Portugal’s non-habitual residence (NHR) regime – 10 years of tax benefits
You may consider moving to the Algarve for a healthier, more relaxed lifestyle. ... - Continue reading
Category: Interest
The UK and Luxembourg Signed A New Double Tax Treaty
On 7 June 2022, a new Double Tax Treaty (the “DTT”) has been signed between Luxembourg and the United Kingdom (UK) to reflect the most recent OECD tax standard. ... - Continue reading
United States: US FinCEN Proposes Expansion Of SAR Sharing Rules
The Bank Secrecy Act ("BSA"), enacted in 1970 and amended most recently by the Anti-Money Laundering Act of 2020 ("AML Act"), was in intended to provide "appropriate frameworks for information sharing" among financial institutions, government authorities and others.2 The BSA provides for the reporting of suspicious transactions, authorizes the secretary of the Treasury (the "Secretary") to issue regulations and allows the Secretary to delegate to the director of FinCEN the authority to "take all necessary and appropriate actions to implement and administer the provisions of the [BSA]."3 ... - Continue reading
Russia submits a proposal to revise the DTT with Switzerland
The Russian Ministry of Finance has sent a proposal to its Swiss colleagues requesting amendments to the current double taxation treaty (DTT) between Russia and Switzerland ... - Continue reading
Poland APA statistics reveal alarming trends
Poland’s National Tax Office has published statistics for its advance pricing agreement (APA) program, updated for 31 December 2020. ... - Continue reading
Often Overlooked Exception to Withholding and Reporting Requirements under FATCA
An often overlooked exception to U.S. withholding taxes may result in a lower overall U.S. tax burden. ... - Continue reading
7 Ways You’re Accidentally Committing Tax Fraud
Not every fraud artist is a sketchy identity thief or faux Nigerian prince from the dark corners of the internet. In fact, you might end up committing accidental tax fraud or accidental tax evasion yourself if you don’t pay careful attention during this tax season. ... - Continue reading
Cyprus: Cyprus – Russia Double Tax Treaty
Cyprus strikes a deal on Double Tax Treaty with Russian Government The Republic of Cyprus and Russia had entered into a Double Tax Treaty (DTT) in 1998 in a joint effort to avoid the double taxing of income and capital generated in Cyprus, in order to promote the economic cooperation between the two countries. Since its introduction, the DTT has been the catalyst for Russian investment in Cyprus, being an attractive jurisdiction with regards to its tax benefits. ... - Continue reading
IRS changes procedure for reporting tax shelters
The Internal Revenue Service is temporarily allowing taxpayers who engage in so-called “reportable transactions,” typically tax shelters, to fax the Form 8886 for initially disclosing them to the IRS instead of mailing in the form. ... - Continue reading
Bermuda: Enforcement Of Judgments 2020 – Trends And Developments
Bermuda is a self-governing overseas territory of the United Kingdom. It has a population of over 60,000 people on a land mass of just 21 square miles. The island group is located in the Atlantic Ocean, approximately 760 miles due east of Cape Hatteras, North Carolina. Surrounded by coral reefs and the Gulf Stream, Bermuda remains a popular destination for tourists but its infrastructure, flexible and innovative corporate structures and strong regulatory environment have made it a leading offshore jurisdiction for company incorporations, including for a number of companies listed on the main New York and Hong Kong stock exchanges ... - Continue reading
Wilful income tax evasion may land you in jail for up to seven years
Cases where the amount of tax sought to be evaded or tax on under-reported income is lesser than ₹25 lakh, the person can be punished with imprisonment of at least three months and up to two years and with fine. ... - Continue reading
Canada: Don’t Let Your Dream Vacation Home Become A Tax Nightmare
Renting your foreign property may require you to disclose information to the Canada Revenue Agency (the "CRA"). A Foreign Income Verification Statement is required to be filed with the CRA where the adjusted cost base of the property exceeds CDN $100,000. ... - Continue reading
OECD publishes model rules for tax reporting by gig economy platform operators
On 3 July, the OECD released model rules for tax reporting by platform operators that assist sellers in the sharing and gig economy. Following international efforts to address the tax challenges in the digital economy, this OECD guidance represents an important step towards transparency through the exchange of information. ... - Continue reading
EU to launch tax observatory
The EU’s awareness of the relevance of tax policy is clear. On 6 July, the European Commission called for proposals for the creation of an EU tax observatory. This follows the adoption of the Commission Decision on the financing of the preparatory action EU Tax Observatory – Capacity building to support Union policy making in the area of taxation and the adoption of the annual work programme for 2020 on 16 June. ... - Continue reading
Norway proposes new withholding tax on some related-party payments
Authorities of Norway come up with new withholding tax rules. ... - Continue reading
Norway consulting on new withholding tax on interest, royalties
Norway’s Finance Ministry is consulting shareholders on a new proposal to introduce withholding tax on certain payments to non-resident related parties. ... - Continue reading
Panama: The ABC Of The Tax Amnesty In Panama Law 99 Of 2019
With this new legal initiative, the taxpayers have the opportunity to clear tax debts without interests, surcharges and fines and to file forms past due without penalties. ... - Continue reading
Peru tax authority guidance addresses deductibility of interest paid to non-residents
On September 20, the Peruvian tax authority issued guidance as to how to treat interest expenses on foreign debt. ... - Continue reading
Ireland Budget 2020 released
On 8 October, the Irish government announced its Budget 2020 measures. Brexit and climate change are core themes of new revenue measures and expenditure commitments. Brexit remains the foremost immediate concern for the Irish economy, whereas tackling climate change requires long-term commitments to tax and spending policies. ... - Continue reading
Worldwide: Financial Institutions And Personal Data
Combating Tax EvasionIn recent years, there have been several high-profile prosecutions for the crime of tax evasion (for example the actor, Wesley Snipes, and the footballer, Lionel Messi). Governments around the world have been making a concerted effort in an attempt to tackle this problem. Their objective is for their respective tax administrations to work together so that taxpayers pay the correct amount of tax in the correct jurisdiction. ... - Continue reading
Despite big corporate tax cut gains, ITC’s stock has not fired up enough
- News flow on the potential sale of an 8% govt stake in ITC held by SUUTI has weighed on sentiments, say analysts
- Sure, the tax cut gives ITC room to delay price hikes and that may prove helpful
Australia provides arm’s length debt test guidance
The Australian Tax Office on 28 August, released its awaited draft guidance contained in Practical Compliance Guideline 2019/D3, on applying the arm’s length debt test contained in Division 820 of the Income Tax Assessment Act 1997, Australia’s thin capitalization statutory provisions. ... - Continue reading
Bulgarian mandatory transfer pricing documentation rules enacted
A new law introducing mandatory transfer pricing documentation in Bulgaria was officially published in the State Gazette in early August. ... - Continue reading
Malaysia: Adding Confidence To Captives
When it comes to risk management, the adage "Failing to plan is planning to fail", rings truer than most. Risk management is vital in any business, and when a more cost-efficient and customisable alternative to outright insurance purchase is sought, captive insurance ticks all the right boxes. ... - Continue reading
German economics minister sees SMEs as “secret weapon”: report
German Minister for Economic Affairs and Energy Peter Altmaier had developed a strategy for the “Mittelstand” or small and medium-sized enterprises (SMEs), the newspaper Handelsblatt reported on Wednesday. “In the eyes of foreigners, SMEs are Germany’s secret weapon and, unlike the Dax 30 companies, SMEs are proving to be extremely… – Continue reading
Argentina: The OECD Guidelines For Multinational Companies And The Specific Instance
For over 20 years the Argentine Republic has adhered to the "OECD Guidelines for Multinational Companies" ("Guidelines"), through the "Declaration on International Investments and Multinational Companies" of the Organization for Economic Cooperation and Development ("OECD"). ... - Continue reading
Taxation of gifts to non-residents: A word of caution
The proposal intends to tax gift of money exceeding ₹50,000 made by residents to non-residents that were earlier claimed to be outside the ambit of India taxation ... - Continue reading
Taxability of annuity paid by Australian account depends on residential status
On July 12 the Netherlands government published a legislative proposal implementing the EU mandatory disclosure directive. This follows an internet consultation on a draft legislative proposal which ran from December 19, 2018 — February 1, 2019. ... - Continue reading
Malaysia Explains New Cap On Interest Expense Deductions
The Inland Revenue Board of Malaysia has released new guidance on restrictions to the deductibility of interest expenses. ... - Continue reading
Australian tax office addresses transfer pricing, debt-equity rule interaction
Tax authority of Australia takes measures on tax issues ... - Continue reading
Pakistan money in Swiss banks dwindling for last three years
LONDON: Money kept by Pakistani nationals and enterprises in Swiss banks fell by 33 per cent to a record low of CHF380 million (Rs63 billion) in 2018, falling below the level of Indian funds for the first time in four years, Swiss National Bank’s (SNB) annual statistics report showed on… – Continue reading
Cyprus: Cyprus–Kazakhstan First-Time Double Tax Treaty: Cyprus Ratifies
On 24 May 2019, Cyprus ratified the first-time double tax treaty it had signed with Kazakhstan on 15 May 2019 (the DTT). Certain legal procedures now need to take place in both states following which the DTT will ‘enter into force’. The DTT will be ‘in effect’ as from the… – Continue reading
NBR for 30pc job quota for Bangladeshis
The National Board of Revenue recommended that the proposed guidelines on local entrepreneurs’ overseas investment should include provisions that the interested businesses have no overdue taxes in Bangladesh and have to employ minimum 30 per cent Bangladeshis in overseas projects. The NBR made the suggestions in its observations sent last… – Continue reading
Madogo Residents Protest Over Tax
Transport along the Garissa-Nairobi highway was briefly interrupted Saturday, after angry residents barricaded the road to protest what they termed as double taxation by Tana River county government. Waving placards and twigs, the residents said since the beginning of the year, revenue clerks have been frequently visiting their business premises… – Continue reading
Tax court drops tax evasion against talent promoter
The Court of Tax Appeals (CTA) has cleared a model and talent promoter of tax evasion charges because the Bureau of Internal Revenue’s (BIR) final assessment notice (FAN) did not mention the date when the alleged deficiency taxes should be paid. The BIR filed the case after its national investigation… – Continue reading
Tax reforms and the future of the economy — Part V
Broadening of tax becomes a far cry on the face of the fact that the government machinery becomes ineffective by even enforcing return on the registered taxpayers. Today, less than 50 percent of the registered taxpayers in all the streams of revenue are filling their return and the remaining are… – Continue reading
Anti-tax avoidance measures come into force
A new raft of anti-tax avoidance measures came into force across the EU yesterday, as part of an ongoing effort to combat corporate abuse of tax systems. The Anti-Tax Avoidance Directive, first proposed in 2016, features rules based on global standards laid out by the Organisation for Economic Co-operation and… – Continue reading
Switzerland: The Brazil And Switzerland Double Tax Treaty: Why Is It So Significant?
Background The Brazilian and Swiss Governments signed a Double Tax Treaty (DTT) on 3 May 2018. Switzerland is one of the biggest investors in the Brazilian market and Brazil and Switzerland have already signed an Automatic Exchange of Information Agreement, which came into force on 1 January 2018. This new… – Continue reading
Has the New Inland Revenue Act paralysed the Double Tax Treaty Network of Sri Lanka? Part 2
7.What are Mutual Administrative Assistance Agreement (MAAAs) The new IRA defines the “Mutual Administrative Assistance Agreement” to mean a tax information exchange agreement or other international agreement for mutual administrative assistance in relation to taxation matters. Section 75 (5) of new IRA “Mutual administrative assistance agreement” means a tax information… – Continue reading
UK withholding tax on interest paid to non-residents
The UK does still have one significant disadvantage namely the 20% withholding tax imposed by UK domestic law on “yearly interest” that arises in the UK is paid to persons whose “usual place of abode” is outside the UK. The UK is normally regarded as an attractive location for the… – Continue reading
How to get a tax refund from SARS
Individuals that are in salaried employment have limited tax benefits. There are, however, certain tax benefits that may be used by individuals in salaried employment who are aware of the South African tax laws, notes Daniel Baines, author of ‘How to Get a SARS Refund‘. These can be grouped into… – Continue reading
Australia Announces Upcoming Guidance On Int’l Tax Matters
The Australian Tax Office has updated and added to its list of the guidance on international tax matters it intends to release this year. This month, the ATO intends to release a guide on corporate residency – central management and control in Australia [reference code 3838], to provide the ATO’s… – Continue reading
Tax Breaks Announced For Swiss ‘Too Big To Fail’ Banks
The Swiss Government is to ease the requirements on banks affected by the Too Big To Fail (TBTF) regime to ensure that they are not subject to an additional tax burden as a result of the legislation. The TBTF regime requires systematically important banks to have sufficient capital so that… – Continue reading
China Sets Out How To Determine Beneficial Owner For Treaties
On February 3, 2018, China’s State Administration of Taxation set out new rules on the disallowance of tax treaty benefits where an entity fails to demonstrate it is the beneficial owner of Chinese assets from which passive income is derived. A beneficial ownership requirement is introduced in treaties to prevent… – Continue reading
New CIT law aims to halt tax evasion
Viet Nam News HA NOI — In the latest draft of Law on Corporate Income Tax (CIT), the Ministry of Finance has raised a regulation aimed at preventing multinational companies with related-party transactions from evading taxes. According to the proposed regulation in the amended draft, the part of interest expense… – Continue reading
CRA finalizes new Information Circular for income tax Voluntary Disclosures Program
On December 15, 2017, the CRA released the final version of Information Circular IC 00-1R6 – Voluntary Disclosures Program (“VDP”) for income tax, after receiving and considering community input on the June 2017 draft version. This article summarizes the important differences between the draft and the final ICs and discusses… – Continue reading
VAIDS: FG Amnesty On Tax Defaulter Ends March 2018 – Fowler
The Executive Chairman, Federal Inland Revenue Service (FIRS), Mr. Babatunde Fowler has said federal government tax defaulters have until March 2018 to declare assets and income via the Voluntary Assets and Income declaration Scheme (VAIDS) or face the consequence. Fowler speaking at the media workshop programme in Lagos, recently, said… – Continue reading
Australian Tax and Cryptoassets
Australian tax rules relating to cryptoassets remain in their infancy, comprising largely of antiquated rules for fiat currency transactions, with impractical attempts at guidance from revenue authorities. This practical guide summarises the Australian tax issues for some typical cryptoasset transactions. In this innovative sector, no two transactions are the same…. – Continue reading
