Category: Jurisdiction

India: Rules To ‘Secondary Adjustment’ Rationalized And Clarified

The concept of 'Secondary Adjustment' was introduced in Finance Act 2017 by introducing new Section 92CE in the Indian Income Tax Act (the Act) to align transfer pricing provisions with international best practices. ... - Continue reading

Nigeria: Unprecedented Global Drive For Tax Transparency – The Nigerian Perspective

In the last few years, the international tax space has experienced an unprecedented drive to achieve increased transparency in the tax practices of Multinational Enterprises (MNEs) and individuals in order to curb tax avoidance and evasion. ... - Continue reading

POGOs’ tax compliance improves

The tax compliance of online gaming operators and their service providers continue to show improvements every month amid the strict enforcement activities of the government, a tax official said. The Bureau of Internal Revenue (BIR) initially reported that its preliminary income tax collection from Philippine offshore gaming operators (POGO) foreign… – Continue reading

BIR Officials: Congress not inclined to lift Bank Secrecy

“The suggestion has been brought up many times before and lawmakers with the support of the business community rejected it,” said a revenue regional director who declined to be named. He recalled that many congressmen even protested when the BIR in 2014 tried to require taxpayers to include in their… – Continue reading

Ireland Budget 2020 released

On 8 October, the Irish government announced its Budget 2020 measures. Brexit and climate change are core themes of new revenue measures and expenditure commitments. Brexit remains the foremost immediate concern for the Irish economy, whereas tackling climate change requires long-term commitments to tax and spending policies. ... - Continue reading

EU Council revises its tax blacklist, addresses “two out of three” exception and foreign source income exemption regimes

As suggested by the EU Code of Conduct Group (Business Taxation), on 4 October, the EU Council today adopted a revised EU list of non-cooperative tax jurisdictions (annex I – blacklist) removing the United Arab Emirates (UAE) and the Marshall Islands. ... - Continue reading

OECD consulting on digital tax proposal

The OECD today published for stakeholders’ comments a proposal to advance international negotiations to ensure that multinational enterprises (MNEs), including digital companies, pay tax wherever they have significant consumer-facing activities and where they generate profits. The proposal – Secretariat Proposal for a Unified Approach – would re-allocate some profits and… – Continue reading

United States: Senators Introduce Bill To Require Reporting Of Beneficial Ownership Information

A bipartisan group of senators introduced a bill which would impose federal beneficial ownership reporting requirements for legal entities established under state law, intended to assist law enforcement in fighting money laundering and terrorist financing ("AML/CFT"). ... - Continue reading

The Fiat and Starbucks state aid tax cases: an absolute loss for legal certainty.

In late September, the EU General Court released its decisions in two long-awaited state aid appeals: Fiat (cases T-755/15 Luxembourg v Commission and T-759/15 Fiat Chrysler Finance Europe v Commission) and Starbucks (cases T-760/15 Netherlands v. Commission and T-636/16 Starbucks and Starbucks Manufacturing Emea v. Commission). ... - Continue reading

Accidental Americans’ sue France over FATCA disclosure rules

A group representing French-American taxpayers  has filed a complaint against France with the European Commission over its compliance with the US Foreign Account Tax Compliance Act (FATCA), in a bid to avoid being blacklisted by French banks starting in January. France is a signatory to an agreement to give the… – Continue reading

Fiji Institute of Accountants concerned about cybercrime, money laundering

SUVA, Oct. 7 (Xinhua) — The Fiji Institute of Accountants (FIA) said Monday they are concerned about the increase in money laundering and cyber-crime activities in the island nation. According to Fiji Broadcasting Corporation (FBC), while presenting before the Standing Committee on Economic Affairs, the Fiji Institute of Accountants President… – Continue reading

Financial resources hit P31 trillion as of March

The country’s total financial resources reached P31.044 trillion as of end-March 2019, according to the latest survey of the Bangko Sentral ng Pilipinas. Preliminary results of the Other Financial Corporation Survey showed the total assets of depository corporations reached P23.068 trillion while the combined resources of other financial corporations hit… – Continue reading

Bermuda: Chambers Private Wealth 2019: Bermuda (2019)

1. Tax1.1 Tax regimes In Bermuda there is no income or profits tax, withholding tax, capital gains tax, capital transfer tax or inheritance tax. There is no exit or similar such tax based on a resident's wealth when ceasing to be resident and there are no other consequences of leaving the jurisdiction. Customs duties and stamp duty are major government revenue earners, with stamp duties charged at different rates and in different manners on a variety of legal documents, excluding wills. ... - Continue reading

East Africa bloc mulls regional tax treaty framework to boost integration

NAIROBI, Oct. 1 (Xinhua) — The East Africa Community (EAC) bloc plans to develop a regional tax treaty framework to boost regional integration, an official said on Tuesday. Doris Akol, commissioner general, Uganda Revenue Authority told Xinhua in Nairobi that once the treaty is in place the trading bloc will… – Continue reading

Uganda: Don’t Make Up Losses To Avoid Tax

Conflicting interests arise for many businesses where decisions have to be made to determine how they consistently achieve profitability, while on the other hand minimise payment of tax. The temptation to minimise profits or even make a loss then becomes a tax risk management strategy. ... - Continue reading

Ukraine: Ukraine Ratifies Protocol Amending Double Taxation Treaty Between Ukraine And Switzerland

On 18 September 2019, the Parliament of Ukraine ratified a protocol (the Protocol) of amendments to the double tax treaty between Ukraine and Switzerland (the DTT) which had been signed by the states on 24 January 2019.  ... - Continue reading

Dutch government asks banks to give American expats more time to deal with FATCA

The Dutch government is urging banks to be accommodating towards American nationals who risk having their bank accounts closed because of US fiscal regulations as it calls on EU member states to campaign together for changes to American tax laws which are affecting thousands who have American nationality but no… – Continue reading