Would businesses really be willing to pay more tax if they had more certainty on what is acceptable for cross-border tax planning? According to a recent Grant Thornton International Business Report, three quarters of business leaders would in fact be ready to pony up more taxes in exchange for greater… – Continue reading
The Government of the British Virgin Islands is pleased to announce that The British Virgin Islands (BVI) has been rated “Largely Compliant” for its approach to tax transparency and exchange of information, in the Supplementary Peer Review report published by The Global Forum on Transparency and Exchange of Information for… – Continue reading
NASSAU, Bahamas — This past week, a bill to enact The Foreign Accounts Tax Compliance Act (FATCA) was passed in the Senate to ensure that The Bahamas continues to remain aligned with the most recent international financial standards. In an earlier debate within the House of Assembly Minister of Financial… – Continue reading
On August 10, 2015 the Dutch Government published the text of a Protocol amending the Agreement between the Government of the Kingdom of the Netherlands and the Government of the Republic of Indonesia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on… – Continue reading
The Virgin Islands was rated “largely compliant” by the Global Forum on Transparency and Exchange of Information for Tax Purposes, according to BVI Finance, a government-sponsored body that promotes the territory’s financial services industry. The rating appeared in The Global Forum’s Supplementary Peer Review report, which reportedly analysed the practical… – Continue reading
After its ratification by all EU member states, the EU-Ukraine Association Agreement will constitute a solid base for comprehensive reforms in Ukraine. The agreement, which includes a deep and comprehensive free trade area, is a pioneering document which will not only open up our markets further but also address competitiveness… – Continue reading
India follows common approach for implementation of FATCA and CRS New Delhi, Aug 8: The Finance Ministry has come up with the rules for information reporting under the Foreign Account Tax Compliance Act (FATCA), spelling out the timelines and the entities have to comply with the new requirements. The new… – Continue reading
Fears of a VDP application giving rise to a ‘witch hunt’ are ill-founded. The rapid development in international tax transparency over the past two years in the form of the OECD (Organisation for Economic Co-operation and Development) Common Reporting Standard (CRS) has caused many South African taxpayers to consider regularising… – Continue reading
On August 7, 2015 the OECD published a Common Reporting Standard Implementation Handbook (Hereafter: the Handbook). According to the introduction included in the Handbook, the purpose of the Handbook is to assist government officials in the implementation of the Standard for the Automatic Exchange of Financial Account Information in Tax… – Continue reading
In April 2002 the OECD Global Forum Working Group on Effective Exchange of Information published a Model Agreement on Exchange of Information on Tax Matters (Hereafter: the Model TIEA). This Model TIEA contains an Article 5 which contains regulations arranging for the Exchange of Information Upon Request. As the current… – Continue reading
Australian Taxation Office New or updated materials on ATO website, including: Reminder: Taxable payments annual report due 28 August Remission of penalties: information about remission of penalties following a tax dispute In focus: Procurement hubs of Australian multinational enterprises: the ATO is reviewing arrangements involving offshore entities that are being used… – Continue reading
The Organisation for Economic Co-Operation and Development (OECD) is likely to recommend that restrictions on interest deductibility should mainly involve a cap calculated as a percentage of EBITDA, an expert has said.07 Aug 2015 Corporate tax Tax International tax Energy Infrastructure However Heather Self of Pinsent Masons, the law firm… – Continue reading
On May 13, 2015, Cyprus and Georgia signed a new double taxation agreement (DTA). Unlike many former members of the USSR, Georgia did not adopt the 1982 Cyprus–USSR DTA when it became independent, and the new agreement is the first between the two countries. It will come into force once… – Continue reading
SINGAPORE’S easiest days as a financial hub are over. The city remains a gateway to Asia, a great base for basing multinationals, settling lawsuits and parking money. But elsewhere, the city is being sidelined; the worry is that is a sign of things to come. In just 50 years, the… – Continue reading
Since 2013, investment institutions have started to increase their investments in private healthcare institutions in mainland China. Though there hasn’t been a real local healthcare group, the modes of investment have become diversified, including the acquisition of healthcare institutions, the establishment of new healthcare institutions and the transformation of public… – Continue reading
LONDON–(BUSINESS WIRE)–Three quarters of business leaders would pay more taxes in exchange for greater clarity from authorities on what is acceptable, according to the Grant Thornton International Business Report (IBR), a global survey of 2,580 businesses in 35 economies. And while few expect a global agreement any time soon, the… – Continue reading
MONTRÉAL, Aug. 5, 2015 /CNW Telbec/ – Three quarters of business leaders would pay more taxes in exchange for greater clarity from authorities on what is acceptable for tax planning, according to the Grant Thornton International Business Report (IBR), a global survey of 2,580 businesses in 35 economies. And while… – Continue reading
Introduction The Cayman Islands have an extremely open, accountable and transparent government and regulatory system. Despite the dated stereotype, the Cayman Islands have promoted transparency regulations and initiatives for many years. In May 2000, the Cayman Islands made commitments to the Organisation for Economic Co-operation and Development (the “OECD“) to… – Continue reading
THE South African Revenue Service (SARS) wants to be able to share disclosed financial information with countries with which it has multilateral exchange of information agreements. The ability to automatically exchange information with revenue authorities and with SA’s treaty partners would allow SARS to expand its tax base and help… – Continue reading
On 30 July 2015, Insurance Europe and the Pan European Insurance Forum jointly published a position paper. The paper summarises the views of the European insurance industry regarding the proposals of the Organisation for Economic Co-operation and Development (OECD) in its draft versions of its Action Plan on Base Erosion… – Continue reading
Business executives are giving mixed predictions on when and if tax reform will finally happen in Washington, in a new survey, reports Accountancy Today. The latest Business Tax Reform Barometer survey from the Tax Council and Ernst & Young polled approximately 1,000 business executives, tax directors, government relations representatives and… – Continue reading
The British Virgin Islands had the highest rate of tax compliance out of 12 countries reviewed by the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes, reports Public Finance International. The forum, which has 127 member nations, exists to implement internationally agreed transparency standards and the… – Continue reading
Until 2009 Switzerland had the questionable reputation of being the ideal parking spot for all kinds of money. The USA action against the UBS was the start of a series of actions to change old practices. Being the world number one in offshore money management, inevitably resulted in Switzerland being… – Continue reading
On May 20, 2015, the U.S. Treasury Department (“Treasury”) released five sets of proposed revisions to the U.S. Model Income Tax Convention (“Model Treaty”) for public comment. The Model Treaty was last updated in 2006. The purpose of the proposed revisions is to ensure that the United States maintains the… – Continue reading
Currently, olim are exempt from Israeli tax on overseas income and gains for 10 years. Now that the Israeli election is long forgotten, government officials have circulated their decisions on what state budget proposals should be presented to the cabinet for approval and submission to the Knesset for enactment. Some… – Continue reading
On 11 July 2015 a new Corporate Income Tax Regulation (CITR) was approved in Spain, introducing, amongst other things, amendments to the Spanish transfer pricing reporting requirements. The new requirements largely reflect the recommendations made by the OECD with respect to Action 13 of the OECD Base Erosion and Profit… – Continue reading
The tax and in particular the transfer pricing arrangements of multinationals is currently under the spotlight both internationally, through the OECD/G20 BEPS project, and domestically in Australia, by way of the Senate inquiry into corporate tax avoidance. This has resulted in new legal measures being adopted (such as the DPT… – Continue reading
This article is the third in our current three part series discussing various impacts of the Organisation for Economic Co-operation and Development’s (OECD’s) efforts to address the perceived global tax problem of base erosion and profit shifting (BEPS). The first article provided an overview of the key aspects of the… – Continue reading
United Kingdom Budget The Chancellor of the Exchequer delivered his Summer Budget to the United Kingdom (UK) Parliament on 8 July 2015. A number of personal, corporate and indirect tax-related measures were announced in the Budget including a reduced corporate tax rate; introduction of a bank corporation tax surcharge; a… – Continue reading
Maples and Calder and Maples Fund Services representatives explain how US and UK Fatca will impact Cayman-based funds. The implementation of the US Foreign Account Tax Compliance Act (US Fatca) and the less well-known but equally applicable UK equivalent (UK Fatca) have been a topical and core focus for Cayman… – Continue reading
CIVIL society organisations and the business community say the impact of Tax Inspectors without Borders (TIWB) initiative meant to curb tax evasion and illicit financial flows depended on the willingness of actors in Zimbabwe to reform and agree to be scrutinised. The TIWB project is aimed at helping developing countries… – Continue reading
Developing nations left behind as OECD countries continue to dominate the global tax agenda called for a UN body on intergovernmental tax to no avail. Tax, more than ever before, is viewed as one of the most significant drivers of development finance. But Organisation for Economic Co-operation and Development (OECD)… – Continue reading
First it was three years, now it’s three months. The Senate’s attempt to pass a multiyear highway bill ran off the road this week after House Republicans announced they will adjourn one day early for the month-long August recess. The House’s early departure forced the Senate to acquiesce to a… – Continue reading
Finland’s print media carries a mixed bag of headlines this Thursday, from former business bosses moving to tax-soft Portugal to studio apartment rents rising fast outside Helsinki. Neutral zone Åland is also under scrutiny, and the boat industry, at least, is doing well. Top tabloid Iltalehti splashes its front page… – Continue reading
Companies and govts have been playing the cat-and-mouse game for several decades on transfer pricing Only a naivete would think of Hilary Clinton’s proposal last week to scale up the rate of capital gains tax as a mere concept to streamline America’s tax rate structure. It is being perceived as… – Continue reading
The European Union (EU) doesn’t like the special tax deals that are offered to companies to entice them to set up in Switzerland. So the Swiss government is working hard to find a replacement. One element of their new plan is to offer patent boxes. A recent study by economists… – Continue reading
Understanding FATCA and having a comprehensive FATCA compliance program is essential for financial firms to limit non-compliance risk and meet obligations with relevant IGA’s. The US has made inroads on the Exchange of Information front and tax havens like Switzerland have declared a willingness to meet or even exceed OECD… – Continue reading
Over the past year, a number of legislative measures have been adopted to ensure that the Cayman Islands remains the leading jurisdiction of choice for structured finance and capital markets transactions and for secured lending transactions generally. This article focuses on two recent key legislative developments. The first is the… – Continue reading
Over the past year, a number of legislative measures have been adopted to ensure that the Cayman Islands remains the leading jurisdiction of choice for structured finance and capital markets transactions and for secured lending transactions generally. This article focuses on two recent key legislative developments. The first is the… – Continue reading
From five-star hotels to humble tavernas, Greek tax inspectors are fixing their attention on tax evasion at summer holiday hotspots. The government served notice on Wednesday that Prime Minister Alexis Tsipras’s promised crackdown on tax evasion is now under way, a week after sweeping increases in value-added tax were imposed…. – Continue reading
There has been much recent focus on tax structures employed by multi-national corporations. This has led to an initiative, spearheaded by the OECD, to combat “base erosion and profit shifting”, or BEPS. The shipping industry is likely to be affected both directly and indirectly by the BEPS initiative – directly,… – Continue reading
The Organisation for Economic Co-operation and Development’s (OECD’s) Parliamentary Group on Tax is meeting for the fourth time to discuss the implementation of the base erosion and profit shifting (BEPS) project. The meeting will take place in Paris on October 19, 2015. The timing has been carefully chosen to fall… – 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
Globalisation has brought many benefits in terms of cross?border trade, efficiency, competition and the free movement of goods and labour. But it has also allowed multinational corporations (MNCs) much greater freedom to reconfigure the location of manufacturing, operations, sales and corporate services in ways which channel reported profits ? and… – Continue reading
Where a foreign company renders professional services to a South African company in South Africa, it is important that the foreign entity considers whether, as a result of rendering such services, the foreign company will create a permanent establishment in South Africa. The reason why this becomes important is that… – Continue reading
On 8 June 2015, the Organisation for Economic Co-operation and Development (“OECD”) released a Country-by-Country Reporting Implementation Package developed under the OECD’s base erosion and profit shifting (“BEPS”) Action Plan 13: Re-examine Transfer Pricing Documentation. BEPS was identified as a risk to tax revenues, tax sovereignty and the tax fairness… – Continue reading
This article deals with the manner in which Canada has complicated, and rendered controversial, what in most other countries is straightforward — the deductibility of business related interest expense. The reasons to write about it are threefold: the almost-concurrent issuance of the Canada Revenue Agency’s administrative views on the matter… – Continue reading
With the focus of 2014 being international tax competition, 2015 shows signs of continuing this trend. The European Commission (COM) and European Parliament (EP) are starting to debate and extensively investigate Member States’ tax ruling policies, partly as a result of the LuxLeaks revelations and partly in relation to the… – Continue reading
The IRS released the fourteenth FATCA GIIN list of foreign financial institutions (FFIs) that have registered with the IRS through its FATCA portal. The IRS provides these FFIs a Global Intermediary Identification Number (GIIN). The FFI may then use its unique 19 digit GIIN to complete the IRS tax self… – Continue reading
Over the past few weeks the European Union has published a list of 30 countries which have been listed as non-cooperative jurisdictions. This publication was part of a wider publication: the “Action Plan for Fair and Efficient Corporate Taxation in the EU” which also includes the Re-Launching of the CCCTB…. – Continue reading
