In its continuing effort to keep the BVI Business Companies Act (the “Act”) at the forefront of offshore company law legislation, the BVI Government, in direct consultation with the private sector, has introduced several updates to the Act as follows: To allow weighted voting by directors whereby certain directors may… – Continue reading
NEW DELHI: Government has collected a total of Rs 2,428.4 crore in taxes after over 600 declarations were made by stash holders to the Income Tax department under the one-time black money compliance window that ended last year. The Central Board of Direct Taxes, in a statement, said this amount… – Continue reading
The Chinese yuan plunged to a five-year low in offshore trading and the gap between it and its mainland counterpart widened sharply on Wednesday, reflecting growing expectations of further weakness in the currency amid an economic slowdown and a slump in stock markets. The offshore yuan fell to 6.6915 against… – Continue reading
A judgment in the Contira case was handed down two weeks ago in the district court which dramatically changes the Cost Plus issues relevant to certain Israeli companies which provide services to a foreign related company. The judgment impacts on the situation where the Israeli company’s employees are granted options… – Continue reading
The Treasury Department and the Internal Revenue Service have proposed regulations setting out a new requirement for certain U.S. persons that are the ultimate parent of a multinational group (a “U.S. MNE group”) having annual revenue of at least $850 million to file an annual report (the “CbC report”). The… – Continue reading
The FCA has reportedly ended its investigation into tax evasion at HSBC, with the bank dodging formal action from the regulator. HSBC spent much of 2015 under fire for the actions of its Swiss private bank, which aided more than 1,000 UK customers evade tax between 2005 and 2007. The… – Continue reading
Billionaire JP McManus is refusing to back down in a row with the US government over a tax bill of $5.2m (€4.8m). The racehorse owner has renewed efforts to secure a tax refund for the sum, court papers seen by the Irish Independent reveal. The disputed cash was part of… – Continue reading
(Reuters) – Texas tycoon Sam Wyly is set to face off against the Internal Revenue Service at trial on Wednesday over more than $2 billion the agency says he owes for using offshore trusts to engage in one of the largest tax frauds in U.S. history. The trial in federal… – Continue reading
Iceland passed legislation that will make secret off-shore accounts very difficult to maintain for tax dodgers. RÚV reports that as of the start of this year, the Directorate of Internal Revenue will have access to the details of all overseas bank accounts held by Icelandic companies and individuals. The legislation,… – Continue reading
Changes to patent box rukes will mean that businesses must now track and trace all of their research and development (R&D) expenditure AFTER the recent government consultation on the UK’s Patent Box scheme, businesses will find it a challenge to comply with the proposed new rules. The changes will mean… – Continue reading
Rules requiring master file and local file reporting—“full” transfer pricing reporting—are advancing in Korea. 5 January 2016 Korea’s parliament on 2 December 2015 approved legislation (released as draft legislation by the Ministry of Strategy and Finance of Korea in August 2015) to implement the OECD’s base erosion and profit shifting… – Continue reading
Guidance—General Resolution No. 3826—issued by the Argentine tax authorities (AFIP) implements new information reporting for banks and financial institutions pursuant to the OECD’s common reporting standard (CRS) regime, effective January 2016. Background Argentina agreed to early implementation of the new “automatic exchange of information” (AEOI) measures. Accordingly, the AFIP will… – Continue reading
Spokesman for B.C. finance minister downplays tax loophole issue A new petition urging B.C. politicians to limit offshore investment and exploitation of tax loopholes in Vancouver real estate is getting a cool reception from Victoria as provincial coffers overflow with property transfer tax revenues in a red-hot housing market. The… – Continue reading
(Special) – Winter brings with it the dream of many Canadian snowbirds of owning a piece of property in the sunny south. With the recent rebound in the U.S. housing market and a decline in the value of the Canadian dollar, however, buying vacation property south of the border may… – Continue reading
Doing business in Poland in 2016? Stay on top of changes to transfer pricing and the potential for tighter local tax regulations. Over the past 12 months we have seen improvements in business-related procedures for tax payers in Poland. Setting up a new company is easier and more efficient, and… – Continue reading
On Friday, December 18, 2015, President Barack Obama signed the “Protecting Americans from Tax Hikes Act of 2015” (“PATH Act”). Our December 10, 2015 client alert discussed significant proposed changes to the rules governing real estate investment trusts (“REITs”) and the Foreign Investment in Real Property Tax Act of 1980… – Continue reading
A striking example of the EU’s efforts to accelerate the implementation of anti-base erosion and profit shifting (BEPS) measures is the amended Parent Subsidiary Directive (PSD). Originally designed to prevent economic double taxation of profits distributed within an EU corporate, the PSD is now also being deployed to counter undesired… – Continue reading
The US Department of Justice (DoJ) has announced that it has now completed agreements with 75 financial institutions, and imposed penalties in excess of US$1bn, under its Swiss Bank Program, reports Tax News. The DoJ’s Swiss Bank Program was signed by the US and Switzerland on August 29, 2013. It… – Continue reading
A UK government body says the UK chancellor is getting £50 million a year less than he expected from a crown dependencies tax deal, reports Manx Radio. The Office for Budget Responsibility says the deal has brought in 20 per cent less cash from tax disclosure facilities that allow people… – Continue reading
Lately, the IRS is warning offshore account holders to disclose before it’s too late. Under FATCA, banks everywhere want to know if you are compliant with the IRS. And the cost of compliance for many people is growing. The IRS updated its list of foreign banks where accounts trigger a… – Continue reading
Bahrain, Sudan also sever diplomatic ties with Iran; two mosques attacked in Iraq UNITED NATIONS/ WASHINGTON: The world community on Monday urged Saudi Arabia and Iran to observe restraint after tension over the execution of a prominent cleric Nimr Al-Nimr along with 46 others by the Saudi government. The UN… – Continue reading
Shortly before New Year’s, on Wednesday, December 30, 2015, the media reported that Julius Baer Group AG (“JB”) expected to pay about $547 million to settle the U.S. investigation into how the bank (and its bankers) assisted U.S. taxpayers in evading tax. This investigation began more than 4 years ago,… – Continue reading
Although the British Virgin Islands is often seen as an offshore tax haven, a closer look shows such opinions may be overstated There is a stereotypical image of the so-called ‘tax haven’ for ‘shady people to put their money’. While it is true that BVI Finance enjoys warm, sunny weather… – Continue reading
Increasing regulation has made transfer pricing complex for multinational enterprises. Technology can help simplify the process In recent years there has been an increasing focus on transfer pricing, in line with the proliferation of transfer pricing requirements from a growing number of countries around the world, and the OECD’s project… – Continue reading
SAS and DataGear implement tailor-made FATCA solution within Al Baraka Bank Dubai, UAE – Al Baraka Bank Egypt , a subsidiary banking unit of Al Baraka Banking Group B.S.C. (ABG) , partnered with SAS®, the leader in analytics, and Data Gear, a Business Intelligence (BI) software & services provider, to… – Continue reading
The international community led by the had initiated the (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. Governments, and social groups have been voicing their concern over the past decade that multinational enterprises… – Continue reading
Several ‘brief-case’ professionals, well accomplished sole proprietors and very important personalities all go around earning millions of Naira in income but paying no tax Tax gap is used here to refer to the difference between taxes collected by government and what could ideally be collectible. Without a doubt, the gap… – Continue reading
As will be recalled from the previous blog posting that discussed so-called “Controlled Foreign Corporations” (CFC), a United States shareholder of a CFC can possibly be treated as having received “dividend” income at various times. These are when the US shareholder (i) has current income inclusions from the CFC under… – Continue reading
On 14 December 2015, the Swiss Council of States discussed the legislative draft of the Corporate Tax Reform III and in principle approved the reform package. In deviation from the revised draft legislation issued by the Swiss Federal Council on 5 June 2015, the Council of States voted against the… – Continue reading
Insurers and financial advisers are required to know the tax information of their customers, according to guidance published by the Association of British Insurers (ABI) and the Association of Professional Financial Advisers (APFA). The new requirement follows UK information exchange agreements including Foreign Account Tax Compliance Act, agreements with Crown… – Continue reading
Representatives of the Cyprus and the Ukrainian governments have signed, in Kiev, on Friday, 11 December 2015, a protocol amending their Double Tax Avoidance Treaty. The protocol is based on the Model Tax Convention for the Avoidance of Double Taxation OECD. The changes need to be ratified by both the… – Continue reading
Non-Belgian shareholders with a participation in a Belgian company with an acquisition value of at least €2.5m (but not reaching the 10 per cent participation threshold under the Parent–Subsidiary Directive) are now entitled to the Belgian participation exemption regime. In C-384/11 (Tate & Lyle Investments), the European Court of Justice… – Continue reading
The Belgian general withholding tax rate applicable to dividends and interest attributed as of 1 January 2016 increases from 25 per cent to 27 per cent. Interest on ordinary saving accounts and on certain government bonds (so-called ‘Leterme bonds’) as well as royalties continue to benefit from reduced withholding tax… – Continue reading
Here’s our overview of recent Belgian tax developments, including the main new Belgian tax measures adopted by the laws of 18 and 26 December 2015. Speculation tax A ‘speculation tax’ of 33 per cent is introduced on capital gains realised by Belgian resident and non-resident individuals within six months from… – Continue reading
Two more top banks getting away with paying NO corporation tax in the UK: Credit Suisse and Citigroup are latest to admit using previous losses to slash their bills Seven foreign investment banks in London now pay no corporation tax Fines and lawsuits used to slash their tax bills by… – Continue reading
International art dealer Guy Wildenstein is going on trial in Paris on charges of defrauding the French state of half a billion euros (about $550 million) in taxes, after two relatives tipped off authorities about the family’s financial dealings. Wildenstein, 70, Franco-American heir of a New York art-dealing empire, is… – Continue reading
Walmart stock has put up one of its worst performances in recent history. Walmart continues to be plagued by a number of issues including swelling costs and poor e-commerce growth. Against this backdrop, can Walmart stock make a comeback in 2016? Can Walmart Stock Make A Comeback in 2016 Walmart… – Continue reading
Indonesian President Joko Widodo’s government will start 2016 trying to get lawmakers to approve the country’s fourth tax amnesty since independence, a plan it says will lure back money stashed overseas to net an extra $4.4 billion of revenue this year. Bad move, say tax analysts, anti-corruption activists and the… – Continue reading
Japan, Taiwan January 4 2016 After many years of discussion and negotiation, Taiwan’s Association of East Asian Relation and Japan’s Interchange Association finally signed 「THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVAION WITH RESPECT TO TAXES ON INCOME」(the “DTA”) in Tokyo on 26 November 2015. For the… – Continue reading
New actions for advisors to consider in light of these developments In the last quarter of 2015, Russia saw a flurry of changes concerning the tax amnesty program, de-offshoring and the reporting of foreign accounts. We highlight the most significant developments below. What the New Rules Say Tax amnesty. On… – Continue reading
The FATCA reporting deadline for financial institutions in Portugal has been extended again, this time to 31 March 2016. An order of the Portuguese Secretary of State for the Financial Affairs, issued 28 December 2015, extends the deadline for Portuguese financial institutions to report relevant information under the FATCA regime… – Continue reading
The Ministry of Finance has announced a withdrawal of the one per cent withholding tax imposed on interest earned by individuals on any investments. The tax imposition on interests is part of provisions in the new Income Tax Act, 2015 (Act 896) which came into force on January 1, 2016…. – Continue reading
United States Vice President Joe Biden has never been one to hold his tongue. He certainly didn’t in his recent trip to Kiev. In a speech before Ukraine’s Parliament, Biden told legislators that corruption was eating Ukraine “like a cancer,” and warned Ukrainian President Petro Poroshenko that Ukraine had “one… – Continue reading
Yet another amnesty scheme mocks honest taxpayers The Federal Board of Revenue (FBR) has once again admitted its failure in dealing with the powerful class of traders in forcing them to file tax returns as other persons do. The government of the day, as expected, is more than keen to… – Continue reading
Official Irish statistics are being fattened up by massive tax inversions and the re-registering of companies, warns Dan White The ESRI estimates that the Irish economy grew by 6.7pc in 2015 and is forecasting GDP growth of 4.8pc for this year. GNP, which is generally regarded as a better measurement… – Continue reading
Two more investment banks have reported paying zero tax in Britain in 2014, prompting the opposition Labour party to urge the government to reverse a tax change it made for banks last year. Citigroup and Credit Suisse disclosed in the past fortnight that their main UK subsidiaries paid no corporate… – Continue reading
India on Wednesday approved the signing and ratification of an agreement with the Maldives for exchange of information aimed at curbing tax evasion and avoidance. According to the Economic Times of India, the approval was given by the Union Cabinet chaired by Prime Minister Narendra Modi. “The agreement will stimulate… – Continue reading
Italy has already brought several cases against global technology companies that have headquarters in low-tax nations like Ireland to avoid paying higher taxes in other countries, like Italy. Tax officials won’t say what Apple has agreed to pay, but citing local reports, the Times reports it may be around $350… – Continue reading
LOOPHOLE:The consulting firm said the transfer of shares from one tax shelter to another would theoretically allow their owners to avoid real-estate transaction taxes The government is likely to step up auditing efforts as a number of major tax amendments come into effect this year, diminishing the effectiveness of tax… – Continue reading
Investors in mutual fund (MF) schemes have to provide additional KYC (know your customer) information in the new year. The additional details have been mandated to ensure that India complies with tax information-sharing laws such as FATCA (Foreign Account Tax Compliance Act). The Association of Mutual Funds in India (AMFI)… – Continue reading
