Category: Jurisdiction

EU anti-money laundering blacklist to be revisited

Next month, the European Union will revamp its methodology for compiling its anti-money laundering blacklist, after a previous list was blocked by EU governments that objected to the listing of Saudi Arabia and four US overseas territories, EU Commissioner for Justice Vera Jourova told the Financial Times recently.“We have admitted… – Continue reading

Cyprus: The Cyprus Investment Programme And The Benefits

The Cyprus Investment Programme is rapidly becoming one of the EU’s most popular residence schemes.

  • Non Cypriot citizens (and their families) can acquire Cyprus Citizenship by investing €2.5 million* in Cyprus.
*In one specific set of circumstances as detailed below in the financial criteria, the investment required is €2.0 million. A non-Cypriot citizen who meets one of the financial criteria detailed below can apply for Cypriot citizenship ‘through naturalization by exception’.
  • Following the application, Cyprus citizenship will be granted in six months, assuming the application has been completed accurately and the correct documentation filed.
  • The applicant needs to be in posession of a residence permit for a period of six months before obtaining the citizenship.
... - Continue reading

FBR issues 253,000 notices to non-filer industrialists

KARACHI: The Federal Board of Revenue (FBR) has issued around 253,000 notices to industrialists and businessmen, asking them to file returns, as the revenue body is expanding its broadening of tax base drive, officials said on Tuesday. An official said the FBR has so far issued 253,700 notices to consumers… – Continue reading

Canada: Transfer Pricing: What’s New In Canada (Part II)

Transfer pricing disputes in Canada have, predominately, been resolved through either a request for competent authority assistance under the Mutual Agreement Procedure ("MAP") of a treaty, or, to a much lesser extent, through the notice of objection process with CRA Appeals.  Regardless of the recent increase in transfer pricing cases being brought before the Courts, the MAP will likely continue to be the dispute resolution process most often utilized by a Canadian corporation in transfer pricing cases because, in the absence of a 100% reversal of a transfer pricing adjustment by either CRA Appeals or a Canadian court, economic double taxation may still exist as a consequence of the CRA upward transfer pricing adjustment. The correlative relief provided by the treaty partner under a MAP settlement resolves that double taxation. ... - Continue reading

Australia provides arm’s length debt test guidance

The Australian Tax Office on 28 August, released its awaited draft guidance contained in Practical Compliance Guideline 2019/D3, on applying the arm’s length debt test contained in Division 820 of the Income Tax Assessment Act 1997, Australia’s thin capitalization statutory provisions.   ... - Continue reading

FBR demands Rs992m from TV channel in alleged tax evasion case

ISLAMABAD: The Federal Board of Revenue (FBR) has served a notice on ARY Communications Limited (ARY) and raised a tax demand of Rs992 million – alleging that the entity had evaded tens of millions in taxes through misrepresentation, concealment and misuse of exemptions, thereby causing a substantial loss to the… – Continue reading

Feature: Labuan IBFC – the gateway to Asia-Pacific

Labuan International Business and Financial Centre (Labuan IBFC) is seeing its comprehensive midshore solution reap results as new businesses soared 12.5% last year. Pedro Gonçalves explains the background to this success. With 1059 new companies mostly from Japan, China and South Korea, Labuan IBFC is also making the most of… – Continue reading

ICAB happy with Barbados’ removal from the EU’s blacklist

Barbados’ removal from the European Union’s (EU) blacklist has been welcomed by the Institute of Chartered Accountants of Barbados (ICAB). During her welcome remarks at the 15th Annual ICAB International Business Workshop, at the Barbados Hilton Resort, ICAB’s Executive Director, Kathy-Ann Hewitt, stated: “We are indeed happy that this change… – Continue reading

Canada, Switzerland ratify instrument to tackle tax avoidance

Canada and Switzerland on August 8 deposited with the OECD their instruments of ratification for the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS MLI). The BEPS MLI, negotiated by over 100 countries and jurisdictions, updates the existing network of tax treaties and… – Continue reading

OECD’s minimum tax to apply by jurisdiction

The Organisation for Economic Co-operation and Development is going to propose a global minimum tax that would apply country by country before the next meeting of G‑20 finance ministers and central bankers set for 17 Oct. in Washington, DC. G7 leaders announced at their Biarritz summit meeting this week a… – Continue reading

British citizens born in America face having bank accounts frozen

Tens of thousands of British citizens born in the US but only lived there for a few months or years face having their bank accounts frozen as part of a crackdown by the US tax authorities.    The Internal Revenue Service (IRS) is ordering British banks to hand over the… – Continue reading

United States: D.C. Circuit Expands U.S. Prosecutors’ Reach Over Foreign Bank Documents

In a recent decision, the U.S. Court of Appeals for the D.C. Circuit unanimously affirmed a district court order compelling three Chinese banks (not currently identified) to produce financial records in response to subpoenas issued by U.S. federal prosecutors, including records that were unrelated to the banks' U.S. operations or U.S. correspondent accounts. ... - Continue reading

European Union: The Increasing Link Drawn By Regulators Between State Aid & Taxation Systems

In 2018, the European Commission (EC) concluded two more investigations into whether the tax ruling practices of Member States breached European Union (EU) State aid rules: the first, a finding of unlawful State aid resulting from tax rulings by Luxembourg in favor of Engie; the second, a rare finding of no aid in respect of the treatment by Luxembourg of McDonald's under the Luxembourg-U.S. double taxation treaty. These decisions are discussed below. ... - Continue reading

Transfer pricing: DGIT starts analysing potential cases of MNCs

The Directorate General of International Taxes of the Federal Board of Revenue (FBR) has started analysing a few potential multinational companies’ cases of transfer pricing where companies are directly involved in shifting their profits outside the country without payment of any taxes. In this regard, Directorate General of International Taxes… – Continue reading

Govt launches crackdown on benami assets

ISLAMABAD: The government has kicked off a far-reaching crackdown against benami assets directing the departments concerned at the federal level and the provincial governments to track benami properties, harvesting the Benami Act, 2019 in the national and global contexts. Prime Minister Imran Khan chaired a meeting on August 20 on… – Continue reading

Bermuda Monetary Authority: 50 Years Later

As the Bermuda Monetary Authority [BMA] celebrates 50 years in 2019, we take a look back at the last five decades. From providing sound policy advice to pushing Bermuda forward as a reputable place to conduct business, the BMA has had an incredible impact on Bermuda’s financial landscape. 1990-1999 Exchange… – Continue reading

Australia’s tax office can use Paradise Papers data to pursue multinationals: Court

Australia’s High Court ruled unanimously that giant Glencore could not rely on “legal privilege” to prevent the Australian Tax Office (ATO) from accessing emails, bank records, PowerPoint presentations and other files from the 2017 Paradise Papers investigation. Typically, documents marked “privileged” do not have to be disclosed in court. Companies… – Continue reading

Canadians for Tax Fairness concerned about inaction on Panama Papers

It is estimated that the use of tax havens is costing federal and provincial governments at least $7.8 billion in lost tax revenue. Low and middle income Canadians are the ones paying for that missing $7.8 billion in tax revenue. Ottawa (11 Aug. 2016) — The leak of the Panama… – Continue reading

Gaming Companies Call for Reaching USA-Croatia Double Taxation Avoidance Deal

ZAGREB, August 21, 2019 – Computer gaming is the most propulsive segment of the IT industry worldwide, and this trend is present in Croatia, too, where local gaming companies export all their products, however the biggest challenge in doing business is the absence of a Croatia-USA double taxation avoidance agreement,… – Continue reading

German economics minister sees SMEs as “secret weapon”: report

German Minister for Economic Affairs and Energy Peter Altmaier had developed a strategy for the “Mittelstand” or small and medium-sized enterprises (SMEs), the newspaper Handelsblatt reported on Wednesday. “In the eyes of foreigners, SMEs are Germany’s secret weapon and, unlike the Dax 30 companies, SMEs are proving to be extremely… – Continue reading

Luxembourg: Luxembourg Starts The Implementation Of ATAD 2

On 8 August, the draft law (the "draft law") implementing the EU Directive 2017/952 of 29 May 2017 ("ATAD 2") amending Directive (EU) 2016/1164 laying down rules against tax avoidance practices that directly affect the functioning of the internal market (the so-called Anti-Tax-Avoidance-Directive, "ATAD") was presented to Parliament. ... - Continue reading

CBI Dominica: Leading with Transparency

19 August 2019, Since 1993, Dominica has been at the forefront of the citizenship by investment (CBI) industry, setting high standards in due diligence, processing times, and most recently, transparency. Indeed, this month the nation liaised with prominent international professional services firm PricewaterhouseCoopers (PwC) to release a report clarifying the… – Continue reading