Malta provides an outstanding opportunity for private equity and venture capital managers. It has a flexible LP structure, an extensive network of double tax treaties, a favourable local tax regime and experienced service providers who can provide a cost-effective solution,” comments Felicity Cole (pictured), Head of the Funds Department at… – Continue reading
Transparency International called today on European Commission President Jean-Claude Juncker to publicly support legislation that would allow citizens to scrutinise the corporate taxes paid by multinational companies to governments. Juncker will appear tomorrow in front of a special tax committee at the European Parliament to defend the Commission’s track record… – Continue reading
The Inland Revenue Board of Malaysia in September 2015 issued guidance concerning the requirements for compliance with an intergovernmental agreement (IGA) to implement the FATCA regime. The FATCA guidance notes provide guidelines and practical information for Malaysian-based financial institutions, businesses, their advisers, and officials dealing with application of the FATCA… – Continue reading
Changing Attitudes to Tax Reputation Risk In recent years, it seems that any discussion of tax includes mention of the moral obligation taxpayers have to “pay their fair share.” Many believe this theme began to get traction in 2011 when Warren Buffett realized that he was paying proportionately less taxes… – Continue reading
The Government should reduce the rate of capital gains tax (CGT) and expand corporation tax relief for start-up companies in next month’s budget to boost growth in the financial technology sector, Financial Services Ireland (FSI), a unit within employers’ group Ibec, has urged, reports the Irish Times. In a 10-page… – Continue reading
NEW DELHI: Finance minister Arun Jaitley has promised “fairest and predictable taxation regime” while inviting US businesses to invest in the country. Speaking at the 11th Indo-US Economic Summit organised by the Indo-American Chamber of Commerce ahead of the India-US Strategic and Commercial Dialogue (SACD) in Washington later this month,… – Continue reading
Under the I-T Act, 1961, taxpayers are broadly categorised as Ordinary Resident, Not Ordinarily Resident (NOR) and Non-Resident (NR). Reporting and paying taxes on overseas incomes and assets come with their own set of challenges. Under the I-T Act, 1961, taxpayers are broadly categorised as Ordinary Resident, Not Ordinarily Resident… – Continue reading
The largest producer of nitrogen-based fertilizer in the United States, CF Industries, is considering merging with a Dutch competitor and moving its headquarters overseas to avoid the “double taxation” of profits earned by overseas subsidiaries going to the domestic company. Curtis Dubay, a tax and economic research fellow with The… – Continue reading
The European Confederation of Independent Trade Unions (CESI) has said that the proposed country-by-country reporting (CbCR) requirements are insufficient, and added that an extended CbCR, disclosure of tax rulings, and whistle-blower protection are key to ensuring corporate tax transparency. In its response to the public consultation on corporate tax transparency… – Continue reading
Anne Berner, who serves as Minister of Transport and Communications, serves on the board of a Luxembourg firm involved in tax planning. This is the first time a Finnish minister has been known to have been involved in such a company. Finland’s Transport minister is a board member at a… – Continue reading
(ZIZ News) — Tuesday’s sitting of the National Assembly featured heated debates on the Foreign Account Tax Compliance (United States of America) (Implementation and Enforcement of InterGovernmental Agreement) Bill 2015. Prime Minister, Hon. Dr. Timothy Harris, who sought leave to have the bill read a first and second time, was… – Continue reading
“Luxembourg is famous for two things: its steel industry and its rose cultivation industry”. This quote from an Italian guidebook of the 1930s was uttered by Luxembourg’s Finance Minister Pierre Gramegna at the annual conference of the Luxembourg Directors’ Association on 17 June 2015[1]. The economic outlook of the tiny… – Continue reading
The Department of Justice announced today that Bank La Roche & Co AG has reached a resolution under the department’s Swiss Bank Program. “Today’s agreement is yet another example of a foreign financial institution coming forward, acknowledging its criminal conduct, taking the necessary steps to resolve its criminal exposure, cooperating… – Continue reading
The number of banks with deferred prosecution agreements with the U.S. government keeps growing. The subject is tax evasion involving American account holders. Today, under FATCA, banks everywhere want to know if you are compliant with the IRS. And the IRS keeps updating its list of foreign banks where offshore… – Continue reading
Is Xi Jinping (習近平)’s anti-corruption campaign crushing it or embarrassingly ineffective? You make the call. It was widely reported the year before Xi assumed office that upwards of 18,000 corrupt officials had fled China since 1990 with about US$120 billion. In early 2012, the Ministry of Supervision released figures saying… – Continue reading
On July 9, 2015, India and the US signed an agreement to implement the Foreign Account Tax Compliance Act (FATCA) that will facilitate exchange of information between the two countries starting on October 1, 2015. FATCA was signed by Revenue Secretary Shaktikanta Das and US Ambassador Richard Verma in New… – Continue reading
Belgian financial institutions have more time to comply with their reporting requirements under the FATCA regime. FATCA reporting for 2014 must be completed prior to the 10th day following the publication of the Belgian FATCA law in the Belgian official gazette. Currently, the law has not been enacted, but it… – Continue reading
The Swedish Tax Agency have published its opinion 27th of August on taxation of dividends from tax havens to Swedish companies. Sweden introduced the current participation exemption rules on dividend and capital gains for companies in 2003. Dividends that is received by tax resident limited liability companies (Aktiebolag or AB)… – Continue reading
An increasing number of Americans renounced their citizenship and cut-off long term residencies during the initial three months of 2015 due to a crackdown in the foreign tax rules. The exit wave went down a little in the second half, but has continued. The Internal Revenue Service and Treasury Department… – Continue reading
Note: This article was published by Bloomberg BNA in Tax Planning International European Tax Service Vol. 17 No. 7 July 2015 Introduction The recent LuxLeaks scandal has once again focused political attention on tax planning practices of multinationals (“MNEs”). It comes in the wake of the European Commission investigation of… – Continue reading
New Article L. 62 A of the French tax procedure code (published in the official bulletin on 2 September 2015) sets forth rules that effectively regularize the tax treatment of certain profits transferred abroad by French taxpayers, and allows for the repatriation of these funds without additional tax—and in particular,… – Continue reading
There are often a few major issues on everyone’s lips in the international community of tax lawyers. This was the case also at The International Fiscal Association’s (IFA) 69th Congress in Basel, Switzerland. One of the main subjects in the congress was how tax payers’ rights can be most efficiently… – Continue reading
The estates of high net-worth individuals often cross borders. They might reside in one country, with assets in that country and elsewhere, and possibly family members residing are in other countries for work, education, or lifestyle reasons. The tax resulting from death can be quite harsh to their estate or… – Continue reading
Seven leading Democrat lawmakers wrote a letter on September 12 to US Treasury Secretary Jack Lew urging him to publish an annual list of companies that have undertaken corporate tax inversions, and to use the Administration’s executive authority further to discourage the use of inversion techniques. Tax inversion techniques are… – Continue reading
Greece would be much better off if the government could collect the taxes owed by the self-employed. That’s the lesson from a paper released this month that uses an innovative method of capturing tax evasion. Estimating shadow economies is tough. Friedrich Schneider of the Johannes Kepler University of Linz in… – Continue reading
The decree of 2015 in accordance with the Assessment and Collection of Taxes Law (Exchange of Information within the framework of the Agreement for the Foreign Account Tax Compliance Act) has been issued and published in the official Gazette of the Republic of Cyprus dated 28th August 2015 (Decree 281/2015)… – Continue reading
Luxembourg recently published a bill to implement the new anti-hybrid rule and the general anti-abuse rule (GAAR) of the EU Parent Subsidiary Directive (PSD). The bill closely follows the wording of the PSD. A similar Dutch bill is expected on 15 September 2015. While the Dutch bill may differ from… – Continue reading
The Organisation of Economic Cooperation and Development (OECD) is like a global think tank for advancing ideas and policy for the leading developed nations. Based in Paris with 2,500 staff, the OECD gathers social and economic data from member states which is analysed, discussed and edited into digests with recommendations… – Continue reading
It may be a common misunderstanding that a U.S. citizen or permanent resident (Green Card holder) can give up their citizenship or surrender their Green Card and then as a non-U.S. taxpayer make gifts or pass their estate to U.S. taxpayers free of estate and gift tax. The IRS recognized… – Continue reading
Before the economic crash, OECD reports on its member countries focused on the structural problems afflicting the individual economies, be it the dominance of a national telecoms company or so-called sheltered areas of the economy which didn’t face competition, including the professions such as lawyers or pharmacists. Even mild recommendations… – Continue reading
ABOUT R80bn is leaving SA illegally each year in what is known as illicit financial flows (IFFs), a parliamentary workshop on base erosion and profit shifting heard. Base erosion and profit shifting are defined as “businesses exploiting gaps in the international tax system to artificially shift profit and avoid paying… – Continue reading
Many countries have enacted a patent box regime in order to spur innovation and create domestic manufacturing jobs. Simply stated, a patent box regime provides a lower tax rate on income from the exploitation of patented goods than for other income. Among the countries that have patent box regimes are… – Continue reading
BARBADOS’ OFFSHORE FINANCIAL SERVICES SECTOR is again under threat. The Organisation for Economic Cooperation and Development (OECD), G20 and the European Union (EU) are acting in concert, armed with the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS). Once implemented, the confidentiality which once protected financial… – Continue reading
EU commissioner urges member states to ensure fair share of tax is paid EU economics commissioner Pierre Moscovici reiterated his commitment to re-launch the Common Consolidated Corporate Tax Base yesterday, urging all EU member states to ensure that companies pay their fair share of tax. Speaking following a meeting of… – Continue reading
Multinationals have come under fire yet again over their tax arrangements in some European countries, as the continent moves closer to a pan-European regime to combat tax avoidance. On Friday, European economy and finance ministers and central bankers (known as an ECOFIN meeting) gathered in Luxembourg to discuss what the… – Continue reading
With the agreement with the US, Vietnam has now signed the double taxation avoidance agreements with 70 out of 170 countries and territories with which Vietnam has trade and investment relations. Double taxation is considered a barrier to trade and investment. It discourages transnational investments while prompts individuals and businesses… – Continue reading
Speaking at an informal meeting of the Economic and Financial Affairs (ECOFIN) in Luxembourg, Finance Minister Edward Scicluna once again expressed Malta’s opposition to tax harmonization. “Taxation remains a sensitive area for Malta, not only because of its obvious role in the revenue collection process, but also as an important… – Continue reading
Panama in May 2014 indicated its intentions to enter into an intergovernmental agreement (IGA) with the United States, for purposes of implementing the FATCA regime. The Panama agreement would follow the Model 1 IGA. As of early September 2015, Panama has yet to sign the IGA. In preparing for implementation… – Continue reading
Budgeting battle But like much of the budgeting in Washington, D.C., it gets complicated. The Congressional Budget Office contends the Ex-Im Bank’s surpluses are the result of the accounting method the bank uses and would disappear — or require a taxpayer subsidy — if the bank used a more appropriate… – Continue reading
All eyes are on how much taxes the British retailer Tesco Group will pay to the South Korean government after its profit of more than 5 trillion won (US$4.21 billion) with the sale of Homeplus. Industry sources say that the company will not have to pay taxes at all, or… – Continue reading
PwC has acquired software company Ellis Financial Systems in a bid to more rapidly meet new tax information reporting required under such regimes as the Foreign Account Tax Compliance Act (FATCA). It has been re-named PwC Tax Information Reporting, and will operate from London. The acquisition represents one of many… – Continue reading
Democratic lawmakers urged the Obama administration to take a more aggressive stance toward the offshore tax deals known as inversions. Seven congressional Democrats in all called on Treasury Secretary Jack Lew to take executive action against a technique known as earnings stripping that makes the offshore deals more attractive. They… – Continue reading
An initiative intended to catch tax dodgers could have a negative impact on those with perfectly legitimate bank accounts. Tax expert Howard Bilton offers advice The draconian Foreign Account Tax Compliance Act (FATCA), introduced by the US Government to tackle tax evasion by its citizens, has already affected Britons living… – Continue reading
Indonesians hold $300 billion in Singapore; controversial tax amnesty on the cards. Indonesia’s finance minister Bambang Brodjonegoro told Euromoney earlier this year that tax collection falls way short of targets and must improve to provide funding for infrastructure and other projects It doesn’t take much for Indonesia’s government officials to… – Continue reading
The finance ministers of 11 euro zone countries willing to introduce a financial transactions tax (FTT) are expected to make progress on the thorny issue in a meeting on Saturday in Luxembourg, Italy’s economy minister said. Germany and France proposed the tax in 2012, in the midst of the euro… – Continue reading
HA NOI (VNS) — The Ministry of Finance has proposed to increase special consumption tax on imported goods to ensure fair competition between locally manufactured products and imported ones. Under the current regulations, the special consumption tax on imported goods is calculated keeping in mind their cost, insurance, and freight… – Continue reading
The Thai Board of Investment introduced a new program to encourage the location of headquarters in Thailand. Among the incentives are provisions providing relief from corporate income tax (0% on non-Thai source income from services, royalties, and dividends, and 10% on certain Thai source income) for a period of 15… – Continue reading
India’s Ministry of Finance, Department of Revenue (Foreign Tax and Tax Research Division) on 31 August 2015 released guidance notes with respect to implementation of the reporting requirements under rules 114F to 114H of the Income tax rules. Rules 114F to 114H implement the intergovernmental agreement (IGA) between India and… – Continue reading
As traders are set to stage a strike on Wednesday (today) following a call given by the All Pakistan Anjuman-e-Tajran against the withholding tax on banking transactions, Lahore Chamber of Commerce and Industry has supported the traders and decided to join the strike. Traders’ leaders warned that the protest could… – Continue reading
Policies are urgently needed for the legalization of the underground economy,” said Representative Oh Je-se of the New Politics Alliance for Democracy, who belongs to the Planning and Financial Committee of the National Assembly on Sept. 10. Rep. Oh added that Korea places sixth among OECD member countries in terms… – Continue reading
