Category: Individuals

New Corporate Criminal Offences of Failure to Prevent Facilitation of Tax Evasion

Quick Guide Part Three of The Criminal Finances Act 2017 (CFA 2017) introduces two new corporate criminal offences: The failure to prevent facilitation of UK tax evasion offences The failure to prevent facilitation of foreign tax evasion offences Both “failure to prevent” offences can be committed by a body corporate… – Continue reading

Guyanese businessmen warned of global crackdown on offshore tax evasion

Commissioner-General of the Guyana Revenue Authority (GRA), Godfrey Statia warned Guyanese businessmen against offshore tax evasion, saying that global systems are being increasingly networked to weed out tax cheats and report them to their home-countries. Addressing a luncheon organised by the Guyana Manufacturing and Services Association (GMSA) at the Georgetown… – Continue reading

Tax expert says amendment to new tax law likely before implementation next year

Removal of withholding tax on G-Sec income effectively frees foreign investors paying any taxes New tax law proposes to remove 10% withholding tax on G-Secs but makes such income liable for income tax up to 24% This likely to result in sizeable leakage of tax revenue to govt. as G-Secs… – Continue reading

Business Europe Rejects EU Digital Turnover Tax Proposal

Markus J Beyrer, Director General of Business Europe, has expressed concerns about the proposed introduction of a European Union turnover tax on digital businesses. On September 21, the European Commission launched a new agenda to ensure that the digital economy is taxed “in a fair and growth-friendly way.” This could… – Continue reading

FBR begins collecting individuals’ account details for OECD members

KARACHI: The tax authorities have kicked off a planned program under which they share foreign individuals’ financial-account information with the member countries of the Organization for Economic Cooperation and Development (OECD), sources said on Saturday/ The Federal Board of Revenue (FBR), issued a notification regarding the schedule for exchange of… – Continue reading

Hong Kong to examine tax concessions to attract global funds, Financial Secretary says

Financial Secretary Paul Chan Mo-po said tax incentives would help Hong Kong compete with other fund management centres The government will examine the existing tax concessions applicable to the fund industry to make Hong Kong into a diversified and competitive international fund management centre against its global counterparts, said the… – Continue reading

Switzerland Consulting On WHT Reforms

The Swiss Federal Department of Finance is consulting on proposals to amend the Withholding Tax (WHT) Ordinance, to more clearly define the rules for non-resident taxpayers. Under the proposed reforms, “quasi-residents” will be permitted to request a subsequent ordinary tax assessment. “Quasi-residents” are employees who are not domiciled in Switzerland… – Continue reading

The Netherlands – Budget 2018 – Dividend withholding tax and non-resident taxation

On 19 September 2017, the Dutch government released the State’s Budget for the year 2018. The Budget includes a draft bill to expand the dividend withholding tax exemption to tax treaty countries, to introduce a withholding tax obligation for holding cooperatives and to limit the taxation of non-resident investors. If… – Continue reading

Income Tax Jitters in The Bahamas Following IMF Recommendation

NASSAU, The Bahamas, Friday September 22, 2017 – An International Monetary Fund (IMF) proposal for The Bahamas to implement a low rate income tax has drawn a mixture of skepticism, approval and downright rejection. Following its Article IV consultation with the Hubert Minnis administration, the Washington-based financial body urged the… – Continue reading

Public Country-by-Country Reporting; Taxpayers’ Rights

Appropriate Use of Country-by-Country Reports The OECD has now published Guidance (available here) on the appropriate use of Country-by-Country Reports (‘CbCRs’) by national tax authorities. This is in response to some valid MNE concerns that tax authorities may misuse CbCRs. “Appropriate use” is clarified as being for (i) high-level transfer… – Continue reading

Government set to crack down on tax perks for well-off investors

Popular investment schemes offering generous tax breaks for wealthier investors are likely to face new restrictions. The Treasury is mulling a crackdown on Enterprise Investment Schemes, likely to be announced in the next Budget on November 22. The scheme allows people to invest in start-ups, either directly or through funds,… – Continue reading

Ghana-Morocco double tax agreement to come into force in 2018 – (Part 2)

In our last publication, we discussed the signing of the Ghana-Morocco Double Tax Agreement (“DTA”) and the provisions of the DTA in relation to the taxation of permanent establishments and business income. In the concluding part of the article, we will discuss the taxation of investment, employment and service incomes… – Continue reading

Turkish gov’t to form special team to surveil, audit e-commerce

In order to tackle irregularities and unfair competition among e-commerce companies, Ankara is planning to form a special unit to track e-commerce activities and transactions in the country The Turkish government is planning to create a special unit of 200 people to track e-commerce activities in the country, Finance Minister… – Continue reading

Multinationals Fear Japan Reports Could Spur Outside Audits

Japanese multinational companies worry that filing their first country-by-country reports in 2018 will lead to a barrage of transfer pricing audits by developing countries. Companies are currently preparing their first country-by-country reports that must be filed with the National Tax Agency by the end of March 2018. Japan adopted country-by-country… – Continue reading

OECD Criticizes Estonia’s Dividend Tax Measure

The OECD has taken issue with the Estonian Government’s plans to reduce the rate of tax on distributed dividends for established companies, warning that the measure could complicate the tax system and discriminate against small firms. Under recently enacted legislation, tax on distributed dividends will be reduced from 20 percent… – Continue reading

Republicans launch worldwide campaign in bid for territorial taxation

Letters calling for the elimination of FATCA, among other tax issues, will be presented to the White House in about two weeks’ time. A global political organisation with affiliation to the Republican Party has recently launched a petition and letter writing campaign in protest of “citizenship-based” taxation – partly in… – Continue reading

The Finnish Supreme Administrative Court confirms that the business model chosen by parties must be respected in transfer pricing context

The Finnish Supreme Administrative Court published on 13 September 2017 precedent 2017:145 that further clarifies the scope of application of the Finnish transfer pricing adjustment provision (Act on Assessment Procedure (“AAP”) Section 31). In its previous landmark precedent KHO 2014:119 the Supreme Administrative Court stated that the so-called re-characterization of… – Continue reading

Donohoe says Ireland opposes ‘equalisation tax’ at EU meeting

The proposals plan to tax giant digital companies on turnover rather than profits EU finance ministers have agreed to step up technical work on harmonising the taxation of the giant digital companies with a view to debating “possible solutions” at their December meeting. The ministerial consensus was a significant setback… – Continue reading

Tax Reform Advocacy Group Outlines Pro-Growth Plan

With corporate tax reform still very much on the table, advocacy group Alliance for Competitive Taxation (ACT) has weighed in with a reform plan that it deems internationally competitive and pro-growth, and capable of driving transformational change in the U.S. economy. ACT doesn’t define its member businesses but says it… – Continue reading

EU Seeks a Digital Tax to Stem the ‘Bags of Money’ Lost to Loopholes

Finance ministers discuss new tax plans in Tallinn, Estonia France’s Le Maire says EU citizens ‘outraged’ by situation European Union finance ministers are developing a new way to tax digital companies such as Amazon.com Inc. and Facebook Inc. to raise money from an industry that they say provides less than… – Continue reading

Tax evaders set to face action: CBDT chairman Sushil Chandra

CBDT chairman Sushil Chandra says income tax dept will soon conclude probe into financial dealings of about 100,000 individuals suspected of tax evasion New Delhi: The income tax department will conclude its investigations into the financial dealings of about 100,000 individuals suspected of tax evasion and persuade many other assessees… – Continue reading

Multinationals would face mandatory tax on offshore profits, Steven Mnuchin says

Multinational corporations with profits held overseas would face a mandatory one-time tax as part of the planned Republican tax legislation, Treasury Secretary Steven Mnuchin said Wednesday. “There will be a ‘deemed tax’ as a one-time charge,” Mnuchin said in an interview with Fox News at the Treasury. U.S. companies have… – Continue reading

Partnership tax rules overhaul by 2018

Changes to partnership taxation are to go ahead with draft legislation now published, effectively clarifying the tax treatment for partnerships to ensure that the principle of taxing the beneficiary of partnership profit applies and to prevent a double reporting burden on investment partnership This measure makes changes to the income… – Continue reading

Slow UK aid for hurricane-hit islands linked to tax haven ties

Anguilla’s ex-attorney general says UK government may fear exposing its role in Caribbean territories’ tax arrangements Aid offered by the British government to its hurricane-battered territories in the Caribbean has been dismissed as “derisory” by a former attorney general of one of the worst-hit islands. Rupert Jones, who completed a… – Continue reading

Google, Facebook, And Others May Have To Pay More For EU Operations

Operations in the European Union haven’t been easy going for tech companies for quite a long time. While many European countries earlier called for strict privacy regulations and large fines on tech companies for violating them, they have now called for increased taxation for these companies for their operations in… – Continue reading

Use data effectively to exceed revenue target for IT, urges Finance Ministry

Prime Minister Narendra Modi had asked tax officers to use data analytical tools to proactively track and determine undeclared income and wealth and highlighted the need to strengthen data analytics and investigation wing of the tax department. gst cbdt Tax officials have been urged to “utilise data effectively” such that… – Continue reading

Anti-tax avoidance measures under fire from employers, tax advisors

The caretaker government may make the Netherlands a less attractive location for international business because of changes to the corporate tax system, the employers’ organisation VNO-NCW and tax advisers have warned, the Financieele Dagblad said on Monday. The employers and Dutch Order of Tax Advisors say the government is choosing… – Continue reading

Australia: Proposed changes to CGT main residence exemption for foreign residents

The Treasurer has recently released exposure draft legislation (Treasury Laws Amendment (Housing Tax Integrity) Bill 2017) in relation to removal of the CGT main residence exemption for foreign residents. The changes are part of the Commonwealth Government’s ‘housing affordability’ reforms announced in the 2017-18 Budget. This will affect both Australian… – Continue reading

Successfully Resolving Contentious Offshore Claims with the IRD: Concepts and Strategies

A Territorial Tax System Since the introduction of business taxation in 1948, Hong Kong has adopted a territorial tax system. Unlike most other advanced jurisdictions, Hong Kong does not tax worldwide income on the basis of residence, but only seeks to charge Hong Kong source profits. Profits tax is governed… – Continue reading

Revenue’s crackdown on VAT evaders yields £3.4bn from small and medium firms

Revenue & Customs collected an extra £3.4billion from small and medium-sized businesses in the tax year to April 2017 after a crackdown on firms that fail to pay VAT, according to tax investigation insurance company PFP. VAT accounted for 49 per cent of the extra tax take from investigations into… – Continue reading

The Corporate Offences of Failure to Prevent the Facilitation of Tax Evasion – What It Means for You

The United Kingdom’s Criminal Finances Act 2017 (the “Act”) creates two new corporate offences of failure to prevent facilitation of tax evasion (the “Corporate Offences”). These new Corporate Offences will be committed where a relevant body fails to prevent an associated person criminally facilitating the evasion of tax, whether the… – Continue reading