Certainty and reduced litigation on transfer pricing (TP) issues will be the cornerstone of creating a non-adversarial tax regime in India. The authors believe that Budget 2015 ought to lay out a roadmap to achieve this goal for TP issues – Recent positive progress on the Advance Pricing Agreement (APA)… – Continue reading
BERLIN – Geneva prosecutors searched the premises of HSBC’s Swiss subsidiary on Wednesday after launching a money-laundering investigation over a report that the bank helped hide millions of dollars for drug traffickers, arms dealers and celebrities. Prosecutors said they were investigating HSBC Private Bank (Suisse) SA and persons unknown for… – Continue reading
The abolition of unfair taxes was one of the foundational principles of Magna Carta, a document that King John assented to on June 15, 1215 at Runnymede, England. Taxation must be fair, and requires the consent of the people. There is no more unfair aspect of fiscal law than retroactive… – Continue reading
On February 6, 2015, the Organisation for Economic Co-operation and Development (OECD) announced that it has reached agreement with the Group of Twenty (G-20) Finance Ministers on three key elements of its base erosion and profit shifting project. The three elements, which the OECD said will enable implementation of the… – Continue reading
Feb 7 (Reuters) – A former Swiss banker charged by U.S. prosecutors with helping wealthy Americans evade taxes has been arrested in Germany pending extradition to the United States, his lawyer said on Saturday. Roger Keller, a onetime client adviser in Zurich at Wegelin & Co, was one of three… – Continue reading
G20 finance ministers will hear about the OECD’s three-pronged approach to implementation of the BEPS Action Plan at their meeting in Istanbul on Monday and Tuesday of next week (February 9 and 10). The OECD, which is leading the work, outlined today what has been agreed so far with the… – Continue reading
New Delhi, Feb. 4: The notification of a social security deal with Norway – often called totalisation agreements — may pave the way for a similar pact with the US that has been hanging fire for a decade. Under the pact, employees sent by Indian firms to Norway on a… – Continue reading
In 2014, China continued to develop its taxation system affecting domestic and crossborder transactions. This “Legal Flash – Special Edition 2014” highlights the most significant tax updates of the year. Please see our monthly legal flashes for more information and analysis here. Taking a step-forward on anti-avoidance provisions, the State… – Continue reading
The present French Tax Update will focus on (i) the most salient features of the new double tax treaty signed by the People’s Republic of China (China) and France on November 26, 2013 (New DTT), (ii) the new double tax treaty signed by Singapore and France on January 15, 2015,… – Continue reading
A Sunday Mirror investigation has found Apple, Facebook, Amazon, Google, Ebay and Starbucks has paid less than one per cent tax Six of the world’s biggest companies paid just 0.3 per cent of their UK earnings in corporation tax last year, a Sunday Mirror probe has found. We have examined… – Continue reading
Jonathan Weiss hasn’t lived in the US for 25 years. But that didn’t keep his foreign bank account from being frozen in the wake of new US tax laws. Find out how you can avoid the same fate at the hands of FATCA. “I had been living in Switzerland for… – Continue reading
On 11 November 2014, the UK and German governments issued a joint statement on proposals for new rules for preferential intellectual property (IP) regimes within the G20/OECD base erosion and profit shifting (BEPS) project. Germany currently does not have a special regime for Patent Boxes, but suffers from structures that… – Continue reading
New Delhi, Jan. 23: India and the US have failed to make much progress in the totalisation pact that addresses the the problem of the double payment of social security taxes by Indian software professionals in America, dampening expectations surrounding President Barack Obama’s visit this weekend. Top officials said discussions… – Continue reading
MUMBAI: UK-based telecom company Vodafone Group will hold its board meeting in Delhi later this month, said two people aware of this. It will be the second such meeting in the country since Vodafone acquired its business in India. The meeting is an “ordinary” board meeting with “routine” agenda items,… – Continue reading
The IRS has unveiled a secure web application, the International Data Exchange Service (IDES), for cross-border data sharing. IDES will allow Foreign Financial Institutions (FFIs) and tax authorities from other countries to transmit financial data on U.S. taxpayers’ accounts, via an encrypted pathway, to the IRS. The tool is part… – Continue reading
SUCCESSFUL INTERNATIONAL STRUCTURES in most cases begin with choosing the right jurisdiction to host a company that will form part of an international business. Depending on the company’s activities, the choice will depend on the range of double taxation treaties and the availability of tax reliefs followed by a host… – Continue reading
The thrust of the Indian government’s economic policy is encouraging, particularly the tax reform of proposed introduction of goods and services tax. NEW DELHI, JAN 20: Germany has made a case for ‘respecting the secrecy’ of any information shared with India for tax administration purposes. This stance assumes significance given… – Continue reading
(Bloomberg)– A Swiss banker who faced more than three years in prison for providing WikiLeaks with confidential details of his former employer’s offshore activities walked out of a Zurich courtroom a free man on Monday. Rudolf Elmer, 59, was given a suspended fine of 16,800 Swiss francs ($19,397) for violating Swiss… – Continue reading
Midlands businesses can still benefit from the Patent Box, according to international accountancy firm Mazars. It follows plans to amend it – resulting in a narrower focus on UK R&D. That is the verdict from Birmingham professionals Peter Jelfs, senior tax manager at international accountancy firm Mazars, and Nicholas Braddon,… – Continue reading
The German Fiscal Code provides for the possibility of a voluntary self-disclosure of tax evasion. Taxpayers are able to correct or complete their own incorrect tax returns or furnish relevant information previously omitted. In such cases, the taxpayer will be exempt from criminal prosecution for tax evasion in respect of… – Continue reading
If you want to abandon “lawful permanent resident” status, or if you want to rely on a treaty tie-breaker to claim nonresident status, you need to take some affirmative steps. Unfortunately, the taxpayer in Gerd Topsnik v. Commissioner1 did not do so. The taxpayer, a German citizen, applied for and… – Continue reading
OFFSHORE property funds should outpace most local property funds in terms of capital growth this year. Many developed countries’ property markets are offering developers low interest rates amid increasing economic growth, while SA is expected to struggle to grow and a number of property funds here will be beset with… – Continue reading
Switzerland’s Financial Centre Reforms Are A Work In Progress by Andreas Keiser, swissinfo.ch In the last few months Switzerland has made progress in making its financial centre internationally compliant. Key areas are the automatic exchange of information, enhanced administrative assistance with other countries, and the reduction of foreign untaxed assets…. – Continue reading
The Price of Offshore Revisited was written by James Henry, a former chief economist at the consultancy McKinsey, for the Tax Justice Network. Tax expert and UK government adviser John Whiting said he was sceptical that the amount hidden was so large. Mr Whiting, tax policy director at the Chartered… – Continue reading
MUNICH (AP) – Former Bayern Munich president Uli Hoeness has been granted day parole seven months after going to prison for tax evasion. Bavaria’s state justice ministry says Hoeness is allowed to leave prison during the day to work as of Friday, though he’ll have to return in the evening… – Continue reading
Swiss banks are training their crosshairs on Israeli customers. Legal sources said that in the past two weeks, the large banks in Switzerland have begun sending many queries to their Israeli customers demanding confirmation either that the assets deposited with the banks were reported to the Israeli tax authorities, or… – Continue reading
Dec 21 (Reuters) – Authorities in the German state of North Rhine-Westphalia have bought a CD containing data about several thousand German clients of a Swiss bank, German newspaper Bild am Sonntag said on Sunday without citing its sources. The clients each have accounts containing up to 5 million euros… – Continue reading
NEW YORK – The multiyear federal crackdown on wealthy Americans who duck taxes by hiding income and assets offshore is targeting a Panamanian legal services firm suspected of arranging anonymous banking services. A Manhattan federal judge on Friday approved special summonses for Sovereign Management & Legal. The approval also covered… – Continue reading
Debate on multinational tax avoidance widens The surprise announcement by the European Commission that it is to extend its request for information on tax rulings to all European Union member states has the potential to significantly shift the terms of the debate on multinational tax avoidance. The timing of the… – Continue reading
The total number of reports on controlled transfer pricing operations, received by the State Fiscal Service of Ukraine, as of October 1, 2014 exceeded 2,500. The head of the department for transfer pricing inspections at the Fiscal Service, Mykola Mishin, said at the round table “Transfer pricing in Ukraine: problems… – Continue reading
Transfer pricing has been an area of high importance for years. We are seeing that multinational companies operating in Germany are being increasingly examined by tax auditors. The level of transfer pricing expertise of the tax auditors is also increasing. Therefore, the transfer pricing environment in Germany is getting more… – Continue reading
The German government must revise rules that allow families to transfer companies from one generation to the next without paying estate tax after the country’s top court ruled the current exemption is unconstitutional. The inheritance law gives an unfair advantage to family-owned businesses over individuals passing on non-company assets, the… – Continue reading
An investigation into tax rulings provided by certain EU member states is to be widened to cover all member states, according to a press release from the European Commission.17 Dec 2014 Tax Disputes and Investigations EU & Competition Tax Public procurement and state aid Corporate tax International tax UK Europe… – Continue reading
Last March MEPs voted overwhelmingly to introduce a new transparency disclosure rule that would compel all 28 European states to make publicly accessible the real owners of companies and trusts. The decision was hailed as a major breakthrough by anti-corruption campaigners fighting financial crime and tax abuse. Lawyers working for… – Continue reading
Rome (dpa) – The head of Italy‘s tax office, Rossella Orlandi, on Monday criticized automaker Fiat‘s decision to move its tax residence to Britain after completing a merger with US peer Chrysler. “I would … like to stress that we need some sense of national pride. In Germany tax rates… – Continue reading
The wise thing is to forget the past, bring reforms to prevent generation of black money Considering other man’s point of view is Decency — George Orwell This quality seems to be in short supply in India although it is the most needed even to understand any black money retrieval…. – Continue reading
Around the world, countries are desperately seeking ways to stop multinational companies from earning profits within their borders without paying taxes on them, while stashing trillions in tax havens like the Cayman Islands. The British government, after a search, says it knows how to tax the profits Google earns in… – Continue reading
As multinationals are forced to reveal more about themselves, where should the limits of transparency lie? HOWARD SCHULTZ, the head of Starbucks, said last year that “the currency of leadership is transparency.” If so, bosses should be feeling ever more qualified to command their troops. Business is being forced to… – Continue reading
Florida Center for Investigative Reporting The Walt Disney Co. generates $18.2 billion per year in economic activity in Florida and and is responsible for more than one in every 50 jobs in the Sunshine State, according to a study the company paid for in 2011. But here’s something Disney won’t… – Continue reading
Stocks rose today for the first time in four trading days in the wake of a report showing strong retail sales in November and as oil continues its sharp decline. The Dow Jones industrial average gained 63.19 points to 17,596.34, the Standard & Poor’s 500 index rose 9.19 points to… – Continue reading
Rudolf Elmer, the former employee of Julius Baer Group Ltd. accused of revealing details of client accounts via WikiLeaks, collapsed at the start of his trial, forcing the court to postpone the case. It was not clear when the trial in Zurich District Court would continue. Proceedings had been under… – Continue reading
Minister of state stresses taxation rates remains a matter for member states Ireland has “nothing to fear” from European proposals to tackle multinational tax avoidance, the Minister of State at the Department of Finance Simon Harris said on Tuesday as EU finance ministers rubber-stamped new rules on the automatic exchange… – Continue reading
Rudolf Elmer, the former employee of Julius Baer Group Ltd. accused of revealing details of client accounts via WikiLeaks, collapsed at the start of his trial, forcing the court to postpone the case. It was not clear when the trial in Zurich District Court would continue. Proceedings had been under… – Continue reading
Juncker has put corporate tax reform firmly back on the EU agenda The “Lux leaks” scandal may have cast a shadow over Jean-Claude Juncker’s first months as European Commission president, but its real significance will be how it impacts the EU’s position on corporate tax. Some contend the scale of… – Continue reading
The EU’s most powerful official is under mounting pressure as dozens more multinational corporate names are dragged into the Luxembourg tax scandal following a new leak of confidential documents on Tuesday. Jean-Claude Juncker, president of the European commission, has been battling to distance himself from the growing furore over the… – Continue reading
China and Turkey have fallen in international rankings of perceived corruption, according to a new report released by the Berlin-based anti-corruption watchdog Transparency International (TI).09 Dec 2014 Regulatory Europe Asia Pacific Gulf Africa According to the latest edition of TI’s Corruption Perceptions Index for 2014, which scores countries on a… – Continue reading
New Delhi: Citing national security and confidentiality clauses, Finance Ministry has declined to disclose information on exchange of correspondence among India, Swiss and German authorities in connection with the black money probe. Replying to an RTI query, the ministry said it was obtaining information regarding Indians having accounts in foreign… – Continue reading
A new leak of confidential documents expands the list of big companies seeking secret tax deals in Luxembourg, exposing tax-saving maneuvers by American entertainment icon The Walt Disney Co., politically controversial Koch Industries Inc. and 33 other companies. Disney and Koch Industries, a U.S.-based energy and chemical conglomerate, both created… – Continue reading
MOSCOW, December 8 (RAPSI) – The world’s four largest audit firms, which provide services under the FATCA norms, have provided contradictory consultations to their Russian clients, Kommersant newspaper writes on Monday. The Big Four are the four largest international professional services networks, offering audit, assurance, tax, consulting, advisory, actuarial, corporate… – Continue reading
Germany’s Deutsche Bank dodged over $100 million in federal taxes, according to allegations in a lawsuit filed by the U.S. Attorney’s office in the Southern District of New York Monday afternoon. “Through fraudulent conveyances involving shell companies, Deutsche Bank tried to make its potential tax liabilities disappear. This was nothing… – Continue reading
