Category: Jurisdiction

Liechtenstein Disclosure Facility To Close In December

The UK and Liechtenstein have published a Joint Declaration that provides for the early closure of the Liechtenstein Disclosure Facility. The UK’s March 2015 Budget brought forward the final date for registration to participate in the LDF from April 2016 to December 31, 2015. The Joint Declaration, signed this month,… – Continue reading

EDF hit with £1bn tax bill

EDF is now an global player in providing electricity, relying on France’s 58 nuclear reactors, as well as developing new plants, notably the controversial Hinkley Point project in Britain. The European Commission’s investigation found the energy company, which is the main electricity provider in France, benefited from tax breaks that… – Continue reading

Lawsuit by U.S. Presidential Candidate Challenges the Constitutionality of FATCA

Senator Rand Paul, R-Ky., along with six current and former U.S. citizens living abroad, filed a lawsuit, July 14, in the U.S. District Court for the Southern District of Ohio challenging the constitutionality of the Foreign Account Tax Compliance Act (FATCA) and foreign bank account reporting (FBAR) regime. “FATCA eschews… – Continue reading

Dealing with FATCA and other problems

A business partnership claims to have successfully deployed a secure online reporting system for financial institutions grappling with the headache of FATCA and Common Reporting Standard (CRS) reporting requirements. Developed by Webtech Limited in conjunction with corporate service provider SMP Partners, the ‘solution’ is said to be designed by users… – Continue reading

The intersection of US tax treaty policy, tax reform and BEPS

Introduction US tax treaty policy can be affected by pressures for tax reform from within the United States and by major developments in international taxation from without. Talk of US tax reform has been widespread for years, although it is sometimes hard to gauge how much of the talk is… – Continue reading

HMRC Consults On Stronger Anti-Avoidance Sanctions

HM Revenue and Customs (HMRC) has published details of proposals to strengthen sanctions against serial promoters and users of tax avoidance schemes, and introduce specific penalties where the General Anti-Abuse Rule (GAAR) applies. The plans are set out in a new HMRC consultation, which explains how each of the measures… – Continue reading

Loeb Faulted for ‘Unconscionable’ Tax Scheme by Teachers

Hedge fund manager Daniel Loeb was singled out for criticism by labor leaders who are urging the U.S. to limit investors’ ability to lower tax obligations through offshore reinsurance ventures. “When just one hedge fund takes advantage of this loophole, it means hundreds of millions of dollars are lost that… – Continue reading

U.S. Tax Avoidance Trumps Greek Tax Evasion

Blatant corporate and personal tax evasion contributed to Greece’s debt crisis, but it’s dwarfed by the tax avoidance of U.S. multinationals operating in countries like Australia. There’s a popular misconception that Greece’s debt crisis was self-inflicted. ‘The Greeks are a bunch of tax evaders! They should never have been allowed… – Continue reading

More transparency over UK prime property ownership needed to prevent fraud, campaigners say

Plans to create a public registry of the real owners of UK companies should be extended to make it clear who is behind the companies that own high-value London properties, Global Witness has said. Plans to create a public registry of the real owners of UK companies should be extended… – Continue reading

New call for prime London agents to be more transparent

A pressure group is calling for estate agents to conduct additional checks to ensure the legal provenance of buyers’ funds, and wants all on- and off-shore companies owning UK property to be obliged to tell the Land Registry the identify of their beneficial owners. Global Witness – a group campaigning… – Continue reading

Sebi busts billion-dollar ‘tax evasion shops’ in stock market

MUMBAI: Suspecting tax evasion of at least Rs 5,000-6,000 crore, regulator Sebi has clamped down on a large number of organised syndicates who had set up ‘shops’ to convert black money into legitimate-looking funds through the stock market platform. While more than 900 entities have been banned from capital markets… – Continue reading

Khalifa ratifies UAE agreements

ABU DHABI: President His Highness Sheikh Khalifa Bin Zayed Al Nahyan has issued a number of federal decrees with respect to ratifying agreements between the UAE and a number of friendly countries and transferring, appointing and promoting a group of diplomatic corps members. The decrees have been published in the… – Continue reading

S’pore’s AUM industry registers strong growth of 30% to S$2.36t in 2014

SINGAPORE – Singapore’s asset management industry grew strongly last year, with more sovereign wealth funds setting up shop here. Assets under management (AUM) rose 30 per cent to S$2.36 trillion in 2014 from S$1.82 trillion in 2013, said the Monetary Authority of Singapore’s (MAS) annual report 2014/15 released on Tuesday…. – Continue reading

Bank of Communications says to issue $2.45 bln offshore preference shares

Bank of Communications Co Ltd , China’s fifth largest commercial bank based on total assets, said it would issue $2.45 billion offshore preference shares to third party investors, to replenish capital and enhance competitiveness. The proposed issue of 5.00 percent non-cumulative perpetual offshore preference shares will also drive transformation of… – Continue reading

Linkage Between Tax Transparency and Information Critical for Sustainable Development

The link between global tax transparency and domestic resource mobilization was a key issue discussed at the sidelines of the Financing for Development conference. The side event, jointly organised by the Organisation for Economic Cooperation and Development (OECD) and UN-DESA,was attended by President of the African Development Bank, Donald Kaberuka,… – Continue reading

Japan and the UK exchange notes concerning article 7 (“business profits”) of the Japan-UK Tax Convention

On July 23, 2015 the Japanese Ministry of Finance issued a press release announcing that on July 22, 2015 the Government of Japan and the Government of the United Kingdom exchanged notes concerning Article 7 of the Convention between Japan and the United Kingdom of Great Britain and Northern Ireland… – Continue reading

Two more Swiss banks strike deals with US over tax evasion

WASHINGTON — Two more Swiss banks will pay penalties to the United States as part of settlements that mean they will not face criminal charges for helping Americans avoid taxes, US authorities said on Thursday. SB Saanen Bank AG will pay nearly $1.4m and Privatbank Bellerive AG will pay $57,000,… – Continue reading

New Scotland bill – tax implications

The UK Government has published draft legislation on devolving certain tax matters to Scotland (the Bill). It intends that the draft legislation should implement the terms of the devolution agreement made in November 2014 between the Westminster and Holyrood governments. Having looked over the Bill, it appears that the Scottish… – Continue reading

Crown Dependency disclosure facilities seen underused

Crown Dependency disclosure facilities set up to offer individuals the opportunity to disclose any overdue payments or irregularities have yielded “surprisingly” low returns for HMRC, according to Pinsent Masons. The international law firm said just £13.9m ($21.6m, €19.7m) has been collected since the facilities opened in April 2013, with £5.6m… – Continue reading

FATCA Takes Effect Next Month

Effective August 17, financial institutions in Jamaica will be required to transmit relevant financial information to Tax Administration Jamaica (TAJ) – the competent authority – on persons who reside permanently in the United States (US) or persons who earn a substantial amount of their income from or within the United… – Continue reading

Dictators and Billionaires Demand Creation of UN Tax Agency

As globalist forces and the international institutions they control openly prepare to plunder humanity’s wealth, Third World dictators and tax-funded “civil society” groups have stepped up their demands for a United Nations tax authority — supposedly to ensure that they all get their “fair share” of the loot from Western… – Continue reading

Cambodia’s Gaming Tax Revenues Surge

Revenues from Cambodia’s gambling taxes increased by 20 percent in the first six months of the year compared with the same period in 2014, thanks partly to players flocking to the country from neighboring Thailand. According to The Cambodian Daily, which cited a finance ministry official, gambling tax revenues reached… – Continue reading

Cayman Islands: Navigating The Complexities Of International Tax Compliance

Introduction Recently, the Cayman Islands Department of International Tax Compliance (DITC) notified financial institutions that in October 2015 it will be introducing local regulations to implement the OECD’s Common Reporting Standard (CRS), also commonly referred to as global FATCA or GATCA. That notice also served as a reminder that international… – Continue reading

Why you should voluntarily disclose offshore investments

In recent years, the popularity of the Canada Revenue Agency’s voluntary disclosures program – which enables taxpayers to correct any mistakes or omissions in their previous tax filings – has ballooned. When taxpayers come forward, their tax problems get solved, the CRA reduces the accrued interest and, most important, waives… – Continue reading

Austria – Tax legislative changes, effective January 2016

July 22: Tax legislative changes in Austria were passed by the parliament, and the effective date for most changes is 1 January 2016. Among the provisions are the following items. Withholding tax on dividend distributions, capital gains The withholding tax rate for dividends and capital gains will be increased to… – Continue reading

As Apple’s offshore cash pile reaches $190B, US Congress moves closer to multinational tax reform

Apple, Google, and other major U.S.-based multinationals may soon be able to bring more of their foreign-earned income back to American shores without facing a huge tax burden, as lawmakers are moving forward on a tax reform framework that could eliminate taxes on international earnings and authorize a one-time repatriation… – Continue reading

Ireland – Updated FAQs for FATCA, CRS

July 22: The Irish Revenue Commissioners updated a list of “frequently asked questions” (FAQs) concerning FATCA reporting obligations of Irish reporting financial institutions. A list of FAQs concerning the Common Reporting Standard (CRS) was also released. Read the FATCA and CRS FAQs (21 July 2015) from the Irish Revenue Commissioners…. – Continue reading

EU orders France to recover state aid from EDF

BRUSSELS–European Union regulators ordered France to recover 1.37 billion euros ($1.5 billion) in state funds from Electricite de France SA (EDF.FR) after concluding the French electricity supplier had benefited from illegal tax breaks. The decision, which follows an annulment of a similar 2003 decision by the EU’s top court, comes… – Continue reading

Supply chain planning in the post-BEPS era: five questions for MNEs

As governments around the world establish austerity measures to compensate for decreases in tax receipts, a new catch phrase has emerged: double non-taxation. Double non-taxation is the phrase used by governments to denote untaxed or lightly taxed profits that result from effective, legal tax planning techniques. These techniques include application… – Continue reading

Tax amnesty: an opportunity to be seized or a further challenge for business to tackle?

On 8 June 2015, the Law “On optional declaration of assets and bank accounts (deposits) by individuals” (the “Capital or Tax Amnesty Law”) came into force. It was announced as part of the deoffshorisation campaign and opens a window of opportunity for the business community to declare “grey” assets without… – Continue reading

Hong Kong Consults On Cross-Border Cash Controls

As part of its framework of measures on anti-money laundering and the counter-financing of terrorism (AML/CFT), Hong Kong’s Security Bureau has launched a three-month public consultation on the establishment of a reporting system on the physical cross-boundary transportation of large quantities of currency and bearer negotiable instruments (CBNIs). A spokesman… – Continue reading

A proposal to extend beneficial ownership rules to UK land-holding foreign companies

A report published today by Global Witness, alleging that an individual with ties to a former Kazakh public official owns large swathes of London, follows much recent interest in the issue of public officials owning property in the UK via secretive corporate structures that conceal their interest. Earlier this month,… – Continue reading

Call for greater transparency in London property

In a published report, anti-corruption organisation highlights complex structures through which swaths of UK property are owned Global Witness has called for greater transparency around the ownership of UK properties after reviewing alleged links between a former Kazakh secret police chief accused of money laundering and a London property portfolio… – Continue reading