Category: Jurisdiction

Knowledge Development Box – to encourage more innovation

Since Minister Noonan announced in October 2014 that Ireland would introduce a “best-in-class” Knowledge Development Box (“KDB” ), there has been a lot of speculation about ‘how low would he go’. Budget 2016 announced that the rate of tax which will apply for income qualifying under the new KDB will… – Continue reading

‘SA is bleeding billions’

JOHANNESBURG – South African has lost R250 billion in the form of service payments over a three-year period, highlighting the significant risk base erosion and profit shifting (BEPS) is posing to the country’s tax base, a South African Revenue Service (Sars) official has said. Almost R80 billion of this were… – Continue reading

GERMANY: FINAL GUIDANCE NOTES, IMPLEMENTING FATCA

Germany’s Federal Ministry of Finance on 3 November 2015 released final guidance notes for implementation of the FATCA regime. An intergovernmental agreement (IGA) signed by Germany and the United States follows the Model 1 IGA. Accordingly, financial institutions in Germany are required to report information concerning assets held by U.S…. – Continue reading

AUSTRALIA: ARE INVESTMENT ENTITIES EXCLUDED FROM “GROUP” FOR COUNTRY-BY-COUNTRY REPORTING?

A question being considered in Australia—concerning country-by-country (CbyC) reporting—is whether an investment entity is to be excluded from the “group” for CbyC reporting purposes. A preliminary position being advanced is when an entity is not required to prepare consolidated financial statements for financial reporting purposes, then it would be excluded… – Continue reading

Liechtenstein Rated “Largely Compliant” By OECD

Liechtenstein’s Prime Minister, Adrian Hasler, has welcomed recognition from the international community for its efforts to improve tax transparency. The Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) recently rated Liechtenstein “largely compliant” with Organisation for Economic Cooperation and Development (OECD) standards on tax transparency…. – Continue reading

Eurodad Identifies Surprising Haven Nations for Tax Evasion and Money Laundering

The European Network on Debt and Development (also known as “Eurodad”), a network of NGOs, has issued a recent report identifying European nations that have served as havens for tax evasion and money laundering. According to the report, Germany, Luxembourg, and Spain are among the most egregious offenders. By turning… – Continue reading

Protocol amending the Convention between India and Turkmenistan for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and on capital

The Union Cabinet chaired by the Prime Minister Shri Narendra Modi, has given its approval today for amending the Double Taxation Avoidance Convention (DTAC) signed between India and Turkmenistan in 1997 for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income… – Continue reading

Apple’s US returns indicate substantial rise in Irish tax paid

Technology company made the largest profit in its history in year to end of September Apple’s latest annual report indicates a substantial increase in the amount of tax it may be paying in Ireland. The latest annual report from Apple, filed last week in the United States, indicates a substantial… – Continue reading

UAE signs agreement on exchange of information for tax purposes with Norway

The visit aimed to explore ways of developing and promoting the technical partnership as well as exchanging experience on financial and economic affairs between the two parties. The UAE delegation started off with a visit to the Capital of Norway Oslo, during which the Ministry of Finance (MoF), signed an… – Continue reading

UK takes two-faced approach to tax, new report suggests

The UK government has a ‘Janus-faced’ approach to tax, a new report suggests: promising an increasingly intolerant approach to evasion and avoidance while being an aggressive participant in global tax competition and tolerating the UK tax havens which facilitate financial crime across the world. The report, Fifty Shades of Tax… – Continue reading

‘Patently False’: Bahamas Not Violating Tax Rules

A former finance minister yesterday slammed as “patently false” suggestions by a prominent tax advocacy group that the Bahamas is “disregarding the rules” and flouting global information exchange and transparency standards. James Smith, also an ex-Central Bank governor, hit out at the Tax Justice Network after its 2015 Financial Secrecy… – Continue reading

Blacklisted HK: The Latvian Case

The blacklisting of Hong Kong by the European Union is over for the moment with Spain explaining to the EU it didn’t have HK on its list. In the course of investigation, Harbour Times receives a quick response from the Latvian embassy in Beijing to clarify their stance on Hong… – Continue reading

Barbados, Slovakia Sign Double Taxation Agreement

Barbados and Slovakia signed a double tax agreement on October 28, 2015, to boost investment and trade prospects. The DTA allocates taxing rights to the two territories, to ensure that cross-border income is not taxed twice. It further stipulates that cross-border income from dividends will be subject to a withholding… – Continue reading

Sixteen States’ Tax Transparency Frameworks Reviewed

Sixteen peer review reports were released at the recent plenary meeting of the OECD Global Forum on Transparency and Exchange of Information for Tax Purposes on October 29-30, 2015. The release of the reports follows reviews of those territories’ legislation for the exchange of tax information and their frameworks for… – Continue reading

Global Forum makes strides toward tax transparency

The timely and effective implementation of the automatic exchange of tax information was a key theme during the Oct. 29-30 meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes held in Bridgetown, Barbados. The meeting, which brought together delegates from the Global Forum’s 128 member… – Continue reading

U.S., Armenia set to talk Double Tax Treaty at bilateral meeting

PanARMENIAN.Net – The negotiation of a U.S.-Armenia Double Tax Treaty will be on the agenda of the upcoming U.S.-Armenia Economic Task Force meeting, an annual bilateral gathering taking place in Washington, DC on November 19. The Armenian National Committee of America (ANCA) welcomed the initiative, suggesting that the Administration support… – Continue reading

Two unexpected countries could be havens for money laundering and tax dodging

Eurodad’s country comparison table, showing how each of the studied countries fared in the evaluation of four tax-related categories. Germany, Luxembourg, and Spain are egregious offenders in “supporting an unjust global tax system,” according to a new report from the European Network on Debt and Development (Eurodad), a network of… – Continue reading

Uganda becomes the 90th jurisdiction to join the most powerful multilateral instrument against offshore tax evasion and avoidance

04/11/2015 – Uganda today signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. It is the 8th country of the African continent to sign the Convention and the 90th jurisdiction to join it. Her Excellency, Nimisha Janat Madhvani, Uganda’s Ambassador to France, signed the Convention in the presence… – Continue reading

Cyprus – Switzerland: Tax Treaty Enters Into Force

TThe Income and Capital Tax Treaty between Cyprus and Switzerland entered into force on 15 October 2015. The provisions of the treaty will become effective on 1 January 2016. The treaty was signed on 25 July 2014. In accordance with the treaty, the following withholding taxes will apply: Dividends: 0%… – Continue reading

Tusk and Juncker set out the EU’s agenda in advance of G20 meeting

The President of the European Council Donald Tusk and the President of the European Commission Jean-Claude Juncker, who are representing the European Union at the G20 summit in Antalya (Turkey) on November 15th and 16th, have set out the EU’s agenda in a joint letter sent to EU Heads of… – Continue reading

How U.S. multinationals are responding to a post-‘Double Irish’ world

One year after the announced closing off of the Double Irish tax arrangement, U.S. multinationals once again turned their attention to Dublin as Ireland announced details of the Knowledge Development Box, or KDB. This new component to its corporate tax regime will allow companies to pay a reduced corporate tax… – Continue reading

Secret tax archives: UK joins move to block MEPs’ access

Treasury says making available documents detailing tax policies tailored for multinational firms would jeopardise ‘open and frank discussions’ The UK has joined Luxembourg, the Netherlands and Belgium in blocking attempts by a committee of MEPs to gain access to secret European archives that detail some of most controversial tax policies… – Continue reading

Financial Services Firms Set For 25% Contraction

The Bahamas will likely suffer a 25 per cent contraction in the number of financial services industry players, a senior international private banking executive said yesterday, as institutions merge to acquire scale and maintain profitability. Ricard Tubau, Andbank’s global chief executiv, said that not only is the financial services industry… – Continue reading

Fighting tax evasion: EU and Andorra finalise negotiations on new tax transparency agreement

Today the EU and Andorra initialled the text of a new tax transparency agreement, marking another important step forward in the fight against tax evasion. Under the new agreement, Andorra and EU Member States will automatically exchange information on the financial accounts of each other’s residents from 2018. Pierre Moscovici,… – Continue reading

Canada: FATCA In Canada: The “Cure” For A U.S. Place Of Birth

ABSTRACT This paper provides analysis of one of the foundational elements of the Foreign Account Tax Compliance Act (FATCA) and various intergovernmental agreements (IGAs): an unambiguous place of U.S. birth and the ability to cure (Cure) this element, thereby rendering the account nonreportable. The IGAs generally allow the individual to… – Continue reading

Tax Haven List Repealed by D.C. Council

After being in effect for only a week, the Council of the District of Columbia (Council) unanimously enacted legislation today that will repeal the list of tax haven jurisdictions specifically enumerated in the D.C. Code. The legislation, titled the Fiscal Year 2016 Second Budget Support Clarification Emergency Amendment Act of… – Continue reading

Canada: Canadian Challenge To FATCA

On August 4 and 5, 2015, the FC heard oral arguments in a lawsuit—commenced on August 11, 2014 by two Canada-US citizens—that challenges the law implementing the Canada- US intergovernmental agreement (IGA) relating to FATCA (Virginia Hillis et al. v. The Attorney General of Canada et al., court file no…. – Continue reading

UK tax agency must report full scale of tax avoidance-lawmakers

LONDON, Nov 4 (Reuters) – British authorities must start reporting the full scale of aggressive tax avoidance and prosecute more people for evading tax by moving money offshore, lawmakers said on Wednesday. The Public Accounts Committee of Britain’s parliament said the government’s tax agency, HM Revenue and Customs (HMRC), should… – Continue reading

MPs say that HMRC is “still failing UK taxpayers”

The Public Accounts Committee (PAC) said that Her Majesty’s Revenue and Customs (HMRC) is “still failing UK taxpayers” because of its “abysmal” performance in dealing with queries from taxpayers. The cross-party committee of MPs stressed that the “unacceptable” quality of HMRC’s customer service is a “genuine threat” to the collection… – Continue reading

Hong Kong second worst in financial transparency, says survey

Hong Kong is the world’s second least transparent financial center, making it vulnerable to tax evasion, money laundering and other wrongdoing. It is topped only by Switzerland in a global survey by Tax Justice Network, a coalition of researchers and activists focused on tax avoidance issues. The United States ranks… – Continue reading

U.K. Offshore Tax Enforcement `Woefully Inadequate,’ Panel Says

The number of U.K. prosecutions for offshore tax evasion is “woefully inadequate” and the tax agency, Her Majesty’s Revenue & Customs, is failing to provide lawmakers with the information they need to close loopholes used for avoidance, the House of Commons Public Accounts Committee said. The agency should also publish… – Continue reading

No revisions in main provisions of DTAA with India: Mauritius PM

Prime Minister of Mauritius, Anerood Jugnauth, on Tuesday said there will be no revisions to the main provisions of its Double Tax Avoidance Agreement (DTAA) with India as both countries are happy with the existing provisions of the tax treaty. “This treaty between our two countries has been there for… – Continue reading

HMRC has made ‘little or no progress’ on tax avoidance transparency, MPs warn

The UK’s tax authority has made “little or no progress” on revealing the scale of aggressive tax avoidance happening in Britain, an influential committee of MPs has warned. In a report released on Wednesday the Public Accounts Committee (PAC) said the tax authority had ignored previous recommendations to provide specific… – Continue reading

EY tax partner warns that foreigners keen to do business here are paying for new property rules requiring you to open a NZ bank account to get an IRD number

Frustrations are mounting, as foreigners keen to do business in New Zealand are getting tangled in red tape aimed at regulating overseas property speculators. EY tax partner, Aaron Quintal, warns the new laws requiring “offshore persons” to have a New Zealand bank account to get an IRD number, are causing… – Continue reading

Why Billions of Dollars in Estate Taxes Go Uncollected

They say the only certain things in life are death and taxes, but a large number of non-U.S. citizens may have found a way to avoid at least one of those. Under U.S. tax law, the estates of foreign holders of U.S. assets, such as stocks, real estate and valuables,… – Continue reading