Category: Jurisdiction

EU Seeks Broader Crackdown On Corporate Tax Loopholes

BRUSSELS (Alliance News) – The EU stepped up the fight against corporate tax avoidance Thursday, unveiling proposals including an EU-wide blacklist of international tax havens, as part of a wider clampdown on firms using loopholes to reduce their tax bills. The EU’s executive estimates that member states are deprived of… – Continue reading

Canada: Taiwan – Canada Tax Arrangement Released

On January 15, 2016, Canada and Taiwan entered into an “Arrangement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income” (the “Arrangement“). The Arrangement will apply to amounts paid or taxation years beginning after January 1 of the year following the… – Continue reading

Start Corporate Tax Reform by Stopping Tax-Dodging Merger

If Republican leaders in Congress really want to fix our broken corporate tax system, as they’ve recently claimed, they should start by blocking what would be the biggest offshore tax dodge in American history. By stopping drug giant Pfizer from changing its legal address to Ireland — and thereby avoiding… – Continue reading

India, Armenia sign protocol to amend tax pact

India and Armenia on Wednesday signed a protocol to amend the existing Double Taxation Avoidance Convention between the two countries. “The Protocol amends the Article on Exchange of Information for tax purposes to bring it in line with the updated provisions in the OECD Model,” said a Finance Ministry release…. – Continue reading

State tax agency launches probe on 30 offshore tax evasion cases

SEJONG, Jan. 27 (Yonhap) — South Korea’s tax authorities said Wednesday that it has launched probes into 30 offshore tax evasion cases as part of its efforts to clamp down on tax dodging. The National Tax Service (NTS) said the investigation is targeting companies and individuals who have allegedly concealed… – Continue reading

Greater tax transparency for multi-nationals a step closer

The South African Revenue Service (Sars) has published additional record-keeping requirements for large multi-national companies which they will have to comply with in future. Many companies have already included some of the required information in their transfer pricing documentation and on their annual tax returns, but there seems to be… – Continue reading

The tax cut we have to have

Australia must not be blown off course from getting a company tax rate closer to 20 per cent. Corporate tax transparency figures released in December by the Australian Taxation Office should not slow momentum. For the first time, the ATO reported the tax affairs of companies with total incomes of… – Continue reading

31 nations sign agreement on exchange of country-by-country transfer pricing reports

In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting out the parameters for automatic exchange of country-by-country reports on large multinational corporations. The agreement — the Multilateral Competent Authority Agreement on… – Continue reading

Africa: EU Anti-Tax Avoidance Package Will Fail to End the Era of Tax Havens, Warns Oxfam

Despite EU intentions to crack down on tax avoidance, the European Commission’s Anti-Tax Avoidance Package does not do what it says on the tin, warns Oxfam, and developing countries will feel the EU’s failure most. The package comes a week after the international NGO revealed that just 62 people own… – Continue reading

Three critical ways an offshore bank can protect you

Let’s take a moment to compare the world today to before the Global Financial Crisis struck roughly eight years ago. In this short period of time, US federal government debt has DOUBLED. The Federal Reserve now holds $2.4 trillion of that debt, up from $479 billion. Interest rates, which were… – Continue reading

Google expected to reveal growth of offshore cash funds to $43bn

Tech company’s 2015 earnings will be announced next week as governments aim to crack down on Google’s controversial tax avoidance arrangements Google is poised to confirm next week that controversial tax structures in Ireland, the Netherlands and Bermuda have boosted its offshore cash mountain to more than $43bn (£30bn), figures… – Continue reading

Global fight against corporate tax avoidance takes off

NEW DELHI, JANUARY 26:Ministers and top tax officials from more than 30 countries including India will sign an international agreement on Wednesday to significantly advance the fight against corporate tax avoidance. This agreement – Multilateral Competent Authority Agreement (MCAA) – will be signed at the OECD in Paris, sources said…. – Continue reading

Central Bank Props up Offshore Yuan in Hong Kong

The People’s Bank of China supports the country’s currency and fends off short sellers in the world’s largest overseas yuan market (Beijing) – The offshore yuan market in Hong Kong has been shaken to the core by weeks of volatility that analysts blame on strong intervention by China’s central bank…. – Continue reading

US taxes and FATCA: ‘The time for hiding is over’

FATCA. Since July 2014, the five-letter acronym has instilled dread in the hearts of American expats all around the world. “The Foreign Account Tax Compliance Act (FATCA) requires banks to report information to the IRS regarding all financial accounts held by American clients,” Ines Zemelman, expat tax specialist and founder… – Continue reading

IRS Still Hunts Offshore Accounts As More Foreign Banks Sign Deals With U.S.

With the web of FATCA information exchanges, whistleblowers, cooperating witnesses, and other sources, the IRS and Justice Department have a wealth of information at their disposal. They have warned offshore account holders to disclose before it’s too late. Under FATCA, banks everywhere want to know if you are compliant with… – Continue reading

Submission for Customs Supplement Tax Administration Jamaica

Transfer pricing is the general term for the pricing of cross-border and domestic, intra-group transactions between connected parties. It refers to the setting of prices for transactions between connected persons involving the transfer of property or services. Companies can be connected in various ways, for example, two wholly owned subsidiaries… – Continue reading

Irish tax advantages may be banned under new EU rules

Ireland will be forced to ban many of the tax advantages it offers multinationals under proposals to be published by the European Commission tomorrow. This is the first step in an effort to have all EU countries introduce similar tax rules to prevent companies in the 28 member states avoiding… – Continue reading

Irish Facebook data centre ‘is not tax dodge’, says Mark Zuckerberg

Facebook founder Mark Zuckerberg has been defending his decision to build a new data centre in Ireland against claims the move is a tax dodge. The social media mogul announced the start of construction of the €200m facility at Clonee on the Meath-Dublin border on his own Facebook page, quickly… – Continue reading

Is it the duty of companies to minimise their tax bills? No, of course not

Here’s a transaction that did the rounds some years ago. If I wanted some foreign exchange in the future I could enter into a contract with a bank by which it would sell me some. Assume that, in order to get a bank to promise to give me $2bn in… – Continue reading

Europe cracks down on tax dodgers

Directive follows a series of high-profile tax cases involving Google, Apple and others. Rampant corporate tax dodging and sweetheart deals that cheat governments and skew markets, have prompted the European Commission to unveil a new directive Thursday. The proposed legislation follows a quick succession of tax rulings, settlements and investigations… – Continue reading

IRS Adds More Foreign Banks To Disclosure Blacklist

The US Internal Revenue Service (IRS) has added more banks to the swelling list of financial institutions involved in tax avoidance. Customers of these banks owning up to past financial indiscretions under the Offshore Voluntary Disclosure Program (OVDP) face penalties based on balances over the past eight years. Penalties for… – Continue reading

How Much Revenue The U.S. Is Losing Through Tax Inversions, And How Much Worse It May Get

Yesterday was quite a day for corporate tax geeks. We saw a corporate tax inversion that comes with a long, Baroque history; an estimate by Reed College economist Kim Clausing that inversions and other income-shifting techniques reduced Treasury revenues by as much as $111 billion in 2012; and a new… – Continue reading

BEPS project: most Indian MNCs see double taxation going up in short term

NEW DELHI, JANUARY 26:A majority of Indian multinationals see the implementation of base erosion and profit shifting (BEPS) project of the Organisation for Economic Cooperation and Development leading to increase in double taxation and compliance burden for them, an India-specific BEPS survey by Deloitte India has revealed. This is interesting… – Continue reading

Deloitte’s BEPS survey: Quite an eye opener

NEW DELHI, JAN 25: A majority of Indian multinationals see the implementation of OECD’s BEPS project leading to increase in double taxation and compliance burden for them, an India-specific BEPS survey by Deloitte India has revealed. This is interesting given that one of the objectives of OECD’s Action Plan on Base… – Continue reading

If you are looking for tax-free residency or citizenship, consider these countries

The UAE is one of the few places in the world where expats can live, earn and keep those well-earned dirhams, as income tax is still not in sight. This benefit has earned the country many rankings as one of the best immigration destinations in the world. Apart from good… – Continue reading

Intellectual property taxation in post BEPS era

On 5th October 2015, the OECD released its final reports setting out the action plan on Base Erosion and Profit Shifting (BEPS) project, thus concluding the two year project which started at the behest of G20 countries in 2013. The reports are aimed at suggesting the measures to reform the… – Continue reading

Anguilla Best Flat Tax Country for a Low Tax Lifestyle

Anguilla levies a 3% flat rate of personal income tax and is otherwise a tax haven with a stunning climate and amazing Carribean lifestyle Whilst there are various categories of flat tax, including marginal flat tax and Hall-Rabushka flat tax, in its simplest form flat tax is simply a rate… – Continue reading

Here We Go Again … IRS Destroys Another Hard Drive

The Internal Revenue Service appears to have violated a court order once again requiring the preservation of evidence needed by investigators looking into questionable practices at the agency. In a case sure to stir up memories of the Lois Lerner investigation, which saw IRS Commissioner John Koskinen dragged before Congress… – Continue reading

Belgian MNCs Gearing Up For BEPS

A vast majority of tax directors working for multinational corporations located in Belgium fear that the base erosion and profit shifting (BEPS) project will lead to higher administrative charges, a survey of over 800 tax directors across Europe has revealed. According to Deloitte’s European Tax Survey, 85 percent of the… – Continue reading

S. Korea, Macau to sign tax information exchange agreement

Macau’s Financial Services Bureau (DSF) has confirmed to Business Daily that the local authority is to sign a Tax Information Exchange Agreement (TIEA) with South Korea, which would add to the existing 15 jurisdictions that have already signed this agreement with the territory. According to the Bureau, its South Korean… – Continue reading

US firm Johnson Controls to cut tax bill with $16bn Tyco takeover

Car battery and heating equipment maker accused of ‘stranding honest taxpayers’ Johnson Controls, a US maker of car batteries and heating and ventilation equipment, has agreed to buy Irish-based peer Tyco International in a $16.5 billion (€15.23 billion) deal that will lower its tax bill. By redomiciling to Tyco’s headquarters… – Continue reading

‘Philippines should demand Thailand’s compliance with WTO cigarette ruling’

The Philippines should compel Thailand to abide by the World Trade Organization’s (WTO) ruling on the cigarette-tax case, after Bangkok slapped tax-evasion charges against Philip Morris Thailand (PMT), a legal expert said over the weekend. Lawyer Anthony Abad, who was part of the Philip Morris Philippines legal team that won… – Continue reading

Cyprus Yacht Registration – New Preferable VAT Treatment

A. INTRODUCTION On the 13th of March 2012, the Cyprus VAT Authority has launched a scheme making Cyprus one of the most attractive EU jurisdictions for yacht registration. According to this scheme, a Cyprus company can enter into a lease-sale agreement of a yacht with a third party, paying VAT… – Continue reading

Budget 2016: Budget may ease rules for offshore fund managers moving to India

In a move to woo offshore fund managers to locate in India, the Union Budget for 2016-17 is likely to relax conditions for them to avail of tax exemptions. Budget 2015 had announced some exemptions by amending the permanent establishment (PE) norms. The rules were changed to the extent that… – Continue reading

Anguilla Best Flat Tax Country for a Low Tax Lifestyle

Whilst there are various categories of flat tax, including marginal flat tax and Hall-Rabushka flat tax, in its simplest form flat tax is simply a rate of tax that remains consistent with a constant marginal rate. What this means is, as an income tax payer in a country with such… – Continue reading

Miners handed tax break

British Columbia’s premier has good news for the province’s mining industry, as the sector flounders amid ailing global commodity prices. Christy Clark announced her government will extend two tax-credit programs while delivering the keynote address at the annual conference into B.C. mineral exploration. The mining-exploration tax credit is a 20… – Continue reading

President Mukherjee calls for innovation to deal with rising tax disputes

The President highlighted transfer pricing, taxation of digital economy and international taxation as the frontier areas of taxation which require special skill sets to deal with disputes. Stressing on the need to improve India’s ranking in ease of doing business, President Pranab Mukherjee on Sunday said rising tax disputes and… – Continue reading

Isle of Man resists offshore ownership register beneficial ownership

The Isle of Man has refused London’s call to reveal the ownership of thousands of offshore companies, joining other UK Overseas Territories in resisting David Cameron’s transparency push. The Isle of Man told the Financial Times it is a “red line” issue, joining jurisdictions including Bermuda and the Channel Islands… – Continue reading

How to take your UK pension pot overseas-and not be hit by a big tax bill

Once the thrill of deciding to retire overseas has subsided, you normally start to think of all the things you need to do before you go. Picking the right removal firm, a lawyer to help you buy a new home are a couple, but the tax & financial implications of… – Continue reading

Can new guidelines get Nigerians into tax net?

The Federal Inland Revenue Service (FIRS) which is now saddled with the onerous task of getting alternative sources of revenue for the federal government has since adopted a stick and carrot approach to bringing tax payers into the tax net. Assistant Editor, Nduka Chiejina looks at the issues contained in… – Continue reading

GST debate: Scott Morrison backs need for option to raise tax as part of reforms

Treasurer says possibility of an increase needs to be on table if voters want relief from the effects of ‘bracket creep’ in income tax Scott Morrison has opened the political new year softening Australians up for an increase in the GST, arguing that reform needs to be on the table… – Continue reading

Gulf’s proposed 5% VAT may translate into more than 10% hit on net income: EY

The Gulf countries’ proposed 5% value added tax (VAT) may translate as more than a 10% hit on net income, unless tax efficiencies are improved, according to Ernst and Young (EY). “A 5% rate may not sound like a lot, but if it ends up as an additional cost on… – Continue reading

TAX DEPT INKS SEVEN NEW TRANSFER PRICING PACTS

The new advanced pricing agreements cover sectors like investment advisory, IT enabled services and manufacturing In the current fiscal year, which is the third year of APA programme, 30 agreements have been signed so far. As part of efforts to reduce tax disputes related to international transactions carried out by… – Continue reading

Google Strikes Deal With U.K. Tax Authority

DAVOS, Switzerland—Google said Friday that it has struck a deal with U.K. authorities that will settle a tax dispute and boost its corporate taxes in Britain, part of a broader effort by European governments to wring more out of big firms in the tech sector. As part of the settlement,… – Continue reading