SARS may now impose a dividends tax on dividends paid by a South African company to a Cypriot shareholder as provided for in the Protocol to the current agreement for the avoidance of double taxation between South Africa and Cyprus. In terms of the current agreement for the avoidance of… – Continue reading
Switzerland is on its way towards the Automatic Exchange of Information (AEOI). The AEOI will lead to the transmission of sets of data from a reporting financial institution (e.g. a bank) to the domestic tax authority. The domestic tax authority will have to exchange such data with the respective foreign… – Continue reading
Following a ruling by the Swiss Federal Tax Administration, payments of interest under the DDM Treasury SEK 300 million Senior Secured Notes with ISIN SE0005280831 (the “Notes”) are subject to Swiss withholding tax since the refinancing executed in June 2015. On 23 June 2015 certain amendments to the documentation in… – Continue reading
The World Bank has placed India twelve notches higher than last year in its Ease of Doing Business rankings for 2016. This comes close on the heels of the country’s sixteen place leap on the World Economic Forum’s Global Competitiveness index. These rankings underline the impact of the recent spate… – Continue reading
Hong Kong’s Secretary for Financial Services and the Treasury, K C Chan, has emphasized that the Government is committed to complying with the latest international tax developments, including on tax transparency and tackling base erosion and profit shifting. In his speech to the Taxation Institute of Hong Kong 2015 CTA… – Continue reading
As the founder of a startup company, one of the first questions you need to consider is “where should I incorporate my company?” Investors are drawn to the British Virgin Islands (BVI) for its flexible and modern corporate regime, tax neutrality, respected legal system, political stability and effective regulatory framework…. – Continue reading
SINGAPORE-listed Sinarmas Land is looking to unlock the value of its investment properties in Indonesia by spinning them into a real estate investment trust (Reit) but has not decided on whether to list in Singapore or Jakarta, with tax benefits on offer likely to be a key determinant. “The unlocking… – Continue reading
Professional services firm PwC has predicted that UK Chancellor George Osborne will introduce an “apprenticeship levy” and seek to lessen the impact of tax credit cuts when he delivers his Autumn Statement on November 25. In his Summer Budget, Osborne pledged that the Government would “introduce an apprenticeship levy on… – Continue reading
A pending Protocol, that would amend the income tax treaty between Luxembourg and France, may not be effective until 2017. RATIFICATION PENDING The Luxembourg Parliament passed a bill to ratify the fourth Protocol to the income tax treaty (1958) between Luxembourg and France. However, it currently appears that the ratification… – Continue reading
On 10 November 2015, the Danish Ministry of Taxation introduced a draft bill (bill no. L46) including an amendment to section 3B of the Danish Tax Control Act (skattekontrolloven). The purpose of the proposed amendment is to implement Action Point 13 of the BEPS Initiative (Guidance on Transfer Pricing Documentation… – Continue reading
Through tweaks to the Model Tax Convention, the OECD believes its work on profit shifting will stem elaborate structures, such as commissionaire arrangements, used by large multinationals to avoid the creation of a permanent establishment. The Organization for Economic Cooperation and Development, however, responded to concerns from taxpayers by narrowing… – Continue reading
The U.K. and the U.S. governments will adopt different approaches to implementing the OECD’s final package of measures to tackle base erosion and profit shifting, panelists at a London forum said. The U.K. government considers an inclusive, multilateral instrument to upgrade bilateral tax treatments as the “best way” for countries… – Continue reading
DESPITE repeated allegations from the Spanish government that Gibraltar is a tax haven, news is regularly received that suggests this is far from the case, and that the government has been doing all that it can to ensure that it complies as fully as possible with international standards, whilst generating… – Continue reading
LK Hewlett Customers throughout the region are likely to see additional or increased fees and charges as their banks incur mounting financial burden in the face of FATCA and CRS. The regional banks have recently had to expand their IT, security and human resources to become compliant with the US’… – Continue reading
Already from December 1, 2015 come into force provisions requiring all financial institutions calling their clients to make statements about their residence tax (FATCA – Foreign Account Tax Compliance Act). It is the first significant action since records to OPF. FATCA imposes on foreign institutions, including the Polish reporting obligations… – Continue reading
Proposed measure would allow US to revoke passport if individual has over $50,000 unpaid taxes The 8 million Americans living overseas should “ensure their financial affairs are in order and compliant” before the New Year, or face having their passports revoked, warns a financial advisory organisation. The company – deVere… – Continue reading
The eight million Americans living overseas, including In Hong Kong and the rest of Asia, should “ensure their financial affairs are in order and compliant” before the New Year, or face having their passports revoked, warns the boss of one of the world’s largest independent financial advisory organizations. Nigel Green,… – Continue reading
ISLAMABAD: In a major scam tax evasion of hundreds of billions of rupees and whitening of black money worth trillions of rupees take place every year with the government authorities facilitating the extremely undervalued sales and purchases of thousands of residential and commercial properties throughout the country every day. While… – Continue reading
YEREVAN, NOVEMBER 23, ARMENPRESS. A businessman should not pay the same tax for two times for a unilateral deal. The agreement of avoidance of double taxation with respect of taxes on income and on capital signed between Armenia and the USA is one of the factors that will contribute to… – Continue reading
The OECD’s final report on Action 13 under the base erosion and profit shifting project—which calls for countries to adopt a country-by-country reporting template, master file and local file—has the potential to be one of its “greatest legacies.” Marlies de Ruiter, head of the Organization for Economic Cooperation and Development’s… – Continue reading
Mutual-fund giant Vanguard Group underpaid taxes on its income in Texas for 2010-14, according to records of the Texas Comptroller of Public Accounts. State-sponsored audits found payment “deficiency” for all four years in Vanguard’s payments of the state’s corporate franchise tax, which charged companies 1 percent percent of a company’s… – Continue reading
Under the judge’s order, Microsoft must hand over more documents and make some former and current executives available for interviews in a long-running tax audit of the company’s books. Microsoft must comply with Internal Revenue Service requests for documents and interviews with current and former executives as part of a… – Continue reading
LK Hewlett St. Kitts-Nevis Permanent Representative to the OAS, Dr. Everson Hull has expressed strong views on the impact of FATCA on the region’s banking system. Delivering a presentation to over 200 banking executives and other stakeholders in the financial services sector from across the Caribbean at the recent Caribbean… – Continue reading
The IRS has upgraded the Foreign Account Tax Compliance Act (FATCA) Online Registration System, enabling sponsoring entities to register their sponsored entities to obtain a global intermediary identification number. The upgraded system also will allow users to update their information, download registration tables and change their financial institution type. The… – Continue reading
WILLEMSTAD – A 20-member delegation from Curaçao participated in the STEP Latin America Conference (STEPLatAm) 2015, which was held on the 22nd and 23rdof October at the Renaissance Hotel in Sao Paulo, Brazil. The STEPLatAm conference is a leading conference for wealth structuring and trust and estate practitioners. During the… – Continue reading
The European Commission has requested that the Netherlands amend the limitation on benefits clause in its double tax treaty with Japan. The Commission said that, on the basis of previous cases such as Gottardo (C-55/00) and Open Skies (C-466/98), a member state concluding a treaty with a third country cannot… – Continue reading
EXCLUSIVE The self-styled biochemist known as “Dr Ageless”, Shane Charter, appears to have shrugged off the Essendon supplements scandal and is pursuing a new business venture — chasing more than $11 million hidden in offshore tax havens by notorious conman Peter Foster. Mr Charter has been negotiating for several months… – Continue reading
Nawaz Sharif has turned his full attention for close relations with Central Asian states since the five of them broke away from Russia 23 years ago. Fast track negotiations between Central Asian and Pakistani leaderships are slated to turn their countries into a big, new economic zone. Their desire and… – Continue reading
VietNamNet Bridge – Apple Operations International (AOI), the owner of Apple Vietnam, has been involved in in the past in tax evasion scandals in the US and Ireland. Vietnamese newspapers reported that Apple has ‘quietly established a subsidiary in Vietnam called Apple Vietnam Limited Liability Company as written in the… – Continue reading
Tax Commissioner Chris Jordan has become more picky about entering agreements with multinationals aimed at giving companies certainty about their tax payment requirements in Australia in future years. Taxpayers can lock in their tax payment for a period of about three years via an “advanced pricing agreement”, or APA. Technology… – Continue reading
Failed tax avoidance business Welbeck hired young actors to push schemes onto City big earners, and reaped millions in commissions that fuelled lifestyles of fast cars and exotic holidays, according to a whistleblower who worked at the firm. Welbeck Solutions sold pensions and financial products, but it specialised in tax… – Continue reading
Private companies that were given a historical exemption from filing annual financial reports are run by a who’s who of corporate Australia, including Malcolm Turnbull Private companies associated with Australia’s business elite, including prime minister Malcolm Turnbull, are on a list of entities not required to publish tax information under… – Continue reading
“India’s concerns are known…there can be no compromise on the issue of terror…India’s longstanding position is that there is no good or bad terror and all forms of terrorism are unacceptable and must be fought by the global community as well as each and every country”, the source told reporters…. – Continue reading
Towards compliance with tax information sharing laws put in place in recent times, all financial intermediaries are mandated to seek information from account holders. They are also obliged to share information of your account with relevant authorities. SEBI too has issued guidelines on identification of beneficial ownership and mandated all… – Continue reading
The North will have its own 12.5pc corporate tax rate from 2018. This means that it will compete harder against the Republic for FDI projects, writes Dan White The 12.5pc company tax rate will no longer be confined to the southern part of the island. Last week’s ‘Fresh Start’ agreement… – Continue reading
NEW DELHI: Tightening the noose around Indians whose names figured in the ‘stolen’ Swiss HSBC bank black money list, the Enforcement Directorate has begun a preliminary investigation in these cases for an independent hawala and money laundering probe. The agency recently has begun obtaining from various court registries the details… – Continue reading
Gabriele Galimberti and Paolo Woods make a complex and impenetrable subject palatable To do justice to the work undertaken by Paolo Woods and Gabriele Galimberti, requires thinking of them not as photographers, but as investigators. Their search for truth begins with a mystery, one embodied in Ian Fleming’s Dr. No…. – Continue reading
On the face of it, Malta literally has the highest corporate tax rate in the EU. At 35%, it hardly seems to be a competitor to European tax havens like Ireland and Cyprus, both applying a rate of 12.5%, or territories like Gibraltar. At a rate of 10%, the latter… – Continue reading
Nov 22, 2015- Lack of clarity over double taxation on petroleum products from China will delay the signing commercial agreement with Petro-China. For now, the government is sending a technical team of Nepal Oil Corporation (NOC) to China on Monday to clarify the issue of taxation before a high level… – Continue reading
The United States is on the verge of economic collapse. It is being tipped over the edge by its own government with an unquenchable thirst for taxes and incurable addiction to spending. The financial system in the United States and everywhere else in the world is in danger of disintegrating… – Continue reading
Notice 2015-79—released November 19, 2015, by the Treasury Department and IRS—announces their intention to issue regulations relating to inversion transactions and post-inversion restructuring transactions. Notice 2015-79 provides for rules that: Limit the ability of domestic companies to effect an inversion Limit the advantages of certain post-inversion restructuring transactions Clarify certain… – Continue reading
The creation of the Group of Twenty (G20) was believed to serve as a remedy to the harsh realities of the world today. The initial formation of the Group of Seven G7 could do little to avert pertinent challenges both the developing and the developed nations face frequently. So a… – Continue reading
Company used actresses including former Alan Partridge star to bombard financial sector workers with cold calls The grey Basinghall Street office building, in the heart of London’s City financial district, gives few clues about the frenzy of activity that was going on inside. But for years, this was the home… – Continue reading
This week, the IRS released Notice 2015-79, which describes intended regulations to cover inversions and related transactions. Colloquially, an inversion refers generally to a transaction in which a domestic corporation is acquired by a foreign corporation. I.R.C. §§ 367 and 7874 operate as the anti-inversion rules; § 367 deals with… – Continue reading
Lately, the IRS is warning offshore account holders to disclose before it’s too late. Under FATCA, banks everywhere want to know if you are compliant with the IRS. And the cost of compliance for many people is growing. The IRS updated its list of foreign banks where accounts trigger a… – Continue reading
The blacklisting saga did not start with Spain, but it did end with a timely correction related to it. Harbour Times explains how Hong Kong was taken off the Spanish tax haven list. Friends of Harbour Times would be familiar with the remedy of Hong Kong being named a non-cooperative… – Continue reading
The European Commission has requested that Spain amend its rules on the taxation of certain income obtained by foreign non-profit entities and of certain contributions to such entities. The crux of the Commission’s complaint is that foreign non-profit entities that derive income from Spain, but which are established in another… – Continue reading
Wrap platforms are increasingly evolving to meet the needs of investors looking offshore for growth, with the addition of managed funds, ETFs and SMAs, Cameron Garrett writes. Traditionally, the investment portfolios of Australians have been heavily weighted towards investing in Australian equities. This is an interesting statistic, especially as the… – Continue reading
On 18 November 2015, Hong Kong and Romania signed an Income Tax Treaty. The treaty will come into force after the two countries exchange ratification instruments. The provisions of the treaty will have effect from 1 January of the calendar year next following that in which the agreement enters into… – Continue reading
The UK has climbed to 15th place in the latest World Bank Group and PwC Paying Taxes report, and is third top among G-20 countries, behind Saudi Arabia and Canada. Paying Taxes 2015 measures how burdensome a country’s tax regime is on the average medium-sized company. The report found that… – Continue reading
