A draft agreement on avoidance of double taxation and prevention of fiscal evasion convention was handed to Afghanistan in February 2014 Pakistan and Afghanistan will hold talks in March on a treaty to avoid double taxation and prevent fiscal evasion, an official said. A draft agreement on avoidance of double… – Continue reading
The Government of the Bahamas has recalled that 2015 brought significant challenges for the territory in the area of tax, with the implementation of a VAT regime, adoption of FATCA legislation, and the expansion of duty free concessions to cover the whole of Grand Bahama. The Bahamas Government recently released… – Continue reading
Range Extension Public Notice [2015] No. 60 provides non-resident taxpayers enjoying bilateral tax agreement and the international transport agreement with applicable unified, standardized management processes. Specific changes include: signed agreements for the avoidance of double taxation signed tax provisions of airlines, shipping and car services, tax agreement for the mutual… – Continue reading
The taxman has been forced to apologise after admitting that Accelerated Payment Notices he sent to 2,000 Montpelier tax scheme contractors should never have been issued. In a letter notifying the affected contractors, HM Revenue & Customs reminds that three conditions must be present for it to be able to… – Continue reading
The Irish Revenue has published a statement announcing that on December 23, 2015 the Convention between Ireland and the Republic of Zambia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains (Hereafter: the new DTA) as concluded on… – Continue reading
The international community led by the G20 initiated the Base Erosion and Profit Shifting (BEPS) project a few years ago with the aim of ensuring that profits are taxed where economic activities are performed and where value is created, the Business Standard reports. Governments, tax authorities and social groups have… – Continue reading
Thai consumer goods group TCC Holding Co. Ltd has completed its acquisition of the Vietnamese operations of Metro for 655 million euros (US$704.1 million). TCC’s subsidiary TCC Land International Pte. Ltd. takes over Metro’s 19 stores and related real estate portfolio in Vietnam, the German company said in a press… – Continue reading
The first stage of an un-precedented worldwide crackdown on tax evasion and banking secrecy has got under way, with Irish banks this week starting to collect details of non-resident bank account holders. The collection of information follows on from the agreements brokered by the Organisation for Economic Co-operation and Development… – Continue reading
January 2016 You will find below a summary of some of the most important tax developments that have happened since the release of our last newsletter, at OECD, EU or country level, in the area of tax transparency and the fight against tax avoidance. EU – Tax transparency and anti-BEPS… – Continue reading
Hong Kong (HKSAR) – The Inland Revenue (Amendment) Bill 2016 was gazetted today (January 8). “The Bill seeks to put in place a legal framework for Hong Kong to implement the new international standard for automatic exchange of financial account information in tax matters (AEOI) as promulgated by the Organisation… – Continue reading
Luanda – Throughout the year just ended, as in the previous, the country’s economy “found himself grappling” with a major setback if they can be considered, due to the continued drop in oil prices, which is in the house $ 37 a barrel, far from the historic $ 122 value,… – Continue reading
The mayhem over the yuan seems to have entangled DBS Group, Standard Chartered Bank and Deutsche Bank, which have all been suspended from conducting some of their businesses related to the Chinese currency, reports said yesterday. The temporary bans are likely a move by the Chinese central bank to clamp… – Continue reading
The financial regulator has launched a public consultation on plans to create alternative models for banking. Proposals being considered by the Financial Services Authority aim to address the decline in traditional offshore banking. Two additional banking licences are mooted – one for banks serving high net-worth individuals and corporate clients… – Continue reading
On 13 November 2015 the Treasurer and Minister of Finance jointly announced that a new double tax treaty had been negotiated with Germany, replacing the 1972 agreement. The new treaty has not yet been formally adopted as part of Australian law, as a change to the International Tax Agreements Act… – Continue reading
With all due respect, the OECD’s BEPS project was a fiasco, accomplishing little of any positive value and opening up a Pandora’s box with its focus on “value creation” in the context of transfer pricing. Despite all the “happy talk” coming out of the OECD and all the talk of… – Continue reading
A Luxembourg trial into the causes of leaks and theft of confidential documents from PricewaterhouseCoopers LLP that contributed to the so-called LuxLeaks scandal with the disclosure of thousands of pages of confidential tax rulings, will begin April 26. French journalist Edouard Perrin, Antoine Deltour, a former auditor at PwC in… – Continue reading
A law implementing the common reporting standard (CRS) in Luxembourg law has been enacted. The law was published on 24 December 2015. Accordingly, the CRS measures for the automatic exchange of financial account information in the field of taxation are enacted as of the end of 2015. The CRS law… – Continue reading
New Delhi: Mutual Fund houses will have to mandatorily provide compliance details for the new global tax avoidance law FATCA with regard to each client on the stock exchange’s mutual fund trading platform. In a circular, BSE said for each and every transaction mutual fund houses have been asked “to… – Continue reading
We conduct transfer pricing reviews as part of broader risk reviews of businesses under our compliance program. Documenting your transfer pricing: > is important for demonstrating your compliance with Australia’s transfer pricing rules > can be costly, particularly for smaller businesses. We have developed some simplified transfer pricing record keeping… – Continue reading
Several Slovak banks are already preparing for the new obligations arising from the agreement FATCA (Foreign Account Tax Compliance Act). Because it had to make changes in particular in its information systems. “Following the agreement FATCA UniCredit Group has developed separate software for the purpose of fulfilling the obligations under… – Continue reading
Jersey and Guernsey will no longer appear on Italy’s tax blacklist, after the Italian parliament revised provisions in the country’s tax code relating to blacklists on corporate taxation and controlled foreign companies (CFC) rules. Blacklist The Stability Law for 2016 abolished blacklists on the deductibility of costs and CRCs as… – Continue reading
Thousands of entrepreneurs are expected to liquidate their companies over the next three months amid fears that an imminent tightening of the tax rules will more than triple their bills, reports the Financial Times. Advisers said many small company owners were drawing up plans to lock in tax rates as… – Continue reading
Dutch holding companies have been again included on the Brazilian government’s list of “privileged tax regimes.” Accordingly, this action has implications for purposes of the transfer pricing, thin capitalization, and tax deductibility rules. Background Under Brazilian tax law, the concept of “privileged tax regimes” is relevant for determining: Whether Brazil’s… – Continue reading
Jamaica has released information explaining its new transfer pricing regime, with transfer pricing documentation due on March 15, 2016. According to the Government, 2015 amendments to the Income Tax Act were intended to remove any subjectivity in the administration of transfer pricing rules. The Government said: “Taxpayers have always had… – Continue reading
SOUTH African Revenue Service (SARS) commissioner Tom Moyane has been instructed by Finance Minister Pravin Gordhan to halt the implementation of his ambitious restructuring plans. The far-reaching restructuring project for the tax authority was one of the first initiatives undertaken by Mr Moyane following his appointment as commissioner in October… – Continue reading
Jan. 6 — Some dual-resident taxpayers don’t have to report specified foreign financial assets on Form 8938 for 2015, the IRS said. These taxpayers won’t have to do the reporting as long as they determine their income tax liability—for all or part of the taxable year—as if they were nonresident… – Continue reading
On 1 January 2016, the Common Reporting Standard (CRS) became effective. The CRS is a new, single global standard on automatic exchange of information. It replaces the EU Taxation on Savings Directive and is essentially a global form of FATCA-like reporting. Under the CRS, Irish funds are now required to… – Continue reading
World Finance spoke to Thierry Afschrift, founder of Afschrift Law Firm and university professor, about how tax lawyers can respond to a changing European environment In keeping with much of Europe, Belgium’s tax system has been subject recently to a shift of important proportions, as policymakers there look to boost… – Continue reading
Adv. Amit Kriegel is suspected of abetting the super-model in evading taxes in Israel. Adv. Amit Kriegel, lawyer for global super-model Bar Refaeli and a former senior Israel Tax Authority official, was questioned under caution by the Tax Authority in the Bar Refaeli criminal investigation. Kriegel, a partner of former… – Continue reading
More than €45.6bn raised for exchequer last year, up from €41.2bn in 2014 The Revenue Commissioners secured 27 criminal convictions for serious tax evasion and fraud in 2015, according to figures released today. Those prosecutions were on top of 2,063 summary convictions, or lesser charges, for the non-filling of tax… – Continue reading
Despite popular campaign and committee recommendations, tax haven restrictions will not be included in bill AN OVERDUE land reform report from the Scottish Government has categorically refused to bring back a proposal which campaigners say would have tackled the phenomenon of Scottish land being owned in offshore tax havens. Dropped… – Continue reading
French authorities are investigating the taxes of designer Karl Lagerfeld, who a French magazine claims used offshore tax havens to avoid paying millions of euros to the French government. The case is the latest involving allegations of high-end tax evasion in France, where the finance ministry has cracked down on… – Continue reading
Mutual Fund houses will have to mandatorily provide compliance details for the new global tax avoidance law FATCA with regard to each client on the stock exchange’s mutual fund trading platform. In a circular, BSE said for each and every transaction mutual fund houses have been asked “to upload FATCA… – Continue reading
Interest paid by UK companies is generally subject to withholding tax at 20%. Although various exemptions apply, most notably in respect of interest payments to banks and other UK companies, and in respect of securities listed on a recognised stock exchange (so called “quoted eurobonds”), such exemptions are often of… – Continue reading
Viacom Inc. was accused by one of its former executives of plotting to hide revenue from “Teenage Mutant Ninja Turtles” in a Netherlands entity to avoid taxes. The ex-vice president for financial planning at Viacom claims she was fired after opposing what she believed was an illegal tax dodge. Nataki… – Continue reading
The Argentine tax authorities (AFIP) posted an updated “white list” of countries, jurisdictions, and territories—that is, a list of countries and jurisdictions that are identified as cooperative for tax transparency purposes. A broader application of Argentina’s transfer pricing rules will not apply to transactions involving entities located in the countries… – Continue reading
The Department of Justice announced today that Union Bancaire Privée, UBP SA (UBP), reached a resolution under the department’s Swiss Bank Program. UBP will pay a penalty of more than $187 million. “Today’s agreement marks the final resolution with UBP, which acknowledges its role in conspiring with U.S. taxpayers to… – Continue reading
The number of legacy bank tax avoidance schemes under investigation by UK tax authority HM Revenue and Customs (HMRC) has fallen since the strengthening of Code of Practice on Taxation for Banks, a new departmental report has shown. The Code of Practice on Taxation for Banks was introduced in 2009… – Continue reading
Now that the final report on BEPS Action 7 has been released, “Preventing the Artificial Avoidance of Permanent Establishment Status” (Final Report), taxpayers are able to consider the final language to be incorporated into Article 5(5) of the OECD Model Tax Convention.1 This language also will be incorporated into the… – Continue reading
On December 18, 2015, the President signed the Omnibus Appropriations Act (the “Act”) into law.1 Notably, the Act contains a number of substantive changes to the tax laws applicable to “real estate investment trusts” (“REITs”). Although several changes will adversely affect certain REITs, on balance REITs and their investors fared… – Continue reading
On October 5, the OECD issued it formal recommendations on the Base Erosion and Profit Shifting (BEPS) Action Plan. These recommendations have been subsequently adopted by the G20. We acknowledge the monumental effort that has been put forth to produce a modernized international system of tax rules through the BEPS… – Continue reading
Taipei, Jan. 6 (CNA) President Ma Ying-jeou (馬英九) lauded his administration’s efforts to improve the country’s development and expressed optimism Wednesday about the future for Taiwan’s next generation, citing a recent survey that found Taiwan the most optimistic about the future among other Asian nations. If peace and prosperity in… – Continue reading
Ex-HSBC employee and whistle-blower Hervé Falciani has lashed out at the Swiss banking system for helping multinationals evade taxes through offshore schemes. He has also demanded that Switzerland recognise the role of whistle-blowers. “In order to survive the Swiss had developed mercenary activities on a grand scale. These are the… – Continue reading
On January 6, 2016 the text of the Memorandum of Understanding with respect to the Exchange of Information for Tax Matters as concluded between the Competent Authorities of the Netherlands and Georgia (Hereafter: the MoU) was published in the Dutch Staatscourant. The MoU was signed by the Dutch competent authorities… – Continue reading
UBP is the latest bank to reach a resolution under the Swiss Bank Program, launched in 2013, that allows Swiss banks to resolve potential criminal liabilities in the United States. UBP between 2008 and 2013 helped U.S. clients to open and maintain undeclared accounts in Switzerland and conceal assets and… – Continue reading
Twelfth night has come and gone, the Chistmas lights are out but John Lewis has reported a set of sales figures that sparkled. The department store believes it has outperformed its rivals, once again, online in particular. And yet it’s managing director told me the fight with one rival –… – Continue reading
The investigation and prosecution of tax evasion has, in the last decade, grown from a specialized subcategory of law enforcement into a first-tier policy concern for the global community. Starting with the U.S. government’s crackdown on Swiss bank UBS in 2008, there has been a steady drumbeat of news about… – Continue reading
A Viacom whistleblower claims she was sacked by the media company for opposing its alleged plan to illegally avoid paying U.S. taxes on the international licensing rights to Teenage Mutant Ninja Turtles. In a complaint filed in Manhattan federal court on Tuesday, former vice president Nataki Williams said she was… – Continue reading
Legislation amending the rules governing transfer pricing documentation—to include country-by-country reporting, as well as master file and local file provisions—has been enacted and has an effective date of 1 January 2016. The Dutch Upper House (Eerste Kamer) on 22 December 2015 passed the legislation (the bill is referred to in… – Continue reading
The Norwegian Ministry of Finance published a public consultation paper regarding country-by country reporting for tax purposes. The proposal suggests that multinational groups—when the ultimate parent company is a resident in Norway—would be required to submit country-by country reports. The reporting requirements could also affect foreign group entities that are… – Continue reading
