Tax residency certificate is required from the resident country tax authorities to claim applicable relief under the DTAA What is the purpose of a tax residency certificate? —Srivats Typically, source of income lies where the services are performed, or where the asset, from which the income arises, is located. Residential… – Continue reading
The Thai Revenue Department announced earlier this month that new legislation effective from April 2 increases penalties for those taxpayers committing tax fraud or evading their tax liability. In a statement accompanying the enactment of the Revenue Code Amendment Act (No.45) B.E. 2560, the Department revealed that such fraudulent activity… – Continue reading
The German Ministry of Finance has published a progress report on its 10-point plan to combat tax evasion, which was first announced in the wake of last year’s Panama Papers leak. The plan, launched on April 12, 2016, outlines the measures that Germany wants to put in place at domestic… – Continue reading
KUALA LUMPUR: The Inland Revenue Board (IRB) plans to increase its penalty to 100% for individuals and companies who evade paying their taxes or misreported tax. IRB chief executive officer Datuk Sabin Samitah said the new penalty scheme, an increase from the current 45% penalty imposed on unpaid tax, will… – Continue reading
As a rule and according to Article 33 of the Cyprus Income Tax Law, which introduces the arm’s length principle (using wording similar to that of article 9 of the OECD Model Tax Convention), all transactions between companies, including loan agreements/transactions by Cyprus companies, must be undertaken at arm’s length… – Continue reading
The Revenue Department on Friday said it has detected evasion of more than Rs 1.37 lakh crore in both direct and indirect taxes and identified over 1,000 shell companies which indulged in bogus transactions worth Rs 13,300 crore in the last three financial years. Warning tax evaders, it said the… – Continue reading
HMRC is to renew and extend the scope of the double taxation treaty passport (DTTP) scheme, which will now be available to all UK borrowers who are required to withhold income tax at the basic rate on certain loan interest payments to overseas lenders from 6 April 2017 The DTTP… – Continue reading
China’s new transfer pricing rules, effective May 1, endorse the continued use of the arm’s-length standard—the internationally agreed bedrock for pricing transactions within multinational enterprises. The new guidance, Bulletin 6, augurs well for resolving tax disputes between China’s State Administration of Taxation and the U.S. Internal Revenue Service over the… – Continue reading
Ukraine has ruled out major tax reform, in consultations with the International Monetary Fund. The IMF noted that Ukraine has major substantial progress on improving its finances. The IMF said budget execution continues to be strong, over-performing relative to program targets. The 2016 budget deficit has been limited to 2.3… – Continue reading
HMRC has launched a new hotline for the public to report fraud and evasion, replacing the existing two separate tax evasion and customs hotlines with one, in a bid to streamline information gathering on tax fraud. Individuals can report all kinds of tax fraud and evasion on the new hotline,… – Continue reading
Dedicated technical experts from the UK’s HM Revenue & Customs (HMRC) will visit all English Premier League, Championship and Scottish Premier League clubs over a three year period and review all compliance risks including payments to players, the government has said. The statement was made in Treasury Minutes containing the… – Continue reading
Hong Kong has signed agreements with Portugal and South Africa for conducting automatic exchange of financial account information in tax matters (AEOI), a Government spokesman said today (April 3). “We have been seeking to expand Hong Kong’s AEOI network with our tax treaty partners. The signing of agreements with Portugal… – Continue reading
HMRC has launched its Making Tax Digital for business pilot to test out its new reporting system, with a year to go before businesses with turnovers above the VAT threshold are required to switch to digital records and provide quarterly summary updates from April 2019 This month HMRC says it… – Continue reading
ANALYSIS: US-style deferred prosecution agreements (DPAs) should be introduced in Scotland to deal with corporate offending, according to a recent report by the global Organisation for Economic Cooperation and Development (OECD). Foreign bribery should attract significant penalties, and Scotland’s civil settlement regime is potentially too lenient, according to the report,… – Continue reading
Google says it paid 36.4m (AUD59.8m) in UK corporation tax in the last financial year, as the internet firm’s operations in this country remain mired in controversy. The US company, which was revealed early last year to have done a 130m (AUD213.7m) deal with the taxman covering 10 years of… – Continue reading
Move shows that Beijing is joining the global move against diversion of profits to low-tax jurisdictions Beijing on Saturday posted a new rule on scenarios that could trigger tax-avoidance investigations of multinationals, under¬lining its commitment to a global move to combat profit shifting. The new rule, posted on the website… – Continue reading
New Zealand has asked taxpayers for input on countries that lack the safeguards to ensure information automatically exchanged under the Common Reporting Standard (CRS) remains confidential. To comply with the new international tax information exchange standard developed by the OECD, the CRS, New Zealand must publish a list of jurisdictions… – Continue reading
As a reaction to the so-called “Panama Papers” the German legislator proposed, on 30 December 2016, a draft bill to combat tax avoidance (so-called Steuerumgehungsbekämpfungsgesetz – StUmgBG). The aim of the draft bill is to enhance the German tax authorities’ means to determine and reveal EU-foreign domicile company structures which… – Continue reading
The Government has told US lawmakers that Ireland has closed down a loophole on stateless entities and is “doing exactly what you would want every country to do to avoid tax abuse”. Last January, the Oregon Department of Revenue made a recommendation that Ireland be included as a ‘listed jurisdiction’… – Continue reading
KARACHI: Tax authorities have sought banks’ assistance to curb tax evasion by flagging suspicious financial transactions, sources said on Friday. The source said the Federal Board of Revenue (FBR) asked banks to share with the board details of foreign trade, detected under anti-money laundering laws. “The purpose for obtaining the… – Continue reading
HM Revenue and Customs (HMRC) is planning to make its Double Taxation Treaty Passport (DTTP) scheme available to all UK borrowers following a consultation on a legislative amendment. The DTTP scheme provides for Double Taxation Relief on UK loan interest payments made by a UK corporate borrower to overseas corporate… – Continue reading
Governments around the world are losing as much as half a trillion US dollars (£400 billion) a year in tax revenue due to so-called “profit shifting” by multinational companies, according to research. The research published by the Tax Justice Network found that poorer countries were hardest-hit by the practice, which… – Continue reading
ISLAMABAD: After Federal Minister for Finance Ishaq Dar took a ‘principled stand’, Pakistani and Swiss authorities are scheduled to ink a revised convention on avoidance of double taxation agreement today (Tuesday) here in the federal capital, enabling the Pakistani authorities to get information about dirty untaxed money of $200 billion… – Continue reading
Swiss bank, UBS Group AG UBS , and its French unit will be facing a trial in France against allegations that the bank helped its clients in that country to evade taxes. Notably, a five-year probe into such allegations was closed last year. Following this, the prosecutor’s office was supposed… – Continue reading
The 2017 Finance Bill was published on Monday 20 March, introducing dozens of initiatives with a focus on improving and modernising the tax system The Treasury said the bill, which is over 700 pages in length, “continues the government’s crackdown on tax avoidance” and “improves the fairness of the tax… – Continue reading
Multinational companies are now paying tax based on their Australian profits instead of shifting income to low-tax countries, officials say. CANBERRA, AUSTRALIA—Facebook, Google and other multinational companies are now paying tax in Australia based on their Australian profits instead of shifting income to low-tax countries since the government cracked down… – Continue reading
MUMBAI: The recent changes in the India and South Korea Agreement for Avoidance of Double Taxation provides recourse to taxpayers of both countries to apply for Mutual Agreement Procedure (MAP) in respect of transfer pricing disputes, and also to apply for bilateral Advance Pricing Agreements (APA) for APA period beginning… – Continue reading
Beware of the dreaded inheritance tax and changes to it from April 2017! Approximately 1.3 million Britons now live in Australia and Brexit may only increase this number! Many think that moving to Australia means they no longer need to worry about UK tax, but often they are not fully… – Continue reading
The Caribbean Community is looking at spending nearly quarter of a million dollars on a Washington-based consultant to lobby the Trump administration about the Foreign Accounts Tax Compliance Act. Cayman appears unlikely, however, to be affected by any lobbying – or even FATCA repeal – in the wake of last… – Continue reading
Value added tax is likely to be an irrecoverable cost, negatively affecting margins for the banking sector Dubai: The UAE and GCC banks that are facing increased regulatory burden from Basel III capital requirements and International Reporting Standards 9 (IFRS 9) are expected to face further pressure in terms of… – Continue reading
You might have thought you have enough on your plate getting to grips with anti-money laundering rules closely followed by FATCA – but it’s not over yet! Next off the block is the Automatic Exchange of Financial Account Information in Tax Matters (AEOI). The AEOI, which we first provided an… – Continue reading
Washington’s Foreign Accounts Tax Compliance Act, known as FATCA, will be assailed afresh as lawyers and lobbyists renew efforts to repeal the law as part of President Donald Trump’s tax reform. Washington-based Jim Jatras, a Republican and co-leader of the Campaign to Repeal FATCA, says “lots is happening,” and his… – Continue reading
A section of the president’s 2005 tax return revealed that about 85% of what he paid the IRS was incurred due to ‘alternative minimum tax’ Donald Trump’s leaked tax return reveals that the businessman had to pay tens of millions of dollars in a single year because of a tax… – Continue reading
Three BBC newsreaders are fighting attempts by HM Revenue & Customs to make pay back nearly £1m in unpaid income tax and national insurance. The Financial Times reports the three presenters – Joanna Gosling, David Eades and Tim Willcox – claim they were forced to set up personal service companies,… – Continue reading
The Portuguese parliament voted unanimously to pass a draft law by the Left Bloc that makes it mandatory to publish the annual total and destinations of transfers to offshore accounts, regardless of any ministerial decisions. Tax office statistics with the amounts transferred to offshore accounts were not published between 2011… – Continue reading
A tax tribunal has ruled against a stamp duty land tax (SDLT) avoidance scheme used by Crest Nicholson, one of the UK’s largest house builders, meaning it will have to pay the £1.3m it owes. HM Revenue & Customs (HMRC) challenged the artificial and complex arrangements made by the FTSE… – Continue reading
The new scanners by Kenya Revenue Authority at entry points has helped curb a multi-million-shilling tax evasion racket. The crooks had used all ways to beat the authority’s system to import luxury cars declared as toys or bicycles; scrap batteries that turned out to be Kenyan tea for export and… – Continue reading
It says anyone who has been involved in designing or overseeing tax-avoidance schemes using charities would be unlikely to pass the test People who have been involved in designing or overseeing schemes to avoid tax using charities are likely to be prevented from taking up senior roles in charities, according… – Continue reading
Under increasing international pressure, the Hong Kong government is considering expanding its Automatic Exchange of Information (AEOI) implementation by imposing broader information collection obligations, entering into more bilateral AEOI agreements at a faster pace, and possibly joining the multilateral AEOI agreement. Background Hong Kong legislated to adopt the OECD Common… – Continue reading
The Bureau of Internal Revenue (BIR) is drafting a proposed legislation making tax evasion an economic sabotage, a heinous crime which is not bailable. This was disclosed on Wednesday (March 8) by BIR Commissioner Caesar R. Dulay as he gave an update about the on-going validation of Mighty cigarettes with… – Continue reading
More tax is lost to onshore evasion or non-compliance than to offshore evasion and avoidance, and HMRC is armed with a raft of tools to curb the practice. In the second of a two part series, Jason Collins, a member of the CIOT’s management of taxes sub-committee and partner at… – Continue reading
Sometimes it can be hard to keep up with the avalanche of government announcements on tax avoidance and evasion. In the first of a two part series, Jason Collins, a member of the CIOT’s management of taxes sub-committee and partner at Pinsent Mason, provides an overview of the rapidly changing… – Continue reading
The United States Court of Federal Claims has turned down a claim from an Irish citizen that more than USD5m in US tax withheld on gambling winnings should be refunded under the US-Ireland double tax avoidance treaty. The claim was filed by the plaintiff, John P McManus, after USD5.22m in… – Continue reading
These three CGT exclusions have remained unchanged for five years. Over the last few years government has collected a significant amount of tax revenue by not fully adjusting the personal income tax tables for inflationary increases in earnings, thereby increasing the effective tax rate of individuals. A middle-class individual earning… – Continue reading
The Italian Revenue Agency is stepping up its fight against international tax evasion. The tax authority will focus on undeclared funds and income held abroad by Italian taxpayers who have become resident abroad since January 1, 2010. Controls will be based on selected lists, which will first target the most… – Continue reading
Each and every bank account is under our scanner to find out tax evasion, said CBDT chairman Sushil Chandra. The Central Board of Direct Taxes (CBDT) is examining several dubious companies and they would be removed from the website of Ministry of Corporate Affairs (MCA) if found to be shell… – Continue reading
South Korea’s tax authorities have been investigating the local importer of Toyota and luxury Lexus vehicles over suspected tax evasions since late 2016, industry sources said Friday. In November, the Seoul office of the National Tax Service (NTS) launched a tax audit into Toyota Korea over suspicions that it paid… – Continue reading
New legislative proposals aim to establish the BVI International Tax Authority (ITA) as a fully fledged independent government institution in the British Virgin Islands with its own legal personality, giving it autonomy over the performance of its functions. The ITA was initially established within the Ministry of Finance to administer… – Continue reading
The new Residence Nil Rate Band will allow people to pass on property to their descendants tax free. But some people need to take action now or risk missing out. In April, a major change to inheritance tax (IHT) law comes into effect with the launch of the Residence Nil… – Continue reading
India has entered into new bilateral advance pricing agreements (APAs) with the United Kingdom and Japan, India’s Central Board of Direct Taxes (CBDT) announced on February 28. The two APAs were entered into over the last week. The CBDT also signed seven unilateral APAs. The APAs signed pertain to various… – Continue reading
