The Internal Revenue Service (IRS) has outlined new procedures for some “accidental Americans,”, giving them the chance to comply with their US tax and filing obligations and in turn qualify for relief from back taxes, penalties and interest. The changes would allow people with less than $2m in net worth… – Continue reading
Nearly 40% of worldwide foreign direct investment (FDI), amounting to $15trn, “passes through empty corporate shells” with “no real business activities”, a study by the IMF and the University of Copenhagen reveals. According to the report, ten economies including Luxembourg, the Netherlands, Hong Kong, BVI, Switzerland, Singapore, Ireland, the Cayman… – Continue reading
A US-born British citizen has started a crowdfunding campaign to stop HMRC sharing her personal information with the US Internal Revenue Service (IRS) under the US Foreign Account Tax Compliance Act (FATCA). Law firm Mishcon de Reya has taken on the UK case for a client who alleges HMRC is… – Continue reading
The preliminary results of an impact assessment reveal that proposals advanced in an OECD-led effort to update the global rules for taxing digital businesses would not create large changes to countries’ existing taxing rights, Pascal Saint-Amans, OECD Director of the Centre for Tax Policy and Administration, said September 11. ... - Continue reading
The Federal Court of Australia on 3 September issued its much-anticipated judgement Glencore Investment Pty Ltd v Commissioner of Taxation of the Commonwealth of Australia [2019] FCA 1432, herein referred to as the Glencore decision. ... - Continue reading
Luxembourg and the US have amended their double taxation convention, updating the exchange of information article to harmonise it with that of the US model income tax treaty and the OECD. US ambassador to Luxembourg Randy Evans and Luxembourg finance minister Pierre Gramegna (DP) on Monday announced the ratification of… – Continue reading
In the past ten years, Switzerland has undertaken significant efforts to combat international tax fraud and tax evasion and to fight for the strict observance of foreign tax laws. In order to do so, a number of tax laws were enacted, allowing Switzerland to comply with international standards issued by the OECD (acting on behalf of the G20). In this respect, Switzerland ratified the Multilateral Convention on Administrative Assistance originally issued by the CoE and the OECD in 1988 and amended in 2011 ("OECD MC"), and it renegotiated numerous Double Taxation Conventions ("DTC"), amongst them also the DTC with Italy, in order to comply with the international standard introduced by the OECD MC in the version of July 2010. ... - Continue reading
The OECD said its initiative to have minimum standards on the collection and exchange of country-by-country (CbC) reports on large multinational businesses has reached 116 jurisdictions and has shown major progress in the delivery of international tax transparency. The OECD’s second annual peer review report on the base erosion and… – Continue reading
Next month, the European Union will revamp its methodology for compiling its anti-money laundering blacklist, after a previous list was blocked by EU governments that objected to the listing of Saudi Arabia and four US overseas territories, EU Commissioner for Justice Vera Jourova told the Financial Times recently.“We have admitted… – Continue reading
Banking details of Indians with accounts in Switzerland have been made available to tax authorities as the automatic exchange of information agreement starts between the two countries. “India will receive information of the calendar year 2018 in respect of all financial accounts held by Indian residents in Switzerland. This will… – Continue reading
The Automatic Exchange of Information mechanism between India and Switzerland is being seen as a major boost in India’s fight against suspected black money stashed abroad A joint team of officials from Central Boad of Direct Taxes (CBDT), Central Bureau of Investigation and other probe agencies, who are looking into… – Continue reading
On June 7, 2017, Canada along with numerous other jurisdictions signed the Organisation for Economic Co-operation and Development’s (“OECD”) Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “MLI” or “multilateral instrument”). The multilateral instrument is the culmination of work undertaken as part of the OECD/G20 BEPS Project to equip governments with domestic and international instruments to address tax avoidance. ... - Continue reading
The government brought into legislation a specific element of the 2017 OECD guidelines that permits the tax authority to re-characterize an intra-group arrangement. ... - Continue reading
The OECD today released a peer review report judging whether 116 countries and their tax administrations have met standards on the collection and exchange of country-by-country (CbC) reports on large multinational businesses. ... - Continue reading
Brian Jenn, former US Treasury Deputy International Tax Counsel, has joined McDermott Will & Emery’s tax practice as a partner, the firm announced today. Jenn will be based in McDermott’s Chicago office. ... - Continue reading
Georgia, an Eastern European Country, was ranked 6th in the World Bank Group’s 2019 “Doing Business” survey. ... - Continue reading
A bill was introduced to the Mexican Congress on August 21 to tax digital platforms. ... - Continue reading
India will start getting details of bank accounts held by its citizens in Switzerland from September, ending the era of Swiss bank secrecy. ... - Continue reading
Barbados’ removal from the European Union’s (EU) blacklist has been welcomed by the Institute of Chartered Accountants of Barbados (ICAB). During her welcome remarks at the 15th Annual ICAB International Business Workshop, at the Barbados Hilton Resort, ICAB’s Executive Director, Kathy-Ann Hewitt, stated: “We are indeed happy that this change… – Continue reading
Canada and Switzerland on August 8 deposited with the OECD their instruments of ratification for the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS MLI). The BEPS MLI, negotiated by over 100 countries and jurisdictions, updates the existing network of tax treaties and… – Continue reading
The Organisation for Economic Co-operation and Development is going to propose a global minimum tax that would apply country by country before the next meeting of G‑20 finance ministers and central bankers set for 17 Oct. in Washington, DC. G7 leaders announced at their Biarritz summit meeting this week a… – Continue reading
Canada and Switzerland have deposited their instruments of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), the OECD today announced. ... - Continue reading
With effect from 1 January 2019, the Anti-Tax Avoidance Directive (ATAD) I intra-EU hybrid mismatches rules were introduced into Luxembourg’s domestic law. ... - Continue reading
Tens of thousands of British citizens born in the US but only lived there for a few months or years face having their bank accounts frozen as part of a crackdown by the US tax authorities. The Internal Revenue Service (IRS) is ordering British banks to hand over the… – Continue reading
After 20 years of negotiations, the European Union and Mercosur have moved forward with the free trade agreement between the two blocs. ... - Continue reading
In a recent decision, the U.S. Court of Appeals for the D.C. Circuit unanimously affirmed a district court order compelling three Chinese banks (not currently identified) to produce financial records in response to subpoenas issued by U.S. federal prosecutors, including records that were unrelated to the banks' U.S. operations or U.S. correspondent accounts. ... - Continue reading
In 2018, the European Commission (EC) concluded two more investigations into whether the tax ruling practices of Member States breached European Union (EU) State aid rules: the first, a finding of unlawful State aid resulting from tax rulings by Luxembourg in favor of Engie; the second, a rare finding of no aid in respect of the treatment by Luxembourg of McDonald's under the Luxembourg-U.S. double taxation treaty. These decisions are discussed below. ... - Continue reading
French President Emmanuel Macron today confirmed that the US and France have reached a compromise agreement which requires France to refund all digital services tax (DST) paid by multinationals once a new international system for taxing multinationals in the digital sector is in place. ... - Continue reading
The Directorate General of International Taxes of the Federal Board of Revenue (FBR) has started analysing a few potential multinational companies’ cases of transfer pricing where companies are directly involved in shifting their profits outside the country without payment of any taxes. In this regard, Directorate General of International Taxes… – Continue reading
ISLAMABAD: The government has kicked off a far-reaching crackdown against benami assets directing the departments concerned at the federal level and the provincial governments to track benami properties, harvesting the Benami Act, 2019 in the national and global contexts. Prime Minister Imran Khan chaired a meeting on August 20 on… – Continue reading
It is estimated that the use of tax havens is costing federal and provincial governments at least $7.8 billion in lost tax revenue. Low and middle income Canadians are the ones paying for that missing $7.8 billion in tax revenue. Ottawa (11 Aug. 2016) — The leak of the Panama… – Continue reading
The Cayman Islands has published a set of frequently asked questions detailing a law requiring that companies with geographically mobile activities have economic substance for tax purposes. ... - Continue reading
The European Union has added further impetus to its objective of providing greater transparency with regard to harmful tax practices through an amendment to EU Directive 2011/16/EU. ... - Continue reading
On 19 July 2019, the Organisation for Economic Cooperation and Development (OECD) released its report on harmful tax practices across various jurisdictions. ... - Continue reading
On July 16, 2019, the US Senate ratified a new protocol that amends the 2013 Double Taxation Treaty signed between the US and Spain. ... - Continue reading
On 8 August, the draft law (the "draft law") implementing the EU Directive 2017/952 of 29 May 2017 ("ATAD 2") amending Directive (EU) 2016/1164 laying down rules against tax avoidance practices that directly affect the functioning of the internal market (the so-called Anti-Tax-Avoidance-Directive, "ATAD") was presented to Parliament. ... - Continue reading
19 August 2019, Since 1993, Dominica has been at the forefront of the citizenship by investment (CBI) industry, setting high standards in due diligence, processing times, and most recently, transparency. Indeed, this month the nation liaised with prominent international professional services firm PricewaterhouseCoopers (PwC) to release a report clarifying the… – Continue reading
A US federal appeals court on Friday affirmed the Tax Court’s decision in Amazon, ruling that cost sharing buy-in payments made by Amazon’s Luxembourg subsidiary in exchange for Amazon’s transfer of intangible property should not include compensation for transferred residual business assets such as workforce in place, goodwill, and going concern value. ... - Continue reading
Luxembourg corporate income taxpayers, including Luxembourg permanent establishments of foreign entities, will be subject to the Draft Law as from 1 January 2020. In addition, provisions targeting reverse hybrid mismatches will be applicable to Luxembourg transparent partnerships that would be treated as opaque by their nonresident owners as from 1 January 2022. ... - Continue reading
Tax residence is one of the most important factors when ascertaining an expatriate worker's tax obligations. ... - Continue reading
Australians are holding more than $100bn in undisclosed offshore accounts, according to new taxation office data collected under the Common Reporting Standard (CRS), British newspaper the Guardian has reported. ... - Continue reading
Banks in France have warned that they could be forced to close up to 40,000 accounts belonging to US citizens because of ongoing difficulties with the Foreign Account Tax Compliance Act (FATCA). ... - Continue reading
"Canada has not only the largest in terms of numbers, but also the most elaborate and longest-standing skilled labour migration system in the OECD," the report says. ... - Continue reading
Today the High Court confirmed that the ATO may use information obtained from data leaks, even if leaked from a law firm. Second Commissioner Jeremy Hirschhorn said today’s decision in Glencore International v. Commissioner of Taxation means the ATO can continue to use the ‘Paradise Papers’ and other similar data… – Continue reading
In February and March of 2019, the OECD organized a public consultation process, releasing a consultation document on February 13, 2019, inviting public comments up until March 6, 2019, and holding a conference where industry experts presented key issues on March 13 and 14, 2019. ... - Continue reading
This was revealed by the Organisation for Economic Cooperation and Development (OECD) last Friday in an announcement made on its website. ... - Continue reading
Uber is moving its intellectual property arm from Bermuda to the Netherlands to save $6.1bn from its tax bid, Bloomberg reported on Friday. ... - Continue reading
The VAT rate in Bulgaria has remained unchanged at 20% for many consecutive years. Recently, there has been a lot of debates on the future possibility of amending the VAT rate for certain food products as well as medicines and books to a rate somewhere in the range between 3% and 5%. ... - Continue reading
CIAT’s BEPS Monitoring Database has been updated to reflect advancements made by Angola, Argentina, Bermuda, Brazil, Chile, Colombia, Costa Rica, Honduras, India, Jamaica, Mexico, Panama, Paraguay, Spain, and Uruguay. ... - Continue reading
The European Union has added further impetus to its objective of enhancing transparency against harmful tax practices with the amendment to Directive 2011/16/EU, commonly referred to as DAC6. ... - Continue reading
