Category: Corporates

Has the New Inland Revenue Act paralysed the Double Tax Treaty Network of Sri Lanka? Part 2

7.What are Mutual Administrative Assistance Agreement (MAAAs) The new IRA defines the “Mutual Administrative Assistance Agreement” to mean a tax information exchange agreement or other international agreement for mutual administrative assistance in relation to taxation matters. Section 75 (5) of new IRA “Mutual administrative assistance agreement” means a tax information...

ATO’s tax gap figures revealed: $2.5 billion missing from corporates, multinationals

An estimated $3.5 billion in revenue from large corporates and multinationals is at risk to the economy, but through audit activity this will reduce to $2.5 billion, according to the Australian Taxation Office. On Wednesday the agency is releasing the first tranche of its long-awaited highly anticipated “tax gap” figures,...

Will the new corporate offence of failure to prevent tax evasion and enhanced international tax transparency change the landscape for tax investigations?

The 30 September 2017 is an important date for HMRC and its “relentless” clampdown on global tax evasion. First, it marks the coming into force of the landmark corporate offence of failure to prevent tax evasion under Part 3 of the Criminal Finances Act 2017. Secondly, it is the commencement...

Time to tackle the shell companies

Hyderabad: Shell companies are becoming a common phenomenon globally and even in India. These companies are posing several challenges to governments and regulators for various reasons had been probing their involvement in large scale money laundering and tax avoidance cases. A shell company is a non-trading organisation that does not...

Treasurer to launch fresh attack on multinational tax avoidance as Parliament resumes

Treasurer Scott Morrison will launch a fresh attack on tax avoidance this week in Parliament in a bid to get the so-called “Google Tax” pushed through and shift public attention towards the Coalition’s record on multinational tax crackdowns. The Diverted Profits Tax is due to be debated this week, almost...

Offshore tax evasion: compliance and penalties – part 1

Sometimes it can be hard to keep up with the avalanche of government announcements on tax avoidance and evasion. In the first of a two part series, Jason Collins, a member of the CIOT’s management of taxes sub-committee and partner at Pinsent Mason, provides an overview of the rapidly changing...

Israel: “Wallet Companies”- Draft Tax Bill Within The Scope Of The Arrangements Law For 2017 – 2018

Recently, the Finance Committee concluded its deliberations regarding the imposition of tax legislation pertaining to “wallet companies” (companies owned by individuals who provide services through them) within the scope of the Arrangements Law for 2017 – 2018. The original draft bill was softened and even sweetened for a particular period...

EU wants stricter transparency rules on ownership to prevent tax evasion and fight Money Laundering

The European Parliament’s Monetary Affairs and Civil Liberties committees’ overwhelming support for access by EU citizens to information concerning the beneficial owners of companies without having to demonstrate a ‘legitimate interest’ and trusts would have to meet the same requirements. MEPs agreed the on their position on EU Anti-Money Laundering...

Indonesia – Key Indonesian Law Considerations For International DCM Issues

Following Moody’s Investors Service affirmation of Indonesia’s sovereign credit rating at Baa3 with a stable outlook in January 2016, there has been renewed interest in the international bond market for Indonesian credits. This bulletin seeks to summarise the regulatory changes in Indonesia over the last 24 months as well as...

Abusive Tax Structures, Make Way For Budget 2017’s Transfer Pricing Combat Weapons

Among other things, Union Budget 2017 will be remembered for two firsts – the introduction of secondary adjustment and thin capitalisation rules. Both are transfer pricing provisions which will have a far-reaching impact on corporates. Secondary Adjustment Since the concept of secondary adjustment is introduced for the first time in...

The end of international tax planning?

CROSS-border taxation in current times is poised for significant changes. Tax is key in foreign ventures. Absent tax strategies and foreign tax leakages would erode margins and return of investment. Although international tax-efficient strategies to mitigate capital gains tax (CGT), withholding tax (WHT) and the risk of creating a taxable...

Income-tax dept issues norms to determine residency status of companies

New guidelines aim to check tax evasion, ensure foreign firms are not taxed on their global income. New Delhi: The income-tax (I-T) department on Tuesday issued the final guidelines for place of effective management (PoEM) rules that seek to determine the residency status of a firm for calculating its tax liability. The...

Showdown between ATO and big business looms as list of company tax paid is revealed

A showdown between the Australian Taxation Office and the nation’s largest companies including Chevron, Crown and BHP Billiton is looming as the tax man hits seven large companies with tax bills amounting to $2 billion. On Friday, the ATO released its corporate tax transparency report for 2014-15, which includes limited...

Final opportunity to disclose offshore assets before 1 May 2017 introduced by Finance Bill 2016

1. Why was a new offshore provision introduced by this year’s Finance Bill? Following revelations in the “Panama Papers” of major worldwide tax evasion in April 2016 (which included certain Irish Resident account holders), the Minister for Finance announced on budget day, 12 October 2016 that this year’s Finance Bill...

Australia’s Google Tax may be the second in the world but it’s too early to tell if it’s the ‘toughest’

When introducing the draft legislation for the Diverted Profits or so-called “Google Tax”, Federal Treasurer Scott Morrison claimed it would: …reinforce Australia’s position as having amongst the toughest laws in the world to combat corporate tax avoidance. Australia is the second country to introduce this type of tax, after the...

Tax havens are under attack

Ireland, accused of being a tax haven for multinationals such as Apple to pay nearly zero tax on the bulk of its profits earned outside the United States, finds itself with a new adversary in the global fight against unfair tax practices — Brazil. As of October 1, Brazil will...

Tax lawyers to grapple with new changes

With elements of the Liberal government’s 2016-17 budget coming to fruition, tax lawyers must stay up to date with the changes as their workload increases, according to a global firm partner. Speaking with Lawyers Weekly, DLA Piper tax partner Jock McCormack (pictured) said tax lawyers can expect to be busy...

HMRC explores tougher methods for publicising tax fraud by the wealthy

Public Accounts committee criticised HMRC’s lack of strategy HM Revenue & Customs (HMRC) is exploring how it can better publicise fraud investigation outcomes and increase the impact of the sanctions it uses, in order to dispel the myth “people are getting away with tax evasion”. The department said it wants...

Corporate tax avoidance: New rules adopted

On 12 July 2016, the Council adopted new rules addressing some of the practices most commonly used by large companies to reduce their tax liability. The directive is part of a January 2016 package of Commission proposals to strengthen rules against corporate tax avoidance. The package builds on 2015 OECD...

IRS inversion rules face blowback

A regulatory effort by the Obama administration to crack down on tax deals is facing backlash from business groups and lawmakers on both sides of the aisle. While the Internal Revenue Service (IRS) rules were intended to combat inversions — transactions in which a U.S. company combines with a foreign...

International Conference for Accountants and Lawyers Highlights Fundamental Changes to Taxation of Companies Involved in Cross Border Business

The recent EMEA Conference of Alliott Group, one of the world’s most established international associations of independent accounting and law firms, brought together tax professionals from 28 countries across the world to discuss Base Erosion & Profit Shifting (BEPS), a project led by the OECD and G20 whose Action Plan...

Australia announces multinational tax avoidance in federal budget

Australia announced a further crackdown on multinational tax avoidance in its annual budget on Tuesday, including the planned introduction of a UK-style diverted profits tax (DPT), that it expects to raise A$3.9 billion over the next four years. The government is creating a new Tax Avoidance Taskforce of 1,000 specialist...

HMRC launches consultation on new tax evasion offence

The Revenue has published its consultation on proposing to make companies criminally liable for failing to prevent their staff facilitating tax evasion The offence was first proposed in the 2015 Budget and was expected to come into effect in 2020. The Panama papers leak and subsequent scandal has put significant...

KPMG: Moves to curb international tax dodges

Global international tax takes from multinational companies will almost certainly increase in the next 5-10 years as governments around the world look to level the taxation playing field. Commenting on the New Zealand Herald’s series examining ‘the tax gap’ – multinationals channelling earnings to lower tax regimes, disadvantaging some of...

Equalisation levy may not be the right move

The ways of doing business in a digital economy have evolved rapidly. Traditional tax norms, effective in addressing issues in a world before high-paced technological and e-commerce, are increasingly becoming outdated. Taxation of e-businesses has been a globally identified challenge with tax authorities acknowledging that corporates in this disruptive environment...

Markit launches tax utility

LONDON & NEW YORK–(BUSINESS WIRE)–Markit (Nasdaq:MRKT), a leading global provider of financial information services, today announced the launch of a tax utility. The initial offering supports compliance with US Treasury FATCA obligations. Designed in partnership with Deutsche Bank, HSBC and Morgan Stanley, the service provides tax form validation and secure...

International and Irish Tax Update – March 2016

Summary The pace of change in international tax is dramatic. Each month brings new initiatives and developments at both national and supra-national levels. In this update, we focus on recent changes which are relevant to our clients. The OECD Base Erosion and Profit Shifting (“BEPS”) reports were finalised in October...

The rich people who pay no tax

Only the little people pay taxes. For a small, select cohort of rich Australians, the famous quote of New York property billionaire Leona Helmsley rings not as an outrage but as an inspiration. In the most recent documents released by the Australian Tax Office, there were 55 people who had...

Nikko Securities America Signs Deal with Fenergo for Regulatory Client Lifecycle Management

Fenergo offers Nikko Securities America, Inc. end-to-end Client Lifecycle Management with a regulatory focus on AML, KYC and FATCA Fenergo, the leading provider of Regulatory Onboarding and Client Lifecycle Management software solutions for investment, corporate and private banks, has announced a new deal to provide Nikko Securities America, Inc. with...

“Relentless in pursuit of tax evasion and avoidance”: HMRC sets out plan to 2020

In its departmental plan for 2015-2020 published last month, HMRC set out it’s role “to help the honest majority to get their tax right and make it hard for the dishonest minority to cheat the system”. One of the headline objectives for this period is: “maximise revenues due and bear...

‘Tax me if you can’: Tax activism of a different kind

It’s unlikely anybody was particularly surprised when Finance Minister Pravin Gordhan announced a number of initiatives to increase the amount of tax revenue; from sugar tax to a “tyre levy” to an increase in a number of existing sin taxes. But it’s perhaps the relaxing of voluntary disclosure rules that...

Budget 2016: Foreign investors seek a non-adversarial and stable tax regime

Is India back on the world map as a lucrative investment jurisdiction? Does the world see the Make in India dream becoming a reality? Well, the $222 billion investment pledges received during the Make in India week do resonate the revived positive sentiment! In fact, recent policy measures have clearly...

Ding ding, seconds out on Malta’s fight to stop Brussels’s tax plans

Malta has always insisted it is no tax haven, but it employs a system which allows foreign shareholders to claim a six-sevenths’ refund on their taxed dividends, taxed at the maximum 35%. There’s a new battle lining up for the Maltese government inside Brussels: an aggressive fight against tax avoidance...

Wind of Change: IMF Chief Calls For New International Taxation System

Governments globally should take steps to adjust taxation systems to close loopholes allowing multinational corporations to avoid paying taxes in countries of their origin, International Monetary Fund (IMF) Managing Director Christine Lagarde said on Monday. WASHINGTON (Sputnik) – The IMF chief said taxation allows governments to mobilize their revenues. She...

Revealed: how Project Goldcrest helped Amazon avoid huge sums in tax

Documents released during the internet giant’s court battle with the US Internal Revenue Service over a possible $1.5bn in unpaid taxes detail a complex restructuring and a deal with Luxembourg that delivered Amazon multimillion-dollar savings Amazon is facing a landmark court ruling in the US that could prise open its...

A global revolution in corporate tax is taking place but it will not be televised

A quiet revolution is taking place across Europe. It isn’t playing out on the streets of capital cities or in the debating chambers of national parliaments. It has been slowly happening with every newspaper headline about how little corporation tax some companies pay relative to their size. It is also...

A New Set of Amendments to the Russian CFC and Beneficial Ownership Rules

On February 15, 2016, the President of the Russian Federation signed Federal Law No. 32-FZ “On Amendments to the First and Second Parts of the Russian Tax Code (with Respect to the Taxation of Controlled Foreign Companies and the Income of Foreign Organizations)”, introducing a new set of amendments to...