Category: Regulatory

Leading Offshore Firm: The Inside View on the Cayman Islands Jurisdiction

MCC interviews three attorneys from Mourant Ozannes. Hayden Isbister is a partner and head of the Corporate practice in the Cayman firm. He specializes in investment funds, general corporate and commercial work. James Burch is a partner and leads the Structured Finance/Banks practice in the Cayman Islands, and Tim Dawson… – Continue reading

Hong Kong’s Advance Pricing Arrangement Program

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

British Virgin Islands: B.V.I. Company – Corporate Environment Summary

The British Virgin Islands is the most popular offshore jurisdiction, with favourable business regulations, a prosperous economy and a stable political situation. British Virgin Islands IBC, is a limited liability company which conducts its trading and business outside the British Virgin Islands and is intended for offshore activities. It takes… – Continue reading

Citigroup unit probed by more authorities over money laundering

[NEW YORK] Citigroup Inc said additional government authorities have started probes of possible breaches of anti-money laundering laws at its Banamex USA unit. The Financial Crimes Enforcement Network, a unit of the US Treasury, and the California Department of Business Oversight have asked the company for information on its compliance… – Continue reading

Treasury clamps down on tax leakage

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

Unhappy Meal: €1 Billion in Tax Avoidance on the Menu at McDonald’s

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

Italy Expects Tax Influx From Swiss Agreement

The signing of a double taxation agreement (DTA) protocol between Switzerland and Italy, which includes a provision for the exchange of information upon request, has fueled an expectation that the Italian Treasury will be able to collect substantial additional tax revenue this year. While it could take up to two… – Continue reading

The Common Reporting Standard: CRS brings the walls tumbling down

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

RBS staff under investigation from German authorities over Swiss tax evasion

Disclosure in bank’s annual results about Coutts comes as it reports seventh consecutive loss Royal Bank of Scotland was dragged into the Swiss tax evasion scandal on Thursday when it emerged that the taxpayer-owned company’s private bank is under investigation for helping wealthy clients evade tax. The small print of… – Continue reading

Listed Guernsey and Jersey funds – FATCA reporting deadlines are looming. Are you ready?

INTRODUCTION 2015 is with us and looming is the 30 June 2015 deadline for the first reports of FATCA information under the reporting regimes that have been put in place in both Guernsey and Jersey to ensure compliance with the US/Guernsey and US/Jersey Intergovernmental Agreements regarding FATCA (“the US IGAs”)…. – Continue reading

HSBC chiefs to testify in tax scandal on tax evasion

First there was money laundering, then foreign-exchange rigging and now tax evasion. Politicians and analysts are asking if big banks became too big to manage from being too large to be allowed to fail HSBC Europe’s biggest bank, has endured a string of scandals and paid millions in penalties to… – Continue reading

CRA Releases Important Transfer Pricing Guidance on Management Fees and Other Intra-Group Services

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

New Non-adversarial Tax Regime: India Shows a Way

Mr. Akhilesh Ranjan, Joint Secretary Ministry of Finance, and also Competent Authority for the Government of India, spoke this past week at the Pacific Rim Tax Institute, February 19-20, reaffirming India’s commitment to a new non-adversarial tax regime to encourage foreign investment and fair treatment of taxpayers. Mr. Ranjan’s appointment,… – Continue reading

OECD says Italy-Swiss treaty helps end bank secrecy -update2

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

OECD Seeks Change In Global Taxation

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

FATCA: The End of ‘Shadow Boxing’ in the Offshore Trust Industry

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

Is international tax planning for contractors illegal or immoral?

The differentiation between tax avoidance, tax evasion and the moral duty to pay tax for the betterment of society has been intentionally screwed by politicians and bureaucrats. This is nothing new. I wrote an couple of articles several years ago questioning the terminology of ‘morally repugnant’ tax avoidance when it… – Continue reading

Jersey chief minister ‘disappointed’ at Miliband letter

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

Union Budget: Clear the confusion on transfer-pricing norms

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

EU official calls for more efforts from member states to combat tax evasion

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

How to navigate transfer pricing in Brazil; Deloitte advises

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

FIU not investigating US$54.8 mil in Swiss accounts

BELIZE CITY, Mon. Feb. 23, 2015–It’s far easier to move money from Belize via an offshore company than to deposit those funds in a local commercial bank, especially with more stringent banking requirements which have been implemented as part of the new anti-money laundering regime here in Belize. If a… – Continue reading

Key Bahrain-India deals to bolster ties

Bahrain and India have signed agreements to increase co-operation in the areas of education, investment, defence and other sectors. It took place during the first meeting of the India-Bahrain High Joint Commission (HJC) in New Delhi, said a report in the Gulf Daily News (GDN), our sister publication. The Bahrain… – Continue reading

Was Bank Leumi too hasty in revealing U.S. clients’ info to the IRS?

The issue of whether Israeli banks should take the Swiss approach and refuse to disclose customer identities may be a moot point, in light of a new international anti-tax-evasion treaty that is taking shape. There is a direct line connecting the disclosure of the identities of 6,200 Israelis with Swiss… – Continue reading

2 Investments to Avoid in Your IRA

IRA plans can be excellent ways to save for retirement, but there are some investments to avoid if you want to take full advantage of IRA tax savings. Two that come immediately to mind are tax-exempt municipal bonds and high-yielding stocks from foreign countries with dividend withholding taxes. Tax-exempt municipal… – Continue reading

Transfer Pricing Audits: With Changes on the Horizon, Upfront Planning Is Key

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

Everything U.S. Expats Need to Know About IRS Tax Forms (But Were Afraid to Ask)

This is the time of the year for millions of Americans to begin the annual ritual of gathering information about income, taxes, charitable giving, health insurance, expenses and sundry other items, and prepare to send mountains of information to the IRS –and to those who prepare their tax returns. Overseas… – Continue reading

‘Don’t over-complicate tax laws’

Attempt to plug every gap makes the system unworkable – Norton Rose Fulbright. JOHANNESBURG – A tax expert has warned against over-complicating tax legislation in an attempt to block every loophole or perceived underpayments of tax, as it makes the tax system “unworkable”. Andrew Wellsted, director at Norton Rose Fulbright,… – Continue reading

Argentine Tax Authority Says It’s Seeking Arrest of Miguel Abadi

(Bloomberg) — Argentine tax authorities said Sunday they are seeking the arrest of money manager Miguel Abadi for alleged involvement in an offshore investment network designed to avoid paying taxes. The agency, in a statement, said it’s seeking information from tax agencies in the Virgin Islands, Uruguay and Bermuda about… – Continue reading

500 accounts frozen under Anti-Money Laundering Act on FIA request: SBP blocks suspicious transactions of $65m

ISLAMABAD: The State Bank has blocked the suspicious transactions of $65 million originating from Malaysis after finding a suspicious transaction report (STR). The National Action Plan on counter-terrorism requires strict monitoring of banking transactions and active coordination among federal and provincial investigation agencies. So far about 500 accounts are reported… – Continue reading

Does tax avoidance among global corporates put UK SMEs at a disadvantage?

The spotlight is firmly on tax reduction among large global firms operating in the UK – but is the practice putting smaller domestic companies on the back foot? The HSBC tax scandal, wilfully fuelled by politicians looking to appear tough on what they call immoral tax practices, has put the… – Continue reading

Terry Baucher says a ‘rare generational shift’ is taking place in international tax – and the implications will be felt for decades

When I consider what’s likely to have the most impact in tax this year, I keep coming back to the massive shift in attitude by tax authorities in the aftermath of the Global Financial Crisis (GFC). Usually changes in the tax world are incremental, but what is going on now… – Continue reading

US, Dominican Republic start tax info exchange

Santo Domingo.- The US Internal Revenue Service (IRS) and Dominican Republic’s Internal Taxes Agency (DGII) have begun a process to exchange bilateral financial and tax information, as part of the on Foreign Accounts Tax Compliance Law (FATCA). A delegation of the IRS’ International Cooperation Program led by its senior manager… – Continue reading

Ministers sign Italian-Swiss tax treaty

Switzerland and neighbouring Italy have revised a double taxation agreement which includes provisions for the exchange of information in line with the standards of the Organisation for Economic Development and Co-operation (OECD). The accord and a roadmap for the amendment of tax rules on cross-border workers as well as improved… – Continue reading

The Quiet Man Who Made Big Trouble for Little Luxembourg

Antoine Deltour sees himself as “just a little auditor” who copied some tax files. Now he may face jail after those documents helped send a shock wave through Luxembourg that is reverberating across the European Union. (Bloomberg) — Antoine Deltour sees himself as “just a little auditor” who copied some… – Continue reading

HSBC Says Gulliver Paid Taxes After Opening Swiss Account

(Bloomberg) — HSBC Holdings Plc, struggling to contain a political storm over the bank’s facilitation of tax evasion through its Swiss unit, said Chief Executive Officer Stuart Gulliver paid taxes after setting up his own Swiss account and keeping his legal residence in Hong Kong. The bank, reacting to an… – Continue reading

double taxation india money laundering pakistan switzerland uk

Tax collections, so maintains the Federal Minister for Finance Ishaq Dar, have improved significantly and he cited a healthy growth rate of around 13 percent in one of his recent press conferences. Sources within the Ministry of Finance, however, revealed to Business Recorder, but on condition of anonymity that the… – Continue reading