Category: Jurisdiction

Cayman Islands: CRS On The Cayman Islands

“He hath founded it upon the seas…” Psalm 24:2 From an ancient decree The motto on the Cayman Islands flag has profound meaning for all residents, whether indigenous or not. At 3:00am on 7 February 1794 the Royal Navy Frigate HMS Convert and its convoy of nine merchant ships were… – Continue reading

Australia: Private company tax information to remain confidential – 16 October 2015

Bill amending the income tax transparency laws passed The highly confidential income and taxation information of Australian-owned private companies will now be exempt from public disclosure. Currently, disclosure is required under the income tax transparency laws. HopgoodGanim Lawyers’ Taxation & Revenue team has previously published an alert on 8 July… – Continue reading

Revealed: How foreign buyers have bought £100bn of London property in six years

Wealthy investors have snapped up at least £100 billion of property across London using overseas companies in the past six years, new figures reveal today. Official data seen by the Standard shows that since 2008 there have been 27,989 purchases of homes, buildings and land in the capital by shadowy… – Continue reading

TP Disputes Trends Report 2015

Since 2002, there has been a steep escalation in transfer pricing disputes in the country, the ‘Taxsutra’s TP Trends Report’, is a perfect compendium which encompasses this escalation. The Chapter under which Transfer Pricing provisions were introduced was with the intent to ensure that there is no avoidance of tax…. – Continue reading

Breaking News: The Gambia Is On The Verge Of Finalizing A Deal With Hong Kong Based Companies To Open An Offshore Bank In Banjul!

The rogue regime in Banjul is on the verge of finalizing an Offshore Banking deal with some Hong Kong multi-million dollar companies, the Freedom Newspaper can reveal. Under the new deal, the Jammeh government is going to open an Offshore Bank in The Gambia, with the primary objective of helping… – Continue reading

Financial product peddler ordered to desist and refrain

On June 16 of this year, the California Department of Business Oversight issued a desist and refrain order to Encinitas’s Lawrence (Larry) Freeman and two of his many now-defunct companies, Yeshilkoy Insurance Services and Structured Marketing. In peddling financial products, Freeman made “an untrue statement of material fact to investors,”… – Continue reading

Ireland reveals Budget and international tax strategy

Ireland’s budget statement for 2016 (Budget) was delivered by the Minister for Finance last week. The Budget’s primary focus was on personal tax matters, which is somewhat unsurprising given the general election early next year. However, the Budget also contained two key announcements on Ireland’s corporation tax system.  In line… – Continue reading

KRA reaches out to former employees

Major tax administration reforms are expected after Kenya Revenue Authority (KRA) Commissioner General John Njiraini was made to cut short the release of quarter one performance on Monday following a call from State House. KRA has already moved to deepen its capacity by inviting former employees to boost its capacity… – Continue reading

Carl Icahn Forms Super PAC Aimed At Tax Reform

Carl Icahn, the iconic activist investor, has shifted, if only for today, his cross-hairs of contempt from the boardrooms of corporate America to the nation’s capital. Icahn sends members of Congress a word of warning Wednesday saw Carl Icahn warn several members of Congress a letter laying out his plans… – Continue reading

Fiat Chrysler reiterates did not receive state aid

“FCF did not receive any state aid and … any finding in this matter would be immaterial to the FCA Group’s reported results,” FCA said in a statement. MILAN: Fiat Chrysler Automobiles (FCA) denied again on Tuesday having received state aid from Luxembourg in a tax-related case, adding any findings… – Continue reading

Margaret Hodge calls for overhaul of UK tax laws

Former chair of the UK public accounts committee Margaret Hodge, who has repeatedly attacked the use of offshore tax avoidance schemes, has called for an overhaul of the British tax system. Speaking during an annual Professional Fee Protection (PFP) tax investigations conference, Hodge said the current tax regime in the… – Continue reading

Ireland: International Aspects Of Ireland’s Budget: 6.25% Knowledge Development Box And Country-By-Country Reporting

Following last week’s publication of the various OECD/G20 reports on the Base Erosion and Profit Shifting (“BEPS”) project, the Irish Budget delivered on 13 October 2015 contains the first Government initiative on implementing some of the recommendations. Key features are the introduction of the first of its kind knowledge development… – Continue reading

CLINTON LIBRARY FUNDED BY OFFSHORE TAX HAVEN

Hillary Clinton is repeating the Democrat trope about “offshore tax havens” that immorally divert profits from workers and the taxman. Closing these is a central plank of her promised agenda as President, she explains in an op-ed laying out her economic agenda. Setting aside the economic merits of her plan,… – Continue reading

25% of Companies Expected to Miss BEPS Deadline, Survey Finds

A recent Thomson Reuters survey report reveals that European companies are outpacing all others in developing their Base Erosion and Profit Shifting (BEPS) action plans by Dec. 31, 2017 – the deadline set by the Organization for Economic Cooperation and Development (OECD). But most respondents voiced several concerns about BEPS… – Continue reading

Hong Kong: The Need To Review Royalty And Technology Transfer Agreements

On October 5, 2015, the Organization for Economic Cooperation and Development (“OECD”) released its final report on the 15 key elements of international tax rules set out in its Base Erosion and Profit Shifting (“BEPS”) Action Plan. The OECD launched the BEPS Action Plan in 2013 at the request of… – Continue reading

China: A Brand-New Reporting Mechanism For Transfer Pricing Contemporaneous Documentation Under Discussion Draft For The Implementation Measures For Special Tax Adjustments

On 17 September, 2015, China State Administration of Taxation (“SAT”) released the Discussion Draft for the Implementation Measures for Special Tax Adjustments (“Discussion Draft”) to overhaul the existing trial version of the Implementation Measures, i.e., Circular 2. In the chapter of “Contemporaneous Documentation” of Discussion Draft, SAT introduces an entirely… – Continue reading

Record View: Amazon morally obliged to pay up their share of tax

WHEN public spending is being slashed in a way that punishes the poor, every firm have a moral obligation to pay their fair share. AMAZON are taking an ever bigger share of the shopping market. Technological advances mean you can order something from their website late at night from your… – Continue reading

The Self-Defeating Corporate Income Tax

For many years, policy makers have criticized the strategies that American corporations use to reduce their taxes by shifting income and capital offshore. The impetus behind these strategies is the U.S. corporate income-tax rate — at 35 percent, the highest of any industrialized nation, easily surpassing countries such as the… – Continue reading

Treasury ignores pleas to retain incentives

National Treasury has decided to scrap a recently introduced incentive to make South Africa’s service sector more competitive, despite an impassioned appeal from multinational companies not to do so. The special foreign tax credit for service fees has protected companies from double taxation where South Africa’s treaty partners levied withholding… – Continue reading

Worldwide: OECD Releases Final BEPS Recommendations – Now What?

On Oct. 5, 2015, the Organization for Economic Cooperation and Development (OECD) released a set of final reports on its 15 point action plan to address Base Erosion and Profit Shifting (BEPS). In an accompanying explanatory statement, the OECD also included plans for additional work on technical matters and a… – Continue reading

Ireland: Ireland’s Budget Statement 2016 – Key Points For Multinational Companies

Most of yesterday’s pre-election budget statement for 2016 (the “Budget“) by Ireland’s Minister for Finance (the “Minister“) focused on personal taxation. In the portion of his statement covering corporation tax, two key announcements were made in line with expectations following on from the publication of the final reports under the… – Continue reading

Chinese bond investors move offshore

Beijing’s monetary easing has sent onshore yields to multiyear lows, reports the Wall Street Journal. China’s booming domestic debt market is pushing investors to seek higher yields offshore, just as its banks start to expand yuan lending world-wide. The shift comes as China’s central bank is selling its first yuan… – Continue reading

HOUSING A TAX DODGE IN RICHMOND AND VANCOUVER

Some might be surprised to learn that certain areas of Richmond and Vancouver, despite being thoroughly decorated with mcmansions, monster homes, and incessantly rising land prices, are actually inhabited by low income residents that make up a surprising per cent of the population. Conservative Party leader Stephen Harper, during a… – Continue reading

Benefits of UAE-Based Offshore Companies

Offshore companies are established for a variety of reasons including a company’s necessity to restructure, create an international business entity as well as protect the assets of the company. The United Arab Emirates (UAE) is home to three authorities that register International or offshore companies. The three UAE authorities that… – Continue reading

London Wants to Become the Center of Chinese Currency Trading

Three years ago, Chinese officials said U.K. Prime Minister David Cameron had “seriously damaged” relations by meeting with the Dalai Lama, the exiled Tibetan leader. As planned talks between the two countries were canceled or failed to take place, worries emerged that Britain would miss out on building deeper economic… – Continue reading

United States: Tax Policy Update – October 13, 2015

NUMBER OF THE WEEK: 0 The number of House Republicans who want to be speaker and can actually secure the necessary 218 votes as of today. After Majority Leader Kevin McCarthy’s dramatic exit from the race last week, the House GOP conference is taking the week-long Columbus Day recess to… – Continue reading

Execs Weigh Impact of OECD BEPS Impact on U.S. Tax Reform

The impact of the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting action plan is still unclear, but tax executives are planning ahead for changes on the international tax front. Earlier this month, the OECD unveiled its plan for combating tax evasion strategies by multinational corporations (see… – Continue reading

LUXEMBOURG: DRAFT LEGISLATIVE PROPOSALS TO IMPLEMENT BEPS MEASURES

The Luxembourg government submitted draft legislative proposals to Parliament—legislation that, if enacted, would both implement certain provisions of the OECD’s base erosion and profit shifting (BEPS) actions and provide for certain EU-compliant measures. The proposals also would be intended to improve the competitiveness of the Luxembourg tax system. The proposals… – Continue reading

Bulgaria joins automatic exchange of financial account information agreement

Sofia. Bulgaria joins the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information, the press office of the Bulgarian cabinet announced. The agreement was signed by 51 jurisdictions on October 29, 2014 in the frames of the Global Forum on Transparency and Exchange of Information for Tax Purposes… – Continue reading

Don’t punish accidental tax evaders

The government’s determination to tackle tax evasion via offshore accounts is evident in its commitment to increasing international tax transparency, but it is in danger of veering seriously off course. Taking evasion action The government has been a key player in developing a common approach to automatically exchanging financial account… – Continue reading

Surge in outbound payments hint at expats’ bid to escape American tax authorities

MUMBAI: There is a sudden, inexplicable surge in money that Indians are sending abroad for ” maintenance of close relatives“. Such fund transfers typically add up to $10-20 million a month. But in July 2015, according to the latest available data, total remittance under this head crossed $124 million. Also,… – Continue reading

Four things to watch in the Medium-Term Budget

What economists and tax practitioners expect to see. JOHANNESBURG – Finance minister Nhlanhla Nene (pictured) will once again be between a rock and a hard place when he presents his Medium-Term Budget Policy Statement (MTBPS) on Wednesday. With the economy under pressure and concerns about how government will balance its… – Continue reading

Property mogul could lose £5.5 million tax break because he keeps coming back to UK for his domestic goddess wife’s great food

A retired millionaire property mogul could lose a £5.5million tax break because his domestic goddess wife’s ‘great cooking’ brought him back to the UK too often, the High Court has heard. James Glyn has insisted he was resident in Monaco when he received a £24million dividend from selling off his… – Continue reading

IMF Welcomes Tunisian Tax Proposals

The International Monetary Fund (IMF) has welcomed Tunisia’s plans for tax reform, noting that they will improve equity in the tax regime, simplify tax rules, and boost revenues. In its 2015 Article IV consultation report for Tunisia, the Fund called for the quick implementation of the tax reform package, which… – Continue reading

Sevan’s agent implicated in Petrobras bribery scandal

An agent who brokered offshore contracts between Sevan Marine and Petrobras in Brazil has come under scrutiny after receiving up to $40m of Sevan’s money into its offshore bank account, Norwegian reports say. The agent’s company is now part of the investigation into whether ex-Sevan Marine employees made bribes to… – Continue reading

Starbucks and Fiat Chrysler’s tax avoidance deals to be ruled illegal

Companies face multimillion-euro repayment bills after EC’s 15-month investigation. Rulings on Amazon and Apple will follow Starbucks and Fiat Chrysler are expected to be billed for tens of millions of euros in additional taxes as the European commission prepares to rule that they had unlawful deals with the Netherlands and… – Continue reading

Indian mining sector comes under scrutiny for fraud

KOLKATA (miningweekly.com) – The Indian federal government has zeroed in on the mining sector as the prime repository of “black money” and unaccounted wealth stashed overseas, and was instructing a clampdown by tax authorities. In a directive to tax authorities, including the Income Tax Department (ITD), the Finance Ministry observed… – Continue reading