A narrative which is now familiar to those working in Africa or who are involved in projects relating to Africa tends to enter into all discussions related to poverty and income disparity on that continent. That narrative, that the poverty and deprivation which exist on the continent are directly attributable… – Continue reading
The private equity industry has long been known for its ability to take advantage of tax rules. But international changes are set to have an impact on their businesses. After a string of multinationals such as Apple, Google and Starbucks came under fire for paying minimal tax on their British… – Continue reading
There have not been too many applicants in the first month seeking to avail of the three-month long compliance window being offered by the government to come clean on unaccounted money in foreign shores, Justice (retd) MB Shah, who is heading the Special Investigation Team (SIT) on black money told… – Continue reading
The Tax Department of Cyprus has annouced that the FATCA reporting deadline has been moved to 31 August 2015 (from 14 August 2015). The FATCA Agreement between Cyprus and the United States was signed on 2 December 2014. FATCA seeks to obtain information on accounts held by U.S. taxpayers in… – Continue reading
The Senate inquiry into multinational tax avoidance will table an interim report today detailing some of its findings after holding five public hearings and receiving more than 100 submissions from some of the world’s largest companies including Apple, Microsoft, BHP, Rio Tinto and Google. The final report is due to… – Continue reading
In short… The current balance of competences between the EU and the UK on tax is quite intricate, with a tension between member states’ desire to determine their own tax systems and the EU-led aim of a level playing field. The EU most obviously influences member states’ indirect taxation (particularly… – Continue reading
The Internal Revenue Service has issued additional informal guidance regarding implementation of the Foreign Account Tax Compliance Act (FATCA). First, the IRS published a new “Frequently Asked Question” on its website addressing form and documentary evidence received by facsimile or email. The text of the guidance, which states that withholding… – Continue reading
Luxembourg has proposed major corporate tax changes which would bring the Grand Duchy into line with recent updates to the Parent-Subsidiary Directive. The Luxembourg government released Bill 6847 (the Bill) on August 5 2015, which includes proposed tax measures for corporations and follows several recent announcements from Finance Minister Pierre… – Continue reading
BENGALURU, AUGUST 17: To conduct research on present tax regulations, address uncertainties arising out of interpretation and ensure higher FDI, the International Tax Research and Analysis Foundation (ITRAF) was launched here on Monday. Headed by Parthasarathi Shome, an economist and former head of the panel on General Anti Avoidance Rules… – Continue reading
FEEDBACK FROM MY LAST ARTICLE, From The Frying Pan, was encouraging. Our past Prime Minister Errol Barrow asked us, “What is your mirror image of yourselves”. A searching question. Our response to FATCA can throw some light on the matter. Encouraged by the USA, the UK, and soon others, are… – Continue reading
New data from Juniper Research has found that more than one in 10 adults worldwide will engage in some form of mobile or online gambling by 2019, with nearly half of adults in UK and Italian markets playing by that time. While to some extent the finding can be attributed… – Continue reading
The tax regime for foreigners who render services in South Africa for a relatively short period of time is a key area which expatriates and their employers are grappling with. These individuals (also more commonly known as ‘short-term business travellers’) are generally physically present in SA for periods ranging from… – Continue reading
The Bombay Stock Exchange (BSE) is putting in place a series of measures to prevent use of its exchange platform by various unscrupulous entities to evade taxes and launder money. These measures include putting additional circuit filters on stocks that are susceptible for price manipulation and reducing the number of… – Continue reading
New transparency requirements could see tax-dodging companies being listed on a ‘name and shame’ register, a Senate committee has proposed. The Australian Tax Office would also be forced to disclose all tax avoidance settlements which exceed a proposed $100 million threshold, Fairfax has reported. In addition, companies based in Australia… – Continue reading
Simplification of tax administration has always been on the government’s agenda. E-filing is one major steps in that direction as it increases the tax base. E-filing is almost paperless, where taxpayers need not submit any supporting documents. E-filing is mandatory for those qualifying as resident and ordinary resident and having… – Continue reading
Luxembourg currently has 76 income tax treaties in force, and there are 29 treaties under negotiation. Tax treaties can provide a legal framework not only for the avoidance of double taxation and fiscal evasion, but also for international administrative cooperation between Luxembourg and its treaty partners in terms of mutual… – Continue reading
IT IS the corporate equivalent of burning the American flag. A “tax inversion” is a manoeuvre in which a (usually American) firm acquires or merges with a foreign rival, then shifts its domicile abroad to reap tax benefits. A spate of such deals last year led Barack Obama to brand… – Continue reading
Americans who believe the region is a safe tax haven to hide money and investments overseas should think twice as Caribbean trade bloc countries are moving to full comply with a new U.S. law designed to catch tax dodgers who stash assets in foreign destinations. The Foreign Account Tax Compliance… – Continue reading
The U.S. and China enjoy increasingly strong connections. Yet virtually no Chinese family or business relishes dealing with the Internal Revenue Service (IRS). American tax laws are famously complex, and dealing with the IRS can be like quicksand. Of course, whether they like it or not, U.S. citizens and green… – Continue reading
On 16 June 2015 the Department of International Tax Cooperation (the “DITC“) of the Cayman Islands government announced that it was moving forward with the implementation of the OECD Common Reporting Standard (“CRS“), via the introduction of Cayman Islands domestic law, by October 2015. The CRS represents a significant step… – Continue reading
Introduction In 1934 distinguished US jurist Judge Learned Hand famously opined that “one may so arrange his affairs so that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to… – Continue reading
Artisan goods marketplace Etsy Inc., which promised to be a beacon for transparency as a public company, recently implemented a strategy that shrouds its offshore tax-cutting arrangements in secrecy. Because of a change in how its Irish subsidiary is registered, Etsy no longer needs to publicly disclose basic financial information… – Continue reading
MUMBAI: Large foreign portfolio investors (FPIs) have voiced concerns before Indian capital market regulator Sebi about the fate of the Mauritius treaty which the government is renegotiating with the tax haven. Officials of more than 20 offshore asset managers, belonging to top banking groups and fund houses, met Sebi chairman… – Continue reading
Yet another American company has announced its intention to carry out a corporate inversion, a fancy term for buying a smaller company, completing some paper work and, for tax purposes, declaring its new headquarters are in a foreign nation. This time it’s Terex, a Connecticut-based heavy equipment and crane manufacturer,… – Continue reading
U.S. COMPANIES HOLDING CASH ABROAD WAITING FOR TAX REFORM. The high U.S. tax rate continues to encourage companies to stash cash and profits offshore while executives wait for tax reform. The Street has an interview with computing giant Cisco’s CFO Kelly Kramer on the company’s plans for more the more… – Continue reading
Revenue authorities need to be “vigilant” in monitoring the super-rich, according to research that called on many of them to improve their scrutiny of their richest taxpayers, reports the Financial Times. The study by the Paris-based OECD is a further sign of the pressure on tax departments to squeeze more… – Continue reading
In his summer budget the first exclusively Conservative one in 19 years British Chancellor George Osborne outlined several key changes for non-domiciled individuals or non-doms, reports MENAFN. These major modifications coming into effect in April 2017 arguably represent the biggest shake-up to the non-dom status since it was first introduced… – Continue reading
As the Islamic financial industry continues to experience exponential growth, offshore financial centres (OFCs) are keen to market their value for the development of Islamic financial products. OFCs are working towards establishing comprehensive eco-systems to gain competitive advantages over other jurisdictions for Islamic finance. Most OFCs promote the element of… – Continue reading
MUMBAI: High net-worth individuals who have invested in residential properties in the UK, will now have to deal with the issue of inheritance tax, which their heirs are unlikely to escape from. In its budget introduced in Parliament in June, the UK plugged a loophole that enabled foreign property buyers… – Continue reading
The regulatory environment surrounding the banking industry already constrains the behavior of banking groups in ways which obviate base erosion and profit shifting (BEPS) risks, the International Banking Federation (IBFed) said in a paper released on August 7. Entitled Base Erosion and Profit Shifting (BEPS): Why International Banks Are Different,… – Continue reading
With the UK announcing new tax rules for foreigners living in the country, the government has been careful not to damage the country’s appeal to wealthy foreigners. The “non-dom” tax status “plays an important role in allowing those from abroad to contribute to our economy”, says George Osborne, the UK’s… – Continue reading
The Polish Ministry of Finance has published the text of the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income as concluded on July 13, 2015 between The Republic of Poland and the Federal Democratic Republic of Ethiopia (Hereafter: the… – Continue reading
On August 11, 2015, the Organisation for Economic Co-operation and Development (OECD) released its annual report addressing global tax administration. The OECD’s stated mission is to “promote policies that will improve the economic and social well-being of people around the world.” The OECD describes its annual report as follows: Tax… – Continue reading
The first reporting cycle for the United States Foreign Account Tax Compliance Act (FATCA) kicked off with the 31 March deadline set by the US Internal Revenue Service’s (IRS) for countries and territories such as Hong Kong that have a Model 2 Intergovernmental Agreement (IGA). Although the IRS has granted… – Continue reading
Seeking to allay fears, the government said full confidentiality will be maintained with regard to disclosures of unaccounted overseas wealth made under the black money compliance window and only those who do not take advantage of the scheme need to worry, reports PTI according to the Free Press Journal. Asking… – Continue reading
The rise of Islamic finance and sukuk issuances have brought with it a growing phenomenon: Shariah banking is increasingly taking advantage of offshore banking jurisdictions, and this for a number of reasons, reports the Gulf Times. Many offshore centres around the world meanwhile offer a wide range of features allowing… – Continue reading
A good test of a fair and just law is that the people who have to comply consider the rules fair and just. Now and then a law sparks controversy and one such law is the US Foreign Account Tax Compliance Act (FATCA). Five years after the law hit the… – Continue reading
The Danish government is hopeful ratification of the convention for avoidance of Double Taxation agreements (DTA) with Ghana — and the Prevention of Fiscal Evasion with respect to taxes on income and capital gains between the two countries — will help to double Denmark’s investment in the country. This brings… – Continue reading
A “legislative requirement” for large businesses to publish their tax strategy could create commercial confidentiality risks IN an age where large corporates continue to engage in tax avoidance or aggressive tax planning, compelling businesses to disclose their tax strategies is, at heart, a good idea. There is a risk, however,… – Continue reading
The Australia government on 6 August 2015 released two exposure drafts in relation to its multinational tax integrity measures. In the 2015 budget, the government announced a package of measures to address multinational tax avoidance. As part of these measures, the two exposure drafts would: (1) introduce the new OECD… – Continue reading
Excerpt from “FATCA in Canada: The Restriction on the Class of Entities Subject to FATCA” first published by the Canadian Tax Foundation in (2014) 62:3 Canadian Tax Journal by Roy Berg and Paul Barba. This article provides an introduction to the Foreign Account Tax Compliance Act (FATCA) for Canadians and… – Continue reading
In doing business, companies will incur operating costs that vary according to the nature of the undertaking. For manufacturers, the key operating costs, apart from raw materials and overheads, might include such expenses as manufacturing know-how and technical assistance. For distributors, the key operating costs will normally include inventory, marketing… – Continue reading
Accommodation company Airbnb has held a meeting in Dublin, for people in Ireland who may owe tax on income earned by renting rooms and properties through the website. However, Airbnb hosts said there was no tax or legal expert to answer their questions and the meeting did not provide clarity… – Continue reading
The latest estimate of the tax potentially underpaid by the UK’s biggest businesses suggests that “the era of billion-pound tax settlements might be over” with HM Revenue and Customs (HMRC) increasingly focusing on mid-tier firms, an expert has said. Heather Self of Pinsent Masons, the law firm behind Out-Law.com, was… – Continue reading
LONDON (Reuters) – Greek shares rose on Tuesday after the indebted euro zone country clinched a multi-billion euro bailout agreement with its international lenders. The latest bailout deal for Greece also resulted in the country’s sovereign borrowing costs falling back. Athens’ benchmark ATG equity index rose 1.2 percent, while the… – Continue reading
FATCA refers to provisions contained in the Hiring Incentives to Restore Employment Act (the ‘HIRE’ Act) signed into law on 18 March 2010 in the United States. The main purpose of FATCA is to identify and gather information on US persons who may be evading tax through the use of… – Continue reading
Only 23 percent of business leaders feel that recommendations from the OECD on base erosion and profit shifting will be successfully implemented, according to the findings of a new survey by Grant Thornton. Three quarters of business leaders would pay more taxes in exchange for greater clarity from authorities on… – Continue reading
In his summer budget the first exclusively Conservative one in 19 years British Chancellor George Osborne outlined several key changes for non-domiciled individuals or non-doms, reports MENAFN. These major modifications coming into effect in April 2017 arguably represent the biggest shake-up to the non-dom status since it was first introduced… – Continue reading
Many tax practitioners will meet holders of foreign accounts who have either deliberately or unintentionally failed to accurately report their foreign accounts and will need to advise them on the best way to make the disclosure to the Internal Revenue Service. Due to the fact that many U.S. taxpayers have… – Continue reading
Controlled foreign companies (CFCs) that are engaged in offshore short-term insurance will be allowed to deduct reserves related to their “short-term insurance business” conducted outside South Africa, once an amendment to the Insurance Act, 2016 is promulgated. For a CFC to be eligible for this deduction (which is similar to… – Continue reading
