Management and procurement services not taxable as “fees for technical services” under the India-UK income tax treaty: India’s Authority for Advance Rulings concluded that services rendered by a group director to its group company in India were “managerial services” that, as rendered by the UK procurement team, did not make… – Continue reading
The Treasury Department today updated its FATCA webpage to report the signing of an intergovernmental agreement (IGA) between the United States and St. Vincent and the Grenadines The IGA [PDF 278 KB] signed between the United States and St. Vincent and the Grenadines is dated as having been signed on… – Continue reading
On August 21, 2015 the Government of Liechtenstein issued a press release announcing that the Austrian Minister of Finance (Hans Jörg Schelling) has invited his German (Wolfang Schäuble), Swiss (Eveline Widmer-Schlumpf), Luxembourg (Pierre Gramegna) and Liechtenstein (Adrian Hasler) counterparts for the annual meeting of Ministers of Finance of the German… – Continue reading
Amit Ramnani, director of Ipanema Wealth, an independent financial consultancy firm, discusses the key issues facing U.S. expatriates. RIO DE JANEIRO, BRAZIL – Many United States citizens living overseas are unaware of the potential tax liabilities they could be facing in near future. To help out the Rio-based firm Ipanema… – Continue reading
Industry lobby groups are calling on lawmakers to bolster business innovation as they debate corporate tax reforms aimed at retaining Switzerland’s status as a location for multinationals, reports Swiss Info. Parliament is currently looking at a government recommendation to replace Switzerland’s current, and controversial, cantonal corporate tax system – that… – Continue reading
The governments of emerging Asian economies need to look at new revenue streams to make their economies more competitive and boost living standards, the OECD said in a new report, reports Tax News. The report, Revenue Statistics in Asian Countries: Trends in Indonesia, Malaysia, and the Philippines, notes these countries’… – Continue reading
Banks overseas, spooked by India’s stringent new black money law, are asking tough questions of people and entities from the country looking to open accounts with them, reports the Economic Times. That’s because it’s not just those who possess unaccounted wealth who will get punished, those found guilty of helping… – Continue reading
American residents or nationals, citizens and green card holders – persons of interest – living in Jamaica are required to file US tax returns and must, by voluntary disclosure, fill out a form to disclose ‘foreign assets’. The filing of a Foreign Bank and Financial Accounts Report (FBAR) is an… – Continue reading
Aug. 19 — Tax authorities and practitioners around the world are awaiting a Canadian court’s ruling on the legality of Canada’s legislation to comply with the Foreign Account Tax Compliance Act. The Federal Court of Canada is due to issue by Sept. 30 a ruling on the validity of the… – Continue reading
South African companies who do direct and indirect business with US organisations, whether in South Africa, Africa, Europe or further afield, must comply with the United States Foreign Account Tax and Compliance Act (FATCA,) or risk being excluded from lucrative markets the world over, reports the Cape Business News. This… – Continue reading
The FINANCIAL — The Ukrainian Grain Association appealed to Natalie Jaresko, Minister of Finance of Ukraine, with a proposal to create the special working group to solve the existing problems of grain exports, declared the press-service of the Association on August 13. According to the announcement, to date there are… – Continue reading
The Australian Senate inquiry into tax avoidance has released its interim report, which makes 17 recommendations, including the introduction of a mandatory tax reporting code. The Senate Inquiry into Corporate Tax Avoidance was referred to the Economics References Committee in October 2014. The first hearing was conducted in April 2015,… – Continue reading
Many have, mistakenly, confused the prime minister (PM)’s recent remark that Rs 6,500 crore had been disclosed by holders of hitherto unaccounted money with disclosures under the compliance window in the recent law on the subject. However, this money has nothing to do with the latter’s three-month window. These came… – Continue reading
Given the current focus on tax transparency and reporting, and the government’s consultation document with proposals to introduce a legislative requirement for large businesses to publish their tax strategy as it relates to or affects UK taxation, UK companies need to consider establishing a process for determining what content can,… – Continue reading
Introduction Individuals whose domicile of origin is outside United Kingdom Non-UK individuals with UK domicile of origin Consultation and legislation New inheritance tax rules for UK residential property held within offshore corporate envelopes Comment Introduction Individuals domiciled outside the United Kingdom might have been justified in thinking that they would… – Continue reading
Key developments Taxpayer bears onus of proving taxable income in Court – 11 August 2015 Rigoli v FC and T Background The Commissioner issued default assessments to the taxpayer in respect of the 1994 – 2001 income years, based on income estimates drawn from an expert report. The taxpayer initially… – Continue reading
ISLAMABAD: In a bid to persuade legislators to withdraw their opposition, the government on Wednesday hinted at reviewing the Rs10 million limit that it proposed for treating tax evasion as an offence under Anti-Money Laundering Act. The government showed this flexibility during a meeting of Senate Standing Committee on Finance and… – Continue reading
19/08/2015 – Increasing tax revenues and ensuring sustainable domestic resource mobilisation will be critical as emerging Asian economies seek to boost the provision of public goods and services and improve economic growth and living standards. Revenue Statistics in Asian Countries: Trends in Indonesia, Malaysia and the Philippines shows that the… – Continue reading
The IRS on 12 August 2015 released a revenue procedure—Rev. Proc. 2015-41—providing guidance and updated procedures regarding advance pricing agreements (APAs). Rev. Proc. 2015-41 addresses the process of how to request and obtain an APA from the IRS’s Advance Pricing and Mutual Agreement (APMA) program and with respect to the… – Continue reading
On August 17th, 2015, Ruling No. 1,580/2015 was published, containing amendments to Ruling No. 1,571/2015 concerning the “e-Financeira”, which is the tax return to be filed for the purpose of informing financial transactions of interest to the Federal Revenue Office. The deadline for filing the e-Financeira, in relation to triggering… – Continue reading
HM REVENUE & CUSTOMS has published a factsheet illustrating the overhaul of the way dividends are to be taxed from 2016. The move, announced in July’s Summer Budget, wipes out the tax advantage of taking payment as a dividend. The tax credit applied to dividends is to be replaced with… – Continue reading
The IRS on 12 August 2015 released Rev. Proc. 2015-40 with respect to requesting competent authority (CA) assistance, and it is generally effective for CA requests filed on or after 30 October 2015. Rev. Proc. 2015-40 updates and supersedes Rev. Proc. 2006-54. The IRS concurrently released Rev. Proc. 2015-41 as… – Continue reading
In late July 2015, Treasury provided an initial notification of “more favorable terms” concerning “certain alternative procedures” under the Model 1 IGA. This notification has been updated, 18 August 2015. Read the updated Treasury notification [PDF 70 KB]
PwC’s views on the Government’s discussion document seeking feedback on proposals for GST and offshore online purchases Following on from the much anticipated Government’s discussion document seeking feedback on proposals for the collection of GST on online purchases of services and intangibles this morning, we are pleased to share our… – Continue reading
FATCA was enacted into law by section 501(a) of the Hiring Incentives to Restore Employments (HIRE) Act 2010 as a revenue offset to help pay for the continuation of unemployment benefits for workers laid off during the 2008-2010 financial crisis. In July 2008, the U.S. Senate Permanent Subcommittee on Investigations… – Continue reading
The Cayman Islands is confident that the pan-European marketing ‘passport’ will be extended to alternative investment funds (AIFs) set up in the jurisdiction, according to the Alternative Investment Management Association (AIMA). Cayman, where a high percentage of offshore hedge funds are registered, still awaits assessment by the European Securities and… – Continue reading
THE START OF THE implementation of the Foreign Account Tax Compliant Act on July 1, 2014, combined with the Organisation for Economic Cooperation and Development’s (OECD) adoption of the common reporting standard, the support by the European Union of the automatic exchange of information (AEI), and the strong support by… – Continue reading
IN THE LAST TEN YEARS the international community has tried to pressure Barbados into signing tax information exchange agreements. Successive administrations, however, have resisted by continuing to show preference for double taxation treaties. That has not stopped the pressure, and some would argue that in some ways the global players… – Continue reading
Due to a little-noticed provision in the new highway appropriations bill signed into law on July 31 – the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 – the deadline for filing an FBAR (Report of Financial Bank and Financial Accounts) has been moved up from June… – Continue reading
(CS) German financial institution HSH Nordbank reportedly reached a 22-million-euro settlement with prosecutors in Cologne over setting up offshore companies through Luxembourg to hide client assets from tax authorities. Newspaper “Süddeutsche Zeitung” and broadcasters NDR and WDR first reported on the deal on Tuesday. Allegedly, HSH Nordbank approached the prosecutor’s… – Continue reading
Subsidiaries in Luxembourg of food group had no staff and assets at year’s end of €1.3bn In its 2014 accounts Glanbia Luxfin, a subsidiary of Irish food group Glanbia, reported profits of $14.2 million and tax of $4,175, while Glanbia Luxinvest reported profits of €2.9 million and tax of €38,863…. – Continue reading
The queue of tax disputes awaiting litigation through the UK’s tax tribunals set a new record last year, with almost 30,000 cases waiting to be heard at the end of last year, according to official figures. The number of outstanding appeals by taxpayers to the first-tier tribunal increased by 8.5%… – Continue reading
Anyone with undisclosed overseas income, gains or assets will be wise to make use of the Liechtenstein Disclosure Facility while it lasts, according to tax experts at Baker Tilly, reports FT Adviser. Andrew Hubbard, a partner at the firm, warned advisers that everything he has heard has led him to… – Continue reading
Turkmen parliament ratified the country’s convention with South Korea on double taxation avoidance and prevention of fiscal evasion with respect to income taxes, the Turkmen government said August 19. Aside from that, according to the government message, the parliament ratified the country’s convention with Austria on avoidance of double taxation… – Continue reading
On 1 April 2015 Cyprus and South Africa signed a Protocol amending their existing double taxation agreement (“DTA”), which was signed in 1997 and has been in force since 8 December 1998. The Protocol amends the 1997 DTA in three areas, namely the definition of residence, withholding taxes on dividends… – Continue reading
South Africans with undisclosed offshore accounts may feel exposed after their offshore Swiss bank account information found its way into the public domain this year. The theft of information relating to some 30 000 HSBC accounts – the biggest banking leak in history – actually took place five years ago… – Continue reading
International finance centers play a significant role in Russian foreign direct investment (FDI). For example, in 2012 it was observed that 11 of the 40 main recipients of Russian FDI were IFCs. Of these finance centers, the largest recipients were the BVI, the Cayman Islands and Cyprus. Despite the popularity… – Continue reading
In May of 2012, and soon before Facebook’s IPO, Eduardo Saverin renounced his U.S. citizenship. Saverin was a co-founder of the social-networking site, and the consensus was that he gave up his citizenship to avoid U.S. taxes that would be levied after the offering. Saverin was widely denounced for his… – Continue reading
In its Resolution of March 25, 2015, on the Annual Tax Report (2014/2114(INI)), the European Parliament renewed its commitment to combating tax havens and tax avoidance. To be sure, most aspects of the resolution have been discussed before. Bundling these aspects into one comprehensive package, however, provides an intriguing snapshot… – Continue reading
Whatever one thinks of Europe’s ruling class, one thing is undeniable: it has chutzpah. Like a gambler who has lost his savings on roulette and decides to bet his house in hope that his luck will turn, the EU leadership is upping the ante in the destructive pursuit of an… – Continue reading
Singapore-based wealth managers, already under pressure from a global move towards tax information sharing, face a more immediate threat as Asian countries including Indonesia and India look to chase undeclared money in the low-tax city state. A global crackdown on tax evasion launched during the 2008 financial crisis has already… – Continue reading
The Singapore Shipping Association (SSA) is pushing for the city-state to have more double taxation agreements. Speaking at a media briefing on Tuesday, Rene Pedersen, chairman of the SSA International Committee said, “Singapore today has some 65 double taxation agreements and that’s actually not a lot.” By comparison the UK… – Continue reading
Taipei, Aug. 18 (CNA) Chinese yuan-denominated deposits held by banks operating in Taiwan were lower at the end of July from a month earlier on rising awareness of the downside risks in China’s economy, according to analysts. Analysts said recent volatility in share prices in China’s equity markets and interest… – Continue reading
Financial Services Minister Hope Strachan said yesterday that the landscape of the country’s financial services industry would be strengthened as a result of the nation’s compliance with the tax information exchange agreements such as the US Foreign Account Tax Compliance Act (FATCA), saying that she was fairly satisfied that The… – Continue reading
The Finance Ministry of Ukraine has proposed that the limit for transactions subject to control under transfer pricing rules should removed and will provide a simulation in the short presentation on tax reform that will be prepared by September. The ministry also proposed that the upper limit of fines for… – Continue reading
With the objective of long-term sustenance of wealth created both inside as well as outside India and continuous revenue generation, high net-worth individuals (HNIs) in India have decrypted and adopted innovative methods for asset protection and estate planning. The latest addition to the existing gamut of methods are offshore investments… – Continue reading
Recently, there’s been a lot of news about the difficulties that 2 banks in Belize have been having after their correspondent banking relationship was severed by the Bank of America. The Prime Minister has commented that it’s a situation that is lamentable, but inevitable. Not surprisingly, Opposition Leader Francis Fonseca… – Continue reading
Tax Commissioner Pierre Moscovici has confirmed that the European Commission has no plans, formal or informal, to harmonize corporation tax rates across the European Union. In a written question to the Commission, Jonathan Arnott, a UK Member of the European Parliament, asked the Commission to confirm its latest position on… – Continue reading
Commercial banks have been facilitating tax evasion for choice clients by misusing their inter-bank tax-free facilities and have cleared billions of rupees in July without deducing the 0.3% withholding tax. According to sources in the Federal Board of Revenue (FBR) and commercial banks, these banks have misused the mechanism of… – Continue reading
Questions over tax — hotly denied — feature in a row centring on one of the capital’s biggest art collectors One of London’s wealthiest but most secretive families is locked in a bitter feud over the ownership of its empire, which spans high-end London properties to African tobacco-trading businesses. A… – Continue reading
