The Luxembourg Intellectual Property (IP) tax regime will be aligned to the “modified nexus approach”, as per Pierre Gramegna, Luxembourg’s Finance Minister. The IP regime is expected to be modified in 2015 and to be in force no later than 30 June 2016. This is driven by the OECD’s Base… – Continue reading
The world’s high and ultrahigh net worth families are run much like businesses these days, with family governance in place as well as fund structures in favourable tax jurisdictions that allow for consolidated reporting across diversified assets. That is the way the world is moving, with global tax authorities grouping… – Continue reading
European finance ministers have backed efforts to fight rampant tax avoidance by multinationals in the wake of the LuxLeaks scandal. But European Union members face tough negotiations to work out the details. Under a new plan the bloc’s 28 countries would share tax deals agreed with some of the world’s… – Continue reading
NUMBER OF THE WEEK: 6.5 percent The tax rate at which companies could voluntarily repatriate their foreign earnings under the Invest in Transportation Act of 2015 ( S. 981). Senators Barbara Boxer (D-CA) and Rand Paul (R-KY) introduced the bipartisan proposal, offering ways to save the Highway Trust Fund. Funding… – Continue reading
Trade in today’s global era visualizes significant number of international transactions in form of transfer of goods, services, capital and intangibles. International transfers arise within the Multinational Enterprise group entities and are called intra-group transfer. What is actually paid by one entity to another entity in the intra-group transfer is… – Continue reading
However, OECD being persuasive may not help funds based out of nations whose treaties do not give specific exemption The Indian government’s clarification that it would honour tax treaties while making a demand of Minimum Alternate Tax (MAT) at the effective rate of 20 per cent came as a relief… – Continue reading
Company accounts provide insight into Parlesse Investments A Larry Goodman company based in Luxembourg made a profit of €52.6 million in 2013 and paid just 0.4 per cent tax, according to accounts in the tiny EU member state. The company, Parlesse Investments Sarl, began operations in 2010 and had accumulated… – Continue reading
On 20 March 2015, the British Virgin Islands Government issued revised guidance notes regarding the Intergovernmental Agreements between the British Virgin Islands (“BVI”) and the United States of America (the “US”) and the United Kingdom (the “UK”) to improve international tax compliance (the “Guidance Notes”). The Guidance Notes confirm that… – Continue reading
Multinationals play such a large role in many nations’ budgets that effective control is crucial. Business Tax-base erosion cripples Africa 24 Apr 2015 00:00 Lisa Steyn Multinationals play such a large role in many nations’ budgets that effective control is crucial. Finance Minister Nhlanhla Nene says practices such as incorrect… – Continue reading
Hong Kong (HKSAR) – The Government today (April 24) launched a consultation exercise to gauge views on proposals to apply, with adaptations for Hong Kong, the prevailing international standards on the automatic exchange of financial account information in tax matters (AEOI). On the basis of the Organisation for Economic Cooperation… – Continue reading
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
Registration is open for the Organisation for Economic Co-operation and Development’s (OECD’s) latest webcast, which will update stakeholders on progress towards the conclusion of its base erosion and profit shifting (BEPS) work. The webcast will last for one hour on June 8, 2015, beginning at 15:00 Central European Time (CET)… – Continue reading
HSBC bank has been based in UK ever since it took over Midland Bank in 1993 but the bank was born in Hong Kong and it looks like its headquarters is headed back East. The bank has traditionally reviewed its head office location every three years, this morning the bank… – Continue reading
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
Documents exposed secret deals to slash global tax bills of multinational companies A French journalist has been criminally charged in Luxembourg for his role in exposing how hundreds of multinational companies used secret deals with the European duchy’s government to slash their global tax bills — a scheme that CBC… – Continue reading
MUMBAI: In a bid to attract investments into Luxembourg, once seen as a “tax haven”, its ambassador today assured industrialists and investors that his government “does not encourage money laundering.” “We do not encourage dirty money. It is a misconception that the Luxembourg is a tax haven,” the alpine nation’s… – Continue reading
Federal Treasurer Joe Hockey has left open the option of scaling back superannuation concessions as part of the tax white paper process. Speaking at the Australian Israel Chamber of Commerce lunch in Melbourne, Mr Hockey also flagged a package for small business and startups in the upcoming federal budget. Mr… – Continue reading
The government on Wednesday assured over 1,000 foreign institutional investors (FIIs) across the United States, Hong Kong and Singapore they can avail of treaty benefits to ward off tax demands on capital gains booked over the years till March 31, reports the Financial Express. The development is significant given the… – Continue reading
FATCA 1. New FATCA IGA guidance notes On 3 February 2015, the Jersey Chief Minister’s Department published the latest version of the Guidance Notes on the Taxation (International Tax Compliance) (Jersey) Regulations 2014 in relation to the implementation of obligations arising under the intergovernmental agreements (IGAs) with the US and… – Continue reading
1 General news 1.1 HMRC organisation chart HMRC has published its latest organisation chart showing the names of senior management. One point to note is the number of senior people now in roles such as change management as opposed to being in pure technical roles. This clearly demonstrates the direction… – Continue reading
The Minister of Finance (Canada), the Honourable Joe Oliver, presented the Government of Canada’s 2015 Federal Budget (“Budget 2015”) on April 21, 2015 (“Budget Day”). Budget 2015 contains several significant proposals to amend the Income Tax Act (Canada) (the “ITA”) while also providing updates on previously announced tax measures and… – Continue reading
Minister of Finance Joe Oliver today tabled the 2015 Federal Budget (the “Budget”), his first budget as Minister of Finance, entitled “Strong Leadership: A Balanced-Budget, Low-Tax Plan for Jobs, Growth and Security”. We are pleased to provide our summary of tax measures contained in the Budget. The Budget proposed no… – Continue reading
As has been widely predicted, today’s federal budget (Budget 2015) delivered a handful of tax “goodies” in the lead-up to the coming election. It also includes a number of important proposed changes to the corporate tax rules. They are noteworthy, although not as extensive as the corporate tax changes proposed… – Continue reading
The arrival of Netflix in Australia has brought into sharp relief the GST base erosion problem caused by global digital commerce. Along with the non-taxation of low-value imported goods, the absence of GST on services and digital products imported by consumers represents an omission from the tax base that is… – Continue reading
After years of upheaval in the financial sector, taxpayer confusion, and widespread international angst, the IRS has finally unveiled its FATCA registration and reporting system. The system is known as IDES, or the International Data Exchange Service, and claims to provide “a secure web application … to transmit FATCA data… – Continue reading
Finance Minister Joe Oliver faced formidable challenges, both economic and political, in delivering his first Budget. In a time of depressed oil prices, and mere months ahead of the next federal election, it appears he felt it was imperative to follow through with prior commitments to balance the budget, provide… – Continue reading
1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins The legal system of the Republic of Ireland is a common law system. In order to ensure consistency, a legal principle developed whereby courts were generally required to follow earlier relevant decisions. This doctrine of… – Continue reading
On March 18th 2015, the European Commission published a new initiative on tax transparency to fight tax evasion and avoidance. The initiative includes a proposal to extend the scope of the Directive on Administrative Co-operation in the field of direct taxation (2011/16/EU), amended by Council Directive 2014/107/EU (the “Directive”) by… – Continue reading
TL: What are the main considerations and advantages for doing business in Malta? AB: Malta’s positive approach to business promotion, development and standard of living within the EU makes the island a destination of choice for relocation of business purposes. Malta offers noteworthy benefits to individuals and investors who are… – Continue reading
(Reuters) – Australia needs to tighten safeguards against money laundering in its booming property market, which has attracted Chinese funds with likely links to corruption, an international anti-money laundering body said in a report released late on Tuesday. The intergovernmental Financial Action Task Force said real estate agents and lawyers… – Continue reading
An inflow of bank deposits to Luxembourg from Asia and the Gulf have replaced reductions from European countries such as France and Germany following an overhaul of the Grand Duchy’s tax secrecy regime, reports the Financial Times. Pierre Gramegna told the Financial Times in an interview that “bank secrecy had… – Continue reading
The European Investment Bank (EIB) must tighten up its lending rules to prevent its money being funnelled through tax havens, NGOs have warned in a new report, reports EU Observer. The report ‘Towards a Responsible Taxation Policy for the EIB’, published on Tuesday (21 April) by transparency NGOs Re-Common and… – Continue reading
Like many other public banks, the European Investment Bank (EIB) leverages its own means by acting as a catalyst for private investment through various financial mechanisms. Too often, though, attempts to attract private capital result in unpredictable risks and higher-than projected costs for the public coffer, write Xavier Sol and… – Continue reading
Companies would be forced to reveal any arrangements that are used to avoid tax, and those not paying their fair share of tax would be named and shamed on a “worst offenders” list, under a plan by the Greens. The party has released a discussion paper detailing policies to fight… – Continue reading
World leaders have drawn up ambitious goals to end extreme poverty by 2030 and promote development over the next 15 years, but now they have to figure out how to pay the bill. Trillions of dollars would be required to achieve the 17 Sustainable Development Goals (SDGs) that the United… – Continue reading
With regard to the First Financial case, the debarred entities include this company itself, its seven promoters and directors, 80 ‘preferential allottees’, 57 First Financial Group entities, as also seven others suspected to be related entities. Sebi has allowed First Financial, which has been barred from the capital market for… – Continue reading
The man chosen by Treasurer Joe Hockey to lead the review of the nation’s tax system has publicly criticised the British government’s “Google tax”, the inspiration for the Coalition’s looming crackdown on multinational profit shifting. Robert Jeremenko, who is running the tax white paper process in Mr Hockey’s office, described… – Continue reading
PRAGUE – The world’s latest contender for statehood, Liberland, is a tiny new, self-proclaimed country sandwiched between Croatia and Serbia that lives up to its “live and let live” motto by offering optional taxes, its president said Monday. “The key idea is voluntary taxes, creating a state so small that… – Continue reading
The Council of the European Union on April 20, 2015, endorsed proposals to require member states to maintain a central register of information on the beneficial ownership of corporate and other legal entities. It would be at the discretion of member states as to whether such information would be publicized…. – Continue reading
HM Revenue and Customs has amended its list of registered pension schemes in what appears to be a bid for clarity in light of the new pension freedoms, toughening risk warnings and modifying language to emphasise that appearing on the list does not confer authorisation, reports the FT Adviser. The… – Continue reading
The internationally recognized handbook for legal experts Global Law Experts has distinguished GRP Rainer Lawyers and Tax Advisors as one of the leading law firms in the field of tax law. GRP Rainer Lawyers and Tax Advisors in Cologne, Berlin, Bonn, Düsseldorf, Frankfurt, Hamburg, Munich, Stuttgart and London has been… – Continue reading
The OECD Mutual Agreement Procedure Statistics for 20131 (MAP Statistics), released on November 25, 2014, show a dramatic surge in the inventory of mutual agreement procedure (MAP) cases among OECD member countries. The MAP Statistics confirm that the potential for double taxation is increasing. This is reflected most starkly in… – Continue reading
On April 2, 2015, the Israeli tax authority (“ITA”) published a draft new circular containing new and unprecedented guidelines with respect to the income tax and VAT aspects applicable to foreign enterprises that transact with Israeli customers over the internet (“the Circular” and “Foreign Enterprises”, respectively). The Circular, in its… – Continue reading
“The business tax system today is inefficient, overly complex, and too riddled with loopholes,” said Mark Mazur, assistant secretary for tax policy at the U.S. Department of Treasury. So much so, in fact, that it can’t fulfill its function to be a world-class system, he noted. Mazur, speaking Tuesday at… – Continue reading
SOUTH Africa’s Finance Minister Nhlanhla Nene says African leaders need to focus more on tax policies and the diversification of tax resources in order to foster growth. Speaking at an African Tax Administration Forum conference on Tuesday, he said the global focus on international taxation offered a unique opportunity for… – Continue reading
Britain’s Conservative Party returned a donation of £50,000 from a wealthy businesswoman on Monday after it emerged she was once wanted on charges of tax fraud in the United States. Beatrice Tollman, founder of luxury hotel chain Red Carnation, made an election campaign donation to the Tories earlier this month…. – Continue reading
Summary:Australia and the UK have reached a deal aimed at helping tackle profit-shifting practices by multinational companies, such as Apple, Google, and Microsoft. Australia and the United Kingdom have agreed to form a joint working group to tackle profit shifting by multinational companies such as Google, Apple, and Microsoft. The… – Continue reading
The United States of America (USA) has toppled Mauritius to become the top jurisdiction from where India is receiving the highest amount of foreign portfolio investment (FPI) into the equity markets. Mauritius lost out due to the uncertainty over the double tax avoidance treaty (DTAA) between India and Mauritius and… – Continue reading
International plans for gathering and analysing data on the extent to which multinational companies are artificially shifting their profits to low-tax jurisdictions are at a disappointingly early stage, an expert has said. Heather Self of Pinsent Masons, the law firm behind Out-Law.com, also said that the global governments involved in… – Continue reading
In his recent article, “A Cursory Analysis of the Impact of Combined Reporting in the District”, Dr. Eric Cook claims that the District of Columbia’s (D.C. or the District) newly implemented combined reporting tax regime is an effective means of increasing tax revenue from corporate taxpayers, but it will have… – Continue reading
