Category: Income Tax

Worldwide: The OECD’s Conquest Of Domestic Tax Codes: Understanding The Costs And Consequences Of The BEPS Project

Authored by IFC Media Recent global events from the release of the Panama Papers to a series of high-profile inversions have given international tax regulators both rhetorical ammunition and public support to execute a global crackdown on multinational tax planning. The goal is to increase total taxes paid by global… – Continue reading

Amended tax treaty with the Isle of Man comes into force

The amended double taxation agreement between the UK and the Isle of Man has entered into force, effective from 5 January 2017, following the latest arrangements signed on 8 March 2016. The bilateral agreements between the UK and the Isle of Man concern cooperation in tax matters through the exchange… – Continue reading

Curbs on black money abroad: Govt revising tax treaties to share data with ED, CBI

Sources said this amendment will allow speedy prosecution and imprisonment of account holders as enumerated in the Panama Papers, Liechtenstein and HSBC Geneva lists. Moving to register criminal charges and impose stricter penalties against those who have stashed black money abroad, India has started revising tax treaties with partner countries… – Continue reading

A Classic Case Of Double Taxation?

The Central Board of Direct Taxes in India issued Circular Number 41 on December 21, 2016 providing clarifications on applicability of ‘indirect transfer’ provisions under the Indian Income Tax Act, 1961 to investors of Foreign Portfolio Investors (FPIs) – earlier known as Foreign Institutional Investors (FIIs) in India. The circular… – Continue reading

Georgia establishes tax free relations with Liechtenstein

Georgia and Liechtenstein are increasing economic cooperation by avoiding double taxation, meaning that people or businesses working between the two countries will be free from income and capital taxes. The deal was signed in May 2015 in Georgia’s capital Tbilisi but entered into force today. Double taxation is the levying… – Continue reading

Ukraine: New Tax Reform Law adopted by Parliament

On 8 December 2016 the Ukrainian Parliament adopted in its first reading the Draft Law No. 5368 “On Amendments to the Tax Code of Ukraine (regarding improving the investment climate in Ukraine)” (hereinafter the “Tax Reform Law”). The Tax Reform Law will introduce among other things changes to VAT administration,… – Continue reading

South African Tax Bills Approved By Parliament

South Africa’s Ministry of Finance has published the 2016 Taxation Laws Amendment Bill (TLAB), which has received parliamentary approval and gives effect to the tax changes announced in the Budget in February this year, together with legislation confirming the final details of the Special Voluntary Disclosure Program (SVDP). With changes… – Continue reading

Govt asks tax cheats to come clean by March, releases mail id for black money tip-offs

The government announced on Friday details of a more stringent income declaration scheme, a “last chance” for tax evaders who will have to cough up 50% of their unaccounted-for wealth in tax. The scheme– called the Pradhan Mantri Garib Kalyan Yojana (PMGKY) – was announced last month and will be… – Continue reading

Corporate tax-dodging in Australia costs billions

Two reports on company taxation show that more than a third of the largest companies operating in Australia paid no tax in 2014–15 and that multinational tax evasion cost an estimated $4.8 billion that year. These reports show the fraud of the claims being made by the Australian government and… – Continue reading

Italy to target non-doms with new tax regime

Italy is to introduce a remittance-style tax regime aimed at attracting non-domiciled high net worth residents, just as the UK makes its rules in this area less attractive post the Brexit vote. The new measure in Italy’s Finance Bill for 2017 was approved by parliament last week, before its prime… – Continue reading

India removes Cyprus from tax blacklist

Cyprus has been formally removed from India’s tax blacklist and will now not be considered as ‘non-cooperative’ jurisdiction for income tax purposes. The Central Board of Direct Taxes (CBDT) has issued a notification, rescinding it’s executive order blacklisting the island nation from November 1, 2013. Cyprus, a popular tax haven,… – Continue reading

Gov’t keen to tax operations with offshore companies

Azerbaijan’s Taxes Minister Fazil Mammadov announced that operations with offshore companies are planned to be a subject of taxation in the country. Mammadov spoke about the changes to the Tax Code in a meeting of Azerbaijan’s parliamentary committee on economic affairs, industry and entrepreneurship. In tote, some 201 amendments and… – Continue reading

PBC urges Dar to ask FBR to go easy on super tax

Pakistan Business Council (PBC) has approached Finance Minister Ishaq Dar to stop the Federal Board of Revenue (FBR) from recovery proceedings of Super Tax against non-resident companies on dividend income from their investments in Pakistan. Sources told Business Recorder here on Tuesday that the PBC has urged the Finance Minister… – Continue reading

Double taxation: Ecuador, Italy sign agreement to foster private investements

Ecuador signed an agreement with Italy to define the tax obligations of the citizens of the two countries, in order to avoid double taxation on income taxes and equity and prevent tax evasion, the Ecuadorian Foreign Ministry said. “This protocol modifies the agreement signed in Ecuador and Italy in 1984… – Continue reading

Rate Competition Is New International Tax Planning Reality

Lower corporate tax rates around the world are expected to play an important part in multinational companies’ tax planning in 2017, with a rate as low as 15 percent on the table in the U.S. and countries such as the U.K. planning to maintain or lower their current rates. A… – Continue reading

Ukraine: Tax Residency Status: Issues To Consider When Moving Abroad

Recent social and economic developments have had a powerful impact on many Ukrainian citizens and businesses and have led them to look for a better life beyond the borders of Ukraine. Obviously, Ukrainians moving abroad is not something new. Periods of economic crisis in almost every state are usually accompanied… – Continue reading

Final opportunity to disclose offshore assets before 1 May 2017 introduced by Finance Bill 2016

1. Why was a new offshore provision introduced by this year’s Finance Bill? Following revelations in the “Panama Papers” of major worldwide tax evasion in April 2016 (which included certain Irish Resident account holders), the Minister for Finance announced on budget day, 12 October 2016 that this year’s Finance Bill… – Continue reading

Bermuda is world’s worst corporate tax haven, says Oxfam

Four UK territories in list ‘undermine Britain’s efforts to be responsible member of the international community’ Bermuda is the world’s worst corporate tax haven, according to a list by Oxfam, which includes three other UK territories among those it names and shames. The charity’s list of the “world’s worst” 15… – Continue reading

Pak-China avoidance of double taxation treaty inked

ISLAMABAD – Pakistan and China signed third protocol to the avoidance of double taxation agreement that would allow a Chinese bank and a state-owned investment fund to avail income tax exemption on interest income from loans for energy projects under China-Pakistan Economic Corridor (CPEC). Federal Board of Revenue (FBR) Chairman… – Continue reading

Italy: Italy Set To Introduce A Territorial System Of Taxation

Italy is considering a proposal to introduce a territorial system of taxation to attract high net worth individuals, including successful individuals in the sports, arts, and fashion and design sectors, who could be interested in moving to Italy to take part in these thriving sectors. The new measure is contained… – Continue reading

Final Response to Non-Dom Consultation Published

In Depth There is mixed news for affected individuals, including far-reaching changes relating to offshore trusts and a further wait (possibly until March 2017) for the rest of the draft legislation. The following are highlights from the government’s response and the draft legislation. Deeming Provisions Deemed Domiciled: Non-doms will become… – Continue reading

UK – FIRMS RESPOND WITH CONCERN OVER PUBLISHED IR35 PUBLIC SECTOR REFORMS

Draft legislation for the public sector IR35 reforms was published yesterday and several firms have responded concernedly to the publication of the documents. IR35 legislation reforms were proposed recently during the Autumn Statement. Julia Kermode, chief executive of The Freelancer & Contractor Services Association, commented on the publication of the… – Continue reading

Planning for the Use of the United States as a Financial Haven: Part One

The United States has not agreed to participate in the Common Reporting Standard (CRS), relying instead on the Foreign Account Tax Compliance Act (FATCA) regime enacted in 2010 and initiated in 2014. United States participation in CRS is highly unlikely. Even with a change in control of Congress, CRS may… – Continue reading

EU Mulls ‘Substance Test’ to Determine Zero-Rate Tax Havens

European Union member countries are considering a “substance test” to determine whether a country or jurisdiction with a zero corporate tax rate qualifies as a tax haven that doesn’t reflect “real economic activity.” After a host of EU member countries rejected in early November the use of a zero corporate… – Continue reading

OFFSHORE TAX HAVENS COST SMALL BUSINESSES ON AVERAGE $5,128 A YEAR

Small businesses in the U.S. have to shoulder, on average, an extra $5,128 in taxes to make up for the revenue lost due to the abuse of offshore tax havens by multinational corporations, according to a new report by U.S. Public Interest Research Group Education Fund. As a new administration… – Continue reading

OECD Says Trump Tax and Spending Plans Will Boost Global Economy

A resurgent U.S. economy would help offset softness elsewhere in the world. Global growth will pick up faster than previously expected in the coming months as the Trump administration’s planned tax cuts and public spending fire up the U.S. economy, the OECD said on Monday, revising up its forecasts. In… – Continue reading

Taxman targets Real and Barca over fraud, says report

Giants Real Madrid and Barcelona are among five La Liga clubs from whom the Spanish taxman is looking to recover €52 million (RM244 million), online newspaper El Confidencial claimed yesterday. Alongside Atletico Madrid, Sevilla and Valencia, the big two are accused of having avoided tax by paying player’s agents directly…. – Continue reading

The IRS Must Adapt to Cryptocurrency, Not Accuse Bitcoin Users of Tax Avoidance

In light of the Coinbase case, expert Perry Woodin explains how the American tax system needs to deal with Bitcoin. It was recently reported that the IRS filed a petition in US federal court seeking full disclosure of Coinbase’s American customers records over just two alleged cases of tax avoidance… – Continue reading

U.K. Seeks to Incorporate Nonresident Companies Into Tax Regime

The U.K. government said it would investigate bringing nonresident companies’ income into the country’s corporation tax regime. The consultation on the move is expected to begin at Budget 2017 in March, the Treasury said in its Autumn Statement Nov. 23. “The government wants to deliver equal tax treatment to ensure… – Continue reading

Microsoft agrees to more transparency on taxes in Australia

The Australian government is one of the most aggressive in highlighting the issue of multinational corporations avoiding taxes through extensive use of tax havens. Microsoft’s Australian subsidiary will start disclosing the amount of tax it pays in Australia, opting in to a government-transparency program aimed at shedding light on the… – Continue reading

SNP MP warns that tax office cuts will lead to an increase in the gap between the rich and poor

TAX office closures will lead to a surge in the gap between rich and the poor and an increase in tax avoidance as well as people not being paid the minimum wage, the UK Government has been warned. Under controversial HMRC plans 18 Scottish offices, including major centres in Dundee,… – Continue reading

Tens of millions of dollars of revenue lost through dodgy trust structures

Just a handful of dodgy tax structures being used by Australians cost tens of millions of dollars in lost revenue, according to the Australian Taxation Office. That could mean many millions more are missing, and is why the ATO is cracking down on people misusing trusts. The agency has long… – Continue reading

Finland allowed to tax pensioners in Portugal

Following pressure from the Finnish government and public opinion in the Scandinavian country, Helsinki has announced a deal which will allow it to come after expat pensioners, who are residing in Portugal, for income tax payments from which they were previously exempt. Other EU states have also expressed their aversion… – Continue reading

Dispute resolution under the Nigerian transfer pricing regime

Background The Federal Inland Revenue Service [FIRS] has begun Transfer Pricing [TP] audits and has been requesting TP documentation and other documents from taxpayers relating to their related party transactions. These actions are in line with its powers under the Income Tax (Transfer Pricing) Regulations No. 1 of 2012 [Regulations]… – Continue reading

Labour and unions demand action on temp agencies’ tax avoidance

Opposition vows to shut down scheme that uses ‘contrived’ financial arrangements to slash national insurance bills Labour and trade unions have called on the government to take action after a Guardian investigation found that an aggressive tax avoidance scheme used by temporary recruitment agencies is depriving the taxpayer of “hundreds… – Continue reading

Cayman may find itself on EU’s ‘non-cooperative jurisdictions’ list

Cayman could find itself on a new EU list of “non-cooperative jurisdictions” in tax matters after the European Council of finance ministers published the criteria for including third countries in the blacklist last week. The provisions emphasize that a jurisdiction “should not facilitate offshore structures or arrangements aimed at attracting… – Continue reading

Penny stocks may come under long-term capital gains tax net

Mumbai: The government plans to withdraw tax exemption on long-term capital gains (LTCG) made on the sale of penny stocks to end the use of stock markets for tax evasion as part of a series of steps to eradicate black money, two people familiar with the development said. “The government… – Continue reading

Australian ­Taxation Office turns to Facebook to catch cheats

Social media posts, private school records and immigration data are being used by the Australian Taxation Office as part of an increasingly sophisticated crackdown on tax cheats that yielded nearly $10 billion last year. ATO Commissioner Chris Jordan said the tax office had been investing in data collection analysis of… – Continue reading

Americans Are Renouncing Citizenship Over FATCA Tax Law, Not Donald Trump

The number of individuals who renounced their US citizenship for Q-3 of Y 2016 was the 2nd-highest in history at 1,380, US Treasury Department reported. The Foreign Account Tax Compliance Act (FATCA), which enacted in Y 2010, and took years to implement, is “having an impact, perhaps bigger than these… – Continue reading

Significant Change In CRA Policy Harms Canadian Investors In US LLPs And LLLPs

Earlier this year the Canada Revenue Agency (“CRA”) announced its new administrative position that limited liability partnerships (“LLPs”) and limited liability limited partnerships (“LLLPs”) formed under the laws of Delaware and Florida are properly viewed as corporations for Canadian income tax purposes. It is widely expected that LLPs and LLLPs… – Continue reading

How Donald Trump’s tax plan might save Apple billions of dollars

Over the past few years, Apple’s cash hoard has swelled to near unthinkable levels. Per the company’s most recent earnings report, Apple now has more than $237 billion in cash and other securities, anchored of course by the company’s insanely lucrative iPhone. Though the iPhone only has a thin slice… – Continue reading

FBR to file FIRs against owners of offshore companies

ISLAMABAD: The Federal Board of Revenue (FBR) is making preparation for registration of FIRs against those selected individuals who owned offshore companies and were named in Panama/Bahamas Leaks but failed to comply against the sent-out tax notices within the stipulated timeframe. The FBR found 114 cases whereby individuals were non-compliant… – Continue reading

Trump’s Corporate Tax Reforms: What CFOs Need to Know

While Trump wants to close loopholes, many of them stem from public policy concerns — not “special interests.” After a dramatic upset victory in one of the most bitterly contested presidential races in recent history, Donald Trump now has some serious work to do. His corporate tax policies—which are vital… – Continue reading

U.S. Multinational Companies Owe $700 Billion In Taxes On Offshore Profits, New Research Shows

American multinational corporations are apparently dodging nearly $700 billion in U.S. taxes they owe on profits stockpiled offshore, according to a new “corporate tax chartbook” from Americans for Tax Fairness (ATF) and the Economic Policy Institute (EPI). Last year, Fortune 500 companies had $2.4 trillion in untaxed offshore profits, on… – Continue reading

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