Category: Government Bodies

China: Asia Tax Bulletin – Spring 2015

CHINA Tax Free Reorganisations • With circulars 109 and 116 jointly issued in December 2014 by the Ministry of Finance and the State Administration of Taxation, the Chinese authorities have relaxed the conditions for internal reorganisations. • Circular 109 deals with internal reorganisations. Provided the pertinent requirements are met, the… – Continue reading

GLOBAL INFO EXCHANGE MUST TO CURB TAX EVASION, INDIA TELLS G-20

The Union Finance Minister, Arun Jaitley, expressed concern over transfer pricing and several other measures taken by MNCs to avoid paying tax on international transactions. The Dollar Business Bureau Stressing on the need to keep a check on tax evasion by multi-national companies (MNCs), India has asked the G20 members… – Continue reading

Global information exchange must to curb black money: Jaitley

Washington, April 20 (IANS): Finance Minister Arun Jaitley here has sought urgent implementation of the automatic exchange of financial account information globally to tackle the menace of black money. “We strongly feel that there is a need to ensure that the common reporting standards on automatic exchange of information should… – Continue reading

United States: As Tax Rules Shift, Companies Need Flexible Structures And Strategies

Technology companies with international operations are increasingly using global tax avoidance methods, despite growing opposition from the public and politicians in the U.S. and abroad. As this opposition fuels ongoing changes in tax rules, organizations must be able to quickly adapt their corporate structures and tax strategies to maintain a… – Continue reading

Netherlands: No Fixed Tax-Free Allowance For Expatriate Employees Living Close To Dutch Border

The European Court of Justice recently ruled that the Netherlands may restrict the 30% fixed tax-free allowance for expatriate costs to employees living more than 150 kilometres from the Dutch border. The 150-kilometre restriction does not restrict the free movement of employees within the European Union. Consequently, an employer and… – Continue reading

Black money: Global automatic information exchange only way to combat tax evasion, says FM Arun Jaitley

Finance Minister Arun Jaitley has sought urgent implementation of common reporting standards on automatic exchange of information globally, asserting that it is the only way to tackle the challenges posed by black money and stop tax evasion. The problem of offshore tax evasion and flow of illicit money can be… – Continue reading

Cyprus: Cyprus’s New Double Taxation Agreement With Bahrain

On 17 March 2015 Cyprus and Bahrain signed a new double taxation agreement. Like all of Cyprus’s recent DTAs it closely follows the 2010 OECD Model Tax Convention. Its main provisions are summarised below. Taxes covered The agreement applies to taxes on income imposed by either country. In Bahrain these… – Continue reading

We are not a rock-island offshore financial centre, says Mauritius

In response to Pranay Gupte’s story on a story published by Firstpost, the Secretary to the Mauritius cabinet, S Seebaluck, has rebutted some of the points made in the story titled: “Mauritius cracks whip on Muslims, not a’ role model of democracy’ as PM Modi said after all.” The following… – Continue reading

Australia must break the shackles of intellectual property in FTAs

Last week some of Australia’s biggest and richest companies voluntarily fronted up to a senate inquiry on corporate tax avoidance. Bigwigs from big brands, including Apple, Google, Microsoft, Rio Tinto, BHP Billiton and Fortescue Metals, squirmed under the spotlight as they were grilled about how they (legally) shift profits offshore… – Continue reading

South Africa Guides On Corporate Residency

The South African Revenue Service (SARS) has issued a revised draft interpretation note that discusses the principles and guidelines for the considering the “place of effective management” in determining the tax residence of a company. SARS points out that the concept of residency is critical in determining a company’s South… – Continue reading

Treasurers should provide transaction documentation according to BEPS

Corporate treasury departments will have to start complying with International tax rules and provide documentation for transactions according to recent reports. G20 leaders attempted to reform the international tax system in July 2012 by setting up the Base Erosion and Profit Shifting (BEPS) project. This task was given to the… – Continue reading

China-led bank starts with 57 members

BEIJING: A total of 57 countries have been approved as founding members of a Chinese-led infrastructure bank, Beijing said on Wednesday, and Norway is included despite frosty relations over a Chinese dissident’s Nobel prize. No nations that formally sought to become founding members of the Asian Infrastructure Investment Bank (AIIB)… – Continue reading

16 of top 50 European hedge funds donate more than £6.5m to Tories

All of the firms have established funds based in offshore tax havens such as Cayman Islands and Jersey, analysis reveals Sixteen of the top 50 European hedge funds or their executives have donated more than £6.5m to the Conservatives, according to a new analysis of data. All of the firms… – Continue reading

Portugal: New Rules For Portugal’s Golden Visa Residence Programme

In October 2012 Portugal launched its Golden Visa Residence Programme with the aim to provide prospective Non-EU foreign investors with the opportunity to take up residency in Portugal through investment. Recently, the Portuguese Parliament promulgated a set of new rules pertaining to this particular programme. The said rules are still… – Continue reading

Your Taxes: OECD helping governments collect more taxes

Israel joined the OECD in 2010. Background The Organization for Economic Cooperation and Development is spearheading a concerted effort to help governments around the world collect more taxes. The OECD is doing so by issuing a series of recommendations for tightening up corporate and personal tax measures. Individual governments are… – Continue reading

OECD: employment tax burdens rise despite static income tax rates

Taxes have risen by around one per cent on the average worker’s wage in Organisation for Economic Co-operation and Development (OECD) countries since 2014, although the majority of governments have not increased income tax rates, the OECD has said. In its Taxing Wages 2015 report, the OECD looks at the… – Continue reading

Tax Directors Expect Their Companies to Expand

Tax directors at many organizations anticipate their companies will grow by entering into new domestic and international markets in the years ahead, according to a new survey by BDO USA. In a sign of an improving economy, 50 percent of the 100 tax directors at $1billion-plus public companies surveyed by… – Continue reading

Cameron crackdown on tax havens ‘purely political gesture’, says Tory peer

David Maclean, Baron Blencathra, wrote to Cayman Islands in 2014 that transparency push was to head off G8 pressure and EU’s financial transaction tax A Conservative peer has described David Cameron’s flagship G8 anti-tax avoidance initiative as a “purely political gesture” designed to head off European attempts to curb the… – Continue reading

Guernsey removed from Italian tax blacklist

The Italian Ministry of Finance has removed Guernsey from its revised tax blacklist. Amendments within the 2015 Finance Act mean that the anti-tax haven deduction blacklist has been revised to exclude all countries that have an adequate exchange of information with Italy. Sinéad Leddy, Head of Technical at Guernsey Finance,… – Continue reading

Administration Proposes to Repeal Deferral, Haircut the Foreign Tax Credit and Interest Expense Deductions, Override Treaties, and Abandon Arm’s-Length Transfer Pricing for Intangibles

As the above title indicates (it is only a modest exaggeration), the Treasury Greenbook regarding the FY 2016 budget proposes a radical restructuring of the system for U.S. taxation of foreign income of U.S. multinational enterprises (MNEs). Some Congressional players have suggested that these proposals are an opening bid in… – Continue reading

Individual Tax Burdens Continued To Rise In 2014

Taxes on wages have risen by about one percent for the average worker in OECD countries between 2010 and 2014, even though the majority of governments did not increase statutory income tax rates, according to the Organisation for Economic Cooperation and Development’s (OECD’s) Taxing Wages 2015 report. According to the… – Continue reading

Tax Directors Anticipate Domestic and Cross-Border Growth Over The Next Three Years, According To The Inaugural BDO Tax Outlook Survey

– Rising Cost of Compliance Within The Tax And Financial Regulatory Environment Creates Opportunities For Increased Efficiency – CHICAGO–(BUSINESS WIRE)–As the economy continues to accelerate, many organizations plan to grow by entering into new markets in the years ahead, reveals the first ever BDO USA, LLP Tax Outlook Survey. Fifty… – Continue reading

Canada: Private Client Tax, Third Edition – Chapter: Canada

1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins Canada is a federal state, with legislative powers divided between the federal and provincial governments. The federal government has legislative jurisdiction over issues concerning Canada as a whole, including foreign affairs, international trade, banking, telecommunications,… – Continue reading

Social networking sites to become work places

The Revenue Office will take steps to tax social networking sites and implement other regulations related to e-commerce. After the implementation of this regulation, all such virtual sites will be deemed as “work places” and the advertisers of social networking sites will also be deemed as “electronic tax payers.” Moreover,… – Continue reading

UAE MoF and UAQ FTZ sign MoU on international OECD tax regulations

The Ministry of Finance (MoF) recently signed a memorandum of understanding (MoU) with Umm Al Quwain Free Trade Zone Authority (UAQ FTZ). This agreement has been signed to ensure international standards of transparency in the exchange of information for tax purposes, as per Organisation for Economic Cooperation and Development (OECD)… – Continue reading

Legal flash – Shanghai office – March 2015 – Announcement of the State Administration of Taxes concerning enterprise income tax on fees resident enterprises pay to overseas related parties

In recent years, the State Administration of Taxes (“SAT”) has paid closer attention to fees resident enterprises pay their overseas related parties, concerned that multinational groups have shifted profits away from China through aggressive tax planning and by paying unreasonable service fees and royalties overseas. Following PRC’s active participation in… – Continue reading

Indian banks make a beeline for space in Gujarat’s Gift City

Bank of India, Bank of Baroda, Corporation Bank, Punjab & Sind Bank, HDFC Bank and many others have signed up for space in Gujarat’s International Finance Tec-City (also known as Gift City). In fact, banks are expected to be the first to kick off operations in 2016/17, when the International… – Continue reading

Peter Jones: Ridiculous, dangerous, unworkable

The SNP’s much-vaunted plan for full fiscal autonomy would land Scotland with more austerity, not less, writes Peter Jones More and more, the SNP’s plans for Scotland to achieve full fiscal autonomy are looking ridiculous (contradictions abound everywhere), dangerous(savage cuts in public spending would be inevitable) and unworkable (gaps cannot… – Continue reading

We are not policemen

The reporting obligations imposed on lawyers are inconsistent and confused. Tax avoidance has become a central issue in the election campaign. So what is usually a topic for a small, specialist group of lawyers has become an item of general interest. And, yes, there is a strong link to lawyers’… – Continue reading

Central Register of Beneficial Ownership to be Introduced in the UK

On 26 March 2015, the United Kingdom Parliament passed into law the Small Business, Enterprise and Employment Act 2015 (the “Act”). The Act will bring about a number of fundamental changes to UK company law including, amongst others, the abolition of bearer shares and corporations acting as directors and, perhaps… – Continue reading

Cayman Islands: Don’t Get Snowed In By GATCA

Offshore investment entities in the Cayman Islands and many other international financial centers should now start turning their attention to compliance with the Common Reporting Standard (“CRS”) promulgated by GATCA – Global FATCA. They must document all account holders existing on December 31, 2015, with the exception of entities with… – Continue reading

No one said reform was easy:Cormann

Finance Minister Mathias Cormann insists the government is not shying away from reform despite a tough year selling its first budget. Senator Cormann says pursuing important economic reform is a “marathon, not a sprint”. “If it was easy, anyone could do it,” he told Sky News on Sunday. Senator Cormann… – Continue reading

The Baltic States and Greece: Divergent Crises

It has become increasingly fashionable to compare the results of Greece and the Baltic States’ response to the financial crisis of 2008, most recently last month with the Financial Times’ column with John Dizard. This, however, is a classic textbook case of comparing apples to oranges. Greece’s crisis was chiefly… – Continue reading

The escalating costs from the many tax loopholes

Listed companies in developed market could be avoiding as much as $82b annually London: Listed companies in developed markets are avoiding at least $82 billion (Dh301 billion) of tax a year by using tax havens and other minimisation strategies, according to detailed analysis of more than 1,000 businesses. The revelation… – Continue reading

Senate tax inquiry: Google, Apple, Microsoft policies highlight golden days of tax laxness

There was a moment on Tuesday evening – hours before the first public hearing of the Senate inquiry into corporate tax evasion – when Treasurer Joe Hockey and his advisers should have sensed a firestorm approaching. Sandwiched between a story on a Gold Coast diet blogger accused of pinching other… – Continue reading

France, German sign double tax treaty changes

BERLIN: The Governments of France and Germany signed an amendment to the France-German treaty dated (the “Treaty”), which will have an impact in the future for certain investments in real estate. For France, this amendment follows the amendment to France-Luxembourg signed on 5 September 2014 which also impacts foreign investments… – Continue reading

Australian Senate tax grandstanding: A preparation for austerity

An Australian Senate parliamentary committee hearing on Wednesday was dominated by the fire and brimstone of Labor and Greens politicians directed against tax avoidance by major corporations. Labor Senator Sam Dastyari called on Australian Tax Commissioner Chris Jordan to “name some of Australia’s worst corporate offenders,” declaring that they “should… – Continue reading