Category: Interest

Guyana formally agrees to share US persons’ bank account info with IRS

Guyana and the United States (US) on Monday inked an agreement, clearing the way for this country to share bank account information about American citizens and permanent residents with the US to help stamp out offshore tax evasion. “Today’s signing makes a significant step forward in our countries’ efforts to… – Continue reading

Vatican advances financial clean-up with Italian tax deal

Individuals and entities that have accounts at the Vatican bank and are subject to taxation in Italy will have until mid-April to report to Italian authorities the income earned by their Vatican accounts. As part of ongoing efforts by the Vatican to increase financial transparency and accountability, an agreement between… – Continue reading

Ukraine and Luxembourg sign a Protocol modifying their double tax treaty

On 30 September 2016 Ukraine signed a protocol (the “Protocol”) modifying the not-yet-in-force Convention between the Government of Ukraine and the Government of the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital (the “Convention”)…. – Continue reading

100 Financial Centres Start Swapping Tax Data

Expats who have money or assets outside Britain can expect to start receiving letters from the UK tax man soon. Hundreds of thousands of letters are being drafted for expats who have returned to the country after spells abroad and for expats considered UK taxpayers who have had overseas assignments…. – Continue reading

S. Korea, Singapore to share financial info on local residents

South Korea said Friday it has signed an agreement with Singapore to share some financial information on their nationals residing in each other’s territory. It’s meant to help tackle offshore tax evasion and other illegal activities, the Ministry of Strategy and Finance said. Under the deal, the two sides will… – Continue reading

Facebook pays just £4million in tax while lavishing British staff with £165MILLION

Accounts show each of the firm’s 682 workers took home average of £242,000 each in 2015 Facebook lavished £165million on its UK staff last year, while handing the taxpayer just £4million. Accounts show each of the firm’s 682 workers took home average of £242,000 each in 2015. The bumper payout… – Continue reading

Vietnam plans new transfer pricing rules to curb tax fraud

Various agencies are expected to work together to draft a decree and keep the practice in check. In a move that signals Vietnam’s apparent stronger stance against tax evasion, the Ministry of Finance has sought to work with other ministries and agencies to draft a new decree on transfer pricing… – Continue reading

STUDY: 73% OF FORTUNE 500 COMPANIES USED TAX HAVENS IN 2015

In 2015, more than 73 percent of Fortune 500 companies maintained subsidiaries in offshore tax havens, according to “Offshore Shell Games,” released today by the U.S. PIRG Education Fund, Citizens for Tax Justice and the Institute on Taxation and Economic Policy. Collectively, multinationals reported booking $2.5 trillion offshore, with just… – Continue reading

CBDT signs five unilateral advance pricing agreements

India’s advance pricing agreements (APAs) programme crossed a milestone with the Central Board of Direct Taxes (CBDT) signing five more unilateral APAs. With the latest move, the total number of APAs entered into by the CBDT has reached 103. The five APAs signed on Friday pertained to diverse sector, that… – Continue reading

OECD BEPS tax avoidance plans fail to change tax approach

Nearly a year after release of the OECD Base Erosion and Profit Shifting (BEPS) anti tax avoidance action plan, which introduces changes to the treatment of interest deductibility and profit shifting, the majority of businesses have not changed their approach to tax compliance. The major economies in the G7 (83%),… – Continue reading

Private sector groups urge passage of FATCA legislation

Seven private sector organisations Tuesday called on the Trinidad and Tobago government and opposition to put aside their differences and ensure the country meets the September 30 deadline for the Foreign Account Tax Compliance Act (FATCA). They also warned that failure to do so could result in ”serious negative consequences”… – Continue reading

EU opens probe into tax deals between Luxembourg and Engie

European Union antitrust regulators opened a probe on Monday into tax deals granted by Luxembourg to French power utility Engie, stepping up the EU’s campaign against tax avoidance by multinationals. The European Commission said it had concerns the tax rulings granted by Luxembourg since 2008 appeared to treat the same… – Continue reading

Australia Singles Out Multinational Profit Shifting Arrangements

The Australian Taxation Office (ATO) has published two new taxpayer alerts that warn against international profit shifting by multinational companies. Taxpayer Alert 2016/11 concerns a new scheme that the ATO said attempts to avoid the Multinational Anti-Avoidance Law (MAAL). The MAAL applies to multinational groups that avoid a taxable presence… – Continue reading

U.S. Citizens Retiring Abroad: “Tax Trigger” Situations and Related Disclosure Forms

The following is a bolded checklist of important situations that may “trigger” a tax review by a skilled United States tax professional. Many of these situations also require a simultaneous review by a foreign tax professional. It is generally best practice for these tax professionals to work together to minimize… – Continue reading

Tax evasion challenge Pakistan, Switzerland moving towards greater cooperation

Pakistan and Switzerland would exchange information on tax evasion once the contracting state exhausts all regular sources of information available under the internal taxation procedure. On August 31, 2016, the Federal Cabinet approved initialed draft for revision of the Convention between Pakistan and Swiss Confederation for the avoidance of double… – Continue reading

Worldwide Disclosure Facility for offshore tax evasion launched

A NEW online disclosure facility has launched today giving offshore evaders a last chance to settle tax on their wealth hidden offshore ahead of new data sharing arrangements and tougher penalties being introduced. The Worldwide Disclosure Facility (WDF) is the final chance for those few still dragging their feet to… – Continue reading

UAE companies to benefit from transfer pricing as profit-shifting plan comes into force

The international tax landscape has been changing rapidly and the Organisation for Economic Co-operation and Development (OECD) has agreed on a base erosion and profit shifting (Beps) action plan that could affect businesses operating in the UAE. The plan addresses the issue of artificial shifting of profits and its proposals… – Continue reading

Israeli government enjoined from disclosing personal account information to the IRS

One disadvantage of United States citizenship is that all income from whatever source, worldwide, is subject to taxation. This is true regardless of how one obtains American citizenship; indeed, there are many “accidental Americans” who, by dint of having been born to a person with American citizenship, are technically American… – 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

Silicon Valley Issues Netherlands With Tax Warning

A coalition of Silicon Valley tech companies has urged the Dutch Government against making changes to the most “attractive” features of its corporate tax regime, warning that it risks damaging its traditionally strong tax competitiveness by doing so. The Silicon Valley Tax Directors Group (SVTDG), which includes more than 80… – Continue reading

CBDT signs 20 Unilateral Advance Pricing Agreements with Indian taxpayers

The Central Board of Direct Taxes (CBDT) entered into twenty (20) Unilateral Advance Pricing Agreements (APAs) with Indian taxpayers. Many of these agreements also have a “Rollback” provision in them, Ministry of Finance said. The 20 APAs signed in these two days pertain to various sectors of the economy like… – Continue reading

Dublin and Washington enter talks to update Double Taxation treaty

Talks have begun between the US and Irish governments about updating certain elements of the Double Tax treaty between the two countries. The existing treaty was signed in 1997 and a Protocol to the treaty was signed in 1999. The Department of Finance and the Revenue Commissioners are calling for… – Continue reading

The U.K.’s Proposed Interest Restriction Rule—Too Much Too Soon?

The U.K. government has been consulting on a proposed “Interest Restriction” rule which will limit the amount of interest expense U.K. companies will be allowed to offset against their income for tax purposes (to 30% of their taxable earnings before interest, tax and amortization). The second consultation phase on the… – Continue reading

Republicans Take New Tack on Taxing Companies’ Overseas Profits

Democrats are likely to object to the House GOP’s and Donald Trump’s plans for sharply lower rates President Ronald Reagan once chided government’s approach to the economy as following this mantra: “If it moves, tax it.” Today’s Republicans are following Mr. Reagan’s ideas by trying the exact opposite approach. The… – Continue reading

Kuwait inks Int’l treaty to combat tax evasion

The State of Kuwait has joined the Multilateral Competent Authority Agreement for swapping taxation information according to criteria of the Development and Economic Cooperation Organization (OECD), becoming the first Arab country to ink the relevant international treaty. Kuwait Finance Undersecretary Khalifa Hamada said in a statement that he led the… – Continue reading

Assessing the Hong Kong – Russia Double Taxation Agreement: Another Step Towards Amplifying China’s Eurasian Connection

Assessing the Hong Kong – Russia Double Taxation Agreement: Another Step Towards Amplifying China’s Eurasian Connection   The long-awaited Comprehensive Double Taxation Agreement (CDTA) between Hong Kong and Russia entered into force on July 29, 2016. The agreement will take effect on April 1, 2017 in Hong Kong and January… – Continue reading

What is the future of corporate tax reform?

On June 7, AEI hosted two panels on how the US could reform the corporate tax code, the first focusing on business-level taxation and the second focusing on shareholder-level taxation. Christopher H. Hanna of the Senate Finance Committee delivered the symposium’s opening remarks, with a major focus on how the… – Continue reading

A Talk on the Benefits of Double Taxation Avoidance Agreement between Cambodia and Singapore

In May 2016, the Cambodian and Singaporean government authorities signed a new agreement to avoid double taxation with respect to taxes on income and on capital. What are the objectives and benefits of a double taxation avoidance (DTA) agreement? The “big-picture” objectives of the DTA between Singapore and Cambodia are… – Continue reading

ATO Issues Anti-Avoidance Warnings For Multinationals

The Australian Taxation Office (ATO) has issued a series of taxpayer alerts that caution large companies against using contrived arrangements to avoid their tax obligations. The first alert concerns arrangements where Australian consolidated groups use offshore permanent establishments that have entered into intra-group transactions. Deputy Commissioner Jeremy Hirschhorn explained: “Through… – Continue reading

GST will reduce tax evasion, improve business environment

The implementation of the goods and services tax (GST) will reduce tax evasion and improve ease of doing business by engendering a common market throughout the country, finance minister Arun Jaitley said on Monday, as he moved the modified constitution amendment bill in the Lok Sabha. “GST will ensure one… – Continue reading

Developing Nations Seek Tax Body to Curb Illicit Financial Flows

Despite Western opposition, the 134-member Group of 77 is continuing to pursue a longstanding proposal for an inter-governmental UN-affiliated tax body aimed at combating corporate tax dodging and curbing illicit financial flows, including money laundering and off-shore banking. The proposal has already been shot down twice by Western nations, first,… – Continue reading

Panama Papers and US initiatives to identify entity beneficial owners

In early April 2016 files leaked from a large Panama-based law firm (known as the ‘Panama Papers’) brought to the attention of many the ways in which offshore companies and structures can be used to obscure the identity of beneficial owners, some of whom have used such entities to avoid… – Continue reading

Ukraine, Malaysia sign agreement on avoidance of double taxation

An agreement on avoidance of double taxation, which was signed today between the governments of Ukraine and Malaysia, will allow enhancing business contacts and attracting investors. Ukrainian President Petro Poroshenko said this at a joint news conference with Malaysian Prime Minister Najib Tun Razak, an Ukrinform correspondent reports. “We think… – Continue reading

EU considers blacklisting NZ over tax laws

Possible EU sanctions against New Zealand could make travel harder and have a massive effect on the economy. New Zealand is under investigation by the EU as it prepares a blacklist of global tax havens, Newshub revealed on Monday night. The grouping of 28 European nations has compiled a list… – Continue reading

Changes to India-Mauritius-Singapore Tax Treaties – Mind the Gap?

As many are now aware, the double tax avoidance arrangement (DTAA) between India and Mauritius was amended through the protocol released last month. The direct impact summarized in one line is as follows: India shall now tax capital gains arising from alienation of shares by a Mauritius investor acquired on… – Continue reading

Banks to hand over offshore tax files

The Trudeau government has won a round in its battle against offshore tax cheats. Two banks have agreed to give the federal revenue minister information from the accounts of a Caribbean financial institution to help the government crack down on Canadian tax evaders. The Federal Court of Canada has approved… – Continue reading

Macau and China add protocol to the agreement to avoid double taxation

The Macau Special Administrative Region (MSAR) and China’s State Administration of Taxation in Beijing signed an additional protocol to the agreement to avoid double taxation and prevent tax evasion, officials said in Macau. The Additional Protocol, the third, according to the statement released by the Office of the Secretary for… – 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

CBDT signs 7 advance pricing agreements to cut tax litigation

The latest APAs signed with taxpayers pertain to various sectors like banking, information technology and automotives In a move designed to reduce tax litigation, the Central Board of Direct Taxes (CBDT) on Monday signed seven more unilateral Advance Pricing Agreements (APAs) with Indian taxpayers. “With today’s signing, the total number… – Continue reading

Pravin Gordhan’s 10-point solution to tax evasion

Tax and prosecution bodies must build the capacity to curb illicit activities that rob countries of tax revenues, said Finance Minister Pravin Gordhan on Thursday, speaking at the High Level Conference on Illicit Financial Flows at the University of Pretoria. Illicit money leaving Africa reduces the amount of resources available… – Continue reading

Corporate tax avoidance: New rules adopted

On 12 July 2016, the Council adopted new rules addressing some of the practices most commonly used by large companies to reduce their tax liability. The directive is part of a January 2016 package of Commission proposals to strengthen rules against corporate tax avoidance. The package builds on 2015 OECD… – Continue reading

‘Tax avoidance’ masters revealed: EXCLUSIVE

The “Big Four” global accounting firms – PwC, Deloitte, KPMG and Ernst & Young – are the masterminds of multinational tax avoidance and the architects of tax schemes which cost governments and their taxpayers an estimated $US1 trillion a year, according to an Australian taxation expert. The controversial new claims… – Continue reading