Category: Jurisdiction

Singapore Yuan Hub Set to Grow Furthe

The offshore yuan market faced a rocky patch following Beijing’s shock devaluation in August, but the push to internationalise the currency has lost little momentum, according to The Strait Times. Similarly, Singapore’s role in the growth of the yuan is likely to continue unabated. The general manager of ICBC Singapore,… – Continue reading

EU Lawmakers Set to Vote on Tax Avoidance in Split Europe

Lawmakers at the European Parliament are set to vote on a controversial series of proposals to harmonize the corporate tax system in Europe in a move that will put them on a collision course with some member states which favor sovereignty over taxation. The EU lawmakers on the TAXE committee… – Continue reading

Expo 2020 will bring world to Dubai to learn and share ideas: Mohammed

His Highness Sheikh Mohammed bin Rashid Al Maktoum, Vice-President and Prime Minister of the UAE and Ruler of Dubai, today received at Zabeel Palace, Nikola Gruevski, Prime Minister of Macedonia, and his accompanying delegation. At the beginning of the meeting, which was attended by Sheikh Maktoum bin Mohammed bin Rashid… – Continue reading

The Latest South African Tax Proposals are Far-reaching

There was a time when, from a tax perspective, South Africa’s “mini budget” used to be a non-event. The main emphasis was on the annual budget speech delivered in February each year when they announced tax policy proposals. However, over the past few years there has been an increasing tax… – Continue reading

Brazil: GSGA – Special Report – Brazilian Tax Review 03/2014 – April/May/June

Taxation of Profits of Controlled Foreign Companies (CFC): Double Taxation Conventions must prevail over domestic rules The Superior Court of Justice (STJ) has recently decided a case involving the applicability of Brazilian CFC rules in cases in which the controlled company is located in a country with which Brazil has… – Continue reading

Government launches consultation on tax avoidance proposals

The government has launched a consultation on tax avoidance policies related to interest deductions that could have significant consequences for real estate. The proposals were released by the the Organisation for Economic Co-operation and Development (OECD) as part of a series of recommendations earlier this month designed to prevent companies… – Continue reading

DTAA tackles double taxation of job income

Expansion activities of companies lead to relocation of their employees to different territories, even outside the country. It goes without saying that transfer in job from one location to another comes with a baggage of issues, including the taxability of income from employment. The tax matter needs particular attention if… – Continue reading

The Mayor’s Free Land

A company controlled by Mayor of Belgrade Sinisa Mali and his family obtained more than 10 hectares of agricultural land worth anywhere from €123,000 to € 250,000 (US$140,000 to US$290,000) for free from a privatized state company. Problem is, the land wasn’t the company’s to give, but was still owned… – Continue reading

EU, World Bank urge Romania to step up efforts to recover graft money

The European Commission and the World Bank urged Romania on Monday to push ahead in its anti-corruption crackdown by recovering stolen assets following court convictions. Corruption in Romania has deterred foreign investors, while tax evasion and bribery put a further strain on the public finances. Anti-corruption prosecutors have launched investigations… – Continue reading

European Union: Tax Advantages For Fiat In Luxembourg And Starbucks In The Netherlands Deemed Unlawful Under EU State Aid Rules

The European Commission (“Commission”) ruled on 21 October that tax advantages granted by Luxembourg to Fiat and by the Netherlands to Starbucks by means of advance tax rulings were unlawful under the EU State aid rules. The two Member States will be required to recover the aid, in each case… – Continue reading

IRS Calls on Coca-Cola to Pay Up

Coca-Cola might owe an additional $3.3 billion in federal income taxes following an audit, says the Internal Revenue Service (IRS). Following a five year audit of the company, the IRS concluded that the company’s strategy of lowering its taxable income through transfer pricing, underestimates the amount the company should’ve been… – Continue reading

Is Europe Honest Enough To Deal With Tax-Dodgers?

The EU tax rulings against Starbucks and Fiat Chrysler are but trifles compared to the ones extant against Apple and Amazon. Everyone lies about tax. Holland said it followed international tax standards when everyone knows it’s a corporate tax haven. That’s why ST has its HQ there. Ireland and Luxembourg… – Continue reading

Procurement Services by Chinese Company Taxable as Fees for Technical Services under India-China Tax Treaty: AAR

• There can be no straight jacket formula to determine what is meant by “provision of service,” which may include where services are i) provided; ii) rendered; or iii) utilized. • The expression ‘provision of services’ is much wider than ‘provision of rendering of services,’ and covers the services even… – Continue reading

INVESTIGATION: How MTN ships billions abroad, paying less tax in Nigeria

MTN has consistently prided itself as the foremost telephone company that is getting Nigerians talking the most. Now the South African company is about to set tongues wagging across networks with revelations that it has routinely been shipping billions of naira overseas to avoid paying its fair share of tax… – Continue reading

Relaxed tax residency rules to help MNCs

Foreign companies with Indian shareholders won’t have to pay taxes here for their worldwide income unless they are managed from India on an everyday basis. If these foreign companies are managed from outside India, whether or not they are promoted by resident Indians, they will have to pay taxes in… – Continue reading

Canada: IRS Reports On The Success Of Its Voluntary Disclosure Programs

Since the initiation of the U.S.Internal Revenue Service’s (IRS) Offshore Voluntary Disclosure Program (OVDP) which originally began in 2009 and the Streamlined Filing Compliance Procedures first offered on September 1, 2012, the IRS recently reported that more than 54,000 taxpayers have come forward and the result is more than $8… – Continue reading

BEPS will affect around 9,000 companies globally: Grace Perez-Navarro

The Organisation for Economic Cooperation and Development (OECD) has been leading the charge to improve transparency in tax administration and curb tax avoidance by multinational companies. Endorsed by the G20 nations, including India, OECD recently came out with a package of measures and a road map to tackle base erosion… – Continue reading

Europe wants to get to the core of our Apple issue

The European Commission looks highly likely to make a finding against Ireland in relation to its tax arrangements with Apple, following two similar findings during the week involving Starbucks and Fiat. It is perplexing that the EC doesn’t just come out and make the announcement. The delay is leading to… – Continue reading

Commentary: Multinationals put poor countries in fix

The African Union Advisory Board on Corruption (AUABC) recently requested major multinationals operating in Africa to be more open about the taxes and royalties they pay governments to improve transparency and accountability. Although a reasonable request, this is a tall order when you consider that often it is the governments… – Continue reading

Art Collectors Find Safe Harbor in Delaware’s Tax Laws

NEWARK, Del. — It may not summon up a sense of international intrigue like Geneva or Luxembourg, but this small city, just off the Interstate and down the road from Wilmington, can now boast that it has joined those more glamorous locales as a tax haven for art collectors. Fritz… – Continue reading

East Africa: Rwanda Taxman Moves to Catch Tax Evaders

Rwanda has commissioned an audit into recent merger and acquisition deals involving foreign firms in its latest effort to clamp down on tax avoidance among multinational corporations. This comes amid growing concern that multinational companies move profits from the countries where they are generated and, in so doing, reduce national… – Continue reading

Shops, care homes and cinema among buildings owned by firms based in offshore tax havens

DOZENS of Winchester properties worth more than £100 million are owned by firms based in offshore tax havens. High street shops, restaurants, care homes, a health clinic and even a single parking space are owned by companies benefitting from low tax regimes overseas. Burma Road student village, sold by the… – Continue reading

UK: Data, Privacy And Taxation – A Very Modern Conflict

Since the revelations on government surveillance and data capture by Edward Snowden, journalists have rightfully raised concerns about governments’ insatiable appetite for data collection and the resulting encroachment on citizens’ civil liberties. In the EU an individual’s right to privacy is regarded as a human right in accordance with Art…. – Continue reading

Cayman Islands: Cayman Islands Issue OECD Common Reporting Standard Regulations

The Cayman Islands Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations, 2015 (the “CRS Regulations”) were issued on 16 October 2015. Cayman Islands Government Industry Advisory – CRS Regulations Are in Effect The CRS Regulations, which are the first part of two in the roll-out of the Cayman… – Continue reading

United Kingdom ‘tax gap’ falls to £34bn Steelers Lounge

The UK’s “tax gap” has fallen to £34 billion, according to HM Revenue & Customs (HMRC) following a series of crackdowns on evasion and avoidance by businesses and individuals. The numbers show the shortfall fell to 6.4% from 6.8% of tax due for 2013/14, remaining static in cash terms at… – Continue reading

Tax Planning for Chinese Investment in U.S. Real Estate

According to recent estimates, Chinese investors represented the largest group of foreign investors in U.S. real estate in the second quarter of 2015 with $1.9 billion in acquisitions. In the last 12 months, Chinese investors acquired $5.9 billion in commercial U.S. real estate, and Asia was second overall to Europe… – Continue reading

India fails to get to root of black money problem

The Indian government’s initial unsuccessful efforts to unearth billions of dollars of undeclared foreign assets – some believed to be hidden in Swiss banks – highlight the complexity of vehicles used to move money illicitly. Earlier in the year, a new law on black money came into effect. It included… – Continue reading

Ireland: Finance Bill shows signs of scrutiny of corporate tax regime

The key corporate tax measures in the Finance Bill show clear signs of the international scrutiny now surrounding multinational tax. The main new measure, the knowledge development box offering a lower tax rate on profits earned as a result of research and development, has been strictly drawn up to comply… – Continue reading

Challenges for family offices in emerging markets

Leading family offices in Latin America and the Caribbean are going through a transitional period, says Steven Cantor, managing partner of Cantor & Webb, a Miami-based law firm, reports the Financial Times. “As the world moves to tax transparency, with a crackdown on undisclosed tax savings in Swiss bank accounts,… – Continue reading

Taiwan and Mainland China signed a Cross-Straits Income Tax Agreement

Taiwan and Mainland China signed the “Cross-straits Agreements for the Avoidance of Double Taxation on Income and Solidifying Cooperation with respect to Taxes” (hereinafter referred to as “Cross-straits ITA”) on 25 August 2015. After the draft Article 25-2 of the “Act Governing Relations between the People of the Taiwan Area… – Continue reading

As Maruti and HUL show, royalty is a small price to pay

While stocks such as Hindustan Unilever (HUL) and Maruti Suzuki have outperformed the markets by a wide margin in the last couple of years, the stocks have sustained the performance even over longer periods. Despite the hue and cry over royalty payments by Indian subsidiaries of multinational companies, these companies… – Continue reading

Icahn Says He’ll Use New Super-PAC to Help America—and Himself

The New York billionaire is aiming his financial might at members of Congress who aren’t willing to cut deals on corporate tax policy. Sure, Carl Icahn might make money—lots of money—on his $6 billion stake in Apple Inc. if a political campaign he announced Wednesday to cut taxes on companies’… – Continue reading

CHANNEL ISLANDS: CRS MEASURES IN JERSEY

Pending draft regulatory measures in Jersey would give effect to the Common Reporting Standard (CRS). In general, the draft regulations would impose an obligation on “reporting financial institutions” in Jersey to identify, review, and report on “financial accounts” maintained by these institutions of accounts held by residents for tax purposes… – Continue reading

Just how dirty is offshore money?

David Cameron threw the proverbial cat among the pigeons in July when, with a steely glare at the UK property industry, he warned that the UK must not become “a safe haven for corrupt money from around the world” and that “there is no place for dirty money in Britain”…. – Continue reading