Category: South America

Resolving cross border tax disputes through Australia’s investment treaties

1. Global focus on transfer pricing There has been a recent surge in regulatory attention around the world towards pricing arrangements within multinational corporate groups. Regulators are concerned that these pricing arrangements may be used as a means of profit shifting and therefore tax avoidance. The price at which an… – Continue reading

Chairman Royce, Rep. Pallone welcome US-Amenia Trade & Investment Framework Agreement

The advantages of off-shore investments Two of the top reasons that South African investors are given to encourage offshore investments are that going offshore diversifies your portfolio and that it gives you access to sectors you could never find on the resource-heavy JSE. “While those are not reasons to be… – Continue reading

Unnerved by tax demands on capital gains, foreign funds flee for safety

The minimum alternate tax row has damaged the credibility of government promises to enforce an investor-friendly tax regime and made the Indian stock market Asia’s worst performer this year New Delhi/Mumbai: Castleton Investment Ltd, a unit of GlaxoSmithKline Plc (GSK), in 2012 asked an arm of the Indian finance ministry… – Continue reading

Russia’s Offshore Money Looks Set to Stay There

Russia is set to enact an amnesty on offshore assets next month, but disagreement and lack of clarity over the terms of the pardon threaten not only to render the measure impotent, but undermine the government’s very drive to lure overseas money back home. The capital amnesty, part of a… – Continue reading

Uruguay – South America’s Best Kept Secret

“Uruguay has now definitely earned its long-time nickname — the Switzerland of Latin America.” That’s what I wrote several months ago during my first visit to this small, south Atlantic costal country wedged between Brazil and Argentina. For the last week, I have been enjoying my second visit to Uruguay,… – Continue reading

Bancolombia Adds AxiomSL FATCA Solution to Reporting Platform

Ease of integration and flexibility of strategic reporting platform drive Colombia’s largest bank to expand partnership Tax reporting solution now deployed in five countries as a result of agreement AxiomSL, a leading provider of regulatory reporting and risk management solutions to the financial services industry, announced today that Bancolombia, Colombia’s… – Continue reading

Falciani: all banks help evade taxes

All the world’s major banks have connections between each other and work together in a secret network to help people evade taxes, whistleblower and former HSBC IT engineer Hervé Falciani said yesterday, warning that illegal offshore transactions can’t be carried out through one single bank but only with the help… – Continue reading

Mexico Supports Costa Rica On Tax Info Exchange

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… – Continue reading

Those Gruelling U.S. Tax Rates: A Global Perspective

The Tax Foundation released its inaugural “International Tax Competitiveness Index” (ITCI) on September 15th, 2014. The United States was ranked an abysmal 32nd out of the 34 OECD member countries for the year 2014. (See accompanying Table 1.) The European welfare states such as Norway, Sweden and Denmark, with their… – Continue reading

Countries and Companies Square Off Over International Tax

An OECD initiative on tax evasion is causing ripples around the world While a host of topics — from the necessity and the proposed scope of corporate tax reform, to corporate rate reduction and corporate inversions — are of major concern to those engaged in international tax, the overriding issue… – Continue reading

How the Isle of Man aims to become the bitcoin capital of the world

Ireland might learn as the Isle of Man positions itself as the new bitcoin capital of the world While bitcoin is attractive because of its inherent decentralised nature, it has struggled to be perceived as a legitimate currency, given the lack of accountability and total absence of someone or something… – Continue reading

Panama, reputed to be region’s top money laundering hub, toughens up legislation

PANAMA CITY (AP) — – Panama took a major step in an effort to clean up its reputation as Latin America’s premier hub for money laundering. The nation’s legislature late Wednesday unanimously approved a proposed law that will toughen supervision of more than a dozen non-financial sectors where illicit proceeds… – Continue reading

Panama acts to clean up reputation for money laundering

Panama took a major step in an effort to clean up its reputation as Latin America’s premier hub for money laundering, reports the AP. The nation’s legislature late Wednesday unanimously approved a proposed law that will toughen supervision of more than a dozen non-financial sectors where illicit proceeds from the… – Continue reading

CONFERENCE PREVIEW: Succession, Cross-Border Tax And Trusts Under Spotlight In Geneva

Moves to create a supposed level playing field for succession issues in Europe, along with more established themes around automatic exchange of information and US extra-territorial tax powers make their appearance in a major Geneva-based conference later in April. Figures from the world of wealth management will gather at the… – Continue reading

Corporate Investigations & White Collar Defense – April 2015

In This Issue: • It’s Stifling in Here! SEC Rules That Companies Can’t Put Restrictive Language in Confidentiality Agreements That Could Potentially Stifle Whistleblowers • An Opinion on Opinions: U.S. Supreme Court Decision in Omnicare • Is OFAC the New Black? Schlumberger and PayPal—The Rise in the Enforcement of Sanctions… – Continue reading

Cayman: Money laundering reports spike

The number of suspicious activity reports of potential money laundering have increased by 42 per cent to 558 cases over 2012/2013, reports the Cayman Compass. The Financial Reporting Authority, the national agency which receives the reports of suspected money laundering and other financial crime, believes the record number was prompted… – Continue reading

'Banks moved their evasion experts to LatAm'

UBS whistleblower Stéphanie Gibaud talks to the Herald before travelling to Argentina With tax evasion allegations against HSBC under the spotlight in Congress, a whistleblower from another banking giant famous for its secrecy, Switzerland’s UBS, says she is coming to the country to testify soon, and warns that emerging economies… – Continue reading

China: Asia Tax Bulletin – Spring 2015

CHINA Tax Free Reorganisations • With circulars 109 and 116 jointly issued in December 2014 by the Ministry of Finance and the State Administration of Taxation, the Chinese authorities have relaxed the conditions for internal reorganisations. • Circular 109 deals with internal reorganisations. Provided the pertinent requirements are met, the… – Continue reading

America’s Most-Wanted Swiss Bankers Aren’t Hard to Find

At least 21 financial advisers in Switzerland charged with aiding American tax dodgers are at large With its tan marble floors and leather-clad reception desk, the staid Zurich offices of the Julius Baer Group, one of Switzerland’s largest private banks, are an unlikely place to find an alleged fugitive from… – Continue reading

OECD: employment tax burdens rise despite static income tax rates

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… – Continue reading

Individual Tax Burdens Continued To Rise In 2014

Taxes on wages have risen by about one percent for the average worker in OECD countries between 2010 and 2014, even though the majority of governments did not increase statutory income tax rates, according to the Organisation for Economic Cooperation and Development’s (OECD’s) Taxing Wages 2015 report. According to the… – Continue reading

Worldwide: Protecting Yourself From International Tax Investigations

Who Will Be Next? How To Respond To A Tax Investigation The international political community continues to make the most threatening noises about those who they believe do not pay enough tax. Long gone it seems are the days where it was accepted that a person could properly organise his… – Continue reading

US and the Caribbean: brief summits not enough

US President Barack Obama and Jamaica Prime Minister Portia Simpson-Miller have pronounced his visit to Jamaica and their bilateral discussions to be a success. What is certain is that media coverage of Obama’s visit and his late night call at the Bob Marley museum where the President declared “I still… – Continue reading

What would joining the OECD mean for Costa Rica?

The Organisation for Economic Co-operation and Development formally invited Costa Rica to apply as a candidate for membership this week, five years after it began its push to join the exclusive club of developed economies. The news of Costa Rica taking one more step closer to joining the league of… – Continue reading

France: French Tax Update – Early 2015 Noteworthy Case Law And Tax Transparency Package

The present French Tax Update will focus on (i) several noteworthy French and European Union court decisions issued in the last months of 2014 and in the first months of 2015, and (ii) the recent presentation by the European Commission of a package of tax transparency measures. VALIDITY OF TAX… – Continue reading

Art: A market laid bare

An arrest over allegations of price fixing has increased calls for tighter regulation of the booming sector On a late February morning, Yves Bouvier arrived at the Monaco home of one of his best clients. He expected Dmitry Rybolovlev, the Russian billionaire owner of AS Monaco football club, to pay… – Continue reading

The ultimate pension freedom: Retire in Portugal and reduce your tax

New freedoms mean you can move your pension abroad. We show you where you’ll pay the least tax It is the ultimate dream for many people – to work hard, build up a nest egg and retire abroad to a climate with year-round sunshine. Now there is an added financial… – Continue reading

No hiding place for expat tax evaders

New rules mean that almost 100 governments around the world will exchange information about bank accounts Expat tax dodgers are running out of places to hide, as information about their bank accounts and assets will soon be exchanged between 93 governments globally. At present, if tax authorities suspect people of… – Continue reading

$32 Trillion Stashed in Offshore Bank Accounts – Asset Protection Planners Examine the Facts

More and more Americans are opening offshore bank accounts. This article provides statistical details about why this is so, that offshore banking can be safe and legal and which banking jurisdictions are safest. Apr. 3, 2015 / PRZen / VALENCIA, Calif. — Offshore banking is growing in leaps and bounds… – Continue reading

Global Tax Transparency Goes Live in 2016

Cross border tax fraud and tax evasion by High Net Wealth Individuals (HNWI) are serious problems for many jurisdictions. For many years exchange of information between countries has been solely upon request. In practise this procedure is not efficiently working as it requires foreseeable relevance, thus ‘fishing’ for information is… – Continue reading

BSI first bank to face US non-prosecution deal fine

After 2008, BSI has more than 3,000 US accounts on its books The Lugano-based BSI bank has been fined $211 million (CHF203 million) by the United States for aiding and abetting tax cheats. It is the first Swiss-based bank to complete the non-prosecution programme set up in 2013 to clear… – Continue reading

Dividend imputation clears an early tax review hurdle

Government questions dividend imputation and company tax rate Australian investors appear to have dodged a bullet, with the government’s first paper on tax reform discussing the dividend imputation system but falling short of attacking it outright as an idea that has outlived its usefulness. David Murray’s inquiry into the Australian… – Continue reading

Luxembourg: Luxembourg’s Direct Tax Administration Publishes Circular On Residency Certificates For Funds

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… – Continue reading

Swiss Private Bank BSI SA Admits Aiding U.S. Tax Cheats, Will Pay $211 Million

In a deal with U.S. prosecutors, Swiss private bank BSI SA agreed today to pay a $211 million penalty and hand over leads on more than 3,000 accounts with U.S. ties, as well as the actual names of an undisclosed, but presumably much smaller group of U.S. account owners. The… – Continue reading

UPDATE 1-Leaked Pacific trade pact draft shows investment carve-outs sought

(Reuters) – Australia’s medicine subsidies, Canadian films and culture, and capital controls in Chile would be carved out from investment protection rules being negotiated in a Pacific trade pact, according to a draft text released by Wikileaks on Wednesday. An investment chapter, dated Jan. 20, from the 12-nation Trans-Pacific Partnership… – Continue reading

Venezuela to probe possible corruption linked to offshore bank holdings

CARACAS, VENEZUELA – Venezuela is launching a probe into large offshore bank deposits amid a spate of reports that at least $2 billion was siphoned off by corrupt, top-level officials at state-run oil company PDVSA. Chief prosecutor Luisa Ortega Diaz’s announcement Tuesday was the socialist government’s first response to the… – Continue reading

Names of Argentines with HSBC offshore accounts in Switzerland to be made public

Argentina will move forward with its investigation of the HSBC offshore accounts in Switzerland, and will make public the names of those Argentine citizens and organizations that held money overseas in the financial entity, allegedly with the purpose of eluding local taxes. Swiss and French officials are also looking into… – Continue reading

Does The U.N. Matter In The Tax World?

The OECD’s base erosion and profit-shifting project has dominated the international tax scene for over a year. Ever since the G-20 tasked the organization with finding solutions to the perceived problem of multinationals paying low effective tax rates, the international tax community has talked about little else. The OECD hoped… – Continue reading