The most common error NRIs commit while filing tax returns is to use the status of residents in India. Non-resident Indians (NRIs) in the UAE enjoy the twin advantages of not having to pay tax in their country of domicile and most sources of income are exempted from tax in… – Continue reading
MUMBAI: Foreign portfolio investors (FPIs) are yet to exorcise the ghost of minimum alternate tax, or MAT. These offshore asset managers, based out of financial centres like Singapore, Hong Kong and New York, will now have to convince the Indian tax office that they do not have “place of business”… – Continue reading
South African Tax Legislation: Proposed Amendments in an International Tax Context[1] This article sets out a brief summary of some of the proposed amendments introduced by recent South African draft Tax Bills. The article focuses on amendments in the context of international taxation. The draft Taxation Laws Amendment Bill, 2015… – Continue reading
Possible opportunities for refund of Dutch dividend withholding tax On 17 September 2015, the Court of Justice of the European Union (“CJEU”) ruled in three distinct (yet comparable) cases that the levy of Dutch dividend withholding tax in relation to portfolio shareholdings in Dutch companies is in conflict with the… – Continue reading
Millions have pounds have gone to countries such as Belize and Anguilla UK paid out £45m to 13 countries on tax haven ‘blacklist’ in just one year Campaigners estimate use of offshore havens costs Treasury £18b a year Revelation will anger Tory backbenchers who have criticised Cameron British aid money… – Continue reading
BRITISH taxpayers forked out £45million in foreign aid spending to countries classed as tax havens in just one year, it emerged today. Nations such as Belize, Marshall Islands, Seychelles and Vanautu – which are all included on a European Commission ‘blacklist’ of international tax havens – have all received cash… – Continue reading
How analytics will nab cheaters. Tomorrow is the Australian Taxation Office’s official cutoff for 2014-15 personal tax returns. Will you be tempted to tell fibs about your income? How will the tax man ever know? Take note: it may already know – or at least can find out – a… – Continue reading
Case involving Dr Brian Mulrean and firm Keveney Monahan settled confidentially An accountant who sued a Dublin dentist for just under €50,000 in professional fees told a judge he had to navigate his way through 41 offshore and local bank accounts. Barrister Jeananne McGovern said in the Circuit Civil Court… – Continue reading
NEW DELHI: The Central Board of Direct Taxes ( CBDT), India’s apex direct taxes body, has said investors will not face any tax on capital gains on offshore rupee bonds. “It has been decided that capital gains, arising in case of appreciation of rupee between the date of Issue and… – Continue reading
With new UK domicile rules coming into force in April 2017, Luca should consider an offshore bond to protect his assets from income tax and CGT, writes Gordon Andrews of Old Mutual Wealth. THE CASE Luca is 52. He is Italian, but he has been living in the UK for… – Continue reading
The finance ministry on Tuesday set up a 10-member committee to review the Income-Tax Act to avoid litigation and improve ease of doing business, after solving past minimum alternate tax (MAT) cases and easing transfer pricing norms. The announcement came on a day when a World Bank report showed only… – Continue reading
The new non-resident capital gains tax came into force in Guernsey on 6 April 2015. The rules intend to capture disposals of residential property in the United Kingdom by all non-residents. These notes provide a summary of who and which property is affected, and describe how a new UK tax… – Continue reading
India will apply a 5 percent withholding tax to offshore rupee bonds for foreign investors, in line with the rate applied to domestic debt, Manoj Joshi, joint secretary at the finance ministry, told reporters on Tuesday. The clarification comes amid some confusion about whether the withholding tax also applied to… – Continue reading
MUMBAI: The government is set to ease a few pre-set conditions for offshore fund managers to allow private equity investors to shift base to India without attracting a tax on capital gains by relaxing safe harbour rules, people familiar with the matter said. The government is likely to allow a… – Continue reading
Provisional Measure No. 692/2015 increases the income tax rate on capital gains earned by individuals and certain companies1 from 15% to 15%-30%. As from January 1st, 2016, when the new rules will become applicable, capital gains earned on the sale or disposition of any assets or rights located in Brazil… – Continue reading
India has told the International Court of Justice that it will soon appoint an arbitrator to resolve the Rs 10,247-crore tax dispute with British oil explorer Cairn Energy Plc. Cairn on March 10 sought arbitration under the India-UK Bilateral Investment Protection Agreement against the tax demand raised on a 2006… – Continue reading
Rwanda has commissioned an audit into recent merger and acquisition deals involving foreign firms in its latest effort to clamp down on tax avoidance among multinational corporations. This comes amid growing concern that multinational companies move profits from the countries where they are generated and, in so doing, reduce national… – Continue reading
According to recent estimates, Chinese investors represented the largest group of foreign investors in U.S. real estate in the second quarter of 2015 with $1.9 billion in acquisitions. In the last 12 months, Chinese investors acquired $5.9 billion in commercial U.S. real estate, and Asia was second overall to Europe… – Continue reading
Foreign tax credit available to taxpayers even on a portion of exempt income. Exempt income (under section 10A) is chargeable to tax under section 4 and 5 of the ITA although no tax may actually be payable. Actual payment of the tax is not necessary for claiming foreign tax credits…. – Continue reading
Mauritius beats Singapore as the world’s top route for foreign investment to India and is a hub for thousands of firms managing half a trillion dollars in assets. But there are only a sprinkling of office blocks in Ebene Cybercity, the heart of the tiny Indian Ocean island’s financial services… – Continue reading
“If we do not achieve growth, revenue will not increase. If revenue does not increase, expenditure cannot be expanded.” It is with this statement that the Minister of Finance set the tone of the Medium Term Budget Policy Statement (MTBPS) which he presented on Wednesday against a fiscal backdrop of… – Continue reading
The Government has moved to boost the Revenue’s powers to tackle tax evaders and it is closing off loopholes used by companies, landlords and individuals to reduce their tax payments. The new measures are included in the Finance Bill, published on Thursday morning, which gives legislative effect to Budget 2016…. – Continue reading
Wealthy investors have snapped up at least £100 billion of property across London using overseas companies in the past six years, new figures reveal today. Official data seen by the Standard shows that since 2008 there have been 27,989 purchases of homes, buildings and land in the capital by shadowy… – Continue reading
Ireland’s budget statement for 2016 (Budget) was delivered by the Minister for Finance last week. The Budget’s primary focus was on personal tax matters, which is somewhat unsurprising given the general election early next year. However, the Budget also contained two key announcements on Ireland’s corporation tax system. In line… – Continue reading
Former chair of the UK public accounts committee Margaret Hodge, who has repeatedly attacked the use of offshore tax avoidance schemes, has called for an overhaul of the British tax system. Speaking during an annual Professional Fee Protection (PFP) tax investigations conference, Hodge said the current tax regime in the… – Continue reading
Hillary Clinton is repeating the Democrat trope about “offshore tax havens” that immorally divert profits from workers and the taxman. Closing these is a central plank of her promised agenda as President, she explains in an op-ed laying out her economic agenda. Setting aside the economic merits of her plan,… – Continue reading
Most of yesterday’s pre-election budget statement for 2016 (the “Budget“) by Ireland’s Minister for Finance (the “Minister“) focused on personal taxation. In the portion of his statement covering corporation tax, two key announcements were made in line with expectations following on from the publication of the final reports under the… – Continue reading
The Luxembourg government submitted draft legislative proposals to Parliament—legislation that, if enacted, would both implement certain provisions of the OECD’s base erosion and profit shifting (BEPS) actions and provide for certain EU-compliant measures. The proposals also would be intended to improve the competitiveness of the Luxembourg tax system. The proposals… – Continue reading
NEW DELHI: Foreign portfolio investors have sought stability in taxation policies as the government looks to lure them to set up fund management business in the country. They have made a number of suggestions, Economic Affairs Secretary Shaktikanta Das said after a meeting of the finance ministry with representatives of… – Continue reading
The BEPS Project involves input from the 34 member countries of the OECD, all G20 members, and more than 40 developing countries. The objective of the BEPS Project is to close gaps in international tax rules, effectively eliminating or substantially reducing BEPS; and to secure government revenues by ensuring that… – Continue reading
Executive summary A new bilateral Tax Arrangement between the Netherlands and Curaçao (TANC), which essentially functions as a tax treaty,1 was ratified by the Dutch Parliament and formally published on 9 October 2015. The TANC will apply to income received on or after 1 January 2016. This long-awaited TANC will… – Continue reading
The Base Erosion and Profit Shifting (BEPS) project, a joint initiative between G20 countries and the OECD, works towards the development of a coherent global taxation system which addresses BEPS concerns. The main purpose of such initiative is to address the gaps in the current international tax rules relating to… – Continue reading
Legislative Activity House Lawmakers Schedule Markup of Transportation Bill Without Revenue Provisions Last week, on Friday, October 16, the House Transportation and Infrastructure Committee released a six-year, $325 billion highway funding bill (the Surface Transportation Reauthorization and Reform Act of 2015); a markup of the legislation is scheduled for Thursday,… – Continue reading
Introduction On 5 October 2015, the OECD delivered the final package (“Final Package”) of its comprehensive Action Plan on Base Erosion and Profit Shifting (“BEPS“). This marks a culmination of a process that started in September 2013, when the Group of 20 (“G20”) Leaders first endorsed the Action Plan on… – Continue reading
The rising wealth of Asia Pacific nations, including Singapore, means more and more people have looked internationally for opportunities to invest in overseas property markets. Recent stock market events have shown the importance of a diversified portfolio capable of riding out the storm when economic conditions put immense pressure on… – Continue reading
Concerned about the impact of tax havens, world powers are tightening the noose on multinationals seeking tax advantages. India wants changes to its tax treaty with Mauritius, forcing the island’s new government to re-examine its business model and focus elsewhere. There is debate in the new government, which took office… – Continue reading
The Internal Revenue Service (IRS) has released a revised October 2015 version of its Publication 597, which provides information on the United States-Canada double taxation agreement (DTA), reports Tax News. A number of DTA provisions that most often apply to US citizens or residents who may be liable for Canadian… – Continue reading
Extensive use has been made of trusts in South Africa, both for tax planning and for the purposes of reducing (or eradicating) one’s estate duty liability upon death. As the use of offshore trusts as a estate and wealth planning vehicle increases, one needs to consider if and how offshore… – Continue reading
Golden visa EU citizens may freely register as residents in Portugal. However, non-EU citizens may also obtain residence in Portugal if they obtain a ‘golden visa’ by participating in investment activity and fulfilling certain requirements. Requirements Obtaining a golden visa requires one of the following types of investment: acquisition of… – Continue reading
Permanent Establishment Based on the new treaty the definition of permanent establishment also includes a building site or construction or installation project or any supervisory activities in connection with such site or project constitutes a permanent establishment only if it lasts more than 9 months. Dividends The withholding tax rate… – Continue reading
The Dutch government presented its Tax Bill 2016 on 15 September 2016. Three elements of this bill could specifically affect multinationals, international investors and investment funds with Dutch headquarters or group companies: The anti-avoidance rules in respect of non-resident taxation of foreign corporate shareholders and the dividend withholding tax treatment… – Continue reading
This summer brought some very significant amendments to the Cyprus tax laws, further enhancing Cyprus’ favourable tax regime. On 17 July 2015, the following laws were amended: The Special Defense for Contribution law No. 117(I) of 2002 as amended; The Income Tax Law No 118(I) of 2002 as amended; and… – Continue reading
Tax experts from the United States, United Kingdom, Canada, Brazil and Israel spoke at a two-day conference at Michigan Law about the challenges of the Foreign Account Tax Compliance Act (FATCA) and a multitude of other issues at the intersection of the law of taxation and citizenship. Panel discussions at… – Continue reading
To facilitate the exchange of Foreign Account Tax Compliance Act (FATCA) data under the intergovernmental agreements (IGAs) with Australia and the U.K., the U.S. Competent Authority has signed Competent Authority Arrangements (CAAs) with the Competent Authority of each country, announced IRS officials on September 24. The CAAs are the first… – Continue reading
The Organization of Economic Cooperation and Development (OECD) released its final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) Project on Monday October 5th, 2015. The final package of BEPS measures includes new minimum standards on: country-by-country reporting, which for the first time will give tax administrations a… – Continue reading
No focus on stock markets and other money-laundering machines After all the noisy assertions, only Rs4,147 crore of unaccounted wealth was declared during the special 90-day compliance window of the The Undisclosed Foreign Income and Assets (Imposition of Tax) Act, 2015 (Black Money Bill). Of this, just Rs2,488 crore will… – Continue reading
Israeli importers and exporters, hi-tech and trading groups will all be in the base erosion and profit shifting firing line. On October 5 the Organization for Economic Cooperation and Development published a final comprehensive package of measures aimed at multinational corporations, large and small, that engage in BEPS – base… – Continue reading
EBENE, Mauritius, Oct 12 (Reuters) – Mauritius plans to launch a trading platform to hedge African currencies against the U.S. dollar, part of a bid to expand its role as a financial hub for the continent, the financial services minister said. The Indian Ocean island is also in talks to… – Continue reading
Historically, unlike UK residents who are generally liable to CGT on disposals of UK residential property (other than their principal residence), non-residents have been able to dispose of such property potentially free from UK CGT. The UK government sought to address this inconsistency by introducing a CGT charge in the… – Continue reading
NEW DELHI: Within days of getting a favourable verdict in the Rs 8,500 crore transfer pricing case from the Bombay High Court, Vodafone Group CEO Vittorio Colao will call on Finance Minister Arun Jaitley this week. Colao will visit India on October 14 and is scheduled to meet Jaitley the… – Continue reading
