Category: Jurisdiction

Cayman drafts law requiring substance tests for offshore businesses

The Cayman Islands government has published draft tax legislation that will have far-reaching impact for the offshore finance industry operating in the jurisdiction by demanding that certain Cayman-registered companies have an adequate level of economic substance locally. The International Tax Co-operation (Economic Substance) Bill 2018 introduces a substance test for… – Continue reading

New IRS offshore amnesty regime imposes bigger penalties for secret accounts

The US Internal Revenue Service (IRS) has issued guidance on the voluntary disclosure regime now in force, following the termination of its offshore predecessor on 28 September 2018. The new rules are effective for all disclosures after that date. And the possible penalties have gone up quite significantly. One of… – Continue reading

Tax reforms will improve UAE’s investment status

Once the UAE fully implements the BEPS minimum standard, it will become a very good location, say tax experts The UAE’s position as an attractive destination for foreign investment will substantially improve once it fully implements minimum standards for base erosion and profit shifting (BEPS), tax analysts said on Saturday…. – Continue reading

Taxman starts questioning & issuing notices to BPOs

One month after the Authority of Advance Ruling (AAR) ruled that back office support services qualify as “intermediary” support services and not exports, officers of the indirect tax department have started issuing preliminary notices to captive units of multinationals and Indian companies exporting offshore support services. AAR’s directive meant several… – Continue reading

FBR drags feet over action on untaxed offshore investment

KARACHI: The Federal Board of Revenue (FBR) is dragging its feet over actions against Pakistanis who couldn’t declare offshore investments to evade taxes despite that the tax authority has stumbled upon critical financial data under an international treaty, people familiar with the matter said on Tuesday. Insiders said the apex… – Continue reading

Gov’t targets to lower corporate tax rate

The government is targeting to increase tax compliance among Micro Small and Medium Sized Enterprises by offering them lower corporate tax. East African Affairs Cabinet Secretary Adan Mohammed says various government agencies are working closely in integrating all tax payment regimes to ease tax payment and boost compliance. Tax avoidance… – Continue reading

Report: £250 billion fraud in UK tax havens greater sum than 20 years of foreign aid budget

Russia most common place of origin for fraudsters using British overseas territories A NEW report has identified over £250 billion in fraudulent funds directed through UK tax havens, more than over 20 years of the UK Government’s foreign aid budget. The report, by Transparency International, examined the UK’s overseas territories,… – Continue reading

US indicts four tied to money laundering at ‘Panama Papers’ firm

The US government announced charges on Tuesday against four men it said laundered money and arranged tax avoidance schemes through the Panama firm at the centre of the “Panama Papers” scandal. The four were affiliated with Mossack Fonseca, the law firm that helped thousands of clients around the world move… – Continue reading

Switzerland: Revised Swiss Corporate Tax Reform Will Keep Switzerland A Top Corporate Location

I. The background of the tax reform In connection with the international pressure on the Swiss corporate tax location, especially in relation to the Cantonal exemption of income for holding companies as well as the status privileged companies (“status privilege”) and the need of Switzerland to recover global recognition as… – Continue reading

EU Details Action Plan On Money Laundering

European Union finance ministers worked out a plan for combating money laundering and also made a deal on major bank reform on Tuesday (Dec. 4), according to reports from Reuters. The money laundering plan is a response to highly visible cases of alleged criminal activity at EU banks in countries… – Continue reading

Canada should invest more to prevent tax evasion, say Canadians and CRA tax professionals

OTTAWA, Dec. 03, 2018 (GLOBE NEWSWIRE) — A large majority of Canadians (77%) agree “It would be a good investment for the Government of Canada to allocate more resources towards preventing tax evasion and avoidance,” according to a recent Environics Research poll. The poll was commissioned by the Professional Institute… – Continue reading

EU finance ministers need to deliver: Digital companies must pay tax

When European finance ministers meet on Tuesday (4 December), they should swiftly adopt the digital service tax: a levy on turnover for very large digital firms such as Google, Apple, Facebook, Amazon, Booking and Spotify, write Udo Bullmann and Paul Tang. Udo Bullmann is president of the Socialist and Democrats… – Continue reading

Tax transparency watchdog urges Israel to step up moves against money laundering

After global index puts Israel in top third of most financially secretive countries, NGO calls for more public scrutiny and regulations to stop rich from hiding their assets Israel must immediately move to pass regulations against tax evasion and money laundering if it is to protect its credit rating and… – Continue reading

Avoidance of double taxation treaty between India, HKSAR comes into effect

A double taxation avoidance agreement between India and Hong Kong has come into effect from Friday, which officials say would stimulate more the two-way flow of investments and help curb fiscal evasion with respect to taxes on income. The agreement between India and the Hong Kong Special Administrative Region (HKSAR)… – Continue reading

Worldwide: UK Tax Round Up – November 2018

General UK Tax Developments Finance Bill The Finance (No 3) Bill 2018-19 (which will become the Finance Act 2019) was published on 7 November and includes legislation to enact the changes highlighted in our UK Budget blog post ( UK Budget Blog). Another key area covered by the Finance Bill… – Continue reading

Is this the end of the road for the EU’s digital services tax?

Ireland, Sweden, Denmark and Germany block digital services tax plan in Brussels. The spectre of a 3pc digital services tax (DST) levied by the EU against multinationals has been vanquished for now after Ireland, Sweden, Denmark and Germany joined forces in what is being heralded as a coup for diplomacy…. – Continue reading

Ireland, Malta Close ‘Single Malt’ Tax Avoidance Structure

Ireland and Malta have agreed to close the “Single Malt” – an aggressive tax planning structure in which some multinational corporations use a company incorporated in Ireland but tax-resident in Malta. The Competent Authority Agreement – entered into as per the provisions of Article 24 (mutual agreement procedure) of the… – Continue reading

FBR urged to clarify taxability of foreign rental income

There is confusion among taxpayers regarding taxability of foreign rental income in Pakistan and filing of income tax returns in view of avoidance of double taxation treaties signed between Pakistan and UAE, UK and Canada. A leading tax consultant Shahid Jami has approached the Federal Board of Revenue (FBR) for… – Continue reading

Canada: Common Reporting Standard Is Now Fully In Effect – If You Have Been Hiding Funds Or Assets Offshore, Now Is The Time To Disclose

Introduction – Offshore funds and Canada Revenue Agency’ reach Gone are the days when offshore bank accounts were outside the Canada Revenue Agency (CRA)’s reach. With the advent of the Common Reporting Standard (CRS), CRA automatically receives financial information of Canadian taxpayers who own bank accounts or assets in other… – Continue reading

KPMG event to shed light on tax developments

The Peninsula KPMG in Qatar will be holding a complimentary event to brief the country’s tax and finance practitioners on recent and upcoming developments in tax processes and regulations, on December 4. The event will see Senior Tax and Advisory leaders from KPMG, along with Salah Gueydi, Director of Tax… – Continue reading

Caribbean Banks support passage of tax bill amendments

THE Caribbean Association of Banks (CAB) has joined the growing list of advocates for the expedited passage of urgent legislation to strengthen this country’s international tax compliance. “Non-compliance with Global Forum Standards and Financial Action Task Force (FATF) recommendations increases the sovereign risk profile of not only the jurisdiction (TT)… – Continue reading

Barbados minister foresees OECD compliance by year-end

Barbados is to scrap its international business company (IBC) regime in response to the OECD labeling the policy as “harmful” to competition, and being in breach of rules governing international taxation. Last year the OECD included Barbados on its list of jurisdictions with a “harmful” preferential tax regime, and said… – Continue reading

India-China amends double taxation avoidance treaty

New Delhi, Nov 26 India and China have amended the bilateral tax treaty which will help prevent tax evasion by allowing exchange of information, the Finance Ministry said Monday. The Government of India and the People’s Republic of China have signed a protocol on November 26, 2018, to amend the… – Continue reading

UK lawmakers seek removal of 12-year offshore investigation limit

Britain’s parliamentary upper house has requested the current investigation limit set out in the Draft Finance Bill 2018 be scrapped. The House of Lords’ request to HMRC would, if passed, remove the 12-year offshore investigation limit from the Draft Finance Bill 2018 – a proposal that has seen an outcry… – Continue reading

Government, European Union in talks over looming blacklist

Government officials have devised what they believe is a solution to the looming European Union blacklist threat, according to Neil Smith, the executive director of government’s Office of International Business (Regulations). The EU has threatened to place the Virgin Islands on an anti-tax avoidance blacklist at the end of the… – Continue reading

Pakistan to finalise new anti-money laundering law

ISLAMABAD: Pakistan is fine-tuning a new law to join forces with the international community to combat money laundering and terrorist financing in line with a recommendation of a global financial watchdog, a top official said on Thursday. Khalida Habib, head of the Securities and Exchange Commission of Pakistan (SECP) said… – Continue reading

Barbados overhauls corporate tax regime, slashes tax rate on local companies more than 20 per cent

BRIDGETOWN, Barbados, Thursday November 22, 2018 – Barbados will harmonize its domestic and international corporation tax regimes, by December 31, 2018, slashing the tax burden for some local companies by up to 29 per cent. Prime Minister Mia Mottley announced in the Barbados Parliament on Tuesday, November 20, the ambitious… – Continue reading

Switzerland: The Brazil And Switzerland Double Tax Treaty: Why Is It So Significant?

Background The Brazilian and Swiss Governments signed a Double Tax Treaty (DTT) on 3 May 2018. Switzerland is one of the biggest investors in the Brazilian market and Brazil and Switzerland have already signed an Automatic Exchange of Information Agreement, which came into force on 1 January 2018. This new… – Continue reading

Canada’s Trudeau Announces $10.5-Billion Fiscal Stimulus to Compete With US

The cabinet of Canadian Prime Minister Justin Trudeau is set to implement tax cuts for the nation’s businesses, which, along with the announced plans to reduce regulation, are highly reminiscent of the economic policies of Canada’s southern neighbour. Kristian Rouz — Canadian Prime Minister Justin Trudeau has unveiled an ambitious… – Continue reading

A tax ruling just opened the Pandora’s box for India’s back offices

MUMBAI: Are India-based back offices of multinationals merely brokers? And, are Indian companies providing services to foreign firms just commission agents? Going by the tax department’s definition, it appears that they are so — and not exporters. Several back offices at multinationals now face 18% Goods and Services Tax (GST)… – Continue reading

Cyprus: Entry Into Force Of The Protocol Amending The Convention On The Avoidance Of Double Taxation Between Cyprus And Mauritius

The Cyprus Tax Department has announced that the procedures for ratification of the protocol dated 23 October 2017 amending the Convention on the Avoidance of Double Taxation between Cyprus and Mauritius have been completed, and the protocol entered into force on 2 May 2018. The protocol replaces text of article… – Continue reading

Kenya and Mozambique move to remove double taxation, ease Visa rules

Foreign Affairs Cabinet Secretary Monica Juma says the move is aimed at eliminating double taxation. Juma and her Mozambique counterpart Jose Antonio Pachecho have constituted a Joint Commission of Cooperation tasked with this mandate ahead of the State Visit by Mozambique President Filipe Nyusi who will be hosted by President… – Continue reading

Spanish Crypto Holders Under Scrutiny as Authorities Seek to Prevent Tax Fraud

The Spanish Ministry of Finance is to inspect some 15,000 individuals who have engaged in cryptocurrency transactions over the last year, Spanish-language news outlet El Pais reported. The announcement follows on from the introduction of compulsory reporting of cryptocurrency transactions for Spanish taxpayers, and will investigate whether there is any… – Continue reading

Trade misinvoicing costs South Africa $7.4bn in tax a year

While SARS is scrambling to meet collection targets, a new report estimates the country lost $37-billion in revenue to trade misinvoicing in five years. Trade misinvoicing is thought to be the largest component of illicit financial flows, draining developing countries of much-needed finances. In a new report, Global Financial Integrity… – Continue reading

Post Panama Papers: are English trusts still trusted?

Trusts still remain under public scrutiny, but can their reputation be safeguarded, asks Stuart Price A recent government consultation on the law of trusts brought out some interesting issues concerning how the status quo aligns with the principles of transparency, fairness and simplicity (the principles that, at least in the… – Continue reading

KRA Reveals 6 Tricks Foreign Firms Use to Evade Tax

Kenya Revenue Authority (KRA) has revealed six tricks that multinational firms use to dodge paying tax. One of the schemes involves the firms exporting very cheaply and importing good very expensively. The authority reports that most firms also under-declare they pay to expatriates a move that reduces their profits and… – Continue reading

Angolan president seeking increased cooperation with Portugal

Luanda, ANGOLA, November 18 – Angolan head of state Joao Lourenco has pledged to raise bilateral cooperation with Portugal during his visit to European country scheduled for 22- 24 November this year. Joao Lourenco made the pledge during an interview with the Portuguese newspaper “Expresso”, on the eve of his… – Continue reading

Corporate America flees zero-tax Caribbean havens after crackdown

Many U.S. multinational corporations have packed up or are choosing to open subsidiaries in low-tax, rather than no-tax, countries that are seen as more legitimate than the formerly popular island destinations of the Cayman Islands and the Bahamas. They’re fleeing in response to regulations from the European Union that require… – Continue reading

Brazil and United Arab Emirates sign agreement to eliminate double taxation

Convention signed on Monday will facilitate investments, can reduce tax evasion Brazil and the United Arab Emirates signed an agreement to eliminate double taxation on income and prevent tax evasion and tax avoidance. The document was signed on Monday (12 November) by Brazilian Foreign Minister Aloysio Nunes Ferreira and UAE… – Continue reading

Tax Planning for NRIs Returning to India

In general, investment and tax provisions relating to non-resident Indians (NRIs) returning to live in India are fairly generous. However, NRIs must carefully plan their return to India to ensure there are no surprises with respect to managing their overseas income and investments. In this article, we examine some of… – Continue reading

HMRC targets wealthy families with trusts

Changes to Britain’s centuries-old trust regime are looming as HMRC is concerned that trusts are letting some families pay less inheritance tax than those who do not pay accountants to set up the complex arrangements. To look at if the law should be changed, HMRC has published wide-ranging research of… – Continue reading

Ministers meet with EU, OECD to discuss ending tax watchlist

Deputy Prime Minister and Minister of Finance, K. Peter Turnquest, led a delegation to Brussels and Paris this week, for frank discussions with high-ranking officials within the European Commission and the Organization for Economic Co-operation and Development (OECD) on The Bahamas’ compliance with international standards on tax governance. The meetings… – Continue reading

Nigeria: Public Notice On The FIRS’ Income Tax (Transfer Pricing) Regulation 2018

The Federal Inland Revenue Service (FIRS) recently released the Income Tax (Transfer Pricing) Regulation 2018 (‘the Regulation’). The Regulation took effect from 12th March 2018 and replaces the Income Tax (Transfer Pricing) Regulations, 2012. The Regulation sets out the legal framework for the application of the arm’s length principle to… – Continue reading

US multinationals dodge $180 billion in taxes on foreign profits per year

US multinational corporations are plundering the populations of the United States and the world to the tune of trillions of dollars by driving down and evading taxes on profits booked overseas. This is the conclusion that emerges from a recent study by University of California at Berkeley economist Gabriel Zucman… – Continue reading

European Union digital tax levy could be delayed until 2020

Arriving at the meeting Tuesday in Brussels, the Danish minister of Finance, Kristian Jensen, said of his side: “Everything is possible in politics but I think that it is very hard to reach an agreement on the taxation of the digital economy”. Under the proposal, a 3pc levy would be… – Continue reading