Category: Income Tax

EU wants companies to disclose where they pay taxes

The European Union’s executive wants thousands of multinationals to disclose in what member states they make money and pay taxes, an effort to close loopholes and crack down on the use of tax havens. Reacting to public anger over tax avoidance by some of the globe’s best-known companies and by… – Continue reading

Adventures in tax avoidance: Canada’s deep offshore tax haven connections

Much of the activity is legal, but it siphons away billions in tax revenue from government coffers The massive Panama Papers data leak shines a light not only on the dirty money being shuffled through tax havens, but also on the legal and common use of offshore accounts to significantly… – Continue reading

No Agreement On Australian State Tax Devolution

The leaders of Australia’s federal, state, and territory governments have failed to reach an agreement on a proposal to enable the states to levy income tax. The Council of Australian Governments (COAG) met on April 1. Ahead of the meeting, Federal Prime Minister Malcolm Turnbull had proposed that the federal… – Continue reading

The missing billions of multinational tax

It’s easy to stoke outrage at multinationals’ low taxes but harder to do something about it. According to the Organisation for Economic Co-operation and Development (OECD) – the so-called rich-countries club – tax avoidance by multinational companies is worth US$100-240 billion a year. That’s 4-10% of total global corporate income… – Continue reading

Scottish residents will be blocked from dodging higher taxes, HMRC says

Is there a serious risk that Scotland’s tax revenues would be hit hard by people fleeing south to avoid the new top rates of tax advocated by Labour or the Scottish Greens? HM Revenue & Customs is not convinced that there is. With a new Scottish rate of income tax… – Continue reading

Canada Revenue Agency’s 2014-2015 annual report to Parliament: Focus on compliance measures

The Canada Revenue Agency (“CRA”) released its Annual Report to Parliament (“Report”), outlining the CRA’s performance and key statistics for 2014-2015. This article highlights some of the measures that the CRA has undertaken to combat non-compliance. During 2014-2015, the CRA assessed over $1.7 billion in additional taxes owing and identified… – Continue reading

KPMG: Moves to curb international tax dodges

Global international tax takes from multinational companies will almost certainly increase in the next 5-10 years as governments around the world look to level the taxation playing field. Commenting on the New Zealand Herald’s series examining ‘the tax gap’ – multinationals channelling earnings to lower tax regimes, disadvantaging some of… – Continue reading

Foreign firms targeted for tax

The tax office plans to deploy a special unit and team up with the Investment Coordinating Board (BKPM) to probe thousands of foreign firms allegedly failing to pay their due taxes. Finance Ministry taxation director general Ken Dwijugiasteadi said around 2,000 foreign investment companies in various sectors, from industry and… – Continue reading

IRS Uses New Tactic to Expand Efforts to Combat Offshore Tax Evasion

In a search for financial records of a U.S. taxpayer who allegedly parked undeclared income offshore, the Internal Revenue Service (IRS) and the U.S. Department of Justice (DoJ) are seeking to enforce a summons against a U.S. branch of a foreign bank for records held by a foreign branch of… – Continue reading

CBDT signs 11 more advance pricing pacts with taxpayers

The Tax Department has signed 11 more Advance Pricing Agreements (APAs) with taxpayers covering overseas transactions within group entities so as to reduce litigations. “Central Board of Direct Taxes (CBDT) has signed 11 unilateral APAs on March 28, 2016. With this signing, India has entered into 59 bilateral and/or unilateral… – Continue reading

Indonesia Seeks To Curb Use Of Tax Havens By Companies

Indonesia hopes its plans for a tax amnesty will dissuade companies from channelling profits through overseas tax havens and shopping around for the most advantageous tax treaties, its finance minister said on Wednesday. Bambang Brodjonegoro said he suspected Indonesian firms of setting up “special purpose vehicles” (SPVs) to benefit both… – Continue reading

Canadian Budget Focuses On Tax Compliance

The first Budget tabled by Canada’s new Liberal Government provides for a major crackdown on tax evasion and avoidance, and streamlines the domestic tax credits system. The Budget was delivered by Finance Minister Bill Morneau on March 22, 2016. He told Parliament: “Today, we begin to restore hope for the… – Continue reading

Indonesia, a ‘real tax haven’ nation

This article’s title may be shocking and antagonize Indonesia’s staunch position of opposing tax evasion by way of tax havens. But, let’s look deeper. While there is no standard definition of a tax haven, it is generally defined as a state, country or territory where tax rates are very low… – Continue reading

Withholding tax on digital transactions

THE digital economy has increased opportunities for digital commerce companies to reap substantial sales from a country without establishing a taxable presence in that country. Existing permanent-establishment (PE) rules in both domestic laws and tax treaties require some type of physical presence before a PE is established in another country…. – Continue reading

‘Scrutiny assessment’ of tax returns to begin soon

The National Board of Revenue (NBR) has issued a guideline asking its income tax offices across the country to start ‘scrutiny assessment’ of the tax returns submitted for the tax year 2015-16. As per the guideline, the taxmen have to complete the scrutiny assessment known as ‘return process’ by December… – Continue reading

Southeast State & Local Tax: Important Developments – March 2016

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast. VIRGINIA CORPORATE INCOME TAX Conformity with Internal Revenue Code. Virginia Governor Terry McAuliffe signed emergency legislation on February 5, 2016 that advances the state’s… – Continue reading

Belarus, Kazakhstan update double taxation agreement

Belarus and Kazakhstan introduced amendments and additions to the intergovernmental double taxation agreement and thus updated the tax legislation, Belarus’ Taxes and Duties Minister Sergei Nalivaiko said after a ceremony to sign the protocol, BelTA has learned. The matter is about the protocol between the governments of Belarus and Kazakhstan… – Continue reading

Income tax cuts will benefit 31 million workers

The amount people can earn before being hit by income tax will rise to £11,500 in April 2017, benefiting millions of workers. The move will cut taxes for 31 million people, according to the Treasury, and will mean 1.3 million low-wage workers are taken out of paying income tax altogether…. – Continue reading

FBAR, FATCA Filings Top 1 Million As IRS Increases Scrutiny On Foreign Accounts

A record high 1,163,229 Report of Foreign Bank and Financial Accounts (more commonly, FBARs) were filed in 2015, up more than 8% from the prior year. That growth, however, is nothing new: FBAR filings have grown on average by 17% per year during the last five years , according to… – Continue reading

IRS now allows Cuban tax credit

President Barack Obama is heading to Cuba next week. When Air Force One lands on that island nation on March 20, Obama will become the first U.S. commander in chief to visit Cuba in 88 years. In advance of that historic visit, which the administration hopes will eventually lead to… – Continue reading

States vie with feds to punish company moves abroad. But does it work?

State lawmakers are getting into the act of demonizing corporate inversions even though there is not much they can do to stop them. Corporate inversions, in which U.S. companies merge with or are acquired by an overseas business, are a hot topic on the campaign trail and in the halls… – Continue reading

The rich people who pay no tax

Only the little people pay taxes. For a small, select cohort of rich Australians, the famous quote of New York property billionaire Leona Helmsley rings not as an outrage but as an inspiration. In the most recent documents released by the Australian Tax Office, there were 55 people who had… – Continue reading

How Sanders and Trump Aim to End Offshore Corporate Tax Havens

Fortune 500 firms may be avoiding $695 billion in U.S. income taxes on $2.4 trillion held offshore. What do Bernie Sanders and Donald Trump have in common? Both seek an end to the use of offshore tax havens by corporate America. Bernie Sanders’ plan ends the ability of corporations to… – Continue reading

London court slams UBS offshore tax schemes

Offshore schemes operated by Swiss bank UBS and Germany’s Deutsche Bank in a bid to avoid paying income tax on bankers’ bonuses are not exempt from tax, the Supreme Court in London ruled Wednesday. British tax authorities, who brought the court action, said the schemes set up by the Swiss… – Continue reading

Uzbekistan, Finland sign protocol to double taxation avoidance agreement

Uzbekistan and Finland signed a protocol on amendments to the Uzbek-Finnish intergovernmental agreement on avoidance of double taxation and prevention of income tax evasion, the Uzbek foreign ministry’s statement posted on its website said. Uzbekistan and Finland signed the agreement on the avoidance of double taxation and prevention of income… – Continue reading

Canada Revenue offered amnesty to wealthy KPMG clients in offshore tax ‘sham’

Federal authorities demanded secrecy in no-penalty, no-prosecution deal to high net worth Canadians The Canada Revenue Agency offered amnesty to multi-millionaire clients caught using what’s been called an offshore tax “sham” on the Isle of Man — a reprieve that was supposed to remain secret and out of the public… – Continue reading

Brown to introduce new tax payment regulation for corporations

With American corporations keeping a record amount of profits offshore to avoid paying U.S. taxes, U.S. Sen. Sherrod Brown (D-OH) will introduce legislation requiring corporations to “Pay What You Owe Before You Go.” During a news conference call today, Brown will outline his bill that would require corporations to settle… – Continue reading

Google And The UK Tax System – Tax Avoidance?

For several years now Google has been facing what appears to be a case of tax avoidance in the UK, at some point in time, the company went as far saying it did not make any money from business in the UK all in a desperate attempt to pay less… – Continue reading

EPF tax row: Will it lead to double taxation?

Even employees earning below Rs 15,000 a month will be impacted if the Centre sticks to the plan of taxing 60% of EPF withdrawals The Budget has proposed significant changes on taxation of Employees’ Provident Fund (EPF). Given that EPF is at the core of the Indian social security system… – Continue reading

Verdict corner: DTAA or domestic law?

Retrospective amendments to domestic laws cannot override international treaties In a judgment that will have a far-reaching impact on double taxation issues, the Delhi High Court has held that Parliament cannot change the terms of an international treaty by bringing in amendments in the domestic law, and any such executive… – Continue reading

India clicks on digital economy with equalisation levy

While equalisation levy appears to be a step to counter double non taxation and protect India’s share of taxation, in its current form it may impact an Indian taxpayer more than foreign MNCs The growth of digital economy entails many benefits, but also poses various tax challenges. These include the… – Continue reading

A closer look at the flat tax

Another form of taxation that has gotten greater attention during the last two presidential election campaigns is the flat tax. A flat tax is a plan that will apply the same rate to every taxpayer, regardless of the income they have earned. At present, federal taxes are calculated on a… – Continue reading

Further clarity on GAAR for FIIs

The industry was hoping GAAR might be postponed again, especially in the light of slowing down of the world economy In a signal to foreign institutional investors, the Union Budget has made a commitment to implement General Anti Avoidance Rules (GAAR) on taxes only from April 1, 2017. “The investment… – Continue reading

Govt negotiating issues relating to DTAA with Mauritius

Outstanding issues relating to the existing Double Taxation Avoidance Agreement (DTAA) are under negotiation between India and Mauritius through the mechanism of Joint Working Group (JWG), Parliament was informed today. “India has proposed changes in the existing DTAA to address concerns relating to treaty abuse, around tripping of funds, double… – Continue reading

No double taxation agreement with Panama; Maltese domicile subject to tax on worldwide income

Maltese individuals resident and domiciled for tax purposes, that is people whose permanent residence is in Malta, are required to pay tax in Malta on their worldwide income, according to the Income Tax Act. This essentially means that Minister Konrad Mizzi is required to pay tax on foreign earnings. However… – Continue reading

Important changes and developments in German double tax treaties

1. New double tax treaty between Germany and the Netherlands: tax authorities now bear burden of proof regarding tax- evading or tax-avoiding arrangements A new Double Tax Treaty (DTT) has been in place between Germany and the Netherlands since 01 January 2016. Art. 23 of the DTT introduces an important… – Continue reading

Double taxation avoidance treaty with Qatar: What is in it for Nigeria?

The federal government of Nigeria and Qatar have signed an agreement for the avoidance of double taxation on income and capital gains for investments between the two countries. In addition to the elimination of double taxation on business income, similar treaties between Nigeria and other countries provide for a lower… – Continue reading

Rationalise taxes on media, entertainment sector: Experts

Budget 2016 should rationalise entertainment tax, exempt newsprint from VAT and end double taxation on temporary transfer of movie rights to television channels, experts said. “Currently, entertainment industry players such as DTH and cable service operators are reeling under the heavy burden of multiple taxation and levies such as licence… – Continue reading

BEPS Action Plan 3: Designing effective controlled foreign company rules

A “controlled foreign company” (CFC) is, as the name implies, a foreign company or subsidiary owned by a parent company which is situated in a country different from the parent company’s country of residence. The tax laws of many countries, including the Philippines, do not tax the CFC’s parent company… – Continue reading

Budget 2016: How base erosion and profit shifting (BEPS) brings HR function into focus

Tax function of an organisation was traditionally run from the tax director’s room. Transfer Pricing (TP) was governed by contracts between related parties and this at times resulted in profits moving to legal entities that had contractual rights but had no significant people functions. There were instances of IP Holding… – Continue reading