Yearly Archive: 2016

Cabinet approves signing of revised DTAA with Cyprus

The Union Cabinet on Wednesday gave its nod for signing of revised double taxation avoidance agreement (DTAA) with Cyprus, a popular tax haven. It is also learnt to have approved the removal of island nation as a non-cooperative jurisdiction for income-tax purpose. Cyprus was the only country to have been… – Continue reading

How Amazon Values Its Tech Assets for Tax Purposes

Regulators in Europe and the US say that the value Amazon places on the technology behind user experience varies radically depending on which appraisal will lower its tax bill. Jeff Bezos’s relentless focus on user experience has helped him make Amazon the most valuable e-commerce company in the world. But… – Continue reading

Treasury proposal may fine tax evaders up to 200% of amount owed

Tougher stance follows Theresa May’s leadership campaign promise to be more punitive of tax evasion and avoidance The Treasury is proposing new rules to punish offshore tax evaders who fail to come clean about their finances before September 2018, with fines of up to 200% of the amount owed. Published… – Continue reading

Ireland: Holding Companies In Ireland – August 2016

Ireland has become a destination of choice for holding companies due to its capital gains participation exemption, generous foreign tax credit system, membership of the EU, ever expanding double tax treaty (“DTT“) network (72 signed, with 70 in effect), lack of controlled foreign companies legislation, thin capitalisation rules and the… – Continue reading

Liechtenstein Ratifies Multilateral CbC Report Pact

On August 22, 2016, Liechtenstein filed its instrument of ratification of the Multilateral Competent Authority Agreement on country-by-country (CbC) reporting. With the move, Liechtenstein will be able to share the information contained in the CbC reports with tax treaty partners that have implemented the necessary reporting standards. Liechtenstein was among… – Continue reading

OECD consults on branch mismatch structures to curb profit shifting

The OECD is consulting on the mechanics of dealing with branch mismatch structures under Base Erosion & Profit Shifting (BEPS) Action 2, designed to neutralise the effects of hybrid mismatch arrangements as part of the wider anti-avoidance action plan The BEPs project has already released a report on Action 2,… – Continue reading

Many Reporting Entities Unprepared For FATCA, CRS

New research shows that financial institutions are generally confident about meeting existing and incoming automatic exchange of information obligations. However, the study also found that a significant proportion of the industry is facing higher costs and risking fines by being under-prepared for new compliance requirements. The research by Aberdeen Group… – Continue reading

Closing tax avoidance loopholes

THE OECD/G-20 Base Erosion and Profit Shifting (BEPS) Project is designed to provide solutions for governments to close the gaps in existing international rules that allow corporate profits to “disappear” or be artificially shifted to low or no tax environments, where companies have little or no economic activity. In February… – Continue reading

Switzerland, Italy Seek Progress On Cross-Border Taxation

Switzerland has informed Italy of its desire to sign the bilateral agreement on the taxation of cross-border commuters. The point was made by Didier Burkhalter, the head of Switzerland’s Federal Department of Foreign Affairs, during a meeting with the Italian Foreign Minister, Paolo Gentiloni. They discussed bilateral issues, Switzerland’s policy… – Continue reading

Offshore jurisdictions unshaken by Brexit

The UK’s crown dependencies and overseas territories are unlikely to suffer following the Brexit vote, and may even be a model for a post-EU UK says Richard Wilson QC Even before the UK’s decision to leave the EU, offshore jurisdictions faced a number of significant challenges: increased pressure to provide… – Continue reading

VAT tweaks to help offset income tax cut

THE FINANCE DEPARTMENT will keep value-added tax (VAT) exemptions for three key sectors, but may opt to remove this benefit from senior citizens and others to arrive at a “fair” tax regime. Finance Secretary Carlos G. Dominguez III told reporters late last week that the government is looking to trim… – 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

Top corporate players sign up for voluntary tax code

Twenty of the nation’s largest companies have voluntarily signed up to a comprehensive new code to disclose more details of their tax affairs in their latest ¬annual accounts following a series of scandals involving local and offshore firms. In the May budget, the federal government announced it was committed to… – 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

Tanzania extends its e-tax system to cut fraud

Tanzania’s president, John Magufuli, has extended the e-tax system to all government bodies as he bids to slash fraud. Tanzania’s president, John Magufuli, has been in office for less than a year, but he is already making a name for himself as a staunch opponent of fraud and corruption. Magufuli… – Continue reading

Imbert signs agreement to share tax info with US

Finance Minister Colm Imbert and US Ambassador John Estrada yesterday signed an agreement that will pave the way for the implementation of the Foreign Account Tax Compliance Act (FATCA) enacted in the United States of America in 2010. Imbert signed on behalf of T&T, while Ambassador signed on behalf of… – Continue reading

India notifies capital gains exemption norms for Mauritius investors

Private equity (PE) investors and venture capital (VC) funds from Mauritius will have to pay capital gains tax on investments into quasi-equity in India, under the revised tax treaty, unless the conversion of investments into equity is not finalised before 1 April 2017. The government has notified the revised double… – 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

Join amnesty or face ‘hell’ for tax evasion: Indonesia finance minister

Indonesian Finance Minister Sri Mulyani Indrawati warned tax dodgers that an eight-month tax amnesty programme was their last opportunity to have all of their “sins deleted” or face “hell” afterwards. In her first interview with the foreign media since returning as minister, the former World Bank managing director also told… – Continue reading

IRS to Allow Voluntary Reporting of Global Tax, Profit

An IRS official said the agency is continuing its work on a mechanism to allow voluntary filings of country-by-country reports for companies required to comply with both the U.S. rules and those in a foreign country with an earlier effective date. “Actually being able to accept CBC reports for the… – Continue reading

Disingenuous Statements About Tax From Apple’s Tim Cook

Apple is a major part of why the United States is the world’s leading innovator on new technologies, particularly those involving telecommunications and computers. The company has over 66,000 domestic employees, and a large percentage of its customers are here — at least 40 percent, according to its latest annual… – Continue reading

‘Enabling’ tax avoidance – legislation must draw distinction between promoting avoidance and advising on the law

Commenting on today’s government consultation paper on ‘Strengthening Tax Avoidance Sanctions and Deterrents’, John Cullinane, Tax Policy Director of the Chartered Institute of Taxation, said: “This is the latest in a series of measures cracking down on those who profit from tax avoidance schemes. The Government need to be careful… – Continue reading

Govt likely to issue notices to industrialists for tax evasion

PESHAWAR: The Khyber Pakhtunkhwa government is likely to issue show cause notices to owners of about 20 industrial units for not paying infrastructure development cess, according to sources. They said that provincial government had levied one per cent infrastructure development cess on imported items. “Now majority of the businessmen have… – 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

City firms could face 100pc fines for helping with tax avoidance

City firms that help businesses run tax avoidance schemes could face huge financial penalties under fresh Government proposals. Banks, accountancy firms and lawyers could be forced to hand over underpaid tax if they are found to have broken the law. Currently, advisers who facilitate tax avoidance by exploiting loopholes and… – Continue reading

Pakistan to sign 98-state convention for tax information exchange

ISLAMABAD: In a major development, Pakistan has been formally offered to sign and ratify a 98-countries’ convention — “Multilateral Convention on Mutual Administrative Assistance in Tax Matters” — to check tax evasion and tax avoidance by any of its nationals living in any of the member countries. Signing the convention… – Continue reading

Mauritius, South Korea Sign New Tax Deal

The Mauritian Government has announced that, on August 11, a tax information exchange agreement (TIEA) was signed between Mauritius and South Korea for the mutual sharing of tax information. The TIEA provide for cooperation in tax matters between the two jurisdictions. The agreement, once ratified, will allow each country to… – Continue reading

Luxembourg Proposes Law To Enact Global Tax Reporting Rules

Companies doing business in Luxembourg will be required to file global tax information now that the nation has released draft legislation to implement new international tax reporting rules. The rules—known as country-by-country reporting—would require companies to submit a global blueprint outlining the location of their operations, taxes paid, income earned,… – Continue reading

Costa Rica and Germany Sign Agreement to End Double Taxation

Last Wednesday August 10 at Germany’s Federal Foreign Ministry Office, Costa Rica and Germany celebrated the ratification of the establishment of legal instruments as part of an agreement to eliminate double taxation of income and assets, stated Costa Rica’s Ministry of Foreign Relations in a press release Friday. The agreement… – Continue reading

Pakistan mulls providing tax-free zones to stimulate investment

In order to encourage foreign investment in Pakistan, the federal government has decided to provide facilities like Panama and Virgin Islands to foreign investors in Pakistan. According to documents available with Daily Times that government is going to introduce the companies’ bill 2016 in parliament soon according to which incumbent… – Continue reading

Wesfarmers urges Aldi to sign tax code in ‘corporate peer pressure’

Coles has urged its German rival Aldi to sign up to a new tax transparency code that will lead to more big businesses, particularly multinationals, releasing detailed information about the tax they pay. Aldi has yet to sign up to the Voluntary Tax Transparency Code, which targets more than 1500… – Continue reading

«Delaware» Crackdown: All Bark and No Bite?

The U.S. has used judicial might to successfully pursue offshore tax cheats all over the world. A little-noticed new rule introduced by Barack Obama’s administration gets tough on U.S. states such as Delaware and Nevada, which are notorious for murky shelters often used for illicit purposes. But there is a… – Continue reading

India Ratifies Mauritius Double Tax Protocol

Through Notification No. 68/2016, the Government of India has ratified a Protocol to its tax treaty with Mauritius. The protocol was signed on May 10, 2016, in Mauritius, in a bid to limit abuse of the India-Mauritius double tax avoidance agreement. The protocol provides India with the right to tax… – Continue reading

Jakarta Plans Tax Haven Near Singapore

Indonesia has defined two islands near Singapore as its own tax havens to prevent taxpayers from keeping their assets offshore – in Singapore, for example. The two islands identified by Indonesia are Bintan and Rempang, according to a report on Monday in the Singaporean daily «Straits Times» and a story… – Continue reading

Scotland formally calls on UK to close “tax haven” loophole

SCOTLAND has formally called on the UK to close a legal loophole that allows Scottish firms to be used as secret offshore tax shelters. Holyrood politicians have been demanding action on Scotland’s limited partnerships (SLPs) ever since some of the unique corporate arrangements were exposed as Eastern European money-laundering vehicles… – Continue reading

Panama Ambassador to U.S.: Our Transparency Commitment Remains Strong

Four months since the so-called “Panama Papers” made global headlines, Panama continues a path of reform aimed at improving financial transparency and closing loopholes exploited by foreign tax cheats. Among our steps, we established an independent committee to examine Panama’s laws and regulations and make recommendations for strengthening them. While… – Continue reading

Greece to Seek Help from Bulgaria, Cyprus to Find Suspected Tax Evaders

Greece intends to sign agreements with Bulgaria and Cyprus which will allow Athens to look into suspected tax evasion by Greek-owned companies registered in the two countries, Greek newspaper Kathimerini has reported. The closer inspection of Greek-owned companies registered in Bulgaria and Cyprus will aim to find out whether they… – Continue reading

Tim Cook addresses Apple’s US taxes, says no repatriation without ‘fair rate’

Apple CEO Tim Cook struck back at critics of the iPhone maker’s strategy to avoid paying U.S. taxes, telling The Washington Post in a wide ranging interview that the company would not bring that money back from abroad unless there was a “fair rate.” Along with other multinational companies, the… – Continue reading

UK offshore companies side-step new transparency rules

Some of Britain’s offshore companies have continued to wriggle out of new transparency restrictions according to research released this weekend. Under rules brought in on 1 July 2016, British companies need to disclose on an annual basis any changes to directors or shareholders – both being deemed “persons of significant… – Continue reading

FG inaugurates national tax policy document committee

The Federal Government on Wednesday inaugurated an eight-man committee tor review and update the National Tax Policy document. The Minister of Finance, Kemi Adeosun, while inaugurating the committee in Abuja, said the government was committed to the continuous improvement of Nigeria’s tax system as part of the dynamic framework to… – Continue reading

Jokowi to Lower Income Tax Rate

“Maybe lower the income tax from 25 percent to 20 percent first, then 17 percent.” The government will once again provide the public with tax break following its tax amnesty program. It is currently reviewing a plan to lower income tax rates and the possibility of establishing a tax haven,… – 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

The councils changing procurement rules to tackle tax avoidance

Salford Council has joined the other 14 councils from across the UK that have adopted motions to support ethical procurement. Moved by Labour and Co-operative councillor Jim King, the recent motion strengthens checks in the council’s procurement to exclude businesses that engage in tax avoidance. The initiative falls in line… – 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

Equalisation Levy seeks to cast Indian tax net wider

Budget 2016 introduced a new tax called Equalisation Levy (“EL”), aimed at taxing online transactions. EL was originally mooted by the OECD in Base Erosion and Profit Shifting (BEPS) Project Final Report on Action 1 – Addressing the Tax Challenges of the Digital Economy (the “Report”). We will examine Equalisation… – Continue reading

BUSINESS MONDAY: NEW AGREEMENT TO BENEFIT B’DOS, USA

AN Intergovernmental Agreement (IGA) between Barbados and the United States will allow for greater co-operation under the Foreign Account Tax Compliance Act (FATCA). This is according to Julia Tonkovich, of the United States Treasury Department. Ms. Tonkovich stated that FATCA, which was in place since 2010, is part of the… – Continue reading