Category: Individuals

 The Pillar Two model rules: a train wreck in the making

On December 20, 2021, the OECD issued model rules for Pillar Two—the 15% global minimum tax. It is a brutally complex 70-page package and introduces two fundamental changes to the October 2021 OECD framework: a new Qualified Domestic Minimum Top-Up tax (QDMTT) and a significant rewrite of the Undertaxed Payment Rule (UTPR). ... - Continue reading

Spain’s National Court challenges the deductibility of intragroup services in the absence of a written contract

In recent years, the Spanish tax administration and Spanish courts have had a clear tendency to challenge the provision of intragroup services, denying its corporate income tax deductibility and increasing the tax burden for taxpayers carrying out these transactions in Spain. ... - Continue reading

United States: US FinCEN Proposes Expansion Of SAR Sharing Rules

The Bank Secrecy Act ("BSA"), enacted in 1970 and amended most recently by the Anti-Money Laundering Act of 2020 ("AML Act"), was in intended to provide "appropriate frameworks for information sharing" among financial institutions, government authorities and others.2 The BSA provides for the reporting of suspicious transactions, authorizes the secretary of the Treasury (the "Secretary") to issue regulations and allows the Secretary to delegate to the director of FinCEN the authority to "take all necessary and appropriate actions to implement and administer the provisions of the [BSA]."3 ... - Continue reading

Is Tax Avoidance A Crime In The Uk?

There are financial and criminal penalties involved in tax evasion. Other instances can be civil or criminal. Generally speaking, HMRC deals with all types of fraud and evasion through civil processes. The severity of your tax evasion depends on how large a jail sentence you can expect, assuming you are charged with tax evasion. ... - Continue reading

Impact of Mexico’s ‘controlling beneficiary’ rules

From 2022, taxpayers are obligated to obtain, keep and provide to the Mexican tax authorities when so requested, information of individuals who are considered to be the ‘controlling beneficiaries’ of legal entities, trusts and other legal vehicles, such as name, date of birth, gender, nationality, tax residence, tax ID number and marital status. ... - Continue reading

How To Evade Taxes Canada?

In order to hide income or inflate expenses, intentionally overstating receipts or claiming in the wrong ways, hiding income, or lying to the Canadians, tax evasion can be considered in this regard. The goal is to gain as many benefits from compliance as possible in violation of the law, whereas aggressive tax avoidance is to evade compliance. ... - Continue reading