Category: Regulatory

Malta halves EU property residency requirement

Malta’s High Net Worth Individual Rules for EU, which carried a minimum property investment of €400,000, has been replaced by the Global Residence Programme, with an entry point as low as €220,000 Malta has announced a new residency programme for EU nationals – and has halved the minimum property purchase… – Continue reading

No request to retrieve ‘$200 billion’ in Swiss banks, says Swiss envoy

ISLAMABAD: Pakistan has not requested for negotiations on exchange of information for restitution of any ill-gotten money presumably stashed in Swiss banks, said Swiss Ambassador to Pakistan and Afghanistan Marc George on Monday. The statement from the Swiss ambassador follows claims by Finance Minister Ishaq Dar that talks would be held with… – Continue reading

Facing up to Fatca

This article was first published in the 2nd quarter 2014 edition of Personal Finance magazine. Most people accept that they have to pay taxes in their country of residence. But citizens of the United States and green card holders who live outside that country – even if they have never… – Continue reading

Tax Fugitives Brought To Justice By HMRC

The organisation hails the capture of five more of its most wanted as “excellent news for all honest taxpayers”. Five of the UK’s top tax fugitives have been brought back to the UK to face justice following a global HM Revenue and Customs (HMRC) initiative, the organisation has said. HMRC… – Continue reading

Protecting Expat Cash In Offshore Savings Accounts

Expat savers dealing with unfamiliar banks are unlikely to know how much of their cash is protected if the foreign bank goes bust. In Britain, the Financial Services Compensation Scheme (FSCS) safeguards up to £85,000 held by each person in accounts under a single banking licence. Each building society has… – Continue reading

European states may bring in their own version of FATCA

BEIRUT: Some bankers have said that European states are expected to follow the example of the United States and ask their citizens abroad to disclose their bank accounts to European financial authorities in a bid to combat tax evasion. “It’s not official yet but we expect some European countries to adopt similar… – Continue reading

The Biggest Tax Scam Ever

I n July, the American pharmaceutical giant AbbVie, maker of the world’s top-selling drug – the arthritis treatment Humira – reached a blockbuster deal to acquire European rival Shire, best known for the attention-deficit medication Adderall. The merger was cheered by Wall Street, not for what the deal will do… – Continue reading

Expatriate Tax Sense or Broad-Brush Overreach: The U.S. Foreign Account Tax Compliance Act (FATCA)

An effort to control tax havens for those hiding their assets overseas has resulted in broad brush impacts on hard-working expatriate Americans living and working out of country. The previously delayed Foreign Account Tax Compliance Act (FATCA) is now in full swing effective July 1, 2014. In an attempt to close a… – Continue reading

Bern talks to focus on taxation treaty

ISLAMABAD: Pakistan and Switzerland will begin technical level negotiations in Bern on Tuesday for revision of ‘Swiss-Pakistan Convention for the Avoidance of Double Taxation’ to enable the treaty to create an environment for better trade and investment between the two countries. The three-day meeting is being held on the request… – Continue reading

Germany-Israel Update Double Tax Arrangements

Israeli Finance Minister Yair Lapid and his German counterpart, Wolfgang Schäuble, signed a revised German-Israeli double taxation agreement in Berlin on August 21, 2014, according to a recent announcement from the German finance ministry. The convention, which was last amended in 1977, has been adapted to make it correspond to… – Continue reading

Govt eyes more tax holiday deals

FRANCISTOWN: Government’s negotiations with other countries to sign Double Taxation Avoidance Agreements (DTAA) are underway to ensure investor benefits from tax holiday incentives continue, Boniface Mphetlhe of Ministry of Trade and Industry (MTI) has said. The Deputy Permanent Secretary in MTI, Mphetlhe, was speaking on the topic of Botswana Investment… – Continue reading

Lichtenstein-based VP Bank pulls Swiss arm out of United States programme on tax evasion

VP Bank said it had now concluded that it no longer needed to take part in the programme. “Thorough internal investigations and external expert opinions showed that the conditions for continued participation did not exist,” the Liechtenstein-based bank said in a statement accompanying its half-year results. “VP Bank therefore withdrew… – Continue reading

Broken levy: How U.S. tax law encourages inversions

An innocuously named species of transaction has inspired a political furor this summer. After a number of U.S. companies announced plans to move overseas in so-called inversion deals, Sen. Carl Levin proposed banning them outright. President Barack Obama called the companies unpatriotic. Because of the controversy, Walgreen Co. backed away… – Continue reading

United States: FATCA’s Impact On Preparing Trusts With Offshore Business or Investment Activities

The Foreign Account Tax Compliance Act (FATCA) was enacted into law as part of the Hiring Incentives to Restore Employment (HIRE) Act of 2010. Its purpose was designed to prevent U.S. taxpayers from “hiding” under the cover of a foreign based entity or trust in evading U.S. income tax and… – Continue reading

Twitter Spain shifts profits to Ireland

Twitter is the latest major internet multinational to have opened up a Spanish subsidiary. But the popular micro-blogging site has followed in the footsteps of Google, Apple, Facebook and Linkedin, all of whom keep their Spanish corporate taxes down to the bare minimum by shifting their income to Ireland. Created… – Continue reading

United States: FATCA’s Impact On Preparing Trusts With Offshore Business or Investment Activities

The Foreign Account Tax Compliance Act (FATCA) was enacted into law as part of the Hiring Incentives to Restore Employment (HIRE) Act of 2010. Its purpose was designed to prevent U.S. taxpayers from “hiding” under the cover of a foreign based entity or trust in evading U.S. income tax and… – Continue reading

Whopper? Microsoft Skirts Billions In Taxes, Google, HP & Apple Have It Their Way Too

With all the talk about inversions and America’s Burger King Going Canadian, it’s easy to ignore even more prevalent tax savings by numerous American companies. Take Microsoft, which admits in its 2014 SEC filing that it avoids $30 billion in U.S. taxes. The trick? Keep about triple that amount, $93… – Continue reading

101 Countries Sign Up For FATCA Network

Foreign Account Tax Compliance Act (FATCA) has been in force for a month and still more countries are joining the tax network. So far, 101 countries and financial jurisdictions have either signed or agreed to join FATCA. FATCA is aimed at identifying US taxpayers with offshore bank accounts and investments. Overseas… – Continue reading

BEST OF 2014 SO FAR: Hostile Tax Legislation Is Driving Non-Doms Out Of The UK – Stephenson Harwood

(Editor’s note: As the summer holidays wind down, we thought readers might appreciate a chance to revisit some of the stronger, and more controversial, items that have been published on this news channel since the start of what has been an eventful year.) Since the financial crisis, governments worldwide have… – Continue reading

Microsoft has nearly $93 billion in overseas cash, and it’s reduced its tax bill by almost $30 billion

Microsoft’s stash of cash stored overseas, not subject to US taxes, is growing. In its latest regulatory filing, the software giant said it has now stockpiled $92.9 billion offshore and that this money could have cost the company $29.6 billion in taxes, but didn’t. That compares to $76.4 billion from… – Continue reading

Burger King-Tim Hortons: Is Canada becoming a corporate tax haven?

Potential inversion deal highlights dropping corporate taxes in Canada, now the lowest among 10 countries, with the U.S. in 5th place. Fast-food giant Burger King faced anger from both Washington and average Americans Monday, a day after it announced that it was in talks to buy Tim Hortons and relocate… – Continue reading

The Global Crackdown on Profit Shifting

CFOs of multinationals need to prepare by assessing how much their companies engage in profit shifting to cut their taxes. Do you have responsibility, whether direct or dotted line, for the tax function in your company? Does your company have, or plan to have, operations outside the United States? If… – Continue reading

The BEPS Initiative: Redefining International Tax Planning?

Technology companies frequently possess an international tax footprint before expanding their domestic tax footprint.  That may soon change as the Organisation for Economic Cooperation and Development (OECD) and its G20 member countries undertake an ambitious agenda to fundamentally alter the international taxation system.  The OECD released its Action Plan Addressing… – Continue reading

Fake reception prompts probe

A political candidate has sparked the Reserve Bank and the Financial Markets Authority to visit a foreign-owned company offering “secret” offshore accounts. Grace Haden, an independent standing for election in Epsom, raised concerns with the regulators about Breder Suasso, which is referred to on overseas websites as a New Zealand… – Continue reading

Double Tax Arrangements in Nigeria: Imperatives for a wider network

THE National Tax Policy (NTP) has identified double taxation as one of the major hindrances to the growth of the Nigerian economy. Double taxation has become an issue paramount to investors and top executives of multinationals as income is generally taxable both in source and residence countries. In order to… – Continue reading

Bosses flee Vietnam, ignoring debts and taxes

VietNamNet Bridge – The bad news about tax evasion and debt repudiation cases by foreign invested companies has darkened Vietnam’s foreign direct investment (FDI) landscape. Tuoi Tre newspaper has reported that Austrian Harald Biebl, director of the HCM City-based Bach Hop Company, operational in Vietnam since 2005, has fled the… – Continue reading

G20 to press for ‘rapid timeline’ for exchange of tax information

NEW DELHI: G-20, a group of developed and developing nations, is likely to press for adoption of “rapid timelines” by different countries for automatic sharing of information with a view to curb tax evasion. The issue of automatic sharing of tax information would figure prominently during the meeting of G-20… – Continue reading

FATCA Alert: IRS Issues Final Version of the Form W-8BEN-E and Accompanying Instructions

On June 25, 2014, the IRS finally issued the instructions to the new version of Form W-8BEN-E, an 8-page withholding certificate to be completed by foreign entities. Previously, foreign individuals and most foreign entities would provide a one-page Form W-8BEN to withholding agents to certify the foreign entity’s entity classification… – Continue reading

Review of patent tax regimes in EU has Irish support

Ireland can adopt ‘wait-and-see’ approach on tax breaks, says Department of Finance Ireland supports the EU review of all patent box regimes – under which certain member states offer tax breaks for intellectual property – and has decided to take a “wait-and-see approach” on the issue until guidance is provided… – Continue reading

5 Year Prison Sentence for Former LR Attorney for Mail Fraud, Tax Evasion

LITTLE ROCK, AR –Former Little Rock attorney David Patrick Henry, Sr., 71, has been sentenced to five years in prison followed by two years of  supervised released, according U.S. Attorney Christopher Thyer.  Henry, Sr. is also ordered to pay over a million dollars. On March 21, a federal jury found… – Continue reading

Billionaire Eugene Melnyk: I’m a ‘whistleblower’ on tax allegations against Valeant

MONTREAL • Eugene Melnyk, the billionaire owner of the Ottawa Senators and founder of drug maker Biovail Corp., is waging war against the company that now controls his one-time business. Mr. Melnyk alleges that Valeant Pharmaceuticals International Inc. is masquerading as a Canadian company to make use of this country’s… – Continue reading

First landmark ruling on Indian indirect transfer taxes! Delhi High Court restricts their applicability

The Delhi High Court upholds the non-taxability of gains from sale of shares of overseas entities by the Copal Group to the Moody’s Group. Interpretation of the indirect transfer tax provisions in a restrictive manner. 50% threshold for substantiality based on guidance by OECD/ UN material and Shome Committee Report… – Continue reading

Scottish Parliament passes legislation establishing Scotland’s first tax collection system for 300 years

Legislation which will establish and govern Scotland’s first tax collection system in 300 years has been passed by the Scottish Legislation which will establish and govern Scotland’s first tax collection system in 300 years has been passed by the Scottish Parliament.21 Aug 2014 The Revenue Scotland and Tax Powers Bill… – Continue reading

Leading Liverpool tax specialist aids guidance in new HMRC tax fraud policy

Those committing tax evasion could face stricter consequences due to the change in government tax legislation, according to a top city accountant. Des Veney, Director of Haines Watts Chartered Accountants on Victoria Street, believes that as a result of the stern regulation, which came into effect earlier this month, UK… – Continue reading