A. Introduction In February 2017 Cyprus Tax Department has announced that the current practice regarding profit margins between related Company loans will be abolished by the 30th June 2017. The announcement indicates that the minimum acceptable margins will apply up to 30th June 2017, and as from 1st July 2017...
Tax Administration Jamaica (TAJ) reported on Tuesday that local financial institutions required to report under the Foreign Account Tax Compliance Act (FATCA) are now 100 per cent compliant. FATCA is United States legislation designed to target US taxpayers holding accounts and assets outside that country and are non-compliant with US...
A Europe-wide crackdown on tax avoidance schemes is set to have a “chilling” effect on recruiters and intermediaries marketing such schemes. The Guardian reported this week that the European Commission will publish proposals tomorrow to force financial intermediaries to automatically disclose any new cross-border tax schemes offered to clients. According...
President Donald Trump and Republican leaders in Congress will soon confront a complex challenge for tax reform: how to limit U.S. corporate tax avoidance schemes that take advantage of low tax rates in foreign countries. Congressional and administration staff have begun to examine options to address profit-shifting schemes that include...
The Government of Australia has announced it is taking steps to become a global financial services leader by loosening a number of policy standards. One includes removing the double tax that currently implemented on digital currencies. The Australian Government has announced it will no longer be imposing a double tax...
The new Common Reporting Standard (CRS) regime will apply to most Australian managed investment schemes from 1 July 2017. Additional procedures for collecting information from new investors will need to be introduced from this date and additional work will be required in respect of existing investors. Overview of CRS Many...
SOUTH Australia is set to become the most competitive tax jurisdiction for commercial investment in Australia according to Collier’s International’s latest Radar research. The boast is prompted by the introduction, on July 1, of the state government’s second stamp duty reform which will come into effect as part of comprehensive...
The Internal Revenue Service has updated its online registration system for the Foreign Account Tax Compliance Act to allow foreign financial institutions to renew their agreement with the IRS. FATCA was included as part of the HIRE Act of 2010, requiring foreign banks and other financial institutions such as hedge...
GOVERNMENT has a bill on the Parliament agenda allowing for automatic extradition for people wanted for tax evasion in foreign jurisdictions, announced Attorney General Faris Al-Rawi. He said on the Parliament agenda there is a miscellaneous bill to deal with allowing prosecution of tax evasion matters in a reciprocal arrangement...
The German upper house of Parliament, the Bundesrat, passed a bill June 2 to stymie tax evasion through letterbox companies as part of a wider crackdown on illegal tax practices in light of last year’s Panama Papers scandal. The bill, which will become law after being signed by the German...
A federal district court has ruled in favor of tax preparers who filed a class-action lawsuit against the Internal Revenue Service over its right to charge fees for Preparer Tax Identification Numbers, and the IRS may need to refund hundreds of millions of dollars in fees collected each year. In...
The OECD has released a document that will form the basis of the peer review and monitoring process of the base erosion and profit shifting (BEPS) Action 6 minimum standard. The minimum standard on preventing treaty shopping was included in the October 2015 report on BEPS Action 6. It is...
The Botswana Unified Revenue Service (BURS) says tax avoidance schemes such as transfer pricing, base erosion and profit shifting appear to be on the rise in the country. Transfer pricing is regarded as a tax avoidance scheme in which multinational corporations shift profits to low tax jurisdictions and avoid taxes...
Russia will sign the OECD’s Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS), the Government announced on May 20. The Convention, developed by the OECD under Action 15 of the BEPS project, will transpose BEPS recommendations into over 2,000 tax treaties worldwide. According...
The WTO has published its fifth review of the trade policies and practices of Switzerland and Liechtenstein, in which it noted that the trade regimes in both countries remain generally open. Juan Carlos Gonzalez, Chairman of the WTO’s Trade Policy Review Body, commented: “On the positive side, the trade and...
The Hungarian parliament has approved an increase to the country’s advertising tax, despite concerns that the measure breaches European Union state aid rules. The new legislation increases the advertising revenues tax from 5.3 percent to 7.5 percent beginning July 1, 2017. However, because companies do not pay the tax on...
The UK Conservative Party has outlined plans to “legislate for tougher regulation of tax advisory firms.” In its Manifesto last week, the ruling Conservative Party said: “We have taken vigorous action against tax avoidance and evasion, closing the tax gap the difference between the amount of tax due and the...
Malaysia uses both progressive and flat rates for personal income tax, depending on an individual’s duration and type of work in the country. As expatriates may fall into either tax category depending on their work, it is important to understand Malaysia’s basic tax structure. The Income Tax Act of 1967...
Westpac has said that Australia’s new bank levy will cost it around AUD370m (USD275.7m) a year, and warned that “no company can simply ‘absorb’ a new tax.” In a letter to shareholders, Westpac chair Lindsay Maxsted described the tax as “bad public policy.” He said that the Government intends to...
New centre established to focus efforts on gaining better foothold in tax havens A unanimous Parliament yesterday agreed to significantly step up Denmark’s efforts to combat international tax evasion. Among the new initiatives are the establishment of a new centre that will consolidate efforts against tax evasion, more transparency regarding...
The Indonesian government on Tuesday issued a regulation in lieu of law (Perppu) to end bank secrecy in the country, with officials of tax offices allowed to directly access bank accounts owned by both Indonesian citizens and foreigners. Perppu No. 1/2017 on financial information access for taxation purposes was signed...
The South African Revenue Service (SARS) launched the Special Voluntary Disclosure Programme (SVDP) in October 2016, providing taxpayers with the opportunity to make good on any tax and/or exchange control contraventions of which they may be guilty in relation to offshore investments. The nine-month window period opened on October 1,...
Money laundering offences usually consist of conduct which seeks to conceal the criminal origin of wealth. When it was first introduced into the legal order in the 1980s, the principal objective of anti-money laundering legislation was to combat the introduction of the proceeds of drug dealing into the legitimate economy...
Panama needs to require greater due diligence from financial and banking institution to tackle tax fraud in the wake of the Panama Papers scandal, a United Nations official has said. “The main component of illicit cash flows at the global level is tax fraud,” UN rights expert Juan Pablo Bohoslavsky...
Norway’s Ministry of Finance has released a consultation on a proposal to further strengthen the nation’s restrictions on interest deductions within groups. The regime, introduced in 2014, is intended to prevent groups from establishing subsidiaries in lower tax territories from which to lend capital to companies in a higher tax...
Brazil’s Senate is considering the introduction of a new wealth tax on high net worth individuals. Senator Vanessa Grazziotin presented draft legislation for the tax on millionaires to the Senate this week. Under Bill 139/2017, the tax would apply to individuals with a net worth of more than 8,000 times...
Tokyo: Finance Minister Arun Jaitley on Monday assured that the Goods and Service Tax (GST) will be implemented on July 1, and there will be no significant change/increase in the price of goods, even as some services may encounter marginal hikes. When the GST comes into the picture, the sectorial...
EESC debate on taxation of the digital economy and the sharing economy European tax rules are not currently prepared for the digital economy. They need to be adapted to reality in order to offer the people of Europe a more prosperous future. This was the main message of the European...
A high percentage of UK executives are unaware of the impending introduction of new laws which could make a business’s failure to prevent tax evasion by its employees and agents a criminal offence, according to research by Pinsent Masons, the law firm behind Out-Law.com. In a YouGov poll of more...
Governments are expanding their use of tax incentives to maintain their country’s international appeal to businesses, alongside the adoption of anti-base erosion and profit shifting measures, according to a survey from EY. EY’s survey of tax policy professionals in 50 countries found that, “While the long-term trend for countries to...
Germany will introduce “license barrier rules” as of January 2018. The new rules will limit the tax deductibility of license fees or royalty payments to foreign related parties that benefit from preferential regimes (“Patent Box”, “IP-Box”, “License Box”) which are incompatible with the “OECD nexus approach” (“unqualified preferential regimes”) (sec....
A newly published federal draft law introduces Russia to a three-tiered approach to transfer pricing documentation and brings Russian regulations in this area in line with the OECD minimum standards under Action 13 of the Base Erosion and Profit Shifting (BEPS) Action Plan. The draft law, published by the Ministry...
Witnesses call for repeal of Foreign Account Tax Compliance Act An agreement that has resulted in hundreds of thousands of Canadian banking records being sent to the U.S. Internal Revenue Service could violate the U.S. constitution, a congressional subcommittee heard Wednesday. Testifying before a subcommittee of the House Committee on...
Indian tax authorities have initiated a $4.75 billion penalty charge against Cairn Energy for failing to pay a capital gains tax demand of $1.58 billion on a 2006 transaction. Under Section 271(1)(c) of the Income Tax Act, Indian tax authorities can levy a maximum 200 percent penalty against transactions after...
The Thai Revenue Department announced earlier this month that new legislation effective from April 2 increases penalties for those taxpayers committing tax fraud or evading their tax liability. In a statement accompanying the enactment of the Revenue Code Amendment Act (No.45) B.E. 2560, the Department revealed that such fraudulent activity...
At the end of March 2017, the Ministry of Finance called for public discussion on a draft bill (the “Bill”) amending the Bulgarian Tax and Social Insurance Procedural Code (the “Code”). The Bill seeks to improve administrative cooperation in the Bulgarian tax sector. The first set of amendments relates to...
On 12/29/2016, Colombia’s Congress approved “Law 1819 of 2016”. The new legislation is a structural tax reform primarily aimed at increasing revenues for Colombia. Colombia suffered a loss of revenues when crude oil prices plummeted beginning in 2014. The loss of revenue created a negative impact on its economy; creating...
Filing of your income tax return (ITR) is mandatory under the Income Tax Act, 1961 under certain circumstances. For instance, if someone’s income exceeds the maximum amount not chargeable to tax, one is required to file income tax return. Similarly, filing ITR is mandatory for ordinary residents having overseas assets...
An Australian taxpayer advocacy group has joined forces with a coalition of international taxpayer organizations and academics to condemn the Government’s plans to abolish the low-value goods and services tax threshold on imports. In separate submissions to the Senate inquiry into the proposes GST changes, the Australian Taxpayers Alliance and...
KUALA LUMPUR: The Inland Revenue Board (IRB) plans to increase its penalty to 100% for individuals and companies who evade paying their taxes or misreported tax. IRB chief executive officer Datuk Sabin Samitah said the new penalty scheme, an increase from the current 45% penalty imposed on unpaid tax, will...
With a total of 15 action points, the OECD’s Base Erosion and Profit Shifting (BEPS) project aims at fighting the artificial shift of profits from jurisdictions with high taxes to tax havens, often as a part of an entirely legal strategy used by MNEs. The BEPS Action 13 (Transfer Pricing...
A bill introduced by a Democratic State Representative in the Prairie State of Illinois has named 18 Caribbean nations as foreign tax havens and if it becomes law, would forbid a company incorporated in any of those nations from submitting a bid or entering into a contract with the state....
As a rule and according to Article 33 of the Cyprus Income Tax Law, which introduces the arm’s length principle (using wording similar to that of article 9 of the OECD Model Tax Convention), all transactions between companies, including loan agreements/transactions by Cyprus companies, must be undertaken at arm’s length...
Muscat: One of the many changes that the Royal Decree 9 of 2017 (RD) has made in the Oman Income tax law is the introduction of withholding tax (WHT) on payment of ‘dividends on shares’ by Omani companies. This amendment requires Omani companies distributing dividends on shares to foreign persons...
The Government of the Netherlands has said that it will take a step forward in its fight against tax evasion and money laundering by introducing a registry of ultimate beneficial owners of companies registered in the Netherlands. Draft legislation for the introduction of a registry of beneficial ownership was published...
A new bill introduced this week by Rep. Mark Pocan (D-WI), the Tax Fairness and Transparency Act, would rip out the offshore corporate tax avoidance system by its roots. This legislation combines into a single, comprehensive bill elements of three pieces of legislation that Rep. Pocan has proposed in previous...
Antigua & Barbuda, on Wednesday, launched what government said was a strong objection with the US State of Illinois, which has introduced legislation, listing the twin island state and 10 Caricom countries as tax havens. In letters to the Speaker of the House of Represen-tatives of the Illinois General Assembly,...
Hong Kong has signed agreements with Portugal and South Africa to automatically exchange financial account information in tax matters. The agreements expand Hong Kong’s Automatic Exchange Of Information (AEOI) network to include a total of 11 countries. The other reportable jurisdictions for Hong Kong are Belgium, Canada, Guernsey, Italy, Japan,...
HMRC has launched a new hotline for the public to report fraud and evasion, replacing the existing two separate tax evasion and customs hotlines with one, in a bid to streamline information gathering on tax fraud. Individuals can report all kinds of tax fraud and evasion on the new hotline,...
Australian lawmakers have passed legislation to cut the company tax rate for SMEs. However, the Enterprise Tax Plan was only partially approved. On March 31, the Senate passed legislation to phase in three years of changes to the company tax system. The Government’s original proposals had covered a period of...
