Category: Jurisdiction

Canada: Upcoming FATCA Deadlines For Canadians

As part of its 2015 Federal Budget announcements, Canada committed to implementing the “Common Reporting Standard” (CRS) promulgated by the Organization for Economic Co-operation and Development (OECD). While the OECD’s efforts to facilitate information reporting via the CRS and Canada’s corresponding implementation of such a regime will certainly have lasting… – Continue reading

Illicit financial flows affect Malawi economy -MEJN

The Malawi Economic Justice Network (MEJN) says illicit financial flows are highly affecting economic growth of the country, saying the siphoning of the funds is undermining growth in Malawi. Speaking during the second meeting of the African parliamentarians on illicit financial flows and tax (APNIFFT) in the capital Lilongwe, MEJN’s… – Continue reading

Falciani: all banks help evade taxes

All the world’s major banks have connections between each other and work together in a secret network to help people evade taxes, whistleblower and former HSBC IT engineer Hervé Falciani said yesterday, warning that illegal offshore transactions can’t be carried out through one single bank but only with the help… – Continue reading

JPMorgan probed over role in French tax evasion case

(Reuters) – U.S. bank JPMorgan Chase (JPM.N) has been placed under formal investigation in France as part of a probe into alleged tax evasion by senior managers at investment firm Wendel (MWDP.PA), a court official said on Wednesday. A Paris-based spokesman for JPMorgan declined to comment on the move, part… – Continue reading

Mexico Supports Costa Rica On Tax Info Exchange

Officials from Mexico’s Tax Administration Service (SAT) met with Costa Rican tax administration officials from April 20 to 22, 2015, to share their experiences in the area of tax information exchange. The Costa Rican authorities learned from Mexico’s experience in implementing the US Foreign Account Tax Compliance Act (FATCA) and… – Continue reading

Government to revise tax treaty with South Korea

NEW DELHI: Ahead of Prime Minister Narendra Modi’s visit to South Korea this month, the Cabinet today approved revising the double tax avoidance pact with Seoul to provide tax stability and facilitate flow of investment and technology between the countries. The Cabinet headed by the Prime Minister gave its approval… – Continue reading

Costa Rica, the OECD and FATCA: What You Should Know

Now that Costa Rica has been formally invited to go through the process of becoming a candidate nation worthy of joining the Organization for Economic Cooperation and Development (OECD), financial advisors and legal professionals are starting to ponder how their clients will be impacted by this new chapter in our… – Continue reading

Tax evasion and avoidance: how much can be raised?

“We will raise at least £5 billion from continuing to tackle tax evasion, and aggressive tax avoidance and tax planning, building on the £7 billion of annual savings we have delivered in this Parliament.” Conservative Manifesto “[We would raise] a further £6bn from tax dodgers.” Lib Dem press release, 19… – Continue reading

India pursues investment funds for tax

UK funds invested in India could face demands for tax from which they thought they were exempt. Minimum alternate tax (MAT), a tax on the book profit of a company, has been in existence in India in its current form since 2001 and is levied at 18.5 per cent. Because… – Continue reading

India: Clarification With Respect To Applicability Of Explanation 5 To Section 9(1) On The Dividend Declared By Foreign Company

The Central Board of Direct Taxes [CBDT] on 26th March 2015 issued a Circular no. 4/2015 wherein they have clarified that while interpreting the provisions of Section 9(1)(i) of the Income Tax Act, 1961 [herein after referred to as ‘Act’] read with Explanation 5 inserted to the said section by… – Continue reading

Ireland: US business body warns not to box in multinationals

The American Chamber of Commerce has warned that new Irish tax incentives may fail because they do not match the needs of multinationals, reports the Irish News. The chamber, which represents 700 US companies, has said the forthcoming Knowledge Development Box – which will replace the discredited Double Irish structure… – Continue reading

The conundrum of the interplay between interest deduction limitations, interest withholding tax and double tax agreements

The deductibility of interest has for years been a contentious issue and this has been reaffirmed with the introduction of section 23M into the Income Tax Act No 58 of 1962 (the “Act”) with effect from 1 January 2015. A further addition to the interest sphere of income tax is… – Continue reading

Sofia City Court returns the Prosecutor’s Office indictment against prominent Bulgarian politician

Sofia. Judicial proceedings against Bulgarian politician Hristo Biserov is terminated and returned to the Prosecutor’s Office to remove breaches in the factual part, the press office of Sofia City Court announced. The order is subject to appeal and protest before the Sofia Court of Appeal in 7 days of service… – Continue reading

Persistent Loss Filter: The Sumitomo Case

“Book Loss” and not “operating loss” a relevant indicator for determining persistent loss – Mumbai Tribunal Ruling in the case of Sumitomo Chemical India Private Limited Transfer pricing aims at establishing the arm’s length price of the controlled transactions using the most appropriate method. The success of transfer pricing lies… – Continue reading

Greece Announces Tax Amnesty Plans

Greek Finance Minister Yanis Varoufakis has announced that he intends to introduce a bill to allow taxpayers to declare funds held abroad without incurring penalties. Funds declared under the amnesty will be taxed at rates of 15 to 20 percent, with no further penalty or investigation. The funds will not… – Continue reading

MoF and RAK Investment Authority signed MoU on international standards of transparency and exchange of information for tax purposes

Dubai – The Ministry of Finance (MoF) recently signed a MoU with Ras Al Khaimah Investment Authority (RAKIA). This MoUhas been signed to ensure the implementation of international standards of transparency in the exchange of information for tax purposes, as per Organisation for Economic Cooperation and Development (OECD) regulations and… – Continue reading

Governments’ Race to Address Corporate Profit Shifting Revs Up’

It’s a race against time for governments of the worlds’ largest economies seeking a coordinated plan to make it more difficult for multinational corporations to shield profits overseas. Some countries are preparing to act on their own. International finance leaders from advanced- and developing- economies are set to gather Wednesday… – Continue reading

Metro’s transfer pricing practices unmasked by GDT

VietNamNet Bridge – Metro Cash & Carry Vietnam, the German invested retailer, which repeatedly reported losses over the last 12 years in Vietnam, has engaged in transfer pricing to evade tax, according to the General Department of Taxation (GDT). It has asked the big retailer to reduce the reported loss… – Continue reading

Cyprus: The Ideal Location For US To Structure A Royalty Company

Choosing the right location for the centralization and management of your IP is a very important strategic business decision. The ideal location to establish an IP structure is one that can serve the organization’s business strategies/model, safeguard and protect its IP and more important to contribute to its tax optimization…. – Continue reading

A place in the sun: Retiring overseas requires careful tax planning

Jason Porter explores the tax regimes in Portugal, France, Malta and Cyprus – four of the most advantageous territories for UK ex-pat retirees People aged 55 and over are now entitled to their pension in the form of a lump sum, to be taxed at marginal rates applying in the… – Continue reading

BREAKING: US and Armenia to sign Trade and Investment Framework Agreement

U.S. Ambassador to Armenia Richard Mills on Tuesday confirmed reports that a U.S.-Armenia Trade and Investment Treaty will be signed during President Sargsyan’s working visit this week to Washington, DC, the final step in the negotiation of a bilateral economic accord long sought by the Armenian National Committee of America… – Continue reading

New tax rules proposed for e-commerce transactions

In the 2015 Budget Speech presented to the National Assembly on 25 February 2015 the Minister of Finance announced that amendments will be proposed to change the rules for the digital economy in line with the latest guidance issued by the Organisation for Economic Co-operation and Development (“OECD”) in its… – Continue reading

EU delays decisions on Apple, Amazon tax probes

BRUSSELS–The European Union won’t meet a self-imposed June deadline for deciding whether four multinational companies including Apple Inc. and Amazon.com Inc. benefited from illegal tax sweeteners, the bloc’s antitrust chief Margrethe Vestager said Tuesday. “We won’t meet the deadline we set ourselves [of] the end of the second quarter,” Ms…. – Continue reading

The Davis Tax Committee on BEPS and the transfer pricing of intangibles in South Africa

The Davis Tax Committee (“DTC”) recently addressed the issue of base erosion and profit shifting (“BEPS”) in South Africa. The international importance of transfer pricing was once again emphasized when 4 out of the 15 actions identified in the OECD Action Plan on BEPS related to transfer pricing. The 15… – Continue reading

The President signed into law the dot. FATCA

Passing between tax administrations Polish and US information on accounts and income tax residents predicts signed by the president Bronislaw Komorowski law on ratification of the agreement with the USA on the use of so-called FATCA Act. As reported by the presidential office, in terms of the Act of 20… – Continue reading

Taxation in Spain

A guide to Spanish taxation in 2015 for expats, with up-to-date information on income tax, VAT, property tax and other taxes for residents and non-residents in Spain. If you are living and working in Spain, you will be liable to pay Spanish taxes on your income and assets and will… – Continue reading

Guernsey Chief Minister meets EU Commissioner Moscovici

Guernsey’s Chief Minister, Jonathan Le Tocq, met today with Pierre Moscovici, the European Commissioner for Economic and Financial Affairs, Taxation and Customs. Deputy Le Tocq’s meeting, which was alongside Jersey’s Chief Minister, Ian Gorst, came at the beginning of a series of engagements over the next 48 hours in Brussels…. – Continue reading

Thai transfer pricing on the verge of new era

Thailand is expected to introduce new transfer pricing (TP) laws in the near future, which will apply to all companies in the Kingdom with related-party transactions. At a recent Deloitte seminar on “Thailand TP Developments”, with participation from senior officials from the Revenue Department, we shared some valuable insights on… – Continue reading