The Bombay High Court, in its landmark judgments in the cases of Vodafone India and Shell India, held that issue of shares, being a capital transaction, does not attract transfer pricing (TP) provisions under the Indian income tax law. The court observed that investment in shares does not fall within… – Continue reading
Thanks in part to past concerns that globalization could lead to double taxation, corporations have numerous techniques at their disposal to reduce their tax bills, including the placement of subsidiaries and spinoff holding companies in low-tax jurisdictions. The Group of 20 wants to change that. The Organisation for Economic Cooperation… – Continue reading
It is estimated that there are at least 100,000 Greeks with American citizenship living in Greece. In addition, thousands of US citizens live and work in Greece, either on a short-term or permanent basis. According to US law, all of these citizens, with very few exceptions, are required to file… – Continue reading
As for the central message that an NRI/PIO want to hear from Modi’s most important budget of his term can be best summed by what he said during an event in central park New York “May the force be with you “Veni Vidi Vici!” he came, he saw and he… – Continue reading
Close to three dozen private equity firms which used investment entities based in Mauritius to route money into Indian portfolio companies have received income-tax notices for payment of Minimum Alternate Tax (MAT) on the capital gains accrued to them for sale of such shares, according to Business Standard. MAT is… – Continue reading
The government is set to make changes in the income tax rules to seek overseas operational details of multinational businesses that have a turnover of over R5,000 crore in India in order to decide which companies should be audited for income suppression, reports Gireesh Chandra Prasad in New Delhi. The… – Continue reading
Not long after the U.S. Department of Justice’s Tax Division (“DOJ”) made international headlines in 2009 for its bombshell announcement that it had entered into a deferred prosecution agreement with the United Bank of Switzerland (UBS), lawmakers in Washington, D.C. began reviewing the testimony of hundreds of UBS’s U.S. clients… – Continue reading
The differentiation between tax avoidance, tax evasion and the moral duty to pay tax for the betterment of society has been intentionally screwed by politicians and bureaucrats. This is nothing new. I wrote an couple of articles several years ago questioning the terminology of ‘morally repugnant’ tax avoidance when it… – Continue reading
PARIS: The heir to the Nina Ricci perfume fortune went on trial for hiding €18.7 million (£13.9 million) from French authorities in what is seen as a test case concerning the HSBC tax avoidance scandal. Arlette Ricci, 74, is among the first of around 50 wealthy French nationals to face… – Continue reading
Jersey’s chief minister Ian Gorst has formally expressed his “disappointment” with statements from Labour Party leader Ed Miliband about tax transparency and disclosure efforts by UK overseas territories. In an open letter to the Opposition leader, Gorst said the Island government had reiterated “many times” in past discussions with the… – Continue reading
The government has been able to instil a positive sentiment in the country. Various policy initiatives like Make-in-India, aimed to make India a manufacturing hub, and the Clean India campaign; updating age-old laws and tweaking the Goods and Services Tax to a more acceptable form, introducing greater clarity in the… – Continue reading
The amendment of matriculation tax law in 2013 signaled a relevant change for charter operations in Spain: the possibility for non EU flagged vessels to be licensed in the Balearics, this change will allow not only EU but Non EU flagged vessels to operate from the Balearic Islands. Alex Chumillas… – Continue reading
Although the importance to Africa’s diaspora is largely discussed around remittances, many Africans are also coming back to join the public service. SOMALIA’S parliament just approved a new parliament, a crucial step on the road to voting on a new constitution and presidential elections scheduled for 2016. A key role… – Continue reading
São Paulo, Brazil. International transfer pricing is able to take place in Brazil, outside of the OECD While Brazil is not a member of the OECD, many multinational groups there are able to successfully navigate international transfer pricing standards, yielding effective results The economic view of Brazil has always been… – Continue reading
BELIZE CITY, Mon. Feb. 23, 2015–It’s far easier to move money from Belize via an offshore company than to deposit those funds in a local commercial bank, especially with more stringent banking requirements which have been implemented as part of the new anti-money laundering regime here in Belize. If a… – Continue reading
JAKARTA, Feb 24 ― Indonesia will crack down on corporate tax avoidance via transfer pricing this year to try and recoup 200 trillion rupiah (RM56.6 billion) in lost state income mainly in the commodities sector, the new head of the tax office told Reuters. Under the transfer pricing method, an… – Continue reading
Eurozone finance ministers are expected to hold a conference call on Tuesday to weigh Greece’s new economic reform plans, raising expectations that they are inclined to sign off on a tentative deal to extend Athens’ €172bn bailout until June. The Greek list of economic reforms, due to be submitted to… – Continue reading
Bahrain and India have signed agreements to increase co-operation in the areas of education, investment, defence and other sectors. It took place during the first meeting of the India-Bahrain High Joint Commission (HJC) in New Delhi, said a report in the Gulf Daily News (GDN), our sister publication. The Bahrain… – Continue reading
A repatriation holiday would have a minimal economic impact and would be the wrong way to pay for the Highway Trust Fund or any other project, according to a new report by the Heritage Foundation. There have been differing congressional proposals recently to change the tax treatment of the USD2… – Continue reading
The issue of whether Israeli banks should take the Swiss approach and refuse to disclose customer identities may be a moot point, in light of a new international anti-tax-evasion treaty that is taking shape. There is a direct line connecting the disclosure of the identities of 6,200 Israelis with Swiss… – Continue reading
An Alberta online bank is believed to be the first Canadian financial institution to deny service to Americans, citing the burden of complying with strict new U.S. tax rules. Canadian Direct Financial, a subsidiary of Edmonton-based Canadian Western Bank, is refusing to open new Internet accounts for U.S. citizens, even… – Continue reading
IRA plans can be excellent ways to save for retirement, but there are some investments to avoid if you want to take full advantage of IRA tax savings. Two that come immediately to mind are tax-exempt municipal bonds and high-yielding stocks from foreign countries with dividend withholding taxes. Tax-exempt municipal… – Continue reading
Transfer pricing policy in the United States is guided by Section 482 of the Internal Revenue Code (and by the Organization for Economic Cooperation and Development under its Base Erosion and Profit Shifting initiative), and its application is not limited to cross-border transactions. In fact, some states, such as New… – Continue reading
This is the time of the year for millions of Americans to begin the annual ritual of gathering information about income, taxes, charitable giving, health insurance, expenses and sundry other items, and prepare to send mountains of information to the IRS –and to those who prepare their tax returns. Overseas… – Continue reading
Attempt to plug every gap makes the system unworkable – Norton Rose Fulbright. JOHANNESBURG – A tax expert has warned against over-complicating tax legislation in an attempt to block every loophole or perceived underpayments of tax, as it makes the tax system “unworkable”. Andrew Wellsted, director at Norton Rose Fulbright,… – Continue reading
(Bloomberg) — Argentine tax authorities said Sunday they are seeking the arrest of money manager Miguel Abadi for alleged involvement in an offshore investment network designed to avoid paying taxes. The agency, in a statement, said it’s seeking information from tax agencies in the Virgin Islands, Uruguay and Bermuda about… – Continue reading
ISLAMABAD: The State Bank has blocked the suspicious transactions of $65 million originating from Malaysis after finding a suspicious transaction report (STR). The National Action Plan on counter-terrorism requires strict monitoring of banking transactions and active coordination among federal and provincial investigation agencies. So far about 500 accounts are reported… – Continue reading
The spotlight is firmly on tax reduction among large global firms operating in the UK – but is the practice putting smaller domestic companies on the back foot? The HSBC tax scandal, wilfully fuelled by politicians looking to appear tough on what they call immoral tax practices, has put the… – Continue reading
Not a single penny of what the treasury loses from tax avoidance is accidental Tax avoidance has rarely been the subject of as much attention as it is at present. That’s welcome. As a tax researcher and chartered accountant, I’ve estimated that it costs the UK at least £19bn a… – Continue reading
With so much attention on FATCA in recent times, the financial services industry could be forgiven for seeing it as the most obtrusive regulation ever to be imposed on them. This view will soon change. Once the Automatic Exchange of Information (AEOI) comes into force, financial institutions will have far… – Continue reading
When I consider what’s likely to have the most impact in tax this year, I keep coming back to the massive shift in attitude by tax authorities in the aftermath of the Global Financial Crisis (GFC). Usually changes in the tax world are incremental, but what is going on now… – Continue reading
Switzerland and neighbouring Italy have revised a double taxation agreement which includes provisions for the exchange of information in line with the standards of the Organisation for Economic Development and Co-operation (OECD). The accord and a roadmap for the amendment of tax rules on cross-border workers as well as improved… – Continue reading
Santo Domingo.- The US Internal Revenue Service (IRS) and Dominican Republic’s Internal Taxes Agency (DGII) have begun a process to exchange bilateral financial and tax information, as part of the on Foreign Accounts Tax Compliance Law (FATCA). A delegation of the IRS’ International Cooperation Program led by its senior manager… – Continue reading
American citizens residing in Malta as well as some Maltese migrants were urged to get their US tax affairs in order during an information session on the US FATCA legislation. Jonathan Phyall, Senior Legal & Compliance Officer at APS Bank explained that an agreement signed between the Malta and US… – Continue reading
Switzerland and neighbouring Italy have revised a double taxation agreement which includes provisions for the exchange of information in line with the standards of the Organisation for Economic Development and Co-operation (OECD). The accord and a roadmap for the amendment of tax rules on cross-border workers as well as improved… – Continue reading
Antoine Deltour sees himself as “just a little auditor” who copied some tax files. Now he may face jail after those documents helped send a shock wave through Luxembourg that is reverberating across the European Union. (Bloomberg) — Antoine Deltour sees himself as “just a little auditor” who copied some… – Continue reading
Greece’s far-left government was last night thrashing out a new package of economic reforms that it claims will crack down on tax evasion and overhaul its bloated civil service. The stricken Mediterranean country has been given until today to unveil the measures after reaching an agreement with its creditors from… – Continue reading
(Bloomberg) — HSBC Holdings Plc, struggling to contain a political storm over the bank’s facilitation of tax evasion through its Swiss unit, said Chief Executive Officer Stuart Gulliver paid taxes after setting up his own Swiss account and keeping his legal residence in Hong Kong. The bank, reacting to an… – Continue reading
Tax collections, so maintains the Federal Minister for Finance Ishaq Dar, have improved significantly and he cited a healthy growth rate of around 13 percent in one of his recent press conferences. Sources within the Ministry of Finance, however, revealed to Business Recorder, but on condition of anonymity that the… – Continue reading
A former Director of Public Prosecutions has accused banking giant HSBC of “grave” cross border crime and of engaging in “a systematic and profitable collusion in serious criminal activity” in the UK. According to the Independent, in a damming intervention Lord Ken Macdonald, who led the Crown Prosecution Service until… – Continue reading
According to Peter Willey, EY’s Channel Islands Head of Tax, the Channel Islands are likely to be impacted by decisions being made now in other jurisdictions. EY recently surveyed its tax policy leaders in 32 jurisdictions to ask them to forecast the tax policy outlook for 2015 in their jurisdiction…. – Continue reading
The Treasury Department’s crackdown on tax inversions last year has slowed but not stopped the movement of U.S. headquarters abroad as American businesses try to reduce tax bills and foreign firms seek to grow. Indeed, with U.S. companies now virtually barred from relocating overseas in order to trim taxes, the… – Continue reading
(Bloomberg) — Swiss prosecutors are scrambling to explain why they took seven years to probe suspicions of money laundering aroused by data stolen from HSBC Holdings Plc’s private bank in Geneva. Inspired by Feb. 8 disclosures by the Washington-based International Consortium of Investigative Journalists that HSBC did business with arms… – Continue reading
DALLAS, TX–(Marketwired – Jan 15, 2015) – Dorchester Minerals, L.P. (NASDAQ: DMLP) announced today the Partnership’s fourth quarter 2014 cash distribution. The distribution of $0.485780 per common unit represents activity for the three-month period ended December 31, 2014 and is payable on February 5, 2015 to common unitholders of record… – Continue reading
Feb 22 (Reuters) – A new criminal offence should be introduced to clamp down on tax evasion, a senior figure in Britain’s finance ministry said on Sunday in the wake of a scandal surrounding HSBC. Allegations that HSBC’s Swiss private bank helped clients evade tax has pushed the issue to… – Continue reading
Following the financial crisis, dividend yields from American banks have remained below the level many income investors are looking for. While all four major American banks yield less than 3%, U.S. investors can still get fat bank dividends by looking abroad. The United Kingdom London has long been a financial… – Continue reading
UK, US, Australia, Brazil, India- governments of developed and developing countries are battling profit shifting by MNCs such as Amazon, Google, Apple and Starbucks. The allegation- MNCs are shifting profits to jurisdictions where there is little or no tax to be paid. The solution- OECD’s BEPS action plan which, among… – Continue reading
MUMBAI: The Securities and Exchange Board of India has banned 33 entities for allegedly misusing the stock exchange system to generate fictitious long-term capital gains of over Rs 1,800 crore and for converting their unaccounted income into legal money. Sebi said Kamalakshi Finance Corp (KFCL) made preferential shares to connected… – Continue reading
Investors seeking global diversification for their property portfolios are increasingly seeing New Zealand as an attractive investment option. Although our commercial and industrial property market is too small to attract the interest of giant global real estate investment trusts (REITs), our manageable size is regarded as an advantage by other… – Continue reading
Certainty and reduced litigation on transfer pricing (TP) issues will be the cornerstone of creating a non-adversarial tax regime in India. The authors believe that Budget 2015 ought to lay out a roadmap to achieve this goal for TP issues – Recent positive progress on the Advance Pricing Agreement (APA)… – Continue reading
