Yearly Archive: 2016

The Netherlands implements OECD BEPS Country-by-Country Reporting as well as the amendments to the EU Parent-Subsidiary Directive

As from 1 January 2016, new rules have become effective in the Netherlands that require multinational enterprises (“MNEs“) to comply with new transfer pricing documentation requirements, including the obligation to prepare a Country-by-Country Report (“CbC Report“), a Master File and a Local File. These rules essentially implement Action 13 of… – Continue reading

Don’t believe the ‘loopholes’ hype

Recent media coverage has prompted impassioned calls for Congress to close the “loopholes” that supposedly explain why the 400 richest taxpayers paid an average federal individual income tax rate of 16.7 percent in 2012. Unfortunately, these calls are based on outdated numbers and an incomplete picture of the tax system…. – Continue reading

Asia-Pacific financial institutions unprepared for FATCA and GATCA compliance

Best positioned firms will upgrade technology infrastructure Financial institutions across Asia-Pacific are behind the curve when it comes to being prepared for evolving global tax reporting regulations. That’s according to a recent survey by Wolters Kluwer Financial Services and the GRC Institute, which indicates that more than 90% of financial… – Continue reading

Multinationals may have to provide global income, tax details to taxman

Budget to implement some of OECD’s standards on profit-shifting NEW DELHI, JANUARY 21: Large multinational enterprises (MNEs) may be required post-Budget to furnish to Indian tax authorities information on their global incomes and taxes. This move — a fallout of India agreeing to OECD’s Action Plan on Base Erosion and… – Continue reading

Intl bodies to fight global tax evasion / Maximum of $240 bil. said to be dodged

The Yomiuri Shimbun Four international organizations will join forces to devise unified global tax rules aimed at preventing tax evasion by multinational companies. The four entities involved are the Organization for Economic Cooperation and Development, the United Nations, the International Monetary Fund and the World Bank. The OECD — whose… – Continue reading

Get a reward for helping Canada Revenue find offshore tax cheats

THE Canada Revenue Agency (CRA) has a new program that offers rewards to individuals who provide precise details about Canadians hiding money or assets offshore and not paying the taxes they owe. It is not illegal to invest money or hold accounts offshore but Canadian residents must report their worldwide… – Continue reading

Tanzania: Managing Tax Risks – Double Tax Treaties and Implications to Undertakings of Multinationals

The term double taxation refers to an exposure to tax more than once on the same profit or income. There are two types of double taxation i.e. economic double taxation and juridical double taxation. Economic double taxation is broad and occurs in a situation where an amount of income is… – Continue reading

Estonia cuts impact of tax evasion through incorporation by EUR 210,000 in 3 months

Largely as a result of interaction between the Estonian Tax and Customs Board and entrepreneurs on the subject of incorporation, 157 more people have started to pay payroll taxes and have paid altogether 210,000 euros in such taxes in three months, the tax authority said, cites LETA/BNS. “In connection with… – Continue reading

Birmingham Post Rich List 2016: More taxing times for non-domiciled individuals

The taxation of ‘non-UK domiciled’ individuals has been a thorny political issue as successive governments have sought to crack down on those enjoying what some have seen as an excessively benign tax regime The taxation of ‘non-UK domiciled’ individuals has been a thorny political issue as successive governments have sought… – Continue reading

Margarita Vestager underlines corporate tax stance

Having companies pay their tax where they make their profits is the best way to resolve unfair tax competition between member states, Competition Commissioner Margarita Vestager said yesterday. She was responding to a European Parliament reporting calling for countries to forfeit tax that the Commission say companies should pay when… – Continue reading

Ireland’s new growth a model for other nations, Enda Kenny tells Davos forum

Ireland’s emergence from economic meltdown provides a model for other nations, the Taoiseach has told the World Economic Forum. Enda Kenny also defended his country’s tax arrangements with multinational companies, telling the audience past claims that it was a tax haven for big businesses were without foundation. Mr Kenny took… – Continue reading

Latest statistics show wealthy already pay more than taxes than other groups

WASHINGTON, D.C.—Recent media coverage has prompted impassioned calls for Congress to close the “loopholes” that supposedly explain why the 400 richest taxpayers paid an average federal individual income tax rate of 16.7 percent in 2012. A few weeks ago, the IRS released new data showing that the average federal individual… – Continue reading

Implementation of POEM rules may hit investments

The implementation of place of effective management (POEM) rules in the current scenario in India could not only hurt the nation’s outbound investments, but also discourage overseas multinational companies from setting up their regional hubs here, feel industry watchers. The draft guidelines for implementing POEM, which was released on December… – Continue reading

MPs question HMRC’s response to tax evasion, the hidden economy and criminal attacks

With the issue of tax evasion a political priority and firmly in the media spotlight, the Public Accounts Committee kick-started 2016 with an evidence session with top HMRC officials as part of its inquiry into: Tackling tax fraud: how HMRC responds to tax evasion, the hidden economy and criminal attacks…. – Continue reading

Changes are afoot for rules over inheritance tax from April 2017

FROM April 2017, there will be a new main residence transferable inheritance tax threshold which will apply when a main home is passed on to a direct descendant. A direct descendent broadly means a child or grandchild and includes adopted children, foster children and stepchildren. The inheritance tax threshold, officially… – Continue reading

Russian Agreement Advances Hong Kong’s DTA Priorities

Hong Kong’s newly signed double tax deal with Russia is said to support the territory’s ongoing efforts to expand its tax treaty network with jurisdictions along “the Belt and Road.” The Belt and Road, or the Silk Road Economic Belt, is a Chinese Government economic development project, which is primarily… – Continue reading

Budget 2016 may introduce BEPS to make tax evasion difficult for MNCs

MUMBAI: In what could lead to an increase in domestic tax liabilities of many Indian conglomerates and multinationals, the government is set to introduce a framework for Base Erosion and Profit Shifting (BEPS), a global agreement to check tax avoidance by multinationals, in the upcoming Budget. Industry sources expect the… – Continue reading

Lionel Messi’s tax fraud trial conflicts with Copa America

MADRID (AP) – Lionel Messi’s tax fraud trial has been set for May 31-June 3, conflicting with the start of the centennial Copa America in the United States. The Copa America Centenario will kick off June 3, meaning the five-time world player of the year will not have the best… – Continue reading

IRS: Banks Get More Time to Certify Accounts Under FATCA

Jan. 19 — Foreign financial institutions will have more time to certify whether their pre-existing accounts are owned by U.S. taxpayers under the Foreign Account Tax Compliance Act, the IRS said in Notice 2016-8. The Jan. 19 notice answers many significant questions raised by taxpayers on compliance with the law…. – Continue reading

Exclusive: EU plans faster investment tax refunds from 2017 – document

European Union countries will have to introduce rules from 2017 to speed up tax refunds on cross-border investments, part of a drive to improve the working of financial markets and lift economic growth, according to an EU document seen by Reuters. The executive European Commission wants to simplify “withholding tax”… – Continue reading

Thailand Charges Philip Morris with Tax Evasion

BANGKOK—Thai prosecutors charged the Thailand subsidiary of global tobacco giantPhilip Morris International Inc. with tax evasion for allegedly under-declaring the value of cigarettes imported from the Philippines. The Office of the Attorney General said in a statement Tuesday it has filed a complaint with a Thai court after a long-running… – Continue reading

Time running out to respond to HMRC’s latest proposals on company distribution anti-avoidance rules

Two weeks remain to influence draft legislation which reduces the ability for individuals to convert income distributions from a company into capital gains by way of winding-up that company, an expert has warned.19 Jan 2016. Proposals amending the Transactions in Securities (TIS) rules were published by HMRC on 9 December… – Continue reading

Cayman copies US tax haven’s limited liability law

Cayman Islands has introduced limited liability company (LLC) legislation that combines the key features of a company and a partnership, intended to increase the structuring options for US investment funds. US clients have reportedly been requesting this legislative development for some time to provide a better match with the Delaware… – Continue reading

PROPERTY TAX POST: ROLL OF THE ‘D.I.C.E.’ —BUSINESS PERSONAL PROPERTY TAX RELIEF IS A CRAP SHOOT

Each year, states enact tax law changes and create local government programs that provide personal property tax breaks for businesses. These concessions come in various forms—deductions, incentives, credits and exemptions (i.e., D.I.C.E.), and they have a significant impact on whether businesses remain viable. Many states commonly impose ad valorem tax… – Continue reading

HMRC to rebate tax to thousands of contractors using offshore schemes

HMRC is set to repay tax to around 2,000 banking and IT contractors who used an offshore scheme because of a flawed process around issuing payment notices. The tax office issued so-called accelerated payment notices to individuals who used Isle of Man-based schemes to limit their income tax during the… – Continue reading

Tax Practice: Applying for Tax Benefits under International Tax Treaties in China

In an effort to facilitate non-resident enterprises in applying for tax benefits, China’s tax bureau recently released the SAT Announcement [2015] No.60, which replaced the previous “Administrative Measures on Tax Treatment under Double Taxation Agreement to Non-resident Enterprises (Guoshuifa [2009] No.124)” and simplified the application procedures for a non-resident enterprise… – Continue reading

QROPS – The Great American Pension Nightmare

The American dream can turn into a nightmare for expats wanting to switch their UK pensions to a Qualifying Recognised Overseas Pension Scheme (QROPS). Thousands of expats cross the Atlantic both ways with London home to Americans in sectors such as finance, entertainment and media, while Florida is a popular… – Continue reading

China: offshore banks’ must reserve more yuan

China’s central bank said on Monday it will start implementing a reserve requirement ratio (RRR) on offshore banks’ domestic deposits, in what appears to be its latest attempt to stem speculation in the yuan and manage money flowing in and out of the country. Confusion over China’s foreign exchange policy… – Continue reading

Hong Kong: Business Compliance Changes At A Glance

According to the World Bank’s ‘Doing Business 2016 Report’, Hong Kong continues to be one of the world’s easiest places to do business, and tops the ranks in Asia Pacific for starting one. To sustain its economic growth and competitiveness, the Hong Kong government underwent three key changes in 2015:… – Continue reading

India, UK to cooperate in infrastructure financing, check tax evasion

LONDON: India and the UK today agreed to strengthen their economic cooperation in infrastructure and financial services as they vowed to address cross-border tax evasion and avoidance. Finance Minister Arun Jaitley, who held talks with his UK counterpart George Osborne as part of the 8th India-UK Economic and Financial Dialogue… – Continue reading

HMRC to repay tax to thousands of banking and IT contractors

Banking and IT contractors forced to stump up tens of thousands of pounds to settle contested tax debts last year are now in line to be repaid, after the UK tax authority accepted it should not have issued payment demands. HM Revenue & Customs has withdrawn so-called accelerated payment notices… – Continue reading

MEPs want companies tax dodges repaid into EU budget

The proceeds from illegal tax breaks brokered between an EU state and a multinational company, known as clawbacks, should be returned either to the EU budget or to the coffer of other states unfairly deprived of the money, according to MEPs. The idea was endorsed by the European parliament in… – Continue reading

Nigeria signs double tax treaty with United Arab Emirates

As part of the ongoing visit by President Muhammadu Buhari to the United Arab Emirates (UAE), both countries today signed six agreements on Trade, Finance and Judicial Matters; Avoidance of Double Taxation; Trade Promotion and Protection; Judicial Agreements on Extradition, Transfer of Sentenced Persons; Mutual Legal Assistance on Criminal Matters;… – Continue reading

Brazil offshore tax amnesty signed into law

Residents of Brazil with undeclared offshore assets can now voluntarily declare and regularise their tax affairs without facing criminal prosecution and only face a one-off charge and penalty. All individuals and legal entities who were resident or domiciled in Brazil on 31 December 2014, can voluntarily declare previously undisclosed goods… – Continue reading

HMRC to repay tax to thousands of banking and IT contractors

Banking and IT contractors forced to stump up tens of thousands of pounds to settle contested tax debts last year are now in line to be repaid, after the UK tax authority accepted it should not have issued payment demands. HM Revenue & Customs has withdrawn so-called accelerated payment notices… – Continue reading

SIM cards, handsets: Scheme of taxation legally impermissible, argue CMOs

Three leading cellular operators have made a joint representation to the Federal Board of Revenue (FBR) that the scheme of taxation contemplated by the Ninth Schedule of the Sales Tax Act 1990 in relation to both items – SIM cards and handsets – is legally impermissible and unconstitutional and practically… – Continue reading

British Virgin Islands: Adoption Of The OECD Common Reporting Standard In The British Virgin Islands

On 1st January 2016, an amendment to the Mutual Legal Assistance (Tax Matters) Act, 2003 came into force which implements the Organisation for Economic Co-Operating and Development (OECD) Common Reporting Standard for the exchange of tax information (CRS) in the British Virgin Islands (BVI). Globally this means that participating jurisdictions… – Continue reading

US TIGHTENS UP ON LUXURY PROPERTY PURCHASES THROUGH OFFSHORE COMPANIES

The US’s Financial Crimes Enforcement Network has announced it will be investigating the individuals behind secretive all-cash purchases of high-end luxury real estate in a six-month trial programme intended to enhance the treasury’s anti-money laundering efforts. The initiative will focus on all-cash property purchases of over $3 million in New… – Continue reading

Russia, Hong Kong sign avoidance of double taxation agreement

Russia and the Hong Kong Special Administrative Region of the People’s Republic of China signed an agreement on avoidance of double taxation and prevention of fiscal evasion regarding profits taxes on Monday. The document was signed by Russia’s State Secretary, Deputy Finance Minister Yuriy Zubarev and the Secretary for Financial… – Continue reading