Category: Income Tax

Swiss Taxpayer Wins US Tax Treaty Refund Dispute

The United States District Court for the District of Columbia on January 31 ruled in favor of Starr International Company in a case concerning an erroneous refund paid to the taxpayer, which the IRS sought to reclaim. In 2011, the IRS erroneously issued a USD21m refund to Starr International Company,...

Apple Could Get a $4 Billion Boost From Tax-Law Quirk

Microsoft, Cisco might also benefit from GOP bill ‘loophole’ Law gives some firms edge in paring offshore cash tax tab Companies that stockpiled trillions of dollars offshore free of U.S. income tax may get one last break before paying up — provided their fiscal years don’t follow the calendar year....

Nawaz directs Miftah to introduce tax reforms

LAHORE: Pakistan Muslim League-Nawaz (PML-N) President Nawaz Sharif has instructed Prime Minister’s Adviser on Finance Economic Affairs and Revenue Miftah Ismail to implement tax reforms to strengthen the economy. During a meeting at his Raiwind residence, Nawaz instructed Miftah to refund 100 per cent sales tax to exporters by February...

Taiwan Seeking US Double Tax Treaty

Taiwanese Premier Lai Ching-Te has directed the Ministry of Finance to work towards a Taiwan-US tax treaty. Speaking at a strategic briefing to the National Development Council on January 4, 2018, Lai noted that the US is one of Taiwan’s most important trading partners. A tax treaty would ensure that...

CRA finalizes new Information Circular for income tax Voluntary Disclosures Program

On December 15, 2017, the CRA released the final version of Information Circular IC 00-1R6 – Voluntary Disclosures Program (“VDP”) for income tax, after receiving and considering community input on the June 2017 draft version. This article summarizes the important differences between the draft and the final ICs and discusses...

Thousand billions in lost tax from foreign enterprises

Vietnam has lost thousands of billions of dong in taxes as foreign enterprises, especially large-scale ones, refuse to pay based on the Double Taxation Avoidance Agreement. Massive revenue without having to pay taxes The Ho Chi Minh City Department of Taxation has recently issued an ultimatum for Uber B.V Netherlands...

Bahamas Faces Major Tax, Exchange Control Shake-Up

The Bahamas may have to completely overhaul its corporate and taxation structure to escape European Union/OECD ‘blacklisting’ threats, the Attorney General revealed yesterday. Carl Bethel QC told Tribune Business that the Government was “looking very carefully” at whether compliance with European (EU) demands will require this nation to eliminate the...

Income tax law changes again

Tax residence gets new rules, support for R&D will increase and the spa industry gets new support instruments. The law on income tax is changing again. The Slovak parliament adopted extensive revisions on December 7, bringing changes in the definition of tax residence, new measures to support the spa industry...

A stark warning for participants of the ‘Alchemy’ tax scheme

On 11 September 2017, His Honour Judge Colin Bishopp handed down his judgement in the case of The Commissioners for Her Majesty’s Revenue and Customs –v- (1) Root2tax Limited (2) Root3tax Limited (in liquidation) [2017] UKFTT 0696 (TC). The Root2 judgement concerned HMRC’s application to the First Tier Tax Tribunal...

Bahamas ‘Done Everything Possible’ To Avoid Blacklist

THE Deputy Prime Minister believes the Bahamas has “done everything we could possibly do” to escape the European Union (EU) ‘tax haven’ blacklist that will be issued tomorrow. K P Turnquest told Tribune Business that the Minnis administration “has no reason to think” this nation will be deemed a ‘non-cooperative...

India to accept mutual agreement process in transfer pricing cases

NEW DELHI The Indian Income Tax Department will accept applications for Mutual Agreement Procedure (MAP) in transfer pricing disputes, as well as for bilateral Advance Pricing Agreements (APAs), even for entities resident in countries with which India has double taxation avoidance agreements (DTAA), minus the provision to claim corresponding tax...

Paradise Papers reveal unethical tax avoidance by tech companies

Under President Trump’s political and economic climate, stocks and the economy have been soaring. Trump constantly aims for three percent GDP growth as a result of cutting corporate income and individual income taxes, which aims to encourage spending across different family incomes. However, these corporations the tax cuts favor have...

Shell transactions under vigil: Serial Income Tax raids on three businessmen

HYDERABAD: Income Tax sleuths on Wednesday conducted simultaneous searches in Hyderabad and Vijayawada on three top businessmen cum-realtors, who were allegedly evading tax, particularly in real estate transactions and unearthed documents pertaining to unaccounted investments running into hundreds of crores of rupees. These are the first big raids after shell...

Australians ‘wising up’ to use of tax havens, says Andrew Leigh

Shadow assistant treasurer suggests companies consider the image their tax minimisation methods project Andrew Leigh, the shadow assistant federal treasurer, has said companies using offshore tax havens to “get around corporate tax” in Australia risk losing what they save in tax via damage to their reputation. Speaking to Guardian Australia...

Business owners believe Irish tax code ‘is barrier’ to growth

Survey respondents cite high marginal rates and lack of staff reward schemes as negatives More than half of Irish business owners view the State’s tax code as a barrier to growth rather than a support, according to a survey by accounting and professional services firm Deloitte. Respondents cited Ireland’s high...

CBDT seeks suggestions on framing of rules on country-by-country reporting

New Delhi [India], Oct.6 (ANI): In keeping with India’s commitment to implement recommendations of 2015 Final Report on Action 13, titled “Transfer Pricing Documentation and Country-by-Country Reporting”, the Department of Income Tax has invited comments from stakeholders and the general public. It has said that these comments and suggestions on...

United States: California Expands Voluntary Disclosure Program for Out‑of‑State Trusts

At a Glance… On September 25, Governor Brown signed into law Senate Bill No. 813, which updated the California Voluntary Disclosure Program (VDP) to include out-of-state trusts with California beneficiaries and non-resident partners of out-of-state partnerships, and to allow the Franchise Tax Board (FTB) to waive the S Corporation or...

Ghana-Morocco double tax agreement to come into force in 2018 – (Part 2)

In our last publication, we discussed the signing of the Ghana-Morocco Double Tax Agreement (“DTA”) and the provisions of the DTA in relation to the taxation of permanent establishments and business income. In the concluding part of the article, we will discuss the taxation of investment, employment and service incomes...

Interpreting double tax treaties in light of the BEPS multilateral instrument

Some double tax treaties are being amended by a multilateral instrument Establishing how a particular treaty is affected can be a complicated process The UK intends to publish amended DTTs and this will help, but the MLI has added an additional layer of complexity 18 Sep 2017 Speed Read LEGAL...

Econ experts laud tax reform plan

MANILA, Philippines — The Foundation for Economic Freedom (FEF) has expressed support for the tax reform program being pushed by the Department of Finance, saying this will lead to better lives for Filipinos. “The comprehensive tax reform program lays a solid foundation for the government’s vision of inclusive growth, improved...

Tax evaders set to face action: CBDT chairman Sushil Chandra

CBDT chairman Sushil Chandra says income tax dept will soon conclude probe into financial dealings of about 100,000 individuals suspected of tax evasion New Delhi: The income tax department will conclude its investigations into the financial dealings of about 100,000 individuals suspected of tax evasion and persuade many other assessees...