MEPs follow UK Treasury approach Allegations the Isle of Man was used as a base for international tax evasion have triggered a fresh investigation in the European Parliament. It comes precisely three months after the Paradise Papers claimed to expose widespread exploitation of VAT loopholes facilitated by the Island’s aircraft… – Continue reading
The Federal Government of Nigeria and some foreign countries, including the United Kingdom Government, have commenced the Automatic Exchange of Tax Information (AETI), particularly on overseas assets held by Nigerians. Minister of Finance, Mrs. Kemi Adeosun, confirmed this on Friday in Abuja during the presentation of Progress Report on Tax… – Continue reading
In 2017, the UK scrapped its non-dom tax regime. Consequently, an increasing number of individuals are instead relocating their tax domicile to Italy At the start of 2017, in a bid to attract more wealthy citizens and capital to Italy, Rome introduced a non-domiciled tax regime. Now, citizens can move… – Continue reading
Apple Europe Ltd, a wholly owned subsidiary of Apple Inc., said it expects to pay more tax in the UK and paid an extra GBP136m for prior years up to September 26, 2015, after an extensive audit by HM Revenue and Customs. In its end-of-year accounts made up to April… – Continue reading
The case of Development Securities (No. 9) Ltd and other v HMRC [2017] UKFTT 0565 is the latest in a line of cases concerning the UK corporate tax residence of offshore companies. The case once again highlights the difficulties in preserving an offshore company’s non-UK tax resident status, whilst giving… – Continue reading
The GOP tax bill that was signed into law by the white house late last year, significantly reduced corporate taxes which has piled pressure on other significant economies around the world to adjust so as not to lose investors to the United States. Just hours after President Trump signed the… – Continue reading
Estonia is expected to get a 100-to-one-euro return on investment for its e-Residency program, which lets anybody start a business from afar. It is even planning to launch ‘estcoins,’ its own cryptocurrency. Becoming a ‘digital resident’ of Estonia, Michael M. Richardson says, was “as easy as getting a fishing license… – Continue reading
Introduction As the government continues to grapple with a budget deficit and strained public finances, there remains considerable pressure on HMRC to crack-down not only on tax evasion, which is illegal, but tax avoidance, which HMRC refers to as “bending the rules of the tax system to gain a tax… – Continue reading
The UK Government has released a consultation on the royalty withholding tax targeting digital firms announced in the UK’s most recent Budget. Under the proposal, the Government intends to introduce legislation in Finance Bill 2018-19 to broaden the circumstances in which certain payments made to non-UK residents have a liability… – Continue reading
A new royalty withholding tax will apply from April 2019 where a non-UK resident entity making sales in the UK pays a royalty to a connected party in a low tax jurisdiction, according to a consultation document which sets out further details of the proposal, which was first announced in… – Continue reading
The number of outstanding tax treaty related disputes in the UK increased in 2016 by almost 20% from 262 at the beginning of the year to 314 at the end of the year, according to statistics released by the Organisation for Economic Cooperation and Development (OECD). The statistics show the… – Continue reading
“The ceiling on taxation of capital gains reflects the national belief that speculation is a more worthwhile way to make a living than work.” – Calvin Trillin, Uncivil Liberties, 1982. Time was when both death and taxes were considered unavoidable. But in the light of the latest revelations contained in… – Continue reading
Bermuda and the UK recently signed an agreement providing for the automatic exchange of country-by-country reports. Bermuda is the first UK Overseas Territory to sign a CbC Competent Authority Agreement with the UK, which enables the automatic reporting of corporate income on a country-by-country basis for UK-related transfer pricing enforcement… – Continue reading
Island tax expert Greg Jones has issued a warning saying he believes the UK taxman has ‘bulked up’ and is starting to ‘flex his muscles.’ Mr Jones, a director of KPMG at its offices in Athol Street, Douglas, has analysed the UK Budget in this special report for Business News:… – Continue reading
On November 22, the UK Government published for stakeholders’ comments a position paper setting out its views on the challenges posed by the digital economy for the corporate tax system and its preferred solutions. The paper, which was published alongside the 2017 Autumn Budget, states that “the Government believes in… – Continue reading
Summary: The Chancellor unexpectedly announced a U-turn to tax gains made by non-residents on UK commercial property with effect from April 2019. This will have a significant impact on overseas investors into UK real estate and creates additional uncertainty during an already volatile time as Brexit negotiations continue. Overseas investors… – Continue reading
The UK government is planning to extend the time limit to 12 years for HM Revenue & Customs (HMRC) to investigate all offshore tax non-compliance, according to documents released as part of the Budget. A Treasury document entitled ‘Tackling tax avoidance, evasion and non-compliance’ states that the government will consult… – Continue reading
UK Offshore tax evaders face much higher penalties for non-compliance under new HM Revenue and Customs rules. The legislation requires those with undeclared offshore tax liabilities to disclose them to HMRC before the 30th of September next year. When the Right to Correct rules come into force, offenders can expect… – Continue reading
ISLAMABAD/LONDON: The thirty-eight-page trust deed of Pakistan Tehreek-e-Insaaf (PTI) leader Jahangir Khan Tareen’s offshore trust was signed and formalised in Geneva, Switzerland, and facilitated by HSBC Guyerzeller Trust Company Geneva – raising questions about Swiss bank accounts. During the hearing before Pakistan’s Supreme Court, Tareen was asked no questions about… – Continue reading
The commitment comes amid ongoing controversy over the use of complex tax arrangements following the Paradise Papers leak. The islands of Jersey, Guernsey and the Isle of Man have signed up to a joint commitment with the British and Irish governments to tackle tax evasion and abusive tax avoidance. The… – Continue reading
GEORGE TOWN, Cayman Islands (CMC) — The Cayman Islands, noting that it has had to get used to “unfair and inaccurate” reporting about its global financial sector, is distancing itself from the so-called Paradise Papers, a set of confidential documents related to offshore investment. In addition, the island has also… – Continue reading
The Chartered Institute of Taxation, the UK tax professionals representative body, has urged lawmakers globally to pause for thought on the direction being taken on the taxation of the digital economy. It is urging that any measures to improve the tax rules covering the digital economy must be developed and… – Continue reading
The difference between the tax due and that collected by the UK tax authority, HM Revenue and Customs (HMRC) – known as the “tax gap” – fell to a record low of six percent in the fiscal year 2015-16, according to official statistics released on October 26, 2017. HMRC pointed… – Continue reading
HMRC has warned convenience retailers to “play by the tax rules” or face the consequences as new stats show a disproportionate amount of tax evasion is committed by convenience stores. While accounting for less than 1% of businesses, convenience stores and newsagents now account more than 6% of all incidents… – Continue reading
Inquiry to centre on George Osborne’s 2013 rule change that allows resident multinationals to shift income offshore The EU is to launch an investigation into a British government scheme that may help multinational firms pay less tax, the Guardian has learned. Margrethe Vestager, the EU competition commissioner, will announce on… – Continue reading
HM Revenue and Customs, the UK tax authority, has welcomed a ruling in its favor against a contrived tax avoidance scheme involving an entity in Jersey and the Cayman Islands. HMRC says it expects that the decision will recover GBP325m in unpaid tax. The decision on the scheme, known as… – Continue reading
Newcastle United are facing a major investigation into possible tax fraud which is suspected to have taken place during some of their transfer dealings, according to The Daily Mirror. Transfer deals between 2011 and 2013 adding up to around £500m are said to be under scrutiny, which include deals for… – Continue reading
Survey respondents cite high marginal rates and lack of staff reward schemes as negatives More than half of Irish business owners view the State’s tax code as a barrier to growth rather than a support, according to a survey by accounting and professional services firm Deloitte. Respondents cited Ireland’s high… – Continue reading
LONDON (Reuters) – Facebook (FB.O) reported profits in Britain in 2016 of 58.4 million pounds ($77 million) after the introduction of anti-profit shifting measures but a modest rise in its tax bill shows the challenge Europe faces in working out how to tax technology giants. Facebook said in filings with… – Continue reading
On 30 September 2017, the Criminal Finances Act came into force. The Act, billed as the British response to the Panama Papers cyber breach scandal, aims to take the profit out of tax evasion. Under the Act, your business could be criminally liable for the actions of your employees. The… – Continue reading
The 30 September 2017 is an important date for HMRC and its “relentless” clampdown on global tax evasion. First, it marks the coming into force of the landmark corporate offence of failure to prevent tax evasion under Part 3 of the Criminal Finances Act 2017. Secondly, it is the commencement… – Continue reading
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
MINSK, 26 September (BelTA) – Belarus and the UK have signed an intergovernmental convention on removing double taxation in respect to income and capital taxes and preventing tax evasion, BelTA informs. The signing ceremony took place at the Belarusian Ministry of Foreign Affairs. The document was inked by Belarus’ Taxes… – Continue reading
Fresh tax evasion laws come into force this Saturday. New tax evasion laws coming into force this week could catch UK companies unaware and put them at risk of unlimited fines, a British law firm has warned. Blake Morgan said it fears that “many” commercial and non-profit firms alike may… – Continue reading
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
ANALYSIS: Companies are likely to receive a preliminary notice under the new diverted profits tax (DPT) regime between now and the end of 2017. They should treat the issue of a notice as potential litigation and should immediately involve their legal advisers. For many companies the time limit for the… – Continue reading
Some double tax treaties are being amended by a multilateral instrument Establishing how a particular treaty is affected can be a complicated process The UK intends to publish amended DTTs and this will help, but the MLI has added an additional layer of complexity 18 Sep 2017 Speed Read LEGAL… – Continue reading
In its latest policy paper to target the cross-border financial services sector, the UK government today unveiled proposed legislation that seeks to prevent the use of offshore trusts to avoid tax. The measure ensures that payments from an offshore trust intended for a UK-resident individual “don’t escape tax when they… – Continue reading
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
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
Non-domiciled taxpayers contributed £9.3 billion to the UK economy in 2014/15 through a combination of income tax, capital gains tax and National Insurance contributions (NICs), according to newly-published figures. The number of non-doms paying tax in the UK marginally increased in 2014/15, to 121,300, up from 119,800 the previous year…. – Continue reading
The reach of Deferred Prosecution Agreements (“DPAs“) has been broadened to include the new offences of failing to prevent the facilitation of UK or foreign tax evasion – strengthening the DPA regime yet further as a weapon in the fight against corruption. From 30 September 2017, it will be an… – Continue reading
Wealth managers have only days to send clients warning letters about disclosing overseas assets to the taxman, or risk a £3,000 fine. Wealth managers, advisers and fund managers have until 31 August to send an HM Revenue & Customs (HMRC) approved letter to clients about holding assets abroad which warns… – Continue reading
Britain is the world’s second largest conduit for multinational companies avoiding tax on profits, according to new research. Although the British government has taken a leading stand in the fight to tackle corporate tax avoidance, data analysis by researchers at Amsterdam University in The Netherlands shows The City of London… – Continue reading
The Supreme Court has recently ruled in favour of HM Revenue and Customs in a long-running dispute with Rangers FC over the use of employee benefit trusts (EBT) as a means of avoiding tax. The case, which was initially decided in favour of the Glasgow-based football club in two employment… – Continue reading
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
The UK tax authority, HM Revenue and Customs (HMRC), has issued guidance for businesses on the preparation of country-by-country reports in the required format. The CbC report is one element of a new three-tiered standardized approach to transfer pricing documentation proposed under Action 13 of the OECD’s base erosion and… – Continue reading
INTRODUCTION HMRC have successfully challenged the offshore residence of Jersey companies holding UK real estate. In the case of Development Securities, the First Tier Tribunal held that Jersey companies set up to hold UK real estate were resident in the UK for tax purposes. This case serves as a timely… – Continue reading
Every individual has a nil rate band of £325,000 after which any assets above this threshold become taxable at 40% unless they are passing to an exempt beneficiary such as a charity or spouse/civil partner. This threshold has been frozen until the end of the 2020/21 tax year. The government… – Continue reading
This article is the third of a series of articles that examines tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors in other offshore financial centres…. – Continue reading
