KUWAIT: Kuwaiti citizens who possess US passports need to straighten out their US tax status to avoid the penalty of having their US passports scrapped, said Abdulaziz Al-Anjeri, head of the American Tax Bureau in Kuwait. Technically Kuwaitis are barred from holding a second citizenship but many are suspected of… – Continue reading
Majlis (Parliament) of Turkmenistan has ratified an agreement with the government of Finland for the avoidance of double taxation with respect to taxes on income during the regular meeting, the Turkmen government said Jan.13. Turkmenistan believes that namely innovations ensured Finland’s competitiveness at international level. The message of the State… – Continue reading
In June of 2015, Connecticut passed legislation that implements combined reporting for tax years beginning on or after January 1, 2016. Part of the new regime, which is codified by Conn. Gen. Stat. P.A. 15-5, § 144 (2015), requires water’s-edge combined groups to include entities incorporated in tax havens in… – Continue reading
The IRS has announced important changes to its offshore account programs. They come as FATCA is taking hold worldwide. Many foreign banks are rooting out Americans with increasing vigilance. One key target of the changes? Americans living abroad and certain others who can now come within the IRS Streamlined Program…. – Continue reading
The Inland Revenue (Amendment) (No.2) Ordinance 2015 (the “Amendment Ordinance”) came into effect on July 17, 2015, extending Hong Kong profits tax exemption to offshore private equity (“PE”) funds. Profits Tax Exemption prior to the Amendment Ordinance This is a welcome development for the private equity industry since, in the… – Continue reading
On January 11, 2016 the Luxembourg tax authorities issued a newsletter announcing that on January 13, 2016 the Agreement between the Grand Duchy of Luxembourg and the Republic of Croatia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on… – Continue reading
Taxpayers in parts of Switzerland this year face an unusual request from fiscal authorities: please delay settling your bill until as late as possible, reports the Financial Times. Zug, the small but affluent canton outside Zürich, has announced it is ending discounts for early payment of tax bills. The reason?… – Continue reading
Ogier partner Marcus Leese has welcomed news from Italy that Guernsey and Jersey are no longer on any Italian ‘black lists’ and will be included on Italy’s ‘white lists’ from early 2016, reports Isle News. Among other benefits, it is anticipated that this will enable Italian resident investors to invest… – Continue reading
The Organisation for Economic Co-operation and Development’s base erosion and profit shifting process will not have significant implications on Luxembourg-based companies, Fitch Ratings has said. The agency on January 8 re-affirmed Luxembourg’s AAA rating, with a stable outlook. According to Luxembourg for Finance, the territory’s financial services promotional agency, the… – Continue reading
The BVI has passed legislation to implement the Organisation for Economic Co-Operating and Development (OECD) Common Reporting Standard for the exchange of tax information (CRS). The amendments to the Mutual Legal Assistance (Tax Matters) Act, 2003, which implement CRS in the BVI, will come into force on 1 January 2016…. – Continue reading
The BVI and Cayman are often referred to as “tax neutral” and you might have been told that, for this reason, it would be advantageous to establish your fund in either jurisdiction. What does this actually mean and what does it mean for your fund? Primarily, it means that BVI… – Continue reading
You may be aware that buying a second home or investing in a “buy to let property” is about to become more expensive. The Chancellor of the Exchequer announced in November 2015 the introduction of new higher SDLT rates of 3% above the current residential rates. The higher rates will… – Continue reading
The KPMG member firm in India has prepared reports concerning the following developments (read more at the hyperlinks provided below). Income attributable to taxpayer’s foreign branches not taxable in India: The Bombay High Court held that income attributable to a taxpayer’s foreign branches, permanent establishments (PEs) outside India, is not… – Continue reading
The Democratic presidential candidate’s plan, which would increase tax rate to 4% for only 0.02% of Americans, was criticized by Sanders’s campaign Hillary Clinton would add a 4% tax “surcharge” on Americans who earn more than $5m a year and close “egregious” tax loopholes if she became president, expanding on… – Continue reading
A Highland hideaway – situated on a private island in the River Beauly in Inverness-shire – has been snapped up for £7million by the Qatari royal family, it has been claimed. The 545-acre Eilean Aigas Estate comes with it a massive luxury mansion, is described as one of the best… – Continue reading
Irish drug giant’s long-standing plan to acquire US rival – and lower its tax bill – is finally sealed thanks to beefed-up cash offer The drugs maker Shire yesterday clinched a $32bn (£22bn) takeover of US rival Baxalta after sweetening the deal with a bumper cash component despite fears such… – Continue reading
The battle between the People’s Bank of China and currency speculators has led borrowing costs for offshore yuan in Hong Kong to shoot up to 200 per cent Tuesday, with analysts saying the central bank is keen to defend the currency and fend off speculative attacks. The PBOC through several… – Continue reading
Tax inversions and corporate tax rate cuts would be huge for these stocks Certain politicians are decrying a tax move known as an “inversions,” which allow a U.S. company to merge with a foreign one with a more favorable tax rate. Yet, it’s the politicians who created the necessity for… – Continue reading
Canada and the United Kingdom have signed an agreement that clearly outlines procedures for the application of the arbitration provisions of the Canada-United Kingdom income tax treaty. The agreement provides for a clearly outlined process for the arbitration of tax disputes between the two nations. The agreement establishes rules and… – Continue reading
Savills estate agent in Bristol is urging those considering selling in 2016 to put their property on the market sooner rather than later, to ensure a sale is completed before 1st April 2016. After this date, purchasers are likely to be liable for an increased level of stamp duty on… – Continue reading
The government aims to turn the screws on tax delinquents this year as well as those who have escaped the taxman’s radar, finance minister Harris Georgiades told MPs on Tuesday. The Tax Department is preparing to launch a drive to track down and tax the owners of luxury assets, such… – Continue reading
HONG KONG: In the space of about five years, the offshore market in Chinese yuan has gone from the poster child of Beijing’s financial market liberalisation to a battleground to regain control of the currency, spooking investors and raising questions about the future of the market. While investor appetite for… – Continue reading
Federal Supreme Court of Switzerland denies treaty benefits in case of dividend paid on shares acquired for hedging derivative contracts. Court stated that due to the fully hedged nature of ownership, there was economic nexus and interdependency between two independent transactions and therefore, the “intermediary” bank did not have beneficial… – Continue reading
U.S. Democratic presidential candidate Hillary Clinton on Tuesday expanded her plan to tax the wealthiest Americans by saying she would close tax-avoidance “loopholes” that allow investments to be routed through low-tax countries and put in tax-deferred retirement accounts. “My plan is kind of simple: we go after the wealthy to… – Continue reading
Washington — JUST about every American chief executive has the same dream: to get out from under the corporate income tax. For many, that means lobbying Congress to change the tax code. But for a growing number, it also involves increasingly creative — and successful — tricks to avoid their… – Continue reading
Microsoft CEO Satya Nadella will be sitting in the House gallery as an honored guest at the State of the Union (SOTU) address tonight. By all rights, he be should sitting before a Congressional committee instead, answering for his company’s blatant tax avoidance. Microsoft is playing a game called “Global… – Continue reading
The UK tax authority, HM Revenue and Customs (HMRC), has announced that new double tax avoidance treaties with Bulgaria and Croatia have entered into force. The 2015 UK-Bulgaria double tax agreement was signed on March 26, 2015, and replaces the former 1987 treaty. It generally limits the withholding tax rate… – Continue reading
The jury is out on whether a group helmed by President Joko Widodo can revive stalled growth in Indonesia’s Islamic finance industry. The head of the world’s biggest Muslim population is chairing a new committee tasked with bringing fragmented regulations under one roof and taking action to spur the market,… – Continue reading
On 10 December 2015 the remaining changes to the income tax and the capital gains tax laws aiming to improve the tax system of Cyprus and make it more attractive to both the local and international business community were voted. The changes came into effect with their publication in the… – Continue reading
BRUSSELS – Three Italian consumer organizations have urged EU antitrust regulators to investigate McDonald’s (MCD.N) franchise system in Europe, a month after the opening of an EU inquiry into the U.S. fast food company’s tax deals with Luxembourg. Codacons, Movimento Difesa del Cittadino and Cittadinanzattiva filed their complaint with the… – Continue reading
‘We’re not a tax haven, we have never been involved in any kind of tax malpractice’ – Michael Noonan, Irish Minister for Finance 5th October 2015 If your top political figures need to constantly state that your country is not a tax haven, then the chances are it probably is… – Continue reading
A web of offshore companies was used to shield controversial builder Tom McFeely’s ownership of an apartment building close to London’s Olympic stadium, an Insolvency Service official has claimed. The allegation was one of several levelled against the Priory Hall developer as part of proceedings issued by official assignee Christopher… – Continue reading
An individual who has been normally resident outside the EU for the last ten continuous years intends to import a private jet into the UK. The aircraft is owned by a BVI company and is currently based in North America. The individual is a director and majority shareholder of the… – Continue reading
U.S.-based multinational corporations are allowed to play by a different set of rules than small and domestic businesses or individuals when it comes to the tax code. Rather than paying their fair share, many multinational corporations use accounting tricks to pretend for tax purposes that a substantial portion of their… – Continue reading
ECOFIN’s latest monthly review of VAT measures includes abandoning plans for a standard VAT return across 28 countries. The Czech Republic has requested to pilot the domestic reverse charge, an anti-VAT fraud measure. The EU’s Economic and Financial Affairs Council (ECOFIN) latest update on VAT measures includes, as anticipated, abandoning… – Continue reading
A lawyer for the Internal Revenue Service on Monday disclosed a series of emails and legal memos from 2004 apparently showing that Dallas entrepreneur Sam Wyly was interested in knowing the legal and financial ramifications if he renounced his U.S. citizenship. The IRS also introduced testimony from previous court proceedings… – Continue reading
AB InBev says it’s `disappointed’ and is assessing its options Vestager lashes out at `double non-taxation’ schemes BRUSSELS – The European Union ordered Belgium to recover about 700 million euros ($763 million) in illegal tax breaks given to at least 35 companies, including Anheuser-Busch InBev and BP, as regulators continued… – Continue reading
Northern Ireland has moved one step closer to setting its own corporation tax rate when its Department of Finance and Personnel signed a memorandum of understanding (MoU) with HMRC, Economia reports. This sets out the arrangements for developing the necessary systems for devolving the tax, which will still be administered… – Continue reading
The focus has been on increasing global participation in India through liberalisation of foreign direct investment (FDI) laws. It covered easing FDI sectorial caps and conditions in diverse sectors ranging from highly regulated sectors like defence, construction& development, civil aviation to single brand retailing, automatic route for FDI in Limited… – Continue reading
As part of the ATO’s reinvention agenda we have been reviewing our Advance pricing arrangement (APA), Mutual agreement procedure (MAP) programs and our Competent Authority Network to identify opportunities to: improve the client experience and better support willing participation improve our bilateral and multilateral engagement increase our efficiency and effectiveness…. – Continue reading
One of the scams police are investigating involves victims being targeted through an online dating websites. The public is being warned about international scams as police investigate a number of serious fraud complaints involving offshore accounts. Hundreds of thousands of dollars are ending up in the hands of unscrupulous scammers…. – Continue reading
An Australian Taxation Office (ATO) report issued last month on “corporate tax transparency” showed that 1,539 of the country’s biggest firms had a combined turnover of $1.6 trillion but paid a total of only $39.9 billion in company tax—about 2.5 percent of the collective turnover. Five hundred and seventy-nine of… – Continue reading
HAVE YOU worked on an overseas project for a Thai employer where you’ve had to stay in an overseas assignment for 183 days or more in a year or over two consecutive years? If so, how should you handle any double taxation? While it’s important to pay tax correctly, you… – Continue reading
According to a recent petition, the Israeli government has taken the wrong side in a world war that the US is waging over taxes of its overseas dual citizens. The financal future of 9 million Americans worldwide and hundreds of thousands living in Israel could be at stake. According to… – Continue reading
India collected INR24.28bn (USD363.4m) in taxes and penalties after 644 declarations were made under the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act 2015. The Black Money Act, which came into force on July 1, 2015, provided taxpayers with a one-time compliance window to declare assets… – Continue reading
Royce Gracie isn’t scheduled to fight at Bellator 149 until February, but he’s in a serious fight with the IRS over his taxes, including whether he rightfully claimed a tax credit for the poor. Remember the scrawny guy in a gi who smoked the field at UFC 1 and had… – Continue reading
Once known as “Spain’s Princess Diana,” King Felipe’s younger sister is facing criminal fraud charges. Monday saw the start of the trial of Princess Cristina de Borbón – the first member of Spain’s royal family ever to be put on trial in a criminal court. Cristina, 50, is charged with… – Continue reading
Most Americans who work overseas feel that FATCA negatively impacts their careers, and that compliance requirements are burdensome, says a new study released by the Americans Abroad Global Foundation and the University of Nevada. The study surveyed nearly 700 adults who live and work in more than 60 countries. Key… – Continue reading
Changes in I-T Act likely to curb tax evasion by multinational companies The government might change transfer pricing provisions in Budget 2016-17 to ensure companies with overseas presence and consolidated revenue of more than Rs 5,000 crore comply with extensive data reporting and documentation. Legislative changes in the Income Tax… – Continue reading
This is the first of our series of posts on Brazilian tax treaties. In each post we will provide an overview of a specific tax treaty between Brazil and a particular foreign country, as well as comments on any Brazilian administrative or judicial precedents applying the treaty, and highlights on… – Continue reading
