Category: Corporates

Canada, Switzerland ratify instrument to tackle tax avoidance

Canada and Switzerland on August 8 deposited with the OECD their instruments of ratification for the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS MLI). The BEPS MLI, negotiated by over 100 countries and jurisdictions, updates the existing network of tax treaties and… – Continue reading

Bermuda Monetary Authority: 50 Years Later

As the Bermuda Monetary Authority [BMA] celebrates 50 years in 2019, we take a look back at the last five decades. From providing sound policy advice to pushing Bermuda forward as a reputable place to conduct business, the BMA has had an incredible impact on Bermuda’s financial landscape. 1990-1999 Exchange… – Continue reading

Australia’s tax office can use Paradise Papers data to pursue multinationals: Court

Australia’s High Court ruled unanimously that giant Glencore could not rely on “legal privilege” to prevent the Australian Tax Office (ATO) from accessing emails, bank records, PowerPoint presentations and other files from the 2017 Paradise Papers investigation. Typically, documents marked “privileged” do not have to be disclosed in court. Companies… – Continue reading

Canadians for Tax Fairness concerned about inaction on Panama Papers

It is estimated that the use of tax havens is costing federal and provincial governments at least $7.8 billion in lost tax revenue. Low and middle income Canadians are the ones paying for that missing $7.8 billion in tax revenue. Ottawa (11 Aug. 2016) — The leak of the Panama… – Continue reading

Gaming Companies Call for Reaching USA-Croatia Double Taxation Avoidance Deal

ZAGREB, August 21, 2019 – Computer gaming is the most propulsive segment of the IT industry worldwide, and this trend is present in Croatia, too, where local gaming companies export all their products, however the biggest challenge in doing business is the absence of a Croatia-USA double taxation avoidance agreement,… – Continue reading

CIAT’s transfer pricing “Cocktail” provides solutions for transactional net margin method overuse

In recent years there has been a major public outcry for governments to take action to force multinational groups to pay a fair share of tax in the jurisdictions where their economic activities take place and to stop shifting profits to offshore tax havens. ... - Continue reading

CBI Dominica: Leading with Transparency

19 August 2019, Since 1993, Dominica has been at the forefront of the citizenship by investment (CBI) industry, setting high standards in due diligence, processing times, and most recently, transparency. Indeed, this month the nation liaised with prominent international professional services firm PricewaterhouseCoopers (PwC) to release a report clarifying the… – Continue reading

US appeals court sides with Amazon in $1.5 billion transfer pricing dispute

A US federal appeals court on Friday affirmed the Tax Court’s decision in Amazon, ruling that cost sharing buy-in payments made by Amazon’s Luxembourg subsidiary in exchange for Amazon’s transfer of intangible property should not include compensation for transferred residual business assets such as workforce in place, goodwill, and going concern value. ... - Continue reading

What happened to the proposed amendments to Bank Secrecy Act?

The news is replete with discussions on the refiling of the proposed bills for the other TRAIN Packages with the 18th Congress. However, there seems to be no discussion yet on any proposed amendment to the Bank Secrecy Act, Republic Act (RA) 1405, as amended, particularly the proposed amendments to… – Continue reading

High Court confirms ATO can use information from data leaks

Today the High Court confirmed that the ATO may use information obtained from data leaks, even if leaked from a law firm. Second Commissioner Jeremy Hirschhorn said today’s decision in Glencore International v. Commissioner of Taxation means the ATO can continue to use the ‘Paradise Papers’ and other similar data… – Continue reading

Mauritius leaks latest reminder of how much we lose to tax havens

Mauritius leaks latest reminder of how much we lose to tax havensA report by Canadians for Tax Fairness Bay Street and Tax Havens revealed how over 90% of Canada’s largest corporations have subsidiaries in tax havens. Ottawa (06 Aug. 2019) — Last month Canadians for Tax Fairness reported that, while… – Continue reading

Taxpayers given six months to challenge Denmark transfer pricing assessments based on insufficient documentation

A Danish tax administration decree, published 12 July in response to the Supreme Court’s decision in the Microsoft case, establishes a new practice for determining whether transfer pricing documentation must be available at the time the taxpayer is required to file its tax return. ... - Continue reading

Journalists publish details of 200+ companies using offshore law firm, conclude Mauritius promotes tax avoidance

Data on more than 200 companies that engaged the Mauritius office of Conyers Dill & Pearman were published on the internet today by the International Consortium of Investigative Journalists (ICIJ) as a result of leak of confidential information. ... - Continue reading

Netherlands draft law requires disclosure of cross-border transactions to tax authorities

On July 12 the Netherlands government published a legislative proposal implementing the EU mandatory disclosure directive. This follows an internet consultation on a draft legislative proposal which ran from December 19, 2018 — February 1, 2019. ... - Continue reading

Portugal: Central bank to disclose public report on large debtors

The Bank of Portugal (BdP) is to publicly disclose aggregated information about large bank debtors by 17 July, announced the chair of the Budget and Finance Committee. On 23 May, the central bank sent parliament an extraordinary report on the problematic loans and other assets that caused banking problems and… – Continue reading

Transfer (mis)pricing

TRANSFER pricing — the pricing of commodities traded between or within multinational enterprises — is a legal practice and a key feature of cross-border and intra-firm transactions. The United Nations prefers to use the broader phrase ‘trade pricing’ in addressing this practice and defines it as a ‘normal incident of… – Continue reading

Taiwan to join anti-tax evasion program CRS

Taiwan expected to share financial information with Japan and Australia in 2020 TAIPEI (Taiwan News) – Taiwan is expected to exchange financial information with a number of countries in September of next year as part of the Common Reporting Standard (CRS) program designed to combat tax evasion. Developed by the… – Continue reading

Taiwan to join anti-tax evasion program CRS

Taiwan expected to share financial information with Japan and Australia in 2020 TAIPEI (Taiwan News) – Taiwan is expected to exchange financial information with a number of countries in September of next year as part of the Common Reporting Standard (CRS) program designed to combat tax evasion. Developed by the… – Continue reading

Bank of Singapore’s Hong Kong CEO on Developing a Greater China Proposition

As Bank of Singapore’s Global Market Head for Greater China and North Asia, and since March 2018 also Hong Kong CEO, Derrick Tan has plenty of challenges in front of him. But he can draw on from his multi-faceted background – he spent five years as an investigating officer with… – Continue reading

Tensions between the drive for transparency and the right to protection of privacy

Update on the UK government’s proposal to improve transparency with a new register of persons with significant control of companies which hold UK property. In our last article (https://hubbis.com/article/transparency-enhanced-in-the-uk) we looked at the UK government’s proposal to improve transparency with a new register of persons with significant control of companies… – Continue reading

BIR files tax evasion charges against 15 Metro Manila business taxpayers

The Bureau of Internal Revenue filed Thursday separate criminal cases against 15 business taxpayers in Metro Manila for alleged refusal to pay tax debts totaling to more than P493 million. This brought to 482 the number of tax evasion charges lodged by the bureau under its Run-After-Tax-Evaders (RATE) program under… – Continue reading

A Huge Tax Break Went to a Politically Connected Company in New Jersey Despite Red Flags

Holtec International told New Jersey regulators that Ohio was competing for its new headquarters. But officials there stripped the firm of past tax awards for failing to create the jobs it promised.n January 2014, as Holtec International explored sites for a new national headquarters and high-tech manufacturing center, the New… – Continue reading

India: Government Of India Ratifies MLI – Bringing India On The Cusp Of A New International Tax Regime

The Government of India (Union Cabinet) has approved the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) and India's final position to the same. ... - Continue reading

Oman to introduce Common Reporting Standards

Muscat: Oman, in line with its commitment to align itself with international best practices in tackling cross-border tax evasion and meeting the standards set by the European Union (EU) and the Organisation for Economic Co-operation and Development (OECD), is currently in the process of issuing regulations for automatic exchange of… – Continue reading

Australia: OECD releases beneficial ownership implementation toolkit to facilitate transparency

In brief – Beneficial ownership toolkit aims to help governments implement legal and supervisory frameworks to identify and collect beneficial ownership information Beneficial ownership is a critical issue in many areas of law, in particular tax and anti-money laundering. National authorities often struggle to keep up with private ingenuity in… – Continue reading

India: Split Residency – ITAT Upholds The Taxpayer’s Claim For Treaty Exemption, Applies Centre Of Vital Interest Test

Dual Residency gets attracted when an expat in the year of move qualifies as a resident of the host country (i.e., the country in which he is deputed) as well as home country (i.e., the country of his residence). On account of dual residency, an expat can be doubly taxed… – Continue reading

Canada: With Recent Regulatory Developments, Canadian Business Interest In Cayman Will Grow

Canada is home to some of the largest multinational corporations in the world, a bustling pension fund and private equity industry, and growing numbers of alternative investment, real estate, and insurance shops. With dynamic industry and growth in the region, Canadian business leaders are leveraging Cayman as a financial centre to help… – Continue reading

India: Bombay High Court Quashes 197 Order Rejecting Mauritius Tax Treaty Benefits

High Court sets aside section 197 order due to absence of prima facie evidence of tax avoidance Rejects factors such as lack of business activities and administrative expenses as conclusive of sham transactions Holds that a detailed inquiry can be conducted during normal assessment Directs refund of withheld tax subject… – Continue reading

British overseas territories top corporate tax loophole index

Governments are stepping up efforts to recoup more tax from multinationals, with the European Commission forcing iPhone maker Apple to repay 13 billion euros after it used Ireland to cut its tax on European profits to almost zero. The Tax Justice Network, a group campaigning for transparency, said its study… – Continue reading

Tax Office Investigating Individuals, Corporations for Offshore Tax Evasion Allegations

The National Tax Service has launched an investigation into 104 individuals and corporations suspected of offshore tax evasion.The National Tax Service of South Korea launched an investigation targeting 104 individuals and corporations suspected of offshore tax evasion. The number is likely to increase over time. The targets include Orion Holdings… – Continue reading