Glencore pays virtually no tax on Australian coal operations Glencore is in trouble and took drastic action today to shore up its finances. One place they won’t find sympathy is in the court of public opinion. Last year, the Sydney Morning Herald revealed that Glencore paid virtually no tax over… – Continue reading
THE BUREAU of Internal Revenue (BIR) has advised Philippine financial institutions to start preparing for the implementation of a United States law requiring the reporting of bank accounts held by American taxpayers locally. In an advisory, the BIR said the start of reporting will not yet take place at the… – Continue reading
The Australian government announced on Monday that a review of the country’s Interactive Gambling Act will be carried out. Officials will be looking for ways to meet the increasing demand for innovative methods for live sports betting. The introduction of regulations for the illegal offshore gambling operators that provide their… – Continue reading
New York, NY, September 05, 2015 –(PR.com)– The Knowledge Group/The Knowledge Congress Live Webcast Series, the leading producer of regulatory focused webcasts, has announced today that Colleen P. Waddell, Managing Director, Outlier Solutions will speak at the Knowledge Group’s webcast entitled: “Latest Regulatory Developments Under FATCA: Best Compliance Practices Uncovered… – Continue reading
MUMBAI India’s tax officials, long the scourge of foreign investors, are under government pressure to avoid aggressive claims against overseas funds and companies, as the country seeks to repair an image dented by high-profile tax battles. The latest dust-up was over a largely overlooked minimum alternate tax (MAT), which had… – Continue reading
The National Assembly’s landlord is a shadowy company based in the tax haven of the British Virgin Islands – and AMs have no idea who is benefitting from the annual rent of more than £2m it pays to the owners. Private Eye magazine has launched a section of its website… – Continue reading
Ireland will probably face censure from European authorities within months in relation to its tax dealings with Apple, according to a person with knowledge of the matter. A finding against Ireland will spark a legal battle that may last years, as the government is ready to fight the decision in… – Continue reading
On 1 July 2015, the Supreme Court (in Anson v HMRC4) held that a taxpayer was entitled to treaty relief on his share of a Delaware LLC’s profits. This casts doubt on HMRC’s published position (though each case must be judged on its own facts). The taxpayer, a UK “non-domiciled”… – Continue reading
A funding line has been launched to help business taxpayers facing payment deadlines arising from Accelerated Payment Notices (APNs) APNs, introduced in 2014, enable HMRC to request full upfront payment of disputed tax within 90 days. They are issued to individuals and companies suspected of partaking in aggressive avoidance schemes…. – Continue reading
PRELIMINARY statistics on the 2015 African Capacity Report (ACR) released yesterday in Addis Ababa, Ethiopia showed that there were significant improvements in revenue collection over the last decade (2006-2015) in Nigeria and 44 other African countries. But despite the cheering news, the report said effective mobilisation of domestic resources in… – Continue reading
On 13 April 2015, HMRC confirmed that UK financial institutions will not be required to file “nil” returns under the UK’s FATCA regulations, if they do not maintain any US financial accounts. However, UK financial institutions that maintain only US accounts below the applicable de minimis threshold ($50,000 or $250,000,… – Continue reading
On 17 June 2015, the European Commission launched its action plan for fair and efficient taxation in the EU. Within the package to be consulted upon are plans for a common consolidated corporate tax base (CCCTB) and a number of administrative measures around cross-border cooperation, dispute resolution and greater transparency…. – Continue reading
A number of further publications have been released this quarter as part of the Organisation for Economic Co-Operation and Development’s (OECD’s) Base Erosion and Profit Shifting (BEPS) project. These include: The 8 June 2015 publication by the OECD of a package of measures relating to “country- by-country reporting” (relevant to… – Continue reading
Ingenious Asset Management has formalised its offering for its transatlantic clients with the launch of IAM-US. Led by investment director Edward Allen, supported by fellow investment directors Wayne Ellis and Peter Clark, who is also chief strategist at the wealth manager, the move recognises the specialist requirements of US-linked clients… – Continue reading
Commercial finance provider LDF has launched a funding line to help taxpayers facing payment deadlines arising from accelerated payment notices issued by HMRC. Accelerated payment notices, otherwise known as APNs, were first introduced in 2014. Designed to change the economics of avoidance, the notice enables HMRC to request full upfront… – Continue reading
German business groups have hit out at Berlin’s plan to reform how it taxes investment funds, warning on Thursday that the proposed changes would hurt pension provisions and reduce the attractiveness of Europe’s largest economy as a place to invest. The finance ministry announced plans in July to reform the… – Continue reading
The Court of Justice of the European Union (CJEU) today issued a judgment concluding that the different tax treatment of dividends received by parent companies of tax-integrated groups, with such treatment depending on the location where the subsidiaries are established, is contrary to EU law. The CJEU judgment therefore holds… – Continue reading
Tax avoidance practices by multinational enterprises (MNEs) often depend on corporate structures that are built by routing investments through offshore investment hubs or conduits that help shift profits from higher to lower tax jurisdictions. In essence, corporate structures built through FDI (foreign direct investment) can be considered “the engine” and… – Continue reading
The European Commission is refusing to hand over documents to MEPs investigating whether EU member states are using special tax regimes that favour large multinational corporations such as Facebook and Amazon. EU economics commissioner Pierre Moscovici wrote to the European Parliament’s special committee on tax rulings (TAXE) this week claiming… – Continue reading
As Labor Day weekend approaches, a tanned and rested Congress is poised to return to Washington to hash out corporate tax changes. Much of the debate over corporate tax reform in Washington sensibly focuses on how to encourage Fortune 500 corporations to repatriate and pay U.S. taxes on the $2.1… – Continue reading
Abu Dhabi: As the world powers get ready to lift sanctions on Iran, a top banker in the UAE said the banks have to carefully understand this change as they prepare to relax their systems and enable the expected business activity. “It is one of the tougher sanctions that the… – Continue reading
Japan has just embarked on the 2015 Tax Reform to be more growth-oriented with the aim of a reduction in the effective corporate tax rates to allow corporations to pay higher wages to existing employees as well as increase overall employment thereby increasing economic consumption and investment. On 31 March… – Continue reading
Revenue Minister Todd McClay announced today that Cabinet has given its approval to a set of proposals intended to address the current inequitable situation where debt remission between related parties can, under certain circumstances, result in an incorrect taxation outcome. At present, in cases when such debt is forgiven by… – Continue reading
Depeartmental review indicates contentious tax credit plays vital role in supporting jobs Several multinational firms have been found to be aggressively and improperly claiming tax credits for research and development to lower their corporation tax bills. A Government scheme gives firms up to 25 per cent of their expenditure on… – Continue reading
The number of Swiss banks that have entered deferred prosecution agreements with the U.S. government keeps growing. The subject is tax evasion involving American account holders. Today, banks everywhere want to know if you are compliant with the IRS. Under FATCA, the entire world is lending the IRS a hand…. – Continue reading
The inquiry raises some larger and perhaps more challenging questions about Australia’s corporate tax system and what is acceptable and unacceptable tax minimisation. On 18 August 2015, the Senate inquiry into corporate tax avoidance tabled a long-awaited interim report, with the subtitle “You cannot tax what you cannot see”. The… – Continue reading
PUTRAJAYA: Malaysia will host the bi-annual keystone 16th International Anti-Corruption Conference (IACC) from today (Sept 2) until Friday. Themed ‘Ending Impunity: People. Integrity. Action’, over 1,000 delegates from over 130 countries are expected for plenary debates and workshops to discuss what can be done to end impunity for corruption. Hosted… – Continue reading
HMRC reintroduces Australian fund to Rops listEU member states are lobbying the European Commission to prevent it from disclosing information on tax rulings to a European Parliament probe, reports the EU Observer. EU economics commissioner Pierre Moscovici, in a letter sent Monday (31 August) to the head of the parliament’s… – Continue reading
On August 31, the government of St Kitts and Nevis signed the agreement with the Government of the United States of America to implement the US Foreign Account Tax Compliance Act (FATCA), reports WINN FM. Enacted by the US Congress in 2010, FATCA targets non-compliance by US taxpayers using foreign… – Continue reading
Moneycontrol Bureau Credit Suisse has maintained its underperform rating on Glenmark Pharma as it feels potential currency devaluation in Venezuela could hurt profit meaningfully. The stock lost more than 3 percent intraday Wednesday. The brokerage expects a 20 percent degrowth in company’s FY17 earnings per share as it continued to… – Continue reading
On August 12 the IRS issued final guidance (Rev. Proc. 2015-40) significantly updating procedures for requesting and obtaining an advance pricing agreement (APA) from the Advance Pricing and Mutual Agreement (APMA) program. All new APA requests will need to be filed under these “new procedures”, however, an APA request may… – Continue reading
Switzerland’s parliament will soon take up the issue of inking a crucial Automatic Exchange of Information (AEOI) agreement with India, a move that could help combat the menace of black money and erect a platform to enable the exchange of information between the two countries. “The domestic procedures regarding AEOI… – Continue reading
Three-quarters of global business leaders would accept higher taxes in exchange for greater clarity on acceptable tax planning, the Grant Thornton International Business Report has found. The survey of 2,580 businesses in 35 countries noted a significant increase from the last time the question was asked – last year –… – Continue reading
Domestic funds will now have to closely examine FATCA rules. Much ink has been spilt of late over a United States (‘US’) federal law called the Foreign Account Tax Compliance Act (‘FATCA’) and hence we thought it fit to spend some time trying to analyse for the readers the aspects… – Continue reading
Investors could be hit hard if they are taxed on the capital gains earned from the sale of holdings in FPIs Today, a stable, predictable tax and regulatory regime is a sine qua non for creating a conducive climate for foreign portfolio investors (FPI). Investors wishing to invest in India… – Continue reading
By accepting the recommendations of the AP Shah panel on the issue of retrospective tax demand on FIIs, the Narendra Modi government has added one more item to the long list of its U-turns. And at the face of it, this one definitely is a wise one, though the question… – Continue reading
The Luxembourg tax authorities released a final version of an administrative circular and an updated administrative circular to implement provisions under the FATCA (Foreign Account Tax Compliance Act) regime concerning the automatic exchange of information between Luxembourg and the United States. An intergovernmental agreement (IGA), that follows the Model 1… – Continue reading
One of Ireland’s richest persons, John P. McManus, seeks $5.2 million from the U.S. government after it was wrongfully withheld from his $17.4 million gambling winnings to cover taxes. In a complaint filed Monday in the U.S. Court of Federal Claims, McManus accuses the withholding agent of erroneously withholding the… – Continue reading
Statutes facilitates automatic exchange of financial account data Pensions regulator PFRDA has asked all intermediaries registered with or appointed by the body to take necessary steps to ensure compliance with respect to the implementation of multilateral competent authority agreement (MCAA) and foreign account tax compliance act (FATCA). Financial regulators in… – Continue reading
WILLEMSTAD – Pan-American Life Insurance Company of Curaçao and Sint Maarten, a member of Pan-American Life Insurance Group (PALIG), facilitated a discussion yesterday with other members of the local insurance association about the practical implications of the U.S. Foreign Account Tax Compliance Act (FATCA) which was introduced in July 2014…. – Continue reading
In 2013, the previous Belgian government introduced a new reporting obligation for individual founders and beneficiaries of so-called “legal arrangements” (i.e., trusts, foundations and certain tax haven companies). At the same time, the previous government also internally discussed a draft bill seeking to further discourage the use of such legal… – Continue reading
On August 12, 2015, the IRS issued Rev. Proc. 2015-40, which revises the procedures for obtaining competent authority (CA) assistance concerning issues arising under U.S. income tax treaties. This revenue procedure replaces current guidance, which was last updated almost 10 years ago, in Rev. Proc. 2006-54. Revisions to the former… – Continue reading
Almost 173,500 financial institutions from around the world have signed up to report customer information to the US Internal Revenue Service (IRS) under the Foreign Account Tax Compliance Act (FATCA). Around 2,230 registered with the FATCA portal in the past month, according to the IRS. At least one financial institution… – Continue reading
New Delhi: Expressing concerns over the outflow of funds from developing countries, including India, through money laundering and other ways, Minister of State for Finance Jayant Sinha today said as much as $300-600 billion moves out through such channels. “Illicit financial flows means the money that actually is black money,… – Continue reading
New Zealand: GST and the digital economy The New Zealand Government has released a Discussion Document regarding the proposal to impose goods and services tax (GST) on online purchases of goods and services from offshore suppliers by New Zealand resident consumers. The publication Taxing by the megabyte: New Zealand’s GST… – Continue reading
For hedge funds in most jurisdictions, the first wave of registration and reporting deadlines surrounding the Foreign Account Tax Compliance Act (FATCA) is now in the rearview mirror, but a significant amount of work likely remains. Due to the staggered approach regarding the definition of a reportable investor in 2014… – Continue reading
The Finance Ministry said Tuesday that it would pardon individuals and companies that not paid taxes on gains from overseas investments, as long as they voluntarily report their gains for tax payment by the end of March. The tax authority’s policy came from the Park Geun-hye administration’s efforts to expand… – Continue reading
Swiss banking secrecy is no longer viable as the U.S. Justice Department closes in on agreements with most of the institutions that may have helped Americans evade taxes, according to the top American diplomat in Switzerland. Negotiations with about one-third of Swiss lenders, known as Category 2 banks, to finalise… – Continue reading
Malta’s tax legislation provides for a number of benefits which can be derived by companies and their shareholders. The tax rules can lead to a tax burden in Malta which is significantly reduced or completely eliminated in certain cases, and the following are some of the key tax benefits which… – Continue reading
U.S. Sen. Orrin Hatch (R-UT), chairman of the Senate Finance Committee, and U.S. Rep. Paul Ryan (R-WI), House Ways and Means Committee chairman, sent a letter on Tuesday to Treasury Secretary Jack Lew, outlining concerns regarding the country-by-country (CbC) reporting requirements in the works at the Treasury Department. The letter… – Continue reading
