Category: Jurisdiction

Metlife Completes Merger of Three Life Insurance Companies and One Former Offshore Reinsurance Subsidiary

MetLife, Inc. (NYSE:MET) today announced that it had completed the mergers of its subsidiaries MetLife Insurance Company of Connecticut, MetLife Investors USA Insurance Company, MetLife Investors Insurance Company and Exeter Reassurance Company Limited. The merged company has been renamed MetLife Insurance Company USA and is domiciled in Delaware. All necessary… – Continue reading

South Africa: President Zuma Wraps Up Brisbane Visit

Pretoria — President Jacob Zuma has concluded his visit to Brisbane, Australia, where he led the South African delegation to the G20 Leaders’ Summit, says the Presidency. The main outcome of the Leaders’ Summit was a commitment to lift the G20’s Gross Domestic Product (GDP) by at least an additional… – Continue reading

Beijing’s Interest in Offshore Tax Evasion Limited to Corrupt Officials

Fifty-one countries signed the Multilateral Competent Authority Agreement in Berlin on Oct. 29 to fight offshore tax fraud and evasion. The agreement aims to put an end to banking secrecy by sharing tax-related information with member states. Missing from the signatory list are the United States and China. China’s absence… – Continue reading

BEPS: G20 leaders mark ‘significant progress’

G20 leaders have made “real progress” towards ensuring that “big companies pay the tax they owe”, David Cameron said at the end of the G20 summit in Brisbane yesterday. “There are now over 92 different countries and tax authorities properly sharing information and, as the OECD set out at this… – Continue reading

Reliance Jio Ties Up With Lenders for $1.5 Billion Loan Facility

New Delhi: Telecom operator Reliance Jio Infocomm has arranged credit facilities worth $1.5 billion with lenders, including Bank of America and Barclays, to refinance existing loans. Mukesh Ambani-led RJio would utilise the latest credit arrangements to re-finance debt tied up by it in 2010. The new loan facilities are guaranteed… – Continue reading

Corporate Close-Up: The Burden of California’s Taxes and Fees on Limited Liability Companies

The limited liability company, or LLC, has become a popular form for organizing a business.  Using an LLC generally avoids the double layer of taxation encountered with a corporation while providing limited liability for its members, and offers more flexibility than S corporations in which corporations may not be shareholders. … – Continue reading

Businesswoman contests release of Cayman bank records

A high-profile businesswoman accused of using Cayman Islands bank accounts to dodge more than $7 million in taxes is seeking to challenge the use of information obtained by the U.S. Internal Revenue Service through a tax information exchange request. Cheryl Womack, a Kansas City businesswoman who has a home and… – Continue reading

Nigeria: Still On the Taxation of Foreign Companies Operating in Nigeria

IN July 2014, the Federal Inland Revenue Service (FIRS) sent letters to some tax consultants requesting their non-resident clients operating in Nigeria to file complete tax returns effective from 2014 tax year. In practice, non-resident companies file their tax returns on the deemed profit basis. Following an initial period of… – Continue reading

Benelux-China legal update

Recent months saw various important developments that are relevant to Sino-European trade and investment. These include (i) changes to the EU Parent-Subsidiary Directive, (ii) the entry into force of the double tax treaty between Luxembourg and Taiwan, and (iii) proposed changes to China’s Foreign Investment Catalogue and the Governmental Verifications… – Continue reading

India economy not yet mature for GAAR: ASSOCHAM

Apex industry body ASSOCHAM has urged the Centre to amend the Indian income-tax law so as not to introduce the general anti avoidance rules (GAAR) from assessment year 2016-17 as India’s economy is neither mature enough to stand up to its exacting standards nor is the tax administration ready to… – Continue reading

Bill Gates commit money to Unitus’ offshore fund; Rupee fund bags $4M more

The venture seed fund has already announced 14 investments in India. Impact investor Unitus Seed Fund (USF) has announced that its India-focused offshore fund vehicle has received commitments from Microsoft co-founder Bill Gates, besides Concur Technologies’ CEO Steve Singh and Diego Piacentini, SVP (international consumer business) at Amazon.com Inc. It… – Continue reading

Greek Ministry of Finance issues templates and guidelines for advance pricing agreement negotiations

ITR Correspondent In an effort to provide taxpayers with an integrated procedural framework for the negotiation of advance pricing agreements (APAs), the Greek Ministry of Finance recently released template application forms for both preliminary consultations and formal negotiations, as well as additional guidelines on the overall APA procedure. The forms… – Continue reading

Global tax avoidance crackdown has broad support – Bill English

There is broad global support for moves to curb international tax avoidance, says Finance Minister Bill English, on the sidelines of the G20 Leaders’ Summit in Brisbane. Cracking down on tax avoidance is one of the key agenda items at this weekend’s G20 Summit, where New Zealand is an invited… – Continue reading

G-20 leaders agree on $2 trillion boost to growth

BRISBANE, Australia — Under pressure to jolt the lethargic world economy back to life, leaders of G-20 nations on Sunday finalized a plan to boost global GDP by more than $2 trillion over five years. The fanfare, however, was overshadowed by tensions between Russian President Vladimir Putin and Western leaders…. – Continue reading

Chevron’s multi-billion tax dodging: We don’t agree

You know those annoying “We Agree” television ads by the fossil fuel corporate giant Chevron? The ones where an actor playing a student or a concerned member of a community “agrees” with supposedly noble objectives of this multinational? Those ads make me feel like puking. The objective of this campaign… – Continue reading

G-20 set for ‘very aggressive’ crackdown on tax avoidance

BRISBANE: Australia has vowed a “very aggressive” crackdown on tax avoidance at weekend G-20 talks, as a row rages over Luxembourg’s sweetheart arrangements with multinationals. Closing corporate tax loopholes and endorsing a common reporting standard to increase transparency are set to be a primary focus of the G-20 summit in… – Continue reading

Cost-benefit analysis puts corporate tax avoidance in perspective

The growing crackdown on tax avoidance risks ushering in a broader suppression of international tax competition, harming the interests of all taxpayers. An inevitable consequence of economic globalisation is that supply chains and financial linkages have become dispersed across geographic space, and producers now strive to provide customers with quality… – Continue reading

Which offshore financial centre is the best?

Expats have a range of choices – so how do they find a safe home for their assets? The traditional use of offshore centres as a way of enabling better tax planning – and even tax evasion – has all but fallen away. An increasing desire for countries to share… – Continue reading

OECD sees competition heating up once tax havens shut down

(AFP) The OECD Friday forecast competition heating up among countries wanting to attract revenue from big digital companies like Apple and Google, even as a row rages over Luxembourg’s arrangements with multinationals. Closing corporate tax loopholes and endorsing a common reporting standard to increase transparency are set to be a… – Continue reading

German Federal Fiscal Court decides on treatment of hybrid entities under the German-US double taxation treaty 14 November 2014

Hybrid entities have long been a tool for corporate tax planning. While tax authorities have fought the use of such hybrid mismatches for tax planning purposes, national efforts to prevent the use of hybrid mismatches have not proven to be very efficient, explain Michael Graf and Timothy Santoli, of Dentons… – Continue reading

E.U. Accuses Starbucks and Netherlands of Making Unfair Tax Deal

BRUSSELS — European Union authorities have accused the Netherlands of making a special deal with Starbucks that helped the company lower its taxes, creating unfair advantages over other countries in the bloc. The report by the bloc’s competition authority, made public on Friday, is a preliminary finding in a review… – Continue reading

LuxLeaks Has Revealed Another Clash between National vs EU

The LuxLeaks scandal is a classical example of the growingly frequent clash between the level of integration of the European economy (and the global for that matter) and the national sovereignty. Greece was first to prove that four years ago when it put to the test the very survival of… – Continue reading

Multinational tax avoidance risks losing citizens’ trust, says Joe Hockey

Multinational tax avoidance risks losing citizens’ trust, says Joe Hockey G20 working on ‘important reforms which will significantly improve the integrity of the tax system’, Australian treasurer says The Australian treasurer, Joe Hockey, has warned that citizens will lose trust in the legitimacy of their governments if multinationals are allowed… – Continue reading

Swiss Federal Council Adopts Dispatches On New DTAs

The Swiss Federal Council has adopted dispatches on five double taxation agreements, which will now be submitted to Parliament for approval. The treaties with Estonia, Ghana, Iceland, and Uzbekistan either replace or revise the current deals, while the agreement with Cyprus is Switzerland’s first with the territory. All of the… – Continue reading

US gains info on bank details of 4,273 under FATCA

TAIPEI, Taiwan — The Financial Supervisory Commission’s (FSC, 金管會) chairman Tseng Ming-chung (曾銘宗) met with the U.S. treasury from Nov. 2 till Nov. 5 and signed an Intergovernmental Agreement (IGA) under the Foreign Account Tax Compliance Act (FATCA) that will see Taiwanese financial institutions directly providing 4,273 Taiwanese green-card holders… – Continue reading

Ukraine and Russia take center stage as leaders gather for G20

(Reuters) – A showdown between Western leaders and Russian President Vladimir Putin is likely at the G20 summit in Australia starting on Saturday, following fresh reports of Russian troops pouring into eastern Ukraine. Ukraine has accused Russia of sending soldiers and weapons to help separatist rebels in eastern Ukraine launch… – Continue reading

Corruption fighters confident for G20 tax haven crackdown

G20 guide: what to expect Brisbane residents will experience “longer travel times” as G20 forces roads and bus stations to be closed in the CBD and South Bank. Autoplay ONOFFVideo feedbackVideo settings G20: full coverage The global coalition against corruption – Transparency International – hopes Sunday’s G20 closing statement in… – Continue reading

Netherlands – EC decision to investigate transfer pricing arrangements

November 14: The European Commission (EC) today released a “non-confidential version” of its June 2014 EC decision to open an in-depth investigation concerning whether certain transfer pricing arrangements of a multinational entity with the Dutch tax authorities constitute state aid that is contrary to EU law. The investigation is identified… – Continue reading

OECD sees competition heating up once tax havens shut down

Brisbane (Australia) (AFP) – The Organisation for Economic Co-operation and Development on Friday forecast competition heating up among countries wanting to attract revenue from big digital companies like Apple and Google, even as a row rages over Luxembourg’s arrangements with multinationals. Closing corporate tax loopholes and endorsing a common reporting… – Continue reading

ITAT ruling gives a boost to black money fight

MUMBAI: In the first ever ruling relating to taxation of black money stashed in overseas tax havens, the Mumbai bench of the Income Tax Appellate Tribunal (ITAT) has given the taxman a lot to cheer. Funds aggregating $2.4 million (Rs 11.73 crore approximately) as of December 31, 2001, held in… – Continue reading

Ansbacher showed that in Ireland taxes were just for the ‘little people’

This offshore illegal scam showed that, in Ireland as elsewhere, taxes really were for the “little people”. The facts emerged as a by-product of the tribunal directed by Mr Justice Brian McCracken in 1997. It was set up to trace payments by supermarket magnate Ben Dunne to Fianna Fail’s Charlie… – Continue reading

PD link to tax dodge dossier alleged in Dail showdown

A WHISTLEBLOWER claimed former Tanaiste Mary Harney “shut down” his investigation into allegations of offshore tax evasion after he uncovered the names of senior politicians in the Progressive Democrats, Fianna Fail and Fine Gael, the Dail has heard. It is the first time Ms Harney’s party, the now defunct PDs,… – Continue reading

Should you stash cash in the Caymans?

The Cayman Islands is touted as one of the world’s top 10 finance hubs. The chief reason that the Caribbean hotspot holds such cachet is an epic perk it provides – freedom from income tax. twitter To get more Money more often, why not follow us on Twitter? We’re @FairfaxMoney… – Continue reading

No WHT exemption to foreign institutional investors: FBR

The Federal Board of Revenue (FBR) has proposed that no exemption whatsoever from withholding tax under Eighth Schedule (Capital Gains Tax) of the Income Tax Ordinance 2001 is available to foreign institutional investors either on the basis of avoidance of double taxation treaties or for any other reason. Through an… – Continue reading

PwC in secret tax deals while advising ATO

NEIL CHENOWETH Global accounting firm PwC was advising the Australian Taxation Office how to run its transfer pricing unit at the same time that its Luxembourg office was cutting favourable tax agreements for Australian companies. Luxembourg documents show PwC obtained secret tax agreements for more than 30 Australian companies in… – Continue reading

India signs tax info exchange pact with Saint Kitts & NevisNITED NATIONS:

To help in its efforts to crack down on suspected black money stashed abroad, India has entered into an information exchange pact with Saint Kitts and Nevis, a two-island Carribean country, perceived as a safe haven for offshore funds. The agreement was signed by India’s Permanent Representative to the UN… – Continue reading

The ‘Sonic’ boom: How Alberta became an ‘Offshore Business’ in the pathology market

Why does Stephen Mandel, the newly minted Minister of Health, think it’s a good idea for Alberta taxpayers to support the lifestyles of wealthy Australian businessmen who earn more than $13 million a year; their executive teams who get ridiculous bonuses and stock options; and the Australian economy as a… – Continue reading

Tax avoidance: three things G20 governments can do

The ability of multinational companies to shift profits into low-tax jurisdictions is undermining governments’ ability to raise revenue. But the cross-border policy solutions are complex. Curbing international tax avoidance has become a focus of G20 discussion this week, after last week’s revelation that major companies including Ikea, AMP and Pepsi… – Continue reading