New legislative proposals aim to establish the BVI International Tax Authority (ITA) as a fully fledged independent government institution in the British Virgin Islands with its own legal personality, giving it autonomy over the performance of its functions. The ITA was initially established within the Ministry of Finance to administer… – Continue reading
What is a business expense deduction? A business expense deduction is a deduction allowed for ordinary and necessary expenses paid or incurred in connection with an individual’s trade, business or profession. IRC Section 62(a)(1) operates to assure that all trade or business expenses, deductible as delineated under specific IRC Sections,… – Continue reading
The New Zealand Parliament has passed a Bill which, following royal assent, will meaningfully increase disclosure obligations for NZ resident trustees of NZ foreign trusts. The Taxation (Business Tax, Exchange of Information, and Remedial Matters) Bill, was passed by Parliament on 14 February 2017. The Bill contains important provisions relating… – Continue reading
Federal agents raided three Caterpillar buildings near its Illinois headquarters on Thursday, company and law enforcement officials said, in an escalation of an inquiry into the heavy equipment manufacturer’s offshore tax practices. Caterpillar has been dogged by accusations that it slashed its domestic tax bill by shifting corporate profits from… – Continue reading
On 30 December 2016 the Commercial Court of Voronezh Oblast delivered a judgement in case No. А14-10190/2014 (the “Decision”) under the claim of Ilyushin Finance Co. Open Joint Stock Company (the “Company”). The case is an example of a broad interpretation of the list of documents confirming entitlement to a… – Continue reading
Nonresident Alien NRA tax withholding is applicable to U.S sourced income paid to foreign person and does not apply to payments made to U.S. persons. Foreign persons include nonresident alien individual, foreign partnerships, foreign corporations, foreign estates, and foreign trusts. The tax generally must be withheld from the payment made… – Continue reading
Muscat: A portal for entities subjected to taxation was launched on Wednesday by the ministry of finance. The ministry, represented by the Secretariat General for Taxation launched the portal www.taxoman.gov.om. The portal has legislations, taxation charts and agreements on avoidance of double taxation as well as developments in the field… – Continue reading
The Internal Revenue Service (IRS) has reminded certain non-US citizens, such as international students and scholars working or receiving scholarship funds, that they may have special requirements to file a US tax return. The IRS also reminded withholding agents, such as payroll professionals or universities, that accurately filed Forms 1042-S,… – Continue reading
The new Residence Nil Rate Band will allow people to pass on property to their descendants tax free. But some people need to take action now or risk missing out. In April, a major change to inheritance tax (IHT) law comes into effect with the launch of the Residence Nil… – Continue reading
The Government recently issued a resolution to ratify an agreement and a protocol on avoiding double taxation and preventing income tax evasion between Vietnam and the United States of America. The Ministry of Foreign Affairs was asked to complete necessary procedures in accordance with law. Meanwhile, the Ministry of Finance… – Continue reading
India has entered into new bilateral advance pricing agreements (APAs) with the United Kingdom and Japan, India’s Central Board of Direct Taxes (CBDT) announced on February 28. The two APAs were entered into over the last week. The CBDT also signed seven unilateral APAs. The APAs signed pertain to various… – Continue reading
THE ORGANISATION for Economic Cooperation and Development (OECD) initiated the base erosion and profit shifting (BEPS) project in 2013 to address perceived gaps in international tax rules causing a loss of revenues for governments of about US$100 billion to $240 billion (Bt3.5 trillion to Bt8.4 trillion) annually. The OECD’s BEPS… – Continue reading
[HONG KONG] More Chinese companies are looking to raise debt offshore after Beijing approved a new funding structure last month that makes it easier and cheaper to tap foreign lenders. China’s foreign exchange regulator in January let domestic companies bring home cash raised through offshore bonds secured by onshore guarantees,… – Continue reading
The importance of taxation to a nation’s economic wealth and development cannot be overemphasised. However, the achievement of this goal is often undermined by tax evasion and deliberate attempts by multinationals to shift profits from one jurisdiction to another, amongst others. Over the years, Nigeria has attempted to use taxation… – Continue reading
KARACHI: Directorate Intelligence and Investigation, (DI&I) Inland Revenue Karachi has detected around 453 fake registered persons, who were reportedly involved in Rs 5.6 billion tax evasion. According to sources, the DI&I-IR, Karachi under the supervision of its Director Hyder Ali Dharejo has kicked off a crackdown against tax mafia, who… – Continue reading
The Netherlands is slowly but surely steering away from facilitating the use of its corporate income tax system by companies that are set up merely to obtain tax benefits. These companies, which often do not actually carry out activities in the Netherlands, have contributed to the perception among policy makers… – Continue reading
The Canadian Government has said that it will review its tax ruling process and voluntary disclosures program as part of its response to recommendations made last year by a parliamentary committee. In October 2016, the Standing Committee on Finance released its report on the Canada Revenue Agency’s (CRA’s) efforts to… – Continue reading
On 22 December 2016 the Luxembourg Parliament passed article 56bis of the Luxembourg Income Tax Law (LITL). This provision gives taxpayers and tax authorities more guidance on how to apply the arm’s-length principle. The new article can be seen as a transposition of OECD BEPS reports (actions 8-9-10) released in… – Continue reading
New Oxfam report indicates Government measures to tackle tax avoidance are failing Multinationals are continuing to route billions of euro in profit to and through Ireland to avoid tax, according to a new report by Oxfam Ireland. The study, which suggests that Government measures aimed at tackling tax avoidance are… – Continue reading
Transfer pricing—the price charged for intercompany transactions between entities in different tax jurisdictions—can be used to shift funds within a multinational corporation (MNC), and serves as an effective means to manage a firm’s finances. Transfer pricing—the price charged for intercompany transactions between entities in different tax jurisdictions—can be used to… – Continue reading
U.S. multinational companies with more than $850 million in annual consolidated gross income now have draft instructions for filing IRS reports on their global tax and profits. The Internal Revenue Service added instructions to the draft Form 8975 and accompanying draft Schedule A it released in December 2016, companies that… – Continue reading
Global banking giant HSBC has disclosed being probed by tax authorities in India and several other countries, including against its Swiss and Dubai units, for allegedly abetting tax evasion of four Indians and their families. Besides, the bank has been approached by the regulatory and law enforcement agencies of various… – Continue reading
Muscat: Dodging taxes can lead to a jail term of up to three years and a maximum fine of OMR50,000 under tax law amendments published by the Ministry of Finance, as government begins its crack down on evaders. Out of the 300,000 companies registered by the Oman Chamber of Commerce… – Continue reading
Jane Moir says the authorities’ plan to require companies to reveal their controlling owners, in the wake of the Panama Papers scandal, does not go far enough Last year’s Panama Papers revelations put Hong Kong in the crosshairs of global anti-money laundering bodies. The dump of 11.5 million documents from… – Continue reading
The government is pulling out all the stops to end perceptions that New Zealand is a tax haven. With tougher disclosure rules set to come into force from July following the Panama Papers scandal, Inland Revenue (IRD) is promising to pass on the details about those with New Zealand foreign… – Continue reading
A bombshell hidden in the detail of the 2017 Budget review relates to the taxation of offshore trusts. It refers to the 2015 Budget review in which it was announced that measures would be introduced to the tax treatment of foreign companies held by interposed trusts. No specific countermeasures were… – Continue reading
Since President George W. Bush signed the Tax Relief and Health Care Act of 2006, the IRS has had a program that rewards Americans who inform the agency on tax dodgers. In its first decade, the program has helped the IRS recover $3.4 billion, and resulted in payouts of $465… – Continue reading
Brazil’s federal revenue service is continuing to adapt the country’s tax rules to OECD recommendations, as shown in recent guidance on how companies should seek help from the government on international tax questions. Normative Instruction 1689, issued Feb. 21, spells out the requirements for companies to request a consultation on… – Continue reading
President of Panama Juan Carlos Varela signed into law today the implementation of the Convention on Mutual Administrative Assistance in Tax Matters (MAC), which allows for sharing tax information multilaterally on request with the 107 jurisdictions that are part of the convention and provides a common legal basis for cooperation… – Continue reading
Finance Minister, Sri Mulyani, says that Indonesia continues to make preparations for implementing exchange of information in financial services and taxation sectors like alignment of the rules in the Law on the General Rules and Procedures of Taxation (KUP). “We will try various ways to incorporate various articles for KUP… – Continue reading
Enugu State government has sealed eight banks for failure to remit to its coffers about N1billion in withholding taxes said to have accrued since 2007. As early as 6.00 a.m. yesterday, enforcement officials of the State Board of Internal Revenue had stormed the premises of the affected banks and effected… – Continue reading
Apple, which was recently slapped with a $14 bn tax bill for its activities in Ireland has now filed a 14-point appeal against the ruling. The EC had filed a case accusing Ireland of giving “state aid” to Apple. The European Commission (EC) charged Apple on various grounds, including tax… – Continue reading
Tax agency calls mandatory fingerprinting ‘a powerful deterrent’ The Canada Revenue Agency’s new policy to fingerprint every person it charges with tax evasion could create travel problems at the U.S. border for some Canadians who haven’t had their day in court The Canada Revenue Agency has begun to record the… – Continue reading
The National Assembly of the Republic of Srpska (RS) adopted amendments to the Profit Tax Law on 28 December 2016. The main changes have become effective as of 1 January 2017 and will be briefly presented in this article. With the amendments, the Law clarifies the definition of “taxable person”… – Continue reading
The CRA has the power to make a transfer pricing adjustment to any amount for a taxation year under s. 247(2) in respect of a non-arm’s length cross-border transaction. A taxpayer is also liable to a 10% penalty under s. 247(3), which penalty is determined with reference to the taxpayer’s… – Continue reading
We are all familiar with the use of offshore intellectual property holding companies to capitalize on international tax gradients. These companies are designed to take advantage of strategic local tax rules to reduce tax burdens on royalty streams generated from licensing. Because of these favorable tax treatments, countries like Luxembourg… – Continue reading
Finance Minister Edward Scicluna presented amendments to rules against tax avoidance practices within the ECOFIN Council today, amounting to a compromise solution which was accepted. The solution provides rules regarding corporate hybrid mismatches and third countries. The Council agreed its position on rules aimed at closing down ‘hybrid mismatches’ with… – Continue reading
The Government is considering making companies include detail of who their supervisor is under the Anti-Money Laundering and Countering Financing of Terrorism Act (AML/CFT Act) as it strives to clean up the Financial Service Providers Register (FSPR). This suggestion is included in a consultation paper on a Financial Services Legislation… – Continue reading
Irish Finance Minister Michael Noonan has criticized the EU’s proposals for a common consolidated corporate tax base (CCCTB) and public country-by-country (CbC) reporting as “against the BEPS consensus.” In a speech to an event on corporation tax, Noonan said that the consensus over the OECD’s BEPS proposals must hold and… – Continue reading
The Australian Government has introduced legislation to extend the goods and services tax (GST) to low value imports from July 1, 2017. The legislation, introduced on February 16, requires overseas vendors, electronic distribution platforms, and goods forwarders with an Australian turnover of AUD75,000 (USD57,528) or more to register for, collect,… – Continue reading
MPs propose tweaks to the Union Revenue Bill. The solution to widespread tax evasion on land purchases is the creation of a fairer, more even taxation system. This was the prevailing opinion of MPs assembled in Nay Pyi Taw last week to deliberate the Union Revenue Bill prescribing three tax… – Continue reading
Uber is simply providing a taxi service and all its drivers must therefore register to pay goods and services tax, Australia’s Federal Court ruled. The Feb. 17 decision, which could yet be appealed to the full bench of the Federal Court, is “one step in the journey of the tax… – Continue reading
It seems that our tax system is quite the topic of conversation. It has even been called “not European”, “not social” and “a harmful tax practice”. Indeed. The idea that there is some moral code that can be called ‘European’ is as absurd a notion as any I have ever… – Continue reading
ABU DHABI, 16th February, 2017 (WAM)–The Ministry of Finance, MoF, has signed two final agreements on the avoidance of double taxation and the protection and promotion of investment with Burundi. The agreements came as part of the Ministry’s strategy to expand its international relations and to protect and promote Emirati… – Continue reading
ISLAMABAD-Pakistan and Hong Kong on Friday signed the pact on avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income. Pakistan’s Ambassador to China Masood Khalid signed the agreement while the Secretary for Financial Services and the Treasury, Professor KC Chan signed on behalf of… – Continue reading
Thousands of properties in Cyprus that have not been declared to the Tax Department have been discovered during a revaluation exercise by the Department of Lands and Surveys according to the island’s Interior Minister. The general assessment of immovable property valuations formed part of the Memorandum of Understanding between Cyprus… – Continue reading
If the referendum passes, all public servants and elected officials in Ecuador will be barred from holding wealth in offshore accounts. As Ecuador heads to the polls Sunday to elect a new president and National Assembly, deciding the fate of President Rafael Correa’s 10-year Citizens’ Revolution, the small South American… – Continue reading
Azerbaijan and Denmark have signed the convention on avoidance of double taxation and prevention of tax evasion on income taxes. The document was signed by Azerbaijani Minister of Taxes Fazil Mammadov and his Danish counterpart Karsten Lauritzen. Mr. Mammadov said that the document will contribute to the development of trade… – Continue reading
As part of the global transparency push, the G20 has committed to implement rules requiring the disclosure of beneficial ownership of legal entities (in addition to automatic exchange of financial account information and the BEPS related transparency measures). On 13 February 2017, Treasury released a consultation paper dealing with part… – Continue reading
In the public vote held on February 12, 2017, Swiss voters rejected the Corporate Tax Reform III Law Proposal (CTR III). Nevertheless, this issue is not yet resolved and remains on the table! A «CTR III 2.0» is expected in a timely manner. Information about the newest developments, but also… – Continue reading
