Ukraine and Austria have agreed to sign a protocol to their double taxation agreement to increase withholding tax rates on dividends, interest, and royalty income. The protocol increases the withholding tax rate for dividends and interest to 15 percent and five percent, respectively. Additionally, the royalty rate for patents, trademarks,… – Continue reading
A recent paper from the Tax Foundation (TF) pointed out that, while most Organisation for Economic Co-operation and Development (OECD) countries lean more on tax revenue from consumption taxes, the United States relies more on individual income tax, while raising relatively little from consumption taxes. The TF noted that “this… – Continue reading
The European Union’s Anti-Avoidance Directive, which has to be put into national legislation by 2019,is aimed at plugging loop-holes in tax systems which allow large corporations to legally avoid paying tax. While Malta has been criticised for offering competitive tax rates, despite the openness and uniformity of such competitive rates,… – Continue reading
The Government seeks to curb revenue loss, prevent double non-taxation, streamline the flow of investment, and stimulate the flow of exchange of information between India and Mauritius The India – Mauritius double taxation treaty was under negotiation for the last 4 years. The Treaty has now been amended by way… – Continue reading
A further five countries have signed the OECD’s Multilateral Competent Authority Agreement for the automatic exchange of country-by-country (CbC) reports, bringing the total number of signatories to 44. The Agreement allows all signatories to bilaterally and automatically exchange CbC reports with each other, as contemplated by base erosion and profit… – Continue reading
THAI MULTINATIONAL companies will be impacted on their cross-border business activities due to rapidly evolving tax laws in Europe and Asia-Pacific. For instance, the European Union (EU) achieved a groundbreaking result on June 20 by agreeing to a package of tax measures to combat corporate tax avoidance, which will be… – Continue reading
A regulatory effort by the Obama administration to crack down on tax deals is facing backlash from business groups and lawmakers on both sides of the aisle. While the Internal Revenue Service (IRS) rules were intended to combat inversions — transactions in which a U.S. company combines with a foreign… – Continue reading
European Union member states have struck a deal on new rules designed to eliminate the most common corporate tax avoidance practices. The measures in the Anti-Tax Avoidance Directive target the main forms of tax avoidance practiced by large multinationals and builds on global standards developed by the Organisation for Economic… – Continue reading
Regardless of whether you were surprised, overjoyed, dismayed or showed any other emotion (perhaps anger as you saw world markets tank), Brexit is here. Yes, we’re talking about the British exit from the European Union. We are not sure why the media coined the term “Brexit,” when it’s not only… – Continue reading
With an aim to avoiding double taxation, improving the investment environment for Taiwan, and increasing the attractiveness of foreign investment into Taiwan, the Ministry of Finance in recent years has focused on entering into tax treaties with other jurisdictions. Following tax treaties signed with Italy and Austria, Taiwan entered into… – Continue reading
Russian President Vladimir Putin has signed a law on ratifying Russia-Singapore agreement on the avoidance of double taxation and prevention of fiscal evasion with respect to the income taxes, according to the official internet portal of legal information. The accord reached on November 17, 2015 in Moscow is aimed at… – Continue reading
The seeds of Canadian corporations hiding billions of dollars in offshore tax havens were sown more than 40 years ago, after the Canadian government pursued a series of tax treaties with tiny Caribbean and European nations. The 92 tax treaties now signed with countries such as Barbados, Jamaica and Malta… – Continue reading
A new double tax treaty between France and Singapore will be of particular help to French companies operating in Singapore, especially in the construction industry, an expert has said. Franck Lagorce, an expert in French tax at Pinsent Masons, the law firm behind Out-law.com was commenting following an announcement from… – Continue reading
Hundreds of policymakers, business executives, and senior tax officials met at the OECD International Tax Conference to discuss the recommendations proposed under the base erosion and profit shifting (BEPS) project and their impact on trade and investment. The conference, which was held in Washington DC on June 6-7, 2016, was… – Continue reading
CHENNAI: The hardest thing in the world to understand is the income tax, is what Albert Einstein had famously said. Amid the long list of taxation categories, to assimilate what is taxable and what is exempted is hard. Even harder is to pay them, of course. As the June 15… – Continue reading
Multinational companies doing business in Italy, Italian companies doing business abroad and non-resident companies which intend to invest in Italy may use the new international tax ruling procedure to reach an advanced agreement with the Italian Tax Authorities regarding the taxation of income derived from cross-border transactions. Recently, Legislative Decree… – Continue reading
The double taxation avoidance agreement between Singapore and France entered into force on June 1, 2016. Under the deal, withholding tax on dividends would be capped at 15 percent in general; and at five percent where the beneficial owner is a company that owns directly or indirectly at least ten… – Continue reading
Recent news of India and Mauritius signing a Protocol to amend their 33 year old tax treaty caused seismic changes in the tax world. Though not completely unanticipated, the change is significant for foreign investors to go back to the drawing board and reassess their structures. The tax treaty between… – Continue reading
In a step forward, Cyprus has said it is “very close” to revising the bilateral tax treaty with India as the island nation has accepted “in principle” proposals made by the Indian side on taxing capital gains. Cyprus, a source of significant foreign fund flows into the country, said rising… – Continue reading
It was quite a revelation when leaked documents, made public in April, showed that Mossack Fonseca, a Panamanian law firm, had helped 14,000 clients worldwide create offshore accounts to conceal assets or dodge taxes. On Monday, a report by The Times found that there were at least 2,400 clients based… – Continue reading
Asia Pacific The January – March edition of tax highlights for the Asia Pacific region highlights industry developments from Australia, China, Hong Kong, India, Indonesia, Korea, Malaysia and Singapore including: Australia’s new tax system for Managed Investment Trusts The final stage of China’s B2V reform to be rolled out from… – Continue reading
On 20 April 2016, the Loan Market Association (“LMA”) updated its Standard Terms and Conditions for Par and Distressed Trade Transactions (Bank Debt/Claims) (“Standard Terms”) to include language that covers FATCA (as defined below) tax withholding on certain payments of US source FDAP income and, potentially, sale proceeds (as described… – Continue reading
India has asked the Netherlands to resume negotiations on amending their bilateral tax treaty as the government extends its efforts to plug loopholes in such accords to curb misuse. The Dutch tax treaty , which allows exemption from capital gains and a lower rate of tax on dividends, has led… – Continue reading
The International Chamber of Commerce (ICC) recognizes the efforts of an increasing number of tax authorities to revise their tax policies in response to the international guidelines outlined in the G20 mandated Organisation for Economic Co-operation and Development (OECD) Base Erosion Profit Shifting (BEPS) project. ICC urges national governments to… – Continue reading
The EU’s Economic and Financial Affairs Council (ECOFIN) has been unable to reach agreement on the European Commission’s proposed anti tax avoidance directive. The issue has therefore been postponed until the next ECOFIN meeting in June. The European Commission announced its proposed anti-tax avoidance directive (ATAD) in January. The proposed… – Continue reading
The recent EMEA Conference of Alliott Group, one of the world’s most established international associations of independent accounting and law firms, brought together tax professionals from 28 countries across the world to discuss Base Erosion & Profit Shifting (BEPS), a project led by the OECD and G20 whose Action Plan… – Continue reading
Members of the US Senate Committee on Finance have called on the US Secretary of the Treasury, Jack Lew, to continue aggressive engagement with the European Commission to ensure its ongoing tax ruling probe does not inappropriately target US multinationals. In their letter submitted to Lew on May 23, 2016,… – Continue reading
Singapore and Cambodia have entered into a double taxation avoidance agreement to boost cross-border trade and investment between the two countries. The Agreement was signed on May 20, 2016, by Indranee Rajah, Singapore’s Senior Minister of State for Law and Finance, and Aun Pornmoniroth, Cambodia’s Senior Minister of Economy and… – Continue reading
May 18 — Russia agreed to automatically share financial account information but passed up an opportunity the same day on a similar agreement to exchange company country-by-country reports. Russia signed the OECD’s common reporting standard (CRS) multilateral competent authority agreement May 12 at a meeting of tax administration heads in… – Continue reading
NEW DELHI: Now that loopholes in the tax treaty with Mauritius have been plugged, the Indian government is gearing up to apply the same fix to its accord with Cyprus. Talks to amend the double taxation avoidance treaty are at an advanced stage and the two sides will soon exchange… – Continue reading
On 10 May 2016, the Government of India issued a press release1 stating that India and Mauritius have signed a protocol (New Protocol) amending the double tax avoidance treaty between the two countries (the Treaty). Based on the press release and the New Protocol, following are the key changes to… – Continue reading
The U.S. is under international criticism because under its Intergovernmental Agreement (known as IGA) reciprocal exchange accords, the U.S. has already transmitted information on those who are tax residents outside the U.S. to respective national tax authorities under the IGA. The spotlight is on the U.S. because the U.S. has… – Continue reading
India and Mauritius have signed a protocol amending the double tax avoidance arrangement between the two countries. The protocol is the outcome of an extensive and long-drawn-out negotiation process that has been going for more than a year and a half. While the text of the protocol is yet to… – Continue reading
US disregarded entities owned by foreign persons would be treated as domestic corporations under regulations proposed by the US Internal Revenue Service (IRS) on Friday (REG-127199-15). The new rules would apply for purposes of the reporting, record maintenance, and other compliance requirements that apply to 25% foreign-owned domestic corporations under… – Continue reading
With regard to the increasing talk in the US Congress on tax reform, American Citizens Abroad (ACA) has provided the House of Representatives Ways and Means Committee with a full reform proposal for the enactment of residence-based taxation (RBT) for American expatriates. ACA has said lawmakers should enact RBT instead… – Continue reading
The deadline for Canadians to file their taxes is rapidly approaching and if you haven’t filed the necessary paperwork you could face stiff penalties.While the usual deadline to file tax returns is April 30, because the date falls on a Saturday this year the deadline has been extended until Monday,… – Continue reading
Introduction Even though a trust may be established under the laws of a US state and have a US trust company serving as trustee (hereinafter a ‘US-based trust’), this does not mean that it is a US domestic trust for income tax purposes. If non-US persons make substantial decisions for… – Continue reading
THE DOUBLE taxation treaty (DTA) between India and Thailand has been successfully renegotiated and agreed to by both states and will come into force in January next year. The key highlights include a reduction of withholding tax on dividends, interest and royalties. Article 10 reduces the dividend withholding tax to… – Continue reading
THE Bureau of Internal Revenue (BIR) recently issued Revenue Memorandum Circular (RMC) No. 32-2016 setting the amendments in the provisions of the Philippines-New Zealand tax treaty, which was originally entered into on Oct. 2, 2008. The Protocol includes the following changes: 1. The rate for dividends was changed to a… – Continue reading
On October 5, 2015, the Organization for Economic Cooperation and Development (OECD) issued final tax policy recommendations stemming from its Base Erosion and Profit Shifting (BEPS) project. The reports, endorsed by the G20 Finance Ministers on October 8 and by the G20 leaders at their November 15-16 summit, consist primarily… – Continue reading
Each year the IRS comes out with a list of the most notable tax scams, informing the public on what to be on the lookout for come tax season. Each year the IRS comes out with list of tax scams called the Dirty Dozen, which is used to bring public… – Continue reading
COMPANIES profiting from schools and hospitals built under private finance initiatives in Scotland are based in tax havens such as Jersey and Guernsey. An analysis carried out by the Sunday Herald has revealed numerous examples of PFI projects in Scotland which have owners based offshore. The owners include an offshoot… – Continue reading
Ministers agree to propose joint list of tax havens and approve plan to automatically exchange data on shell company owners EU finance ministers have approved a series of measures to tackle tax-evading methods that were exposed by the Panama Papers. Speaking on the second day of talks in Amsterdam, Jeroen… – Continue reading
ANALYSIS: Despite some action from both Labor and Coalition governments, multinationals are still using accounting tricks to avoid paying Australian tax.While politicians in Canberra bicker over whether or not to cut company tax, or whether it’s acceptable for effective income tax rates to rise through bracket creep, glaring leaks in… – Continue reading
The French taxman, Le Fisc, has apparently decided to send McDonald’s MCD -0.24% France a tax bill for €300 million ($341 million). It’s not entirely obvious that this is a correct demand: nor, in fact, necessarily a legal one. If there were no European Union and no rules about the… – Continue reading
To provide relief to corporates having income abroad, the tax department today proposed simplified ‘Foreign Tax Credit’ rules allowing companies to claim credit for taxes paid overseas. The Central Board of Direct Taxes (CBDT) in its draft FTC rules said tax credit will be available to entities paying taxes in… – Continue reading
On April 13 in Riga, Hong Kong’s Secretary for Financial Services and the Treasury K C Chan signed a comprehensive double taxation agreement between Hong Kong and Latvia. “This is the 35th CDTA that Hong Kong has signed with its trading partners and it signifies the Government’s ongoing efforts to… – Continue reading
The release of the so-called Panama Papers has shone a light on the secretive world of offshore tax havens and shown the exhaustive lengths that companies and wealthy individuals will go to in an effort to avoid paying tax. The trove of documents leaked from the Panama-based law firm Mossack… – Continue reading
In the wake of the Panama Papers leak debates about the morality of taxation are back in vogue. Unlike tax evasion, tax avoidance is, by definition, legal. This is not the same thing as saying it’s acceptable. No one wants to live in a society where everything questionable is banned… – Continue reading
HMRC complicite in tax avoidance scheme after it emerged it rents its own office from tax haven based company A day on, the world is still reeling from the revelations of the Panama Papers leak, the full repercussions of which are yet to be felt. Eleven million documents leaked from… – Continue reading
