Category: Jurisdiction

Canada: New Bank Of Israel Directive Is Prompting Canadian Taxpayers To Bring Their Tax Affairs In Order

Change to the Procedural Requirements at the Bank of Israel The Bank of Israel has recently implemented measures that are designed to minimize legal and reputational risks for Israeli banks. The Bank of Israel circulated a draft directive for all Israeli banks by virtue of which all foreign (non-Israeli resident)… – Continue reading

Korea faces second ‘investor-state dispute’

Hanocal Holdings, a Dutch subsidiary of the Abu Dhabi-based International Petroleum Investment Company, has filed a lawsuit against the South Korean government through the World Bank’s International Center for Settlement of Investment Disputes. This is the second time that Korea is facing international arbitration under the “investor-state dispute settlement” process…. – Continue reading

Belgium and Russia sign new tax treaty

Belgium and the Russian Federation announced in March 2007 that they would negotiate a new double tax treaty (the “Treaty”). Nearly seven years after discussions began on 20 November 2008, the Treaty was finally signed on 19 May 2015 in Brussels. This newsflash is based on an unofficial version of… – Continue reading

Ukraine: Ukraine Updated A Blacklist Of Tax Havens For Application Of Transfer Pricing Rules On Cross-Border Operations

The Ukrainian legislation for transfer pricing came into force in 2013, with implementation of respective amendments to the Tax Code of Ukraine (“CCU”). However, at present the transfer pricing rules (provided for the CCU) are not applied accurately. In light of the above, in order to clarify the transfer pricing… – Continue reading

Ukraine: Ukraine Updated A Blacklist Of Tax Havens For Application Of Transfer Pricing Rules On Cross-Border Operations

The Ukrainian legislation for transfer pricing came into force in 2013, with implementation of respective amendments to the Tax Code of Ukraine (“CCU”). However, at present the transfer pricing rules (provided for the CCU) are not applied accurately. In light of the above, in order to clarify the transfer pricing… – Continue reading

Diverted Profits Tax: counterbalancing the UK’s “open for business” agenda?

The UK’s introduction of the diverted profits tax (DPT) has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) and in effect as of April 1, the DPT seemed intended to appease public anger at multinationals failing to pay their ”fair… – Continue reading

International tax and withholding considerations for US companies and their directors

To staff their board of directors with the best and most diverse talent, multinational companies commonly elect boards with international representation. It is also common for companies to convene periodic board meetings outside the United States. This may be done, for example, to provide board members with an opportunity to… – Continue reading

FM pledges better tax regime

New Delhi, May 22: The government plans to phase out exemptions and lower the effective tax rates to global levels to encourage better compliance and leave more money in the hands of the people. Speaking to reporters on the completion of one year of the Narendra Modi-government, finance minister Arun… – Continue reading

Singapore Enhanced Regulatory Framework for Corporate Service Providers

On 15 May 2015, Singapore has implemented a new enhanced regulatory framework for Singapore Corporate Services Providers. The strengthened regime for Singapore Corporate Services Providers is expected to help further boost the reputation of Singapore as a trusted international financial and business centre with robust regulatory frameworks against money laundering… – Continue reading

Treasury Releases Select Draft Provisions for Next U.S. Model Income Tax Treaty

The Treasury Department announced draft changes for the U.S. Model Income Tax Treaty — the baseline text used by the Treasury Department when it negotiates tax treaties. The current U.S. Model was last updated in 2006. The proposed changes in the draft provisions are intended to combat so-called Base Erosion… – Continue reading

Cayman Islands: FATCA Update: New Deadlines For Notification And Reporting To The TIA

The Cayman Islands Department of International Tax Cooperation has extended the deadlines for Cayman Reporting Financial Institutions (RFIs) to provide notification and reporting and to the Tax Information Authority for U.S. FATCA Reportable Accounts. RFIs now have until Friday, May 29, 2015 to submit notifications. The new reporting deadline is… – Continue reading

Malaysia Delays FATCA Reporting Deadline

The Inland Revenue Board (IRB) has informed Malaysian financial institutions (MYFIs) that their filing deadline in respect of the 2014 reporting year under the US Foreign Account Tax Compliance Act (FATCA) has been deferred from June 30, 2015. FATCA requires all FIs outside the United States to submit regular information… – Continue reading

Government Issues Beneficial Ownership Report

The Cayman Islands Government today issued a report stating that it will continue its current method of providing beneficial ownership information to law enforcement, tax and regulatory authorities, as the method adheres to global standards. As explained in its Consultation Report on Maintenance of Legal and Beneficial Ownership Information, Government’s… – Continue reading

The Financial Services Commission welcomes new Standard on the Regulation of Trust and Company Services Providers

The Gibraltar Financial Services Commission (“FSC”) has welcomed the new Standard of Regulation that has been issued by the Group of International Finance Centre Supervisors (“GIFCS”). The FSC is a member of GIFCS and actively participated in the working group which drafted the standard. The FSC has been regulating this… – Continue reading

India to go for ‘face-to-face’ talks with low tax jurisdictions for fast recovery of black money

The finance ministry, after due consultations with the SIT on black money and various financial probe agencies, has decided that a team of senior officials will hold bilateral meetings with foreign jurisdictions either in India or at the locations of their counterparts to thrash out issues quickly, reports the India… – Continue reading

Revised Anti-Money Laundering Examination Forms

The Compliance Commission (the Commission) has revised its Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) Examination Forms which were last revised in 2010. The examination forms were revised to clarify: The requirement for a written Risk-based AML/CFT policies and procedures document; Examination of financial institutions with a branch or branches;… – Continue reading

Government Issues Beneficial Ownership Report

The Cayman Islands Government today issued a report stating that it will continue its current method of providing beneficial ownership information to law enforcement, tax and regulatory authorities, as the method adheres to global standards. As explained in its Consultation Report on Maintenance of Legal and Beneficial Ownership Information, Government’s… – Continue reading

Gibraltar: Gibraltar Financial Services Commission

FSC restructuring plans for 2015 he Gibraltar Financial Services Commission (FSC) has recently announced restructuring plans for 2015. The restructure will take effect on 1 January 2015, focussing on supporting efficient and effective delivery of the FSC’s regulatory objectives and with a particular focus on strengthening existing sector-specific expertise. This… – Continue reading

Georgia seeks broader economic ties with Poland

Georgia and Poland held negotiations in Warsaw this week over an agreement on avoiding double taxation on income and capital. At the bilateral meeting the sides initialed the renewal agreement, which is based on the OECD Model Convention 2014 and envisages the introduction of new standards of cooperation in taxation… – Continue reading

Valeant Pharmaceuticals, Concordia Healthcare zoom ahead of U.S. peers

Canada’s health-care stocks are sizzling, as Concordia Healthcare Corp. and Valeant Pharmaceuticals International Inc.’s buy-and-streamline strategy has pushed the industry’s earnings and margins ahead of U.S. peers. The drugmakers are the two top-performing stocks in the Canadian equity benchmark this year, boosting total returns for the members of the Standard… – Continue reading

British Virgin Islands: When Life Gives You Lemons… The BVI And The Global Push For Tax Transparency

It is quite clear that the more recent past has seen a notable shift in the debate from various supranational initiatives implemented over the years, designed to curtail the activities of smaller offshore financial centres, towards the real issues of tax transparency, regulatory cooperation and managing systemic risk in the… – Continue reading

Global attempt on to ensure MNCs cough up proper taxes

OECD, G20 team up to plug loopholes that allow companies evade taxes in jurisdictions they operate to prevent tax base erosion There is now a serious global attempt to ensure that multinationals pay taxes in the jurisdiction in which they carry out their business. The attempt is being made keeping… – Continue reading

Jersey: Jersey Described As ‘One Of The First And Best’ In Shaping Transparency Landscape At London Conference

Jersey’s positive role in helping to drive forward and shape the international transparency landscape has been praised by a senior OECD tax expert at this year’s Jersey Finance Annual London Private Client Conference. Addressing an audience of more than 400 senior private client tax, trust and wealth management professionals at… – Continue reading

Jersey: Jersey Described As ‘One Of The First And Best’ In Shaping Transparency Landscape At London Conference

Jersey’s positive role in helping to drive forward and shape the international transparency landscape has been praised by a senior OECD tax expert at this year’s Jersey Finance Annual London Private Client Conference. Addressing an audience of more than 400 senior private client tax, trust and wealth management professionals at… – Continue reading

Resolving cross border tax disputes through Australia’s investment treaties

1. Global focus on transfer pricing There has been a recent surge in regulatory attention around the world towards pricing arrangements within multinational corporate groups. Regulators are concerned that these pricing arrangements may be used as a means of profit shifting and therefore tax avoidance. The price at which an… – Continue reading

OECD strengthens recommendations on transfer pricing documentation

In 2014, the Organization for Economic Co-operation and Development (“OECD”) began making recommendations to Member States for the implementation of certain actions aimed at limiting base erosion and profit shifting, known as “BEPS”. The project includes 15 actions, representing 15 areas of regulation that allow states to monitor data which… – Continue reading

German tax deferral rules infringe EU law

German tax law allows deferring the tax on certain disposal gains by transferring the hidden reserves in the disposed assets to similar newly acquired or newly produced assets (“Replacement Assets”). The tax deferral requires an allocation of the Replacement Assets to a German permanent establishment. The ECJ has recently ruled… – Continue reading