Category: Jurisdiction

Malta: Taking Up Residence In Malta – January 2015

The Maltese climate, culture, history and lifestyle make Malta an attractive place to live in. The fact that this is coupled with a beneficial tax system for people taking up residence in Malta makes Malta an even more desirable location. Introduction to Malta Situated in the middle of the Mediterranean… – Continue reading

CHINA: MANAGING IP TAX CHALLENGES IN BEPS ENVIRONMENT

Multinational enterprises (MNEs) producing or selling their products in China have had to contend with the commercial, legal, and tax challenges of managing how their intellectual property (IP) is used in relation to their Chinese operations. Regulatory approvals for joint ventures operating in China have often required that IP rights… – Continue reading

Five German-speaking finance ministers reaffirm common approach in the field of taxation, banking union and Greece

At their meeting in Salzburg, Pierre Gramegna, Austrian Finance Minister Hans Jörg Schelling, Liechtenstein Prime Minister and Finance Minister Adrian Hasler, the Swiss Finance Minister Eveline Widmer-Schlumpf and Germany’s Finance Minister Wolfgang Schaeuble employed in particular with international tax policy, the fight against tax optimization models overlooking the BEPS Initiative… – Continue reading

Canada: Anti-Avoidance And Intercorporate Dividends: Changes To Section 55 Of The Income Tax Act

The Income Tax Act (ITA) contains many anti-avoidance rules forbidding taxpayers from misusing the provisions of the ITA to achieve tax benefits contrary to Canadian tax policy. The 2015 Federal Budget has proposed changes1 to one of these anti-avoidance rules, which may significantly impact the ability of business owners to… – Continue reading

Beijing reiterates calls to combat underground banking

The Ministry of Public Security has announced a state-wide crackdown on underground banking to block the funnelling of ‘grey funds’ China’s Ministry of Public Security said on Monday that it would launch a three-month crackdown on underground banking to curb money laundering and illegal funds transfers as unstable markets stoke… – Continue reading

UK sets sights on large-scale tax dodgers

The UK is preparing to triple the number of prosecutions of “serious and complex” tax evaders using an arsenal of proposed new powers, reports the Financial Times. A unit combining the civil and criminal investigations teams at HM Revenue & Customs will spearhead a crackdown that George Osborne, the chancellor,… – Continue reading

Hearing Set on Injunction to Stop FATCA Reporting

Aug. 21 — A federal court will hold a hearing Sept. 4 on whether to stop the U.S. from requiring banks in four countries to report information on U.S.-owned accounts under the Foreign Account Tax Compliance Act. As the Sept. 30 deadline for that reporting approaches, the U.S. District Court… – Continue reading

Canada’s dirty money detection system ‘broken all the way through’

Money laundering experts say there is no way for Canadians to know how much dirty money is being laundered in Vancouver real estate through Canadian lawyers. As a Province investigation revealed Monday, Canada’s financial intelligence unit Fintrac has ramped up an audit of Vancouver’s booming property market because of concerns… – Continue reading

Luxembourg performs poorly in anti-money laundering index

In an assessment of money laundering and terrorism financing risks, Luxembourg scored in the bottom half of a ranking of 152 countries carried out by the Basel Institute on Governance, reports the Luxemburger Wort. The institute says that its AML (Anti-Money Laundering) Index is the only such review carried out… – Continue reading

India Seeking To Resolve International Tax Disputes

India will soon settle international tax disputes with close to 120 American companies as well as entities from Japan and other such countries, according to the nation’s Revenue Secretary Shaktikanta Das. Earlier this month, India announced a Framework Agreement under the mutual agreement procedure provision of the India-US tax treaty… – Continue reading

Inniss optimistic about Barbados’ removal from blacklist

MINISTER OF INTERNATIONAL Business, Donville Inniss is optimistic that given Barbados’ and Italy’s continued efforts at strengthening bilateral relations, Barbados could soon be removed from Italy’s blacklist. He made this disclosure this morning during his brief remarks at the end of a signing of a Double Taxation Agreement (DTA) between… – Continue reading

REFILE-Swiss law aims to return foreign funds stashed by erstwhile leaders

Aug 24 (Reuters) – Switzerland expects to adopt a new law by the end of the year that will speed restitution of illicit funds stashed in the Alpine country, where thousands of ‘politically exposed persons’ are believed to hold bank accounts, a top Swiss official said on Monday. Swiss authorities… – Continue reading

Real estate bought with offshore cash raises money laundering concerns

Investigator says Canadian real estate market has developed reputation as a place to launder money A report prepared for Canada’s anti-money laundering watchdog points to offshore cash in the real estate sector as a “significant risk” for criminal wrongdoing. The Financial Transactions and Reports Analysis Centre of Canada, commonly known… – Continue reading

Canada Life’s offshore bond market share hits 29% on L&G deal

Canada Life’s acquisition of Legal & General International has resulted in a combined 29% share of the offshore bond market into the UK. Managing director of Canada Life International, Sean Christian, revealed the figure in an interview with international Adviser while discussing the details of the deal and the opportunities… – Continue reading

HONDURAS MAKES CARLOS SLIM PAY ITS TAX

The multinational companies in Latin America demand security, efficient services, infrastructure and good educational standards, but they are not very willing to contribute themselves by paying their fair share of tax. Honduras is a case in point, and is one of the most unequal countries on the continent. The government,… – Continue reading

Senate economics committee releases interim report on corporate tax avoidance

What has happened? On 2 October 2014 the Senate referred an inquiry into corporate tax avoidance to the Senate Economics References Committee for inquiry and report. The Committee conducted public hearings1 in Sydney, Melbourne and Canberra and received submissions from a number of senior executives from high profile multinational corporations… – Continue reading

Draft regulations could require disclosure of all but the most basic IHT planning, warns law firm Boodle Hatfield

Draft regulations have been published that could see individuals and their tax advisers having to disclose participation in all but the most basic of inheritance tax (IHT) planning. The draft regulations could, says law firm Boodle Hatfield, require even straightforward arrangements to be disclosed, swamping HMRC with information that they… – Continue reading

Uganda: Revenue Authorities Plot an End to Multinational Companies Criminal Tax Activities

Uganda Revenue Authority (URA) has entered into partnership with the continent tax bodies in a move to wipe out illicit financial flows from Africa. A report on illicit financial flows (IFFs) estimates that Uganda loses at least Shs1.5 trillion every year to illegal activities perpetrated by the multinational companies. The… – Continue reading

Cyprus: A fairer tax regime

The Cyprus government recently announced a number of tax incentives aimed at encouraging economic activity and attracting inward direct investment. At the same time it submitted a number of draft laws to the House of Representatives to implement the new provisions of the EU Parent-Subsidiary Directive, to simplify the tax… – Continue reading

Tax Free Profits to Non-Domiciled Investors to Boost Cyprus’ Investment Appeal

Dubai – Cyprus’ recently revised taxation framework make sit the only citizenship-by-investment program in Europe to offer non-domiciled investors tax free profits. Will this new tax regime and business incentives attract more foreign direct investment (FDI) into the country? Henley & Partners, the global leaders in residence and citizenship planning… – Continue reading

Sebi steps up black money fight; busts gains through ‘losses’

MUMBAI: As it steps up its crackdown on tax evasion and laundering of black money through stock markets, regulator Sebi has busted an ‘innovative’ scheme wherein HNIs were incurring ‘bogus losses’ to offset tax liabilities. The probe, which has resulted in an interim ban on 59 entities, including HNIs and… – Continue reading

Bahamas “largely compliant” says OECD Tax Policy Director

The director of the Organization for Economic Co-operation and Development’s (OECD) Centre for Tax Policy and Administration, Pascal Saint-Amans, has praised The Bahamas for its “tremendous progress” in adopting Foreign Account Tax Compliance Act (FATCA) standards and paving the way for automatic exchange of information between the US and The… – Continue reading

British banks’ offshore banking activities ‘the greatest threat to national solvency’

A new paper shows that British banks engaged in more offshore banking than any other financial centre. Researchers examining the resilience of the world’s financial centres after the global economic crisis conclude that the future stability of the UK is perhaps the most uncertain of all. The paper concludes that… – Continue reading

Proposal to make arbitration mandatory under MAP dropped

India opposed the proposal saying it impinges on the sovereign rights of developing countries in taxation New Delhi: An international proposal to make arbitration mandatory and binding under mutual agreement procedures (MAP) in tax treaties has been dropped after India strongly opposed it. Last year, the Organisation for Economic Co-operation… – Continue reading

India moving fast to resolve tax disputes with overseas entities: Revenue Secretary

Hopeful of settling disputes with 120 US companies in next 3 months NEW DELHI, AUG 23: India will, in the next three months, settle tax disputes involving 120 US companies, Revenue Secretary Shaktikanta Das has said. This will be done under the new framework agreement on Mutual Agreement Procedure (MAP)… – Continue reading

Ireland making ‘little or no’ effort to curb corruption – report

Ireland has made “little or no” effort over the past four years to create a corruption-free playing field for global trade, violating its “obligation to combat cross-border bribery”, reports the Irish Times. The Transparency International Exporting Corruption report, released on Thursday, found that Ireland, along with countries such as Russia,… – Continue reading

India approves pact with Seychelles to curb tax evasion, avoidance

To check black money generation, the government today approved signing and ratification of the agreement between India and Seychelles for exchange of information with respect to taxes, reports the Economic Times. The agreement will stimulate the information exchange between India and Seychelles for tax purposes, which will help curb tax… – Continue reading

France: Dividend Withholding Tax Exemption And Specific Anti-Abuse Provision

In a recent decision (CAA Versailles, July 8, 2015, n°13VE01079), the Versailles Administrative Court of Appeals (CAA) provided an interesting illustration of the operation of the specific anti-abuse provision (i.e., different from the general abuse of law theory) attached to the dividend withholding tax exemption provided, in accordance with the… – Continue reading

Preparing for new corporate offence of agents facilitating tax evasion

FOCUS: The UK government plans a new criminal offence for companies and partnerships whose ‘agents’ facilitate the evasion of UK tax. The proposal is to make corporations criminally responsible if they fail to take reasonable steps to prevent their agents from taking actions that facilitate tax evasion. Agents include employees… – Continue reading

Worldwide: Double Tax Treaties – Ratification Update

LUXEMBOURG On September 5, 2014, the Ministers of Finance of France and Luxembourg signed an amendment (Lux Amendment) to the double tax treaty entered into between France and Luxembourg on April 1, 1958, as amended by the 1970 exchange of letters and by the 1970, 2006, and 2009 protocols (FR/Lux… – Continue reading

Tax Transparency In European Union

On 17 June 2015, the European Commission launched a public consultation on further corporate tax transparency, which suggests a variety of tax transparency measures including country-by-country reporting (see here). The consultation is intended to gather feedback on which companies should offer more tax transparency and to whom. The deadline for… – Continue reading

Use of Estonia in U.S. International Tax Planning

According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects this number to reach 1,000 by the year 2020. This makes Estonia the number one start-up technology… – Continue reading