The French Finance Minister, in an October 2015 press release, welcomed the agreement reached by the EU Finance Ministers on the introduction of provisions for the automatic exchange of information on cross-border tax rulings and the publication of the OECD reports on base erosion and profit shifting (BEPS). The French… – Continue reading
The details of the recently signed Income Tax Treaty between Jersey and Rwanda have become available. The treaty was signed on 26 June 2015. 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… – Continue reading
Margrethe Vestager, the EU’s competition commissioner, looks set to launch the international community’s most punitive attack on corporate tax avoidance as early as next Wednesday, with rulings that could impose heavy costs on multinationals, reports the Financial Times. Ms Vestager is understood to have postponed her first trip to China… – Continue reading
The Luxembourg Finance Minister Pierre Gramegna Wednesday announced a tax amnesty measure for income from Luxembourg which has not been declared, a first in the Grand Duchy, reports the Luxemburger Wort. He announced an action to “launder” tax evaders during the presentation of the draft budget 2016 before the Chamber… – Continue reading
Several close associates of Russian President Vladimir Putin may have benefited from Deutsche Bank AG trades that are now coming under the glare of U.S. prosecutors, according to people familiar with the matter. The U.S. Department of Justice is investigating whether Germany’s biggest bank properly vetted as much as $6… – Continue reading
Labor has urged Prime Minister Malcolm Turnbull to sell out of his hedge fund investments in the Cayman Islands, in an escalation of its attack in Parliament this week. Despite criticism his party had stooped to the “politics of envy”, NSW Senator Sam Dastyari told Fairfax Media on Friday that… – Continue reading
The September 29 2014 tax reforms (Law 20,780) introduced new provisions to the Tax Code (Decree-Law 830 1974, as amended), which empower the Tax Department to challenge transactions that have been carried out with the aim of avoiding taxes. These provisions introduce a general anti-avoidance rule for the first time…. – Continue reading
Government has made it easier for Australian companies to avoid paying tax, says Greens spokesperson Adam Bandt Greens MP Adam Bandt has lambasted the passing of new laws that ensure tax details of Australian-owned private companies are exempt from public disclosure rules, saying the government has made it easier for… – Continue reading
The central government is stepping up its anti-graft drive by cracking down on illegal lending and money-laundering operations in a bid to prevent outbound flows of stolen assets. The Ministry of Public Security says “black banks” and illegal currency exchanges have facilitated the flights of a number of former government… – Continue reading
BENGALURU: The Karnataka tax department’s recent proposal to e-commerce firms, considered a face-saver, may not be legally tenable, tax experts said citing High Court and apex court rulings. The Karnataka commercial taxes department, last week, asked e-commerce firms including Amazon, Flipkart and Snapdeal to deduct 1% of the money payable… – Continue reading
The following editorial appears in Friday’s Yomiuri Shimbun: International cooperation must be bolstered to close tax loopholes that can be exploited by multinational business corporations. The Group of 20 major economies and the Organization for Economic Cooperation and Development have worked out new international taxation rules to clamp down on… – Continue reading
The Department of Justice announced today that BBVA Suiza S.A. has reached a resolution under the department’s Swiss Bank Program. “Swiss banks such as BBVA Suiza S.A. are providing detailed information regarding their efforts to conceal U.S.-related accounts, and are turning over the names of individuals and entities that facilitated… – Continue reading
We are entering a new world of tax revenue wars, and no one can say who will emerge as the victor. All we know is that there will be tension over the next five years as governments seek to implement the global plan to end to tax havens from Luxembourg… – Continue reading
South Africa is allowing MTN potentially lucrative tax credits on money sent from its African operations to a letterbox company in Mauritius. Last week, amaBhungane and Finance Uncovered, a global reporting project, exposed how MTN’s African subsidiaries send billions in management fees to MTN International in Mauritius. The Mauritian entity… – Continue reading
Transfer pricing firms have been called upon to educate foreign tax authorities and the ATO on technical areas, as the topic receives unprecedented attention. Shannon Smit, director of Transfer Pricing Solutions, winner of the 2014 Australian Accounting Awards Boutique Firm of the Year award, spoke of the emphasis placed upon… – Continue reading
Orica has again found itself at odds with the Australian Taxation Office, this time over the circular financing arrangements the explosive maker put in place in 2002 to improve profits for the then struggling group. Orica has disputed the amended tax assessment from the ATO in relation to its “round-robin”… – Continue reading
Hong Kong (HKSAR) – The Hong Kong Special Administrative Region Government noted that the European Commission (EC) updated its webpage on October 12 on the listing of non-cooperative tax jurisdictions amongst the European Union (EU) Member States. After the Government’s liaison and clarification with relevant authorities, the technical error of… – Continue reading
(Bloomberg) — The People’s Bank of China is considering starting direct trading between the yuan and the Swiss franc, according to three people with direct knowledge of the matter. The Swiss franc would become the seventh major currency to be exchangeable directly for yuan in Shanghai, joining the U.S., Australian… – Continue reading
Ireland is growing as a global maritime business hub and its strengths in asset leasing could provide an alternative source of finance for shipping, according to a new report commissioned by the Irish Maritime Development Office and authored by tax advisors KPMG and legal firm Dillon Eustace, reports Splash. The… – Continue reading
A resolution was published in Panama’s official gazette in September 2015 replacing and “repealing” an August 2015 resolution, concerning how taxpayers may seek a ruling from the tax authorities as to whether benefits under income tax treaties for the avoidance of double taxation apply to the taxpayer’s specific transaction or… – Continue reading
With Medtronic being one of Ireland’s largest employers, analysts say there is a new incentive for the medical device maker to prioritize its Dublin headquarters for R&D. In the eyes of developed nations, Ireland has become notorious for baiting multinational firms to its land with the offer of friendly tax… – Continue reading
The Internal Revenue Service (IRS) has released a revised October 2015 version of its Publication 597, which provides information on the United States-Canada double taxation agreement (DTA), reports Tax News. A number of DTA provisions that most often apply to US citizens or residents who may be liable for Canadian… – Continue reading
In a summary judgment released on September 16, 2015, the Federal Court of Canada examined and disposed of the non-constitutional arguments in the Hillis and Deegancase[1] generally finding that the automatic data collection and disclosure of taxpayer information to the United States by Canada pursuant to the Canada-U.S. Intergovernmental Agreement… – Continue reading
Extensive use has been made of trusts in South Africa, both for tax planning and for the purposes of reducing (or eradicating) one’s estate duty liability upon death. As the use of offshore trusts as a estate and wealth planning vehicle increases, one needs to consider if and how offshore… – Continue reading
NEW DELHI: The Vodafone Group has started “preparatory work” for an initial public offering of its Indian unit, although no dates have been set yet, the British telecom company’s CEO said, expressing optimism about the emergence of a new India. Vodafone CEO Vittorio Colao, however, argued against the government’s proposal… – Continue reading
London will struggle to become a home for the catastrophe bond market due to higher taxes and regulatory hurdles compared with offshore regimes, a report by Britain’s department of trade and consultants Grant Thornton said on Wednesday, reports Reuters. The report pours cold water on British government plans to develop… – Continue reading
PR chief, who pocketed more than £11m from his agency last year, attacks tax system for foreign-owned companies Matthew Freud has attacked the pittance Facebook pays in UK tax after footing a bill for almost £3m last year, as he pocketed more than £11m from his PR and marketing agency… – Continue reading
SOON, THAILAND will no longer have mere transfer-pricing guidelines in the form of Departmental Instruction Paw 113/2545, but will instead put into effect a transfer-pricing law, the draft of which was approved by the Cabinet in May. Taxpayers will of course be required to abide by the new law. There… – Continue reading
Golden visa EU citizens may freely register as residents in Portugal. However, non-EU citizens may also obtain residence in Portugal if they obtain a ‘golden visa’ by participating in investment activity and fulfilling certain requirements. Requirements Obtaining a golden visa requires one of the following types of investment: acquisition of… – Continue reading
Permanent Establishment Based on the new treaty the definition of permanent establishment also includes a building site or construction or installation project or any supervisory activities in connection with such site or project constitutes a permanent establishment only if it lasts more than 9 months. Dividends The withholding tax rate… – Continue reading
Finance professionals will play a key role in dealing with changes brought about by a global project to combat corporate tax avoidance. A GLOBAL effort to tackle the problem of companies that attempt to reduce their tax burden by exploiting loopholes in tax rules will impact the way global businesses… – Continue reading
The Canada Revenue Agency (CRA) rents office space from a Vancouver-based property developer – a company that exploits offshore tax havens in Liechtenstein, the British Virgin Islands and Channel Islands. Larco Investments Ltd. owns three buildings in Montreal, Calgary and Edmonton where they rent office space to the CRA. Larco… – Continue reading
The United States has rejected India’s claim that schemes such as Atal Pension Yojana, Rashtriya Swasthya Bima Yojana, Employees Provident Fund Organization and others should be taken into account while determining the size of population covered under social security schemes. In recently resumed talks on Totalization Pact, the US said… – Continue reading
The Treasury Inspector General for Tax Administration has generally praised the US Internal Revenue Service for its implementation of the Foreign Account Tax Compliance Act. To improve US taxpayer compliance in reporting foreign financial assets and offshore accounts, Congress passed FATCA in March 2010. FATCA is intended to ensure that… – Continue reading
In just over two months, thousands of U.S.-based financial institutions will face new requirements for sharing financial information. These businesses should get ahead of the deadline and start preparing for the impact these rules will have on their operations and bottom lines. The Organisation for Economic Co-operation and Development’s new… – Continue reading
MINSK, 15 October (BelTA) – The House of Representatives of the National Assembly of Belarus ratified the Belarus-Georgia intergovernmental agreement on avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and capital on 15 October, BelTA has learned. It is expected that the agreement… – Continue reading
x At present, says the Government, serial avoiders find themselves in no worse a position than someone who has used only one failed avoidance scheme and has decided not to do it again. They face no additional deterrent to stop them persistently seeking to circumvent the will of Parliament. With… – Continue reading
Starbucks Corp. and a Fiat Chrysler Automobiles NV unit are set to be first in the firing line as European Union regulators issue a series of rulings over tax breaks for global companies, including Apple Inc. The EU may issue decisions against Starbucks and Fiat as soon as next week… – Continue reading
Do your individual clients howl about paying too much federal income tax? Just wait until you get an earful from your business clients. Advertisement A new report from the Tax Foundation, a conservative-leaning think tank located in our nation’s capital, found that the United States has the third-highest marginal corporate… – Continue reading
The Dutch government presented its Tax Bill 2016 on 15 September 2016. Three elements of this bill could specifically affect multinationals, international investors and investment funds with Dutch headquarters or group companies: The anti-avoidance rules in respect of non-resident taxation of foreign corporate shareholders and the dividend withholding tax treatment… – Continue reading
This summer brought some very significant amendments to the Cyprus tax laws, further enhancing Cyprus’ favourable tax regime. On 17 July 2015, the following laws were amended: The Special Defense for Contribution law No. 117(I) of 2002 as amended; The Income Tax Law No 118(I) of 2002 as amended; and… – Continue reading
HM Revenue and Customs (HMRC) has succeeded against a £200 million tax avoidance scheme which exploited the UK’s double taxation agreement with the Isle of Man, whereby people are not taxed on the same income in both the UK and the Isle of Man. Those who took advantage of the… – Continue reading
As Noonan moves to stimulate domestic growth we need to think about the global debate The Irish economy is now in better shape than at any time since the beginning of the financial crisis. After many years of tough austerity measures, last year’s budget marked a turning point where Minister… – Continue reading
The chief of the generic drug company discussed her “counterintuitive” strategy for creating U.S. jobs. Mylan is one of a handful of U.S. companies that has recently completed a controversial tax inversion, as the generic drug company moved its official base to the Netherlands earlier this year. While the decision… – Continue reading
Members of the European Parliament’s Economic and Monetary Affairs Committee have described last week’s agreement on a directive for the automatic exchange of information on tax rulings as a “missed opportunity”. The European Commission said last week that the Economics and Financial Affairs Council of the European Union (ECOFIN) had… – Continue reading
Individuals and families whose tax plans include trusts should take note of the recent decision of the Supreme Court of Newfoundland and Labrador in Discovery Trust v Minister of National Revenue (“Discovery Trust”)1 – the first case to deal with the issue of the residency of a trust for provincial… – Continue reading
A series of recent developments means that tax is now a key part of the Australian foreign investment regime and the foreign investment rules have significantly more bite. When determining whether a foreign investment proposal is “contrary to the national interest”, the Foreign Investment Review Board (FIRB) actively considers the… – Continue reading
David Gauke, the Financial Secretary to the UK Treasury, has said that international agreement on the OECD’s base erosion and profit shifting (BEPS) reports “is just the start of the process of reform.” In a speech to EY’s 34th Annual International Tax Conference, Gauke said: “To ensure timely, effective implementation,… – Continue reading
Last week’s OECD release of the final package of measures for a coordinated international approach to the reform of the international tax system, under the OECD/G20 base erosion and profit shifting (BEPS) project, marks the end of the discussion and recommendation phase, and the start of the implementation and practical… – Continue reading
The number of EU countries that regard Gibraltar’s tax regime as harmful has dropped from nine to seven, according to updated information released by the European Commission yesterday, report the Gibraltar Chronicle. The Commission database collects information on how the EU’s 28 members view other countries’ tax regimes. When it… – Continue reading
