Category: Israel

A precedential judgment in the matter of transfer pricing shuffles the cards as to granting options to employees

A judgment in the Contira case was handed down two weeks ago in the district court which dramatically changes the Cost Plus issues relevant to certain Israeli companies which provide services to a foreign related company. The judgment impacts on the situation where the Israeli company’s employees are granted options… – Continue reading

Swiss bank Julius Baer to settle US tax probe for $547 mn

One of the leading Swiss banks Julius Baer Group AG is set to reach a deal with US authorities over a tax probe by paying $547 million early next year. Julius Baer, Switzerland’s third-largest wealth manager after UBS and Credit Suisse has been under criminal investigation since 2011 by the… – Continue reading

Azerbaijan, Israel should pay much attention to private sector for constructive ties (exclusive)

By Anakhanum Khidayatova – Trend: A lot should be left to the private sector to achieve constructive relations between Azerbaijan and Israel, according to Dan Stav, Israeli ambassador in Baku. “In order to encourage business in each country, you need to create conducive environment,” he said speaking to Trend Dec…. – Continue reading

Israel and Niue become the 91st and 92nd jurisdiction to sign OECD’s Convention on Tax Assistance Among Countries

In Paris on the occasion of the COP21, the Honourable Billy Graham Talagi, Minister for Ministry of Natural Resources of Niue signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters in the presence of Deputy Secretary General Rintaro Tamaki. Previously, Israel signed the Multilateral Convention on Mutual Administrative… – Continue reading

Corporate tax revenues falling- OECD

Corporate tax revenues have been falling across OECD countries since the global economic crisis, putting greater pressure on individual taxpayers to ensure that governments meet financing requirements, according to new data from the OECD’s annual Revenue Statistics publication. Average revenues from corporate incomes and gains fell from 3.6% to 2.8%… – Continue reading

Israel becomes 91st country to join OECD tax avoidance effort

Israel has joined 90 other countries in signing up to the OECD’s instrument to combat offshore tax avoidance and increase transparency in tax matters. The middle-eastern country became the 91st jurisdiction to sign the Multilateral Convention on Mutual Administrative Assistance in Tax Matters yesterday, which enables the exchange of information,… – Continue reading

FATCA me if you can: Hong Kong should learn from Israel

Israeli politicians occasionally risk the ire of their American allies. Some have successfully challenged legislation in court to slow the implementation of FATCA-related legislation. Watch and learn, Hong Kong. As the United States continues to bring country after country to their knees to comply with its Foreign Account Tax Compliance… – Continue reading

The State of Israel increases enforcement ability against tax evaders

On November 22, 2015 the Israeli Ministry of Finance issued a press release announcing that on November 18, 2015 the Israeli Knesset approved in second and third reading a bill to increase the enforcement ability against tax evaders. According to the press release the bill allows the director of the… – Continue reading

Bets off again in Playtech’s takeover of Plus500

Teddy Sagi still owns a 30 per cent stake in Playtech, the gambling software firm The Israeli billionaire Teddy Sagi’s £460m takeover of Plus500, the financial trading firm, was torpedoed yesterday due to “concerns” raised by the Financial Conduct Authority watchdog. Mr Sagi is the founder of the gambling software… – Continue reading

Malta: Malta’s Double Tax Treaties – November 2015

In order to encourage the growth of international trade including that of financial services, successive Maltese governments have sought to conclude double tax treaties with important trading partners as well as with emerging countries. This policy is expected to continue in the future. To date, treaties are in force with… – Continue reading

Israel signs the Multilateral Convention on Mutual Administrative Assistance in Tax Matters

Did we only yesterday (November 23, 2015) report that the State of Israel increases enforcement ability against tax evaders and that on November 18, 2015 the Israeli Knesset approved a bill to increase the enforcement ability against tax evaders and that the bill promotes the affiliation of Israel to the… – Continue reading

HMRC publishes a policy paper setting out planned negotiations on DTAs and TIEAs

On November 13, 2015 the UK HM Revenue & Customs (HMRC) published a policy paper setting out planned negotiations on Double Taxation Agreements (DTAs) and Tax Information Exchange Agreements (TIEAs). According to the policy paper HMRC will begin negotiations on double taxation agreements with: • Nepal • Romania • Trinidad… – Continue reading

Fair’s Fair: Balancing The Interests of the State and of Wealthy Migrants

Clare Maurice, Arabella Murphy and Sophie Mazzier, Maurice Turnor Gardner LLP For better or worse, the concept of “fairness” is here to stay in relation to taxation, whether domestic or international. Politicians of all persuasions like to insist that their respective policies will ensure that everyone pays his or her… – Continue reading

Israel and Australia in tax treaty talks

An Israel delegation is scheduled to visit Australia in June 2016. The Israel Tax Authority is negotiating a treaty for prevention of double taxation with Australia, sources inform “Globes.” Tax Authority head Moshe Asher is currently in advanced talks with Australian Treasurer Joe Hockey, who himself declared that the Australian… – Continue reading

Israel looks to join int’l anti-money laundering task force

A Financial Action Task Force (FATF) delegation visits Israel this week to consider Israel’s application for membership. “Israel is working tirelessly to upgrade its standing as a regional leader in the struggle against money laundering and financing of terrorism through persistent regulatory changes and a more effective regime. Up until… – Continue reading

Your Taxes: Exporters beware of sales agents

On October 5 the OECD published recommended measures that purport to tackle BEPS – Base Erosion Profit Shifting. Exporters around the world need to take note of the latest recommendations of the OECD. Any business that uses overseas agents or warehouses should take note. A company resident in country A… – Continue reading

Mandatory disclosure rules: OECD releases final paper on BEPS 12

What has happened? On 5 October 2015 the OECD issued its final paper on BEPS Action 12 Mandatory Disclosure Rules, Action 12 – 2015 Final Report (Paper). In this Alert we highlight the main issues and recommendations for taxation reform raised in the Paper. The Australian Treasurer’s BEPS Press Release… – Continue reading

Mylan CEO Heather Bresch: We needed tax inversion in order to grow

The chief of the generic drug company discussed her “counterintuitive” strategy for creating U.S. jobs. Mylan is one of a handful of U.S. companies that has recently completed a controversial tax inversion, as the generic drug company moved its official base to the Netherlands earlier this year. While the decision… – Continue reading

Conference Focuses on Intersection of Tax Law and Citizenship

Tax experts from the United States, United Kingdom, Canada, Brazil and Israel spoke at a two-day conference at Michigan Law about the challenges of the Foreign Account Tax Compliance Act (FATCA) and a multitude of other issues at the intersection of the law of taxation and citizenship. Panel discussions at… – Continue reading

Your Taxes: OECD starts the BEPS tax revolution

Israeli importers and exporters, hi-tech and trading groups will all be in the base erosion and profit shifting firing line. On October 5 the Organization for Economic Cooperation and Development published a final comprehensive package of measures aimed at multinational corporations, large and small, that engage in BEPS – base… – Continue reading

India-Israel to sign pact on double tax avoidance

India and Israel will sign a double taxation avoidance pact and explore ways to ramp up engagement in diverse sectors during President Pranab Mukherjee’s three-day historic visit to the Jewish state, the first by an Indian Head of State, beginning tomorrow, reports NDTV. Ahead of his visit, Israel said the… – Continue reading

Leumi to Reclaim Bonuses From Executives After U.S. Tax Fine

An independent panel appointed by Bank Leumi Le-Israel Ltd. recommended that a former chairman and chief executive officer both return bonuses after the lender agreed to pay a fine to U.S. authorities in a tax probe. An insurer for the former bank officials will pay an additional $92 million. Leumi,… – Continue reading

Justice Department Focuing on Offshore Account

At a recent tax conference a senior Justice Department official reaffirmed the commitment of the U.S. Department of Justice to continue offshore enforcement efforts. As is widely reported the official stated: “We are well beyond Switzerland at this point,” she said, citing enforcement announcements concerning India, Israel, Liechtenstein, Panama, the… – Continue reading

Transnational laws needed to curb fires

To solve the problem of the haze afflicting Singapore, Indonesia and Malaysia, extraterritorial action is needed to quench the forest fires in Indonesia that are generating the haze. A cross-border solution is a necessary answer even if it raises questions of national sovereignty. The Singapore Government should implement laws that… – Continue reading

U.S. Chases Swiss Bank Secrets to Singapore and Israel

Dozens of banks signed amnesty agreements disclosing tactics, providing prosecutors with valuable information At a rate of one or two a week, Swiss banks are doing what was once unthinkable: revealing to the world how they helped wealthy Americans cheat on their taxes. Once bastions of secrecy, 41 Swiss banks… – Continue reading

Cabinet approves double taxation avoidance protocol between India & Israel

The Union Cabinet chaired by the Prime Minister Narendra Modi, has approved the protocol amending the convention and the protocol between India and Israel, for avoidance of double taxation and for prevention of fiscal evasion with respect to taxes on income and on capital. The protocol provides for internationally accepted… – Continue reading

Cabinet okays amendments to tax avoidance pacts with Israel, Vietnam

NEW DELHI, OCTOBER 7: The Union Cabinet on Wednesday gave its nod for the introduction of a ‘limitation of benefit’ clause in the double taxation avoidance convention (DTAC) with Israel. The ‘LOB’ Article is an anti-abuse provision aimed at preventing misuse of the convention. The protocol that received the Cabinet’s… – Continue reading

Singapore: Singapore Tax Treaties: The End Of Limitation Of Relief?

What is limitation of relief? Here is an actual illustration: A client in Singapore has loans to a Spanish SOCIMI, a real estate investment company equivalent to a REIT. Spain requires tax to be deducted at source when interest becomes payable even if in fact the interest is not actually… – Continue reading

More disappointing news for U.S. citizens residing in Canada

In addition to Justice Martineau’s denial of injunctive relief and dismissal of the request for summary judgment in Hillis and Deegan v. The Attorney General of Canada, as discussed in our previous post, U.S. citizens residing in Canada received more disappointing news on September 29, 2015, when Judge Thomas M…. – Continue reading

Your taxes: Info exchange inner workings

The OECD Common Reporting Standard (CRS) and FATCA in the United States are long-winded. So the OECD published on August 7 a much shorter and lighter guide: the “Common Reporting Standard Implementation Handbook” (the CRS Handbook). The CRS and FATCA represent a sweeping change toward automatic information exchange and away… – Continue reading

Israel and Australia to negotiate tax treaty

Australian Treasurer Joe Hockey: Australian companies can take greater advantage of Israel’s knowledge-based economy. There is no tax treaty between Australia and Israel, but the lack will soon be made good, according to an announcement by Joe Hockey, Treasurer in the Australian government. “As part of the Government’s ongoing efforts… – Continue reading

Malta – the optimum choice for private equity

Malta provides an outstanding opportunity for private equity and venture capital managers. It has a flexible LP structure, an extensive network of double tax treaties, a favourable local tax regime and experienced service providers who can provide a cost-effective solution,” comments Felicity Cole (pictured), Head of the Funds Department at… – Continue reading

FACTA: Expect the unexpected (and the worst) in tax treatment and disclosure of offshore assets, particularly for Indian assets

On July 9, 2015, India and the US signed an agreement to implement the Foreign Account Tax Compliance Act (FATCA) that will facilitate exchange of information between the two countries starting on October 1, 2015. FATCA was signed by Revenue Secretary Shaktikanta Das and US Ambassador Richard Verma in New… – Continue reading

Israel Banking Watchdog Says Leumi Execs May Have to Return Bonuses

Regulator demands Bank Leumi investigate top management in wake of U.S. tax-evasion settlement. Bank Leumi should take back bonuses it paid three former senior executives after the lender was forced to pay a huge penalty to the United States for tax violations that occurred under their watch, Banks Supervisor David… – Continue reading

Ireland making ‘little or no’ effort to curb corruption – report

Ireland has made “little or no” effort over the past four years to create a corruption-free playing field for global trade, violating its “obligation to combat cross-border bribery”, reports the Irish Times. The Transparency International Exporting Corruption report, released on Thursday, found that Ireland, along with countries such as Russia,… – Continue reading

Canada Court Ruling Could Put Brakes on FATCA

Aug. 19 — Tax authorities and practitioners around the world are awaiting a Canadian court’s ruling on the legality of Canada’s legislation to comply with the Foreign Account Tax Compliance Act. The Federal Court of Canada is due to issue by Sept. 30 a ruling on the validity of the… – Continue reading

Worldwide: Governments Continue To Welcome Wealthy Foreigners

With the UK announcing new tax rules for foreigners living in the country, the government has been careful not to damage the country’s appeal to wealthy foreigners. The “non-dom” tax status “plays an important role in allowing those from abroad to contribute to our economy”, says George Osborne, the UK’s… – Continue reading

Prison for Accountants’ Offshore Tax Fraud

LOS ANGELES (CN) – Two tax preparers convicted of running an offshore tax-fraud scheme were given federal prison sentences on Monday, the Justice Department said. David Kalai and his son Nadav, both principals of United Revenue Service, were convicted of one count of conspiracy to defraud the Internal Revenue Service… – Continue reading

Sars to waive penalties for voluntary disclosure?

Fears of a VDP application giving rise to a ‘witch hunt’ are ill-founded. The rapid development in international tax transparency over the past two years in the form of the OECD (Organisation for Economic Co-operation and Development) Common Reporting Standard (CRS) has caused many South African taxpayers to consider regularising… – Continue reading

The $100 Billion Deal Is Still Out There for Pharma

Why stop at $221 billion? Drug companies are entering another round of dealmaking, after plowing past the global record. Teva Pharmaceutical Industries Ltd.’s $40.5 billion agreement Monday to purchase Allergan Plc’s generic-medicines business puts the mechanism in place to trigger more takeovers. For starters, the remaining Allergan company — with… – Continue reading

The future is transparent : As banking secrecy comes to an end, taxpayers with overseas assets should ensure they are on the right side of what can be draconian law.

It is widely recognized that offshore banking secrecy is fast becoming a thing of the past. The signing of bi-lateral and multi-lateral agreements between jurisdictions and the fast approaching Common Reporting Standard (CRS) under which jurisdictions will automatically exchange financial information has seen to that. The UK’s voluntary disclosure program… – Continue reading

British trade boost: How UK firms profit from Middle East commerce

Lord Sieff, then head of food at Marks and Spencer, returned from 1950s Israel having inked an agreement with horticulturalist Gordon Bickel to buy his gypsophila spray carnation. More than half a century later Bickel’s firm, Carmel Agrexco, has expanded from what he calls the ‘white gold’ that was behind… – Continue reading

Your Taxes: The draft transparency law

A draft amendment to the Income Tax Ordinance and the Prohibition on Money Laundering Law regarding Israel joining international tax information-sharing agreements. The Israel Tax Authority (ITA) has just circulated a draft amendment to the Income Tax Ordinance and the Prohibition on Money Laundering Law regarding Israel joining international tax… – Continue reading

Justice Department Announces Two Banks Reach Resolutions under Swiss Bank Program : Banque Pasche SA Will Pay $7.229 Million Penalty and ARVEST Privatbank AG Will Pay $1.044 Million Penalty; Both Continue to Cooperate With Department of Justice

Washington, DC—(ENEWSPF)—July 9, 2015. The Department of Justice announced today that two banks, Banque Pasche SA and ARVEST Privatbank AG, have reached resolutions under the department’s Swiss Bank Program. “Banque Pasche and ARVEST have provided detailed information regarding the ways in which Swiss banks helped U.S. taxpayers conceal foreign accounts… – Continue reading

OECD establishes roadmap for membership with Lithuania

10/07/2015 – The OECD set out a clear path for Lithuania’s accession to the Organisation, reinforcing the OECD’s commitment to further extend its global membership. On 8 July 2015 the 34 OECD Members adopted the Roadmap for the Accession of Lithuania to the OECD Convention setting out the terms, conditions… – Continue reading