The UK Government launched a consultation on 22 October 2015 regarding the UK corporate tax rules for interest deductibility. The consultation seeks views on the design of a general limitation for UK corporation tax deductions for interest and similar finance costs, imposing a capcalculated by reference to a fixed percentage… – Continue reading
Amazon, Facebook and Google in line of fire after committee backs proposals to force multinational corporations to pay tax where they make their sales MEPs have launched a scathing attack on Facebook, Google and Amazon in the European parliament, accusing them of diverting profits worth billions of pounds to low… – Continue reading
A sharper focus on offshore banking activity and tax avoidance has seen HM Revenue & Customs grow its Affluent Unit by more than 50% in the past two years. In 2013 the unit had 213 people in its function whereas now headcount sits at 327, an increase of 54%. It… – Continue reading
The FINANCIAL — Apostle Matthew was a tax collector in Galilee — perhaps the most hated occupation in the ancient world. By quitting his job and deciding to follow Jesus, Mathew accomplished one the greatest transformations possible in a person’s life. Modern tax inspectors are certainly not expected to follow… – Continue reading
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
MELAKA: Some 180 participants from 47 countries will attend the five-day 36th annual Technical Conference of the Commonwealth Association of Tax Administrators (CATA) here from tomorrow. The Inland Revenue Board (IRB) said among the countries taking part in the conference are Australia, South Africa, Brunei, India, New Zealand, Canada, Pakistan,… – Continue reading
Early last week, Greece’s financial prosecutors sent a long letter to Prime Minister Alexis Tsipras, urging him to appoint more inspectors and expert staff to boost their efforts to raise much-needed revenue from tax evasion, Kathimerini understands. The 26-page letter, the second to be sent to Tsipras this year, was… – Continue reading
Former London mayor says owners of the Mail, Telegraph, Sun and Times fear the Labour leader will make them pay more tax if he becomes prime minister Ken Livingstone has said the owners of the Daily Mail, Telegraph, Sun and Times will “do anything” to stop Jeremy Corbyn becoming prime… – Continue reading
Companies such as Apple, Starbucks, and Amazon are well known for legally using international law to their advantage when it comes to tax. Now a small Welsh town is mimicking their tactics. Independent traders in Crickhowell are moving their businesses “offshore” to avoid paying tax. The local businesses – including… – Continue reading
Tax: Luxembourg among countries helping US firms cut their tax bills by more than a quarter, campaigners say. The abuse of holding company structures in the Grand Duchy, and fiscal regimes in several other countries, allows American firms to avoid paying billions of dollars in corporate profit taxes, two NGOs… – Continue reading
The US Treasury Department released proposed revisions to the US Model Income Tax Treaty (the ‘Model Treaty’); the proposed changes are intended to combat treaty abuse and deny treaty benefits in certain situations. The revisions to the Model Treaty include: (i) changes to the Limitation on Benefits provision which most… – Continue reading
Draft regulations in Guernsey for implementing the common reporting standard (CRS) for the automatic exchange of information are expected to be published in final form in early 2016. Guernsey has indicated its commitment for adopting the CRS, with effect from 1 January 2016, so that the first reporting would take… – Continue reading
Some time ago we wrote an article on the Foreign Account Tax Compliance Act (‘FATCA’) which says that although the FATCA tentacles are fairly intrusive, at the end of the day, it represents just another form for tax payers to complete. Rather to my surprise this article elicited a threat… – Continue reading
The final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) project were issued on 5 October (the “Reports”) after a two-year consultation period during which 62 countries and many other stakeholders (such as the World Bank, the IMF, and many trade associations) participated. These Reports, split into 15… – Continue reading
Thanks to the FiTAX tax reporting solution, some 2,000 financial institutions successfully met the reporting requirements of tax authorities. FiTAX FATCA covers more than 45 countries. ZURICH, SWITZERLAND—(Marketwired – Nov. 12, 2015) – 2015 marks a turning point in the FATCA timeline: for the first time, Financial Foreign Institutions (FFIs)… – Continue reading
Edward Troup says the tax authority is doing its job well The amount of tax going uncollected in the Britain is no worse than in other countries around the world, a senior official at the tax authority has said. Edward Troup, HMRC’s tax assurance commissioner, told the House of Commons… – Continue reading
On September 16, 2015, the Australian government introduced into Parliament Tax Laws Amendment (Combating Multinational Tax Avoidance) Bill 2015, which contains, among other items (including the implementation of country-by-country reporting), the proposed legislative language to implement Australia’s version of the United Kingdom’s diverted profits tax. The bill was accompanied by… – Continue reading
Introduction On September 30 2015 Her Majesty’s Treasury published its long-awaited consultation on two of three proposed changes to the taxation of individuals domiciled outside the United Kingdom. The three measures – announced by Chancellor George Osborne in the 2015 Summer Budget published on July 8 – are intended to… – Continue reading
THE world appears to be getting much smaller. Rapid technological advances, increased people mobility, and changes in the international political climate have all helped to break down many of the traditional barriers to global and regional trade. For dynamic, fast-growing businesses, this increased globalisation represents an excellent opportunity for businesses… – Continue reading
The nine-month old Team Unity administration has been pursuing quiet diplomacy to recalibrate international relationships for the benefit of the people of St. Kitts and Nevis, reports SKN Vibes. So said St. Kitts and Nevis Prime Minister Dr. the Hon. Timothy Harris at last week’s press conference at government headquarters…. – Continue reading
Following the October 2015 release of the OECD’s base erosion and profit shifting (BEPS) deliverables, some consultations in the UK have already been opened—including one on the UK’s rules concerning the deductibility of corporate interest expense and how this treatment would be affected by BEPS Action 4 (which seeks to… – Continue reading
The National Association of Estate Agents is awaiting a response from the government to its demand for four changes to sale and purchase processes in a bid to combat money-laundering. In one of the association’s first major statements on the issue since the Channel 4 From Russia With Cash documentary,… – Continue reading
Double Taxation Treaty Network UK’s Key Strength in Attracting Tax- Transparent Funds LONDON, Nov 11, 2015 (BUSINESS WIRE) — The value of UK Authorised Contractual Scheme (ACS) funds under management in the UK is likely to exceed GBP250 billion by 2017, according to a Northern Trust survey of UK based… – Continue reading
LONDON – Both developed countries and developing countries are loosing out on tax revenues due to a continued lack of progress in fighting international tax avoidance. Large multinational businesses are still using international tax rules to avoid paying taxes in the countries where they raise profits, according to information contained… – Continue reading
Britain has done more to tackle secretive company ownership practices which facilitate corruption than other leading economies, while the United States and China are falling short of their promises, a leading anti-corruption group said. Britain has made good progress on making beneficial ownership information accessible, having legislated for a central… – Continue reading
The Common Reporting Standard (“CRS”) will impose new investor due diligence and reporting obligations on funds and other financial institutions based in “early adopter” participating jurisdictions, with effect from January 1, 2016. According to the OECD, all major financial centres have now signed up to the standard. Financial institutions should… – Continue reading
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
In this edition we also include the leading trustees, private bankers and accountants serving the private client industry. RBC Wealth Management leads our research in trust and advisory services with an impressive 18 names recommended. Alan Binnington specialises in establishing and administering trust and fiduciary structures for high net worth… – Continue reading
DID you hear the story about the Queen, tax evasion, a nationalised British bank for the rich and famous, a whistleblower and a £7bn under sale to ‘reward cronies and cheat the taxpayer’? Sounds like a pretty big deal, right? But last Thursday’s damning testimony from Helen Goodman MP –… – Continue reading
Headline: G20 among biggest losers in large-scale tax abuse – but poor countries relatively hardest hit G20 countries are the biggest losers when US multinationals avoid paying taxes where they do business. This is the main finding of a new report on the global tax system, ‘Still Broken,’ released by… – Continue reading
The Powys tax rebellion, led by traders including the town’s salmon smokery, local coffee shop, book shop, optician and bakery, could spread nationwide When independent traders in a small Welsh town discovered the loopholes used by multinational giants to avoid paying UK tax, they didn’t just get mad. Now local… – Continue reading
Where the likes of Google and Starbucks avoid paying huge amounts of tax in the UK by being registered in tax havens, this town is using the same accountancy loophole A whole town of independent traders in Wales are turning the tables on tax loopholes used by the world’s largest… – Continue reading
More than 1,600 new financial institutions have signed up to the US Foreign Account Tax Compliance Act (FATCA) List. The list now covers 177,147 institutions in 226 financial jurisdictions – up 1,604 from the last list published on October 1. The US Internal Revenue Service (IRS) keeps the list to… – Continue reading
Broad and retroactive legislation are two reasons the rule of law is under attack The rule of law – essentially, the idea that nobody is above the law – has come under threat in recent years, and could lower the UK’s desirability to do business with, according to a report… – Continue reading
The BMF has application letter sent to the chief financial authorities of the countries associated with the between the Federal Republic of Germany and the United States of America concluded by 31.5.2013 FATCA Agreement. Background Background of extensive, comprehensive 71 pages, application letter from the Federal Ministry of Finance on… – Continue reading
Law firm RPC has called on the UK tax authority, HM Revenue and Customs, to confirm that it will not force individuals into bankruptcy through the use of Accelerated Payment Notices. HMRC began sending APNs to UK users of certain tax avoidance schemes in August 2014. The notices give recipients… – Continue reading
The company at the centre of the revelations denied any wrongdoing Some of the best-known names in British football face losing millions of pounds after being allegedly advised to invest in “risky” projects that have subsequently failed or were hit with tax bills. Rio Ferdinand and Andy Cole, both former… – Continue reading
The UK is one of several countries to introduce voluntary disclosure schemes. More people are coming forward to regularise their affairs as they realise there is nowhere left to hide in this new world of tax transparency. Tax authorities and financial institutions are gearing up for the new automatic exchange… – Continue reading
LONDON, Nov 8: The British government has set a target for this year to triple annual prosecutions for the most serious tax evasion to 100 each year. It plans to create a “strict liability” offence of offshore tax evasion, according a report in the international media. This means that an… – Continue reading
Leave.EU, supported by Ukip and financed by a multimillionaire, vies to lead Britain’s exit from Europe A leading campaign group seeking to take Britain out of the European Union was set up by an offshore company that offers tax avoidance services to “high net worth individuals”, the Observer can reveal…. – Continue reading
Abolishing the UK’s deed of variation legislation as a means of tackling tax avoidance could risk causing distress to bereaved families, warned the Association of Taxation Technicians. A deed of variation gives beneficiaries of an estate a two-year window to alter the distribution of that estate following the death of… – Continue reading
A FINAL decision on the so-called Rangers “big tax case” may not happen until 2017, and Scotland’s footballing authorities are unlikely to deal with the ramifications of the matter until after that. Sir David Murray’s companies are yet to decide whether or not to appeal against the decision by three… – Continue reading
Call to halt bank sale in favour of reform rejected by UK Government UK MINISTERS decided to “wash their hands” of a tax evasion scandal in a subsidiary of the government-owned Royal Bank of Scotland, according to damning testimony given by a former treasury official who is now a Labour… – Continue reading
Plans to list its European REIT on the JSE. Feeding South Africans’ seeming insatiable desire for rand-hedge stocks, Schroder Real Estate is planning to launch a European Real Estate Investment Trust (REIT), which will have a primary listing on the London Stock Exchange with a secondary listing on the Johannesburg… – Continue reading
On September 7, 2015, the local tax court of Cologne (the “Court”) issued an injunction against the German Federal Central Tax Office (“FCTO”) to prevent the FCTO from conducting a coordinated exchange of information with the E6 countries Canada, Great Britain, France, Australia and Japan, which aimed at gathering intelligence… – Continue reading
Since Minister Noonan announced in October 2014 that Ireland would introduce a “best-in-class” Knowledge Development Box (“KDB” ), there has been a lot of speculation about ‘how low would he go’. Budget 2016 announced that the rate of tax which will apply for income qualifying under the new KDB will… – Continue reading
HM Revenue and Customs (HMRC) has won a judgement that Rangers’ use of Employee Benefit Trusts (EBTs) broke tax rules. Rangers used the scheme from 2001 until 2010 to give millions of pounds of tax-free loans to players and other staff. In what became known as the “big tax case”,… – Continue reading
The UK government has a ‘Janus-faced’ approach to tax, a new report suggests: promising an increasingly intolerant approach to evasion and avoidance while being an aggressive participant in global tax competition and tolerating the UK tax havens which facilitate financial crime across the world. The report, Fifty Shades of Tax… – Continue reading
A former finance minister yesterday slammed as “patently false” suggestions by a prominent tax advocacy group that the Bahamas is “disregarding the rules” and flouting global information exchange and transparency standards. James Smith, also an ex-Central Bank governor, hit out at the Tax Justice Network after its 2015 Financial Secrecy… – Continue reading
HM Revenue and Customs is failing to prosecute wealthy tax evaders who hide their fortunes in overseas, MPs have warned, reports the Isle of Man Today. The Commons Public Accounts Committee said HMRC’s record of just 11 prosecutions for offshore tax evasion in the past five years was “woefully inadequate”… – Continue reading
