Category: Jurisdiction

UK enforcement agencies to visit Cayman

(CNS): The UK is expected to send law enforcement officials to Cayman in the New Year to enhance the current cooperation regime between this jurisdiction and the authorities in Britain regarding financial crime and money laundering. Financial Services Minister Wayne Panton said that experts are coming at Cayman’s invitation to… – Continue reading

___uk to modify patent box in line with oecd recommendations__

Its approach includes a new “nexus principle”, as agreed by the multinational Organisation for Economic Cooperation and Development (OECD). This is designed to ensure that the benefits of the UK tax regime are only available where the research and development (R&D) expenditure required to develop that innovation also took place… – Continue reading

Update to Canada’s FATCA litigation

The grassroots group responsible for launching the FATCA-based litigation in Canada has issued a public call for witnesses. They are looking for “a Canadian who has been somehow harmed by this FATCA legislation, are interested in helping out by becoming a Witness in our lawsuit, and are willing to have… – Continue reading

Hundreds more evaders caught by the taxman: Number of fraudsters prosecuted for fiddling the system up 58% in a year

Hundreds more people who fiddled their tax have been prosecuted in the past year, it was revealed today. HM Revenue & Customs (HMRC) has said its assault on tax evasion has produced a 58 per cent rise in convictions with criminals getting a total of 400 years in jail. HMRC… – Continue reading

Canada: Temporary Assignment Of An Employee From Canada To The United States – December 8, 2015

This article is the fourth and final part in a series examining the Canadian and U.S. income tax implications of the temporary assignment of an employee from Canada to the U.S. Specifically, these articles address the situation of an employee remaining employed by a Canadian entity, but temporarily assigned to… – Continue reading

Investing in Morocco

Over recent years, Kingdom of Morocco has created a legal and regulatory framework very attractive for foreign investors. In addition to its political stable environment, a recent series of tax treaties with numerous countries and reforms in almost all of its sectors of activities, in conjunction with its creation of… – Continue reading

Tax info sharing kicks in 2017

Come 2017, tax information on all foreign nationals holding bank accounts or other financial holdings in Cayman will be automatically shared with tax authorities in their home countries when the Mutual Administrative Assistance in Tax Matters convention kicks in. Maples, in a Cayman Islands Automatic Exchange of Information update statement… – Continue reading

Meg Hillier: Meet the Public Accounts Committee chairwoman taking over from Margaret Hodge

Meg Hillier has a tough act to follow. This parliament’s Public Accounts Committee chairwoman had a ringside seat watching her predecessor, Margaret Hodge, tear into tax avoiders and the tax man. “It is very exciting – you see all the guts of Whitehall spilled out in front of you,” she… – Continue reading

HMRC turns to aggressive tactics to target accountants

HMRC has been accused of targeting accountants with “aggressive” letters, without any evidence A City law firm, RPC, claims that the Revenue is writing to traditional high street accountants, implying they are helping clients avoid tax, without offering evidence in support. According to RPC, the letters imply that if accountants… – Continue reading

Ryanair pilot supplier reported to be at centre of tax evasion probe

British police and German investigators searched Brookfield Aviation International headquarters The Times of London reports this morning that a company that supplies Ryanair with pilots is at the centre of an international investigation for tax evasion. It is understood both British police and German investigators have searched the headquarters of… – Continue reading

Senate approves tax treaties with Turkey, Italy & Germany

The Senate concurred, after hearing, the ratification of tax treaties between the Philippines and the governments of Italy, Germany and Turkey that will prevent double taxation. Sen. Juan Edgardo “Sonny” Angara said the approval on third and final reading of Senate resolutions 1540, 1541, 1542 on the double taxation avoidance… – Continue reading

Company which owns Queen’s jeweller Mappin & Webb ‘has paid no corporation tax for five years despite £66million profits’

The company that owns the Queen‘s jeweller Mappin & Webb has paid no corporation tax for five years – despite profits of £66million. The allegations made against Mappin & Webb owners Aurum Holdings came as the conduct of firms holding royal warrants was scrutinised amid revelations about their tax arrangements…. – Continue reading

MEPs to Commission: make member states share tax information and protect whistle-blowers

Tax evasion costs the EU €1 trillion a year in lost tax revenue, according to the European Commission. The Lux leaks scandal showed that EU countries sometimes court multinationals with advantageous tax schemes. These practices were investigated by the Parliament’s special committee on tax rulings. MEPs adopted its report last… – Continue reading

India, Saudi Arabia try to sort out joint fund irritants

NEW DELHI: India and Saudi Arabia are exploring ways to overcome the issue of exemption from capital gains tax on the proposed $750-million joint fund to facilitate investments into the Indian infrastructure sector. “Unfortunately, we have not been able to move forward on our bilateral fund with Saudi Arabia due… – Continue reading

Canada: Canadian Tax Amnesty – Time May Be Running Out For Canadians With Swiss Bank Accounts To File A Voluntary Disclosure With CRA

Swiss Banks Sending Letters to Canadian Account Holders For resident Canadian taxpayers that hold Swiss bank accounts which have not been reported to the Canada Revenue Agency (“CRA”), the window to come clean with Revenue Canada by filing a Voluntary Disclosure, and thereby avoid financial penalties and the possibility of… – Continue reading

An Overview of Transfer Pricing in Vietnam

Transfer pricing is a tax planning method where related companies enter into transactions among each other to shift funds, and thereby profits. For instance, a parent company can extract funds from a subsidiary by having the issue a dividend, but the parent can also provide a service to subsidiary and… – Continue reading

A special relationship

Each year the elected leaders of Britain’s overseas territories (OTs) gather from around the world to meet with British Ministers in London. Their objective is to discuss the continuing partnership with the UK, to establish priorities and to try to resolve differences. For the most part the issues covered at… – Continue reading

Kuwait, Kyrgyzstan sign cooperation agreements

Kuwait and Kyrgyzstan on Sunday signed a host of bilateral agreements and a MoU, covering various fields of cooperation. The signing ceremony, at Bayan Palace, was attended by His Highness the Amir Sheikh Sabah Al-Ahmad Al-Jaber Al-Sabah, visiting Kyrgyz President Almazbek Atambayev, His Highness the Crown Prince Sheikh Nawaf Al-Ahmad… – Continue reading

Outcry over royal warrant handed to foreign-owned firms ‘who legally avoid paying tax’

The Queen’s jeweller has not paid corporation tax in five years, it is claimed, despite reported profits of £66million Demands are growing for a review of the royal warrant system after firms supplying the monarchy were criticised for moving profits overseas. The crest is a mark of British craftsmanship and… – Continue reading

‘The best has yet to come in financial services sector’

Outgoing Deloitte Malta chairman and senior partner Andrew Manduca speaks to Anthony Manduca about the future of the financial services sector in Malta, his 36 years in the profession and the need for more accountants. Andrew Manduca is very confident about the future of Malta as a leading international financial… – Continue reading

Signing of Advance Pricing Agreements (APAs) signals major push towards tax certainty

The Central Board of Direct Taxes (CBDT) has recently entered into eleven (11) more Advance Pricing Agreements (APAs) with Indian subsidiaries for foreign companies. In a major push towards providing certainty to foreign investors in the arena of transfer pricing, the CBDT signed these APAs operating in various segments of… – Continue reading

How Microsoft moves profits offshore to cut its tax bill

Cash doesn’t flow directly from buyers’ pockets to Microsoft’s headquarters in Redmond, Wash. Instead, the company operates through three regional sales units, centered in Ireland, Singapore and Puerto Rico. These groups control the rights to profit from Microsoft products around the world. By conducting sales from places with small populations… – Continue reading

Globalisation and regulation driving industry growth

The asset servicing industry is likely to see a growth spurt driven by globalisation and regulatory change, according to an Ernst & Young (EY) report, reports the Asset Servicing Times. The report outlined six key drivers of growth: asset growth and breadth; globalisation; regulation; new products; platform extension and consolidation;… – Continue reading

Isle of Man to be removed from Spain’s ‘tax haven blacklist’

The Isle of Man has signed a tax information exchange agreement with Spain, reports the Isle of Man Today. It’s part of what the Manx government calls its ‘continuing commitment to meet international standards in tax co-operation and transparency’. The agreement was signed by Mr José Manuel Gutiérrez Delgado, Financial… – Continue reading

Permanently support families, not corporate tax giveaways

Temporary lapses of judgment can be corrected. Permanent mistakes are harder to fix. Congress is poised to offer very costly permanent tax giveaways to powerful corporations. It is also considering renewing more modest tax credits that encourage work and support millions of low-wage workers and their children. This is an… – Continue reading

TAXE: Have We Taken the Right Path To Ensure Fairer and More Efficient Taxation in the European Union?

After the LuxLeaks affair in November 2014, the European Parliament established a special committee “on tax rulings and other measures similar in nature or effect” (TAXE) in February 2015. The committee’s report was adopted in a plenary session of the European Parliament on 25 November 2015. The Conference of Presidents… – Continue reading

Nigeria: Pricing Of Intangible Property (“IP”) Rights In Nigeria – Why Commercial, Fiscal And Currency Control Interests Must Align

A review of Nigeria’s present fiscal and currency control regimes as they relate to commercial and industrial IP rights become imperative in order to give impetus to government’s efforts towards reviving and diversifying the country … Prior to the introduction of the Income Tax (Transfer pricing) Regulations on 2 August,… – Continue reading

Capacity market: Fossil fuel companies controlled by tax haven entities receive millions in subsidies

Fossil fuel companies and nuclear power producers, some of which have been involved in shaping government energy policy, will receive over £834 million* in state subsidies for the winter of 2019-2020, the government has announced. The big winners of the capacity market auction, which is managed by National Grid and… – Continue reading

Royal warrant companies accused of using tax havens and moving their manufacturing out of Britain

Companies like Mappin & Webb have not paid any corporation tax for the past five years, according to the Sunday Times Several companies which hold the much-coveted royal warrant have come under scrutiny after being accused of benefiting from tax havens and moving their manufacturing out of Britain. The warrants… – Continue reading

‘Final’ UK disclosure facility for tax irregularities to run until September 2018, says government

A “final” disclosure facility which will give UK taxpayers a means of correcting any irregularities involving offshore income and gains will run until September 2018, one year longer than originally anticipated, the government has announced. No details of the planned disclosure facility have been published, but it is expected to… – Continue reading

The ugly face of FATCA: Why life for American expats is getting harder

The Foreign Account Compliance Act (FACTA), while designed to “minimize tax cheats”, is making banking — and life in general — painfully difficult for millions of American expats, according to Mike Michelini, a Hong Kong-based business consultant withglobalfromasia.com. Here is his editorial. Under FACTA, all 8 million or so Americans… – Continue reading

Urgent advisory: Commence voluntary disclosures before the end of 2015

Data from the Canada Revenue Agency (“CRA”) confirms that voluntary disclosures (“VDs”) of offshore assets, gains and income hit record levels in 2015. This proliferation of VDs is attributable to various factors, including increased public awareness of: international tax compliance issues through media reports; the CRA’s Offshore Tax Informant Program;… – Continue reading

ATAF pushes for scrapping of double taxation

THE African Tax Administration Forum (ATAF) has come up with a draft document on avoidance of double taxation and prevention of fiscal evasion within the continent. The Zimbabwe Revenue Authority (Zimra), a member of ATAF, has said avoidance of taxation and prevention of fiscal evasion was with respect to taxes… – Continue reading

Tax evaders to feel full force of the law

New legislation brings the possibility of jail sentences for those who aren’t upfront with HMRC about assets held overseas A new criminal offence is due to hit the statute book next year under which people who engage in tax evasion abroad could get a criminal record, fines and a jail… – Continue reading

Guiding Clients on the IRS Offshore Voluntary Disclosure Program

One of today’s most talked about tax topics is the Offshore Voluntary Disclosure Program of 2014 (OVDP) and the compliance of individuals, institutions, and governments with the Foreign Account Tax Compliance Act. However, it is vital for one to understand why the IRS provided the public with the opportunity represented… – Continue reading

IFA and tax promoter guilty of film tax fraud

An IFA and an accountant have been convicted of attempting to steal millions in a tax fraud linked to the film industry. Terrance Potter, formerly an accountant at EY, was identified as the architect of the fraud following an investigation by HM Revenue & Customs (HMRC). Potter devised and sold… – Continue reading

Exchange of Tax Information to Promote International Standards

Basseterre, St. Kitts, December 11, 2015 (SKNIS): The proposed amendments to the Saint Christopher and Nevis Mutual Exchange of Information on Taxation Matters (Amendment) Bill, 2015 would greatly assist in minimizing the challenges that St. Kitts and Nevis faces when executing obligations under Agreements with treaty partners, said Prime Minister,… – Continue reading

Anastasiades to sign deals with Kiev

Cyprus will sign agreements with Ukraine on Friday, as President Nicos Anastasiades visits Ukraine to make deals on bilateral issues such as double taxation, higher education, energy, and other areas of cooperation. Anastasiades is on an official visit to Ukraine and will meet on Friday with the President of Ukraine… – Continue reading

Business Brief – Double Tax Agreement – Residence – change of HMRC practice

Following an agreement between the UK and Jersey, HMRC has published an important change of interpretation on residence for treaty purposes. HMRC’s view now is that the better interpretation of residency article in the UK-Jersey Double Tax Agreement 1952 (“UK Jersey DTA”) is that it includes a tie breaker provision… – Continue reading