Category: Regulatory

Tax disputes: FinMin’s new mechanism for resolution should cheer foreign firms

NEW DELHI, JANUARY 2:  The dispute resolution mechanism for matters relating to international tax and transfer pricing has been streamlined. The Finance Ministry has put in place a new framework that seeks to bring much-needed rigour and neutrality to dispute resolution on international tax issues. The move should encourage multinationals… – Continue reading

Don’t run before you can walk – Russian deoffshorisation uncertainties

The new deoffshorisation legislation that passed with lightning speed through Russia’s Parliament and then hastingly signed by President Putin in the time span of a week and a half, comes into force on January 1, 2015. The new deoffshorisation legislation that passed with lightning speed through Russia’s Parliament and then… – Continue reading

The Outlook for Taxes in 2015

The new year could bring important changes to the tax landscape. Here are several issues that will affect how much taxpayers owe for 2015 and beyond: Federal tax policy There is serious talk of overhauling the federal tax code. “There appears to be a consensus” on making changes, says Stephen… – Continue reading

LuxLeaks: An opportunity?

BRUSSELS – As political honeymoons go, it was short and ended abruptly. Just one week into his job as European Commission president, Jean-Claude Juncker was broadsided by a series of newspaper articles outlining the depth and breadth of corporate tax avoidance schemes in Luxembourg. Schemes thought up and enacted while… – Continue reading

Financial institutions rush to meet FATCA deadline

A number of financial institutions rushed to meet a registration deadline after a late-night regulatory circular on Tuesday urged them to sign up with American tax authorities. The circular had advised registration by Thursday. The institutions have to do so under America’s Foreign Account Tax Compliance Act (Fatca). It requires… – Continue reading

Taxing times

Businesses in the island’s vital financial services are gearing up for ‘substantial changes’ dealing with tax. That was one of the important messages to come out of a seminar organised by KPMG in the island. More than 200 experts attended the event which covered a series of changes in property… – Continue reading

Financial institutions rush to meet FATCA deadline

A number of financial institutions rushed to meet a registration deadline after a late-night regulatory circular on Tuesday urged them to sign-up with American tax authorities. The circular came out on 30th December, and asked institutions to register by 1st January. The institutions have to sign up under the Foreign… – Continue reading

Cayman Islands: Government Issues Beneficial Ownership Report

The Cayman Islands Government today issued a report stating that it will continue its current method of providing beneficial ownership information to law enforcement, tax and regulatory authorities, as the method adheres to global standards. As explained in its Consultation Report on Maintenance of Legal and Beneficial Ownership Information, Government’s… – Continue reading

SA must not miss out on e-commerce tax revenue, says Davis committee

SOUTH Africa’s tax authorities need to beef up the country’s tax laws and regulations to ensure it derives its rightful dues from the digital economy and e-commerce, the Davis committee says. The committee’s interim report on base erosion and profit shifting, released for public comment last week, said gaps in… – Continue reading

Tax systems and the 183 days’ rule

The conditions for becoming tax-resident and tax non-resident vary from country to country and depend on such things as length of stay, type of accommodation, location of family, and nationality. In most tax systems, presence of an individual in a country for 183 days or more in any 12-month period… – Continue reading

Zero corporation tax: the arguments for and against

Once a niche proposal, the recent public focus on corporate tax avoidance has sparked real interest in the idea of eliminating corporation tax altogether. Surprisingly, the statistics suggest that employees and other stakeholders may also benefit from this In winter 2012, hundreds of activists packed inside their local Starbucks after… – Continue reading

New FATCA requirements apply to U.S. and non-U.S. insurers and insurance brokers on January 1, 2015

Summary New FATCA requirements that apply to U.S. and non-U.S. insurance brokers and insurance companies will take effect on January 1, 2015. Those requirements impose new information gathering and reporting rules when U.S. insurance and reinsurance premiums are sent outside the U.S. Background The Foreign Account Tax Compliance Act (FATCA)1… – Continue reading

Swiss banks target Israeli tax evaders

Swiss banks are training their crosshairs on Israeli customers. Legal sources said that in the past two weeks, the large banks in Switzerland have begun sending many queries to their Israeli customers demanding confirmation either that the assets deposited with the banks were reported to the Israeli tax authorities, or… – Continue reading

Internal Revenue Service Getting Tough on Production of Evidence From Current and Former Microsoft Executives In Connection With Its Transfer Pricing Audit

In recent court filings made in various federal district courts in Washington and California, the Internal Revenue Service is seeking to enforce testimonial summonses issued to current or former Microsoft employees, including former CEO Steven A. Ballmer. The summons had been issued earlier this fall. Microsoft’s outside tax counsel responded… – Continue reading

Asia to test bond record again in 2015

[HONG KONG] Asia could set another record for international bond issues in 2015 if Chinese companies continue to borrow offshore at the same voracious pace they did this year, while bankers expect a heavy redemption schedule and larger pipelines from India and Indonesia to lift activity. Barclays is forecasting volumes… – Continue reading

HMRC prolongs Contractor Loan Settlement Opportunity until June 2015

HM Revenue and Customs (HMRC) has confirmed it has extended the lifetime of the Contractor Loan Settlement Opportunity (CLSO), a chance for contractors to own up to using an offshore tax avoidance scheme, until 30th June 2015. The settlement opportunity was originally meant to be open until January 2015. HMRC… – Continue reading

IRS Adds FATCA FAQ On In-Substance IGAs

Within its list of frequently asked questions (FAQs) on issues associated with the requirements of the Foreign Account Tax Compliance Act (FATCA), the United States Internal Revenue Service (IRS) has provided added information for foreign financial institutions (FFIs) in jurisdictions with in-substance intergovernmental agreements (IGAs). FATCA, which was enacted by… – Continue reading

Analysis of Asia’s Tax Rates, Part 2: Withholding Tax

A withholding tax is a tax that is kept back from an employee’s salary and subsequently paid directly to the government. Withholding taxes are commonly employed by countries throughout the world to help combat tax evasion. Countries in Asia typically divide withholding tax into dividends, interest and royalties payments, with… – Continue reading

Vodafone transfer pricing case: Tax dept may not lose hope

The transfer pricing department is yet to make adjustments on share issuances by Vodafone India services to Vodafone Teleservices Mauritius for assessment year 2011 and 2012. The transfer pricing department has sought clarity from the government on legal recourse in the Vodafone transfer pricing case. Sources have indicated that the… – Continue reading

South Africa urged to finalise renegotation of Mauritius tax treaty

CAPE TOWN — South Africa needs to finalise the renegotiation of its tax treaty with Mauritius as soon as possible to prevent the loss of large sums of money through “treaty shopping” the Davis tax committee has urged. The committee released its interim report on ways to prevent base erosion… – Continue reading

Vatican Bank Complies With FATCA. St. Lawrence Pray For Us!

Forbes is reporting on the Vatican Bank’s decision under pressure to comply with the FATCA requirements for reporting on American citizen accounts. In his annual Christmas messages to more than one billion Catholics, the Pope may have left out something: offshore account compliance. Maybe, but the U.S. Treasury is more… – Continue reading

News Round Up

Currently, there is a tendency among those who take an interest in international tax developments to look to the future and try to guess how the international tax landscape will look in, say, three of four years, once countries begin to implement the OECD’s base erosion and profit shifting (BEPS)… – Continue reading

High hopes for Jokowi to boost tax revenues

Indonesia has only met its tax revenue collection target two times in the past 10 years, but President Joko “Jokowi” Widodo has vowed to transfer his past success in boosting tax revenue at the regional level in Jakarta and Surakarta to the nationwide level. Jokowi has laid out his plan… – Continue reading

London mayor’s unpaid tax bill provides food for thought

You may have heard in the news about Boris Johnson. He’s a flamboyant politician in the U.K. with an unruly mop of blonde hair. Recently, he made news by publicly saying he absolutely won’t pay his U.S. taxes. And yes, he is the mayor of London (the “real” London, where… – Continue reading

Josephine Feehily: unclear how tax changes will affect firms

Interview: Outgoing Revenue Commissioners head is proud of her time leading the department The international tax environment is still too unsettled for one to predict how any changes taking place will affect the State’s attractiveness for foreign direct investment, according to outgoing chairwoman of the Revenue Commissioners Josephine Feehily. Feehily… – Continue reading

Move to stop multinationals artificially loading debt overseas to dodge tax

The OECD is urging governments to tackle interest payments made by multinationals and their subsidiaries as part of a global crackdown on profit shifting. The aim is to also stop companies artificially loading debt in no-tax or low-tax jurisdictions to reduce their tax bills. It comes as the government backs… – Continue reading

The “Laffer curve” turns 40 years old

The informal Washington D.C. dinner that took place 40 years ago has become the stuff of legend. That’s when economist Arthur Laffer used a beverage napkin to sketch a chart that became known as the “Laffer Curve.” The following four decades proved Laffer’s point: People change their behaviors in response… – Continue reading

Tax evasion: Govt moves to make laws stricter

ISLAMABAD: The government has prepared draft bills to introduce amendments to four relevant laws to declare tax evasion as an offence related to money laundering, aimed at curbing misuse of foreign investment and remittance schemes. The step is being taken to meet a condition of the International Monetary Fund (IMF) that… – Continue reading

Canada transparency laws force ASX companies to disclose tax bills

Two Australian mining companies will be forced to disclose how much tax they pay in every country around the world by new transparency laws introduced in Canada. Paladin Energy and OceanaGold, both dual-listed in Australia and Canada, will have to comply with new Canadian laws requiring all oil, gas and… – Continue reading

India studying info provided by Cyprus on tax evaders

NEW DELHI, DEC 25: India will look at removing Cyprus from the blacklist of countries that do not share details about tax evaders after examining information given the island nation. India had blacklisted Cyprus last year for not sharing information about tax evaders. “They (Cyprus) have given some information. We are… – Continue reading

Swiss Bankers in Limbo After U.S. Jury Clears Ex-UBS Manager

The courtroom victory of the only Swiss banker to beat the U.S. in a trial over offshore tax evasion may embolden other indicted financial workers to leave a legal limbo some have endured more than five years. Twenty-five offshore bankers, lawyers and advisers have yet to answer U.S. Justice Department… – Continue reading

KPMG responds to transfer pricing ruling

KPMG has responded to the ATO’s recent taxation ruling TR 2014/8 (documentation requirements) and practice statements PSLA 2014/2 (penalties) and PSLA 2014/3 (simplification). Anthony Seve, KPMG transfer pricing partner, said the ruling places increased compliance and documentation obligations on larger companies. This, he said, is reflective of global developments. “Although… – Continue reading

Scorecard of Offshore Tax Crimes: Advisers, Bankers and Lawyers

A mixed success record has been notched up by the US Justice Department when it comes to prosecuting offshore bankers, advisers and lawyers accused of assisting American taxpayers cheat their taxes. The United States Government, from 2008, has charged 38 individuals, including Swiss bankers like the top three managers of… – Continue reading