The files at the foundation of the Swiss Leaks articles are based on data secreted away by Hervé Falciani, a former HSBC employee-turned-whistleblower. He turned the data over to the French government in 2008 and its tax authority launched an investigation. The French newspaper Le Monde obtained a version of… – Continue reading
The Minerals Council of Australia (MCA) has warned against international tax proposals, including changes to thin capitalization rules, that have been put forward by the Opposition in Australia. The Council said that any changes to the thin capitalization rules – which it said are already among the world’s most robust… – Continue reading
The former UBS Group banker whose cooperation with the United States has helped expose tax evasion by thousands of Americans says the Swiss bank used similar practices elsewhere and he’s eager to help European governments. “It’s not a US issue, it’s not a French issue, it’s a global issue. UBS… – Continue reading
THIRUVANANTHAPURAM, MARCH 4: The taxman has taken a headlong plunge into an alphabetic soup to comply/align with emerging tax and jurisdictional requirements, domestic and foreign, of which is GST is only one. Advance Pricing Agreements (APAs); General Anti-Avoidance Rules (GAAR); BEPS (Base Erosion and Profit Sharing); and POEM (Place… – Continue reading
Bermuda and other international financial centres are “routinely attacked and demonised” in Europe, according to Bermuda’s top financial regulator, reports the Royal Gazette. Jeremy Cox, chief executive officer of the Bermuda Monetary Authority, said in opening remarks in the BMA’s Business Plan 2015, published today, that it was “time for… – Continue reading
NUMBER OF THE WEEK: $42,268. The projected average taxable income of all tax returns in 2015, according to the Joint Committee on Taxation’s Feb. 27 report on “Fairness and Tax Policy.” The report also projects that the top ten percent (in terms of income) of all taxpayers in 2015 will… – Continue reading
Fiscal competition between EU member states could lead to the disintegration of the European Union, the chairman of the European Parliamentary tax rulings committee has warned In a recent interview, French MEP Alain Lamassoure said that such an outcome would be “unacceptable”. “Fiscal competition can be healthy when it contributes… – Continue reading
The Public Accounts Committee (PAC) met last month to ask HM Revenue & Customs (HMRC) about its efforts to curb tax avoidance, including how HMRC has developed its transfer pricing approach to counteract tax arrangements such as those by Google, Amazon and Starbucks. Present at the hearing on February 11,… – Continue reading
Helping tax cheats or money launderers has never been an integral strategy of the Swiss financial centre, Swiss Bankers Association (SBA) chief executive Claude-Alain Margelisch tells swissinfo.ch as the HSBC ‘Swiss Leaks’ scandal continues. The unsavoury activities of HSBC, UBS AG (NYSE:UBS) and others, brought into the public domain by… – Continue reading
Australia and Switzerland have signed a deal to swap banking information in a bid to crack down on tax evasion. James Bond hasn’t been kind to Switzerland. Swiss ambassador to Australia Marcel Stutz is keen to counter the image of his country being the preferred banker for baddies. Mr Stutz… – Continue reading
Hong Kong Financial Secretary, John Tsang delivered his eighth budget speech on 25 February 2015. Key Points: >Expansion of tax exemption for certain offshore investment funds >Tax concession for treasury centre activities on the way >Full steam ahead with implementation of OECD automatic exchange of tax information standard >Addressing Hong… – Continue reading
Italy has made a pact with Monaco aimed at clamping down on tax evaders, the finance ministry said in a statement on Monday. The agreement, which will see the two states exchanging information for tax purposes, follows similar ones made recently with Switzerland and Liechtenstein. It is expected to give… – Continue reading
Smaller companies, which innovate and create jobs, carry an unfair share of the burden In pre-revolutionary France aristocrats were exempt from direct taxation. On present trends the world’s elite corporations may soon find themselves similarly privileged. In the larger advanced countries the corporate tax base is eroding, partly because the… – Continue reading
An investment registration scheme launched by the government last year attracted a total of 1,469 valid registrations covering an aggregate of €455.8 million worth of eligible assets, The Finance Ministry told The Malta Independent. Of the total amount registered, €69.8 million or 15% of the total was repatriated following registration…. – Continue reading
Global entities liable to pay tax on yearly income if their place of effective management is India even for a single day Shell companies based abroad would have to pay taxes on their global income for a year if their place of effective management (POEM) is India even for a… – Continue reading
Bill Shorten, criticised for adopting a near invisible profile as Labor Leader, outlined a “policy brief” on Monday intended to tackle multinational tax avoidance and add nearly $2 billion to consolidated revenue over three years. The four-pronged approach includes changing the so-called thin-capitalisation rules allowing corporations to claim tax deductions… – Continue reading
Under Article 185, § 2, B of the Belgian Code on revenue taxes, an international group may ask for its taxes to be reduced by so-called excess profits, which are registered in the account of the Belgian entity as a result of the benefits of being part of an international… – Continue reading
Corporate tax reform has emerged as an area of potential bipartisan action in the United States Congress over the next few months. But fundamental questions about the right approach remain. There is widespread agreement that the US corporate tax system is deeply flawed. The rate is too high; the base… – Continue reading
In previous updates we have alerted clients to the introduction of Cayman Islands regulations1, which give effect to the automatic exchange of tax information principles established by the US and UK intergovernmental agreements (the “Cayman US Regulations” and the “Cayman UK Regulations”, respectively). While many Cayman Islands entities will be… – Continue reading
The Conversation Five years ago the Henry Review undertook a detailed examination of Australia’s tax and transfer system. Today, the Tax and Transfer Policy Institute at ANU’s Crawford School has revisited the Henry Review, as the Australian government prepares to release its tax white paper. Tax reform should not be… – Continue reading
In previous updates we have alerted clients to the introduction of Cayman Islands regulations1, which give effect to the automatic exchange of tax information principles established by the US and UK intergovernmental agreements (the “Cayman US Regulations” and the “Cayman UK Regulations”, respectively). While many Cayman Islands entities will be… – Continue reading
Government proposes to come out with a modified General Anti-Avoidance Rules by incorporating provisions of the OECD’s BEPS project so as to effectively deal with the problem of tax avoidance by MNCs. The BEPS initiative aims to ensure that taxes are paid where profits are made. Multinational companies use a… – Continue reading
When an economist presents his opinion to the public on any subject he should be asked to swear, similar to what witnesses do in a court trial, that he will follow Henry Hazlitt’s Lesson (Economics in One Lesson – Henry Hazlitt – 1946 – Harper & Brothers): “The art of… – Continue reading
As recommended by Tax Administration Reforms Commission (TARC) under Parthasarathi Shome, for taxation, the appellate functions must be housed separately from the field functions, in order to have fair and judicious orders passed. Indian Revenue should be divided into two distinct sets—the operational side and the technical/adjudication side. The quasi-judicial… – Continue reading
ROME, Feb. 27 (Xinhua) — Italian Economy Minister Pier Carlo Padoan signed a treaty on Thursday with Liechtenstein Prime Minister and finance minister Adrian Hasler in Rome, a measure which abolishes bank secrecy. The agreement, which helps identify potential tax evaders, was fundamentally the same as the one signed between… – Continue reading
Bank of America and four other banks have been queried by financial regulators about a complex trading maneuver that allows hedge funds to escape certain taxes. Reuters Financial regulators are heightening their focus on banks involved in complex international trades designed to skirt taxes, the Wall Street Journal reports. The… – Continue reading
Making tax-transparency standards watertight will be difficult THE optimistic view of the tax-evasion scandals that have bedevilled banks since 2008 is that they can only be seen in the rear-view mirror. The incriminating files in the latest case, regarding tax-dodging personal accounts held at the Swiss arm of HSBC, date… – Continue reading
IN THIS INSTALLMENT of our series on the Base Erosion and Profit Shifting (BEPS) initiatives of the Organization for Economic Co-operation and Development (OECD), we will tackle Action Plan 8 on the revisions to Chapters I, II and VI of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax… – Continue reading
On February 24, Seychelles became the 85th signatory of the Organisation for Economic Co-operation and Development’s (OECD’s) Multilateral Convention on Mutual Administrative Assistance in Tax Matters, reports Tax News. The Convention is described as a comprehensive multilateral instrument to tackle tax evasion and increase transparency. In a statement, the OECD… – Continue reading
Nationalist MEP says he will oppose any attempts to harmonise sensitive areas of taxation at a European level Taxation should remain the prerogative of European member states, Nationalist MEP David Casa said. “I will continue to oppose efforts at harmonisation at EU level of sensitive areas of taxation simply because… – Continue reading
In a February 20 letter to US Senate Majority Leader Mitch McConnell (R – Kentucky), the National Foreign Trade Council and other leading business organizations urged action on pending bilateral double taxation agreements (DTAs) and protocols. A coalition of ten business organizations, including the Business Roundtable, National Association of Manufacturers,… – Continue reading
Amid widespread condemnation of multinational profit shifting, Tax Commissioner Chris Jordan says the Australian Taxation Office is on track to recoup $1 billion in revenue from companies. The political pressure on the Tax Office and Treasury to stop companies such as Apple, Google and Microsoft from shifting profits to low-tax… – Continue reading
On February 25, South Africa’s Minister of Finance, Nhlanhla Nene, presented a 2015 Budget that was said to be constrained by a slowing economy and lower-than-expected tax revenues. Nene indicated that the Government now has to rebalance its fiscal policy to reduce the “structural gap” that exists between spending on… – Continue reading
When combined with aggressive tax planning, Hong Kong’s onshore-offshore tax regime often results in a reduced tax burden for taxpayers that operate through Hong Kong companies by pricing intra-group transactions. This has led to heightened transfer pricing scrutiny from the Hong Kong Inland Revenue Department in recent years. In order… – Continue reading
Amid global efforts to combat profit shifting. PRETORIA – In line with international efforts to combat tax avoidance, National Treasury on Wednesday said it is taking further steps to curb financial leakage. With government under pressure to collect more revenue amidst dwindling economic growth, Finance Minister Nhlanhla Nene on Wednesday… – Continue reading
Tax structure allowed McDonald’s to divert revenue for years, costing European countries over €1 billion in lost taxes between 2009 and 2013. Today in Brussels, a coalition of European and American trade unions, joined by the anti-poverty campaign group War on Want, unveiled a report about McDonald’s deliberate avoidance of… – Continue reading
HM Revenue and Customs (HMRC) will be given more substantial access to details of international bank accounts from next year as the tax authority steps up its efforts to crack down on offshore tax evasion. HMRC will receive information of overseas bank accounts held by UK taxpayers as part of… – Continue reading
A country known for its clocks, chocolate and most importantly banks, the agreement by Switzerland’s government to share details of those super-secret bank accounts is one that will change the world at large. Gone are the days of the elusive Swiss bank account. The arrival of Common Reporting is upon… – Continue reading
CRA recently released a new Transfer Pricing Memorandum (TPM-15) giving detailed guidance on CRA’s audit approach to management fees and other charges for intra-group services, including on allocation keys for indirect chargebacks and markups on costs. The document expands considerably upon brief guidance on this topic in CRA’s main Information… – Continue reading
Pact on information exchange in tax treatment Paris, February 25 – An important tax treaty signed between Italy and Switzerland is evidence of the “change of a crucial paradigm,” in banking secrecy with global implications, Pascal Saint-Amans, director of the center for tax policy and administration at the OECD told… – Continue reading
Thanks in part to past concerns that globalization could lead to double taxation, corporations have numerous techniques at their disposal to reduce their tax bills, including the placement of subsidiaries and spinoff holding companies in low-tax jurisdictions. The Group of 20 wants to change that. The Organisation for Economic Cooperation… – Continue reading
The government is set to make changes in the income tax rules to seek overseas operational details of multinational businesses that have a turnover of over R5,000 crore in India in order to decide which companies should be audited for income suppression, reports Gireesh Chandra Prasad in New Delhi. The… – Continue reading
Not long after the U.S. Department of Justice’s Tax Division (“DOJ”) made international headlines in 2009 for its bombshell announcement that it had entered into a deferred prosecution agreement with the United Bank of Switzerland (UBS), lawmakers in Washington, D.C. began reviewing the testimony of hundreds of UBS’s U.S. clients… – Continue reading
Jersey’s chief minister Ian Gorst has formally expressed his “disappointment” with statements from Labour Party leader Ed Miliband about tax transparency and disclosure efforts by UK overseas territories. In an open letter to the Opposition leader, Gorst said the Island government had reiterated “many times” in past discussions with the… – Continue reading
The government has been able to instil a positive sentiment in the country. Various policy initiatives like Make-in-India, aimed to make India a manufacturing hub, and the Clean India campaign; updating age-old laws and tweaking the Goods and Services Tax to a more acceptable form, introducing greater clarity in the… – Continue reading
BRUSSELS, Feb. 23 (Xinhua) — Member states need to pay more heed to coordinating their efforts in corporate taxation to combat tax evasion, said economic and financial affairs commissioner Pierre Moscovici on Monday. Moscovici said the European Commission (EC) had actively supported European member states in their efforts to secure… – Continue reading
The amendment of matriculation tax law in 2013 signaled a relevant change for charter operations in Spain: the possibility for non EU flagged vessels to be licensed in the Balearics, this change will allow not only EU but Non EU flagged vessels to operate from the Balearic Islands. Alex Chumillas… – Continue reading
São Paulo, Brazil. International transfer pricing is able to take place in Brazil, outside of the OECD While Brazil is not a member of the OECD, many multinational groups there are able to successfully navigate international transfer pricing standards, yielding effective results The economic view of Brazil has always been… – Continue reading
Eurozone finance ministers are expected to hold a conference call on Tuesday to weigh Greece’s new economic reform plans, raising expectations that they are inclined to sign off on a tentative deal to extend Athens’ €172bn bailout until June. The Greek list of economic reforms, due to be submitted to… – Continue reading
Transfer pricing policy in the United States is guided by Section 482 of the Internal Revenue Code (and by the Organization for Economic Cooperation and Development under its Base Erosion and Profit Shifting initiative), and its application is not limited to cross-border transactions. In fact, some states, such as New… – Continue reading
