PETALING JAYA, Mar 15 (Sin Chew Daily) — Local taxation expert Koong Lin Loong said the Internal Revenue Department’s target was not wealthy people but tax evaders. “Whether a person is evading tax is normally assessed with the ten-point criteria, and assets of unidentified origins will be their focus of… – Continue reading
Last November, the High Court’s decisions in Bywater Investments and Hua Wang Bank (Bywater) confirmed that a number of companies incorporated overseas were nevertheless Australian resident for tax because they “carried on business” and had their “central management and control” (CM&C) in Australia. The facts were extreme: the primary judge… – Continue reading
The Central Board of Direct Taxes (CBDT) has on 24th January 2017 issued final guidelines for determination of “Place of effective management”(POEM). On 27th of January, again CBDT released clarifications on “General Anti Avoidance Regulations” (GAAR). POEM is effective April 01,2016 whereas GAAR is effective from April 01,2017.POEM can be… – Continue reading
The LuxLeaks and Panama Papers scandals aroused shock and outrage the world over. However, reaction from Central and Eastern European statesmen and citizens was decidedly more muted. A new report has suggested profit shifting and tax dodging by businesses in the region is endemic – perhaps accounting for the lack… – Continue reading
It’s unlikely that RCM will be there for agricultural produce such as fruit, vegetables or cereals In services and goods prone to tax evasion, there will be a mechanism under the proposed goods and services tax (GST) regime to make buyers or receivers liable to pay the tax, instead of… – Continue reading
Ghana has signed an agreement with the government of Mauritius to ensure that its investors will not be taxed twice by the two countries and vice-versa. Known as the Double Taxation Avoidance agreement (DTA), the both Foreign Affairs ministers Shirley Ayorkor Botchwey and Mauritius counterpart Hon SeetanahLutchmeenaraidoo signed the agreement… – Continue reading
Creating a fairer tax system is on the state budget agenda again with a proposal from Democratic Gov. Tom Wolf to eliminate a business tax loophole. Wolf wants to close the Delaware loophole — a mechanism that allows businesses headquartered in other states to avoid paying taxes on their operations… – Continue reading
These three CGT exclusions have remained unchanged for five years. Over the last few years government has collected a significant amount of tax revenue by not fully adjusting the personal income tax tables for inflationary increases in earnings, thereby increasing the effective tax rate of individuals. A middle-class individual earning… – Continue reading
The Hong Kong Government has put forward a proposal to amend its tax laws to establish a dedicated tax regime for aircraft owners/lessors based in Hong Kong and leasing to offshore (including PRC) lessees/airlines (see Timeline / References below) (“Proposed Regime”). Assuming there are no surprises or drafting issues in… – Continue reading
What is a business expense deduction? A business expense deduction is a deduction allowed for ordinary and necessary expenses paid or incurred in connection with an individual’s trade, business or profession. IRC Section 62(a)(1) operates to assure that all trade or business expenses, deductible as delineated under specific IRC Sections,… – Continue reading
Federal agents raided three Caterpillar buildings near its Illinois headquarters on Thursday, company and law enforcement officials said, in an escalation of an inquiry into the heavy equipment manufacturer’s offshore tax practices. Caterpillar has been dogged by accusations that it slashed its domestic tax bill by shifting corporate profits from… – Continue reading
On 30 December 2016 the Commercial Court of Voronezh Oblast delivered a judgement in case No. А14-10190/2014 (the “Decision”) under the claim of Ilyushin Finance Co. Open Joint Stock Company (the “Company”). The case is an example of a broad interpretation of the list of documents confirming entitlement to a… – Continue reading
Nonresident Alien NRA tax withholding is applicable to U.S sourced income paid to foreign person and does not apply to payments made to U.S. persons. Foreign persons include nonresident alien individual, foreign partnerships, foreign corporations, foreign estates, and foreign trusts. The tax generally must be withheld from the payment made… – Continue reading
THE ORGANISATION for Economic Cooperation and Development (OECD) initiated the base erosion and profit shifting (BEPS) project in 2013 to address perceived gaps in international tax rules causing a loss of revenues for governments of about US$100 billion to $240 billion (Bt3.5 trillion to Bt8.4 trillion) annually. The OECD’s BEPS… – Continue reading
Transfer pricing—the price charged for intercompany transactions between entities in different tax jurisdictions—can be used to shift funds within a multinational corporation (MNC), and serves as an effective means to manage a firm’s finances. Transfer pricing—the price charged for intercompany transactions between entities in different tax jurisdictions—can be used to… – Continue reading
The Australian Government has introduced legislation to extend the goods and services tax (GST) to low value imports from July 1, 2017. The legislation, introduced on February 16, requires overseas vendors, electronic distribution platforms, and goods forwarders with an Australian turnover of AUD75,000 (USD57,528) or more to register for, collect,… – Continue reading
The EU has signalled plans to ramp up its work to tackle harmful tax practices internationally, with the Council working group that oversees implementation of the EU’s code of conduct on business taxation finalising a list of jurisdictions that are considered non-cooperative in tax matters to be published shortly. The… – Continue reading
Business leaders are calling on Chancellor Philip Hammond to tackle anomalies in the tax system that see high street shops pay higher rates on small premises than online giants do for vast warehouses. The Institute of Directors said the Chancellor should use next month’s Budget to set up a New… – Continue reading
A prominent QC yesterday backed calls for the Bahamas to switch to a ‘low tax’ business model, warning: “The survival of financial services is not an option.” Brian Moree QC, senior partner at McKinney, Bancroft & Hughes, said the Bahamas had to “figure out how to adjust its business model”… – Continue reading
Last Autumn, HMRC issued “Measuring Tax Gaps”, an annual report on the estimated UK tax gap. The tax gap being the shortfall in tax estimated by HMRC as being due in any one tax year from that which is eventually collected. In the accompanying press releases and in comments made… – Continue reading
Selection of Foreign Company as a tested party – practical considerations Introduction Transfer pricing regulations adopted by India are based on the arm’s length principle which revolves around the concept that the price or margin determined in a controlled transaction involving two Associated Enterprises (AE) should be commensurate with an… – Continue reading
MARTINSBURG — The Internal Revenue Service has started releasing this year’s top 12 scams targeting consumers known as “The Dirty Dozen.” The annually compiled list features a variety of scams the agency says are common and that taxpayers could encounter anytime, but especially during peak filing season. Phishing schemes lead… – Continue reading
Business Council of Australia is urging tax cuts to remain competitive but transparency report show members’ effective rate is 24.3% The members of the Business Council of Australia, who are leading the push to cut Australia’s corporate tax rate from 30%, already pay an effective tax rate five percentage points… – Continue reading
The Kuwait Ministry of Finance (MOF) has issued a ministerial resolution announcing that Deloitte & Touche, Al-Wazzan & Co in Kuwait has been certified with the ministry for the provision of Foreign Account Tax Compliance (FATCA) services. FATCA is a US legislation which aims to combat tax evasion by US… – Continue reading
THE scope of the withholding tax — a tax imposed on non-residents for services rendered to Malaysia-based companies — has been widened. It is one of the major tax changes that came into effect on Jan 17 under the Finance Act 2017. Under the changes, non-residents must pay withholding tax… – Continue reading
Legislation reintroduced in both the Senate and the House of Representatives calls for the repeal of the estate tax, or “death tax” as it is commonly known in the United States. Until 2012, estates paid a 35 percent tax above a USD5m cap. The tax was scheduled to revert in… – Continue reading
U.S. companies hold cash—lots and lots of cash—overseas to avoid paying the top corporate tax rate of 35% on those foreign earnings. But the rate could be heading down with a change in the federal government’s leadership, and the prospect of more repatriated earnings to work with has finance chiefs… – Continue reading
A European leader in financial, tax and regulatory reporting for the banking and insurance sectors, Invoke is expanding its software range to meet CRS/AEoI cross-country tax reporting requirements. As part of the global fight against tax evasion, the G20 and OECD program for the exchange of tax payers’ financial information… – Continue reading
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… – Continue reading
On December 21, 2016, the new Canada–Israel tax treaty entered into force. The new treaty was signed on September 21, 2016 in New York, and replaces the existing treaty that dates from 1975. For most purposes, the provisions of the new treaty took effect as of January 1, 2017. Overall,… – Continue reading
KARACHI: Finance minister Ishaq Dar on Friday said that tax evaders will find no place to park their ill-gotten money, as Pakistan will begin automatic-exchange of information from next year. “As per international agreement with OECD (Organisation of Economic Cooperation and Development), Pakistan will start automatic exchange of information regarding… – Continue reading
World Economic Forum debate hears how fight to make companies ‘pay their fair share’ is being undermined by race to cut corporation tax rates Efforts to tackle global tax avoidance are being undermined by a “race to the bottom” on corporate tax rates led by Britain and the US, the… – Continue reading
Agency is increasingly turning to cutting-edge data analysis techniques to improve service and ‘compliance’ The Canada Revenue Agency is scrutinizing the Facebook pages, Twitter feeds and other social media posts of Canadians it suspects could be cheating on their taxes. That’s just one example of the agency’s increasing focus on… – Continue reading
THERE was a time when a tax professional would confidently tell you that tax avoidance would not get you in trouble. You might be bending the rules a little to minimise your tax liability, but as long as you followed the letter of the law, you would be fine. On… – Continue reading
KUALA LUMPUR: The Royal Malaysian Customs Department is considering amendments to the Goods and Services Tax Act (GST Act) to start taxing foreign online service suppliers, said deputy director-general Datuk Subromaniam Tholasy. “E-commerce is pretty much catered for, except business-to-consumer (B2C) for example, downloads from overseas, how do we tax… – Continue reading
The Israeli Tax Authority has issued an official draft circular to clarify the tax guidelines that apply to bitcoin adopters. In an announcement last week, the Israel Tax Authority released its draft [PDF] on the proposed taxation of virtual currencies which are considered “assets”. Pointedly, the announcement also cites the… – Continue reading
Chancellor tells German newspaper if Britain were closed off from markets it may abandon European-style social model The chancellor, Philip Hammond, has suggested Britain could transform its economic model into that of a corporate tax haven if the EU fails to provide it with an agreement on market access after… – Continue reading
Trade agreement would have to include strict rules to prevent Britain becoming offshore haven, Dutch deputy PM says The Netherlands will block any EU trade deal with the UK unless it signs up to tough tax avoidance regulations preventing it from becoming an attractive offshore haven for multinationals and the… – Continue reading
THE Panama Papers, the world’s biggest leak, highlighted the complex ways used by companies and individuals to conceal who the actual beneficiaries of a company are. Some of them put their money into offshore accounts such as in Labuan, which is also an off-shore financial centre and tax haven. One… – Continue reading
Portuguese income tax law provides for a 20% reduced rate and, in respect to income obtained abroad, a full tax exemption, for certain types of income derived by individuals having the status of Non-Habitual Portuguese Residents (NHPR). Any individual that in a certain year becomes tax resident in Portugal will… – Continue reading
The 2017 Budget Law introduced (starting from fiscal year 2017) favourable provisions for people wishing to become tax residents in Italy. It is aimed at wealthy individuals who wish to bring in new capital resources. The regime is inspired by the non-domiciled resident regime which is in force in the… – Continue reading
The Slovak Government and Parliament made several changes to the tax system with effect from 1 January 2017. The recently adopted amendments concern – among others – corporate and personal income tax, value added tax, special levy in regulated industries, as well as social security and health insurance contributions. Here… – Continue reading
Move could be a worrying indicator of investment trends post-Brexit, post-Beps Snap, the company behind Snapchat, has opted to open its new new international headquarters in London, rather than Dublin, Amsterdam or Luxembourg, bucking a trend which for decades has seen US multinationals book their international sales in one of… – Continue reading
Cyprus signed the Organisation for Economic Co-operation and Development’s Multilateral Competent Authority Agreement for the Automatic Exchange of Country-by Country Reports between its member states on 1 November 2016 after approval by the Council of Ministers at its meeting held on 28 September 2016. Following publication in the government gazette… – Continue reading
Authored by IFC Media Recent global events from the release of the Panama Papers to a series of high-profile inversions have given international tax regulators both rhetorical ammunition and public support to execute a global crackdown on multinational tax planning. The goal is to increase total taxes paid by global… – Continue reading
Centralised company registers will now detail who ultimate beneficiaries are. Malta’s stand on amendments seen as ‘watering down’ anti-money-laundering rules are in line with the EU’s position, a spokesman for the Office of the Prime Minister told the Times of Malta. EU governments have just agreed to create centralised company… – Continue reading
Jean-Claude Juncker deliberately blocked the EU’s efforts to fight tax avoidance while in office as prime minister of Luxembourg, according to documents revealed by The Guardian and the International Consortium of Journalists. EurActiv France reports. Member states have supposedly spent the last two decades cooperating in the committee on business… – Continue reading
The German Government has adopted draft anti-avoidance legislation intended to make it more difficult for domestic taxpayers to avoid tax through the use of “mailbox companies in tax havens.” The draft bill, approved by the Cabinet on December 21, contains more stringent reporting obligations for German taxpayers with foreign financial… – Continue reading
The Central Board of Direct Taxes in India issued Circular Number 41 on December 21, 2016 providing clarifications on applicability of ‘indirect transfer’ provisions under the Indian Income Tax Act, 1961 to investors of Foreign Portfolio Investors (FPIs) – earlier known as Foreign Institutional Investors (FIIs) in India. The circular… – Continue reading
Treasury says individuals or corporations who take deliberate action to help others evade paying tax face steep fines. Tax advisers, accountants and lawyers who aid the super-rich with offshore tax evasion will face tough new penalties from New Year’s Day, with HMRC now able to publicly name and shame “enablers”…. – Continue reading
