United States: The OECD Unified Approach Marches (Stumbles?) Forward
The OECD Secretariat proposed the Unified Approach in October 2019 to address the tax challenges arising from the digitalization of the economy. ... - Continue reading
Category: Income Tax
Puerto Rico changes income tax law for intercompany charges
Puerto Rico has amended its income tax rules to allow taxpayers to fully deduct intercompany expenses if taxpayers file a transfer pricing study with their income tax return, due April 15, 2020, if not extended. ... - Continue reading
Vietnam issues Draft Pronouncement on Tax Administration, Transfer Pricing, Minimum Basic Wage and Personal Income Tax
The Vietnam Ministry of Finance has issued the draft pronouncement amending certain tax rulings. Some of the main aspects of the draft include: ... - Continue reading
Tax obligations of permanent establishments
The Philippines generally follows the “source of income” rule in identifying the income that are taxable to corporations in the Philippines. ... - Continue reading
Switzerland: Tax On Inbound Investments 2020
Tax treatment of different acquisitions ... - Continue reading
India: Role Of Permanent Establishment Vis-A-Vis Indian Laws
India's position with respect to Permanent Establishment ... - Continue reading
HK, Macau reach pact to avoid double taxation
For Macau residents, double taxation will be avoided by way of exemption of the income taxed in Hong Kong from the Macau tax, or by crediting the Hong Kong tax paid against the Macau tax payable in respect of the same income. ... - Continue reading
India launches Income Tax information portal
The portal is a repository of policy and technical circulars and guidance issued by the Central Board of Direct Taxes. In an attempt to reach out to financial institutions and account holders, the Central Board of Direct Taxes has created an exchange of information portal on the income tax department… – Continue reading
Indirect linkages to Tax Havens
According to the most current Federal Tax Compliance Research Report, there is an estimated US Net Tax Gap (Tax Not Collected) of $406 Billion. ... - Continue reading
When A New York Exempt Resident Trust Meets The Sale Of A Business
Insights into the functioning of a trust ... - Continue reading
Parliament ratifies double tax agreement with Malaysia
The Verkhovna Rada of Ukraine ratified an agreement with Malaysia on the avoidance of double taxation and the prevention of tax evasion and the protocol thereto, adopting Bill No. 0002. 333 MPs voted in favor of it. It was broadcasted by official Rada Channel. The agreement extends to individual income… – Continue reading
U.S. govt deficit hits 7-year high
The U.S. government ended fiscal year 2019 with the largest budget deficit in seven years as gains in tax receipts were offset by higher spending and growing debt service payments, the Treasury Department said on Friday. It is the first time since the early 1980s that the budget gap has… – Continue reading
Dutch ditching their US citizenship over tax fears
Some 1,700 ‘accidental’ Dutch Americans have applied to give up their US nationality this year, a six-fold rise on three years ago, before a new tax law is implemented next year. As FATCA is enforced, these Dutch Americans must file a tax return in the United States. If they do… – Continue reading
Tax department posts 32pc growth in revenue in 1Q
A regional tax office posted 32 percent jump in revenue collection to Rs26.43 billion in the first quarter of the current fiscal year as tax rates on non-compliance increased during the period, sources said on Wednesday. Revenue collection by the Regional Tax Office (RTO)-II Karachi amounted to Rs19.98 billion in… – Continue reading
Canada: TFSA Non-Residence Contribution Tax Cancellation – A Toronto Tax Lawyer Analysis
For Canadians who are planning their retirement by investing their savings, the Tax-Free Savings Account (TFSA) has become an important supplement to the Registered Retirement Savings Plan (RRSP) since its introduction in 2009. ... - Continue reading
India: Rules To ‘Secondary Adjustment’ Rationalized And Clarified
The concept of 'Secondary Adjustment' was introduced in Finance Act 2017 by introducing new Section 92CE in the Indian Income Tax Act (the Act) to align transfer pricing provisions with international best practices. ... - Continue reading
Singapore: Why setting up in Singapore makes sense for business in ASEAN.
Singapore has long been a preeminent destination for setting up a regional headquarters to pursue business opportunities across ASEAN and Asia. ... - Continue reading
What OECD’s tax plan for tech giants means for India
- OECD has proposed that profits of MNCs should be available for taxation in the country where their customers are, irrespective of any physical presence in that market
- A formula should be evolved for such taxation
India: No Withholding Tax Applicable On Arbitral Award
The Delhi High Court ("Court") in Glencore International AG v. Dalmia Cement (Bharat) Limited has held that amounts paid to a non-resident pursuant to an international arbitration award would not be subject to withholding tax in India. ... - Continue reading
Nigeria: Key Considerations On Employment And Remuneration Of Expatriates In Nigeria
The natural resources and the economic opportunities in Nigeria continue to attract foreign direct investments (FDI) by investors across the world. ... - Continue reading
Citizenship, residency and tax liability
Is it true that if I become Italian I have to pay taxes in Italy? “I am a U.S. citizen and I plan to move my residency to Italy. I will continue working remotely for my U.S.-based company and will continue paying my taxes in the U.S. What should I… – Continue reading
BIR warns delinquent POGOs anew
The Bureau of Internal Revenue (BIR) said that service providers for Philippine offshore gaming operators (POGO) must cooperate and comply with the tax authorities to avoid revenue losses once they become subject for closure. BIR Commissioner Caesar R. Dulay said that POGO service providers should be prepared to incur millions… – Continue reading
Imminent Changes To US Immigration Program
There has been a lot of recent media attention surrounding the EB-5 Investment Visa Program, and for good reason. South African residents are not able to emigrate for exchange control purposes (sometimes referred to as a financial emigration) unless they have a lawful right of abode in the country to… – Continue reading
Uganda: Don’t Make Up Losses To Avoid Tax
Conflicting interests arise for many businesses where decisions have to be made to determine how they consistently achieve profitability, while on the other hand minimise payment of tax. The temptation to minimise profits or even make a loss then becomes a tax risk management strategy. ... - Continue reading
Despite big corporate tax cut gains, ITC’s stock has not fired up enough
- News flow on the potential sale of an 8% govt stake in ITC held by SUUTI has weighed on sentiments, say analysts
- Sure, the tax cut gives ITC room to delay price hikes and that may prove helpful
Indian court rules Hitachi Singapore’s liaison office is a permanent establishment
In a landmark ruling, the Delhi bench of the Income Tax Appellate Tribunal has concluded that a liaison office could be treated as a permanent establishment of a foreign entity in India. ... - Continue reading
Hong Kong signs tax treaty with Estonia
The Hong Kong government today announced that Hong Kong and Estonia have signed a comprehensive tax treaty. ... - Continue reading
Mexico 2020 tax reform: big changes proposed for foreign companies doing business in Mexico
On September 8, the executive branch of the Mexican government introduced Mexico 2020 tax reform, proposing far-reaching changes to the Mexican income tax, value-added tax, and Federal Tax Code. ... - Continue reading
Netherlands: The Netherlands: Tax Plan 2020
On September 17, 2019, the Dutch government released the Budget 2020 containing its Tax Plan 2020 with certain amendments to Dutch tax law. ... - Continue reading
Nigeria: The FIRS Has Published Regulations On Common Reporting Standard
The Federal Inland Revenue Service (FIRS) has issued the Income Tax (Common Reporting Standard) Regulations, 2019 (CRS Regulations). This follows Nigeria's signing of the Multilateral Convention on Mutual Administrative Assistance in Tax Matters (MAC) and the Multilateral Competent Authority Agreement (MCAA) on the Automatic Exchange of Financial Account Information, signed by Nigeria on 17 August 2017. ... - Continue reading
FBR issues notices to 475 printers for return filing
KARACHI: The Federal Board of Revenue (FBR) has issues 475 notices to owners of printing press and advertising businesses, asking them to file their income tax returns, sources said on Tuesday. The FBR issued notices for mandatory filing of income tax returns and wealth statement in order to determine annual… – Continue reading
Panel to hear taxpayer before invoking GAAR under new set of rules
New rules mandate officials to refer a suspected case of tax avoidance to a panel of senior officials ... - Continue reading
CTA acquits gold trader in P110-million tax evasion case
A gold trader has been acquitted by the Court of Tax Appeals in the P110-million tax evasion case for the failure of the Bureau of Internal Revenue (BIR) to prove his guilt beyond reasonable doubt.n a 56-page decision, the CTA’s Second Decision said the BIR was not able to present… – Continue reading
Salary received abroad by ‘resident and ordinary resident’ is taxable in India
You may evaluate claiming foreign tax credits under the India-US Double Tax Avoidance Agreement, for the taxes, if any, paid in the US on the salary received during the assignment, subject to satisfaction of conditions ... - Continue reading
Australia: Glencore’s ‘big win’ for taxpayers on transfer pricing
The Federal Court of Australia on 3 September issued its much-anticipated judgement Glencore Investment Pty Ltd v Commissioner of Taxation of the Commonwealth of Australia [2019] FCA 1432, herein referred to as the Glencore decision. ... - Continue reading
India: Whether A Foreign Company Is Required To File Its Tax Return In India?
A question arises is whether a foreign company which has earned income from a source in India is required to file its tax return in India. ... - Continue reading
Italy: New Tax Incentives For Attracting Human Capital: Italy As The New Eldorado For The Taxation Of Sport Stars
Tax treatment is a key factor for private individuals such as workers, executives, entrepreneurs and professional athletes who relocate to new jurisdictions. ... - Continue reading
DoF: Tax perks should be reviewed every 2 yrs
FINANCE Secretary Carlos Dominguez 3rd is pushing for tax perks to be reviewed every two years as he reiterated that the Philippines had been too generous in granting incentives to select companies. In a statement on Thursday, the Department of Finance (DoF) quoted its chief as saying the government must… – Continue reading
Cyprus: The Cyprus Investment Programme And The Benefits
The Cyprus Investment Programme is rapidly becoming one of the EU’s most popular residence schemes.
- Non Cypriot citizens (and their families) can acquire Cyprus Citizenship by investing €2.5 million* in Cyprus.
- Following the application, Cyprus citizenship will be granted in six months, assuming the application has been completed accurately and the correct documentation filed.
- The applicant needs to be in posession of a residence permit for a period of six months before obtaining the citizenship.
FBR issues 253,000 notices to non-filer industrialists
KARACHI: The Federal Board of Revenue (FBR) has issued around 253,000 notices to industrialists and businessmen, asking them to file returns, as the revenue body is expanding its broadening of tax base drive, officials said on Tuesday. An official said the FBR has so far issued 253,700 notices to consumers… – Continue reading
Canada: Transfer Pricing: What’s New In Canada (Part II)
Transfer pricing disputes in Canada have, predominately, been resolved through either a request for competent authority assistance under the Mutual Agreement Procedure ("MAP") of a treaty, or, to a much lesser extent, through the notice of objection process with CRA Appeals. Regardless of the recent increase in transfer pricing cases being brought before the Courts, the MAP will likely continue to be the dispute resolution process most often utilized by a Canadian corporation in transfer pricing cases because, in the absence of a 100% reversal of a transfer pricing adjustment by either CRA Appeals or a Canadian court, economic double taxation may still exist as a consequence of the CRA upward transfer pricing adjustment. The correlative relief provided by the treaty partner under a MAP settlement resolves that double taxation. ... - Continue reading
FBR demands Rs992m from TV channel in alleged tax evasion case
ISLAMABAD: The Federal Board of Revenue (FBR) has served a notice on ARY Communications Limited (ARY) and raised a tax demand of Rs992 million – alleging that the entity had evaded tens of millions in taxes through misrepresentation, concealment and misuse of exemptions, thereby causing a substantial loss to the… – Continue reading
Mexico proposes new rules to tax highly digitalized businesses
A bill was introduced to the Mexican Congress on August 21 to tax digital platforms. ... - Continue reading
HMRC collects record £191bn in income tax
The taxman is raking in record amounts in income tax as the latest figures reveal Britons paid an extra £11bn in 2018/19. Income tax receipts have soared to a record £191bn, according to figures published, a 6% increase from the previous year. Britons are paying almost 30% more income tax… – Continue reading
India will start getting Swiss Bank details of Indians from today
India will start getting details of bank accounts held by its citizens in Switzerland from September, ending the era of Swiss bank secrecy. ... - Continue reading
Nigeria: Regulatory Authorities’ Approvals And The Application Of Arm’s Length Principle In Nigeria: The Need For Coherence
One of the key objectives of the Income Tax (Transfer Pricing) Regulations, 2018 (NTPR) as captured in regulation 2(e) is to provide taxable persons with certainty of transfer pricing treatment in Nigeria. ... - Continue reading
Banks dominate list of top corporate taxpayers
Country’s bank sector with eight private commercial banks dominated the list of top-10 highest corporate taxpayers in last fiscal year (2018-2019) despite a cut in the corporate tax rate for the sector. The 10 highest corporate taxpayers paid a total of Tk 5,843.44 crore in corporate income tax in FY19… – Continue reading
Senate inquiry into foreign workers’ tax payments pushed
SEN. Sherwin Gatchalian has called on the Senate to hold an inquiry on the uncollected taxes from registered and unregistered foreign workers, especially those in the Philippine Offshore Gaming Operators (POGOs) industry. n calling for an investigation, Gatchalian stressed that taxes properly collected are essential since revenues enable the government… – Continue reading
Will a new direct tax law push up compliance?
- Numerous amendments over five decades, as well as the influence of case laws, often made it difficult to interpret the rules
- India is rewriting its direct tax law to make it simpler, more sophisticated and less prone to disputes.
