Category: Jurisdiction

Senate Probe: Caterpillar Avoided $2.4B in U.S. Taxes

Caterpillar avoided $2.4 billion in federal taxes between 2000 and 2012 by shifting $8 billion in profits from international parts sales to a tax haven in Switzerland, said Chairman Carl Levin, (D-MI), of the Senate Permanent Subcommittee on Investigations on Monday. Joining Microsoft (MSFT), Hewlett Packard (HPQ) and Apple (AAPL),… – Continue reading

Luxembourg Supports New Savings Tax Directive

Luxembourg’s Prime Minister Xavier Bettel said the conclusions adopted at the recent European Council meeting on the revised Savings Tax Directive have enabled “a green light from the Grand Duchy of Luxembourg.” He expressed his satisfaction that all 28 European Union (EU) member states reached an agreement at the latest… – Continue reading

Cayman Islands: Cayman Islands To Introduce New Directors Registration And Licensing Regime

The Cayman Islands government has announced, by way of a Gazette dated 21 March 2014, its intention to introduce a registration and licensing regime for directors of certain regulated entities in the Cayman Islands.  This has been anticipated since the Cayman Islands Monetary Authority (“CIMA“) conducted its industry wide corporate… – Continue reading

Bahamas Suffers 40% Uk Visitor Fall

The Bahamas suffered a 40.6 per cent fall in UK stopover arrivals in the six years to 2013, with a senior hotel executive expressing hope that London’s aviation tax cuts will have an “overarching positive impact” in reversing this trend. #Stuart Bowe, the Bahamas Hotel and Tourism Association’s (BHTA) president,… – Continue reading

Isle of Man: Safe Haven for Digital Currencies

The Isle of Man, a self-governing British Crown Dependency, is looking mighty interested in digital currencies. On Wednesday, the island’s Financial Supervision Commission(FSC) affirmed that “a Bitcoin exchange that holds client funds with a licensed overseas payment service provider is not required to obtain a license in the country for its… – Continue reading

Mexico, Panama Finish Free-Trade Talks

MEXICO CITY—Mexico and Panama have finished negotiating a free-trade agreement, which the two governments expect to go into effect once it is approved by their respective legislatures. The document was signed Monday by Mexican Economy Minister Ildefonso Guajardo and Panamanian Trade and Industry Minister Ricardo Quijano during a visit to… – Continue reading

Double taxation risk in chasing multinational companies

A call to tax technology companies such as Apple and Google in the countries where they have substantial activities has re-ignited concerns companies may be taxed twice and stop business altogether. The Organisation for Economic Co-operation and Development, which is working on a global plan to prevent companies from avoiding paying… – Continue reading

China likely to seek personal tax details worldwide, say analysts

Hong Kong may feel affect of any new law to uncover financial information China is expected to impose its own version of the new US tax law which requires financial institutions around the world to provide Washington with information on US taxpayers, analysts say. On March 25, the Secretary for… – Continue reading

Quebecor companies registered in Delaware prompt questions

Québec Solidaire on Saturday asked Pierre Karl Péladeau, the Parti Québécois candidate for Saint-Jérôme, to confirm or deny the registration of more than 60 Quebecor affiliates in Delaware, a state considered by many to be a popular tax haven. Amir Khadir, Québec Solidaire’s candidate in the Montreal riding of Mercier, described Delaware as a known tax haven for… – Continue reading

Black money menace

It would be surprising if Union finance minister P. Chidambaram’s threat to his Swiss counterpart — to declare Switzerland an uncooperative nation for not sharing information on the 562 Indians who allegedly stashed their black money in Swiss banks — is actually carried out. The threat has trade implications. These… – Continue reading

I-T dept signs APAs with 5 MNCs, more pacts in offing

NEW DELHI: Seeking to reduce litigations and promote foreign investments, the Income Tax department has signed Advance Pricing Agreements with 5 multinational firms and plans to enter into more such pacts. “We have signed 5 APAs so far. We will be signing more in the coming days. Foreign companies are eager to… – Continue reading

A changing world

Recent discussions about the movement of capital and offshore accounts have to be a major cause for concern. During a Central Bank seminar recently, Minister of Industry, International Business, Commerce and Small Business Development, Donville Inniss, sounded the warning that compliance with the recently passed Foreign Account Tax Compliance Act… – Continue reading

Plan for FATCA compliance in the ECCU

This report provides an update on the progress of on-going efforts by the ECCU Working Group on FATCA (Working Group) towards stablishing a compliance framework for the region. The report concludes with a synopsis of the planned way forward for ensuring compliance by the implementation date.

France Tightens Disclosure Requirements for Large Companies, Particularly in Relation to Transfer Pricing

The Anti-Tax Evasion Act and the Finance Act 2014 have introduced an annual transfer pricing documentation filing obligation and new disclosure requirements for large companies. Since 2010, French companies that have an annual turnover or gross asset value exceeding €400 million, are related to a French or foreign entity exceeding one of… – Continue reading

Australian Tax Amnesty Announced

In the early hours of Thursday Morning, Australia announced a tax amnesty on any tax resident with offshore assets not declared to the Australian Taxation Office Geraint Davies, Managing Director of Montfort International sees this move as significant from many perspectives.  “We have seen the breaking news of a complete… – Continue reading

India, Switzerland spar over access to bank accounts information

NEW DELHI: The Indian Tax authorities and the Swiss government could be headed for a showdown over what the Indian side regards as lack of co-operation from the Alpine country over access to information on bank accounts. Last week Finance Minister P Chidambaram wrote to his Swiss counterpart – officials… – Continue reading

Registration of Licensed Non-bank Financial Institutions in Compliance with FATCA

BASSETERRE, St. Kitts, March 26th 2014 (CUOPM) – The Member Governments of the Eastern Caribbean Currency Union (ECCU) have commenced discussions with the United States of America (US) towards executing an Inter-Governmental Agreement (IGA) for the implementation of the provisions of the US Foreign Account Tax Compliance Act (FATCA).   The… – Continue reading

‘Last chance’: ATO amnesty for offshore cash

The Tax Office is allowing Australians with money parked in offshore accounts to avoid harsh penalties by coming forward, in an amnesty program worth up to half a billion dollars. ATO Commissioner Chris Jordan will announce the program today, which will reduce the penalties for taxpayers who hand over information… – Continue reading

Caterpillar to face U.S. Senate panel on offshore taxes

WASHINGTON (Reuters) – Caterpillar Inc’s offshore tax strategies will come under scrutiny on Tuesday at a U.S. Senate hearing expected to examine dealings by the world’s largest mining and construction equipment maker in Switzerland, Bermuda and Luxembourg. With many multinationals being criticized for tax avoidance, veteran tax sleuth Senator Carl Levin… – Continue reading

United States: Remain Vigilant On Indian Permanent Establishments, Even After The Favorable e-Funds Decision

The U.S. and Indian competent authorities are famously at loggerheads over the principles to be applied in transfer-pricing double-tax cases.  Some of the important issues involved are:  the appropriate markup on costs for services; when and how to reward location savings; and whether marketing intangibles exist.  Virtually all of these… – Continue reading

UPDATED: CRA MAY IGNORE FATCA TRUST RULES

Aleaked document appears to reveal the Department of Finance and CRA may deviate from a tax deal struck with the U.S. Leaked by the Isaac Brock Society yesterday, the document purportedly presents the agency’s interpretation of draft legislation which, if passed, would give force to the Intergovernmental Agreement (IGA) on FATCA signed… – Continue reading

Internet groups face global tax crackdown

A looming global crackdown on aggressive tax avoidance is set to stop internet companies slashing bills by routing profits to havens. Plans to “restore taxation” in the countries where digital companies make their sales and base their headquarters were set out on Monday in the first international response to the… – Continue reading

Multinationals face new rules on aggressive tax avoidance

OECD plan to make practice of shifting locations ineffective New rules aimed at preventing the type of aggressive tax avoidance schemes run by some of the largest multinational employers here will begin to be introduced in September, according to a draft report seen by The Irish Times . Structures that artificially shift… – Continue reading

The plea deal of an ex-banker details tax-evasion schemes

As part of a plea agreement, an ex-Credit Suisse banker recently disclosed how U.S. customers avoided offshore account disclosure requirements. In an effort to crack down on offshore accounts, federal prosecutors have stepped up investigations of the largest Swiss banks, their bankers and account holders. The most recent bank to… – Continue reading

Caterpillar Previews Tax Defense for Senate Offshore Hearing (1)

Caterpillar (CAT:US) Inc. began defending its international tax maneuvers as a U.S. Senate investigative panel set an April 1 hearing to examine the company’s “offshore tax strategy.” Representatives from Caterpillar and PricewaterhouseCoopers LLP will testify, according to the hearing notice posted today by the Senate’s Permanent Subcommittee on Investigations. The committee, led… – Continue reading

Budget 2014: Tax advisers caught out on corporate properties

THE PENSIONS INDUSTRY may have been caught on the hop with George Osborne’s unexpected upheaval of the regime, but tax advisers didn’t get away scot-free. While Budgets have been more benign under the coalition government, advisers were caught out with revisions to the taxing of properties purchased within corporate wrappers. The… – Continue reading

Ghana and Denmark sign Double Taxation Agreement

Ghana and Denmark have signed a Double Taxation Agreement, moving the bilateral cooperation between the two countries to another level. A Double Taxation Agreement regulates the tax treatment of income or capital gains in situations where the same taxpayer is subject to tax in two states with respect to the… – Continue reading

Why ‘Londongrad’ Weighs On Britain’s Russia Policy

LONDON — They are the most expensive and luxurious flats in the whole of London. Their ultramodern bay windows offer an unobstructed view onto Hyde Park. An underground corridor connects them to the Mandarin Oriental, the palace where Michelin-starred chef Heston Blumenthal has one of his prized restaurants. In total, the… – Continue reading

EU adopts landmark directive to crackdown on tax evasion

The European Union has formally adopted the Savings Tax Directive after six years of negotiations. The directive is intended to bolster the power of the EU to crackdown on tax evasion. The measure was adopted shortly after Luxembourg and Austria abandoned their opposition to the plan. EU tax commissioner Algirdas Semeta, commenting… – Continue reading

Luxembourg Ordered to Give EU Tax-Deal Detail Amid Aid Probe (1)

European Union competition watchdogs ordered Luxembourg to hand over details of tax breaks for businesses after they said the Grand Duchy was hindering a state-aid probe spanning several EU nations. Luxembourg refused to deliver details concerning the 100 largest companies benefiting from a special program for companies whose profits stem… – Continue reading