Category: Business

HMRC to ‘bear down’ on tax planning in updated vision

A CLAMPDOWN on tax planning, a transformation of its services for taxpayers and delivering a professional, efficient and engaged organisation are the three key objectives for HMRC in its updated single departmental plan. The government department has outlined its main visions and objectives for the period between 2015 and 2020,… – Continue reading

Hungary, Turkmenistan sign double taxation avoidance agreement

Hungary’s State Secretary for Economic Development and Regulation István Lepsényi and Turkmenistanʼs Minister for Economy and Development Bazarov Batyr signed a double taxation avoidance agreement yesterday in Budapest, according to reports. Hungary and Turkmenistan initiated negotiations on the matter last year to allow for a more transparent and favorable business… – Continue reading

Global Tax Update – June 2016

Asia Pacific The January – March edition of tax highlights for the Asia Pacific region highlights industry developments from Australia, China, Hong Kong, India, Indonesia, Korea, Malaysia and Singapore including: Australia’s new tax system for Managed Investment Trusts The final stage of China’s B2V reform to be rolled out from… – Continue reading

UK To Close Property Developer Offshore Tax Loophole

The United Kingdom has legislated to stop property developers from using offshore structures in the Crown Dependencies to avoid UK tax on profits. The UK has published legislation to bring into force amendments to the tax treaties between the UK and the Crown Dependencies – Guernsey, Jersey, and the Isle… – Continue reading

India Signs OECD Country-by-Country Reporting Agreement

In an ongoing effort to increase transparency by multinational enterprises (MNEs), India joined Canada, Iceland, Israel, New Zealand and the People’s Republic of China in becoming the 39thsignatory to the OECD ‘s Multilateral Competent Authority agreement for the automatic exchange of Country-by-Country reports (CbC MCAA). The Country-by-Country Reporting Agreement was… – Continue reading

Google tax kicks in starting June 1

The finance ministry has notified that the equalisation levy (popularly known as Google tax) introduced in this budget, will come into force from June 1. As of now, it will apply to payments for online advertisements made by Indian business entities to non-residents (such as Google,Yahoo, Twitter, Facebook) where the… – Continue reading

ICC urges consideration of broader trade implications of tax policies in response to BEPS recommendations

The International Chamber of Commerce (ICC) recognizes the efforts of an increasing number of tax authorities to revise their tax policies in response to the international guidelines outlined in the G20 mandated Organisation for Economic Co-operation and Development (OECD) Base Erosion Profit Shifting (BEPS) project. ICC urges national governments to… – Continue reading

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… – Continue reading

Value Chain and Your Business: How do BEPS, transfer pricing and the new union customs code interact?

OECD BEPS guidance, outlining new standards for tax transparency and transfer pricing documentation, and the new union customs code, containing important changes to customs valuations, call for immediate action. Recent developments At the doorstep of a new era of tax transparency driven by the OECD BEPS project, the new Union… – Continue reading

Will new tax treaty with Mauritius turn India into a fund management hub?

The new tax treaty between India and Mauritius may achieve what last year’s budget tried to do, albeit unsuccessfully—encourage offshore fund managers to relocate to India, in the process making the country a fund management hub, much like London, Dubai or Singapore. With the new agreement restoring parity between domestic… – Continue reading

Cyprus and Latvia sign Treaty for the Avoidance of Double Taxation on Income

Cyprus and the Government of the Republic of Latvia signed in Brussels on Wednesday the Treaty for the Avoidance of Double Taxation on Income. The Treaty was signed by the Minister of Finance, Harris Georgiades, on behalf of the Republic of Cyprus, and the Minister of Economics, Dana Reizniece-Ozola, on… – Continue reading

Visible change in tax administration, but still a long way to go

The Delhi HC has delivered path-breaking and bold verdicts, quashing proceedings initiated by CBDT and CBEC administrative guidance for assessments and subsequent denial of benefits. A question tax professionals are often asked is: Has the government done enough to address the situation on tax? Several negative catchphrases had peppered headlines… – Continue reading

Cyprus and Latvia sign Treaty for the Avoidance of Double Taxation on Income

Cyprus and the Government of the Republic of Latvia signed in Brussels on Wednesday the Treaty for the Avoidance of Double Taxation on Income. The Treaty was signed by the Minister of Finance, Harris Georgiades, on behalf of the Republic of Cyprus, and the Minister of Economics, Dana Reizniece-Ozola, on… – Continue reading

Being Named In The Panama Papers Doesn’t Mean You Broke the Law

The Panama Papers have recently drawn a great deal of investigation and public attention. Over 230,000 organizations and individuals were named as having set up offshore companies in tax haven like the British Virgin Islands, Panama, the Cayman Islands or the Bahamas. The public’s initial reaction was suspicion and anger toward… – Continue reading

Singapore, Cambodia Sign Tax Treaty

Singapore and Cambodia have entered into a double taxation avoidance agreement to boost cross-border trade and investment between the two countries. The Agreement was signed on May 20, 2016, by Indranee Rajah, Singapore’s Senior Minister of State for Law and Finance, and Aun Pornmoniroth, Cambodia’s Senior Minister of Economy and… – Continue reading

EU Lays Down the Law on Tax Deals as Apple Probe Continues

The European Union, locked in a tax battle with the likes of Apple Inc. and McDonald’s Corp., laid down the law in its bid to rein in governments that woo multinationals with special fiscal deals allowing them to reduce their fiscal liability by booking profits abroad. The European Commission, which… – Continue reading

India-Mauritius Tax Treaty Renegotiated

On 10 May 2016, the Government of India issued a press release1 stating that India and Mauritius have signed a protocol (New Protocol) amending the double tax avoidance treaty between the two countries (the Treaty). Based on the press release and the New Protocol, following are the key changes to… – Continue reading

U.S. non-participation in the Common Reporting Standard (CRS) will be a challenge

The U.S. is under international criticism because under its Intergovernmental Agreement (known as IGA) reciprocal exchange accords, the U.S. has already transmitted information on those who are tax residents outside the U.S. to respective national tax authorities under the IGA. The spotlight is on the U.S. because the U.S. has… – Continue reading

Philippines Gets Tougher On Tax Evasion

The Philippines Department of Finance has tabled before the Congress a slew of amendments aimed at further strengthening the country’s anti-money laundering and bank secrecy laws. The amendments to Anti-Money Laundering Act 2001 (AMLA) are aimed at improving the Anti Money Laundering Council’s (AMLC’s) ability to safeguard the financial system… – Continue reading

Investors making money must pay taxes, no fear of FDI fall: Arun Jaitley

India had in August 1982 signed the treaty with Mauritius to eliminate double taxation of income and capital gains to encourage mutual trade and investment. Investors must pay taxes on money they earn in India and the domestic economy is now strong enough to depend on any “tax-incentivised route” to… – Continue reading

EAC fail to reach consensus on common tax rates

East African Community member states have failed to reach a deal on a common tax rate as the bloc’s smaller economies worry about significant revenue losses. The failure to harmonise value added tax, income tax and excise tax rates has left the regional bloc deliberating on how to harmonise legislation… – Continue reading

UK Finance Bill 2016 – Royalty Witholding Tax

Domestic UK law imposes a 20% royalty withholding tax on limited types of payment and on specific categories of intellectual property. This year’s Finance Bill expands the scope of intellectual property royalties that are subject to UK royalty withholding tax. UK businesses should review their intellectual property licensing agreements to… – Continue reading

Transfer Pricing in China 2016 – New Publication from China Briefing

Transfer Pricing in China 2016, the latest publication from China Briefing and Dezan Shira & Associates, is out now and available for purchase through the Asia Briefing Bookstore. Transfer pricing is a reality for any multinational company. As a result of a globalized economy and increasing complexity in business models,… – Continue reading

Tax havens accuse US of ‘hypocrisy’ over tax avoidance

A group of tax havens have accused larger countries like the United States of “hypocrisy” when it comes to cracking down on tax avoidance. With the issue of offshore finance high on the agenda in light of the fall out from the so-called Panama Papers scandal, world leaders convened in… – Continue reading

Government of Canada Signs International Agreement on Enhanced Tax Reporting by Large Multinationals

National Revenue Minister Diane Lebouthillier announced today that the Government of Canada has taken another step to stop the unfair practice of aggressive tax planning by signing an international agreement to implement stronger international reporting obligations for large multinational enterprises (MNEs). Thirty-one other jurisdictions have also signed the agreement. The… – Continue reading

GAAR to override bilateral tax treaty provisions: Official

New Delhi, May 11 (IANS) Following the revision of India’s bilateral tax treaty with Mauritius, the government on Wednesday said the General Anti-Avoidance Rule (GAAR ) provisions, with effect from April next year, will override the Double TaxationAvoidance Agreement (DTAA) in case of abuse. “GAAR being anti-abuse provision can prevail… – Continue reading

U.S. companies are saving $100 billion a year by shifting profits overseas, report says

NEW YORK — U.S. multinational companies are saving $100 billion a year by shifting their profits overseas to lower their tax bills, according to a study released Tuesday that found that corporate tax-dodging is a bigger problem than previously estimated. Most U.S. companies pay far less than the country’s 35… – Continue reading

China airs plan to help close multibillion-dollar corporate tax loophole

Authorities answer OECD call to clamp down on corporate grey area of internal transfer pricing with proposal for tougher reporting standards China is mulling plans to tighten tax reporting requirements on multinationals operating in the country to help close a ¬massive global loophole. If the plan goes ahead, multinationals would… – Continue reading

Who gains, who loses in new tax pact with Mauritius? Will FIIs run away?

India and Mauritius have signed a protocol amending the double tax avoidance arrangement between the two countries. The protocol is the outcome of an extensive and long-drawn-out negotiation process that has been going for more than a year and a half. While the text of the protocol is yet to… – Continue reading

Bank of Ireland loses £27m tax avoidance case in UK

Bank of Ireland has lost a £27m (€34.2m) tax avoidance case in the UK after an attempt to exploit a loophole that did not exist. HM Revenue and Customs challenged the attempt to avoid corporation tax by Bank of Ireland through a subsidiary, the former building society Bristol and West,… – Continue reading

National Assembly’s Procrastination to Lead to Extra Taxes with Korea-US FTA

The National Assembly of South Korea is postponing the ratification of the Foreign Account Tax Compliance Act (FATCA) for the automatic exchange of South Korean and U.S. taxpayers’ financial information. Under the circumstances, South Korean financial companies are about to be forced to pay more than 600 billion won (US$521… – Continue reading

Banks bear the brunt of tax laws which force foreigners to open an account

Banks say tax rules cracking down on property speculation force them to screen for money-laundering at their own cost. Banks are refusing to open accounts for foreigners if they think the costs outweigh the benefits. New property and tax laws launched late last year made “offshore persons” buying or selling… – Continue reading

Bank account requirement makes it tougher to pay tax in NZ: expert

A change to our tax rules aimed at foreign property investors is likely to affect many people, a tax expert says. A bill poised to be passed by Parliament this week may increase the red tape for anyone based overseas doing taxable business with this country. The Taxation (Residential Land… – Continue reading

Hong Kong: Recent Development On CRS / AEOI & CbC Reporting

In August 2015, the Organisation for Economic Co-operation and Development (OECD) published the first edition of the Common Reporting Standard (CRS) Implementation Handbook to provide practical guidance to assist government officials in implementing the Standard for Automatic Exchange of Financial Account Information in Tax Matters (AEOI). The AEOI and CRS… – Continue reading

Irish Revenue Explains Estonia DTC Royalty Tax Changes

The Irish Revenue has issued a brief explaining how the implementation of a most favored nation clause in Ireland’s tax treaty with Estonia will affect the tax treatment of royalties. Ireland’s Double Tax Convention (DTC) with Estonia became effective in 1999. It contains a provision whereby the tax treatment of… – Continue reading

Australia Moves to Remove ‘Double Taxation’ on Digital Currency

For a month starting May 3, The Treasury of the Australian government will be accepting submissions from interested parties to comment on a newly-released discussion paper entitled ‘GST treatment of digital currency’ as part of the 2016-17 Budget. The Treasury says the government has realized that consumers are ‘double taxed’… – Continue reading

US plans reporting requirements for foreign-owned disregarded entities

US disregarded entities owned by foreign persons would be treated as domestic corporations under regulations proposed by the US Internal Revenue Service (IRS) on Friday (REG-127199-15). The new rules would apply for purposes of the reporting, record maintenance, and other compliance requirements that apply to 25% foreign-owned domestic corporations under… – Continue reading

Residence-Based Taxation Put Forward For Americans Abroad

With regard to the increasing talk in the US Congress on tax reform, American Citizens Abroad (ACA) has provided the House of Representatives Ways and Means Committee with a full reform proposal for the enactment of residence-based taxation (RBT) for American expatriates. ACA has said lawmakers should enact RBT instead… – Continue reading

Governor of U.S Tax Haven Delaware Launches Blockchain Initiative

Governor Jack Markell will extend Delaware’s hospitality (home to more corporations than people) to Blockchain firms. Speaking at the Bitcoin community’s event in New York, Consensus 2016, Democratic Governor Jack Markell announced an initiative by the U.S State of Delaware to embrace the blockchain industry. His plan is to provide… – Continue reading

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… – Continue reading

UAE – Jersey trade relations: from a tax haven to taxonomy

As with any offshore financial centre, secrecy has been synonymous with the Channel Islands of Jersey. But the reason for the strong relations between the self-governing British dependency and the United Arab Emirates – still not known to many – is not confidentiality alone. It has not been so long… – Continue reading

Tax planning in the context of Panama Papers

Panama Papers’ disclosures now and earlier dealings of Vodafone through Cayman Islands are stories of famous tax havens, which evoke discussions of how tax evasion takes place. These are all direct taxes, mainly corporate tax, and not indirect tax. These are cases of tax planning that come to the fore… – Continue reading

Equalization levy resistance shows up BEPS’ challenges

The Internet and Mobile Association of India’s (IAMAI’s) pushback against the equalization levy on e-commerce transactions introduced in the union budget shows up the difficulty revenue authorities will have when they try to protect their tax base. The last word on this subject hasn’t been said and the original budget… – Continue reading

Thomson Reuters Releases Special Report on OECD”s Country-by-Country Reporting Requirements

Thomson Reuters Checkpoint has just released a special report addressing the European Commission’s Anti-Tax Avoidance Package (ATA) and other global Country-by-Country Reporting (CbCR) developments designed in conformity with the OECD BEPS Action 13 recommendations. The report, BEPS Filing Requirements for Multinationals Under Country-by-Country Reporting, will help multinational enterprises (MNEs) gauge… – Continue reading

Mexico: Multilateral Agreement For Automatic Exchange Of Transfer Pricing Documentation

On January 27, 2016, 31 Countries (among them Mexico) signed the Multilateral Competent Authority Agreement for automatic exchange of Country-by-Country reports (the “Agreement”) to be received from their taxpayers as part of the implementation of Action 13 of the Base Erosion and Profit Shifting Action Plan issued by the Organisation… – Continue reading

LuxLeaks whistleblower trial begins in Luxembourg

The former PwC employee turned whistleblower behind the LuxLeaks scandal that implicated Luxembourg in industrial tax avoidance went on trial in the tiny European duchy on Tuesday. Antoine Deltour, 30, a former auditor at global accounting firm PwC, is accused of stealing documents from his employer before he quit the… – Continue reading

DNB to reveal tax haven customers

Scandal-plagued Norwegian bank DNB has agreed to turn over information to state tax authorities about Norwegian customers who have held bank accounts set up in tax havens by DNB’s own operation in Luxembourg. The future of DNB’s board of directors, meanwhile, was in doubt following heavy criticism that neither DNB’s… – Continue reading