Lawmakers seek late deal to scale back ‘Cadillac tax’ Lawmakers are making a late push to repeal or scale back Obamacare’s “Cadillac tax” by the end of the year, eying inclusion of changes in a broader tax package, wrote Peter Sullivan of The Hill. But lawmakers in both parties say… – Continue reading
The U.S. multinational will likely be investigated for evading taxes with Luxembourg’s help, following a report by trade unions earlier this year. McDonald’s is under investigation by European Union regulators for illegal tax deals with Luxembourg, according to sources close to the inquiry. The multinational—joining a list of EU tax… – Continue reading
The Government has recently launched a consultation on amending the UK’s interest deductibility rules for companies. The consultation follows the OECD’s recommendations as part of the Base Erosion and Profit Shifting (BEPS) project. In line with those recommendations, it is proposed that a company’s net interest deductions be limited to… – Continue reading
An EU deal with Liechtenstein, which will make it harder for EU citizens to hide cash from the tax man in bank accounts there, was endorsed by Parliament in a vote on Wednesday. Under the deal, the EU and Liechtenstein will automatically exchange information on the bank accounts of each… – Continue reading
By SYLVESTER MWALE – THE Government has resolved to liquidate the outstanding US$300 million owed to Eastern and Southern African Trade and Development (PTA) Bank accumulated through petroleum importation. The arrears would be dismantled in four installments within a period of one year. Chief Government Spokesperson Chishimba Kambwili said in… – Continue reading
Thailand’s vote this past May to implement a new transfer pricing law is expected to come into effect in the early part of the new year. Transfer pricing refers to the sale of goods or services between branches of a company or subsidiary companies to a parent enterprise, and most… – Continue reading
Swiss Senate has sealed the end of banking secrecy for foreign clients, following the House of Representatives in accepting the legal groundwork for the automatic exchange of information. The decision paves the way for a “decorous funeral for tax secrecy,” as senator Roberto Zanetti of the leftwing Social Democrats put… – Continue reading
Inland Revenue is looking at the tax treatment of hybrid debt and equity instruments and the use of related party loans funding local subsidiaries as part of a global clamp-down on tax avoidance. Acting deputy commissioner of policy and strategy David Carrigan told Parliament’s finance and expenditure select committee that… – Continue reading
The US Internal Revenue Service (IRS) reports no new registrations under Foreign Account Tax Compliance Act (FATCA) rules in November. The list stays at 177,147 institutions in 226 financial jurisdictions. The list details which overseas financial institutions have agreed to pass personal and financial information about accounts and investments controlled… – Continue reading
The Global Forum established an AEOI group in consequence of the G20 Leaders’ Declaration in September, 2013 with a view to establish a mechanism to monitor and review the implementation of the new global standard on automatic exchange of information. As India and other countries enhance their cooperation to crack… – Continue reading
Members of the European Parliament have tasked the EU Commission to table measures to improve corporate tax transparency, coordination, and EU-wide policy convergence, in legislative recommendations passed by the Economic and Monetary Affairs Committee on December 1, 2015. The recommendations build on the work of EU Parliament’s Special Committee on… – Continue reading
Republicans in both chambers of Congress said international tax reform is necessary to retain companies in the United States following pharmaceutical giant Pfizer’s announcement it is moving its headquarters overseas after its merger with Ireland-based Allergan, citing the country’s high corporate tax rates. During hearings in the House Ways and… – Continue reading
UK tax authority HM Revenue and Customs (HMRC) has announced a change of view on the interpretation of the company residence articles in 16 double taxation agreements (DTAs), reports Tax News. The change was prompted by an agreement with Jersey on the interpretation of the company residence tie-breaker article in… – Continue reading
AUTOMATIC EXCHANGE OF INFORMATION IN TAX MATTERS – THE COMMON REPORTING STANDARD Introduction The Common Reporting Standard (CRS) is a tool which facilitates the automatic exchange of information at a global level. The fight against tax evasion in cross border transactions has become a priority for Government around the globe…. – Continue reading
Taxes levied on foreign stock dividends can be recouped, but it makes most sense for high-net-worth clients with multimillion-dollar positions Advisers could be missing out on a way to maximize returns on their clients’ foreign investments. Americans investing in non-U.S. stocks could be earning less of a return than they’d… – Continue reading
Congress tightens the tax abuse of Americans who live and work abroad Doubling down on Americans living and working abroad is a way for the Internal Revenue Service to squeeze the turnip a little harder in pursuit of a little more blood. The Obama administration, which has never met a… – Continue reading
As the Joint Ministerial Council meeting continues in London this week Financial Services Minister Hon Wayne Panton says he intends to meet with European States in a bid to have Cayman removed from their lists of third-country, Non-cooperative Tax Jurisdictions. The minister, speaking at the last sitting of the Legislative… – Continue reading
Things are heating up in the economic substance doctrine area, which could lead to a U.S. Supreme Court review of the IRS’s aggressive arguments for the doctrine. Certiorari Petitions Salem Financial Inc. and Bank of New York Mellon Corporation have both petitioned for Supreme Court review of the Federal Circuit… – Continue reading
The European Commission’s use of state aid rules to challenge corporate tax agreements is causing uncertainly for businesses in Europe, Luxembourg finance minister Pierre Gramegna has said. Gramegna told the Financial Times this week that the situation “raises so many issues about predictability and certainty”. The Commission announced in October… – Continue reading
Taxes levied on foreign stock dividends can be recouped, but it makes most sense for high-net-worth clients with multimillion-dollar positions Advisers could be missing out on a way to maximize returns on their clients’ foreign investments. Americans investing in non-U.S. stocks could be earning less of a return than they’d… – Continue reading
This statistic might even make the 1% feel humbled. America’s 20 wealthiest people — a group that could fit in one Gulfstream G650 jet — are now worth $732 billion, which means they have more wealth than the 152 million people who make up the least wealthy 50% of U.S…. – Continue reading
Holiday home owners and others who inadvertantly break new tax rules could be ‘criminalised’ Holiday home owners who miscalculate tax owed, and those inheriting offshore money, face having their income wiped out entirely due to new penalties and punishments being introduced in the New Year. HM Revenue & Customs has… – Continue reading
A new international framework is targeting tax avoidance—and it has implications for captive insurers. Jenny Coletta of Ernst & Young explains In recent years, tax authorities around the world have been increasingly scrutinising captive insurance arrangements, focusing on questions relating to commercial purpose, pricing and substance. In what is likely… – Continue reading
Former UBS bank executive Raoul Weil believes the United States tried to use him to batter down Swiss banking secrecy by having him arrested and placed on trial last year. In an interview with the Tages-Anzeiger newspaper on Wednesday, Weil said the US Department of Justice intended to “lead me… – Continue reading
The introduction of the so-called “offshore tax” in Latvia may have adverse effects on Latvia’s accession to the Organization for Economic Cooperation and Development (OECD), reports LETA. The OECD has informed Latvia about this, urging the country to consider the potential effects of the “offshore tax” on its progress towards… – Continue reading
1. On November 30 (Mon.), an exchange of diplomatic notes for the entry into force of the Agreement between the Government of Japan and the Government of the State of Qatar for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (signed… – Continue reading
On 17 September, 2015, China State Administration of Taxation (“SAT”) released the Discussion Draft of Implementation Measures for Special Taxation Adjustments (“Discussion Draft”), as a complete revamp to the existing trial version of the Implementation Measures, i.e., Circular 2. Circular 2 has been serving as a backbone transfer pricing (“TP”)… – Continue reading
For the sixth consecutive year, the British Virgin Islands (BVI) has been named the most important offshore financial services jurisdiction by OIL’s annual Offshore 2020 report. The report is based on the opinions of 300 global financial services industry professionals and explores key trends and issues facing the industry. Martin… – Continue reading
The Common Reporting Standard (CRS) is the standard for automatic exchange of financial account information produced by the Organisation for Economic Cooperation and Development (OECD) which provides for systematic and periodic automatic exchange of information between signatory jurisdictions. At its heart is a requirement for financial institutions, including British Virgin… – Continue reading
Following a directive proposal put forward by the European Commission as part of a package of measures in March, the European Council reached political agreement on a directive amending the text of 2011/16/EU directive on administrative cooperation in the field of taxation. EU member states will be required to automatically… – Continue reading
The Channel Islands (Jersey and Guernsey) have long been known as leading offshore centres for the establishment of investment funds and other investment structures. In particular, Channel Island vehicles are often used for alternative investment structuring – including private equity, infrastructure and real estate. This article explains the trends in… – Continue reading
Amazon Anonymous van drove through central London emblazoned with the line: ‘Enjoy unlimited instant tax dodging subsidised by government hand-outs. Anywhere, anytime’ Anti-Amazon campaigners drove a van through central London yesterday that was emblazoned with a crowdfunded, fake Amazon advert attacking the online retailer’s alleged tax avoidance. Booksellers have championed… – Continue reading
In a previous article we have discussed that you might be entitled to reclaim withholding tax on your foreign investments in Russia (including ADRs, GDRs). For transactions where the ultimate beneficial owner is not declared prior to the payment of income, local Russian custodians apply 30% withholding tax on dividends1… – Continue reading
The new Income Tax Treaty between the Netherlands and Germany has entered into force today, 1 December 2015. The new Treaty generally applies from 1 January 2016 and replaces the old treaty of 1959. In accordance with the new treaty, the following withholding taxes will apply: Dividends: 5% if the… – Continue reading
“Luxembourg is famous for two things: its steel industry and its rose cultivation industry”. This quote from an Italian guidebook of the 1930s was uttered by Luxembourg’s Finance Minister Pierre Gramegna at the annual conference of the Luxembourg Directors’ Association on 17 June 2015[1]. The economic outlook of the tiny… – Continue reading
The Senate, on Friday (November 27), passed amendments to the Income Tax Act, which will empower the Government to prevent tax leakage through the transfer pricing system. Transfer pricing is used by multinational companies for sales and services within their corporate groups and by individuals in transactions with corporations under… – Continue reading
Some U.S. lawmakers on Tuesday used a pair of hearings in the Senate Finance Committee and the House Ways and Means Committee to showboat for corporate special interests and oppose a growing worldwide movement to crack down on international tax avoidance. Last month, leaders of the 20 largest economies in… – Continue reading
The 28 nations of the European Union lose up to $1 trillion per year in revenue thanks to multinational corporations that use a spider’s web of completely legal constructs to lower their taxes. Now, Europe’s law enforcers and lawmakers want to wipe away these intricate tax-avoidance systems. If they have… – Continue reading
Today, the Senate Finance Committee met to discuss the Organization for Economic Co-operation and Development’s (OECD) project on Base Erosion and Profit Shifting (BEPS), a set of proposals on international tax policy approved earlier this fall that will place U.S. companies at a competitive disadvantage globally. Testifying with me today… – Continue reading
“It is not the strongest or the most intelligent who will survive but those who can best manage change”-Charles Darwin The Organization for Economic Co-operation and Development (OECD) released its final recommendations on the Base Erosion and Profit Shifting (BEPS) Project on October 5, 2015. The BEPS project consist of… – Continue reading
Minister of Foreign Affairs and Foreign Trade of Barbados, Senator Maxine Mc Clean, called on the Minister for Foreign Affairs, George Vella. Minister Mc Clean praised the Government of Malta for the organisation of the CHOGM, at which Barbados was represented by Prime Minister Freundel Stuart, and congratulated Minister Vella… – Continue reading
Finance Minister Ishaq Dar has said the government does not have any evidence of Rs 430 billion being taken out by Pakistanis abroad adding the figure was based on media reports. The Minister stated this while addressing a news conference after a special meeting of the Economic Co-ordination Committee (ECC)… – Continue reading
Looking back at tax developments over the past year, we’ve seen some promising incentives granted by the government and other developments that have caused taxpayer anxiety. One contentious issue involved transfer pricing, which we discussed in a previous column (“Transfer Pricing Loopholes Likely to be Closed Soon”, June 2). The… – Continue reading
The UK Government has issued a reminder that existing taxpayer disclosure facilities will be replaced by a tougher, “last chance” regime from 2016, reports Tax News. Financial Secretary to the Treasury David Gauke has launched a campaign that explains how the new regime will work. He said that the UK’s… – Continue reading
Tax authorities in Britain will be given new powers to demand personal financial details from Bermuda, reports the Royal Gazette. The Island is one of 90 countries that will begin to share the financial details of British residents with HM Revenue & Customs (HMRC) from January under new plans to… – Continue reading
The UK taxman has collected £301.8 million in unpaid property tax due to what is described as an aggressive clampdown on stamp duty avoidance. HMRC’s new Counter Avoidance Directorate collected the amount in the last year as part of a policy to crackdown on Stamp Duty and Land Tax (SDLT)… – Continue reading
The House and Senate held hearings Tuesday on the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting action plan, also known as OECD BEPS, for combating tax avoidance by multinational corporations. A number of the lawmakers expressed a skeptical view of the international tax reforms. “The OECD’s… – Continue reading
UK tax authority HM Revenue and Customs (HMRC) has announced a change of view on the interpretation of the company residence articles in 16 double taxation agreements (DTAs). The change was prompted by an agreement with Jersey on the interpretation of the company residence tie-breaker article in their 1952 DTA…. – Continue reading
First Private Bank has not committed tax evasion since its establishment, said Dr Sein Maung, the bank’s chairperson, at the 24th annual general meeting of the bank on November 29. “First Private Bank (FPB) has fewer branches than Myanmar’s major private banks. From its inception until the end of the… – Continue reading
The yuan jumped in late offshore trade on Monday on suspected intervention by Chinese state banks on behalf of the central bank but the onshore spot yuan closed weaker. Traders said the onshore spot yuan weakened because the People’s Bank of China set the yuan’s official midpoint at a three-month… – Continue reading
