Category: Jurisdiction

Facing up to tax challenges in the age of digital economy

THE WORLDWIDE increase in digital commerce has alerted many countries to the unique tax challenges it presents. Facing up to tax challenges in the age of digital economy THE WORLDWIDE increase in digital commerce has alerted many countries to the unique tax challenges it presents. There is now a common… – Continue reading

G20 Brisbane: Five corporate tax havens around the world and how the summit can crack down on them

Prime Minister Tony Abbott has nominated global tax avoidance as one of the key issues on the agenda for this weekend’s G20 summit in Brisbane. Major companies including Google and Apple have faced strong criticism over their efforts to lower their tax bills by shifting profits to jurisdictions with low… – Continue reading

Costello defends Future Fund tax bill

Future Fund chairman Peter Costello has defended the amount of tax the sovereign wealth fund pays, saying it has ‘sovereign immunity’ when it invests overseas. The government-owned Fund was named along with other Australian companies for using Luxembourg as a base in which to lower global taxes in one of… – Continue reading

MEPs call for action on tax avoidance in Europe

Members of the European Parliament called for action on tax avoidance in Europe on Wednesday. A report released earlier this month by the International Consortium of Investigative Journalists documented secret deals arranged with multinational corporations, enabling them to avoid paying tax in Luxembourg. Hundreds of major corporations like Pepsi, IKEA… – Continue reading

HMRC’s Yield From Specialist Investigations Rises

New research from international law firm Pinsent Masons has shown that the compliance yield from HM Revenue and Customs’ (HMRC’s) “Specialist Investigations” team rose by 23 percent last year to hit a record GBP3.65bn (USD5.79bn). 2013-14 was the team’s most successful year to date, according to Pinsent Masons. The GBP3.65bn… – Continue reading

Australia – Considerations of ATO’s policy on transfer pricing reconstruction

November 13: Taxation Ruling (TR) 2014/6—issued yesterday by the Australian Taxation Office (ATO)—sets forth the Commissioner’s view on the application of the reconstruction provisions as contained in Australia’s new transfer pricing rules. The significance of these reconstruction provisions is that they authorise the Commissioner to re-price, reconstruct or disregard a… – Continue reading

Swiss Banker Faces Charges of Conspiring to Hide Hundreds of Millions

Preet Bharara, the United States Attorney for the Southern District of New York, and Shantelle P. Kitchen, Acting Special Agent in Charge of the New York Field Office of the Internal Revenue Service, Criminal Investigation (“IRS-CI”), announced today the indictment of MARTIN DUNKI, a former client advisor and Senior Vice… – Continue reading

US FATCA Registration Deadline Approaching: 31 December 2014

The British Virgin Islands (the “BVI”) has now enacted legislation which allows for the implementation of its commitments under the Model 1B (i.e. non-reciprocal) intergovernmental agreements with the United States, signed on 30 June 2014, (the “US IGA”) and with the United Kingdom, signed on 28 November 2013, (the “UK… – Continue reading

More than 4,000 Taiwan bank accounts affected by FATCA

Taipei, Nov. 13 (CNA) Taiwan’s financial authorities have found that there are 4,273 bank accounts in Taiwan whose holders are obligated to report assets to the United States tax authorities, Taiwan’s top financial regulator said Thursday. Tseng Ming-chung, chairman of the Financial Supervisory Commission, said most of the account holders… – Continue reading

Sobotka: EU is safe haven

Prague, Nov 13 (ČTK) — The EU is a safe haven guaranteeing stability and prosperity to the Czech Republic, Czech Prime Minister Bohuslav Sobotka said at the opening of the National Convention on the EU today. In his speech, Sobotka also criticized the non-observance of the rules and the existence… – Continue reading

No extra NHR tax exemptions in 2015, say Portuguese officials

Proposals to extend capital gains and investment income tax exemptions under Portugal’s Non-Habitual Residents Tax Regime have not been passed, say government officials It seems that the Portuguese government has shelved plans, at least for 2015, to extend capital gains and investment income taxation exemptions. However, officials say they are… – Continue reading

Regulators fine global banks $4.3 billion in currency investigation

(Reuters) – Regulators fined six major banks a total of $4.3 billion for failing to stop traders from trying to manipulate the foreign exchange market, following a yearlong global investigation. HSBC Holdings Plc, Royal Bank of Scotland Group Plc, JPMorgan Chase & Co, Citigroup Inc, UBS AG and Bank of… – Continue reading

Toyota, Mitsui, Marubeni to sign first set of pacts

Mitsui, Toyota and Marubeni are likely to be among Japanese companies that would sign the first set of bilateral advance-pricing agreements (APA) with India shortly. These agreements will provide certainty to Japanese multinational firms operating in India and avoid conflicts over sharing of taxes between India and that country. Two… – Continue reading

Absence of treaties with tax haven nations blocking black money fight

New Delhi: Absence of criminal legal treaties between India and tax haven nations have been cited by probe agencies working in the SIT on black money as one of the major impediments in initiating steps to bring back illegal funds stashed abroad by Indians. These agencies, including the Central Board… – Continue reading

India to sign agreement for data on tax evasion soon

India will soon put its signature on an agreement for exchange of information to curb tax evasion after refusing to sign the multilateral pact along with 51 nations in Berlin last month. Finance Ministry officials told Deccan Herald that the government was currently in the process of completing the internal… – Continue reading

Ireland scores poorly in European ‘Hidden Taxes’ report

NGO report calls for central listing of beneficial owners of EU firms and trusts The European Union should introduce a centralised public register revealing the identities of beneficial owners of companies and trusts, according to a pan-European report to be published today. Hidden Taxes: the EU’s Role in Supporting an… – Continue reading

Anti-Abuse Clause Mooted For Parent-Subsidiary Directive

The European Union’s 28 member states are seeking agreement on the proposed introduction of a common anti-abuse clause in the Parent-Subsidy Directive (2011/96/EU). The plans were discussed at a meeting of the EU’s Economic and Financial Affairs Council (ECOFIN) on November 7, 2014. The proposed anti-abuse clause would allow member… – Continue reading

Sears, Pinnacle Entertainment Look At US REITs

Sears Holdings and Pinnacle Entertainment have become the latest US companies to announce that they are considering establishing real estate investment trusts (REITs), to unlock tax advantages that have been considered by some companies as an alternative to a corporate inversion. REITS do not pay corporate tax as long as… – Continue reading

Ending corporate secrecy: time for the Government to support Anti-Money Laundering Directive

A new report on tax transparency across 15 EU states highlights hidden profits People in Europe and in developing countries are being robbed. One trillion euro is lost to tax dodging every year in the EU, with billions being lost from developing countries each year for the same reason. It… – Continue reading

Transferring Capital and Profit Into and Out of Vietnam

HCMC – Foreign exchange control is a paramount concern of all foreign investors entering into Vietnam, as regulations on capital inflows and outflows have a great influence on operations and profit. Foreign exchange control includes transferring capital into and out of the country, opening and using bank accounts, borrowing foreign… – Continue reading

No one solution to tax avoidance issue – Maugham

THERE IS NO single policy or solution that can prevent the occurrence of tax avoidance because there is no single cause for the phenomenon, according to Devereux Tax Chambers barrister Jolyon Maugham. Speaking at the ICAEW’s Hardman Lecture, Maugham told the institute’s members that “plugging holes” in the tax code… – Continue reading

Another Big Year of MLP ETF Inflows

With U.S. interest rates remaining at historic lows, yield-starved investors have continued allocating massive amounts of capital to exchange traded products offering exposure to master limited partnerships (MLP). So popular are MLP ETFs and exchange traded notes (ETNs) that the asset class has not endured a month of net outflows… – Continue reading

Construction Company Wins Egyptian Tax Evasion Appeal

Orascom Construction Industries, an international engineering and construction firm, has won a ruling in its favor from the Egyptian Tax Authority’s Independent Appeals Committee, against an earlier USD1bn tax evasion ruling relating to its Egyptian subsidiary. Orascom Construction Industries (OCI) SAE said that it had been served with an assessment… – Continue reading

Denmark – Withholding tax on dividends distributed to investment funds

November 12: Danish companies subject to Danish corporate income tax generally must withhold tax at a rate of 27% on dividend distributions, but the rate of the withholding tax may be reduced to 15% when dividends are distributed to Danish domiciled investments funds that are known as “IMBs” (i.e., investment… – Continue reading

UK proposes ending its patent box scheme after agreement with Germany

The UK has agreed to put forward a proposal to  close its patent box tax break, which allows income from the commercial exploitation of intellectual property (IP) to be taxed at 10%, in a concession to German concerns about artificial shifting of profits between European countries.12 Nov 2014 Intellectual Property… – Continue reading

New Russian tax law to clamp down on offshore tax schemes

In March 2014 the Russian Ministry of Finance published a draft anti-offshore law which is currently submitted for consideration by The State Duma (parliament) with the decision expected to be made by the end of 2014. Russia is aiming to clamp down on the use of foreign offshore tax shelters… – Continue reading

Australia – Transfer pricing reconstruction not limited to “exceptional circumstances”

Australia – Transfer pricing reconstruction not limited to “exceptional circumstances” November 12: The Australian Taxation Office (ATO) today finalised a transfer pricing ruling that sets forth the Commissioner’s position on application of the reconstruction provisions, as outlined in section 815-130 of the Income Tax Assessment Act 1997. The ruling—TR 2014/6—covers… – Continue reading

Joe Hockey’s constituents not buying the Treasurer’s tough on tax avoidance talk

Treasurer Joe Hockey has made tax avoidance by the world’s largest companies one of the cornerstone issues for discussion by the world’s most powerful leaders at the G20 summit in Brisbane this week – but it appears he still has some way to go to convince those closer to home… – Continue reading

Zimbabwe: U.S.$6 Million Tax Evasion Bid Lands Pair in Dock

Two Zimbabwe Revenue Authority officers yesterday appeared in court charged with soliciting for a bribe from Megalinks Pvt (Ltd) to help the firm evade paying over $6 million in taxes. zimra chief investigation officer Tafara Gumede (41) of 4 Gainsbrugh Court in Harare and an investigation officer Obrie Tinashe Tozivepi… – Continue reading

BJP Raises Singhvi Tax Evasion Issue, Asks Sonia to Clarify

BJP today accused Congress leaders of generating black money in the country while referring to the matter of the alleged tax evasion by its spokesperson Abhishek Singhvi and asked Congress President Sonia Gandhi to clarify on the issue. “The issue of Singhvi is just a sample as it is only… – Continue reading

George Osborne waters down flagship controversial tax break

Patent boxes allow firms to pay much lower taxes on profits from patented inventions, but critics say it gives UK too much of a fiscal advantage George Osborne’s move removes one of the potential flash points between the UK and Germany before this week’s G20 summit in Brisbane. Photograph: Pa… – Continue reading

Ahead of any devolution Northern Ireland chiefs must investigate any tax avoidance schemes

Northern Ireland is a serious player in the international market to attract more foreign investment. The comprehensive requirement: can Northern Ireland offer a competitive combination of access to markets, favourable domestic costs including employment costs, an adequate infrastructure base, a stable society and taxation policies that help to ensure attractive… – Continue reading

Apple to Fiat EU Tax Cases Should Be Finished Ahead of New Ones

The European Union should complete its four tax probes before it can “decide what to do next,” EU Competition Commissioner Margrethe Vestager said. “Maybe in the beginning of the second quarter of next year we will have results on at least some of those open cases,” Vestager told reporters after… – Continue reading

FATCA is financial imperialism: critics

The US Treasury has opened a new front in its war against offshore tax evasion. But for some it amounts to financial imperialism. Americans with legitimate bank accounts outside the country, and foreigners working in the United States, have begun receiving letters from their banks in Paris, Tokyo, Johannesburg and… – Continue reading

Pension Tax Relief Sought For All Americans Abroad

With American taxpayers newly able to easily secure more favorable US tax treatment for Canadian retirement plans, American Citizens Abroad had requested that such treatment should be extended worldwide to all foreign pensions and retirement savings. Under the recent change, many Americans and Canadians with registered retirement savings plans and… – Continue reading

Benefits of Investing in India via a Singapore Holding Company in a New Guide by Rikvin

With the change in government in India, the world is looking up to its new Prime Minister Narendra Modi to revive the country’s economy, who recently launched his flagship ‘Make in India’ campaign to propel the country into top 50 of World Bank’s Ease of Doing Business rankings by 2016…. – Continue reading

Ansbacher probe: Gardai get 5,500-page tax evasion file

Official ‘offered €20,000’ to wrap up tax evasion probe GARDAI have now received 5,500 pages of files relating to allegations of tax-evasion by holders of Ansbacher accounts. Jobs Minister Richard Bruton forwarded the allegations of a whistleblower in his department to the gardai last night. The documents have been sent… – Continue reading

Automatic exchange of tax info, balanced growth on G-20 agenda

Prime Minister Narendra Modi would attend the G-20 summit later this week where world leaders would come together for discussing issues including automatic exchange of tax information, taxation of large companies operating digitally, and a comprehensive strategy for strong, sustainable and balanced growth. Official sources said that the leaders will… – Continue reading