Category: Jurisdiction

Cayman Islands: New ITC-AML Headaches For Cayman Funds In 2016

In 2016, hundreds of directors, managers, principal points of contact (PPCs), compliance officers, administrators, and Money Laundering Reporting Officers (MLROs) serving Cayman Islands funds, banks, trust companies and other Reporting Financial Institutions (RFIs) will start to feel the full force of ‘a great wind’: global tax transparency. If you are… – Continue reading

Australia widens legislation to target more companies for tax avoidance

Federal government increases number of companies under tax office scrutiny from 30 to 80 under budget measures announced in May The federal government has widened the scope of legislation aimed at tackling multinational tax avoidance, increasing the number of large companies under the tax office’s microscope from 30 to 80…. – Continue reading

Global film scheme gang on trial for £100m tax fraud

A financial adviser and a group of film producers who set up an international scheme are facing a trial for fraud. It is alleged the scheme, which took advantage of the tax relief the UK Government offers the film industry, created the appearance of huge “paper losses”, The Times reported… – Continue reading

Uber and Airbnb confirm they send profit offshore

Uber and Airbnb have revealed in submissions to a federal inquiry that they route profit through companies in the Netherlands and Ireland, where taxes are lower. Uber and Airbnb have told a Senate corporate tax avoidance inquiry that while they comply with Australian tax laws, their Australian operations merely provide… – Continue reading

US companies holding $2.1 trillion offshore profits

There’s enough cash sitting in offshore bank accounts to wipe out the federal deficit — if only it was subject to U.S. taxes. That’s because U.S. companies are saving some $620 billion by parking profits outside the country, according to the latest accounting from Citizens for Tax Justice and U.S…. – Continue reading

Cabinet approves double taxation avoidance protocol between India & Israel

The Union Cabinet chaired by the Prime Minister Narendra Modi, has approved the protocol amending the convention and the protocol between India and Israel, for avoidance of double taxation and for prevention of fiscal evasion with respect to taxes on income and on capital. The protocol provides for internationally accepted… – Continue reading

Singapore’s tax jurisdiction largely in line with OECD’s tax proposals: Experts

The proposals are aimed at preventing aggressive tax planning by multinationals. However, experts warn that the risk of double taxation may increase. SINGAPORE: Tax experts have said that Singapore’s tax jurisdiction is broadly in line with new tax proposals announced on Monday (Oct 5) by the Organisation for Economic Co-operation… – Continue reading

Many of Metro Vancouver’s off-shore buyers practicing tax avoidance, investigation finds

A Wednesday forum organized by the Urban Development Institute in Vancouver is dealing with foreign ownership in the local housing market. and there’s new concern about offshore buyers avoiding Canadian tax. Globe and Mail reporter Kathy Tomlinson investigated one case of a private equity manager in Beijing buying a $2.3… – Continue reading

The tax considerations of living abroad

While the thought of going abroad to work or retire may be exciting, the months leading up to departure are likely to be highly stressful. It is vital that you pay adequate attention to financial planning. In particular, the tax consequences of leaving the UK are quite complex, so it’s… – Continue reading

Cabinet okays amendments to tax avoidance pacts with Israel, Vietnam

NEW DELHI, OCTOBER 7: The Union Cabinet on Wednesday gave its nod for the introduction of a ‘limitation of benefit’ clause in the double taxation avoidance convention (DTAC) with Israel. The ‘LOB’ Article is an anti-abuse provision aimed at preventing misuse of the convention. The protocol that received the Cabinet’s… – Continue reading

Greek Minister Pledges Crackdown on Tax Evasion, with German-Style Tax Raids on Big Business

The government intends to crack down on tax evasion by adopting best practices from other countries, Greek Alternate Finance Minister Tryfon Alexiadis said in Parliament on Tuesday, during the debate on the government’s policy statements. Among others, he announced plans to follow the German model for tax inspections, in which… – Continue reading

UK: The Use Of UK Holding Companies In International Group Structures

The location of a holding company is a significant consideration in any international corporate structure. Choice of jurisdiction for a group holding company (‘Holdco’) is relevant both from the point of view of tax optimisation (maximising withholding tax free dividend, interest and royalty flow up through the group and minimising… – Continue reading

ECOFIN Council reaches agreement on the automatic exchange of information on tax rulings and APAs

On 6 October 2015, the Council of the European Union reached agreement on a proposal for a Council Directive (‘the New Directive’) amending Directive 2011/16/EU (Directive on administrative cooperation between Member States) and requiring automatic exchange of information on ‘advance tax rulings’ (‘Tax Rulings’) and ‘advance pricing arrangements’ (‘APAs’) between… – Continue reading

Russian Federation: Russian 2015 Tax Revolution

For many years international tax planning for Russian inbound and outbound investments, and wealth planning for Russian resident individuals, was rather straightforward. That was primarily due to relatively simple domestic tax rules and a degree of inexperience amongst the Russian tax and other interested authorities in relation to international tax… – Continue reading

OECD proposals could save countries US$240bn in lost taxes

With the bulk of the OECD’s work on the BEPS project complete, attention will now turn to the implementation of the recommendations by member countries and others. Minister for Finance, Michael Noonan said that he welcomed the Base Erosion and Profit Shifting (Beps) report, and that the OECD’s proposals would… – Continue reading

Tax experts criticise ‘thin’ non-dom consultation paper

The UK Government’s consultation paper on non-domicile status is “thin on the ground” when it comes to detail and, if introduced as proposed, will fail to treat some ‘non-doms’ fairly, according to tax experts. “It feels like this new legislation is being rushed through,” said Dean Mullaly, managing director of… – Continue reading

72% of Fortune 500 Used Foreign Tax Havens

Nearly three-quarters of Fortune 500 companies booked their profits to tax havens last year, with just 30 companies accounting for 62 percent of earnings stashed offshore, according to a new report. The report, “Offshore Shell Games,” released Tuesday by the U.S. PIRG Education Fund and Citizens for Tax Justice, found… – Continue reading

CORRECT: NZ’s biggest companies may face ‘enormous compliance burden’ from OECD tax dragnet

Oct. 6 (BusinessDesk) – Fonterra Cooperative Group is likely to be among some 20 New Zealand companies left dealing with increased red tape to comply with wide-ranging reforms to corporate tax rules proposed by the Organisation for Economic Cooperation and Development and expected to be endorsed by the world’s 20… – Continue reading

BEPS plan puts companies in the firing line, say experts

The OECD-G20 plan to stop multinational tax avoidance could put companies in the middle of border disputes between revenue authorities, tax experts have warned. But civil society groups say the plan has not gone far enough and could make it easier for some multinationals to dodge tax. Treasurer Scott Morrison… – Continue reading

The CRA complied with the September 30 FATCA deadline after the IRS advised that Notice 2015-66 did not apply to Canada

In an affidavit that was filed with the Federal Court of Appeal on September 25, 2015 in support of the government’s response to block a motion for injunctive relief that had been brought by the plaintiffs, Sue Murray, Director of the Canada Revenue Agency’s Competent Authority Services Division, International and… – Continue reading

25% of Global Companies Say They Won’t Meet BEPS Deadline

One-quarter of corporate tax and transfer pricing directors surveyed say their companies will fail to meet the first deadline proposed by the Organisation for Economic Co-operation and Development (OECD) in its Base Erosion and Profit Shifting (BEPS) Action Plan. Finance ministers for the G20 countries called on the OECD to… – Continue reading

OECD: countries commit to minimum standards on international tax dispute resolution

Countries should commit to minimum standards on the resolution of international tax disputes, the Organisation for Economic Co-operation and Development (OECD) said in a report published as part of its base erosion and profit shifting (BEPS) project.06 Oct 2015 The standards would include a commitment to “seek to resolve” cases… – Continue reading

CAB requests the removal of named Caribbean territories on US “Tax-haven” list

PRESS RELEASE – The Caribbean Association of Banks Inc. (CAB) is once more forced to express its deep concern over yet another “tax-haven” list which includes 15 Commonwealth Caribbean countries. The referred list appears within the District of Columbia’s 2015 Budget Support Act which expands the definition of “tax haven”… – Continue reading

Top Wall Street Banks Stash Billions Of Dollars In Nearly 400 Offshore Tax Havens

Six of the nation’s largest banks — Bank of America, Citigroup, JPMorgan Chase, Wells Fargo, Morgan Stanley and Goldman Sachs — utilize a combined 395 known tax havens to avoid potential tax bills in the billions, according to a new analysis. In total, the big six banks kept $126 billion… – Continue reading

US firms pan international tax proposal

The architects of a sweeping set of recommendations to battle offshore tax avoidance insist their project won’t allow foreign countries to simply grab cash from U.S. companies. The business community isn’t convinced. Senior officials at the Organization for Economic Co-operation and Development (OECD), a Paris-based research group sponsored by almost… – Continue reading

Turkey: Council Of Ministers Approves Agreement Between Turkey And Kosovo To Prevent Tax Evasion And Double Taxation

The Council of Ministers has approved an agreement between the Republic of Turkey and Republic of Kosovo (“State” or collectively “States”) to prevent tax evasion and double income taxation for residents of the two countries (“Agreement”). On 19 August 2015, the Council of Ministers approved the Agreement and its annexed… – Continue reading

These eight Massachusetts companies have used offshore tax havens

BOSTON – Tax havens are legal, but proponents of tax reform say eight companies headquartered in Massachusetts are using them and costing the state millions of dollars in revenue. The MassPIRG Education Fund and Citizens for Tax Justice released a report on Tuesday saying 72 percent of Fortune 500 companies… – Continue reading

EU ministers agree measures to curb multinationals’ tax avoidance

LUXEMBOURG: European Union finance ministers agreed on Tuesday to automatically exchange information on deals struck with multinational companies from 2017 in a bid to reduce tax avoidance, officials said. “We have a political deal on this issue,” Luxembourg’s finance minister Pierre Gramegna told his EU counterparts in a public session… – Continue reading

OSPIRG: Nike uses offshore tax havens

72% of Fortune 500 companies have offshore subsidiaries PORTLAND, Ore. (KOIN) — More than 72% of Fortune 500 companies have subsidiaries in offshore tax havens to take advantage of tax loopholes, a new study by the Oregon State Public Interest Research Group showed. Oregon-based companies in the Fortune 500 are… – Continue reading

Mythbusters: the UK/Spain tax treaty

Writing exclusively for SuperyachtNews.com, Patrick Maflin, of Marine Accounts, advises crewmembers on how best to avoid falling foul of the UK/ SPAIN Double Taxation Agreement… The Seafarers Earnings Deduction (SED) is arguably the taxation scheme of choice for most Seafarers nowadays working on foreign going yachts. It is open to… – Continue reading

Adviser attacked over £262m tax avoidance scheme as court battle begins

A financial adviser is one of the five defendants embroiled in a court battle after facing allegations of setting up a £262 million tax avoidance scheme. In a trial at Birmingham Crown Court, financial adviser Norman Leighton, chartered accountant and film producer Keith Hayley, producer Robert Bevan, Charles Savill and… – Continue reading

Singapore: Singapore Tax Treaties: The End Of Limitation Of Relief?

What is limitation of relief? Here is an actual illustration: A client in Singapore has loans to a Spanish SOCIMI, a real estate investment company equivalent to a REIT. Spain requires tax to be deducted at source when interest becomes payable even if in fact the interest is not actually… – Continue reading

Big U.S. firms hold $2.1 trillion overseas to avoid taxes: study

The 500 largest American companies hold more than $2.1 trillion in accumulated profits offshore to avoid U.S. taxes and would collectively owe an estimated $620 billion in U.S. taxes if they repatriated the funds, according to a study released on Tuesday. The study, by two left-leaning non-profit groups, found that… – Continue reading

Ireland tweaks tax regime to divert avoidance criticism

The Irish government is set to make further changes to the country’s corporate tax regime as it seeks to align itself with a global initiative to clamp down on corporate tax avoidance, reports the Financial Times. The change being considered will oblige companies that have global headquarters in Ireland to… – Continue reading

Isle of Man: US FATCA Information Exchange Put Back A Year

In a move which is likely to be of interest to those organisations who put systems and procedures in place to comply, the US has recently announced (September 2015) that information on US persons does not now need to be exchanged for certain jurisdictions until September 2016. In Notice 2015-66… – Continue reading

Gaming the System: Underlying Problems of the U.S. Tax Code Must be Addressed

Last year at this time, news about “tax inversions” was grabbing headlines – cases where large U.S. multinationals would buy a foreign company in a tax-friendly jurisdiction, and then relocate its headquarters to reap the tax arbitrage benefits. The Obama administration responded to the rash of high-profile inversions with new… – Continue reading

OECD poised to release new tax dodge rules

Senior EY partners Andy Archer and David Snell look at some looming changes to international tax rules. In what will be the biggest change to the international tax rule book since it was put in place before World War 2, the OECD will tomorrow (4 am Tuesday 6 October) release… – Continue reading

Internal Revenue Service Begins Reciprocal Automatic Exchange of Tax Information Under FATCA IGAs

On October 2, 2015, the Internal Revenue Service announced that it had achieved a key milestone in implementation of the Foreign Account Tax Compliance Act (FATCA), a critical anti-tax evasion law passed by Congress in 2010 but not fully implemented until July 2014. The milestone announced by the IRS was… – Continue reading