Category: Jurisdiction

Malawi Releases 2018 Budget

Malawi’s recent budget included numerous tax changes and announced updates to the country’s transfer pricing rules. On the indirect tax front, the Budget, released in mid-August, introduced a 10 percent excise tax on television subscriptions and introduced a value added-tax exemption for dairy products, animal or vegetable fats and oils,… – Continue reading

India slaps tax demand on Hutchison for Vodafone deal

India’s income-tax department has raised a tax demand for Hutchison’s capital gains during its sale of India mobile business to Vodafone in 2007 India’s income-tax department has now trained its guns on Hong Kong-based Hutchison Telecommunications International Ltd (HTIL) in connection with its alleged capital gains during the US$ 11-billion… – Continue reading

SARS to crack down on multinational companies and subsidiaries’ tax returns

MEDIUM and large businesses with multinational ties will soon have to start supplying the South African Revenue Service (SARS) with more detailed reports of their relationships and transactions with connected entities residing in other countries. SARS has beefed up its Transfer Pricing Division and is now actively involved in the… – Continue reading

Australia Making Inroads On Tackling MNE Tax Avoidance

Kelly O’Dwyer, Australia’s Minister for Revenue and Financial Services, has stressed that the Government has taken and will continue to take steps to tackle corporate tax avoidance by large businesses. Speaking to Sunrise’s David Koch on August 23, 2017, the Minister said: “We absolutely believe very strongly that you cannot… – Continue reading

Anti-tax avoidance measures under fire from employers, tax advisors

The caretaker government may make the Netherlands a less attractive location for international business because of changes to the corporate tax system, the employers’ organisation VNO-NCW and tax advisers have warned, the Financieele Dagblad said on Monday. The employers and Dutch Order of Tax Advisors say the government is choosing… – Continue reading

Investors would rather put their money in Mauritius than South Africa

Despite a larger economy and a much bigger population, South Africa’s political uncertainty and failure to draw cost-sensitive investors has given way for the rise of Mauritius as the top investment destination in Africa. Speaking to CNBC Africa, Bravura’s executive director, Soria Hay, said Mauritius is fast-gaining the reputation among… – Continue reading

Changes to tax laws in sight for MNCs as the authorities adopt BEPS

MULTINATIONAL corporations (MNCs) in Malaysia will soon be seeing more tax law changes coming their way as the authorities get down to tackling base erosion and profit shifting (BEPS). This follows efforts by the Organisation for Economic Co-operation and Development (OECD), approved by G20 leaders, to formulate a 15-step action… – Continue reading

The new corporate offences of failing to prevent the facilitation of tax evasion and Deferred Prosecution Agreements

The reach of Deferred Prosecution Agreements (“DPAs“) has been broadened to include the new offences of failing to prevent the facilitation of UK or foreign tax evasion – strengthening the DPA regime yet further as a weapon in the fight against corruption. From 30 September 2017, it will be an… – Continue reading

Singapore sees tax revenue up 5 pct in 2016/17 financial year

SINGAPORE, Aug. 24 (Xinhua) — The Inland Revenue Authority of Singapore (IRAS) publicized its annual report on Thursday, showing it collected 47 billion Singapore dollars (about 34.53 billion U.S. dollars) in tax revenue in Financial Year 2016/17, up 5 percent from the past financial year. IRAS attributes the revenue collection… – Continue reading

Court Rules In Favor Of Taxpayer In Canadian TP Audit Case

The Federal Court of Canada has ruled that the Canadian Revenue Agency may not conduct further in-person interviews with representatives from a multinational corporation concerning its transfer pricing affairs, having already discussed earlier tax years. Cameco Corporation declined to produce approximately 25 personnel for oral interviews in relation to an… – Continue reading

Microsoft Reaches Tax Agreement with Australia

Microsoft says iicrosoft says it has settled an Australian tax audit, a deal that follows criticism of the company’s practice of lowering its local tax payments by routing sales made to Australian customers through Singapore. The settlement was disclosed by Daniel Goff, Microsoft’s corporate vice president of worldwide taxes, in… – Continue reading

I-T Department open to reducing withholding tax for foreign companies: Official

NEW DELHI: The Income Tax department is open to lowering the withholding tax rate for foreign companies which have income in India, a senior official said today. Central Board of Direct Taxes (CBDT) Chairman Sushil Chandra also urged firms and MNCs operating in India to pay their due share of… – Continue reading

CBDT head says tax information from countries pouring in, firms can’t escape anymore

Central Board of Direct Taxes (CBDT) Chairman Sushil Chandra on Wednesday said that the tax exchange agreements with other countries was resulting in information pouring in at a fast pace, thus there was no escaping for the multi-national companies (MNCs) from fair taxation. “We have got wide (tax) information from… – Continue reading

Deadline for FATCA FFI agreement renewal quietly extended

The Internal Revenue Service has extended the deadline for foreign financial institutions to have renewed their FFI Agreements, it has emerged. As reported, the original deadline was 31 July. However, accounting industry sources have flagged up the fact that the Internal Revenue Service is now stating that the deadline for… – Continue reading

Australia: Proposed changes to CGT main residence exemption for foreign residents

The Treasurer has recently released exposure draft legislation (Treasury Laws Amendment (Housing Tax Integrity) Bill 2017) in relation to removal of the CGT main residence exemption for foreign residents. The changes are part of the Commonwealth Government’s ‘housing affordability’ reforms announced in the 2017-18 Budget. This will affect both Australian… – Continue reading

Multinational giants accused of shifting Australian revenue offshore

Four of the world’s largest companies have been under investigation by Australian tax authorities, amid new evidence from US executives about how Facebook, Google, Apple and Microsoft are shifting money to offshore tax havens. Appearing before a highly anticipated public hearing into corporate tax evasion, the executives endured questions about… – Continue reading

Britain’s Links With Offshore Tax Havens Revealed

Britain is the world’s second largest conduit for multinational companies avoiding tax on profits, according to new research. Although the British government has taken a leading stand in the fight to tackle corporate tax avoidance, data analysis by researchers at Amsterdam University in The Netherlands shows The City of London… – Continue reading

Voluntary offshore disclosures: Final SARS deadline fast approaches

JOHANNESBURG — Despite question marks hanging over SARS, its chief Tom Moyane and the institution’s current ability to effectively collect taxes, the authority continues to push ahead with expanding its international net. A 31 August deadline for taxpayers to disclose their offshore assets and income to SARS is fast approaching…. – Continue reading

African tax authorities consider how to boost revenue

African nations will have more resources at their disposal to meet the Sustainable Development Goals if their national revenue authorities can boost tax collection. The United Nations Economic Commission for Africa estimates that the continent loses more than $50 billion through illicit financial outflows per year, much of this linked… – Continue reading

Australia warns multinationals over tax as Chevron drops appeal

PERTH (miningweekly.com) – US oil and gas major Chevron has withdrawn its High Court appeal over a A$340-million bill from the Australian Taxation Office (ATO). The withdrawal means that the Full Federal Court decision of April is now final. The company in May turned to the High Court after a… – Continue reading

Successfully Resolving Contentious Offshore Claims with the IRD: Concepts and Strategies

A Territorial Tax System Since the introduction of business taxation in 1948, Hong Kong has adopted a territorial tax system. Unlike most other advanced jurisdictions, Hong Kong does not tax worldwide income on the basis of residence, but only seeks to charge Hong Kong source profits. Profits tax is governed… – Continue reading

The Corporate Offences of Failure to Prevent the Facilitation of Tax Evasion – What It Means for You

The United Kingdom’s Criminal Finances Act 2017 (the “Act”) creates two new corporate offences of failure to prevent facilitation of tax evasion (the “Corporate Offences”). These new Corporate Offences will be committed where a relevant body fails to prevent an associated person criminally facilitating the evasion of tax, whether the… – Continue reading

IRD moves to audit maximum 25,000 income tax files to detect evasion

The Internal Resources Division (IRD) has issued a directive to audit maximum 25,000 income tax files of both individuals and corporate taxpayers to detect tax evasion and concealment of actual income, officials said. The income tax authority has received the directive from the IRD not to exceed this number of… – Continue reading

Banker’s Toolbox addresses beneficial ownership rules

Banker’s Toolbox, Inc., the leader in Bank Secrecy Act anti-money laundering compliance solutions for financial institutions, announced today the launch of its Due Diligence Manager solution for Beneficial Ownership. This extension of the existing BAM+ platform delivers exciting and holistic features including a completely flexible question builder and automated periodic… – Continue reading

Swiss asset manager settles US tax evasion charges

The Geneva asset management firm Prime Partners has agreed to pay $5 million (CHF4.8 million) to the United States to settle charges for tax evasion and assisting US taxpayers in opening and maintaining undeclared foreign bank accounts from 2001 to 2010. A US Department of Justice (DOJ) statement external linkon… – Continue reading

Indian authorities investigate Amitabh Bachchan’s name in Panama Papers

Indian income tax department started probe into Amitabh Bachchan’s overseas transactions in the light of his name in Panama Papers. The I-T department sent officer to the British Virgin Islands in order to collect his financial information. The authorities received criticism for lack of action against the Bollywood actor after… – Continue reading

Mexico: New Substance-Over-Form Litigation Procedures In Mexico

Mexico has introduced new substance-over-form procedures that change the country’s formal approach into one more compliant with the BEPS Project. Taxpayers should take note of these developments as they may impact tax disputes, writes Bernardo Ramírez and Valentín Ibarra of Chevez, Ruiz, Zamarripa y Cía. Resulting from a G20 world… – Continue reading

UK Issues Guidance On Preparing CbC Reports

The UK tax authority, HM Revenue and Customs (HMRC), has issued guidance for businesses on the preparation of country-by-country reports in the required format. The CbC report is one element of a new three-tiered standardized approach to transfer pricing documentation proposed under Action 13 of the OECD’s base erosion and… – Continue reading