Canada and Switzerland have entered into an agreement which will commence in 2018 for the automatic exchange of information. Swiss banks are already requiring Canadian clients to provide evidence that their Swiss offshore bank accounts have been reported in Canada on form T1135 and offshore income reported on a T1… – Continue reading
Instead of hiking income taxes, change consumer taxes Finance Minister Bill Morneau is going ahead with the Liberal election promise to give a tax break to middle-class Canadians. The resulting shortfall in revenue was to be financed by raising taxes on individual incomes exceeding $200,000 per year. As we now… – Continue reading
The present French Tax Update contains (i) an overview of the main provisions proposed by the draft amending finance bill for 2015 (loi de finances rectificative pour 2015, 2015 Draft Amending Finance Bill), (ii) an update of the parliamentary amendments adopted in respect of the draft finance bill for 2016… – Continue reading
HM Revenue & Customs (HMRC) today published the results of its consultation, alongside draft legislation, for a proposed criminal offence for companies which fail to prevent the facilitation of tax evasion. The draft legislation lays down provisions for a criminal offence where somebody who is performing services on behalf of… – Continue reading
On December 9, 2015 the UK HM Revenue & Customs (HMRC) published a policy paper titled: “Corporation Tax: anti-hybrid rules”. Next to publishing the policy paper the UK Government also announces that on December 22, 2015 a series of examples illustrating the application of the hybrid mismatch rules will be… – Continue reading
On December 9, 2015 the UK HM Revenue & Customs (HMRC) published a policy paper titled: “Corporation Tax: Patent Box – compliance with new international rules”. The policy paper gives the following general description of the measure: “The government is proposing changes to the design of the UK Patent Box… – Continue reading
SOUTH Africa ranks seventh among developing countries in terms of illicit financial outflows, a Washington-based research organisation has found. Illicit outflows from the country are of great concern to the Treasury, which has introduced a number of measures to curb it, particularly the outflows achieved through profit shifting by large… – Continue reading
By Anakhanum Khidayatova – Trend: A lot should be left to the private sector to achieve constructive relations between Azerbaijan and Israel, according to Dan Stav, Israeli ambassador in Baku. “In order to encourage business in each country, you need to create conducive environment,” he said speaking to Trend Dec…. – Continue reading
Trigger for prosecution will be loss to HMRC of £25,000 a year, up from £5,000 – but experts say legislation is ‘step too far’ Government plans to make offshore tax evasion a criminal offence even when there is no proof of intention to break the law have been softened under… – Continue reading
NEW DELHI: India and Korea have inked a new memorandum of understanding on suspension of collection of taxes during pendency of mutual agreement procedure. This MoU will relieve the burden of double taxation for taxpayers in both the countries during the pendency of MAP proceedings. MAP or Mutual Agreement Procedure… – Continue reading
The Cabinet has submitted a bill to the Parliament Speaker’s Office for presentation and approval by the legislature of an agreement with the US that concerns the sharing of information between the countries to prevent tax fraud. A letter accompanying the legislation sent to the speaker’s office on Nov. 19… – Continue reading
The Government has decided to roll out plans to name and shame serial users of tax avoidance schemes despite concerns the power is unfair and disproportionate. In a consultation paper published in July, the Government set out a raft of proposals aimed at tackling those who “persist in engaging in… – Continue reading
WASHINGTON: India ranks fourth in black money outflows with a whopping USD 51 billion siphoned out of the country per annum between 2004-2013, a US-based think-tank’s report said today. Notably India’s defence budget is less than USD 50 billion. China tops the list with USD 139 billion average outflow of… – Continue reading
Many US citizens resident in Jamaica are unaware of the tax compliance requirements of FATCA. Notwithstanding, this article is not about providing full information or professional advice about FATCA. That information can be obtained in a variety of ways. This article is about informing those who do not yet know… – Continue reading
Providenciales, 08 Dec 2015 – Since December of 2014, the Turks and Caicos signed an Intergovernmental agreement or IGA so that the laws of the US FATCA or Foreign Accounts Tax Compliance Act and the UK equivalent could have force in these islands. Last month, the Ministry of Finance issued… – Continue reading
Banking secrecy no longer protects foreign clients: Council of States approved the transition to the automatic exchange of information. At the same time, he rejected the idea of a tax amnesty. Rejection of the tax amnesty was the main surprise of the discussion of the Government’s project to move to… – Continue reading
In Paris on the occasion of the COP21, the Honourable Billy Graham Talagi, Minister for Ministry of Natural Resources of Niue signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters in the presence of Deputy Secretary General Rintaro Tamaki. Previously, Israel signed the Multilateral Convention on Mutual Administrative… – Continue reading
The Liechtenstein Disclosure Facility (LDF) was introduced in September 2009 to allow UK taxpayers to make the disclosure of offshore assets not subject to taxation. However, in the budget of March 2015, it was announced that the LDF facility and the disclosure to the Crown dependencies start to a close… – Continue reading
On 8 December 2015, the Council adopted a directive aimed at improving transparency on tax rulings given by member states to companies in specific cases about how taxation will be dealt with. The directive is one of a number of initiatives aimed at preventing corporate tax avoidance. It will require… – Continue reading
Following persistent demands from the United Kingdom that its Offshore Territories include beneficial ownership information on public central registers, it was agreed at the Overseas Territories Joint Ministerial Council (JMC) that “similarly effective systems” are a permissible alternative. A joint statement after the JMC meeting said: “We agreed to hold… – Continue reading
MUMBAI: India has been an active participant in the Base Erosion and Profit Sharing (BEPS) action plan, the final package of which was rolled out by the Organisation for Economic Co-operation and Development (OECD) in October. The action points, set down by the OECD, aim at closing loopholes that enable… – Continue reading
Global corporation tax reform proving good for country As things stand, it would appear that matters are going Ireland’s way insofar as global corporation tax reform is concerned. The country-by-country reporting rules that have been proposed under the OECD’s Beps programme, and that commentators had been focused on in relation… – Continue reading
The Indian Government has accepted the recommendation of the Shah Committee that the Income Tax Act 1961 be amended to clarify that minimum alternate tax (MAT) does not generally apply to foreign institutions investors (FIIs) and foreign portfolio investors (FPIs). The Committee proposed that Section 115JB of the Income Tax… – Continue reading
WASHINGTON Illicit financial flows or black money from developing and emerging economies surged to US$1.1 trillion or a staggering 4 percent of the developing world’s GDP in 2013, according to a study released Wednesday by Global Financial Integrity (GFI), a Washington, DC-based research and advisory organization. The cumulative illicit outflows… – Continue reading
Explosives maker Orica will take a $36 million hit to its bottom line after the Federal Court found it had avoided tax by using “round robin” financing arrangement it put in place a decade ago to boost its profit and ward off takeover bids. BusinessDay revealed Orica’s battle with the… – Continue reading
On October 30, 2015, the Global Forum on Transparency and Exchange of Information for Tax Purposes decided that Cyprus, Luxembourg and Seychelles have actually and substantially implemented the international standard on transparency and exchange of tax information. Therefore, companies no longer have the obligation to declare payments made to persons… – Continue reading
Ramos Vega asked to accept pay 2% of sales per year as a reasonable contribution Representative Luis Vega Ramos called Walmart today the company to desist from his claim against the Government of Puerto Rico by the tax increase purchases subsidiary on the island does to its parent company. The… – Continue reading
Yahoo has reportedly abandoned its plan to spin off its stake in Alibaba. Yahoo’s proposed spinoff had been driven by tax concerns. In a world without taxes, Yahoo could have simply sold its Alibaba shares and distributed the proceeds to shareholders. Yahoo will now concentrate on other strategic options, including… – Continue reading
The EU Council has adopted a new transparency directive aimed at preventing corporate tax avoidance The directive, which was proposed by the European Commission (EC), is aimed at improving transparency on tax rulings given by member states to companies about how their taxes are calculated. Under the new directive, member… – Continue reading
The Department of Justice announced today that Aargauische Kantonalbank (AKB) reached a resolution 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 States. Swiss banks eligible to enter… – Continue reading
The new agreement marks the end of bank secrecy between San Marino and the EU. As of 2017, San Marino and EU Member States will automatically exchange information on the financial accounts of one another’s residents. Pierre Moscovici, Commissioner for Economic and Financial Affairs, Taxation and Customs, said: “This agreement… – Continue reading
Finance Minister Edward Scicluna pushes for ‘flexibility’ during today’s meeting of EU finance ministers in Brussels Malta has come out strongly against applying “rigid rules”, urging the European Commission to adopt a more flexible approach as it drafts legislation on taxation. Corporate tax was high on the agenda of EU… – Continue reading
INTRODUCTION The Taxation Laws Amendment Act, 2015 and the Tax Administration Laws Amendment Act, 2015 have both now been passed by Parliament, but await signature by the President. Once again, and now for the second year running, the number and scope of the changes to the various fiscal Acts (mainly… – Continue reading
Australia’s Parliament on 2 December 2015 concluded legislative action for this calendar year, with the following outcomes in respect of a number of major tax developments: The multinational anti-avoidance rule—Australia’s “de facto” diverted profits tax regime—was passed by Parliament. There are two amendments that: (1) require the Australian businesses of… – Continue reading
Ministers due to adopt conclusions on future of EU’s code of conduct on business taxation Corporate tax will top today’s meeting of EU finance ministers in Brussels, as ministers discuss the latest state of play regarding the common consolidated corporate tax base (CCCTB) and cross-border tax rulings. In particular, finance… – Continue reading
CANBERRA – School rolls are the latest weapon employed by Australian tax authorities in their fight against tax evaders. More than 100 households in Australia will be investigated by the Australian Tax Office in the near future, after authorities obtained information from several private schools about the payment of school… – Continue reading
A bill that will see offshore property speculators pay a withholding tax on profits from property transactions under the ‘Bright-line test’, and GST applied to online purchases of services and intangibles from overseas suppliers has passed its first reading. Revenue Minister Todd McClay says the Residential Land Withholding Tax (RLWT),… – Continue reading
With a new tax on company dividends coming into force from April 2016, a financial planner explains how Britons overseas will be affected, and what steps they should take Investors who receive more than £5,000 from company dividends held outside tax-efficient plans such as Isas will pay more tax from… – Continue reading
This Administration has shown flashes of the kind of thinking that countries need to achieve economic growth. On previous occasions we have, in this space, pointed to some of the policies implemented and have extended due commendations to Mrs Portia Simpson Miller’s team. Just two months ago, we commented on… – Continue reading
The Internal Revenue Service (IRS) continues its focus on perceived abuses in corporate inversion transactions. On November 19, the IRS released Notice 2015-79, which places new limitations on the ability of a U.S. multinational corporation to reduce its U.S. tax burden by inverting its corporate structure. U.S.-based multinationals are subject… – Continue reading
Tax inversions — the process of U.S. firms, merging with or buying foreign companies to shift their taxpaying headquarters abroad — have deprived the U.S. Treasury of ever-increasing billions of dollars. Although President Barack Obama promised to take punitive action against companies deliberately engaging in mergers and/or acquisitions for tax… – Continue reading
The Circular of the State Administration of Taxation on Strengthening the Administration of Corporate Income Tax on Incomes of Equity Transfers of Non-Resident Enterprises (“Circular 698”) was issued in 2009 to regulate tax treatment of indirect transfers of equity interest in a domestic Chinese company by non-residents. Circular 698 empowered… – Continue reading
Taxpayers fume about wastage and corruption, but large-scale evasion seems unlikely. JOHANNESBURG – There seems to be increasing concern that South Africa could be heading for a tax revolt. This comes amid an outcry against corruption, wastage of taxpayer money and the fact that the country’s deteriorating fiscal situation will… – Continue reading
The Circular of the State Administration of Taxation on Strengthening the Administration of Corporate Income Tax on Incomes of Equity Transfers of Non-Resident Enterprises (“Circular 698”) was issued in 2009 to regulate tax treatment of indirect transfers of equity interest in a domestic Chinese company by non-residents. Circular 698 empowered… – Continue reading
The government will look into compelling taxpayers to report to authorities if they receive consulting to reduce their tax obligations. The Ministry of Strategy and Finance said Sunday that it will review the measure as a follow-up to the Base Erosion and Profit Shifting program approved at last month’s Group… – Continue reading
Main principles of direct taxation – Domestic Tax Rules In our second article in a series of articles on the tax challenges of the digital economy, we shall be providing you hereunder with a brief overview of the principles of direct taxation, with a focus primarily on the taxation of… – Continue reading
INTRODUCTION In the context of changes in the international system of taxation of the company in the choice of jurisdiction for the implementation of operational activities closely fit to the question of economic feasibility, to protect their interests. The strategic location of Cyprus, the presence of the country’s full membership… – Continue reading
HMRC has reached an agreement with Jersey concerning the interpretation of the company residence tie-breaker in the Jersey-UK 1952 double tax agreement. This change also affects the interpretation of 15 other double tax agreements (DTAs) which have identical or very similarly worded company residence tie-breakers. The issue concerns dual residents… – Continue reading
Singapore has displaced Mauritius as the top source of foreign direct investment (FDI) in India during the first half of this fiscal. Figures compiled by the Department of Industrial Policy and Promotion show that during April-September, India attracted $6.69 billion (Rs 43,096 crore) FDI from Singapore and $3.66 billion (Rs… – Continue reading
The plan seeks to limit the fiscal erosion through interest deduction explains Alma Gutierrez; also seeks to prevent abuses in treaties and strengthening of controlled foreign companies rules. MEXICO CITY (CNNExpansión) – The Organisation for Economic Co-operation and Development (OECD) is a forum where the governments of different countries, including… – Continue reading
