, says Finance Secretary It has been dubbed “double non-taxation” and it’s an international practice that was the focus of discussion last week in Lima, Peru. It is also something that Mexico’s finance authorities want to see addressed. It was during a… – Continue reading
THAI property tycoon Khunying Sasima Srivikorn, who co-owns an English Championship football club, recommends the United Kingdom as the best location for offshore property investment after realising a double-digit yield from a recent investment in the country. Speaking at an exclusive forum recently held by Tisco Wealth and Forbes Thailand,… – Continue reading
Both internal and external factors threaten politics, economics Hong Kong’s run of good luck is running out. One obvious sign is the increasing interference of Beijing in its domestic affairs, most recently using tame Chief Executive C.Y. Leung and a clique of yes-men to interfere in a senior academic appointment… – Continue reading
THE ADVANTAGES OF JERSEY For high net worth individuals considering a relocation, there are a number of factors that will be weighed up in making a choice which is right for both the head and the heart. To be a serious contender, a jurisdiction must certainly be fiscally friendly. But… – Continue reading
EBENE, Mauritius, Oct 12 (Reuters) – Mauritius plans to launch a trading platform to hedge African currencies against the U.S. dollar, part of a bid to expand its role as a financial hub for the continent, the financial services minister said. The Indian Ocean island is also in talks to… – Continue reading
A blistering attack on major countries who brand offshore financial centres as tax havens has been launched by Bob Richards. The Minister of Finance warned that pressure on the offshore sector from abroad will continue into the foreseeable future. Mr Richards, speaking at the launch of a British Virgin Islands… – Continue reading
At a recent tax conference a senior Justice Department official reaffirmed the commitment of the U.S. Department of Justice to continue offshore enforcement efforts. As is widely reported the official stated: “We are well beyond Switzerland at this point,” she said, citing enforcement announcements concerning India, Israel, Liechtenstein, Panama, the… – Continue reading
Historically, unlike UK residents who are generally liable to CGT on disposals of UK residential property (other than their principal residence), non-residents have been able to dispose of such property potentially free from UK CGT. The UK government sought to address this inconsistency by introducing a CGT charge in the… – Continue reading
At the beginning of the week, the Organization for Economic Cooperation and Development—an international organization founded to advise industrial nations on economic policy—proposed a plan to address what has become an important international issue: tax avoidance. The OECD, in response to a request to look at the tax rules international… – Continue reading
A former head of Australia’s anti-money-laundering agency wants tough rules introduced to prevent the country from becoming a safe haven for foreign corrupt funds. Despite credible warnings that large volumes of illicit money leaving China are being laundered in Australia, an investigation by ABC programme Four Corners has found no… – Continue reading
G20 finance ministers have endorsed a package of measures to tackle corporate tax avoidance, but questions remain about whether certain countries will follow through on the plans or leave loopholes multinationals can exploit. The ministers agreed to back proposals drawn up by the OECD, which aim to shake up rules… – Continue reading
NEW DELHI: Within days of getting a favourable verdict in the Rs 8,500 crore transfer pricing case from the Bombay High Court, Vodafone Group CEO Vittorio Colao will call on Finance Minister Arun Jaitley this week. Colao will visit India on October 14 and is scheduled to meet Jaitley the… – Continue reading
(Ferenstein Wire) – Big tech companies are safeguarding billions of dollars in offshore tax havens, according to a new study. Apple alone, the biggest offender, is stashing $181 billion in revenue with an estimated tax burden of $59.2 billion. In other words, Apple’s taxes could pay for nearly the entirety… – Continue reading
Staff at Facebook’s UK arm took home an average of more than £210,000 last year in pay and bonuses, while their employer paid just £4,327 in corporation tax. Facebook made an accounting loss of £28.5m in Britain in 2014, after paying out more than £35m to its 362 staff in… – Continue reading
To solve the problem of the haze afflicting Singapore, Indonesia and Malaysia, extraterritorial action is needed to quench the forest fires in Indonesia that are generating the haze. A cross-border solution is a necessary answer even if it raises questions of national sovereignty. The Singapore Government should implement laws that… – Continue reading
The OECD’s base erosion and profit shifting (BEPS) final reports that focus on transfer pricing are comprised of a number of updates to different parts of existing OECD transfer pricing guidance. In particular, BEPS Actions 8-10 are designed to provide that transfer pricing outcomes are aligned with value creation, and… – Continue reading
The UK government released draft regulations for country-by-country (CbC) reporting, to implement Action 13 of the OECD’s base erosion and profit shifting (BEPS) project. The draft UK regulations broadly reflect the OECD reports, released 5 October 2015, and specifically make reference to the model legislation. Key points of the CbC… – Continue reading
Merely because exemption has been granted under the Indian Income Tax Act, foreign tax credit cannot be denied The Karnataka High Court, in the case of Wipro Ltd, apart from other substantial questions on law, has held that tax credit for the income tax paid in a foreign jurisdiction shall… – Continue reading
The Government has expressed a commitment to improving levels of UK corporate transparency but a recent Private Eye article [1], documenting the extent of ownership of British Land through offshore entities, shows just how far there is to go. By far the most common reason for owning UK property through… – Continue reading
The Cayman Islands Tax Information Authority is moving forward with its plans for implementing the OECD Common Reporting Standard (CRS). The Cayman Islands was a signatory to CRS when released in October 2014. he Cayman Islands tax authority in September 2015 released a draft version of regulations—Tax Information Authority (International… – Continue reading
The CBDT has clarified that MAT provisions will not be applicable to those FIIs /FPIs which do not have a permanent establishment in India, for the period prior to 1 April 2015. An amendment to the IT Act will be made in the winter session of Parliament and directions have… – Continue reading
The hedge fund trade to gain exposure and then encourage a U.S. corporation to enter into an acquisition transaction with a foreign corporation where it incorporates internationally to lower its tax burden, known as a corporate inversion, might have slowed of late, but the issue is now being addressed at… – Continue reading
Keen to put in place a system to prevent international tax evasion and avoidance, Finance Minister Arun Jaitley, in the Commonwealth finance ministers’ meeting has reiterated the need for global implementation on a fully reciprocal automatic exchange of tax Information under Common Reporting Standards. Jaitley welcoming the final guidelines on… – Continue reading
Oct. 7 — The IRS offered two-pronged guidance on the effective dates of agreements for entities that apply on or after April 1 to be withholding foreign partnerships or withholding foreign trusts under the Foreign Account Compliance Act. In general, the Internal Revenue Service said Oct. 7, entities that apply… – Continue reading
As a newly-elected Australian lawmaker a decade ago, Malcolm Turnbull wrote an unsolicited 52-page proposal to reform the tax system. The report and its 281 recommendations were dismissed by the government and his costings called into question. Now, a month after replacing Tony Abbott as leader of the world’s 12th-largest… – Continue reading
NEW YORK, Oct. 9, 2015 /PRNewswire/ — KPMG’s Tax Governance Institute (TGI) will examine the final recommendations from the Organisation for Economic Co-operation and Development (OECD) on Base Erosion and Profit Shifting (BEPS) and discuss what they could mean for U.S. multinationals during a live video webcast on Tuesday, Oct…. – Continue reading
On October 2, 2015, the U.S. Internal Revenue Service (IRS) announced the exchange of financial account information with certain foreign tax administrations in compliance with their obligations under various intergovernmental agreements (IGAs) put in place to implement the Foreign Account Tax Compliance Act (FATCA). IRS Commissioner John Koskinen stated that… – Continue reading
