EU member states sent a letter to 92 countries on Wednesday (1 February) informing them that they will be “screened” with a view to inclusion in a future “blacklist” of tax havens. The list of the countries that have been contacted is not public, but EUobserver understands that it is… – Continue reading
Multinationals owe responsibility to a wider group than their shareholders As the Apple tax case moves towards the European Union courts, €13 billion has been transferred to Ireland. The implications of the case will effect how multi-national companies implement taxes across Europe. has been accused of “bending the rules” in… – Continue reading
In a move that will facilitate ease of business, domestic transfer pricing provisions will apply only if one of the parties to a deal is availing of tax benefits. Traditionally, transfer pricing applied to international transactions entered into by a company in India with related parties, such as its foreign… – Continue reading
The Kuwait Ministry of Finance (MOF) has issued a ministerial resolution announcing that Deloitte & Touche, Al-Wazzan & Co in Kuwait has been certified with the ministry for the provision of Foreign Account Tax Compliance (FATCA) services. FATCA is a US legislation which aims to combat tax evasion by US… – Continue reading
Individuals who will be deemed UK domicile from 6 April 2017 should be considering their options with regard to offshore trusts as a matter of priority. On 5 December 2016, the UK Government published the Reforms to the taxation of non-domiciles: further consultation outcome, which provided clarity on the following… – Continue reading
The OECD made its end-November 2016 deadline to release the text of the multilateral treaty to give effect to the BEPS Actions which involve changes to tax treaties, see here. The 49 page treaty text, which is commonly referred to as the multilateral instrument or MLI, and 85 page explanatory… – Continue reading
More than 20 informants have signed contracts with tax agency that could lead to reward money The Canada Revenue Agency’s offshore tax evasion tip line has resulted in signed contracts with more than 20 informants and more than $1 million in tax reassessments and penalties. The tips have also resulted… – Continue reading
SMUGGLING of petroleum products has been rampant in the last couple of years. The value-added tax (VAT) and excise-tax exemptions of free-port and economic zones (FEZs) are being abused by enterprising individuals. To curtail this problem, the Bureau of Internal Revenue in 2012 required the payment of VAT and excise… – Continue reading
Among other things, Union Budget 2017 will be remembered for two firsts – the introduction of secondary adjustment and thin capitalisation rules. Both are transfer pricing provisions which will have a far-reaching impact on corporates. Secondary Adjustment Since the concept of secondary adjustment is introduced for the first time in… – Continue reading
Indonesia has entered the third phase of its tax amnesty program, which was first launched in July 2016 to boost the country’s meagre revenue by collecting previously unreported funds hidden by wealthy citizens abroad and at home. The country, which has long struggled to increase its tax revenue, has so… – Continue reading
THE scope of the withholding tax — a tax imposed on non-residents for services rendered to Malaysia-based companies — has been widened. It is one of the major tax changes that came into effect on Jan 17 under the Finance Act 2017. Under the changes, non-residents must pay withholding tax… – Continue reading
Main residence exemption costing budget $61.5bn, almost double the $33bn lost to super concessions The federal government’s tax breaks for home owner-occupiers are dwarfing tax breaks for superannuation. New figures show the capital gains tax concession on the family home is now worth $61.5bn, almost double the $33bn lost to… – Continue reading
The Caribbean Association of Banks (CAB) has expressed concern about the number of countries in the region which have not yet put in place inter-governmental agreements (IGAs) with the United States on the Foreign Account Tax Compliance Act (FATCA). It said it was therefore renewing the call for Caribbean countries… – Continue reading
A key outcome of the Organisation for Economic Development and Co-operation’s (OECD’s) final Report on Action Plan 13 (Transfer Pricing Documentation and Country-by-Country reporting) is the commitment of OECD and G20 countries to introduce Country-by-Country (CbC) reporting along with the associated master file and local file documentation for large Multinational… – Continue reading
Legislation reintroduced in both the Senate and the House of Representatives calls for the repeal of the estate tax, or “death tax” as it is commonly known in the United States. Until 2012, estates paid a 35 percent tax above a USD5m cap. The tax was scheduled to revert in… – Continue reading
CROSS-border taxation in current times is poised for significant changes. Tax is key in foreign ventures. Absent tax strategies and foreign tax leakages would erode margins and return of investment. Although international tax-efficient strategies to mitigate capital gains tax (CGT), withholding tax (WHT) and the risk of creating a taxable… – Continue reading
Deutsche Bank will pay a $425 million fine in relation to a money-laundering scheme that regulators say moved $10 billion out of Russia, the New York State Department of Financial Services said Monday. The department said Deutsche was moving money out of Russia by using a stock “mirror trading” strategy,… – Continue reading
The Stamp Duty (Amendment) Bill 2017, which implements a further stamp duty increase to cool Hong Kong’s housing market, was gazetted on January 27, and will be introduced into the Legislative Council on February 8. The Bill includes the demand-side management measure announced on November 4, 2016. With effect from… – Continue reading
Documents for thousands of Canadian residents transferred under controversial FATCA legislation Banking records of more than 315,000 Canadian residents were turned over to the U.S. Internal Revenue Service last year under a controversial information sharing deal, CBC News has learned. That is double the number transferred in the deal’s first… – Continue reading
The Trump White House favours a “flexible” border adjustment tax targeting countries with which the United States runs big trade deficits, including Mexico, China and Germany, the President’s top trade and industry adviser said. Peter Navarro, a sceptic of free trade, wants the US to entice advanced manufacturing production onshore… – Continue reading
The programme includes measures to combat base erosion and profit shifting, based on four main measures that can challenge exploitation of tax agreements, monitor developing international tax work rules, and ensure a more transparent environment. Egypt was chosen by the Organisation for Economic Cooperation and Development (OECD), in a conference… – Continue reading
HM Revenue and Customs’ failure to get tough with Britain’s richest individuals is undermining confidence in the whole tax system, MPs have warned. In a scathing report, the Commons Public Accounts Committee accused HMRC of creating the impression in its dealings with taxpayers there was “one rule for the rich… – Continue reading
U.S. companies hold cash—lots and lots of cash—overseas to avoid paying the top corporate tax rate of 35% on those foreign earnings. But the rate could be heading down with a change in the federal government’s leadership, and the prospect of more repatriated earnings to work with has finance chiefs… – Continue reading
In a significant step, Mauritius will soon start automatically sharing of tax information with India and other countries as part of global efforts to curb multinational companies from profit shifting activities. The development also comes months after the island nation, long perceived to be a jurisdiction for alleged illegal fund… – Continue reading
What GAO Found In 2015, the Organization for Economic Co-Operation and Development (OECD) issued revised guidelines, including 15 actions to help reduce base erosion and profit shifting (BEPS) of multinational enterprises (MNEs). One action focuses on transfer pricing guidance with the intent of aligning MNE profits with the location of… – Continue reading
On January 19, Greece and the United States signed an intergovernmental agreement (IGA) to facilitate compliance with the US Foreign Account Tax Compliance Act (FATCA) by financial institutions (FIs) in Greece. FATCA is intended to ensure that the US Internal Revenue Service (IRS) obtains information on financial accounts held at… – Continue reading
A European leader in financial, tax and regulatory reporting for the banking and insurance sectors, Invoke is expanding its software range to meet CRS/AEoI cross-country tax reporting requirements. As part of the global fight against tax evasion, the G20 and OECD program for the exchange of tax payers’ financial information… – Continue reading
China’s banking regulator issued guidelines on Wednesday calling for the country’s financial institutions to strengthen their control and management of funding for outbound investment. The guidelines are the latest new rules on overseas investment as Beijing moves to clamp down on cross-border capital outflows and halt questionable investments. The China… – Continue reading
Several countries in Latin America have established new transfer pricing documentation obligations associated with the OECD’s Base Erosion and Profit Shifting (BEPS) initiative. In this new year, Mexico, Colombia and Peru have included in their local legislation new documentation requirements that follow a three-tiered approach: country-by-country (CbC) report, master file,… – Continue reading
The most important task of the Finance Minister in the 2017-18 budget is to tame the “Indirect Transfer Provisions” monster born out of amendments to Section 9 of the Income Tax Act, 1961. In response to the Supreme Court’s judgement in the famous Vodafone case, the Finance Act, 2012 amended… – Continue reading
New guidelines aim to check tax evasion, ensure foreign firms are not taxed on their global income. New Delhi: The income-tax (I-T) department on Tuesday issued the final guidelines for place of effective management (PoEM) rules that seek to determine the residency status of a firm for calculating its tax liability. The… – Continue reading
The new administration and Congress have signaled their intention to undertake fundamental tax reform in the coming months. Lawmakers will need to weigh the costs and benefits of numerous policy trade-offs as they undertake this effort. Among the most visible debates already underway concerns “border adjustability,” or moving the U.S…. – Continue reading
Revenue appraisers began crosschecking the withholding tax returns from some companies to determine propriety of the pay disbursed to their foreign and local employees and consultants. In recent times, the submitted accounts on the pay-as-you-earn tax of some multinational companies (MNCs) and domestic firms have been under surveillance of the… – Continue reading
On October 3, 2016 the Federal Government proposed changes to the Income Tax Act (the “Act”) and administrative policies that will impact claiming the principal residence exemption. 1. All dispositions of principal residences must now be reported. Previously, the CRA did not require taxpayers to report the sale of a… – Continue reading
ISLAMABAD – The Securities and Exchange Commission of Pakistan (SECP) has proposed the government to give one time amnesty scheme for the owners of offshore companies to declare their hidden assets by paying nominal tax. “I have asked the Finance Minister Ishaq Dar to give one opportunity to offshore companies… – Continue reading
Double Taxation Avoidance Agreement Amended between S. Korea and India The Korea Shipowners’ Association announced on January 24 that the Double Taxation Avoidance Agreement between South Korea and India was amended so that South Korean shipping companies’ shipping income generated as a result of their maritime transport services provided for… – Continue reading
Bermuda – the world’s former “top tax haven” – has joined the Organisation for Economic Cooperation and Development’s fight against multinational profit shifting. Bermuda disputes it is a tax haven despite companies such as Apple and Google in the past being accused of using the British overseas territory to minimise… – Continue reading
JERSEY could be left vulnerable to being blacklisted as a ‘tax haven’ by the EU as the UK’s influence in Brussels fades during the Brexit process, a top adviser to the States has warned. Speaking at an Institute of Law seminar on the implications of Brexit for Jersey, Colin Powell… – Continue reading
Germany’s BDI industry group has come out against a government plan to unilaterally close so-called ‘patent box’ tax loopholes used by foreign companies to avoid paying full taxes on profits earned in Germany. The Association of German Industrialists, BDI, said Tuesday that the government’s unilateral move would send a negative… – Continue reading
Country’s reputation being exploited for ‘snow washing’ global money trails, experts warn Far from the palm-fringed beaches of the usual offshore tax havens, Canada has quietly become a go-to destination for international tax cheats eager to exploit the country’s twin benefits of a sterling reputation and rules that allow private… – Continue reading
The OECD recently released a public discussion draft entitled the “BEPS Action 6 Discussion Draft on non-CIV examples” to clarify when investors like private equity funds, real estate funds and hedge funds should be entitled to tax treaty benefits. The release of the 2017 Discussion Draft is timely, given that… – Continue reading
Nassau, The Bahamas – The Bahamas has taken many steps to comply with global standards in the financial services sector. One such step is the implementation of the Common Reporting Standard (CRS). The Common Reporting Standard (CRS), developed in response to the G20 request and approved by the OECD Council… – Continue reading
Hong Kong (HKSAR) – Hong Kong has signed an agreement with Korea with a view to commencing the automatic exchange of financial account information in tax matters (AEOI) in 2019, a Government spokesman said today (January 24). “Since the signing of the first two agreements for AEOI with Japan and… – Continue reading
Ministry of Finance – State of Kuwait recently “went live” with the Vizor Software for FATCA & AEOI solution to meet its FATCA obligations under the terms of its Intergovernmental Agreement (IGA) with the United States of America’s Internal Revenue Service (IRS). Today, Vizor Ltd. announced the Kuwaiti Ministry of… – Continue reading
The move comes after HM Revenue & Customs received representations from the Association of Charitable Foundations and the Charity Finance Group HM Revenue & Customs has updated its guidance on the forthcoming common reporting standard after receiving concerns from charities. The CRS is an international standard for the automatic exchange… – Continue reading
A new legislative approach of the German tax authorities leaked last December 19 will have a significant impact on the tax deductibility of royalties owed to related persons being subject to a preferential back end tax regime for IP not being in compliance with the Organisation for Economic Co-operation and… – Continue reading
Bahrain has signed an agreement to implement the US Foreign Account Taxpayer Compliance Act with the United States. FATCA, enacted by the US Congress in 2010, is intended to ensure that the US obtains information on accounts held abroad at foreign financial institutions (FFIs) by US persons. Failure by an… – Continue reading
The Offshore Compliance Advisory Committee issued a report in December 2016 to the Canada Revenue Agency about the Voluntary Disclosures Program (VDP or tax amnesty). If a taxpayer submits a successful income tax or GST/HST voluntary disclosure program application then generally criminal income tax prosecution and civil tax penalties under… – Continue reading
On December 21, 2016, the new Canada–Israel tax treaty entered into force. The new treaty was signed on September 21, 2016 in New York, and replaces the existing treaty that dates from 1975. For most purposes, the provisions of the new treaty took effect as of January 1, 2017. Overall,… – Continue reading
Manama, Jan. 22 (BNA): An agreement was signed between the Government of the Kingdom of Bahrain and the Government of the United States of America to improve international tax compliance and implement the Foreign Account Tax Compliance Act (FATCA). The agreement was signed by the Minister of Finance, H.E. Shaikh… – Continue reading
