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
Now that Costa Rica has been formally invited to go through the process of becoming a candidate nation worthy of joining the Organization for Economic Cooperation and Development (OECD), financial advisors and legal professionals are starting to ponder how their clients will be impacted by this new chapter in our… – Continue reading
European Competition Commissioner Margrethe Vestager has called for a common consolidated corporate tax base (CCCTB) and the automatic exchange of information on tax rulings. Vestager appeared before a hearing of the European Parliament’s Special Tax Rulings Committee on May 5. In her opening remarks, she said: “There is a lot… – Continue reading
For the fourth consecutive year, PKF Malta will be participating in Canada’s premier Captive Insurance event for risk managers. Captives & Corporate Insurance Strategies Summit will take place in Sheraton Center Toronto, located in the heart of this vibrant city, on 27th-28th May2015. In this year’s event, George Mangion, Senior… – Continue reading
The deductibility of interest has for years been a contentious issue and this has been reaffirmed with the introduction of section 23M into the Income Tax Act No 58 of 1962 (the “Act”) with effect from 1 January 2015. A further addition to the interest sphere of income tax is… – Continue reading
“Book Loss” and not “operating loss” a relevant indicator for determining persistent loss – Mumbai Tribunal Ruling in the case of Sumitomo Chemical India Private Limited Transfer pricing aims at establishing the arm’s length price of the controlled transactions using the most appropriate method. The success of transfer pricing lies… – Continue reading
Cracking down on sweetheart tax deals with multinational corporations is proving more difficult than the European Commission had anticipated. Delays, uncooperative member states, and missed deadlines are among the frustrations highlighted Tuesday (5 May) by the EU’s competition chief, Margrethe Vestager. Speaking at a special committee on tax rulings at… – Continue reading
Dubai – The Ministry of Finance (MoF) recently signed a MoU with Ras Al Khaimah Investment Authority (RAKIA). This MoUhas been signed to ensure the implementation of international standards of transparency in the exchange of information for tax purposes, as per Organisation for Economic Cooperation and Development (OECD) regulations and… – Continue reading
It’s a race against time for governments of the worlds’ largest economies seeking a coordinated plan to make it more difficult for multinational corporations to shield profits overseas. Some countries are preparing to act on their own. International finance leaders from advanced- and developing- economies are set to gather Wednesday… – Continue reading
Choosing the right location for the centralization and management of your IP is a very important strategic business decision. The ideal location to establish an IP structure is one that can serve the organization’s business strategies/model, safeguard and protect its IP and more important to contribute to its tax optimization…. – Continue reading
US fast-food giant McDonald’s could be facing a European Commission (EU) investigation into its tax affairs. EU competition commissioner Margrethe Vestager said she is looking into trade union allegations that the restaurant chain avoided paying more than €1bn (£658m; $1.1bn) in corporate taxes between 2009 and 2013. Unions claim McDonald’s… – Continue reading
In the 2015 Budget Speech presented to the National Assembly on 25 February 2015 the Minister of Finance announced that amendments will be proposed to change the rules for the digital economy in line with the latest guidance issued by the Organisation for Economic Co-operation and Development (“OECD”) in its… – Continue reading
BRUSSELS–The European Union won’t meet a self-imposed June deadline for deciding whether four multinational companies including Apple Inc. and Amazon.com Inc. benefited from illegal tax sweeteners, the bloc’s antitrust chief Margrethe Vestager said Tuesday. “We won’t meet the deadline we set ourselves [of] the end of the second quarter,” Ms…. – Continue reading
Passing between tax administrations Polish and US information on accounts and income tax residents predicts signed by the president Bronislaw Komorowski law on ratification of the agreement with the USA on the use of so-called FATCA Act. As reported by the presidential office, in terms of the Act of 20… – Continue reading
Guernsey’s Chief Minister, Jonathan Le Tocq, met today with Pierre Moscovici, the European Commissioner for Economic and Financial Affairs, Taxation and Customs. Deputy Le Tocq’s meeting, which was alongside Jersey’s Chief Minister, Ian Gorst, came at the beginning of a series of engagements over the next 48 hours in Brussels…. – Continue reading
The patent box regime, adopted at the end of 2014 with Italy’s Stability Law, was recently modified by the Investment Compact Decree and implemented into law at the end of March 2015. A distinctive feature of the Italian regime is that the measure now also covers trademarks and designs. A… – Continue reading
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
With a new candidate seemingly entering the race for president each week, national attention is understandably focused on American politics. But while Americans spare little mind for the goings-on of international organizations, their activities not only have significant impact around the world, but could also play a role in the… – Continue reading
On 21 April 2015, the Danish Parliament adopted a bill, which sets out to deal with certain potential abuses recently encountered by the tax authorities as well as the Danish enactment of the general international anti-abuse initiatives currently considered at EU and OECD level. The new Danish GAAR will take… – Continue reading
Warning corporates not to take unfair advantage of the liberalised tax environment, Finance Minister Arun Jaitley on Friday said the world is moving towards a more transparent regime that would remove the veil of secrecy from unlawful transactions. “I think, for every assessee, every person in the commercial business also,… – Continue reading
With its enviable reputation in offshore trusts, pensions and insurance, Bermuda is an ideal jurisdiction for employers to establish international pension and employee benefit plans (IPPs). Global organisations may consider establishing Bermuda IPPs for employees who work outside their home country or the home country of both the employees and… – Continue reading
The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project is changing the international tax landscape by building a new international consensus on how to tackle BEPS. In September 2014, the first seven of the deliverables under the 15-point BEPS Action Plan were presented to G20 Finance Ministers when they met… – Continue reading
The debate around transparency, information exchange and beneficial ownership continues to evolve and has demanded a real focus for those working in International Finance Centres (IFCs), which frequently find themselves in the frame when it comes to ill-considered accusations relating to secrecy and illicit financial flows. In fact, Jersey and… – Continue reading
Introduction The Organisation for Economic Cooperation and Development (OECD) recently issued a discussion draft on the use of profit split methods in relation to transfer pricing and in the context of global value chains as part of the Base Erosion and Profit Shifting (BEPS) project.(1) This update provides an overview… – Continue reading
Singapore is not a tax haven, it’s a value-adding hub. That is the claim of the island nation’s Economic Development Board, the Singaporean government agency that’s been charged with attracting business and investment. It has disputed recent claims at the Senate inquiry into corporate tax avoidance that it’s being used… – Continue reading
SAN FRANCISCO, April 30 — Apple Inc. has raised a flag about the potential cost if the company is required to pay past taxes to Ireland as part of a European Commission investigation that started last year. While Apple hasn’t been able to estimate the amount, it could be “material,”… – Continue reading
France’s minister for digital affairs says abolition of ‘double Irish’ was a welcome move Multinational companies, particularly those in the digital sector, will need to pay tax where they create value in a new digital single market for Europe, France’s minister for digital affairs has said. Speaking to The Irish… – Continue reading
The European Union (EU) needs an “ambitious blueprint for taxation,” Tax Commissioner Pierre Moscovici has said. Speaking at a recent conference, Moscovici said: “The European Union needs an ambitious roadmap to put an end to the distortionary nature of its tax policy and regulatory framework. In my view, the way… – Continue reading
Big hue and cry from the rich and the powerful against modification of tax return forms has again pushed the govt on back foot John Maynard Keynes famously said the avoidance of tax is the only intellectual pursuit that carries a reward. Historically, tax ‘avoidance’ is understood as an intellectual… – Continue reading
Autumn Statement 2014, Budget 2015 and Finance Act 2015 The UK Chancellor delivered his Autumn Statement on 3 December 2014 and his Budget speech on 18 March 2015. For an overview of some of the key announcements, please see our Autumn Statement 2014 briefing and Budget 2015 briefing. The UK’s… – Continue reading
ZURICH: Switzerland’s money laundering office received a record number of suspicious activity reports last year, in part due to increased vigilance from Swiss banks. The Alpine nation has faced intense international pressure over bank secrecy, tax evasion and money laundering, most recently highlighted by allegations that the Swiss arm of… – Continue reading
Most people have heard of the Organisation for Economic Co-operation and Development (OECD) and are probably aware it wants to make the world a “better” place. Its work is probably of little interest to most companies based in the UK. But this would change if constitutional arrangements between Scotland and… – Continue reading
Bern, 29.04.2015 – At its meeting today, the Federal Council decided to put into effect in two stages the Federal Law of 12 December 2014 on the implementation of the Financial Action Task Force recommendations, revised in 2012. On 12 December 2014 the Federal Assembly approved the Federal Law on… – Continue reading
The new omnibus bill presented by the Greek ministry of finance will be tabled in parliament on Thursday in order to expedite negotiations with creditors and reach an intermediate deal. The new bill includes several measures and reforms such as methods of tackling tax evasion, revenue increase from value added… – Continue reading
Starting with 1 June 2015, non-resident taxpayers earning interest income from Romania are allowed to apply the same tax treatment as resident taxpayers. The change in the law results from a European Commission infringement procedure against Romania regarding the discriminatory treatment applied to non-resident legal entities compared to resident taxpayers…. – Continue reading
As compared to past federal Budgets, Budget 2015 contained fewer (and arguably less controversial) international tax measures. Nevertheless, Budget 2015 did announce the Government’s intention to address taxpayer concerns relating to (i) the withholding obligations borne by non-resident employers that have non-resident employees that work in Canada, and (ii) the… – Continue reading
THE global economic recovery, which has been assessed as uneven with manifest divergences across countries and regions, has however, been supported by Emerging Markets and Developing Countries (EMDCs) as the major drivers of global growth, although it is currently moderating in some countries. But the Intergovernmental Group of Twenty-Four on… – Continue reading
The British Virgin Islands Government has received a report that it commissioned on finding a new direction for the financial services industry, the recommendations from which will now be implemented, reports Tax News. The BVI engaged consulting firm McKinsey and Company to develop a pragmatic new strategy and implementation plan… – Continue reading
Turkey is to host a G20 international tax symposium next month to discuss developments to address Base Erosion and Profit Shifting (BEPS) and the exchange of information between tax administrations The event, organised by Turkish Ministry of Finance, also aims to ensure that developing and low-income countries benefit from the… – Continue reading
The April 21, 2015 Federal budget released by the Conservative Government includes updates on Canada’s involvement in the BEPS project and how Canada intends to fulfill its obligations to implement an automatic exchange of tax information with the G-20. Notably (with the exception of the common reporting standard discussed below),… – Continue reading
Premier Michael Dunkley spoke at a recent Transcontinental Trusts Conference forum here on the island, the first time that the conference’s flagship event has been held outside of Europe in 30 years. In his remarks, Premier Dunkley said, “As this is the leading trust event for private client professionals, our… – Continue reading
The Greek government will table a new draft bill to Parliament that will allow Greek citizens to voluntarily reveal deposits held in Switzerland in exchange for a smaller tax payment, Finance Minister Yanis Varoufakis said on Tuesday. Speaking to reporters after a meeting with Swiss State Secretary for International Financial… – Continue reading
LONDON (Reuters) – HSBC shares have rallied after the bank said it was reviewing whether to move its headquarters out of Britain and potentially back to its former home in Hong Kong. The following are some of the regulatory issues raised if Europe’s biggest bank were to relocate to Hong… – Continue reading
In brief: At the recent G20 meeting in Washington, Treasurer Joe Hockey announced the establishment of a working group between Australia and the UK to develop initiatives to address so-called diverted profits involving multinational enterprises. What are the implications for multinationals doing business in Australia? Partner Martin Fry (view CV)… – Continue reading
Ireland found itself surrounded by supporters, for the first time, on the issue of corporate tax rates, during an informal meeting of EU finance ministers, reports the Irish Examiner. Finance Minister Michael Noonan was not present, as he returned to Dublin early, but the head of the Central Bank, Patrick… – Continue reading
Hong Kong’s Government has launched a consultation on proposals to apply, with certain adaptations, new international standards on the automatic exchange of account information (AEOI) in tax matters. The Government’s AEOI proposals would alter the definition of financial institutions (FIs), the information FIs would be required to secure from account… – Continue reading
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
Earlier, SEBI also beefed up norms for defaulters trying to raise fresh money. The Reserve Bank of India (RBI) has clarified that only nominee and independent directors who are not whole-time board members of a firm deemed as a ‘wilful defaulter’ would be excluded from being labelled as a party… – Continue reading
British Virgin Islands through its International Tax Authority (BVI ITA), went live last week with the Vizor for FATCA & AEOI solution, the “BVI Financial Account Reporting System”. Today, Vizor Ltd. announced that BVI went live with the Vizor for FATCA & AEOI solution. The British Virgin Islands Government (BVIG)… – Continue reading
On Saturday 25 April, at the second session of the informal meeting of the Economic and Financial Affairs Council (ECOFIN), one of most important issues on the agenda was the further development of the Capital Markets Union concept, which was broadly supported by the ministers and Governors of central banks…. – Continue reading
