Category: Jurisdiction

Georgia – United States

FATCA Agreement Signed On 10 July 2015, Georgia and the United States signed a Foreign Account Tax Compliance Act (FATCA) Agreement. FATCA seeks to obtain information on accounts held by U.S. taxpayers in other countries. It requires U.S. financial institutions to withhold a portion of certain payments made to Foreign… – Continue reading

UAE: FATCA Reporting Deadline Set

The Ministry of Finance of the United Arab Emirates (UAE) announced that the Foreign Account Tax Compliance Act (FATCA) reporting deadline is set on 30 July 2015. In addition, on 6 July 2015, the Ministry of Finance issued the first set of guidance notes for implementing the FATCA Agreement. The… – Continue reading

HMRC update QROPS list

HMRC has published the latest Qualifying Recognised Overseas Pension Scheme (QROPS) List following the recent suspension of the list, iExpats reports. In the two week suspension, 3,037 schemes and seven financial centres have been delisted. Although HM Revenue & Customs (HMRC) refuses to discuss individual QROPS, the main reason for… – Continue reading

World can end AIDS epidemic by 2030, finance conference hears

The world can end the AIDS epidemic by 2030, the United Nations said on Tuesday, highlighting global success in rolling out life-saving drugs over the last 15 years. The UN Millennium Development Goal to halt and reverse the spread of the disease has been achieved, said UNAIDS, the global body’s… – Continue reading

Don McKinnon: China will be listening to our housing debate

New Zealand China Council chairman Sir Don McKinnon says we need to have a national debate on housing that avoids sending mixed messages to valued overseas partners. New Zealand is far from alone in having a red hot property market. Headlines in Australia, Britain and Canada paint a strikingly similar… – Continue reading

Big changes to India-Mauritius DTAA?

Mauritius’ former finance minister claims that his country has given up the right to tax capital gains. This has raised questions regarding the scope of the renegotiation of the India-Mauritius Double Tax Avoidance Treaty (DTAA) Former finance minister of Mauritius says renegotiated tax treaty with India will have devastating effect… – Continue reading

Alex Malley: Key goes in to bat for imputation credits

The Government’s submission to the “Re:think” tax white paper process under way in Australia highlights the lack of mutual recognition of imputation credits as the most significant barrier to a seamless transtasman market and calls for visionary political leadership. Prime Minister John Key displays the very leadership he’s calling for,… – Continue reading

Syz Buys Royal Bank of Canada Swiss Unit as Foreigners Exit

Banque Syz SA of Geneva is buying Royal Bank of Canada’s Swiss private bank as foreign financial firms retreat from Switzerland amid higher regulatory costs. The business, based in Geneva, had 10 billion Swiss francs ($10.5 billion) of client assets under management at the end of October, Royal Bank said… – Continue reading

Unicredit’s German unit in talks to strike tax deal with authorities – sources

HypoVereinsbank, the German arm of Italy’s UniCredit, is in talks with German prosecutors to pay a fine to put two tax probes behind it, two people familiar with the matter said. HypoVereinsbank and the Cologne prosecutors declined to comment on the development, which was first reported by German daily Sueddeutsche… – Continue reading

Aggressive “tax avoidance” must not cost Worcestershire’s taxpayers, vows councillor

CALLS are being made to change the rules at Worcestershire County Council to prevent any companies from taking advantage of “aggressive tax avoidance” to rip off taxpayers. Councillor Richard Udall wants bosses at County Hall to review the guidelines when allowing firms to bid for work such as office supplies,… – Continue reading

Recent IRS policy shift requires taxpayers to reevaluate decisions made as to previously undisclosed offshore accounts and assets

The US voluntary disclosure landscape has changed dramatically over the last 12 months. As a result, the options to voluntarily disclose previously unreported offshore accounts and assets have evolved to allow unprecedented relief for a broader group of US taxpayers. This is particularly true for those whose mistakes were inadvertent,… – Continue reading

Double taxation in the AEC and tax credits in Thailand

The long-awaited formation of the Asean Economic Community (AEC) is just over five months away. Drawn by the promise of a freer flow of goods, services, investment, capital and skilled labour, many businesses need to study how to prevent or reduce the effects of double taxation. Double taxation results from… – Continue reading

Deutsche Bank ‘faces money laundering probe’

US authorities are investigating German banking giant Deutsche Bank over alleged money laundering in Russia, people familiar with the matter said Monday. The investigation centers on billions of dollars’ worth of transactions carried out by Deutsche Bank in Russia that New York state regulators believe may have been used to… – Continue reading

Your Taxes: The draft transparency law

A draft amendment to the Income Tax Ordinance and the Prohibition on Money Laundering Law regarding Israel joining international tax information-sharing agreements. The Israel Tax Authority (ITA) has just circulated a draft amendment to the Income Tax Ordinance and the Prohibition on Money Laundering Law regarding Israel joining international tax… – Continue reading

‘Google tax’ – a step into the unknown

Special Business News article by Rob Rotherham, KPMG tax division senior manager, on the effects of the UK Budget. With effect from April 1, 2015, the UK Government introduced a new tax: the Diverted Profits Tax. (DPT). The DPT is aimed at countering the use of aggressive tax planning techniques… – Continue reading

Bloomberg BNA and Baker & McKenzie Global Transfer Pricing Conference Comes to Shanghai September 17-18, 2015

ARLINGTON, Va., July 14, 2015 /PRNewswire/ — Bloomberg BNA today announced the latest event in its Global Transfer Pricing Conference series with Baker & McKenzie, in association with the Tax Management Educational Institute, to be held September 17-18, 2015 in Shanghai, China. The conference provides an opportunity to hear from… – Continue reading

Worldwide: Privacy: What’s Left?

A seismic change in the international private wealth arena is under way. Over 90 jurisdictions have committed to automatically exchange comprehensive financial information on an annual basis under the OECD’s Common Reporting Standard (CRS). The CRS will start in 2016 in over 55 jurisdictions. This article comments on the CRS… – Continue reading

Ireland’s sweetheart tax deals under threat as EU investigates

European Commission to issue decisions on four test cases, including Apple in Ireland, Until a few months ago, the medieval town of Athenry in County Galway owed its fame mainly to a song. Irish rugby and football fans often burst into stirring renditions of “The Fields of Athenry”, a ballad… – Continue reading

Congress Wants to Reward Corporate Tax Dodgers with Lower Taxes

It’s well-documented that profitable Fortune 500 companies are stashing profits offshore to the tune of at least $2.1 trillion and avoiding as much as $550 billion in U.S. taxes. But instead of taking steps to halt this brazen tax dodging, lawmakers have floated various misguided “reform” proposals that would actually… – Continue reading

His Majesty issues two Royal Decrees

Muscat: His Majesty Sultan Qaboos Bin Said today issued two Royal Decrees as follows: Royal Decree No. 30/2015 establishes Oman Governance and Sustainability Centre and promulgates its bylaw. Article (1) states that a centre to be named “Oman Governance and Sustainability Centre” shall be set up and affiliated to the… – Continue reading

Vietnam: FIRST EVER Double Taxation Agreement Signed Between Vietnam And The United States Of America

On 07th July 2015, the United States and Vietnam signed an income tax treaty with Vietnam, the first ever between the two countries. The Double Taxation Agreement applies to personal income tax and enterprise income tax in the case of Vietnam. What is a permanent establishment? Under the Double Taxation… – Continue reading

Jaresko: Ukraine, Cyprus agree to revise taxation agreement

Ukraine and Cyprus have agreed to review bilateral agreements on taxation to prevent the withdrawal of capital to offshore zones, Finance Minister Natalie Jaresko wrote on Facebook. “After very lengthy negotiations, we’ve finally taken an important step in the fight against capital withdrawal to offshore zones: we have with the… – Continue reading

Seventh Circuit upholds non-incarceration sentence for Beanie Baby creator

On Friday, the Seventh Circuit upheld what it determined to be a substantively reasonable sentence for billionaire Ty Warner, the creator of Beanie Babies. We previously blogged about Warner’s district court sentencing, during which Judge Kocoras found that Warner’s “very unique” circumstances warranted a non-incarceration sentence – well below the… – Continue reading

Lisbon treaty: Technical briefing with NDR

Portugal is an increasingly desirable destination, thanks to its tax-friendly stance. Portugal may not be top of everyone’s list in terms of tax-friendliness, particularly given the recent backdrop of the recession and bail-out, but it does have a history of running successful tax-friendly programmes, for example the Madeira and Azores… – Continue reading

Canada’s anti-terrorism laws and taxes – what’s the connection?

The short answer to the question of the connection between Canada’s new anti-terrorism laws and taxes is that recent amendments to the Income Tax and Excise Tax Acts which arise through the Anti-Terrorism Act permit more extensive disclosure and sharing of private and confidential taxpayer information. The longer answer is… – Continue reading

Offshore Perspectives: News Update – Globally Combating Tax Evasion

TWO NEW SWISS BANKS REACH JUSTICE AGREEMENT On June 19th, 2015, the Department of Justice (DOJ) came to an agreement under the Swiss Bank Program with two new Swiss banks, Bank Linth LLB AG and Bank Sparhafen Zurich AG. BANK LINTH 126 U.S.-related accounts are attributed to Bank Linth Bank… – Continue reading

Cabinet approves co­op agreements with several countries

KUWAIT, July 13 (KUNA) ¬¬ The cabinet, under the chairmanship of His Highness the Prime Minister Sheikh Jaber Al¬Mubarak Al¬Hamad Al¬Sabah, approved Monday a number of agreements to boost cooperation with several friendly countries. The endorsed agreements included a memorandum of understanding for cooperation in social insurance with Bahraini government,… – Continue reading

Key pillar of the Beps process is to align profit with value creation

OECD guidance needs to be clear otherwise the process could favour the bigger nations In Paris last week, as Angela Merkel and Francois Hollande discussed events in Greece, the international tax system was being discussed in an underground meeting room at OECD headquarters. For almost two days tax authority delegates… – Continue reading

Dirty Dealing: China and International Money Laundering

In the midst of turmoil in the Chinese stock markets, one serious problem that may appear is increased currency outflows created by current and potential investors who would rather move their assets to foreign countries viewed as safer havens. Money laundering should be under close surveillance. Chinese involvement in money… – Continue reading

Ingenious, HSBC, UBS and Coutts sued by ‘tax avoidance’ clients

Private client banks such as Royal Bank of Scotland’s Coutts, HSBC and UBS have been sued by clients for wrongly advising them to invest in film investment specialist Ingenious as its schemes have since been labelled by tax authorities as tax-avoidance vehicles. Ingenious Media and around 50 other associated financial… – Continue reading

Normative Ruling RFB No. 1,571/2015: creation of the Electronic Financial Return (“e-Financeira”)

Normative Ruling RFB No. 1,571/2015, which institutes the Electronic Financial Return, the so-called “e-Financeira”, was published on July 3rd, 2015. The e-Financeira is a statement, transmitted electronically to the Public Digital Bookkeeping System (“SPED”), compulsory for insurance companies and legal entities with activities relating to (i) structuring and selling private… – Continue reading

India: recent developments regarding Minimum Alternate Tax

Over the past few months, several foreign portfolio investors registered in India have received notices from the Indian tax authorities demanding payment of Minimum Alternate Tax in respect of transactions which took place over the course of prior assessment years. The Indian Government has indicated that it could raise several… – Continue reading

China developers head home, but offshore bonds set to hedge political ris

HONG KONG, July 13 (IFR) – Chinese property developers are wary about relying too heavily on onshore funding, even after regaining access to the cheaper domestic bond market. Evergrande Real Estate and Longfor Properties last week became the latest Chinese developers to cut their interest costs through the issuance of… – Continue reading