INTRODUCTION The Taxation Laws Amendment Act, 2015 and the Tax Administration Laws Amendment Act, 2015 have now both been passed by Parliament, but await signature by the President. Once again, and for the second year running, the number and scope of the changes to the various fiscal Acts (mainly the… – Continue reading
In 2015, after returning from a 40 years-long Swiss tax exile, IKEA’s founder and the 11th richest person in the world, Ingvar Kamprad, paid Swedish tax for the first time. In 2014, Kamprad declared income of €1.9 million in Sweden. As a result, he was subject to Swedish personal income… – Continue reading
We have on several occasions fingered Panama as a particularly recalcitrant secrecy jurisdiction: our recent Panama Narrative Report spills a fair number of beans in that respect. Its recalcitrance is perhaps hardly surprising, given the quantity of Colombian and Mexican drugs money believed to be sheltered there – to name… – Continue reading
Patent Boxes, Innovation Boxes, Intangible Property Boxes, Knowledge Development Boxes (IP Regimes) – countries may use different names, but all of these regimes are designed to allow a preferential rate of tax to be applied to income generated from intangible property (IP). There are a number of these regimes in… – Continue reading
There are a variety of benefits to moving offshore, yet few would argue the assertion that tax neutrality is paramount among them. As anyone familiar with the phrase “tax haven” would surely recognize, many countries offer strongly favorable tax terms as an incentive to draw new business. Written by CT… – Continue reading
The draft agreement is intended to settle the issue of taxation of business profit, property revenues, sea and air transportation earnings, passive revenues and individual income MOSCOW, December 10. /TASS/. The Russian Government approved the draft intergovernmental agreement with Hong Kong on avoidance of double taxation and prevention of tax… – Continue reading
Advisers – including tax agents – who facilitate offshore tax evasion are in the sights of the ATO, which in the past week has visited several wealth management firms linked to offshore arrangements. The tax evasion crackdown comes with the ATO having obtained more than 5,000 client names from wealth… – Continue reading
An income tax treaty between Cyprus and Switzerland has entered into force, and will be effective 1 January 2016. 10 December 2015 The Cyprus-Switzerland income tax treaty does not include a limitation on benefits (LOB) clause. Withholding tax provisions The treaty includes the following withholding tax provisions: Dividend payments subject… – Continue reading
Firms over a certain threshold group turnover may be required to give detailed info of financials. MULTINATIONAL companies in India over a certain threshold group turnover may be required to make comprehensive disclosures relating to their revenues, taxes paid, staff strength and assets in different countries where they operate from… – Continue reading
The Organization for Economic Co-Operation and Development is keen on putting a stop to the revenue losses countries face from tax avoidance strategies employed by multinational companies. CNBC-TV18’s Navin Shetty and Aayush Ailwadi find out just how prepared India is, to adopt the new action plan. The Organization for Economic… – Continue reading
The Association of Retail Trade (ACDET), which is part of Walmart, defended the decision to the chain filed a lawsuit against the government and the law 72. Considers that the law is unconstitutional and arbitrarily penalize one company. “Since April we warn the people that the measures were being discussed… – Continue reading
The Cayman Islands Tax Information Authority (“TIA“) has issued an advisory addressing several points of note regarding the Common Reporting Standard (“CRS“) in the Cayman Islands. Updated Self-Certification Forms The TIA has published new entity and individual self-certification forms which address the account holder disclosure requirements under each of CRS,… – Continue reading
FATCA requires sponsored entities (including those governed by an IGA) to have their own Global Intermediary Identification Number (GIIN) for FATCA reporting and withholding purposes by 31 December, 2016. Under a transitional rule, it is possible for one FFI to act as a sponsor for a number of other FFIs…. – Continue reading
New Zealand lawmakers approved at first reading a Bill to levy a withholding tax on offshore property speculators and apply goods and services tax to online purchases of services and intangibles from overseas suppliers, reports Tax News. Revenue Minister Todd McClay said the Residential Land Withholding Tax (RLWT), GST on… – Continue reading
The Department of Justice announced today that Cornèr Banca SA (Cornèr) and Bank Coop AG (Bank Coop) reached resolutions under the department’s Swiss Bank Program. The Swiss Bank Program, which was announced on Aug. 29, 2013, provides a path for Swiss banks to resolve potential criminal liabilities in the United… – Continue reading
Global Financial IntegrityGlobal Financial Integrity (GFI) on 8 December 2015 released the Global Illicit Financial Flows Report 2015 entitled Illicit Financial Flows from the Developing Countries: 2004-2013. This study is GFI’s 2015 annual global update on illicit financial flows from developing economies. It is the sixth annual update of GFI’s… – Continue reading
A global law firm has today criticised HM Revenue & Customs’s (HMRC) recently announced plans for cracking down on tax avoidance by businesses, saying that parts of the proposals would make HMRC the “judge, jury and executioner.” Further details on legislation that would allow the UK tax authority to place… – Continue reading
As the EU prepares for country-by-country tax reporting requirements, businesses would do well to understand the minutiae of the upcoming regulations October 2015 was a busy month for announcements regarding base erosion profit shifting (BEPS) and country-by-country reporting. The OECD issued the last of the guidelines on BEPS, the various… – Continue reading
Companies will to scrutinise their R&D activity more closely under proposed changes to patent box regime BUSINESSES will to scrutinise their R&D activity more closely under proposed changes to the design of the UK Patent Box regime outlined by the government The government is making the changes in order to… – Continue reading
When you think of a tax haven, you probably imagine the far off tropical islands of Bermuda or Grand Cayman, but the reality is that there is a major tax haven even closer to home in the state of Delaware. A new report from Institute on Taxation and Economic Policy… – Continue reading
Samuda blasts Gov’t for transfer pricing policy Opposition spokesman on industry and commerce Karl Samuda addressing the transfer pricing policy in Parliament on Tuesday. KARL Samuda has described the transfer pricing regime, as well as the Government’s push to implement it retroactively, as unfriendly to business, and has predicted that… – Continue reading
Leeds United chairman Massimo Cellino has been cleared of charges of tax evasion relating to the transfer of two players during his time as owner of Italian club Cagliari. Cellino was acquitted by a court in Sardinia today after his lawyers successfully argued that a government ruling introduced last year… – Continue reading
Chisinau, 10 December /MOLDPRES/-The parliament today ratified a Moldovan-American intergovernmental cooperation agreement to facilitate the implementation of the provisions of the Foreign Account Tax Compliance Act (FATCA). According to the chairman of the parliamentary commission for international relations and EU integration, Valentina Buliga, the ratified document sees that U.S. authorities… – Continue reading
The Cayman Islands Tax Information Authority (“TIA“) has issued an advisory to confirm that the limited life debt investment entity (“LLDIE“) exemption established under FATCA has been extended in the Cayman Islands to the OECD Common Reporting Standard (“CRS“).1 As such, a Cayman Islands LLDIE has been designated as a… – Continue reading
Ukraine’s state budget next year may amount to only $38 billion. For perspective, that is less than half of the municipal budget of New York City, with eight million residents, compared to Ukraine’s 43 million people. But viewed another way, the spending represents 40 percent of the official gross domestic… – Continue reading
The financial crisis at Bolton Wanderers has become critical after Her Majesty’s Revenue and Customs issued a winding-up petition for unpaid PAYE tax and VAT, the club have confirmed. Bolton, who were in the Premier League for 11 years until relegation in 2012 , announced they could not pay their… – Continue reading
NEW DELHI: With India stepping up efforts to bring back illicit funds stashed abroad, Switzerland has said both sides have improved their cooperation on tax matters following several high-level meetings. Over the past few months, both countries have been working closely on mutual administrative assistance, according to the Swiss government…. – Continue reading
Macedonia’s Prime Minister Nikola Gruevski and his Israeli counterpart Benjamin Netanyahu signed Wednesday in Jerusalem a declaration of friendship, as well as agreements on avoiding double taxation and protection of investments. The Prime Ministers affirmed the excellent relations between the two countries, based on mutual friendship and understanding, Gruevski’s Cabinet… – Continue reading
Earlier this month the Tax Laws Amendment (Combating Multinational Tax Avoidance) Bill 2015 (Bill) was passed with the support of the Greens. The Bill, now awaiting Royal Assent, passed with key amendments (Amendments) to the original bill reported on in our previous update. The Bill aims to ensure that large… – Continue reading
Two tax compliance agreements with Liechtenstein and Switzerland have received the seal of approval from the EU council of ministers today, reports Economia. And a third – with San Marino – was approved and signed today. They herald the start of a new era of tax transparency with three countries… – Continue reading
On 1 December 2015, the Income Tax (Approved International Agreements) (Implementation) (Common Reporting Standard) Regulations 2015 came into operation. The regulations implement the Council of Europe–OECD Mutual Assistance Treaty (1988) (as amended through 2010), under which, in order to improve international tax compliance, information will be automatically exchanged in accordance… – Continue reading
Thirteen jurisdictions signed the OECD Multilateral Competent Authority Agreement (MCAA) at a meeting on October 29-30, 2015, in Barbados. In joining the MCAA, the territories commit to automatically exchange tax information with other nations’ tax authorities under the OECD’s new tax information exchange standard, the Common Reporting Standard. A total… – Continue reading
Jakarta. Indonesia’s tax office is considering a tax amnesty for financial crimes, in a move that could bring back at least 100 trillion rupiah ($7.5 billion) to the state coffers, the director-general of taxes said on Wednesday. Southeast Asia’s biggest economy is grappling with the weakest economic growth in six… – Continue reading
Taipei, Dec. 9 (CNA) Taiwan and Macau are scheduled to sign an agreement Thursday to avoid double taxation on aviation business, according to Taiwan’s Mainland Affairs Council (MAC). The negotiations were concluded recently and the two sides will sign the agreement in Macau, the MAC said in a statement Wednesday…. – Continue reading
Hong Kong’s Financial Services Development Council (FSDC) has released a number of research reports, including one that addresses tax issues relating to open-ended fund companies (OFCs) and private equity (PE) investments, reports Tax News. One report entitled “A Paper on the Tax Issues on OFCs and Profits Tax Exemption for… – Continue reading
In 2013, the 39th G8 summit in Lough Erne committed to reform the international tax system. The G8 Lough Erne Declaration stated that such reforms would benefit developing countries. The G20 declaration in St Petersburg 2013 also stated specifically that “Developing countries should be able to reap the benefits of… – Continue reading
Germany and Australia signed a new income tax treaty that follows, in some instances, the OECD Model Tax Convention, but not in other instances. For example, the treaty includes definitions for installation permanent establishments (PEs) and agency PEs, with the latter defined with a view to the OECD’s base erosion… – Continue reading
Source: United Kingdom – Executive Government & Departments – Press Release/Statement: Headline: News story: Finance Bill 2016 paves way for even simpler tax system and tough offshore evasion regime The government has today (Wednesday 9 Wednesday) published draft tax legislation to implement policies published at Summer Budget 2015 and Autumn… – Continue reading
Changes to the tax law in Sweden reflect additions of anti-avoidance provisions to the EU Parent/Subsidiary Directive and are intended to bring Swedish tax law into compliance with the directive. The new anti-avoidance provisions will be effective 1 January 2016—which is also the timeframe for EU implementation of the directive’s… – Continue reading
Publican pays €3m in tax, interest, and penalties Two of the four largest published tax settlements in the last quarter were made by businesses in the Cork region. Revenue’s latest tax defaulters’ list for the three months to the end of September shows that a total of €13.99m was recouped,… – Continue reading
Akhilesh Ranjan, joint secretary (foreign tax), who led India’s initiative in the BEPS project, candidly shared his views on India’s plans for its implementation and what lies in the future. The fundamental principle of the BEPS project, is that income of MNCs should be taxed in that country where economic… – Continue reading
Policy will disrupt investment: Samuda THE Government fell back on its huge majority in the House of Representatives yesterday to approve the back tax provisions included in new transfer pricing regulations despite objections from the Opposition that the measure would strangle businesses and obstruct investments. The 21 Government members (excluding… – Continue reading
The Cayman Islands Ministry of Financial Services’ Department for International Tax Cooperation (DITC) on 8 December 2015 issued an industry advisory regarding the ongoing implementation of the Common Reporting Standard (CRS) in the Cayman Islands. The advisory issued two new templates; the entity self-certification form and the individual self-certification form… – Continue reading
It is time for re-regulation; Europe is strengthening its AML/CFT measures in order to lower current terrorist financing (TF) risks. “Money is the lifeblood of terrorist operations,” declared George Bush after the 9/11 attacks. French finance minister Michel Sapin has beaten the same drum when he recently claimed that “the… – Continue reading
Who is likely to be affected This measure will affect taxpayers engaging in abusive tax avoidance arrangements which fall within the General Anti Abuse Rule (GAAR). General description of the measure The measure will introduce a penalty of 60% of the tax due which will be charged in all cases… – Continue reading
Half of requests to come clean came from Lombardy (ANSA) – Rome, December 9 – The government’s voluntary disclosure program will generate four billion euros in taxes by year’s end, Internal Revenue chief Rossella Orlandi said Wednesday. Hidden assets equal to 59.5 billion euros have emerged thanks to the voluntary… – Continue reading
Barclays has launched its new offshore banking proposition at the Dubai International Financial Centre (DIFC) and regulated by the Dubai Financial Services Authority. Commenting on the launch, Andrew Mortimer, managing director and UAE Country Manager, said: “We have further developed Barclays’ International Banking proposition to provide our clients with a… – Continue reading
Settlement with German prosecutors, which involves immunity for any current for former staff, is latest embarrassment for bailed-out bank Royal Bank of Scotland is paying €23.8m (£17.3m) to German prosecutors to settle an investigation into tax evasion by part of Coutts, best known for being banker to the Queen. The… – Continue reading
ROME—The Italian government will pocket over €4 billion ($4.4 billion) in proceeds from a tax amnesty it launched as part of a broad crack down on Italian money stashed abroad. The additional money will be a boon for the government, as it seeks to meet its budget targets amid a… – Continue reading
Legislative amendments to the Tax Administration Act were affected in the Tax Administration Laws Amendment Bill, 2015, in order to implement a scheme under which SARS may require South African financial institutions to collect information under the OECD Standard for Automatic Exchange of Financial Account Information in Tax Matters, which… – Continue reading
