Category: Cyprus

Cyprus: Tax Evasion Or Tax Avoidance: A Predicate Offence Under Cyprus Anti-Money Laundering Laws?

Money laundering offences usually consist of conduct which seeks to conceal the criminal origin of wealth. When it was first introduced into the legal order in the 1980s, the principal objective of anti-money laundering legislation was to combat the introduction of the proceeds of drug dealing into the legitimate economy...

Cyprus and Luxembourg object to a proposed EU common corporate tax base directive

Cyprus and Luxembourg, two of the EU`s financial centres, on Monday cautioned against the implementation of the proposed Common Consolidated Corporate Tax Base (CCTB) in the European Union. “Cyprus believes that we should be very cautious and very careful when it comes to corporate taxation,” Cypriot Finance Minister Harris Georgiades...

Cyprus: Abolition Of Profit Margins On Intra Group Loans – Upcoming Transfer Pricing Legislation – Transfer Pricing Studies Requirement

As a rule and according to Article 33 of the Cyprus Income Tax Law, which introduces the arm’s length principle (using wording similar to that of article 9 of the OECD Model Tax Convention), all transactions between companies, including loan agreements/transactions by Cyprus companies, must be undertaken at arm’s length...

Russian Federation: Confirmation Of Direct Investment In Capital To Apply A Reduced Tax Rate On Payment Of Dividends

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...

Property tax dodgers discovered

Thousands of properties in Cyprus that have not been declared to the Tax Department have been discovered during a revaluation exercise by the Department of Lands and Surveys according to the island’s Interior Minister. The general assessment of immovable property valuations formed part of the Memorandum of Understanding between Cyprus...

Multilateral Instrument: The new dilemma of foreign investors

MUMBAI: The Multilateral Instrument (MLI), a new global tax avoidance agreement, that is in the process of being signed by 100 countries, is now causing a lot of anxiety among foreign portfolio investors (FPIs). MLI is an agreement put out by OECD, the intergovernmental economic organisation, to stop Base Erosion...

International tax-avoidance rules may override GAAR, other tax treaties

There is a possibility that the General Anti-Avoidance Rules (GAAR, on taxes) and the tax treaties signed by the government with those of Mauritius, Singapore and Cyprus, and even other nations such as Netherlands, could be overtaken by another event. These could, say experts, be partially or fully overridden by...

New tax regime for Ukrainian loan participation notes issued on international capital markets

January 2017 – On 21 December 2016, Ukraine’s parliament adopted the Law “On Amendments to the Tax Code of Ukraine Concerning Improvement of the Investment Climate in Ukraine” No. 1797-19. With effect from 1 January 2017, the legislation introduces new rules for the taxation of interest payable by Ukrainian economic...

Budget 2017: Tax Reform For Financial Services

Given the recent developments in the Indian economy, the upcoming Union Budget will certainly be critical and important in determining the future outlook of the economy. The financial services industry has been one of the key drivers of growth due to its strong cause and effect relationship with the economy....

India may leave tax treaty with Netherlands unchanged

India is unlikely to amend its tax treaty with the Netherlands as it did with Mauritius, Singapore and Cyprus and this could shape the investment strategy of foreign portfolio investors (FPI) and private equity (PE) funds investing in India, said three people in the know. “There were talks to amend...

Cyprus: Country-By-Country Reporting Under Base Erosion And Profit Shifting Action 13

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...

Singapore Goes The Mauritius Route, Loses Right To Tax Equity Capital Gains Arising In India

Starting April 1, 2017, India will have the right to tax capital gains arising on Indian equity shares sold by a Singapore resident. The governments of India and Singapore have amended the double taxation avoidance treaty between the two countries, in line with the changes India recently made to a...

Ireland Rejects Oxfam’s Tax Haven Claims

Ireland’s Ministry of Finance, the EU and several other governments have emphatically rejected claims by Oxfam International that the countries are tax havens, with Ireland insisting its corporate tax laws are “fully compliant” with international best practices when it comes to transparency and information exchange. The Irish government said the...

Oxfam: Luxembourg, Ireland, Netherlands among worst tax havens

The NGO’s report exposes the worst offenders in the ‘race to the bottom on corporate tax.’ Luxembourg, Ireland, Cyprus, and the Netherlands are among the world’s 10 worst tax havens, despite an ongoing EU crackdown on tax avoidance and profit shifting across the bloc. The findings come in a report...

HUNGARY COULD BE A CORPORATE PROFIT TAX HAVEN IN THE EUROPEAN UNION

The new 9 percent flat corporate profit tax – to be introduced 1st of January 2017 – will put Hungary in a very good position in the international race for investments as Hungary will offer even better conditions than Ireland and Cyprus, which are both often regarded as the European...

India, Cyprus ink new Double Tax Avoidance Agreement

New Delhi– India on Friday signed a revised double taxation avoidance agreement (DTAA) with Cyprus, an official statement said here. “A revised agreement between India and Cyprus for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion (DTAA) with respect to taxes on income, along with its protocol,...

EU agrees screening process for tax havens, critics cry foul

European Union finance ministers agreed on Tuesday how to screen countries for a blacklist of tax havens across the world, officials said, and said applying zero-rate taxes was not necessarily a factor, prompting an outcry. The bloc committed in May to agree on a common list of tax offenders by...

UN expert urges next UN chief to crack down on Malta and other ‘tax havens’

A United Nations human rights expert has urged the next UN secretary-general to make the elimination of tax havens a priority to ensure that corporations, billionaires and ‘kleptocrats’ pay their fair share of taxes. Speaking on Friday, American law professor Alfred de Zayas also urged Antonio Guterres, who will succeed...

Heat on tax evaders could be endgame for black money

Chances of tax evaders coming under the scanner is rising due to the implementation of the GST, greater use of technology and exchange of information between countries New Delhi: The noose is tightening around tax evaders. Be it the implementation of the goods and services tax (GST) or the greater...

Cabinet approves signing of revised DTAA with Cyprus

The Union Cabinet on Wednesday gave its nod for signing of revised double taxation avoidance agreement (DTAA) with Cyprus, a popular tax haven. It is also learnt to have approved the removal of island nation as a non-cooperative jurisdiction for income-tax purpose. Cyprus was the only country to have been...

Nine measures taken by government to curb black money

The government is hell-bent on cracking down on black money and undisclosed income of Indians within the country and safely stowed away abroad. While there is no proper estimation of the actual amount of black money in the economy, the government is actively taking measures to stop it. Recent media...

India, Cyprus finalise DTAA; capital gains to be taxed at source country

India and Cyprus have reached an in-principle agreement on all pending issues on Double Taxation Avoidance Agreement, including taxation of capital gains, which once implemented would help remove the island-nation from a non-cooperative jurisdiction for income tax purposes. An official level meeting between India and Cyprus in New Delhi last...

European Commission gets closer to agreeing anti-tax avoidance directive

The European Commission is on the brink of agreeing its far-reaching anti-tax avoidance directive, but is waiting on approval of some elements of the package by the Belgian and Czech governments, before it introduces new rules at midnight on Monday 20 June At the end of last week the Commission’s...

Cyprus agrees to amend tax treaty ahead of GAAR with caveat

Ahead of India’s rolling out of anti-tax avoidance regulations, Cyprus has shown eagerness to amend the bilateral tax treaty allowing New Delhi to tax capital gains. In turn, has pitched to be taken off the blacklist or being considered a “notified jurisdiction” for not sharing tax information, which implies increased...

Cyprus says ‘very close’ to revising tax treaty with India

In a step forward, Cyprus has said it is “very close” to revising the bilateral tax treaty with India as the island nation has accepted “in principle” proposals made by the Indian side on taxing capital gains. Cyprus, a source of significant foreign fund flows into the country, said rising...

After Mauritius, now government wants to amend Dutch tax treaty; asks Netherlands to resume talks

India has asked the Netherlands to resume negotiations on amending their bilateral tax treaty as the government extends its efforts to plug loopholes in such accords to curb misuse. The Dutch tax treaty , which allows exemption from capital gains and a lower rate of tax on dividends, has led...

Expert group to guide FIIs on capital gains tax, GAAR rules

The finance ministry expert panel is expected to pre-empt any potential confusion, assuage foreign investors facing twin changes in the tax regime New Delhi: The finance ministry is setting up an expert group to work out the modalities of implementing changes in the tax regime stemming from the withdrawal of...

India gearing up to apply Mauritius tax treaty fix to double taxation avoidance accord with Cyprus

NEW DELHI: Now that loopholes in the tax treaty with Mauritius have been plugged, the Indian government is gearing up to apply the same fix to its accord with Cyprus. Talks to amend the double taxation avoidance treaty are at an advanced stage and the two sides will soon exchange...

Canada’s record on finding tax evaders is dismal

Only a week after the so-called Panama Papers burst into the media spotlight early last month, the Canadian government issued a news release vowing to “crack down on tax evasion and tax avoidance.” The leak of a staggering 11.5 million documents from a Panama City law firm promised to reveal...

The problem of secretive tax havens

Panama is a tax haven, but Mauritius is one with which India has a comprehensive double tax treaty. This complicates matters more. In popular Indian imagination, a tax haven is generally associated with Switzerland and its numbered bank accounts. But tax havens are numerous, have grown in importance, and are...

French Tax Update – Recent Case Law and Other Noteworthy Publications

The present French Tax Update will focus on an overview of several noteworthy publications, including decisions issued during the past few months by the French Administrative Supreme Court (Conseil d’Etat) and French Constitutional Court (Conseil Constitutionnel), as well as the European Commission decision in respect of the Belgian Excess Profit...

How to take your UK pension pot overseas-and not be hit by a big tax bill

Once the thrill of deciding to retire overseas has subsided, you normally start to think of all the things you need to do before you go. Picking the right removal firm, a lawyer to help you buy a new home are a couple, but the tax & financial implications of...

The hidden wealth of nations

India’s biggest source of FDI is India itself, money departing on a short holiday to a tax haven and then routed back as FDI. Will the government muster up the political will to clamp down on the tax-allergic business elite? This could be a bumper year for the ever-lucrative tax...

On tax avoidance

The only thing worse than paying taxes is the idea that other people avoid paying their fair share of them. On the subject of tax avoidance by other people, I can think of at least three principal feelings. As the kids say, I feel all the feelings. Outright tax fraud...

End nears for tax cheats

The government aims to turn the screws on tax delinquents this year as well as those who have escaped the taxman’s radar, finance minister Harris Georgiades told MPs on Tuesday. The Tax Department is preparing to launch a drive to track down and tax the owners of luxury assets, such...

CYPRUS TAX UPDATE

On 10 December 2015 the remaining changes to the income tax and the capital gains tax laws aiming to improve the tax system of Cyprus and make it more attractive to both the local and international business community were voted. The changes came into effect with their publication in the...

Cyprus: Taxation – Amendments On The Double Tax Treaty Between The Republic Of Cyprus And Ukraine

Representatives of the Cyprus and the Ukrainian governments have signed, in Kiev, on Friday, 11 December 2015, a protocol amending their Double Tax Avoidance Treaty. The protocol is based on the Model Tax Convention for the Avoidance of Double Taxation OECD. The changes need to be ratified by both the...