More than €45.6bn raised for exchequer last year, up from €41.2bn in 2014 The Revenue Commissioners secured 27 criminal convictions for serious tax evasion and fraud in 2015, according to figures released today. Those prosecutions were on top of 2,063 summary convictions, or lesser charges, for the non-filling of tax… – Continue reading
Despite popular campaign and committee recommendations, tax haven restrictions will not be included in bill AN OVERDUE land reform report from the Scottish Government has categorically refused to bring back a proposal which campaigners say would have tackled the phenomenon of Scottish land being owned in offshore tax havens. Dropped… – Continue reading
French authorities are investigating the taxes of designer Karl Lagerfeld, who a French magazine claims used offshore tax havens to avoid paying millions of euros to the French government. The case is the latest involving allegations of high-end tax evasion in France, where the finance ministry has cracked down on… – Continue reading
Mutual Fund houses will have to mandatorily provide compliance details for the new global tax avoidance law FATCA with regard to each client on the stock exchange’s mutual fund trading platform. In a circular, BSE said for each and every transaction mutual fund houses have been asked “to upload FATCA… – Continue reading
Interest paid by UK companies is generally subject to withholding tax at 20%. Although various exemptions apply, most notably in respect of interest payments to banks and other UK companies, and in respect of securities listed on a recognised stock exchange (so called “quoted eurobonds”), such exemptions are often of… – Continue reading
Viacom Inc. was accused by one of its former executives of plotting to hide revenue from “Teenage Mutant Ninja Turtles” in a Netherlands entity to avoid taxes. The ex-vice president for financial planning at Viacom claims she was fired after opposing what she believed was an illegal tax dodge. Nataki… – Continue reading
The Argentine tax authorities (AFIP) posted an updated “white list” of countries, jurisdictions, and territories—that is, a list of countries and jurisdictions that are identified as cooperative for tax transparency purposes. A broader application of Argentina’s transfer pricing rules will not apply to transactions involving entities located in the countries… – Continue reading
The Department of Justice announced today that Union Bancaire Privée, UBP SA (UBP), reached a resolution under the department’s Swiss Bank Program. UBP will pay a penalty of more than $187 million. “Today’s agreement marks the final resolution with UBP, which acknowledges its role in conspiring with U.S. taxpayers to… – Continue reading
The number of legacy bank tax avoidance schemes under investigation by UK tax authority HM Revenue and Customs (HMRC) has fallen since the strengthening of Code of Practice on Taxation for Banks, a new departmental report has shown. The Code of Practice on Taxation for Banks was introduced in 2009… – Continue reading
Now that the final report on BEPS Action 7 has been released, “Preventing the Artificial Avoidance of Permanent Establishment Status” (Final Report), taxpayers are able to consider the final language to be incorporated into Article 5(5) of the OECD Model Tax Convention.1 This language also will be incorporated into the… – Continue reading
On December 18, 2015, the President signed the Omnibus Appropriations Act (the “Act”) into law.1 Notably, the Act contains a number of substantive changes to the tax laws applicable to “real estate investment trusts” (“REITs”). Although several changes will adversely affect certain REITs, on balance REITs and their investors fared… – Continue reading
Taipei, Jan. 6 (CNA) President Ma Ying-jeou (馬英九) lauded his administration’s efforts to improve the country’s development and expressed optimism Wednesday about the future for Taiwan’s next generation, citing a recent survey that found Taiwan the most optimistic about the future among other Asian nations. If peace and prosperity in… – Continue reading
Ex-HSBC employee and whistle-blower Hervé Falciani has lashed out at the Swiss banking system for helping multinationals evade taxes through offshore schemes. He has also demanded that Switzerland recognise the role of whistle-blowers. “In order to survive the Swiss had developed mercenary activities on a grand scale. These are the… – Continue reading
On January 6, 2016 the text of the Memorandum of Understanding with respect to the Exchange of Information for Tax Matters as concluded between the Competent Authorities of the Netherlands and Georgia (Hereafter: the MoU) was published in the Dutch Staatscourant. The MoU was signed by the Dutch competent authorities… – Continue reading
UBP is the latest bank to reach a resolution under the Swiss Bank Program, launched in 2013, that allows Swiss banks to resolve potential criminal liabilities in the United States. UBP between 2008 and 2013 helped U.S. clients to open and maintain undeclared accounts in Switzerland and conceal assets and… – Continue reading
Twelfth night has come and gone, the Chistmas lights are out but John Lewis has reported a set of sales figures that sparkled. The department store believes it has outperformed its rivals, once again, online in particular. And yet it’s managing director told me the fight with one rival –… – Continue reading
The investigation and prosecution of tax evasion has, in the last decade, grown from a specialized subcategory of law enforcement into a first-tier policy concern for the global community. Starting with the U.S. government’s crackdown on Swiss bank UBS in 2008, there has been a steady drumbeat of news about… – Continue reading
A Viacom whistleblower claims she was sacked by the media company for opposing its alleged plan to illegally avoid paying U.S. taxes on the international licensing rights to Teenage Mutant Ninja Turtles. In a complaint filed in Manhattan federal court on Tuesday, former vice president Nataki Williams said she was… – Continue reading
Legislation amending the rules governing transfer pricing documentation—to include country-by-country reporting, as well as master file and local file provisions—has been enacted and has an effective date of 1 January 2016. The Dutch Upper House (Eerste Kamer) on 22 December 2015 passed the legislation (the bill is referred to in… – Continue reading
The Norwegian Ministry of Finance published a public consultation paper regarding country-by country reporting for tax purposes. The proposal suggests that multinational groups—when the ultimate parent company is a resident in Norway—would be required to submit country-by country reports. The reporting requirements could also affect foreign group entities that are… – Continue reading
In its continuing effort to keep the BVI Business Companies Act (the “Act”) at the forefront of offshore company law legislation, the BVI Government, in direct consultation with the private sector, has introduced several updates to the Act as follows: To allow weighted voting by directors whereby certain directors may… – Continue reading
NEW DELHI: Government has collected a total of Rs 2,428.4 crore in taxes after over 600 declarations were made by stash holders to the Income Tax department under the one-time black money compliance window that ended last year. The Central Board of Direct Taxes, in a statement, said this amount… – Continue reading
The Chinese yuan plunged to a five-year low in offshore trading and the gap between it and its mainland counterpart widened sharply on Wednesday, reflecting growing expectations of further weakness in the currency amid an economic slowdown and a slump in stock markets. The offshore yuan fell to 6.6915 against… – Continue reading
A judgment in the Contira case was handed down two weeks ago in the district court which dramatically changes the Cost Plus issues relevant to certain Israeli companies which provide services to a foreign related company. The judgment impacts on the situation where the Israeli company’s employees are granted options… – Continue reading
The Treasury Department and the Internal Revenue Service have proposed regulations setting out a new requirement for certain U.S. persons that are the ultimate parent of a multinational group (a “U.S. MNE group”) having annual revenue of at least $850 million to file an annual report (the “CbC report”). The… – Continue reading
The FCA has reportedly ended its investigation into tax evasion at HSBC, with the bank dodging formal action from the regulator. HSBC spent much of 2015 under fire for the actions of its Swiss private bank, which aided more than 1,000 UK customers evade tax between 2005 and 2007. The… – Continue reading
Billionaire JP McManus is refusing to back down in a row with the US government over a tax bill of $5.2m (€4.8m). The racehorse owner has renewed efforts to secure a tax refund for the sum, court papers seen by the Irish Independent reveal. The disputed cash was part of… – Continue reading
(Reuters) – Texas tycoon Sam Wyly is set to face off against the Internal Revenue Service at trial on Wednesday over more than $2 billion the agency says he owes for using offshore trusts to engage in one of the largest tax frauds in U.S. history. The trial in federal… – Continue reading
Iceland passed legislation that will make secret off-shore accounts very difficult to maintain for tax dodgers. RÚV reports that as of the start of this year, the Directorate of Internal Revenue will have access to the details of all overseas bank accounts held by Icelandic companies and individuals. The legislation,… – Continue reading
Changes to patent box rukes will mean that businesses must now track and trace all of their research and development (R&D) expenditure AFTER the recent government consultation on the UK’s Patent Box scheme, businesses will find it a challenge to comply with the proposed new rules. The changes will mean… – Continue reading
Rules requiring master file and local file reporting—“full” transfer pricing reporting—are advancing in Korea. 5 January 2016 Korea’s parliament on 2 December 2015 approved legislation (released as draft legislation by the Ministry of Strategy and Finance of Korea in August 2015) to implement the OECD’s base erosion and profit shifting… – Continue reading
Guidance—General Resolution No. 3826—issued by the Argentine tax authorities (AFIP) implements new information reporting for banks and financial institutions pursuant to the OECD’s common reporting standard (CRS) regime, effective January 2016. Background Argentina agreed to early implementation of the new “automatic exchange of information” (AEOI) measures. Accordingly, the AFIP will… – Continue reading
Spokesman for B.C. finance minister downplays tax loophole issue A new petition urging B.C. politicians to limit offshore investment and exploitation of tax loopholes in Vancouver real estate is getting a cool reception from Victoria as provincial coffers overflow with property transfer tax revenues in a red-hot housing market. The… – Continue reading
(Special) – Winter brings with it the dream of many Canadian snowbirds of owning a piece of property in the sunny south. With the recent rebound in the U.S. housing market and a decline in the value of the Canadian dollar, however, buying vacation property south of the border may… – Continue reading
Doing business in Poland in 2016? Stay on top of changes to transfer pricing and the potential for tighter local tax regulations. Over the past 12 months we have seen improvements in business-related procedures for tax payers in Poland. Setting up a new company is easier and more efficient, and… – Continue reading
On Friday, December 18, 2015, President Barack Obama signed the “Protecting Americans from Tax Hikes Act of 2015” (“PATH Act”). Our December 10, 2015 client alert discussed significant proposed changes to the rules governing real estate investment trusts (“REITs”) and the Foreign Investment in Real Property Tax Act of 1980… – Continue reading
A striking example of the EU’s efforts to accelerate the implementation of anti-base erosion and profit shifting (BEPS) measures is the amended Parent Subsidiary Directive (PSD). Originally designed to prevent economic double taxation of profits distributed within an EU corporate, the PSD is now also being deployed to counter undesired… – Continue reading
The US Department of Justice (DoJ) has announced that it has now completed agreements with 75 financial institutions, and imposed penalties in excess of US$1bn, under its Swiss Bank Program, reports Tax News. The DoJ’s Swiss Bank Program was signed by the US and Switzerland on August 29, 2013. It… – Continue reading
A UK government body says the UK chancellor is getting £50 million a year less than he expected from a crown dependencies tax deal, reports Manx Radio. The Office for Budget Responsibility says the deal has brought in 20 per cent less cash from tax disclosure facilities that allow people… – Continue reading
Lately, the IRS is warning offshore account holders to disclose before it’s too late. Under FATCA, banks everywhere want to know if you are compliant with the IRS. And the cost of compliance for many people is growing. The IRS updated its list of foreign banks where accounts trigger a… – Continue reading
Bahrain, Sudan also sever diplomatic ties with Iran; two mosques attacked in Iraq UNITED NATIONS/ WASHINGTON: The world community on Monday urged Saudi Arabia and Iran to observe restraint after tension over the execution of a prominent cleric Nimr Al-Nimr along with 46 others by the Saudi government. The UN… – Continue reading
Shortly before New Year’s, on Wednesday, December 30, 2015, the media reported that Julius Baer Group AG (“JB”) expected to pay about $547 million to settle the U.S. investigation into how the bank (and its bankers) assisted U.S. taxpayers in evading tax. This investigation began more than 4 years ago,… – Continue reading
Although the British Virgin Islands is often seen as an offshore tax haven, a closer look shows such opinions may be overstated There is a stereotypical image of the so-called ‘tax haven’ for ‘shady people to put their money’. While it is true that BVI Finance enjoys warm, sunny weather… – Continue reading
Increasing regulation has made transfer pricing complex for multinational enterprises. Technology can help simplify the process In recent years there has been an increasing focus on transfer pricing, in line with the proliferation of transfer pricing requirements from a growing number of countries around the world, and the OECD’s project… – Continue reading
SAS and DataGear implement tailor-made FATCA solution within Al Baraka Bank Dubai, UAE – Al Baraka Bank Egypt , a subsidiary banking unit of Al Baraka Banking Group B.S.C. (ABG) , partnered with SAS®, the leader in analytics, and Data Gear, a Business Intelligence (BI) software & services provider, to… – Continue reading
The international community led by the had initiated the (BEPS) project a few years ago with the aim of ensuring that profits are taxed where economic activities are performed and where value is created. Governments, and social groups have been voicing their concern over the past decade that multinational enterprises… – Continue reading
Several ‘brief-case’ professionals, well accomplished sole proprietors and very important personalities all go around earning millions of Naira in income but paying no tax Tax gap is used here to refer to the difference between taxes collected by government and what could ideally be collectible. Without a doubt, the gap… – Continue reading
As will be recalled from the previous blog posting that discussed so-called “Controlled Foreign Corporations” (CFC), a United States shareholder of a CFC can possibly be treated as having received “dividend” income at various times. These are when the US shareholder (i) has current income inclusions from the CFC under… – Continue reading
On 14 December 2015, the Swiss Council of States discussed the legislative draft of the Corporate Tax Reform III and in principle approved the reform package. In deviation from the revised draft legislation issued by the Swiss Federal Council on 5 June 2015, the Council of States voted against the… – Continue reading
Insurers and financial advisers are required to know the tax information of their customers, according to guidance published by the Association of British Insurers (ABI) and the Association of Professional Financial Advisers (APFA). The new requirement follows UK information exchange agreements including Foreign Account Tax Compliance Act, agreements with Crown… – Continue reading
