Artisan goods marketplace Etsy Inc., which promised to be a beacon for transparency as a public company, recently implemented a strategy that shrouds its offshore tax-cutting arrangements in secrecy. Because of a change in how its Irish subsidiary is registered, Etsy no longer needs to publicly disclose basic financial information… – Continue reading
In a new update on the financial status of the UAE, the International Monetary Fund (IMF) has advised additional taxation among several options for the UAE government to further strengthen its revenue base in order to minimise dependence on the fluctuating global oil price, reports the Emirates 24/7. The UAE… – Continue reading
COLOMBIA: The Tax Authority (DIAN) clarified the withholding tax rate applicable to payments made abroad based on the provisions of Law 1739 of 2014 Article 28 of Law 1739 of 2014 set forth that revenue obtained by companies and foreign entities, that are not attributable to a branch or permanent… – Continue reading
The July 21 edition of the Brazilian Official Gazette contained provisional measure 685 (PM 685), which creates an obligation on taxpayers to formally report to tax authorities certain transactions that result in tax benefits. The requirement is supposedly in line with the OECD’s base erosion and profit shifting (BEPS) project… – Continue reading
Financial Adviser Jonathan Lachowitz of White Lighthouse Investment Management published the following editorial regarding FATCA on the The Wall Street Journal on Tuesday July 28th: Managing personal financial issues is challenging for most people. For American expats, the normal complexities and expenses are compounded by a panoply of post-financial crisis… – Continue reading
With different tax laws, exemptions, double taxation treaties and free trade zones for services exports affecting outsourcing operations across Latin America, gaining a solid understanding of the distinct tax obligations in each country is imperative. In a bid to attract investment, several Latin American countries have introduced double taxation treaties,… – Continue reading
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… – Continue reading
Consultation Solution no. 176, published by the Brazilian Federal Revenue Secretariat on July 8, 2015, made clear the tax administration’s position to require application of the PCI and Pecex methods on import and export transactions involving commodities, by determining the reliable sources of information to obtain the parameter prices for… – Continue reading
Law 20,780 – published in the Official Gazette on September 29 2014 – introduced the most complex and comprehensive tax reform in Chile for decades. Several provisions are already in force, while others will enter into force on January 1 2016. Most of the remaining provisions will be in full… – Continue reading
ABU DHABI: President His Highness Sheikh Khalifa Bin Zayed Al Nahyan has issued a number of federal decrees with respect to ratifying agreements between the UAE and a number of friendly countries and transferring, appointing and promoting a group of diplomatic corps members. The decrees have been published in the… – Continue reading
TOKYO — Disputes over cross-border double taxation can take a decade to resolve, putting a heavy burden on multinational corporations, but this would be shortened to around two years under new rules being crafted by the OECD and the Group of 20 major economies. Corporations can seek to resolve such… – Continue reading
THIRUVANANTHAPURAM, JULY 22: In its quest to collect taxes from multinational companies (MNCs), the government should not create a structure that makes their operations completely unviable, said Parthasarathi Shome, former Chairman, Tax Administrative Reforms Commission. “The basic thing to remember is that India is part and parcel of a much… – Continue reading
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… – Continue reading
SAO PAULO (AP) ” Three top officials of Brazil’s Camargo Correa construction company have become the first business executives to be convicted in the corruption-kickback scandal engulfing state-run oil company Petrobras. The Federal Prosecutor’s Office says Judge Sergio Moro on Monday sentenced the three on charges of money laundering, corruption… – Continue reading
The US can making giant vying to buy British industrial champion Rexam has sought to play down fears that the deal will stifle competition and could lead to higher prices. Earlier this year Ball Corporation swooped on Rexam in a £4.3billion takeover that will create the world’s largest beverage can… – Continue reading
The Government’s submission to the “Re:think” tax white paper process under way in Australia highlights the lack of mutual recognition of imputation credits as the most significant barrier to a seamless transtasman market and calls for visionary political leadership. Prime Minister John Key displays the very leadership he’s calling for,… – Continue reading
Shanghai is China’s biggest international financial centre in terms of inflows of foreign direct investment, while Beijing tops the table for outflows, The Banker reports. Shanghai is the Chinese financial centre that has attracted the largest inflows of foreign direct investment (FDI) in the country. A total of 21 projects… – Continue reading
Normative Ruling RFB No. 1,571/2015, which institutes the Electronic Financial Return, the so-called “e-Financeira”, was published on July 3rd, 2015. The e-Financeira is a statement, transmitted electronically to the Public Digital Bookkeeping System (“SPED”), compulsory for insurance companies and legal entities with activities relating to (i) structuring and selling private… – Continue reading
10/07/2015 – The OECD set out a clear path for Lithuania’s accession to the Organisation, reinforcing the OECD’s commitment to further extend its global membership. On 8 July 2015 the 34 OECD Members adopted the Roadmap for the Accession of Lithuania to the OECD Convention setting out the terms, conditions… – Continue reading
10/07/2015 – The OECD set out a clear path for Lithuania’s accession to the Organisation, reinforcing the OECD’s commitment to further extend its global membership. On 8 July 2015 the 34 OECD Members adopted the Roadmap for the Accession of Lithuania to the OECD Convention setting out the terms, conditions… – Continue reading
PARIS (Reuters) – The U.S, UK and Chinese economies are showing fresh signs of weakening while activity in the euro zone as a whole is firming up, the Organisation for Economic Co-operation and Development said on Wednesday. The OECD’s monthly leading indicator, a measure designed to flag turning points in… – Continue reading
Step aside, Doctors Without Borders. A new class of professionals is ignoring national frontiers to come to the aid of economically struggling nations. A team called Tax Inspectors Without Borders will begin helping developing countries deal with the flood of income to low-tax jurisdictions once it’s established next week by… – Continue reading
BARBADOS is targeting the South American country of Colombia for more international business. A delegation from the island will be spending the next week or so in that country as this island looks to broaden the more than $900 million in domestic contributions by the international Business and Financial Services… – Continue reading
The head of South American soccer, who skipped most of the region’s top competition, said he was forced to stay away from the Copa America to deal with the fallout from turmoil in the sport’s global governing body. Juan Angel Napout, in his first English-language interview since the FIFA scandal… – Continue reading
Congress just approved the intergovernmental agreement between Brazil and the United States for the automatic exchange of financial account information (Legislative Decree 146/2015, published on June 26). According to the terms of the agreement, Brazilian financial institutions (or Brazilian branches of foreign financial institutions) must identify financial accounts of United… – Continue reading
Brazil’s federal police have arrested another former Petrobras (PBR +1.8%) executive as part of an investigation into a broader corruption scandal surrounding the company. Police arrested Jorge Zelada, the company’s director of international operations during 2008-2012; he replaced Nestor Cerveró, who has been convicted of money laundering and sentenced to… – Continue reading
Brazilian President Dilma Roussef met with President Barack Obama at the White House this week. Below is the new multi-faceted partnership. The United States and Brazilian relationship has been unstable since the U.S. spying policy became known in 2013. Brazilian President Dilma Roussef canceled a 2013 visit to Washington, D.C…. – Continue reading
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…. – Continue reading
Ethiopia and Brazil concluded an agreement for the avoidance of double taxation on profits derived from international air and shipping transport on June 22, 2015 in Brasilia, according to Fana Broadcasting corporate. H.E Ambassador Sinknesh Ejigu, Special Envoy, Ambassador Extra ordinary and plenipotentiary of the Federal Democratic Republic of Ethiopian… – Continue reading
A recent report by Americans For Tax Fairness looks at how Walmart, the world’s largest corporation, uses a vast network of subsidiaries and branches in overseas tax havens with two purposes: 1.) to minimize taxes owed on its foreign operations. 2.) most importantly, to avoid United States taxes on those… – Continue reading
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…. – Continue reading
The European Commission has added Panama to its blacklist of countries designated as tax havens over a lack of support for anti-tax fraud and evasion efforts. The European Union’s executive Commission unveiled the list in the introduction to its action plan to fight tax fraud. The blacklist consists of 30… – Continue reading
Abstract Over the past 25 years, Cyprus has become the portal of choice for investment into and out of Russia and Central and Eastern Europe. The new Russian de-offshorization law, which took effect on 1 January 2015, will have significant implications for users of overseas structures. This article examines the… – Continue reading
Paris, Jun 18 (Prensa Latina) The Union Bank of Switzerland (UBS) had a network with intermediaries for Latin American countries who help launder money and evade taxes, it was learned here on Thursday. The revelation was made in this capital by former UBS Director Stephanie Gibaud, who met here with… – Continue reading
BERN, Switzerland – Reeling from an American federal investigation of bribery in soccer, FIFA was put under more pressure Wednesday as the scale of a separate Swiss investigation of suspected money laundering was revealed. Banks in Switzerland have flagged up 53 possible acts of money-laundering that could be linked to… – Continue reading
Wal-Mart Stores Inc. owns more than $76 billion of assets through a web of units in offshore tax havens around the world, though you wouldn’t know it from reading the giant retailer’s annual report. A new study has found Wal-Mart has at least 78 offshore subsidiaries and branches, more than… – Continue reading
He has distorted the facts about the nation’s current tax system. Chris Christie repeatedly has said that U.S. corporations are taxed twice on income earned abroad, claiming in one speech that IRS officials “don’t recognize the tax you paid to a foreign country.” That’s false. It’s true that the U.S…. – Continue reading
On May 24, Premier Li Keqiang and a delegation of Chinese senior officials arrived in Chile. During the visit, China and Chile signed a double taxation avoidance agreement (DTA), updated their Free Trade Agreement and agreed on setting up an RMB clearing center in Chile, reports China Briefing. China and… – Continue reading
The Barcelona forward is now due to stand trial on accusations he defrauded authorities Lionel Messi’s appeal against allegations of tax evasion has been thrown out by a Barcelona court and the Argentina star will now stand trial. The Blaugrana forward and his father and agent, Jorge Messi, are accused… – Continue reading
The Argentine Supreme Court ruling on Toepfer International, a commodity exporting firm, has finally been published, tw o months after the decision, providing lessons for BEPS action 10 (cross border commodity transactions). This case, AFIP v Alfred C Toepfer Internacional, belongs to the first group of three controversies, related to… – Continue reading
LONDON — Like other global institutions, HSBC, Europe’s largest bank, has been under severe pressure since the 2008 financial crisis to cut costs, meet stringent new regulatory demands and satisfy restless shareholders. To that end, the British bank said on Tuesday that it would shed as many as 50,000 of… – Continue reading
“The same methodology [in the HSBC case] appeared in the JP Morgan investigation, the most important given that there is a witness who has implicated himself, the corporation’s Latin American chief. Due to a conflict with his employer, he has made a complaint in Argentina naming himself as the organizer… – Continue reading
The country’s affluent investors have roughly doubled their offshore investment, curbing growth at Brazil’s wealth management firms. Scandal, recession and weak oil prices have caused economic vitality to seep out of Brazil. Now the money is following. Wealthy Brazilians are sending more of their assets overseas because of concerns about… – Continue reading
Afip has blamed Julio Grondona for authorising a $10-million payment that prosecutors have characterised as a bribe to vote for SA for World Cup 2010. Julio Grondona, a former Fifa vice-president and head of finance who ran Argentina’s soccer federation from 1979 until his death last year at 82, will… – Continue reading
The past decade or more has not been an easy road to manoeuvre for IFCs. The Bahamas like other IFCs has faced the combined challenges of international initiatives, increased competition, industry consolidation, changing client demographics, emerging market requirements; legacy market stagnation and of course the financial crisis just a few… – Continue reading
Argentina and Chile have signed a new double tax treaty to replace the treaty unilaterally terminated by Argentina in 2012. Ignacio Rodriguez and Andres Edelstein of PwC in Argentina outline the new structuring opportunities that are available for taxpayers. Argentina and Chile signed a new double tax treaty on May… – Continue reading
BUENOS AIRES, Argentina — Argentina tax officials say they’re seeking U.S. information about alleged corruption involving FIFA. Tax chief Ricardo Echegaray tells La Once Diez radio that his agency has asked the U.S. for “all the documentation that permits us to quantify” Argentina’s tax losses. And he’s not ruling out… – Continue reading
Santiago de Chile, May 25 (Prensa Latina) Chile and China will sign several cooperation and trade agreements today in a ceremony at La Moneda Palace, in the presence of Chilean President Michelle Bachelet and Chinese Prime Minister Li Keqian. Li, who arrived in this capital yesterday afternoon, held a meeting… – Continue reading
Argentine political analysis is increasingly introspective but sometimes it is worth looking at developments in the wider world in order to place things in perspective. The substantial rise in the tax burden over the past decade has led to plenty of local moaning and groaning at both national and provincial… – Continue reading
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… – Continue reading
