This French Tax Update will focus on (i) the main provisions of the draft Finance Bill for 2016 (Projet de loi de finance pour 2016) issued by the French Government on September 30, 2015 and to be discussed before the French Parliament between October and December (“Draft Finance Bill for… – Continue reading
David Gauke, the Financial Secretary to the UK Treasury, has spoken out in support of the international tax measures being adopted by the UK, and pushed the idea of diverted profits taxes. Speaking at the American Enterprise Institute in Washington DC on September 29, 2015, Gauke said recent reforms have… – Continue reading
Pharmaceuticals group defends use of legal avoidance scheme, after paying no UK corporation tax over two years despite global profits of £3bn AstraZeneca, one of Britain’s largest businesses, is using a multimillion-pound tax avoidance scheme in the Netherlands, set up months after the UK relaxed its tax laws for multinationals… – 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
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
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
Reading companies’ annual reports to the Securities and Exchange Commission is a reliable cure for insomnia. Every so often, though, there is a significant revelation in the paperwork. Last year, one of the most important revelations came from Microsoft’s filings, which spotlighted how the tax code allows corporations to enjoy… – Continue reading
Content supplied by EY New Zealand is one of only a few countries with a dividend imputation regime. Introduced in 1988, New Zealand’s imputation regime removes double taxation on distributions by attributing to shareholders a credit for the tax borne on profits at the company level. Benefits include a single… – Continue reading
The IRS recently replaced Rev. Proc. 2006-54 for requesting assistance under the Mutual Agreement Procedure (“MAP”) article of U.S. tax treaties, and Rev. Proc. 2006-9 for requesting Advance Pricing Agreements (“APAs”). The new Rev. Procs. (2015-40 and 2015-41, respectively) largely track draft procedures issued in 2013 (Notices 2013-78 and 2013-79),… – Continue reading
The IRS has let Americans living abroad wrongly claim tax credits on their foreign income, according to a new report from the agency’s watchdog. The Department of Treasury’s inspector general for tax administration said the IRS allowed taxpayers to wrongly claim around $95 million between 2010 and 2012 in foreign… – Continue reading
With the August recess now well in the rearview mirror, Congress is already deep into grappling with the imminent expiration of the U.S. Government’s funding authority on September 30. Amid the debates over the “Continuing Resolution” and related funding issues, the Iran deal, and other high-profile issues, the work on… – Continue reading
THE proposed Income Tax Bill is not clear whether disbursement cost are also included for charging Withholding Tax, says Fiji National Provident Fund (FNPF) Investment principal legal officer Siteri Saru. FNPF made a submission to the Standing Committee on Justice, Law and Human Rights on the Income Tax Bill in… – Continue reading
Speed read On 15 September 2015 the Dutch government published its Tax Plan 2016. In this e-alert we discuss the legislative proposals in the Tax Plan which are of interest for companies. 1 INTRODUCTION Today, the Dutch Ministry of Finance published its Tax Plan 2016. In fact, the government sent… – Continue reading
Some Italian parliament members published a proposal for a new law that may dramatically change the scenario for e-commerce and web operators doing business in Italy. The proposal (called by some commentators as “Digital” or “Web Tax”) is substantially a combination of domestic rules affecting the taxation of the digital… – Continue reading
The Organisation for Economic Cooperation and Development (OECD) has recommended that Ireland lower its high effective marginal income tax rates, abolish the reduced value-added tax (VAT) rate for the tourism industry, and phase in a planned Local Property Tax (LPT) hike. The recommendations are made in the OECD’s latest Economic… – Continue reading
On Thursday, The House Ways and Means Committee will once again contemplate making permanent controversial tax breaks that overwhelmingly benefit big business at a cost of $380 billion over the next 10 years. Known as tax extenders, these giveaways are a package of tax breaks that Congress must vote to… – Continue reading
A wealthy Victoria, B.C., family paid virtually no tax over a span of eight years – and even obtained federal and provincial tax credits – while being involved in an offshore tax “sham” developed by one of the country’s most respected accounting firms, the Canada Revenue Agency alleges. The Canada… – 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
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
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
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
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
WINDS OF CHANGE – GEORGE OSBORNE’S FIRST BUDGET AS THE CHANCELLOR OF A CONSERVATIVE GOVERNMENT BROUGHT SEVERAL SIGNIFICANT ANNOUNCEMENTS. By Mark Wingate Taking a leaf from the Labour Party’s election manifesto, there will be a further tightening of the rules for non-doms. In an attempt to provide a more level… – Continue reading
The multinational companies in Latin America demand security, efficient services, infrastructure and good educational standards, but they are not very willing to contribute themselves by paying their fair share of tax. Honduras is a case in point, and is one of the most unequal countries on the continent. The government,… – Continue reading
HM REVENUE & CUSTOMS has published a factsheet illustrating the overhaul of the way dividends are to be taxed from 2016. The move, announced in July’s Summer Budget, wipes out the tax advantage of taking payment as a dividend. The tax credit applied to dividends is to be replaced with… – Continue reading
The IRS on 12 August 2015 released Rev. Proc. 2015-40 with respect to requesting competent authority (CA) assistance, and it is generally effective for CA requests filed on or after 30 October 2015. Rev. Proc. 2015-40 updates and supersedes Rev. Proc. 2006-54. The IRS concurrently released Rev. Proc. 2015-41 as… – Continue reading
Greek lawmakers and European Union finance ministers have signed off on a third bailout deal, including a diverse range of tax increases and commitments to curtail spending. A memorandum between the two parties, released on the blog of the former finance minister Yanis Varoufakis, acknowledges that the Government has recently… – Continue reading
Offshore e-commerce service providers should make themselves aware of changes to Japanese law that affect their operations. Pursuant to a recent amendment of the Consumption Tax Act, a new Registration of Foreign Business Operator system has been in effect since July 1, 2015. Many affected businesses have not yet registered… – 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
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
On May 20, 2015, the U.S. Treasury Department (“Treasury”) released five sets of proposed revisions to the U.S. Model Income Tax Convention (“Model Treaty”) for public comment. The Model Treaty was last updated in 2006. The purpose of the proposed revisions is to ensure that the United States maintains the… – Continue reading
The decree to implement Italy’s “patent box” has been signed by Minister of the Economy and Finance Pier Carlo Padoan and Minister of Economic Development Federica Guidi and should be gazetted shortly. The patent box will offer a preferential tax regime in 2015 for income derived from the use or… – Continue reading
Overpayments are often the result of errors on the part of the Government rather than criminal intent Last month the National Audit Office published a ‘stocktake’ of incorrect payments by Department for Work & Pensions and HM Revenue & Customs to those claiming state benefits, including working tax credits. It… – Continue reading
First it was three years, now it’s three months. The Senate’s attempt to pass a multiyear highway bill ran off the road this week after House Republicans announced they will adjourn one day early for the month-long August recess. The House’s early departure forced the Senate to acquiesce to a… – Continue reading
There is a rising trend that many start-ups incorporate their ultimate holding companies abroad, especially in Singapore for various reasons with tax being one of the top 3 factors for such decisions. Some of them have restructured the holding structures after few months of direct Indian holding to accommodate requests… – Continue reading
In the first 100% Conservative Budget in nearly two decades, chancellor George Osborne has introduced a raft of changes, including significant revisions to UK non-dom status. On 8 July, chancellor George Osborne delivered the first Conservative Government Budget for 19 years. Many headlines had already been flagged up in advance,… – Continue reading
With different tax laws, exemptions, double taxation treaties and free trade zones for services exports affecting outsourcing operations across Latin America, gaining a solid understanding of the distinct tax obligations in each country is imperative. In a bid to attract investment, several Latin American countries have introduced double taxation treaties,… – Continue reading
South Africans who provide services from within this country to entities or individuals in another country should not be able to claim a special tax credit for foreign withholding taxes. This is according to a proposal by National Treasury in the Draft Taxation Laws Amendment Bill, which was released for… – Continue reading
Introduction US tax treaty policy can be affected by pressures for tax reform from within the United States and by major developments in international taxation from without. Talk of US tax reform has been widespread for years, although it is sometimes hard to gauge how much of the talk is… – Continue reading
The total of uncollected VAT and income revenue by HM Revenue and Customs (HMRC) rose by £1 billion in the last 12 months to an eye-watering total of £34 billion. The £34 billion ‘tax gap’ – the difference between what HMRC is actually owed and what it physically collects –… – Continue reading
Senate tax writers cleared a hodgepodge of expired tax breaks on Tuesday, as lawmakers insisted they don’t want to wait until year’s end to restore a group of incentives that historically has had bipartisan support. The Finance Committee voted to extend the roughly $95 billion collection of tax breaks, known… – Continue reading
Energy giants called to explain billions in tax havens To describe Gorgon as another super-sized resources project in Western Australia does not do justice to the scale and scope of the venture. When the taps are turned on later this year and liquefied natural gas begins to flow, Australia will… – Continue reading
The long-awaited formation of the Asean Economic Community (AEC) is just over five months away. Drawn by the promise of a freer flow of goods, services, investment, capital and skilled labour, many businesses need to study how to prevent or reduce the effects of double taxation. Double taxation results from… – Continue reading
Top Democrats are increasingly embracing a framework for taxing offshore corporate earnings that has long been favored by Republicans, as the two parties seek a deal that could provide long-term funding for the nation’s highways Sen. Charles Schumer (D-N.Y.) is the latest Democrat to get on board, releasing a plan… – Continue reading
A ruling at the First-tier Tribunal has allowed different form of tax credit relief on certain types of offshore dividends taxed in the UK. Overpayment claims for 2010/11 and later years should be considered immediately. Shirley v HMRC A UK resident who benefited from an overseas trust has successfully claimed… – Continue reading
The US Administration has put more of its hoped-for, but perhaps poltically difficult, tax reforms into the Fact Sheet that was issued after the 2015 United States-China Strategic and Economic Dialogue held in Washington on June 23-24. In the 2014 Fact Sheet, the Administration had merely stated that it was… – Continue reading
The Bahamian insurance industry was yesterday granted a ‘last-minute’ two-week extension for the filing of its first Value-Added Tax (VAT) ‘credits’ claim, a leading executive acknowledging the sector “didn’t get everything we wanted”, reports the Bahamas Tribune. Emmanuel Komolafe, the Bahamas Insurance Association’s (BIA) chairman, told Tribune Business that the… – Continue reading
Error meant that BBC Trust was not told in advance about creation of two companies designed to benefit from creative industry tax credits The BBC Trust has fired a warning shot over the bows of the corporation’s executives, calling on them to “have regard to the BBC’s reputation” following public… – Continue reading
He has distorted the facts about the nation’s current tax system. Chris Christie repeatedly has said that U.S. corporations are taxed twice on income earned abroad, claiming in one speech that IRS officials “don’t recognize the tax you paid to a foreign country.” That’s false. It’s true that the U.S…. – Continue reading
Crucial deadlines are approaching for millions of U.S. taxpayers who live abroad or have offshore financial ties. For expatriates, the annual income-tax filing deadline is normally June 15, instead of April 15. In addition, all U.S. taxpayers with offshore accounts totaling more than $10,000 in 2014–regardless of where they live–have… – Continue reading
