Category: Jurisdiction

Top UK cricketers caught up in film scheme losses

Several former England cricket captains have been caught up investing in disputed film schemes that have also seen many high-profile footballers lose millions. The Sunday Times reported over the weekend that it had seen documents showing that Michael Vaughan, Andrew Flintoff and Marcus Trescothick were among the cricketers who had… – Continue reading

Canadians with Swiss bank accounts have until December 31, 2015 to file a voluntary disclosure

The United States came down hard on Swiss banks after receiving, from various whistleblowers, Swiss bank data evidencing U.S. citizens had hidden fortunes in Swiss accounts. Swiss banks were fined billions for assisting U.S. citizens in evading taxes and now want to avoid repetition of this scenario when the exchange… – Continue reading

Tata Steel to refinance $1.5bn offshore debt

Tata Steel’s Singapore arm T S Global Holdings Pte raised $1.5 billion debt to settle outstanding loans, the company said in a statement. Tata Steel group executive director-finance and corporate Kaushik Chatterjee said, “Tata Steel actively reviews all its financing options and seeks to continuously optimise its debt based on… – Continue reading

TaxTalk Today- 7th December 2015

Australian Taxation Office New or updated materials on ATO website, including: Class ruling to be released on Wednesday BAS reporting – offshore to offshore supply of goods: Some taxpayers are incorrectly including offshore to offshore supplies of goods in their business activity statements (BAS). This document sets out to clarify… – Continue reading

Yanukovych-era digital TV monopoly fined for abuses

A digital TV monopoly left over from the era of ex-President Viktor Yanukovych has caught the eye of anti-trust authorities and lawmakers. The Antimonopoly Committee of Ukraine on Dec. 4 fined Zeonbud, the nation’s monopoly digital TV provider, Hr 44 million (less than $2 million) for abusing its position on… – Continue reading

What CFOs Need to Know About BEPS

The Base Erosion and Profit Shifting (BEPS) project is an initiative being pursued by the Organization of Economic Cooperation and Development (OECD) to curtail perceived exploitation of international tax rules and loopholes by multinational enterprises (MNEs). The OECD’s BEPS project was initiated in 2013 at the request of the Group… – Continue reading

Bermuda accuses critics of ‘a lack of respect’ over transparency

Campaigners attack offshore centre for support of tax dodging, corruption and terrorist financing, reports the Financial Times. Bermuda has hit back against its critics, claiming that the financial centre is the victim of an “irresistible urge to stereotype” the British overseas territories. Bob Richards, finance minister, mounted a trenchant defence… – Continue reading

Noonan explains Ireland’s stance on CCCTB, code of conduct

Michael Noonan, Ireland’s Finance Minister, underlined Ireland’s position on key international tax issues that were scheduled for discussion at a meeting of the EU’s Economic and Financial Affairs Council (ECOFIN), reports Tax News. Noonan was addressing the Joint Committee on Finance, Public Expenditure, and Reform on December 1, 2015, in… – Continue reading

Call for UK clampdown on territories

An influential UK newspaper has called for Britain to force its Overseas Territories to create a public register of owners of companies. Chris Blackhurst, the group content director of a four-newspaper stable, writing in the London Evening Standard, said: “Only then, once we have put our own house in order,… – Continue reading

Australian Senate Passes Multinational Anti-Avoidance Law

The Australian Senate has passed legislation that will require companies that “avoid” taxes to pay back double what they owe, plus interest. The new Multinational Anti-Avoidance Law (MAAL) will cover all multinationals operating in Australia with global revenues of more than AUD1bn (USD730.7m). Approximately 1,000 companies will be affected. The… – Continue reading

Swaraj calls on Mauritius Prez, discusses range of issues

External Affairs Minister Sushma Swaraj today called on Mauritius President Ameenah Gurib-Fakim and discussed a range of issues of mutual interest including impediments to investment inflows. Gurib-Fakim, the first woman President of Mauritius, who is a distinguished scientist, arrived here yesterday on a three-day visit. In the meeting, Gurib-Fakim and… – Continue reading

Clinton offers new ‘exit tax’ on U.S.-foreign company mergers

WASHINGTON — Hillary Clinton on Wednesday will unveil a proposal for a new “exit tax” aimed at cracking down on corporate inversions, a practice that permits U.S. companies to merge with corporations overseas to lower their tax bill. The new tax would be part of a broader effort to target… – Continue reading

Passport Revocation for Unpaid Taxes: Brager Tax Law Group Warns of Act’s Extraordinary Impact

LOS ANGELES, Dec. 07, 2015 (GLOBE NEWSWIRE) — If you think the Fixing America’s Surface Transportation Act (FAST), passed by Congress on December 3rd, is only about transportation…think again. According to Dennis Brager, founder of the Brager Tax Law Group, a little noticed provision in this wide sweeping Act may… – Continue reading

FSDC releases reports to promote Hong Kong’s asset management business

Hong Kong (HKSAR) – The following is issued on behalf of the Financial Services Development Council: The Financial Services Development Council (FSDC) today (December 7) released three research reports to promote Hong Kong’s asset management business, focusing on fund distribution, tax issues relating to private equity investments and an alternative… – Continue reading

The minister who dismantled Swiss banking secrecy

As the curtain falls on Eveline Widmer-Schlumpf’s career in government, one of the most abiding legacies she leaves behind is the collapse of Swiss banking secrecy under her watch as Finance Minister. Her predecessor, Hans-Rudolf Merz, told the world in 2008 that it would “break its teeth on Swiss banking… – Continue reading

Terrorist threat will force countries to tear up EU budget laws

Pierre Gramegna says “challenging and long lasting” impact of the terrorist and refugee crises means countries have “no choice” but to ramp up spending Terrorist attacks are the biggest threat facing the European Union and countries have “no choice” but to tear up budget rules and ramp-up spending in order… – Continue reading

More than 50 banks which helped American clients dodge tax in Swiss bank accounts receive immunity from criminal prosecution in US

More than 50 banks which helped American clients dodge tax in Swiss bank accounts have received immunity from criminal prosecution in the US. The firms, which include UK giant Standard Chartered, Germany’s biggest lender Deutsche Bank, and France’s BNP Paribas, have reached plea bargains with the US Department of Justice…. – Continue reading

Cadbury owner paid no UK corporation tax last year

Mondelez was able to pay no UK corporation tax as a result of a Channel Islands-based bond, despite Cadbury making £96.5m profit in 2014 Mondelez, which owns Cadbury, is facing controversy over its tax arrangements after it was reported that it had not paid UK corporation tax last year. An… – Continue reading

Private sector opposes retroactive tax measure

THE Private Sector Organisation of Jamaica (PSOJ) is not happy with amendments to the Income Tax Act that will see the implementation of a transfer pricing regime retroactive to April 1 this year. The PSOJ, in a letter to Tax Administration Jamaica (TAJ) Commissioner General Ainsley Powell in September, had… – Continue reading

Wal-Mart Sues Puerto Rico Over ‘Astonishing’ Tax Increases

   Island’s biggest employer files suit in San Juan federal court    Legal challenge comes as Puerto Rico copes with debt payments The Puerto Rico unit of Wal-Mart Stores Inc. sued the island’s government, seeking to overturn a new tax the retailer calls unfairly high. Enacted in May, Puerto Rico’s… – Continue reading

Chinamasa hails China mega deals

Ellah Mukwati Herald Correspondent The recent historic visit by the Chinese President Xi Jinping which saw 12 mega deals worth $4 billion being signed cemented the good bilateral relationship between Zimbabwe and China, the Minister of Finance and Economic Development has said. In a statement released yesterday Minister Patrick Chinamasa… – Continue reading

The richest 20 Americans are as wealthy as half of the entire U.S. population combined

 Wealthiest 20 Americans, with combined net worth of $732billion, are as wealthy as half of the U.S. population, new study says  Study found country’s richest 20 people now own more wealth than bottom half of population which is about 152 million people Wealthiest 20 people includes eight founders of corporations,… – Continue reading

Google, Apple and Starbucks would face ‘laughable’ fines for tax dodging under new rules

£300 penalties would be dwarfed by millions in potential profits for firms that take advantage of tax-avoidance schemes Huge multinational companies that dodge millions of pounds in tax in the UK and around the world face “laughable” fines of £300 under new rules proposed by HM Revenue and Customs. The… – Continue reading

‘OECD’s tax haven plan on Indian lines’

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

Pfizer and Allergan chiefs say merger is good for America

Employees at Allergan have been told a proposed merger with Pfizer is about changing healthcare – not skirting tax law. Allergan’s global chief executive Brent Saunders has written directly to the company’s employees – including around 1,000 in Ireland, telling them the controversial deal is not just about tax savings…. – Continue reading

Luxembourg plots to steal London’s financial crown

The tiny nation wants to become “the European location of choice” for global financial services firms, and is already the biggest centre for fund management in the EU, reports the Telegraph. Luxembourg’s finance sector has set out plans to become Europe’s leading financial centre in the next five years, plotting… – Continue reading

Australian multinational tax avoidance laws to come into effect next year

From the start of 2016, multinational companies found to be avoiding tax will have pay back the tax owed, plus a 100 per cent penalty, reports ZD Net. The Australian Greens have voted with the Coalition to pass legislation that will see multinational companies with annual revenue above AU$1 billion… – Continue reading

Year-End Tax Planning for U.S. Expatriates in Brazil: Sponsored

Amit Ramnani, director of Ipanema Wealth, an independent financial consultancy firm, discusses year-end tax planning techniques for U.S. expatriates. RIO DE JANEIRO, BRAZIL – Amit Ramnani, director of Ipanema Wealth, reminds U.S. expatriates that they still have time to apply some year-end tax-planning techniques. U.S. citizens who are resident in… – Continue reading

Sunshine Islands Feel Heat Over Tax Avoidance

The British government is about to get tough with so-called tax havens that are dragging their feet on revealing the secret ownership of thousands of offshore companies. One of the main thrusts of Britain’s drive to clean up the murky world of tax avoidance has been to put pressure on… – Continue reading

Italy Issues Patent Box Guidance

On December 1, the Italian Revenue Agency issued a guide delineating how companies can take advantage of Italy’s “patent box,” together with a circular containing the answers to questions arising out of the new regime’s operation. With effect from the present 2015 fiscal year, the patent box offers an optional… – Continue reading

France-Luxembourg tax treaty change cannot come into force until 2017

France and Luxembourg failed to ratify a protocol changing the France-Luxembourg double tax treaty by 30 November, which means that a change which will affect real estate structures cannot come into force until 1 January 2017, at the earliest, for companies whose fiscal year is based on a calendar year…. – Continue reading

A battle over billions in business tax incentives

Deep in the $1.1 trillion dollar spending bill that Congress has to pass by Dec. 11 to avoid a government shutdown are 50 annual “tax extenders” that would provide tens of billions of dollars in tax relief for the private sector. Advocates say these measures, which have been around for… – Continue reading

UK: Diverted profits tax guidanc

HM Revenue & Customs (HMRC) updated its diverted profits tax guidance to clarify the tax authority’s interpretation of the legislation and proposed administrative practice. Highlights Some highlights from the revised guidance include: Both the “insufficient economic substance condition” and the “design test” in section 86 FA 2015 (avoidance of UK… – Continue reading

Italy: Decree removes Hong Kong from certain “black lists”

Italy has removed Hong Kong from two of three “black lists.” A ministerial decree in November 2015 removed Hong Kong from the black lists that apply with respect to: The Italian controlled foreign corporation (CFC) rules and the full taxation of inbound dividends Costs that arise in transactions between Italian… – Continue reading

Luxembourg: EC investigation of tax rulings, issued to US multinational

The European Commission today announced its decision to launch a “state aid” investigation into tax rulings granted by the tax authorities in Luxembourg to a company that is a member of a U.S.-based multinational taxpayer group. Background According to a February 2015 report, in 2008-2009, the group transferred its European… – Continue reading

Netherlands: CRS draft implementing decree

The Dutch Ministry of Finance published a draft decree for implementing the “common reporting standard” (CRS) and that includes the identification and reporting requirements contained in the CRS for reporting financial institutions. The CRS, developed by the OECD and largely based on FATCA, is a standard that governs the exchange… – Continue reading

Varga calls for joint EU crackdown on tax evasion

Hungary’s National Economy Minister Mihály Varga called on European Union members to assist in a joint crackdown on value added tax evasion, the minister said today at a conference in Prague, according to a report from the National Economy Ministry. Varga and Czech finance minister Andrej Babis, whose ministry organized… – Continue reading

Statement on Multinational Tax Legislation

“The Business Council welcomes the passage of the government’s multinational tax bill through the Parliament. The legislation will see Australia play its part in responding to the OECD’s Base Erosion and Profit Shifting package. It will provide companies with certainty around their obligations, and provide the community with greater confidence… – Continue reading

Swiss bank to pay tax evasion penalty

Switzerland’s EFG Bank is to pay a penalty of $29m to the US Department of Justice to avoid prosecution for helping its American account holders evade taxes. The bank came forward as part of a voluntary programme launched in 2013, which allows Swiss banks to admit their potential role in… – Continue reading

Multinationals’ tax leeway set to shrink

Multinationals in India will soon have to forgo to a great extent the flexibility in managing their tax outgo in the country and have to report their global operations in elaborate detail to the tax authorities here. This is because New Delhi is set to adopt a new regime to… – Continue reading