The OECD’s measures to reform international corporate tax systems will cause Ireland fewer problems than forecast, but for eurozone countries it will be just the beginning of greater and more detailed change. Following two years of constant meetings between tax experts from its 34 country members, the Paris-based body releases… – Continue reading
On Monday (5 Oct) the Paris-based Organisation for Economic Cooperation and Development (OECD) will present its final Base Erosion and Profit Shifting (Beps) project corporate tax reform proposals and on Tuesday the Ecofin council of EU finance ministers, is expected to agree on the exchange of tax rulings between member… – Continue reading
By: Jayesh Sanghvi, Partner & National Leader – International Tax Services, EY India Multinational groups can create non-resident affiliates in low tax jurisdictions to which income is shifted, wholly or partly for tax reasons rather than for non-tax business reasons. Such overseas profits are not subjected to tax in the… – Continue reading
The United States has included India in a list of 34 countries with which the US administration would automatically share information under the Foreign Account Tax Compliance Act (FATCA) regulations. The US Treasury Department has now added 16 new countries, including India, to an original list with which the US… – Continue reading
The world’s richest nations will launch a huge crackdown on multinational tax avoidance on Monday as part of the biggest shake-up of international tax rules for decades. The move could lead to a multi- billion pound gain for Chancellor George Osborne and higher tax bills for a raft of blue-chip… – Continue reading
Millions of pounds of British aid money could have been given to known tax havens to fund public services The UK paid out £45m to 13 countries on the European Commission’s tax haven “blacklist” in 2013, according to a report in The Independent. The blacklisted countries that received British aid… – Continue reading
Government’s anti-corruption champion says legislation is one option if British overseas territories fail to adopt public registers of companies The government could legislate to force the UK’s tax havens to reveal for the first time the true owners of offshore companies, anti-corruption champion Sir Eric Pickles has indicated. Pickles described… – Continue reading
The new Protocol to the Cyprus – Ukraine double taxation agreement The Cyprus Ministry of Finance has announced that agreement has been reached with Ukraine on a Protocol that will amend the existing DTA between the two countries. The existing DTA was signed in 2012 and entered into force on… – Continue reading
Once again, Commonwealth Caribbean countries are under attack as “tax havens”, even though they are nothing of the sort. This time it is not only the usual countries which have been listed. Trinidad and Tobago has been included, and we can bet that Jamaica and Guyana will be added unless… – Continue reading
Under the intergovernmental agreement between the UAE and the US the first report, disclosing the financial activities of US citizens in 2014, was due to be submitted to the US by September 30, 2015. This agreement was signed to facilitate implementation of the Foreign Account Tax Compliance Act (Fatca), a… – Continue reading
MUMBAI: The US Treasury Department has issued a list of 34 countries which includes India with whom it would share information under FATCA (foreign account tax compliance act) regulations. The pact aims to cover automatic sharing of information on bank accounts and other instruments like mutual funds, insurance and equities… – Continue reading
EU member states to reveal information on tax rulings offered to companies Ireland’s corporate tax regime is to come under renewed scrutiny next week as EU finance ministers sign off on a proposal obliging member states to reveal information on tax rulings offered to companies. EU finance ministers meeting in… – Continue reading
Efforts to block the exchange of information on US taxpayers’ foreign accounts are halted as an Ohio federal judge says Sen. Paul and six others don’t have standing to challenge parts of the Foreign Account Tax Compliance Act, reports BNA. US District Court for the Southern District of Ohio Judge… – Continue reading
On July 27, 2015, the U.S. Tax Court issued a stunning rebuke to the IRS by invalidating the part of the Internal Revenue Services’ (IRS) cost-sharing regulations under section 482 of the Internal Revenue Code that says taxpayers have to take into account, among other costs, the costs of stock-based… – Continue reading
An offshore bank account is a must for many internationally mobile expats operating in the UAE and Middle East. But finding the right bank with the right extras as well as high service standards isn’t easy. There are plenty of big names to choose from, including the global operators Barclays,… – Continue reading
The Internal Revenue Service said Friday it has met a key milestone relating to the Foreign Account Tax Compliance Act, or FATCA, having begun exchanging tax information with certain foreign governments in time to meet a Sept. 30, 2015 deadline. The automatic exchange of account information with tax authorities abroad… – Continue reading
On September 18, 2015, the Danish Ministry of Taxation published draft legislation to introduce a new country-by-country reporting obligation for multinational corporations. The draft Bill would introduce the new three-tiered approach to transfer pricing documentation that is to be proposed formally by the OECD as part of the BEPS deliverables… – Continue reading
Introduction The Foreign Account Tax Compliance Act (FATCA) requires non-US financial institutions, including investment entities, to report US account holders to the Internal Revenue Service (IRS). This reporting is causing US taxpayers living abroad to consider whether they have been adequately filing annually their income and information returns in the… – Continue reading
George Osborne’s plans to tighten tax rules for wealthy foreigners living in Britain will leave many offshore trusts outside the UK tax net, according to proposals published on Wednesday, reports the Financial Times. The Treasury’s consultation on “carefully targeted” changes to the rules for “non-doms” — people who live in… – Continue reading
The Luxembourg “FATCA Law”1 became effective on 1 August 2015. Among other provisions, the FATCA Law implemented the Model 1 Luxembourg–U.S. intergovernmental agreement of 28 March 2014 (IGA). On the day prior to the law taking effect, the Administration des Contributions Directes (Office of Income Tax) issued two circulars on… – Continue reading
Prime minister says he is still not happy with way some British overseas territories are resisting financial transparency, reports The Guardian. David Cameron has accused some British overseas territories and crown dependencies of not doing enough to tackle tax evasion and money laundering. The prime minister took the offshore financial… – Continue reading
Using companies incorporated in international financial centres (IFCs) in structuring financial transactions, capital raisings and corporate structures has long been popular in Asia, particularly Hong Kong (itself an IFC). Following the energetic expansion of the PRC economy and assisted in part by the relaxation of PRC regulations in relation to… – Continue reading
Oct 1 Germany is not ruling out the introduction of tax breaks for companies on revenue generated from patented or licensed research, a senior official said on Thursday. The government has repeatedly said it would consider introducing so-called patent boxes if there were no progress towards fair tax competition at… – Continue reading
European Commission list identifies the city as one of 30 non-cooperative tax jurisdictions, reports the South China Morning Post. The European Commission is likely to remove Hong Kong from its list of top 30 tax havens, according to a source familiar with the situation. The source, who cannot be identified,… – Continue reading
NEW DELHI: The finance ministry, seeking to build on the recent success in pitching India as an attractive destination, is looking at burying for good the remaining high-profile acrimonious tax tangles involving Cairn India and Royal Dutch Shell, which have tarnished the country’s administration. North Block is likely to replicate… – Continue reading
Federal judge in Ohio says Republican presidential candidate Sen. Rand Paul and others don’t have standing to challenge a law requiring banks to report on foreign accounts of U.S. taxpayers, and they aren’t likely to succeed on merits of case, Bloomberg BNA’s Alison Bennett reports. U.S. District Judge Thomas Rose… – Continue reading
On 14 September 2015, Cambodia and the United States signed a Foreign Account Tax Compliance Act (FATCA) Agreement. FATCA seeks to obtain information on accounts held by U.S. taxpayers in other countries. It requires U.S. financial institutions to withhold a portion of certain payments made to Foreign Financial Institutions (FFIs)… – Continue reading
On 16 June 2015, the Department of International Tax Cooperation of the Cayman Islands (the “DITC”) announced that it would be implementing the CRS into domestic law. The draft Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations, 2015 are currently under review and it is expected that these… – Continue reading
Tens of millions of pounds worth of property in St Austell is owned by companies based in offshore tax havens. They include large parts of Fore Street in the town centre; the beaches at Carlyon Bay, and dozens of individual buildings throughout St Austell and the clay country. NHS Kernow’s… – Continue reading
A stream of people, including those from Rajasthan and Karnataka, walked into the only designated office before the closure of the one-time compliance window The Centre’s efforts to unearth unaccounted money stashed abroad seems to have got a tepid response, with the declarations made under the three-month compliance window that… – Continue reading
In addition to Justice Martineau’s denial of injunctive relief and dismissal of the request for summary judgment in Hillis and Deegan v. The Attorney General of Canada, as discussed in our previous post, U.S. citizens residing in Canada received more disappointing news on September 29, 2015, when Judge Thomas M…. – Continue reading
Donald Trump’s tax plan was revealed with a message for millions of Americans: “You win!” But like everything linked to taxes, not everyone would win equally under his plan, which the Republican presidential candidate says is geared toward providing tax relief for the middle class and giving the U.S. economy… – Continue reading
After a whistleblower leaked the details of secret Swiss accounts at global bank HSBC earlier this year, the strongest reaction came from advanced economies, where governments launched efforts to reclaim tax money hidden abroad. But a new analysis by the Financial Transparency Coalition and Christian Aid shows that the financial… – Continue reading
Under pressure to find resources for his promises of sweeping tax cuts, Italian Prime Minister Matteo Renzi is hoping to raise billions of euros by forcing multinational Internet firms to pay taxes on profits generated in Italy. Treasury Undersecretary Enrico Zanetti said a so-called “Google Tax” could yield up to… – Continue reading
The Belgian Parliament has adopted a Program Law containing a wide array of fiscal measures. The most salient of these measures are (i) the introduction of a transparency tax regime for physical and legal persons subject to legal persons tax and that qualify as founders or third-party beneficiaries of so-called… – Continue reading
A new report by global consulting outfit, Price¬waterhouseCoopers (PwC), released on Monday has indicated that expanding com¬pliance burden, more audits and the potential for increased and double taxation remain key hurdles facing companies due to the rapidly evolving global tax landscape. The report’s findings showed that the demand for greater… – Continue reading
Secret Luxembourg document discussed risks of special tax deals, but Jean-Claude Juncker says he cannot remember discussing it with its author The president of the European Commission faces fresh questions about his role in designing Luxembourg’s controversial system of “sweetheart” tax deals after he released an 18-year old document that… – Continue reading
NEW YORK, September 30, 2015 – A new report from Thomson Reuters sheds light on the dividend and income reporting requirements for banks, brokerages, and other financial institutions under the Foreign Account Tax Compliance Act (FATCA). Published by Thomson Reuters Checkpoint, New FATCA Compliance Obligations Facing Business Entities can be… – Continue reading
WASHINGTON, D.C., Sept. 30, 2015 –His Excellency Dr. Eugene Newry, Bahamas Ambassador to the United States, has written a letter to Municipal Officials of the District of Columbia and Federal Congressional Officials protesting “in the strongest terms” The Bahamas’ designation as a “tax haven” by D.C. authorities in the District… – Continue reading
The OECD/ G20 Action Plan on Base Erosion and Profit Shifting (BEPS) published in July 2013, identifies 15 actions to address BEPS in a comprehensive manner. Actions 8-10 of the BEPS Action Plan relate to a number of closely related topics. These include the development of rules to prevent BEPS… – Continue reading
The tax authority has moved to compile a statement of international transaction (SIT) for the first time by collecting details of all of the cross-border financial transactions conducted by the taxpayers across the country. The Income Tax wing under the National Board of Revenue (NBR) has taken the initiative to… – Continue reading
By: Pinakin D Desai, Partner – Tax & Regulatory services, EY India The term Base Erosion and Profit Shifting (BEPS) refers to tax avoidance strategies which, by exploiting gaps and mismatches in tax rules, shift profits of Multinational Enterprise (‘MNE’) Groups to low or no tax locations where there is… – Continue reading
At least 25 multi-millionaire Canadians used an offshore “sham” set up by accounting firm KPMG, a document filed Tuesday in Federal Court shows. For more than two years, KPMG has been fighting a court order to provide the list of names of multi-millionaire clients who had used what the CRA… – Continue reading
The Yomiuri Shimbun The Organization for Economic Cooperation and Development will establish a comprehensive package of international rules to clamp down on tax saving tactics by multinational companies, The Yomiuri Shimbun learned Tuesday. The pillar of the package is to halt tax-saving practices like unrealistic lending and borrowing as well… – Continue reading
On 5 August 2015, the Luxembourg government presented a bill implementing Council Directives 2014/86/UE and 2015/121/UE amending Council Directive 2011/96/UE of 30 November 2011 on the common taxation applicable in the case of parent companies and subsidiaries of different Member States (the Parent-Subsidiary Directive). In accordance with Directive 2014/86/UE, the… – Continue reading
The Guernsey Association of Compliance Officers (GACO) chair, Mark Dunster, has urged those affected by the introduction of the Foreign Account Tax Compliance Act (FATCA), and other exchange of information regimes, to attend a free seminar hosted by the association next Monday. Guernsey Income Tax office compliance and international manager,… – Continue reading
Ireland ‘needs to end its dependence on multinationals’ Ireland needs to end its dependence on multinationals and broaden its support to indigenous businesses, tax experts said yesterday, as they called for a €1 billion package to boost entrepreneurship. “While Irish tax policy must ensure that Ireland remains a competitive location… – Continue reading
At the request of the G20, OECD published its Action Plan on addressing ‘base erosion and profit shifting’ (BEPS) in July 2013, wherein it identified 15 actions on BEPS for future work, intending to carry out fundamental changes to the international tax standards. Amongst other, Action 7 deals with ‘preventing… – Continue reading
Tax treaties serve to reduce or eliminate double taxation which, if unrelieved, would be a significant barrier to cross-border trade and investment. At the same time, there was need felt to protect against granting of treaty benefits in inappropriate circumstances. In this background, the work of the OECD and G20… – Continue reading
China will be at the forefront of embracing the emerging international tax rules to combat base erosion and profit shifting, known as BEPS, as it shifts toward becoming a “capital-export” country, said senior EY executives. “China is not going to be a laggard. A lot of small developing countries are… – Continue reading
