Representatives of the Cyprus and the Ukrainian governments have signed, in Kiev, on Friday, 11 December 2015, a protocol amending their Double Tax Avoidance Treaty. The protocol is based on the Model Tax Convention for the Avoidance of Double Taxation OECD. The changes need to be ratified by both the… – Continue reading
Non-Belgian shareholders with a participation in a Belgian company with an acquisition value of at least €2.5m (but not reaching the 10 per cent participation threshold under the Parent–Subsidiary Directive) are now entitled to the Belgian participation exemption regime. In C-384/11 (Tate & Lyle Investments), the European Court of Justice… – Continue reading
The Belgian general withholding tax rate applicable to dividends and interest attributed as of 1 January 2016 increases from 25 per cent to 27 per cent. Interest on ordinary saving accounts and on certain government bonds (so-called ‘Leterme bonds’) as well as royalties continue to benefit from reduced withholding tax… – Continue reading
Here’s our overview of recent Belgian tax developments, including the main new Belgian tax measures adopted by the laws of 18 and 26 December 2015. Speculation tax A ‘speculation tax’ of 33 per cent is introduced on capital gains realised by Belgian resident and non-resident individuals within six months from… – Continue reading
Two more top banks getting away with paying NO corporation tax in the UK: Credit Suisse and Citigroup are latest to admit using previous losses to slash their bills Seven foreign investment banks in London now pay no corporation tax Fines and lawsuits used to slash their tax bills by… – Continue reading
International art dealer Guy Wildenstein is going on trial in Paris on charges of defrauding the French state of half a billion euros (about $550 million) in taxes, after two relatives tipped off authorities about the family’s financial dealings. Wildenstein, 70, Franco-American heir of a New York art-dealing empire, is… – Continue reading
Indonesian President Joko Widodo’s government will start 2016 trying to get lawmakers to approve the country’s fourth tax amnesty since independence, a plan it says will lure back money stashed overseas to net an extra $4.4 billion of revenue this year. Bad move, say tax analysts, anti-corruption activists and the… – Continue reading
Japan, Taiwan January 4 2016 After many years of discussion and negotiation, Taiwan’s Association of East Asian Relation and Japan’s Interchange Association finally signed 「THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVAION WITH RESPECT TO TAXES ON INCOME」(the “DTA”) in Tokyo on 26 November 2015. For the… – Continue reading
New actions for advisors to consider in light of these developments In the last quarter of 2015, Russia saw a flurry of changes concerning the tax amnesty program, de-offshoring and the reporting of foreign accounts. We highlight the most significant developments below. What the New Rules Say Tax amnesty. On… – Continue reading
The FATCA reporting deadline for financial institutions in Portugal has been extended again, this time to 31 March 2016. An order of the Portuguese Secretary of State for the Financial Affairs, issued 28 December 2015, extends the deadline for Portuguese financial institutions to report relevant information under the FATCA regime… – Continue reading
The Ministry of Finance has announced a withdrawal of the one per cent withholding tax imposed on interest earned by individuals on any investments. The tax imposition on interests is part of provisions in the new Income Tax Act, 2015 (Act 896) which came into force on January 1, 2016…. – Continue reading
United States Vice President Joe Biden has never been one to hold his tongue. He certainly didn’t in his recent trip to Kiev. In a speech before Ukraine’s Parliament, Biden told legislators that corruption was eating Ukraine “like a cancer,” and warned Ukrainian President Petro Poroshenko that Ukraine had “one… – Continue reading
Yet another amnesty scheme mocks honest taxpayers The Federal Board of Revenue (FBR) has once again admitted its failure in dealing with the powerful class of traders in forcing them to file tax returns as other persons do. The government of the day, as expected, is more than keen to… – Continue reading
Official Irish statistics are being fattened up by massive tax inversions and the re-registering of companies, warns Dan White The ESRI estimates that the Irish economy grew by 6.7pc in 2015 and is forecasting GDP growth of 4.8pc for this year. GNP, which is generally regarded as a better measurement… – Continue reading
Two more investment banks have reported paying zero tax in Britain in 2014, prompting the opposition Labour party to urge the government to reverse a tax change it made for banks last year. Citigroup and Credit Suisse disclosed in the past fortnight that their main UK subsidiaries paid no corporate… – Continue reading
India on Wednesday approved the signing and ratification of an agreement with the Maldives for exchange of information aimed at curbing tax evasion and avoidance. According to the Economic Times of India, the approval was given by the Union Cabinet chaired by Prime Minister Narendra Modi. “The agreement will stimulate… – Continue reading
Italy has already brought several cases against global technology companies that have headquarters in low-tax nations like Ireland to avoid paying higher taxes in other countries, like Italy. Tax officials won’t say what Apple has agreed to pay, but citing local reports, the Times reports it may be around $350… – Continue reading
Investors in mutual fund (MF) schemes have to provide additional KYC (know your customer) information in the new year. The additional details have been mandated to ensure that India complies with tax information-sharing laws such as FATCA (Foreign Account Tax Compliance Act). The Association of Mutual Funds in India (AMFI)… – Continue reading
SEATTLE — When someone in Seattle buys a copy of Office at a Microsoft Store, that cash doesn’t take the short route to the company’s area headquarters. Instead, after accounting for state taxes, the profit goes to a Microsoft sales subsidiary in Nevada. From there, much of that money begins… – Continue reading
This is apropos a Business Recorder news item ‘Investment in Dubai real estate: NAB asks FBR to verify claims of Transparency International-Pakistan ‘. According to the report, the National Accountability Bureau (NAB) has asked the Federal Board of Revenue (FBR) to verify claims of Transparency International-Pakistan on a huge investment… – Continue reading
Dr Peter Phillips, the finance minister, is about to undo all the good he has done with the economy by implementing the proposed transfer pricing regime. The Government assures the country that this unconstitutional transfer pricing mechanism isn’t a tax, but an attempt to get affected businesses to pay their… – Continue reading
MUMBAI: The Reserve Bank of India has tightened norms for banks lending to overseas subsidiary of Indian companies by raising the provisions substantially against these loans. On Thursday, RBI said that banks can extend loan to overseas subsidiaries of Indian corporates but they have to make 2% of the loan… – Continue reading
THE COUNCIL OF THE DISTRICT OF COLUMBIA (DC) recently enacted, as part of its budget, provisions that force entities doing business in any of 39 arbitrarily designated “tax havens” to report their income on worldwide combined reporting. Eighteen are Caribbean jurisdictions. A tax haven is defined by the DC code… – Continue reading
An Inter-Governmental Agreement between India and USA was signed for implementation of Foreign Account Tax Compliance Act (FATCA). The Government of India has also joined the Multilateral Competent Authority Agreement (MCAA) for Automatic Exchange of Information as per Common Reporting Standard (CRS). For implementation of FATCA and CRS, necessary legislative… – Continue reading
A deadline for comments on the draft guidelines to determine the tax residency of a foreign company has been extended to January 9. The government felt the need to determine a company’s place of effective management due to lack of detail in the Income Tax Act leading to the possibility… – Continue reading
Although President Barack Obama likes to snarl about the unfairness of income inequality, under his administration, the 400 top earning American families now pay about one-third less of their income in taxes than under President Ronald Reagan. The IRS each year tabulates the effective tax rates paid by 400 individual… – Continue reading
HMRC said the amount of money in tax avoidance schemes has fallen from £3.2bn in 2013 to £1bn All but two UK-registered banks have signed up to a Government scheme encouraging lenders to avoid using tax avoidance schemes. Some 303 lenders, including banks and building societies, have now signed up… – Continue reading
Returns on Treasury Bills or Bonds, will incur 8 percent income tax. Beginning today 1st January, 2016 all foreign investors on Ghana’s local capital or investment markets will pay 8% Withholding Taxes on their returns. This is according to the new Tax Act passed in Parliament in September 2015 and… – Continue reading
Georgia and Iceland are stepping up their bilateral cooperation in taxation and customs affairs. Today a cooperation agreement on avoidance of double taxation, prevention of evasion of income and capital taxes, came into force. The agreement initially was signed in May this year when Finance Ministers of Cyprus, Liechtenstein and… – Continue reading
The year 2015 was arguably a momentous one for transfer pricing (TP). A combination of local and international developments will mark it as a period which defined the future direction of this subject. Key Developments The Organization for Economic Cooperation & Development (OECD) released final reports as part of its… – Continue reading
ONE | A NEW LIBERAL GOVERNMENT Elected in October 2015, Canada’s new Liberal government has proposed a tax platform featuring significant changes, including a four per cent increase (to 33 per cent) in the federal tax rate for individuals on income over C$200,000 and a 1.5 per cent drop in… – Continue reading
Bermuda has “long been a popular tax haven” according to a story by gobankingrates.com, which ranked the island as one of the “top 10 best tax havens in the world.” The story said “Bermuda has long been a popular tax haven, said Ravi Ramnarain, an independent certified public accountant. “Wealthy… – Continue reading
The Minister of Finance has announced a decision on international information exchange based on the FATCA agreement. This decision contains a publication of the concluded in November 2015 between the competent authorities of the Netherlands and the US administrative arrangements for the practical application of the FATCA agreement EN-US 2013… – Continue reading
An Inter-Governmental Agreement between India and USA was signed for implementation of Foreign Account Tax Compliance Act (FATCA). The Government of India has also joined the Multilateral Competent Authority Agreement (MCAA) for Automatic Exchange of Information as per Common Reporting Standard (CRS). For implementation of FATCA and CRS, necessary legislative… – Continue reading
VietNamNet Bridge – The agreements on double taxation avoidance that Vietnam has signed with other countries is one of the reasons that have made it impossible for state agencies to clarify the suspected cases of multinational conglomerates conducting transfer pricing. A lot of multinational conglomerates such as Coca-Cola, Metro Cash… – Continue reading
Two Swiss banks will pay a total of more than $107 million to the U.S. Department of Justice to avoid possible prosecution for helping Americans evade taxes, the department said on Thursday. Bank Lombard Odier & Co. Ltd, a Geneva-based unit of Lombard Odier Group, will pay $99.8 million in… – Continue reading
One of the leading Swiss banks Julius Baer Group AG is set to reach a deal with US authorities over a tax probe by paying $547 million early next year. Julius Baer, Switzerland’s third-largest wealth manager after UBS and Credit Suisse has been under criminal investigation since 2011 by the… – Continue reading
In order to exchange information aimed at curbing tax evasion and avoidance, Union Cabinet chaired by the Prime Minister Narendra Modi approved the signing and ratification of an agreement between India and Maldives. The Agreement will stimulate effective exchange of information between the two countries which will help curb tax… – Continue reading
The Caribbean territory Saint Kitts and Nevis has set out plans to amend the territory’s international tax rules in its 2016 Budget. The Budget is said to target “the potential for abuse through the use of transfer pricing techniques,” which the Government said “not only affects the withholding tax regime… – Continue reading
On January 1, 2016, the new standard for automatic exchange of information between tax authorities developed by the OECD (the “Common Reporting Standard”) becomes effective in the Cayman Islands, Bermuda, the British Virgin Islands, Guernsey, Jersey and a number of other jurisdictions that are part of the “Early Adopters Group.”… – Continue reading
On December 30, 2015 on the website of the Dutch Staatscourant the text of the Competent Authority Arrangement between the Competent Authorities of the United States of America and the Kingdom of theNetherlands was published. The Competent Authority Arrangement between the Competent Authorities of theUnited States of America and the… – Continue reading
The Luxembourg Parliament in December 2015 approved tax measures affecting both corporate and individual taxpayers. These provisions generally are effective beginning 2016, with a few measures applying retroactively as from 2015. Among the measures in the tax legislation are the following provisions: Transposition of amendments to the EU Parent-Subsidiary Directive… – Continue reading
China’s central bank has suspended at least three foreign banks from conducting some foreign exchange business until the end of March, three sources who had seen the suspension notices told Reuters on Wednesday. Included among the suspended services are liquidation of spot positions for clients and some other activities related… – Continue reading
Multinational companies have enjoyed a sustained period of falling corporate tax rates around the world. However, with the conclusion of the OECD’s base erosion and profit shifting project earlier this year marking the start of fundamental changes to the international tax system, and with governments more determined than ever to… – Continue reading
As the year comes to an end, the Cyprus Parliament in its last session before the holidays passed a series of tax updates attempting once again a balancing act between flexibility and tax transparency. Some of the most important provisions passed include the FOREX Neutralisation which targets the significant exchange… – Continue reading
The Office for Budget Responsibility says some areas of scheme are underperforming compared to expectations George Osborne’s plan to crack down on tax avoidance has fallen £600m short of its hearalded benefits, according to an analysis by a Government watchdog. The Office for Budget Responsibility (OBR) said in an analysis… – Continue reading
KUWAIT CITY, Dec 26: The US passports of some 6,000 Kuwaitis, among other 250,000 GCC citizens are vulnerable to sanctions by early next year unless they pay their taxes next month, according to the Foreign Account Taxes Compliance Act (FATCA), reports Al- Shahed daily. As of the beginning of January… – Continue reading
Expats who buy a property in New Zealand and sell it within two years could face a new property tax that citizens of the country will not have to pay. The Residential Land Withholding Tax (RLWT) is part of a Bill currently going through Parliament that is set to be… – Continue reading
Tax cheats are facing a series of year-end deadlines to come clean, as an international dragnet affecting both wealthy Canadians with offshore accounts and Americans in Canada who have failed to file U.S. tax returns keeps tightening. Lawyers say some Canadians with Swiss bank accounts have received letters demanding written… – Continue reading
The World Captive Forum takes place in Florida next month Bermuda’s business chiefs will be out in force at next month’s World Captive Forum. The event, to be held in Florida, will include several speakers from Bermuda including lawyers, regulators and business leaders. And Bermuda delegates will use the event… – Continue reading
