Category: Exemptions

Multinationals Dodged Bullet on ‘Earnings Stripping’ Rules

Many kinds of U.S. multinational companies, including S-corporations, REITS, and financial services companies apparently dodged a bullet last month when the U.S. Treasury Dept. issued its final, substantially revised rules aimed at curtailing “earnings stripping.” The revised regulation represents an attempt by Treasury to help “narrow the rule and avoid… – Continue reading

Vulture funds may have to wait until Christmas to learn fate

Department of Finance receives ‘unprecedented’ lobbying from property funds Overseas investors in Irish property may have to wait for a further two months for clarity on how the Government plans to tax structures they have used to snap up billions of euro of real estate after the financial crisis. The… – Continue reading

Pakistan’s taxation crisis

Whether they indulged in legal tax avoidance or evaded taxes under the counter, leaked documents of a Panamanian firm revealed quite a lot in April about a number of Pakistani politicians and businessmen. Tax evasion has of late become synonymous with Pakistan because of its failure to overcome its taxation… – Continue reading

Ghana loses US$2.1 billion to tax evasion annually

Ghana loses nearly $2.1 billion dollars to tax evasion and incentives annually, reveals a study carried out by the Integrated Social Development Centre (ISODEC), a civil society organisation. According to the study, which was conducted on behalf of the National Coordinating Council of the Public Services International (PSI), there was… – Continue reading

Tax reform as new human rights agenda

Today, we see more enthusiasm for tax reform in Indonesia. Although opposed by some civil society groups, President Joko “Jokowi” Widodo’s administration continues to push its fiscal framework reform — which includes a tax amnesty and more incentives for taxpayers. Last year, the Finance Ministry issued a new tax holiday… – Continue reading

VAT tweaks to help offset income tax cut

THE FINANCE DEPARTMENT will keep value-added tax (VAT) exemptions for three key sectors, but may opt to remove this benefit from senior citizens and others to arrive at a “fair” tax regime. Finance Secretary Carlos G. Dominguez III told reporters late last week that the government is looking to trim… – Continue reading

IMF call for ‘comprehensive reform’ of US tax system

An International Monetary Fund (IMF) review has called for a comprehensive reform of the US tax system, with the aim of removing exemptions, simplifying the system, rebalancing from direct to indirect taxes, and reducing statutory rates for individual and corporate income taxes According to its annual Article IV consultation report… – Continue reading

Brexit – The UK and International Tax Consequences

The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications of Brexit, this OnPoint also considers some of the potential tax implications from the perspective of… – Continue reading

Bulgaria adopts controversial amendments to the “Offshore Companies Act”

On 15 June 2016 the Bulgarian Parliament adopted long discussed amendments to the so called “Act on Economic and Financial Relations with Companies Registered in Jurisdictions with Preferential Tax Treatment, their Related Parties and Actual Owners” (the “Offshore Companies Act”, or the “Act”). The Act was adopted in 2014 and… – Continue reading

Income tax: Know your taxes and exemptions

CHENNAI: The hardest thing in the world to understand is the income tax, is what Albert Einstein had famously said. Amid the long list of taxation categories, to assimilate what is taxable and what is exempted is hard. Even harder is to pay them, of course. As the June 15… – Continue reading

India-Mauritius tax treaty: An end and a new beginning

Recent news of India and Mauritius signing a Protocol to amend their 33 year old tax treaty caused seismic changes in the tax world. Though not completely unanticipated, the change is significant for foreign investors to go back to the drawing board and reassess their structures. The tax treaty between… – Continue reading

FBR seeks powers in Finance Bill to prevent tax evasions

The FBR has proposed powers through Finance Bill 2016-17 for entering into treaty with bilateral or multilateral forums for exchange of information to ensure prevention of tax evasions in the aftermath of Panama Leaks disclosure that many Pakistani influential owned offshore companies abroad. In totality, the FBR took tax measures… – Continue reading

EU finance ministers fail to agree on anti tax avoidance directive

The EU’s Economic and Financial Affairs Council (ECOFIN) has been unable to reach agreement on the European Commission’s proposed anti tax avoidance directive. The issue has therefore been postponed until the next ECOFIN meeting in June. The European Commission announced its proposed anti-tax avoidance directive (ATAD) in January. The proposed… – Continue reading

India-Mauritius Tax Treaty Renegotiated

On 10 May 2016, the Government of India issued a press release1 stating that India and Mauritius have signed a protocol (New Protocol) amending the double tax avoidance treaty between the two countries (the Treaty). Based on the press release and the New Protocol, following are the key changes to… – Continue reading

Reasons behind decrease in effective rate of sales tax identified

The effective rate of sales tax is within the range of 3 to 3.5 percent as compared to the standard rate of 17 percent sales tax due to massive tax evasion and illegal/inadmissible input tax adjustment claimed by the unscrupulous elements. Official sources told Business Recorder here on Saturday that… – Continue reading

Southeast State & Local Tax: Important Developments – March 2016

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast. VIRGINIA CORPORATE INCOME TAX Conformity with Internal Revenue Code. Virginia Governor Terry McAuliffe signed emergency legislation on February 5, 2016 that advances the state’s… – Continue reading

International and Irish Tax Update – March 2016

Summary The pace of change in international tax is dramatic. Each month brings new initiatives and developments at both national and supra-national levels. In this update, we focus on recent changes which are relevant to our clients. The OECD Base Erosion and Profit Shifting (“BEPS”) reports were finalised in October… – Continue reading

EPF tax row: Will it lead to double taxation?

Even employees earning below Rs 15,000 a month will be impacted if the Centre sticks to the plan of taxing 60% of EPF withdrawals The Budget has proposed significant changes on taxation of Employees’ Provident Fund (EPF). Given that EPF is at the core of the Indian social security system… – Continue reading

A closer look at the flat tax

Another form of taxation that has gotten greater attention during the last two presidential election campaigns is the flat tax. A flat tax is a plan that will apply the same rate to every taxpayer, regardless of the income they have earned. At present, federal taxes are calculated on a… – Continue reading

BEPS Action Plan 3: Designing effective controlled foreign company rules

A “controlled foreign company” (CFC) is, as the name implies, a foreign company or subsidiary owned by a parent company which is situated in a country different from the parent company’s country of residence. The tax laws of many countries, including the Philippines, do not tax the CFC’s parent company… – Continue reading

Clampdown on tax avoidance

“We are clear. We will not stand for a minority of taxpayers continuing to seek out unacceptable ways to reduce the amount of tax they pay, and we will ensure HMRC has the tools to robustly tackle such activity.” So said David Gauke, Exchequer Secretary to the Treasury. A clampdown… – Continue reading

Budget cost of family home tax breaks close to $55bn a year, says Treasury

Surge in revenue foregone by exempting family home from capital gains tax – largely driven by higher property prices – fuels fiscal policy debate The budget cost of tax breaks on family homes has reached nearly $55bn a year, fuelling debate about alternative options as the Turnbull government prepares its… – Continue reading

Canada: Tax Withholding Obligations Of Non-Resident Employers: Further Exemption Details Released

In its 2015 Budget, the Canadian federal government announced its intention to exempt “certified” non-resident employers from the obligation to withhold and remit income tax in respect of certain employees that perform duties in Canada. The Canada Revenue Agency (the “CRA“) recently released the application form that a non-resident employer… – Continue reading

Budget 2016: Budget may ease rules for offshore fund managers moving to India

In a move to woo offshore fund managers to locate in India, the Union Budget for 2016-17 is likely to relax conditions for them to avail of tax exemptions. Budget 2015 had announced some exemptions by amending the permanent establishment (PE) norms. The rules were changed to the extent that… – Continue reading

Infrastructure could suffer ‘collateral damage’ from international tax changes, experts say

FOCUS: Major infrastructure projects and other purely commercial transactions could suffer collateral damage from proposals to reform the international tax system and prevent avoidance by multinationals. Rising tax costs could put additional strain on the viability of key projects. Infrastructure projects are capital intensive and often have a high level… – Continue reading

Start-up investment in India to get capital gains tax exemption

PM Narendra Modi also announces a Rs.10,000 crore fund to provide support to innovation driven enterprises New Delhi:In an effort to give a fillip to the start-up ecosystem in the country, the government on Saturday announced its intention to exempt capital gains tax on investments in start-ups and a Rs.10,000… – Continue reading

CYPRUS TAX UPDATE

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

Ireland: the Tax Haven that Dare Not Speak Its Name

‘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