INTRODUCTION HMRC have successfully challenged the offshore residence of Jersey companies holding UK real estate. In the case of Development Securities, the First Tier Tribunal held that Jersey companies set up to hold UK real estate were resident in the UK for tax purposes. This case serves as a timely… – Continue reading
The government’s plan to impose more levies on large companies will undermine their competitiveness amid a rising global trend of tax reductions and further distort the country’s taxation structure, analysts say. A draft tax code revision unveiled early this month proposes raising the corporate tax rate for businesses with taxable… – Continue reading
Every individual has a nil rate band of £325,000 after which any assets above this threshold become taxable at 40% unless they are passing to an exempt beneficiary such as a charity or spouse/civil partner. This threshold has been frozen until the end of the 2020/21 tax year. The government… – Continue reading
This article is the third of a series of articles that examines tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors in other offshore financial centres…. – Continue reading
NAIROBI, Aug. 15 (Xinhua) — The Kenyan government on Tuesday announced the deregistration of two human rights and governance lobby groups, citing their failure to adhere to domestic tax and employment regulations. Executive Director of NGO Coordination Board, Fazul Mahamed ordered the Kenya Human Rights Commission (KHRC) and African Center… – Continue reading
Ireland has published guidelines for requesting Mutual Agreement Procedure (MAP) assistance. The guidelines, issued in early August, set out the legal basis for requesting MAP assistance as well as: the process through which taxpayers can request assistance from Ireland’s Competent Authority (the Revenue) the possible outcomes resulting from a request… – Continue reading
Prospects for Mauritius’s economy remain “robust,” with the Government undertaking a number of initiatives to improve the attractiveness of the domestic tax regime for businesses, the International Monetary Fund said. Amadou Sy, who led an IMF mission to the territory, said that the economy remains “robust” but that “Mauritius is… – Continue reading
The UK tax authority, HM Revenue and Customs (HMRC), has warned taxpayers to avoid disguised remuneration schemes that attempt to recharacterize loan arrangements to avoid the 2019 loan charge on disguised remuneration. “HMRC is aware of schemes that claim to avoid the 2019 loan charge on disguised remuneration. These schemes… – Continue reading
The Irish Government is said to be nearing a deal with Apple that would protect the state from any losses that could arise while it holds in escrow the “state aid” money the EU has ordered the tech giant to pay back. Bloomberg reported that an individual familiar with the… – Continue reading
Launching the taxpayer directory for the 2016 tax year, Pakistan’s Finance Minister, Ishaq Dar, revealed that government efforts to broaden the country’s taxpayer base have been successful. The number of registered taxpayers, he said, has increased by nearly 50 percent from four years ago, when the first “directory” was released…. – Continue reading
America has formally agreed to share detailed information of companies with the Australian government’s Tax Avoidance Taskforce. This means authorities get access to additional intelligence to track down US-based multinationals. This month, US authorities signed a country-by-country report exchange deal with Australia. It seeks to give authorities a broader picture… – Continue reading
The US Internal Revenue Service (IRS) has begun accepting country-by-country (CbC) reports from multinational corporations. In June 2016 the IRS issued final regulations requiring CbC reporting by the ultimate parent entity of a multinational enterprise (MNE) group with revenue of USD850m or more in the preceding accounting year. The first… – Continue reading
The UK tax man has raised almost an extra £30 billion in the past year from cracking down on avoidance. The boost came in a year that saw HM Revenue & Customs collect a record £574.9 billion in taxes from individuals and businesses. The tax take was £38.1 billion up… – Continue reading
Companies operating in Belgium sent more than €221 billion to countries local authorities regard as tax havens, according to Belgian daily Le Soir. Belgium’s gross domestic product was €466 billion last year. According to the country’s tax authorities, 853 Belgian companies funneled almost a half of the country’s economic output… – Continue reading
The Budget Advocacy Network (BAN) has called on the country’s revenue authority to push for better taxation not more taxation. In its Transfer Pricing Report, BAN identified that such efforts hold the potential to stimulate further growth and investment whilst also allowing for increased levels of tax collection. The huge… – Continue reading
Bill would require private companies with more than $100m in turnover to publicly release tax information Six hundred of Australia’s biggest private companies could finally be forced to publish their high-level tax information, under a new push by Labor to repair a notorious piece of legislation. Labor will introduce a… – Continue reading
Brazilian football star Neymar is willing to pay a fine of £1.9 million to settle tax evasion allegations in his country, his lawyer said Friday. The 25-year-old wants to leave the fight with Brazilian authorities behind him as he prepares for a new professional life with Paris Saint-Germain after his… – Continue reading
I am a trustee of an offshore trust settled by a UK resident, non-UK domiciled settlor (with no UK origins) for the benefit of himself and his family. He previously opted to be taxed on the remittance basis. The trust holds only offshore investments. The settlor lent monies to the… – Continue reading
The statutory federal corporate tax rate in the United States is 35%, and it has been since 1993. Any company that pays that rate should probably be looking for a new chief financial officer. When state taxes are slotted in, the average combined tax rate is 39.1%, according to a… – Continue reading
Luxembourg Finance Minister Pierre Gramegna has introduced legislation into parliament that would establish a new intellectual property tax regime in Luxembourg. The bill was submitted to the Chamber of Deputies on August 4, 2017, and is designed to be aligned with the “modified nexus” approach to special IP tax regimes… – Continue reading
Opposition to the widening of the automatic exchange of information (AEOI) is growing stronger, and now the populist Swiss Peoples Party (SVP) has called for a slowing of the process. In the consultative process several bodies, including the Union of Swiss Private Banks (Vereinigung Schweizerischer Privatbanken) have criticised the rapid… – Continue reading
The Government of Hong Kong has said that it will introduce legislation into the Legislative Council by the end of this year to implement the minimum standards proposed by the OECD as part of its base erosion and profit shifting project. The BEPS framework, proposed by the OECD at the… – Continue reading
Whilst the peer-to-peer (P2P) economy has posed many challenges to traditional tax collections systems, the sector’s technological foundation also holds the keys to solving these problems, according to a new report by the International Monetary Fund (IMF). The IMF working paper, published on August 8, explores the implications for the… – Continue reading
Revenue Minister Judith Collins has welcomed a second round of negotiations between China and New Zealand tax officials aimed at updating the current double tax agreement signed between the two countries in 1986. “The aim is to agree a new treaty, adopting modern treaty language and concepts, including agreed measures… – Continue reading
HM Revenue & Customs’ new online Trusts Registration Service is now up and running, and beginning to get the attention of trust providers in a big way. Here, tax commentator Gerry Brown looks at the new regulations, and what they will mean for those in the trusts industry. The UK… – Continue reading
Amazon has refused to reveal how much it paid in total UK tax last year after it emerged it actually got a rebate of £1.3million. The online giant, which three years ago pledged to stop using a controversial tax avoidance scheme, admitted it had paid just £7million in corporation tax… – Continue reading
On August 3, 2017, the Irish Revenue published Revenue e-Brief No. 74/17, which contains guidance for taxpayers on complying with Ireland’s transfer pricing documentation requirements. The guidance notes that companies are legally required to maintain transfer pricing documentation. However, there is no requirement for documentation to be kept in a… – Continue reading
Contrary to calls from businesses from the regulation’s withdrawal, the Institute on Taxation and Economic Policy has called on the US Treasury to fully implement and strengthen its final Section 385 anti-earnings stripping debt-equity regulations, designed to reduce the benefits of corporate tax inversions. The final regulations, released in October… – Continue reading
The New Zealand Government has announced the signature of two Orders of Council that will implement amendments to its tax treaty arrangements with India and San Marino. The third protocol to the double tax agreement (DTA) with India updates the information exchange provisions and inserts an article on assistance in… – Continue reading
Brazil’s Inland Revenue has announced that assets worth BRL4.6bn (USD1.46bn) have been declared by Brazilian taxpayers through its amnesty for undeclared overseas holdings. It said that the income tax and fines linked to these assets totalled BRL1.6bn. The figures cover the period between March 3 and July 31, 2017, when… – Continue reading
Global consultancy EY among firms now offering advanced services that redefine how companies face new developments in tax, audit and compliance Rigid new global initiatives to increase transparency of business data are giving rise to more advanced professional tax services, which employ innovative tools that include cloud computing, financial technology… – Continue reading
The Philippines is set to sign a double taxation agreement (DTA) with Brunei while eyeing to start negotiations with three other Asean countries as part of its commitments under the regional integration framework. Internal Revenue Assistant Commissioner Marissa O. Cabreros told the Inquirer yesterday that the Philippines’ DTA with Brunei… – Continue reading
Israel’s $41 million tax demand from the Coca-Cola Co. on royalties from its Israeli licensee could mark the start of a wave of claims against U.S. and other multinationals with similar business operations in the country. That could lead to a conflict with U.S. and other authorities about which country… – Continue reading
The Swiss Federal Council has announced that an information exchange amendment to the double tax agreement with Belgium has entered into force. On August 7, the Council said the additional agreement to amend the DTA had entered into force on July 19. It contains an administrative assistance clause in accordance… – Continue reading
France is Airbnb’s second largest market and yet in 2016, the internet giant paid the country just €92,944 in taxes – equivalent to the amount paid by small and medium-sized enterprises (SMEs). Second only to the US as Airbnb’s biggest market and with Paris its top city for listings, during… – Continue reading
HAVANA – Tax evasion and smuggling have forced the government of Cuba to stop issuing new licenses for some businesses. The government of Cuba is ceasing the issuance of business licenses until the problems associated with self-employment have been perfected. Previously, Cubans who wanted to strike out and be self-employed… – Continue reading
In an effort to create a ‘level playing field’, Asian economies are committing to new standards of transparency At the risk of losing some foreign investors, Asian jurisdictions are stepping up efforts to combat corporate tax avoidance to meet new global transparency standards. More than a dozen Asia-Pacific jurisdictions have… – Continue reading
Stock analysts in South Korea played down the possible impact of the government’s decision Wednesday to impose taxes on foreign investors holding over 5 percent of a company, but warned of widening volatility prompted by foreign investors’ sell-offs over the past couple of weeks. Starting January 2018, a broader scope… – Continue reading
The notification follows hectic parleys between India and Switzerland for introduction of AEOI (Automatic Exchange of Information) under guidance of G20, OECD (Organisation for Economic Cooperation and Development) and other global organisations. Switzerland found India’s data security and confidentiality laws “adequate” for entering into an automatic exchange of information pact,… – Continue reading
An ATO ruling is being interpreted as allowing ‘bucket companies’ linked to trusts to be eligible for lower tax rate The federal government’s company-tax reforms are making the use of family trusts even more attractive as a tax minimising strategy, experts have warned. The Coalition’s company tax rate cut from… – Continue reading
The current plan for US tax reform would disproportionately benefit the wealthy, the International Monetary Fund has said, recommending more support for low-income taxpayers and higher indirect taxes. On the need for tax reform, the IMF said in its Article IV consultation for the United States that “the US personal… – Continue reading
Taxpayers have been reminded of the looming deadline for the Special Voluntary Disclosure Programme (SVDP) on 31 August 2017. SVDP is a window period for individuals and companies to regularise undisclosed or unauthorised foreign assets and associated income. It came into effect on 1 October 2016. Taxpayers are urged to… – Continue reading
Nigeria’s federal government on Wednesday signed an agreement with Singapore that would help companies operating in the two countries avoid double taxation in their different bases. The agreement clearly spells out taxing rights of the two countries in respect of different incomes derived from each country. It will specifically assist… – Continue reading
The International Revenue Service’s Criminal Investigation unit is readying two new programs focusing on data investigations and international tax enforcement. The data initiative will tie together the information uncovered by the IRS’s field offices around the country with headquarters in Washington, D.C. “We are standing up a nationally coordinated data… – Continue reading
APAs were recently implemented in the Croatian tax legislation. Our Transfer Pricing team briefly presents the main points of the Croatian legislation related to an APA. Transfer pricing legislation was introduced in Croatia by way of the Corporate Income Tax Act (CIT) on 1 January 2005. However, the Croatian tax… – Continue reading
The Act currently provides for income taxable as ‘capital gains’ to be computed after taking into account the full value of consideration received or accrued on transfer of a capital asset “A person doesn’t know how much he has to be thankful for until he has to pay taxes on… – Continue reading
Representatives of most multinational companies believe that there is a radical global change in both tax and tax control. Accordingly, the global tax model is undergoing a process of alignment with other principles, and the approach of the tax authorities during controls becomes stricter, a survey by Deloitte published in… – Continue reading
The Costa Rican government is very interested in forming part of the Organization for Economic Co-operation and Development (OECD http://www.oecd.org/ ). The OECD is formed by 35 nations to promote policies that will improve the economic and social well-being of people around the world. Last Thursday, economist Bert Brys, explained… – Continue reading
As part of the Irish Budgetary process, officials from the Finance Department have published a paper on the implications of Brexit for Ireland’s tax system. The paper was prepared for consideration by the Tax Strategy Group (TSG), an interdepartmental committee chaired by the Finance Department. The papers produced by the… – Continue reading
The UK will not engage in aggressive tax competition to attract business post-Brexit, Chancellor Philip Hammond has said. He added that the country’s economy will remain aligned with the European model after leaving the EU. “It is often said that London would consider launching into unfair competition in terms of… – Continue reading
