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...
Cyberspace may not be a tax haven for New Mexico shoppers much longer. As bipartisan support grows among state lawmakers for tax collections on internet sales to bring in more revenue and help level the playing field for local businesses, major internet companies are becoming increasingly willing to comply and...
Similar trade agreements have been used to facilitate apparent tax avoidance in the past A controversial new trade deal between the EU and the United States could make it more difficult to fight tax avoidance, a new report has warned. TTIP, the Transatlantic Trade and Investment Partnership, is expected to...
The Nigerian Transfer Pricing (TP) Regulations officially known as Income Tax (Transfer Pricing) Regulations No 1, 2012 regulates transactions between connected taxable persons (controlled transactions). The regulation seeks to ensure that transactions among connected taxable persons are carried on at arm’s length. Applying the arm’s length principle to controlled transactions...
Firms over a certain threshold group turnover may be required to give detailed info of financials. MULTINATIONAL companies in India over a certain threshold group turnover may be required to make comprehensive disclosures relating to their revenues, taxes paid, staff strength and assets in different countries where they operate from...
The New Zealand foreign trust regime – its use in international wealth planning The New Zealand “foreign trust” regime came into being over 25 years ago. It arose from a domestic initiative to make the use of offshore trusts for tax minimisation more difficult for New Zealand residents, by imposing...
Headline: G20 among biggest losers in large-scale tax abuse – but poor countries relatively hardest hit G20 countries are the biggest losers when US multinationals avoid paying taxes where they do business. This is the main finding of a new report on the global tax system, ‘Still Broken,’ released by...
The Bahamas will likely suffer a 25 per cent contraction in the number of financial services industry players, a senior international private banking executive said yesterday, as institutions merge to acquire scale and maintain profitability. Ricard Tubau, Andbank’s global chief executiv, said that not only is the financial services industry...
The IRS has announced that as of September 30, 2015 it will implement the automatic exchange of tax information as set forth in the Foreign Account Tax Compliance Act, (FATCA). The IRS Commissioner in announcing the implementation of the automatic exchange of information stated: “This information exchange is part of...
On September 1, Venezuelan President Nicolas Maduro arrived to Beijing in an effort to strengthen economic ties between Venezuela and China. In his second visit this year, the Venezuelan President signed a number of deals that will strengthen cooperation in new areas beyond the current focus on the oil industry....
Mexico’s government withheld hundreds of millions of dollars in tax refunds owed to Procter & Gamble, Unilever, and Colgate combined as it sought to coax them and other multinationals to pay more income tax locally, according to people close to the talks. After luring foreign companies with corporate tax breaks...
Following the trends of countries such as Spain and Mexico, among others, Brazil has begun to amend and introduce new legislation to reflect BEPS recommendations in its internal legislation. Provisional Measure (PM) 685 was issued this month, determining a disclosure procedure as a result of BEPS Action Plan 12 (Mandatory...
Mexico on July 17, 2015, published the text of its agreement with Turkey to avoid double taxation between the two countries and prevent tax evasion. The double tax agreement (DTA) was signed in 2013 and is valid from July 23, 2015. Under the agreement, dividends will be subject to a...
1. Permanent Establishment 1.1. Subjects and activities that generate a PE Article 64 of the LISH provides that a PE is created whenever ever a resident abroad for tax purposes carries on with activities under the LH in Mexican territory or the exclusive economic zone over which Mexico has jurisdiction....
FATCA – Which Countries Are In And Out The controversial US Foreign Account Tax Compliance Act (FATCA) law is set to start from July 1, 2014, so with less than 21 days to go, here’s a look at which countries are in and who is outside of the tax network....
To staff their board of directors with the best and most diverse talent, multinational companies commonly elect boards with international representation. It is also common for companies to convene periodic board meetings outside the United States. This may be done, for example, to provide board members with an opportunity to...
Officials from Mexico’s Tax Administration Service (SAT) met with Costa Rican tax administration officials from April 20 to 22, 2015, to share their experiences in the area of tax information exchange. The Costa Rican authorities learned from Mexico’s experience in implementing the US Foreign Account Tax Compliance Act (FATCA) and...
Taxes have risen by around one per cent on the average worker’s wage in Organisation for Economic Co-operation and Development (OECD) countries since 2014, although the majority of governments have not increased income tax rates, the OECD has said. In its Taxing Wages 2015 report, the OECD looks at the...
Luxembourg’s Direct Tax Administration has published a circular on February 12 clarifying issues relating to residency certificates for Luxembourg funds. These are applicable to both UCITS and non-UCITS funds regulated by Luxembourg’s investment fund legislation of December 17, 2010, which transposed the UCITS IV Directive, as well as Specialised Investment...
Feb 12 (Reuters) – Brazilian Trade Minister Armando Monteiro said on Thursday he does not see much chance of agreeing on a tax treaty with the United States in the short term. In an interview during a visit to Washington, his first overseas trip as minister, Monteiro said double taxation,...
Thomas Piketty’s “Capital in the 21st Century” was a 2014 must-read for anyone interested in economics. But while his claim that income and wealth inequality has risen over recent decades to highs last seen before the start of the First World War was widely accepted, his policy prescriptions were not....
Gains derived from the sale of Mexican public debt instruments listed abroad between two foreign tax residents will soon be exempt from Mexican tax. Currently, for Mexican income tax purposes, any gains derived from the transfer of publicly-traded bonds, securities and other credit instruments are treated as interest. If the...
Last year, $20 trillion disappeared into secret off-shore tax havens across the world — an amount that can save 3.6 million lives annually. A study conducted by the UK-based NGO, ONE, has found that corruption, tax evasion and corporate malpractices is leading to monetary losses of the scale that could...
NEW DELHI: G-20, a group of developed and developing nations, is likely to press for adoption of “rapid timelines” by different countries for automatic sharing of information with a view to curb tax evasion. The issue of automatic sharing of tax information would figure prominently during the meeting of G-20...
Feb 24 (Reuters) – U.S. prosecutors are widening their probe of how Swiss banks helped wealthy Americans avoid taxes to look at insurers as well, the Wall Street Journal reported on Monday, citing unnamed sources. Insurers in Switzerland have been preparing for months for U.S. officials to investigate products known as insurance...
Barbados’ financial-services sector is rated as the second-largest source of foreign exchange earnings, behind tourism, for which new markets are being sought outside of Canada. On Thursday, central bank governor, Dr DeLisle Worrell, said the country has been losing business in its International Business and Financial Services Sector (IBFS), which...
Seven companies, chiefly American-based, including Fortune 500 companies in the automotive, mining and retail industries are now under investigation for alleged tax evasion in Mexico. Oscar Molina, who lead audits of big companies at Mexico\’s tax collection agency SAT, says the firms cannot be identified for legal reasons. All seven...
