Category: Tax Authority

Multinationals Warned on Coke’s $41 Million Israel Tax Claim

Israel’s $41 million tax demand from the Coca-Cola Co. on royalties from its Israeli licensee could mark the start of a wave of claims against U.S. and other multinationals with similar business operations in the country. That could lead to a conflict with U.S. and other authorities about which country… – Continue reading

Black money: Switzerland finds India’s data security laws ‘adequate’ for auto-sharing banking info

The notification follows hectic parleys between India and Switzerland for introduction of AEOI (Automatic Exchange of Information) under guidance of G20, OECD (Organisation for Economic Cooperation and Development) and other global organisations. Switzerland found India’s data security and confidentiality laws “adequate” for entering into an automatic exchange of information pact,… – Continue reading

US government delays Obama earnings-stripping rule deadline

The change converts tax-deductible interest payments employed by the schemes into taxable stock dividends. The U.S. government on Friday gave companies an extra year to comply with an Obama-era regulation meant to crack down on corporations that try to minimize their U.S. tax bills by shifting profits abroad to countries… – Continue reading

Irish Committee Calls For WHT For Overseas Artists

The Irish Parliament’s arts committee has recommended the introduction of a “foreign artists’ withholding tax (WHT) scheme.” The committee has released a report on the Government’s Culture 2025 initiative, which is intended to provide a framework for the development of Irish arts, culture, and heritage over the next eight years…. – Continue reading

2017 changes to the taxation of non-domiciliaries – deemed domicile status, rebasing, cleansing mixed funds, business investment relief

THE BENEFITS OF NON-DOMICILE STATUS An individual who is resident but not domiciled in the UK does not pay tax on overseas income and gains, as long as they are kept outside the UK and are not used to provide benefits in the UK. This is called the remittance basis… – Continue reading

HMRC tops £4bn in tax avoidance scheme crackdown

HM Revenue and Customs (HMRC) has collected more than £4bn through its controversial ‘pay now, dispute later’ accelerated payment notices rules, for people who have used a tax avoidance scheme. HMRC said that more than 75,000 accelerated payment notices (APNs) have been issued to people under enquiry for tax avoidance… – Continue reading

Company directors to make ‘uncomfortable’ tax disclosures

Companies will have to disclose “uncertain” tax positions, including amounts disputed by the Australian Tax Office, under new accounting rules designed to increase information available to investors. Australia will adopt international accounting guidance with effect from 2019 that RSM Australia national technical director Ralph Martin said would result in some… – Continue reading

Vizor Software’s Solution for FATCA & AEOI Selected by the Government of Bermuda, Ministry of Finance Treaty Unit

Global leader in cross-border information exchange for Tax Authorities has been selected by the Government of Bermuda, Ministry of Finance, Treaty Unit to meet Common Reporting Standards. Today, Vizor Ltd. announced the Government of Bermuda, Ministry of Finance, Treaty Unit has selected the Vizor for FATCA & AEOI Solution for… – Continue reading

Thousands of British expats could face tax penalties for undeclared cash: report

The first set of ‘hidden’ financial data about Britons living abroad is set to be handed to the UK’s Revenue & Customs later today, as part of the global transparency drive that has been introduced via a series of information sharing agreements across the world’s financial centres. As a result,… – Continue reading

BVI AEOI Update – CRS Deadlines and BVIFARS Opening

Common Reporting Standard The Government of the British Virgin Islands (“BVI“) has recently announced an extension to the deadlines for the notification and reporting obligations under the Common Reporting Standard (“CRS“). Under the extended deadlines for CRS, all BVI Reporting Financial Institutions now have until 30 June 2017 to enrol… – Continue reading

31 May deadline for filing automatic exchange of information (AEOI) returns

The deadline for submitting automatic exchange of information (AEOI) returns for the year ended 31 December 2016 is 31 May 2017 for financial institutions, and that this is the first year for common reporting standards (CRS) filing Returns should include reportable accounts for the financial accounts tax compliance act (FATCA),… – Continue reading

The common reporting standard and charities: do you have filing requirements with HMRC?

The Common Reporting Standard (the CRS) is, like FACTA (the Foreign Account Tax Compliance Act), an information exchange regime aimed at realising international tax transparency. Exchange of information under CRS is achieved by requiring certain bodies including banks and other “Financial Institutions”, to collect data and report some of it… – Continue reading

Why U.K. ‘Google Tax’ is Hitting British Plc

The U.K’s diverted profits tax was dubbed the ‘Google Tax’ even before its introduction in April 2015. Yet instead of netting foreign tech companies engaged in complex tax planning such as California-based Google Inc., only U.K. multinational companies outside the technology sector have issued warnings so far over the tax… – Continue reading

Corporate Criminal Offence: Failure to Prevent Facilitation of Tax Evasion

The Criminal Finance Act 2017 received Royal Assent on April 27, 2017, making its way onto the statute book before the halting of Parliamentary business ahead of this year’s general election. As well as giving enforcement agencies further powers to recover the proceeds of crime and tackle money laundering, the… – Continue reading

Data leak reveals details of 70,000 offshore firms in Malta, German state minister claims

Malta denies claims A data leak has revealed information about 70,000 offshore companies in Malta, a German state minister claimed this morning. North Rhine-Westphalia finance minister Norbert Walter-Borjans said the data also included information about several German corporations and up to 2,000 German taxpayers. Tax authorities in the city of… – Continue reading

UK: The UK Company: A New Alternative For International Investors?

This article is the first of a series of articles that looks at tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors. An essential feature of… – Continue reading

Voices UN seeks a broader transfer pricing role

Four of the most significant transnational organizations are working together to eliminate transfer pricing schemes and abuses. The four organizations—the International Monetary Fund, the Organization for Economic Co-operation and Development, the United Nations and the World Bank Group—are seeking to achieve global cooperation in tax matters. Transfer pricing is one… – Continue reading

Draft rules released to prevent tax evasion via unquoted shares

NEW DELHI: India’s apex body for direct taxes has proposed new rules for bringing the value of unquoted shares on a par with the fair market value of underlying assets, seeking to prevent tax avoidance by firms that use the historical acquisition cost to set the price of unlisted stock…. – Continue reading

‘Ball In Bahamas Court’ Over Tax Exchange Pledges

“The ball is in the Bahamas’ court” to meet its automatic tax information exchange commitments, a senior industry executive yesterday saying there is “no alarm” about this nation having to alter its approach. #Tanya McCartney, the Bahamas Financial Services Board’s (BFSB) chief executive, told Tribune Business that the private sector… – Continue reading

FBR initiates scrutiny of offshore transactions

KARACHI: The Federal Board of Revenue (FBR) has initiated audit of all those taxpayers who have made offshore transactions during the last six years, sources said on Tuesday. “All corporate and individual taxpayers, who have made offshore investments, have been selected for audit to check the tax concealment,” an official… – Continue reading

Survey finds low levels of awareness of new ‘failure to prevent’ tax evasion offences

A high percentage of UK executives are unaware of the impending introduction of new laws which could make a business’s failure to prevent tax evasion by its employees and agents a criminal offence, according to research by Pinsent Masons, the law firm behind Out-Law.com. In a YouGov poll of more… – Continue reading

Russia introduces draft law on country-by-country reporting requirements: implications for multinationals

A newly published federal draft law introduces Russia to a three-tiered approach to transfer pricing documentation and brings Russian regulations in this area in line with the OECD minimum standards under Action 13 of the Base Erosion and Profit Shifting (BEPS) Action Plan. The draft law, published by the Ministry… – Continue reading

Transfer Pricing Investigation in China: Understanding the Latest Adjustments

New transfer pricing regulations issued by the State Administration of Taxation (SAT), the Measures for Administration of Special Tax Investigation Adjustment and Mutual Agreement Procedures (“the Measures”), came into effect on May 1, 2017. The Measures consolidate China’s pre-existing regulations regarding self-adjustment and outbound payments with the new transfer pricing… – Continue reading

Tax treaty relief made easy

(Second of two parts) In last week’s article, we discussed the revised procedure to avail of tax treaty benefits for dividend, interest, and royalty payments under Revenue Memorandum Order (RMO) No. 8-2017. Under the amended rules, a tax treaty relief application (TTRA) is no longer required and withholding agents can… – Continue reading

How to Manage the tax Affairs of Foreign Managers

It often occurs that a multinational company employs a foreign manager based on an employment contract or secondment. In the first case, the Hungarian company is considered as the legal and economic employer, therefore the salary is payed directly by it. In the second case, the employee maintains the employment… – Continue reading

Deal that sends Canadian bank records to IRS is ‘illegal,’ lawyer tells U.S. committee

Witnesses call for repeal of Foreign Account Tax Compliance Act An agreement that has resulted in hundreds of thousands of Canadian banking records being sent to the U.S. Internal Revenue Service could violate the U.S. constitution, a congressional subcommittee heard Wednesday. Testifying before a subcommittee of the House Committee on… – Continue reading

FIRS, EFCC to launch anti-tax-fraud team

The Federal Inland Revenue Service (FIRS) and the Economic and Financial Crimes Commission (EFCC) are putting a new breath to the fight against tax fraud and evasion in Nigeria, as the two agencies will soon launch an anti-tax fraud and evasion team. This collaboration, according to the FIRS Executive Chairman,… – Continue reading

Newcastle United and West Ham raided in HMRC tax fraud investigation

Newcastle managing director Lee Charnley released after HMRC investigation Offices at St James’ Park and club training ground raided by tax authorities The offices of Newcastle United and West Ham United were raided on Wednesday morning and Chelsea confirmed they were asked to provide information as part of a wide-ranging… – Continue reading

Early adoption of tax common reporting standard problematic

Many of the data submissions made by early adopters over the next two months under the new common reporting standard (CRS) are likely to be rejected and returned for correction and resubmission, adding to compliance costs, according to predictions from Sovos, a global tax compliance solution provider The UK is… – Continue reading

India Initiates $5 Billion Tax Penalty Against Cairn Energy

Indian tax authorities have initiated a $4.75 billion penalty charge against Cairn Energy for failing to pay a capital gains tax demand of $1.58 billion on a 2006 transaction. Under Section 271(1)(c) of the Income Tax Act, Indian tax authorities can levy a maximum 200 percent penalty against transactions after… – Continue reading