Category: Regulatory

Luxembourg: Tax Dispute Resolution Mechanism

The Bill of Law 7431 (“Bill”) introduced by the Luxembourg government on 11 April 2019 implements the European Union (“EU”) Directive 2017/1852 dated 17 October 2017 on tax dispute resolution mechanisms in the EU (the “Directive”). The Directive meets the BEPS Action Plan 14 minimum standards and is a subsidiary… – Continue reading

India: Split Residency – ITAT Upholds The Taxpayer’s Claim For Treaty Exemption, Applies Centre Of Vital Interest Test

Dual Residency gets attracted when an expat in the year of move qualifies as a resident of the host country (i.e., the country in which he is deputed) as well as home country (i.e., the country of his residence). On account of dual residency, an expat can be doubly taxed… – Continue reading

Canada: With Recent Regulatory Developments, Canadian Business Interest In Cayman Will Grow

Canada is home to some of the largest multinational corporations in the world, a bustling pension fund and private equity industry, and growing numbers of alternative investment, real estate, and insurance shops. With dynamic industry and growth in the region, Canadian business leaders are leveraging Cayman as a financial centre to help… – Continue reading

NBR building up profiles of MNCs

National Board of Revenue is building up profiles of the multinational companies operating in the country for the purpose of conducting audits on the MNCs’ accounts to prevent tax evasion through misuse of transfer pricing system. Transfer Pricing Cell (TPC) of NBR is also conducting risk assessment of the companies’… – Continue reading

United States: IRS Faces Big Decisions To Update The 482 Transfer Pricing Rules

It has been over a year since the Tax Cuts and Jobs Act (“TCJA”) was enacted. The transfer pricing rules set forth in the treasury regulations with respect to IRC Sec. 482 (“the Section 482 regulations”) have remained relatively unchanged since 1986. Nonetheless, multinational corporations doing business within the United… – Continue reading

Cyprus: The True Impact Of BEPS On International Business Structures

In the last decade, OECD officials have recommended measures to combat tax avoidance, culminating first in the BEPS (Base Erosion and Profit Shifting) initiative in 2015 and then the MLI (Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS) effective from July 2018 – yet have all their… – Continue reading

Budget and taxation

With the present outdated and corrupt tax system, FBR cannot collect taxes as per its real potential — even proposed target of Rs5500 billion for next fiscal year 2019-20 would be an uphill taskThe Pakistani state does not need any borrowing, if all the citizens, especially the rich, are taxed… – Continue reading

India: Bombay High Court Quashes 197 Order Rejecting Mauritius Tax Treaty Benefits

High Court sets aside section 197 order due to absence of prima facie evidence of tax avoidance Rejects factors such as lack of business activities and administrative expenses as conclusive of sham transactions Holds that a detailed inquiry can be conducted during normal assessment Directs refund of withheld tax subject… – Continue reading

British overseas territories top corporate tax loophole index

Governments are stepping up efforts to recoup more tax from multinationals, with the European Commission forcing iPhone maker Apple to repay 13 billion euros after it used Ireland to cut its tax on European profits to almost zero. The Tax Justice Network, a group campaigning for transparency, said its study… – Continue reading

Cyprus: Cyprus–Kazakhstan First-Time Double Tax Treaty: Cyprus Ratifies

On 24 May 2019, Cyprus ratified the first-time double tax treaty it had signed with Kazakhstan on 15 May 2019 (the DTT). Certain legal procedures now need to take place in both states following which the DTT will ‘enter into force’. The DTT will be ‘in effect’ as from the… – Continue reading

Bahamas’ Corporate Tax World’s Most ‘Corrosive’

The Bahamas yesterday received no credit for laws said to have raised compliance costs by 75-80 percent after its corporate tax policies were rated as the world’s most “corrosive”. This nation achieved a “perfect” 100 out of 100, a score matched only by the Isle of Man, Turks & Caicos… – Continue reading

Delving into Hong Kong’s New Transfer Pricing Landscape

On July 4, 2018, Hong Kong’s Inland Revenue Department passed the country’s final Inland Revenue (Amendment) (No. 6) Bill 2017, (the Amendment Bill).  This Amendment Bill (which became law on July 13, 2018) specified the documentary requirements from a transfer pricing perspective and also introduced measures to address various recommendations… – Continue reading

Government Should Investigate BAT’s Tax Evasion

Kenya  Tobacco Control Alliance KETCA has today called upon the government to prioritize regulations that enable the  maximization of corporate tax revenue from British American Tobacco (BAT) Company. The  KETCA  Chairman, Joel  Gitali  said that  BAT avoids paying full corporate taxes which would have been used for public  services like… – Continue reading

New ranking reveals UK’s role in breakdown of global corporate tax system

Decades of tax wars among the world’s richest countries are unravelling the century-old global corporate tax system, new research finds. Forty per cent of today’s cross-border direct investments reported by the IMF – $18 trillion in value – are being booked in just 10 countries that offer corporate tax rates… – Continue reading

Revised tax treaties usher in a new era in investment, taxation

Policy tweaks  curb evasion,  show  India  can woo investments without  sops Singapore, another major FDI contributor to India, too, enjoyed the same tax sops under a similar treaty with India NEW DELHI: For about a decade-and-a-half, revenue authorities examining foreign investment proposals received by the erstwhile Foreign Investment Promotion Board… – Continue reading

Nigeria Signs Off On Common Reporting Standard With OECD

As we await official communication, information reaching us have it that Nigeria has signed off on the Common Reporting Standard (CRS) with the Organisation for Economic Co-operation and Development (OECD). As publicly stated on Wikipedia, ‘The Common Reporting Standard (CRS) is an information standard for the Automatic Exchange Of Information… – Continue reading

Anti-Money Laundering Software Market to Generate the Revenue of US$ 4,262.0 Mn by 2026

Companies, especially in the financial services industry are investing in the anti-money laundering software to effectively track the transactions and eliminate the risk of fraudulent. Companies offering anti-money laundering software are also focusing on providing effective and efficient software including currency transaction reporting software, transaction monitoring software, compliance management software,… – Continue reading

Cyprus to adopt new Transfer Pricing regime

After consulting with professionals in the Mediterranean island’s service sector the Finance Ministry is drafting a bill on Transfer Pricing guidelines. The Transfer Pricing regime concerns tax treatment of intra-group financing transactions. The draft bill aims to put an end to the over-pricing of intra-group invoices so that any low… – Continue reading

NBR for 30pc job quota for Bangladeshis

The National Board of Revenue recommended that the proposed guidelines on local entrepreneurs’ overseas investment should include provisions that the interested businesses have no overdue taxes in Bangladesh and have to employ minimum 30 per cent Bangladeshis in overseas projects. The NBR made the suggestions in its observations sent last… – Continue reading

Ex-soccer player among 9 held on suspicion of laundering millions

Also arrested is a former senior local council figure suspected of advancing interests in return for benefitsFour people were arrested and five detained for questioning in connection with the suspected international laundering of millions of shekels over a long period, police said Sunday. The four include a former senior elected… – Continue reading

‘Consider PH credit standing in okaying tax reforms’

Lawmakers should consider the country’s latest credit rating standing in approving the remaining tax reform proposals of the government, Finance Secretary Carlos Dominguez 3rd said. “I hope that, with this credit rating upgrade recently, the Senate will really consider passing these bills that will redound to the benefit of the… – Continue reading

US IRS begins FATCA crackdown

After years of deliberation and debate spanning two administrations, the Tax Information Exchange (United States of America) Bill, 2016, also known as the Foreign Account Taxpayer Compliance (FATCA) Bill was passed in the Senate on March 7, 2017. This following its unanimous passage in the House of Representatives, two weeks… – Continue reading

Pakistan, Bulgaria sign double taxation treaty

ISLAMABAD: Pakistan and Bulgaria on Tuesday signed an agreement to get rid of double taxation and cooperate in preventing tax evasion as a state delegation from the European Union member country concluded its two days visit. The Federal Board of Revenue (FBR) Director General and Deputy Minister of Economy Bulgaria… – Continue reading

Court rules John Doe summons to identify law firm clients isn’t barred by attorney-client privilege

Section 7609(f) of the tax code allows the Internal Revenue Service to use a “John Doe” summons when the target is unknown. It has been used successfully by the IRS against banks and other financial institutions to find offshore accounts. Now, a district court in the Western District of Texas… – Continue reading

Greenville County Councilman billed $55K in back property taxes on Anderson lake house

The Anderson County Assessor’s Office this month discovered that a Greenville County leader who owns a home on Hartwell Lake in Anderson underpaid by about $3,900 a year on his property taxes between 2009 and 2018. Calling it an oversight, Greenville County Councilman Ennis Fant said he would work with… – Continue reading