Category: Offshore

Malta Pushes to Ease EU Cross-Border Interest, Withholding Tax

European Union presidency holder Malta has launched a new attempt to salvage pending EU legislation designed to eliminate withholding taxes for cross-border interest and royalty payments in the EU single market. One of the key hurdles the Interest and Royalties Directive has faced in the Council of Economic and Financial… – Continue reading

Federal Budget 2017: Foreign home buyers hit by vacancy tax and restrictions

Foreign ownership of new developments will be restricted, there will be steeper charges applied to purchases, less favourable tax treatment and charges on those with empty properties, in a raft of measures in the federal budget aimed at taking the sting out of the housing market. One measure to be… – Continue reading

UK: The UK Company: A New Alternative For International Investors?

This article is the first of a series of articles that looks at tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors. An essential feature of… – Continue reading

FBR initiates scrutiny of offshore transactions

KARACHI: The Federal Board of Revenue (FBR) has initiated audit of all those taxpayers who have made offshore transactions during the last six years, sources said on Tuesday. “All corporate and individual taxpayers, who have made offshore investments, have been selected for audit to check the tax concealment,” an official… – Continue reading

Lawyers as “Gate Keepers” – The European Parliament Examines the Roles of Attorneys in Tax Evasion and Laundering Schemes

Starting on April 27, and finishing on May 2, the European Parliament (EP)’s Committee of Inquiry into Money Laundering, Tax Avoidance and Tax Evasion (PANA) is holding two meetings to present several related studies which address the impact of, and the fight against, tax evasion and money laundering, particularly in… – Continue reading

Deal that sends Canadian bank records to IRS is ‘illegal,’ lawyer tells U.S. committee

Witnesses call for repeal of Foreign Account Tax Compliance Act An agreement that has resulted in hundreds of thousands of Canadian banking records being sent to the U.S. Internal Revenue Service could violate the U.S. constitution, a congressional subcommittee heard Wednesday. Testifying before a subcommittee of the House Committee on… – Continue reading

Trump Plans to Seek 10% Tax on Offshore Earnings, Official Says

President said to call for taxing pass-throughs at 15% Pass-throughs are currently taxed at higher individual rates President Donald Trump plans to propose a 10 percent tax on more than $2.6 trillion in earnings that U.S. companies have stockpiled offshore, said a White House official familiar with the president’s tax… – Continue reading

Trust Companies, Banks Should Be Main Haven Targets: EU Report

New measures targeting trust companies and banks in their role of helping to create offshore companies, such as the more than 200,000 exposed in the year-old Panama Papers, should be the priority for EU legislators in their efforts to crack down on the use of tax haven intermediaries, according to… – Continue reading

India Initiates $5 Billion Tax Penalty Against Cairn Energy

Indian tax authorities have initiated a $4.75 billion penalty charge against Cairn Energy for failing to pay a capital gains tax demand of $1.58 billion on a 2006 transaction. Under Section 271(1)(c) of the Income Tax Act, Indian tax authorities can levy a maximum 200 percent penalty against transactions after… – Continue reading

Sharif’s finances in foreign tax havens not accessible to JIT

ISLAMABAD: Even before the formation of a seven-member joint investigation team (JIT) on the money trail of assets owned by Prime Minister Nawaz Sharif and his family, in accordance with the decision of the Supreme Court, new questions have arisen over its supposed modus operandi. The JIT team will not… – Continue reading

UAE inks multilateral tax co-operation convention

The United Arab Emirates (UAE) has signed an international tax agreement – Multilateral Convention on Mutual Administrative Assistance in Tax Matters(MAC), which is now seen as the ‘gold standard’ for co-operation in tax administration. With this move, UAE has become the 109th jurisdiction to join the most powerful multilateral treaty… – Continue reading

US tax cuts could lead to financial instability: IMF

Report warns that Trump’s proposed corporate tax reforms could spark risk-taking WASHINGTON • The International Monetary Fund (IMF) warned yesterday that United States President Donald Trump’s proposed tax cuts and reduction of financial regulations could spark a new round of financial risk-taking of the type that preceded the last crisis… – Continue reading

Tax amnesty plan premature, says Citi

MANILA, Philippines – Instead, the government should pursue the enactment of the proposed Comprehensive Tax Reform Program (CTRP) before pursuing a tax amnesty program, Citi economist Jun Trinidad said. He said fiscal priority remains the passage of the first component of the tax reform measure that includes income tax cut… – Continue reading

Sao Paulo Property Secrecy Exposes Continuing Role of UK Tax Havens

A new report from Transparency International has revealed that more than US$2.7 billion worth of property in Sao Paulo, Brazil’s biggest city, is hidden behind shell companies, many of which have close links to the United Kingdom, which has many offshore tax havens in its overseas dependencies. Using newly released… – Continue reading

Sao Paulo Property Secrecy Exposes Continuing Role of UK Tax Havens

A new report from Transparency International has revealed that more than US$2.7 billion worth of property in Sao Paulo, Brazil’s biggest city, is hidden behind shell companies, many of which have close links to the United Kingdom, which has many offshore tax havens in its overseas dependencies. Using newly released… – Continue reading

How to Shut Down Offshore Corporate Tax Avoidance, Full Stop

A new bill introduced this week by Rep. Mark Pocan (D-WI), the Tax Fairness and Transparency Act, would rip out the offshore corporate tax avoidance system by its roots. This legislation combines into a single, comprehensive bill elements of three pieces of legislation that Rep. Pocan has proposed in previous… – Continue reading

Corporate giants hit with $2.2b Australia tax bill

Companies including Apple, Google and BHP Billiton were grilled at parliamentary hearings on their tax structures in 2015 SYDNEY: Australia on Thursday said it had slapped seven large multinationals with a multi-billion-dollar tax bill as it pursued global firms shifting profits offshore to minimise liabilities. The companies hit with the… – Continue reading

UK-UAE treaty means UK pension free of income tax

Denton warns people of the long-term implications of stripping down their pension A new double tax treaty (DTA) between the UK and the UAE, which becomes effective April 6, will allow UAE residents to access their UK pension free of UK income tax, according to an expert. David Denton, Head… – Continue reading

Art of the deal: Trump, Dems look for common ground to close tax loopholes

Venture capitalists, investors left unfazed Both President Trump and Capitol Hill Democrats head into negotiations over tax reform vowing to put the squeeze on hedge fund managers by closing the carried interest tax loophole — a point of agreement that held out promise for becoming a foundation for a once-in-a-generation… – Continue reading

€8 billion annual risk of money laundering

Malta’s threat places it 20th out of 27 states, Pana Committee told Malta faces an annual €8 billion money laundering risk, according to figures quoted in a study presented to the European Parliament’s Pana committee. The committee, which visited Malta in February for a fact-finding mission on the island’s involvement… – Continue reading

House bills to fund infrastructure reward big multinationals

U.S. Rep. John Delaney has introduced two infrastructure funding bills — H.R. 1669 and H.R. 1670 — that good government groups say would further incentivize corporate tax dodging, reward the biggest multinational corporations for stashing their profits in offshore tax havens and replace one system riddled with tax loopholes with… – Continue reading

Ottawa to spend $500M on pursuit of tax cheats, budget reveals

Money will be used to hire more auditors and develop computer systems to “target high-risk international tax” evasion. Tax auditors and fraud investigators have been given more than half a billion dollars to pursue tax cheats, and the government expects them to collect five times that much in additional taxes…. – Continue reading

Facebook, Google paying more local tax in Australia after tax avoidance crackdown: officials

Multinational companies are now paying tax based on their Australian profits instead of shifting income to low-tax countries, officials say. CANBERRA, AUSTRALIA—Facebook, Google and other multinational companies are now paying tax in Australia based on their Australian profits instead of shifting income to low-tax countries since the government cracked down… – Continue reading

Next off the block – AEOI

You might have thought you have enough on your plate getting to grips with anti-money laundering rules closely followed by FATCA – but it’s not over yet! Next off the block is the Automatic Exchange of Financial Account Information in Tax Matters (AEOI). The AEOI, which we first provided an… – Continue reading

New ATO draft ruling on company tax residence

Last November, the High Court’s decisions in Bywater Investments and Hua Wang Bank (Bywater) confirmed that a number of companies incorporated overseas were nevertheless Australian resident for tax because they “carried on business” and had their “central management and control” (CM&C) in Australia. The facts were extreme: the primary judge… – Continue reading

Combatting Foreign Tax Evasion With New Filing Requirements for Foreign-Owned Disregarded Entities: Tax Update, Volume 2017, Issue 2

The new regulations expand the filing requirements for Form 5472 to include disregarded entities with foreign owners when there are certain reportable transactions. If a non-U.S. person (individual or corporation) owns 100 percent of the stock of a U.S. corporate subsidiary, the subsidiary needs to obtain an employer identification number… – Continue reading

Parliament makes publication of offshore transfer totals mandatory

The Portuguese parliament voted unanimously to pass a draft law by the Left Bloc that makes it mandatory to publish the annual total and destinations of transfers to offshore accounts, regardless of any ministerial decisions. Tax office statistics with the amounts transferred to offshore accounts were not published between 2011… – Continue reading

Bank transparency, data matching for tax purposes

The government’s plan to issue a regulation in lieu of law (Perppu) concerning banking transparency, which includes allowing the tax authority to access taxpayers’ bank data, has sparked hot public debate. The proponents argue that such an initiative is critical, outlining the fact that the government has to comply with… – Continue reading

HMRC guidance clarifies fit and proper persons test

It says anyone who has been involved in designing or overseeing tax-avoidance schemes using charities would be unlikely to pass the test People who have been involved in designing or overseeing schemes to avoid tax using charities are likely to be prevented from taking up senior roles in charities, according… – Continue reading

Pakistan, Switzerland to sign agreement for bank account information exchange: Dar

Finance Minister Ishaq Dar on Wednesday told the National Assembly that Pakistan will sign an agreement with Switzerland on exchange of information regarding bank accounts on March 21. “The Swiss government offered to sign such an agreement with Pakistan in the third quarter of the current month that will enable… – Continue reading

Five things agents and developers need to know about the non-dom tax changes

From 6 April 2017, non-dom owners of UK property will be liable to inheritance tax (IHT) at 40% on any UK residential property they own. This has always been the case where a non-dom (broadly an individual who is resident in the UK but who has their permanent home abroad)… – Continue reading

India, Belgium sign protocol to amend double taxation avoidance agreement

New Delhi, March 9 (IANS) India and Belgium have signed a Protocol to amend the double taxation avoidance agreement to curb tax evasion, an official statement said on Thursday. “India and Belgium have signed a protocol amending the existing agreement and protocol between the two countries for avoidance of double… – Continue reading

Chancellor slaps 25% charge on people who move pensions abroad to dodge UK tax bills

People still be able to shift pensions overseas tax-free if they and their pot are located in same country Stiff new penalty is aimed at those who retire to one country while parking their pension in an offshore tax haven The Chancellor is to slap a 25 per cent charge… – Continue reading

Offshore tax evasion: compliance and penalties – part 1

Sometimes it can be hard to keep up with the avalanche of government announcements on tax avoidance and evasion. In the first of a two part series, Jason Collins, a member of the CIOT’s management of taxes sub-committee and partner at Pinsent Mason, provides an overview of the rapidly changing… – Continue reading

HK’s proposed dedicated tax regime for offshore aircraft leasing

The Hong Kong Government has put forward a proposal to amend its tax laws to establish a dedicated tax regime for aircraft owners/lessors based in Hong Kong and leasing to offshore (including PRC) lessees/airlines (see Timeline / References below) (“Proposed Regime”). Assuming there are no surprises or drafting issues in… – Continue reading

Bills, cars, bank accounts: the Italian Revenue Service will chase evaders who pretend to be abroad

The Italian Revenue Agency is stepping up its fight against international tax evasion. The tax authority will focus on undeclared funds and income held abroad by Italian taxpayers who have become resident abroad since January 1, 2010. Controls will be based on selected lists, which will first target the most… – Continue reading

S. Korea Probing Toyota Korea over Suspected Tax Evasion

South Korea’s tax authorities have been investigating the local importer of Toyota and luxury Lexus vehicles over suspected tax evasions since late 2016, industry sources said Friday. In November, the Seoul office of the National Tax Service (NTS) launched a tax audit into Toyota Korea over suspicions that it paid… – Continue reading

KPMG offshore tax dodge a ‘facade’ designed to hide money, ex-client says

Accounting firm’s contracts with federal government questioned. A former client of the accounting giant KPMG says a tax dodge that involved wealthy people gifting their money to an offshore jurisdiction was a “facade” designed to hide money from the taxman. The client, who spoke to CBC’s the fifth estate and… – Continue reading

New Zealand: New Zealand To Enact Tighter Foreign Trust Disclosure Rules

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

U.S. Agents Raid Caterpillar Over Offshore Tax Practices

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

Foreign person NRA tax withholding

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