Category: Jurisdiction

Cyprus: Foreign Account Tax Compliance Act (FATCA) – The Decree In Accordance With The Assessment And Collection Of Taxes Law

The decree of 2015 in accordance with the Assessment and Collection of Taxes Law (Exchange of Information within the framework of the Agreement for the Foreign Account Tax Compliance Act) has been issued and published in the official Gazette of the Republic of Cyprus dated 28th August 2015 (Decree 281/2015)… – Continue reading

Netherlands: Luxembourg Bill Implements Anti-Abuse And Anti-Hybrid Rules For EU Intra-Group Dividends

Luxembourg recently published a bill to implement the new anti-hybrid rule and the general anti-abuse rule (GAAR) of the EU Parent Subsidiary Directive (PSD). The bill closely follows the wording of the PSD. A similar Dutch bill is expected on 15 September 2015. While the Dutch bill may differ from… – Continue reading

Timothy Charles Pratten found guilty of fraud, hiding millions from the ATO

Fraudster Timothy Charles Pratten has been found guilty on seven counts of obtaining a financial advantage by deception, in the Supreme Court of NSW in Sydney this week. Justice Stephen Rothman found Pratten, A 55-year-old insurance broker, failed to properly declare income of more than $5 million between 2003 and… – Continue reading

HMRC nets £1bn from tax avoidance crackdown

HM Revenues & Customs (HMRC) has collected £1 billion from users of tax avoidance schemes after introducing new rules to collect disputed tax upfront. The government introduced the Accelerated Payments regime last year to change the economics of avoidance where disputed tax is paid upfront by avoidance scheme users, who… – Continue reading

OECD publishes Irish report

Before the economic crash, OECD reports on its member countries focused on the structural problems afflicting the individual economies, be it the dominance of a national telecoms company or so-called sheltered areas of the economy which didn’t face competition, including the professions such as lawyers or pharmacists. Even mild recommendations… – Continue reading

Accountants defend their tax record

As Big Four accountancy firm PwC publishes its annual report Madeline Ratcliffe talks to chairman Ian Powell. PWC, ONE of the world’s largest financial services companies, will today report their full year profits increased by six per cent, to £818m, reflecting a policy of growth and investment over the last… – Continue reading

NNPC’s new oil swap deal not transparent — Group

A civil society group focused on transparency in the oil and gas sector has criticized the interim Offshore Processing Agreement, OPA, between the Nigerian National Petroleum Corporation, NNPC, and three multinational trading companies to boost the supply of refined petroleum products in the country. The Africa Network for Environment and… – Continue reading

KMT to push cross-strait taxation pact in new legislative session

Taipei, Sept. 14 (CNA) The Kuomintang (KMT) government will be prioritizing passage of a cross-strait agreement on double taxation avoidance as well as bills on the budget, government restructuring and an all-volunteer military in the fall legislative session that opens Tuesday, Premier Mao Chi-kuo (毛治國) said Monday. Mao said the… – Continue reading

The Advantages of Enacting a Patent Box Regime

Many countries have enacted a patent box regime in order to spur innovation and create domestic manufacturing jobs. Simply stated, a patent box regime provides a lower tax rate on income from the exploitation of patented goods than for other income. Among the countries that have patent box regimes are… – Continue reading

Apple China Ordered To Pay $10 Million Fine For Tax Evasion

Apple’s CEO Tim Cook announced on Wednesday, Sept.9, that the famed brand’s revenue significantly increased in China by up to 75 percent in the past year. However, the country’s finance authorities cut the celebration short. China’s Ministry of Finance demanded Apple to pay 452 million yuan, a price equivalent to… – Continue reading

Not international business as usual

BARBADOS’ OFFSHORE FINANCIAL SERVICES SECTOR is again under threat. The Organisation for Economic Cooperation and Development (OECD), G20 and the European Union (EU) are acting in concert, armed with the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS). Once implemented, the confidentiality which once protected financial… – Continue reading

Moscovici resolute on common corporate tax base

EU commissioner urges member states to ensure fair share of tax is paid EU economics commissioner Pierre Moscovici reiterated his commitment to re-launch the Common Consolidated Corporate Tax Base yesterday, urging all EU member states to ensure that companies pay their fair share of tax. Speaking following a meeting of… – Continue reading

Tax trouble brews for Starbucks, Apple as Europe takes aim at taxes

Multinationals have come under fire yet again over their tax arrangements in some European countries, as the continent moves closer to a pan-European regime to combat tax avoidance. On Friday, European economy and finance ministers and central bankers (known as an ECOFIN meeting) gathered in Luxembourg to discuss what the… – Continue reading

Vietnam-US double taxation avoidance will bring more gains than losses

With the agreement with the US, Vietnam has now signed the double taxation avoidance agreements with 70 out of 170 countries and territories with which Vietnam has trade and investment relations. Double taxation is considered a barrier to trade and investment. It discourages transnational investments while prompts individuals and businesses… – Continue reading

Malta remains against tax harmonization

Speaking at an informal meeting of the Economic and Financial Affairs (ECOFIN) in Luxembourg, Finance Minister Edward Scicluna once again expressed Malta’s opposition to tax harmonization. “Taxation remains a sensitive area for Malta, not only because of its obvious role in the revenue collection process, but also as an important… – Continue reading

PANAMA: UPDATE ON FATCA

Panama in May 2014 indicated its intentions to enter into an intergovernmental agreement (IGA) with the United States, for purposes of implementing the FATCA regime. The Panama agreement would follow the Model 1 IGA. As of early September 2015, Panama has yet to sign the IGA. In preparing for implementation… – Continue reading

Government panel submits financial sector reforms report

A government committee on financial sector reforms has finalised a report, broadly outlining the amendments required in financial laws and taxation to make domestic sector more competitive in the international market. Sources in the know said the report was submitted on Tuesday by the Standing Council of Experts, which was… – Continue reading

U.S. companies given Export-Import Bank subsidies keep profits offshore, skirt taxes

Budgeting battle But like much of the budgeting in Washington, D.C., it gets complicated. The Congressional Budget Office contends the Ex-Im Bank’s surpluses are the result of the accounting method the bank uses and would disappear — or require a taxpayer subsidy — if the bank used a more appropriate… – Continue reading

Tax evader crackdown could reduce offshore banking options for expats

An initiative intended to catch tax dodgers could have a negative impact on those with perfectly legitimate bank accounts. Tax expert Howard Bilton offers advice The draconian Foreign Account Tax Compliance Act (FATCA), introduced by the US Government to tackle tax evasion by its citizens, has already affected Britons living… – Continue reading

Private banking: Singapore, Indonesia in private banking tug-of-war

Indonesians hold $300 billion in Singapore; controversial tax amnesty on the cards. Indonesia’s finance minister Bambang Brodjonegoro told Euromoney earlier this year that tax collection falls way short of targets and must improve to provide funding for infrastructure and other projects It doesn’t take much for Indonesia’s government officials to… – Continue reading

How captive IT offshore centers are driving IT innovation

Companies like Amazon, Tesco and Honeywell are looking to offshore IT subsidiaries to deliver digital transformation. New launches of captive centers offshore continued to increase in the first half of 2015, according to research from outsourcing consultancy Everest Group. Companies in the manufacturing, telecommunications and technology industries, in particular, expanded… – Continue reading

Italy sees progress on euro zone financial transactions tax

The finance ministers of 11 euro zone countries willing to introduce a financial transactions tax (FTT) are expected to make progress on the thorny issue in a meeting on Saturday in Luxembourg, Italy’s economy minister said. Germany and France proposed the tax in 2012, in the midst of the euro… – Continue reading

INDIA: FATCA GUIDANCE NOTES

India’s Ministry of Finance, Department of Revenue (Foreign Tax and Tax Research Division) on 31 August 2015 released guidance notes with respect to implementation of the reporting requirements under rules 114F to 114H of the Income tax rules. Rules 114F to 114H implement the intergovernmental agreement (IGA) between India and… – Continue reading

UK Revenue & Customs ‘winding down’ inquiries into HSBC Swiss tax evaders

After reopening investigation into HSBC clients hiding money in Switzerland, HMRC admits it has still only prosecuted one tax cheat, reports The Guardian. HM Revenue and Customs (HMRC) is winding down its inquiries into hundreds of British customers who used HSBC’s Swiss bank to evade tax, a senior official has… – Continue reading

TIGTA report recommends improvements to verify taxpayer claims for social security tax exemption under Totalization Agreements

In a July 17, 2015 report released today, the Treasury Inspector General for Tax Administration (TIGTA) recommended that the IRS coordinate with the Social Security Administration to identify U.S. citizens and resident aliens working in a foreign country and resident aliens working in the United States who may have improperly… – Continue reading

Valiant Bank AG Reaches Resolution Under US Justice Department’s Swiss Bank

The Department of Justice announced today that Valiant Bank AG has reached a resolution under the department’s Swiss Bank Program. “Offshore enforcement remains a top priority of the department, and banks seeking to avoid prosecution pursuant to the terms of the Swiss Bank Program continue to accept responsibility, provide a… – Continue reading

RBS sells corporate loan commitments portfolio

LONDON–Royal Bank of Scotland Group PLC (RBS.LN) has sold a portfolio of corporate-loan commitments related to its banking business in China for 498 million pounds ($755.1 million), as part of the bank’s strategy to focus mainly on U.K. and European customers. RBS said it has reached an agreement with China… – Continue reading

Underground Economics Korea’s Underground Economy Places 6th among OECD Member Countries

Policies are urgently needed for the legalization of the underground economy,” said Representative Oh Je-se of the New Politics Alliance for Democracy, who belongs to the Planning and Financial Committee of the National Assembly on Sept. 10. Rep. Oh added that Korea places sixth among OECD member countries in terms… – Continue reading

Agreement between Mainland China and Taiwan to avoid double taxation on income

On August 25, 2015, the People’s Republic of China and Taiwan signed an Agreement for the Avoidance of Double Taxation regarding Taxes on Income (“the DTA”), which will enter into force when the legal procedures have been completed. The DTA’s highlights: 1. Permanent establishment (“PE”) specifications The DTA establishes a… – Continue reading

Venezuelan President’s Visit to China Indicative of Growing Sino-Latin American Trade and Opportunities

On September 1, Venezuelan President Nicolas Maduro arrived to Beijing in an effort to strengthen economic ties between Venezuela and China. In his second visit this year, the Venezuelan President signed a number of deals that will strengthen cooperation in new areas beyond the current focus on the oil industry…. – Continue reading

The Case For A Territorial Tax Regime For Curaçao

Recently the Curaçao Minister of Justice, Mr. Nelson Navarro, approved the so-called Investor’s Permit to accommodate bonafide high net worth persons and entrepreneurs who seek admission to Curaçao. The purpose of the Investor’s Permit is for the investor to provide real economic benefit to Curaçao by increasing employment opportunities and… – Continue reading

Sebi asks market entities to follow I-T Department norms for FATCA

NEW DELHI: To ensure compliance with FATCA — the new US law to check offshore tax evasion — regulator Sebi today asked all market intermediaries to follow reporting requirements prescribed by Income Tax Department in this regard. Under Foreign Account Tax Compliance Act (FATCA), foreign financial institutions that fail to… – Continue reading

Malaysia Resolving International Tax Disputes

Introduction Shaped three decades ago by the then Prime Minister, Tun Dr. Mahathir bin Mohamad, Vision 2020 outlined Malaysia’s goals in becoming a fully developed nation. With the country’s move towards achieving this ‘Malaysian dream’, more Malaysian companies are venturing and investing outside of Malaysia. The increase in trade transactions… – Continue reading