Category: Jurisdiction

New Corporate Criminal Offences of Failure to Prevent Facilitation of Tax Evasion

Quick Guide Part Three of The Criminal Finances Act 2017 (CFA 2017) introduces two new corporate criminal offences: The failure to prevent facilitation of UK tax evasion offences The failure to prevent facilitation of foreign tax evasion offences Both “failure to prevent” offences can be committed by a body corporate… – Continue reading

Guyanese businessmen warned of global crackdown on offshore tax evasion

Commissioner-General of the Guyana Revenue Authority (GRA), Godfrey Statia warned Guyanese businessmen against offshore tax evasion, saying that global systems are being increasingly networked to weed out tax cheats and report them to their home-countries. Addressing a luncheon organised by the Guyana Manufacturing and Services Association (GMSA) at the Georgetown… – Continue reading

The common reporting standard – your foreign bank account could be coming to Nigeria

If you live in Nigeria and you have a foreign bank account; you should read this.If things go as planned, the FIRS will soon have access to information on the money and other financial investments that you have in your foreign bank account. This will happen when the Common Reporting… – Continue reading

U.S. companies urge EU to refrain from unilateral moves on Web tax

BRUSSELS (Reuters) – The European Union’s plans to increase taxes on digital firms risks undermining the bloc’s growth and stifle global efforts to find common solutions, U.S. companies operating in the EU said on Tuesday. Critics say online firms such as Google (GOOGL.O) or Facebook (FB.O) pay too little tax… – Continue reading

Tax expert says amendment to new tax law likely before implementation next year

Removal of withholding tax on G-Sec income effectively frees foreign investors paying any taxes New tax law proposes to remove 10% withholding tax on G-Secs but makes such income liable for income tax up to 24% This likely to result in sizeable leakage of tax revenue to govt. as G-Secs… – Continue reading

Business Europe Rejects EU Digital Turnover Tax Proposal

Markus J Beyrer, Director General of Business Europe, has expressed concerns about the proposed introduction of a European Union turnover tax on digital businesses. On September 21, the European Commission launched a new agenda to ensure that the digital economy is taxed “in a fair and growth-friendly way.” This could… – Continue reading

BEPS Actions 8-10 Most Important For Latin American, Caribbean States

The Inter-American Center of Tax Administration (CIAT) has released a new statement summarizing the feedback from Latin American and Caribbean countries from ongoing discussions on countering base erosion and profit shifting. CIAT said it and a number of regional and international organizations have brought together policymakers from countries in the… – Continue reading

Foreigners in Sri Lanka Treasury bonds may not have to pay tax

ECONOMYNEXT – Foreign investors in Sri Lanka’s rupee bonds may not have to pay taxes after April 2018, Deputy Central Bank Governor Nandalal Weerasinghe said, amid some uncertainty in markets how a new Inland Revenue law will be interpreted. Sri Lanka lifted a 10 percent withholding tax government bonds from… – Continue reading

New Swiss tax data exchange deals raise red flags

The automatic exchange of tax information (AIE) between countries is generally seen as an effective way of cracking down on tax cheats. But what if a country uses the data to politically oppress its citizens? It’s a burning issue facing Swiss lawmakers. This week, Swiss parliament will begin a debate… – Continue reading

Armenia insists on signing double taxation agreement with USA

YEREVAN, September 25. /ARKA/. Until 2022 Armenia will conclude agreements on the exclusion of double taxation with 8 more countries and will pursue an agreement also with the United States to abolish double taxation, Armenian finance minister Vardan Aramyan said at a press conference on Monday. So far Armenia has… – Continue reading

The OECD is focused on maintaining the integrity of the CRS

As of August 2017, 102 international Jurisdictions are committed to the implementation timelines of the Common Reporting Standard (CRS). There are 49 Jurisdictions that are committed to the first exchange during 2017 and 53 Jurisdictions for 2018. The OECD is taking extra precautions to ensure that reportable financial information regarding… – Continue reading

Taxmen set their sights on digital economy

KUALA LUMPUR: The taxmen of the Inland Revenue Board (IRB) and Royal Malaysian Customs Department have set their sights on the digital economy. Treasury secretary-general Tan Sri Dr Mohd Irwan Serigar Abdullah pointed out last week that some foreign-owned digital economy players like Google, Uber and Facebook are currently not… – Continue reading

FBR begins collecting individuals’ account details for OECD members

KARACHI: The tax authorities have kicked off a planned program under which they share foreign individuals’ financial-account information with the member countries of the Organization for Economic Cooperation and Development (OECD), sources said on Saturday/ The Federal Board of Revenue (FBR), issued a notification regarding the schedule for exchange of… – Continue reading

Hong Kong to examine tax concessions to attract global funds, Financial Secretary says

Financial Secretary Paul Chan Mo-po said tax incentives would help Hong Kong compete with other fund management centres The government will examine the existing tax concessions applicable to the fund industry to make Hong Kong into a diversified and competitive international fund management centre against its global counterparts, said the… – Continue reading

Switzerland Consulting On WHT Reforms

The Swiss Federal Department of Finance is consulting on proposals to amend the Withholding Tax (WHT) Ordinance, to more clearly define the rules for non-resident taxpayers. Under the proposed reforms, “quasi-residents” will be permitted to request a subsequent ordinary tax assessment. “Quasi-residents” are employees who are not domiciled in Switzerland… – Continue reading

The Netherlands – Budget 2018 – Dividend withholding tax and non-resident taxation

On 19 September 2017, the Dutch government released the State’s Budget for the year 2018. The Budget includes a draft bill to expand the dividend withholding tax exemption to tax treaty countries, to introduce a withholding tax obligation for holding cooperatives and to limit the taxation of non-resident investors. If… – Continue reading

Income Tax Jitters in The Bahamas Following IMF Recommendation

NASSAU, The Bahamas, Friday September 22, 2017 – An International Monetary Fund (IMF) proposal for The Bahamas to implement a low rate income tax has drawn a mixture of skepticism, approval and downright rejection. Following its Article IV consultation with the Hubert Minnis administration, the Washington-based financial body urged the… – Continue reading

Swedish retirees are flocking to Portugal to avoid taxes – but they could soon end up like their Danish and Finnish peers

In recent years, Portugal has become a popular low-tax haven for Swedish retirees. Since 2009, almost 2300 Swedes, most of them senior citizens, have swapped dark winters for the Mediterranean sun, and moved to Portugal either part- or full-time. Doing so, they have been able to avoid paying taxes to… – Continue reading

US set to lose $12bn in tax take by 2027 if multinationals relocate overseas

Tax inversions by US multinationals attempting to shift profits into lower tax jurisdictions could cost the US up to $12bn (£7.4bn) in lost corporate tax revenues by 2027, according to figures released by the US Congressional Budget Office There were 11 major corporate inversions from 2014-2015, although two significant inversions… – Continue reading

BHP willing to head to court against ATO tax bill

BHP is willing to head to court to fight the Australian Taxation Office on a more than $1 billion tax bill over its Singapore marketing hub. The world’s largest miner has continually defended its Singapore marketing hub, where it is accused of routing profits, and says it is confident of… – Continue reading

Public Country-by-Country Reporting; Taxpayers’ Rights

Appropriate Use of Country-by-Country Reports The OECD has now published Guidance (available here) on the appropriate use of Country-by-Country Reports (‘CbCRs’) by national tax authorities. This is in response to some valid MNE concerns that tax authorities may misuse CbCRs. “Appropriate use” is clarified as being for (i) high-level transfer… – Continue reading

Government set to crack down on tax perks for well-off investors

Popular investment schemes offering generous tax breaks for wealthier investors are likely to face new restrictions. The Treasury is mulling a crackdown on Enterprise Investment Schemes, likely to be announced in the next Budget on November 22. The scheme allows people to invest in start-ups, either directly or through funds,… – Continue reading

Ghana-Morocco double tax agreement to come into force in 2018 – (Part 2)

In our last publication, we discussed the signing of the Ghana-Morocco Double Tax Agreement (“DTA”) and the provisions of the DTA in relation to the taxation of permanent establishments and business income. In the concluding part of the article, we will discuss the taxation of investment, employment and service incomes… – Continue reading

Turkish gov’t to form special team to surveil, audit e-commerce

In order to tackle irregularities and unfair competition among e-commerce companies, Ankara is planning to form a special unit to track e-commerce activities and transactions in the country The Turkish government is planning to create a special unit of 200 people to track e-commerce activities in the country, Finance Minister… – Continue reading

Multinationals Fear Japan Reports Could Spur Outside Audits

Japanese multinational companies worry that filing their first country-by-country reports in 2018 will lead to a barrage of transfer pricing audits by developing countries. Companies are currently preparing their first country-by-country reports that must be filed with the National Tax Agency by the end of March 2018. Japan adopted country-by-country… – Continue reading

OECD Criticizes Estonia’s Dividend Tax Measure

The OECD has taken issue with the Estonian Government’s plans to reduce the rate of tax on distributed dividends for established companies, warning that the measure could complicate the tax system and discriminate against small firms. Under recently enacted legislation, tax on distributed dividends will be reduced from 20 percent… – Continue reading

Review of Ireland’s Corporation Tax Regime

Ireland’s Minister for Finance (the “Minister”) welcomed the results of the independent review of Ireland’s corporation tax regime (the “Review”) issued on 12 September 2017: “I welcome the emphasis given in the Review to the importance of certainty, which is core to our corporate tax offering. Our 12.5% corporation tax… – Continue reading

Republicans launch worldwide campaign in bid for territorial taxation

Letters calling for the elimination of FATCA, among other tax issues, will be presented to the White House in about two weeks’ time. A global political organisation with affiliation to the Republican Party has recently launched a petition and letter writing campaign in protest of “citizenship-based” taxation – partly in… – Continue reading

Vodafone Ghana sues GRA over GH¢160m transfer pricing assessment

…as tax dispute escalates Vodafone Ghana has filed a motion at the High Court of Justice, Commercial Division in Accra, against the Ghana Revenue Authority (GRA) disputing tax assessments of GH¢160 million, according to the Writ obtained by ghanabusinessnews.com. The GRA has asked Vodafone to pay 30 per cent of… – Continue reading

Indonesia to Trace and Tax Assets Kept Hidden During Amnesty

JAKARTA — Indonesia’s government has issued new regulations aimed at tracing and taxing the wealth of taxpayers who were not pardoned in the nine-month tax amnesty that ended in March. Around 972,000 taxpayers joined the amnesty programme and declared assets worth a total of 4,881 trillion rupiah (272 billion pounds)…. – Continue reading

Interpreting double tax treaties in light of the BEPS multilateral instrument

Some double tax treaties are being amended by a multilateral instrument Establishing how a particular treaty is affected can be a complicated process The UK intends to publish amended DTTs and this will help, but the MLI has added an additional layer of complexity 18 Sep 2017 Speed Read LEGAL… – Continue reading

The Finnish Supreme Administrative Court confirms that the business model chosen by parties must be respected in transfer pricing context

The Finnish Supreme Administrative Court published on 13 September 2017 precedent 2017:145 that further clarifies the scope of application of the Finnish transfer pricing adjustment provision (Act on Assessment Procedure (“AAP”) Section 31). In its previous landmark precedent KHO 2014:119 the Supreme Administrative Court stated that the so-called re-characterization of… – Continue reading

US Hearing On Improving IRS Appeals Process

On September 13, the US Ways and Means Oversight Subcommittee launched a hearing on improving the resolution process for taxpayer disputes and appeals with the Internal Revenue Service. The hearing is said to be the fourth in a series of attempts to reform and improve the IRS appeals process. “In… – Continue reading

Swiss Bankers Urge Care In Information Exchange

The CEO of the Swiss Bankers Association (SBA) has stressed that confidentiality, data security, and data protection requirements must be complied with when the automatic exchange of tax information gets underway. Claude-Alain Margelisch argued that there should also be a “number of security mechanisms in place that protect customers and… – Continue reading

Econ experts laud tax reform plan

MANILA, Philippines — The Foundation for Economic Freedom (FEF) has expressed support for the tax reform program being pushed by the Department of Finance, saying this will lead to better lives for Filipinos. “The comprehensive tax reform program lays a solid foundation for the government’s vision of inclusive growth, improved… – Continue reading