Category: Jurisdiction

Recent Developments – Australian Transfer Pricing (TP) Rules: Time To Step Up

With the Australian Taxation Office’s (ATO) escalating focus on international profit shifting, it is essential for multinational taxpayers (MNEs) to properly understand the new Australian Transfer Pricing (TP) rules, assess the implications of these rules on their operations/transactions, what documentation they need to prepare and when, and what penalties may… – Continue reading

Italy Looks To Vatican For Next Tax Deal

After recently completing tax information exchange agreements (TIEAs) with Switzerland, Liechtenstein, and Monaco, the Italian Government is now looking to agree a similar treaty with the Holy See in Rome’s Vatican City. The TIEAs between Italy and Switzerland, Liechtenstein, and Monaco, and the prospective treaty with the Vatican, all provide… – Continue reading

Cayman Islands: Extension Of FATCA Notification Deadline

On 23 February 2015, the Cayman Islands Department for International Tax Cooperation (“DITC”) announced that the Governor in Cabinet of the Cayman Islands had approved an extension to the notification deadline contained in Regulation 14(3) of the Tax Information Authority (International Tax Compliance) (United States of America) Regulations, 2014 (the… – Continue reading

Passports for cash: the countries selling citizenship to tax havens

Citizenship has been turned into a commodity by countries including Cyprus, Grenada, Antigua, Malta and St. Kitts in the Caribbean, which is now the most popular place in the world to buy a passport – for as little as $250,000. The draw? Little or no tax. New citizens of St…. – Continue reading

Public sector wages the main budget issue

OPPOSITION spokesman on finance and planning, Audley Shaw, believes that the failure of the Government to make any progress in wage-related discussions with its employees could make it the major challenge for 2015/16, as the budget debate commences this afternoon at Gordon House. “There is nothing in the budget which… – Continue reading

Customs seeks technical support from EDB in tax evasion case against Paramount Corporation

KARACHI: The customs authorities have referred the case of importer Paramount Corporation to the Engineering Development Board (EDB) for seeking technical view point into the case. The sources informed Customs Today that the authorities concerned of Customs Adjudication-II have forwarded the case of Paramount Corporation to the EDB for seeking… – Continue reading

New tax avoidance offence expected in Budget

Accountancy firms predict that a new offence of aiding and abetting tax evasion and aggressive tax avoidance will be announced in next week’s Budget It is expected that George Osborne will outline proposals to introduce special measures, aimed at professional service firms, to deter serial avoiders and scheme promoters. The… – Continue reading

Narendra Modi: India, Mauritius will work to avoid tax treaty abuse

Port Louis, March 12 : Prime Minister Narendra Modi on Thursday assured that India would work with Mauritius to avoid the “abuse” of the double taxation avoidance agreement and added that the destinies of both nations are “linked by the currents of the Indian Ocean”. Addressing the National Parliament of… – Continue reading

GOP stands in way of Obama gambit for offshore corporate cash

Under a plan baked into the White House’s budget for 2016, U.S. corporations would theoretically be forced to pay hundreds of billions in new taxes on money kept abroad. Levying fees on the $2.1 trillion in funds largely held by shell companies through an accounting trick called deferral, the move,… – Continue reading

Articles – Budget 2015 predictions: EY’s runner and riders

The Chancellor will take credit for the improving state of the economy and public finances, but real policy changes will have to wait until after the election. Chris Sanger, Head of Tax Policy at EY, comments: “With this Budget announced in the dying embers of the coalition, next week’s event… – Continue reading

India offers $ 500 million credit to Mauritius, negotiations on tax treaty to continue

Port Louis: India offered US dollar 500 million concessional line of credit to Mauritius for key infrastructure projects even as the two countries agreed to continue negotiations on hammering out a revised double tax treaty to prevent its “abuse”. The two countries also signed five agreements, including one on developing… – Continue reading

Dutch, German firms urge fair patent box changes

Two business federations from the Netherlands and Germany have urged the Organisation for Economic Co-operation and Development to ensure that there is a level playing field under new international rules proposed for preferential regimes for intellectual property (IP) income, reports Tax News. The two organizations’ statement concerns the development of… – Continue reading

Nowhere to hide

The call for tax transparency is being echoed around the globe, with ‘midshore’ centres like Bahrain and the UAE emerging as reputable, regulated and tax efficient jurisdictions A 2012 book entitled Offshore Apocalypse – The Collapse of the Tax Haven Industry, written by a team of tax-law academics, auditors, compliance… – Continue reading

double taxation european union investments latvia legislation oecd south korea

On 9 March 2015, the State Secretary of the Latvian Foreign Ministry, Andrejs Pildegovics, met with the members of the South Korean Parliament, Byun Jae Ill and Park Young-sun, who are visiting Latvia from 9 to 11 March in order to strengthen cooperation between the Latvian and South Korean Parliaments,… – Continue reading

The voters hate Google. Heeeeyyyy… how about a ‘Google Tax’?

You may have noted there’s an election in the offing Worstall on Wednesday As the tech news outlet of record has told us, UK chancellor George Osborne is preparing to bring in the “Google Tax”. Properly known as the Diverted Profits Tax, it is supposed to be a way of… – Continue reading

FIs may have their hands full with FATCA provisions

Ever since the Foreign Account Tax Compliance Act (FATCA) was enacted in 2010 by the US Congress to target non-compliance by taxpayers using foreign accounts, the hallucination effect has come into force. Banks and financial intuitions are related with US treasury accounts in some way or the other just like… – Continue reading

UK targets ‘high risk’ tax scheme promoters

Under new rules introduced by the UK Government, “high risk” promoters of tax avoidance schemes will have to publicize the fact that they are being monitored by HM Revenue and Customs (HMRC), reports Tax News. Laws introduced last year allow HMRC to issue “high risk” promoters with Conduct Notices requiring… – Continue reading

Transfer pricing customs duty refund applications – let’s do it right

The Canada Border Services Agency (CBSA) has informed the Canadian importing community that importers may be entitled to obtain customs duty refunds in connection with downward transfer pricing adjustments having the effect of correcting/reducing invoiced prices that served as the basis of customs valuation of imported goods. On January 19,… – Continue reading

Canada: Case Study: Temporary Assignment Of An Employee From Canada To The United States

This article is the first in a series of four parts that will examine the Canadian and U.S. income tax implications when an employee employed by a Canadian entity is assigned temporarily to work in the U.S. This first article focuses on the importance of the determination of “residency” for… – Continue reading

Multinationals should be made to pass “common sense” test on where they get taxed

The Australian Taxation Office should be given the power to ignore multinational transactions that fail to pass the “common sense test” and ensure that technology company profits are taxed where they are earned, the Australia Institute submission to the inquiry into corporate tax avoidance says. The submission takes a swipe… – Continue reading

Scotland’s sticky finances

Scotland is running at a loss. And you’d be forgiven for also being at a loss about the conflicting use of statistics over just how much it’s in the red, or how badly. You can emphasise that tax paid in Scotland, and from its offshore oil and gas, was £400… – Continue reading

Expert Global Commission Responds to One-sided Tax Debate

Responding to widespread anger about corporate tax avoidance, the impacts of such avoidance on inequality and poverty, and concerns that current tax reform processes are inadequate, a new nonpartisan body-the Independent Commission for the Reform of International Corporate Taxation (ICRICT)-has been established to propose reforms from the perspective of the… – Continue reading

Malta features in poker giant’s €300 million tax avoidance route

Rome police accuse PokerStars.it managing director over €300 million of undeclared monies that were traced to Malta and the Isle of Man The managing director of PokerStars in Italy, a leading online poker brand, has been accused of fraud and tax evasion of some €300 million by Rome’s finance police… – Continue reading

Hungary and Luxembourg sign agreement to avoid double taxation

Representatives of the governments of Hungary and Luxembourg signed an agreement to eliminate double taxation on the sidelines of a meeting of EU finance ministers, the economy ministry said. The new agreement, signed by Economy Minister Mihály Varga and counterpart Pierre Gramegna, replaces an earlier one signed in 1990. It… – Continue reading

Anti-avoidance powers to hunt multinationals 'ineffective': ATO

The main legal weapon used by the tax office to hunt down multinationals trying to avoid paying tax often doesn’t work, a problem that could cost the federal government billions a year. A Tax Office internal document, Offshore hubs mitigation strategy overview, said that Australia’s general anti-avoidance rule, Part IVA,… – Continue reading

Seychelles: Seychelles Company – Corporate Environment Summary

Seychelles is one of the most popular offshore jurisdiction, with favourable business regulations, a prosperous economy and a stable political situation. Seychelles IBC, is a limited liability company which conducts its trading and business outside the Seychelles and is intended for offshore activities. It takes up to 2 days to… – Continue reading

Argentina Asks Bermuda For Tax Information

Argentina has sent requests for information to tax authorities in the Virgin Islands, Uruguay and Bermuda, according to a Reuters report. This comes as Argentina wants HSBC Holdings Plc to repatriate some $3.5 billion that it says the bank’s Argentine branch moved offshore to help clients evade taxes and move… – Continue reading

Breaking: PokerStars’ Italian Subsidiary Under Investigation for Alleged Tax Evasion

According to Italy’s financial police, the Halfords Media Italy S.r.l., one of the companies used by PokerStars for marketing activities in the country, is currently under investigation for a €300 million tax fraud. Contacted by PokerNews, Head of Corporate Communication at PokerStars Eric Hollreiser said to be confident that the… – Continue reading

Project Wickenby’s seven-year hunt lifts lid on dubious trades

NEIL CHENOWETH The raids unfolded across the city at 8.40 on a Tuesday evening. Squads of federal police descended on Point Piper, Chatswood, city offices and the departure lounge of Sydney International Airport. Accountant Vanda Gould was up when police arrived to arrest him. Across town officers scooped up his… – Continue reading

Here’s one budget proposal that may bring back Vodafone-like horrors for foreign cos

The Finance Bill 2015 (the Bill) has quietly slipped in an amendment that could engender a fresh set of disputes with foreign companies away from the hitherto transfer pricing hair-splitting. Hitherto, all Indian companies were residents and all foreign companies were non-resident, period. Of course foreign companies would have become… – Continue reading