Some of New Zealand’s largest companies are calling on any future government to lower the corporate tax rate, which is becoming high compared to other countries, and a “New Zealand first” approach to policing cross-border finance arrangements that under-tax revenue in other countries. Published jointly by peak business lobby Business...
This article is the third of a series of articles that examines tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors in other offshore financial centres....
Bill would require private companies with more than $100m in turnover to publicly release tax information Six hundred of Australia’s biggest private companies could finally be forced to publish their high-level tax information, under a new push by Labor to repair a notorious piece of legislation. Labor will introduce a...
I am a trustee of an offshore trust settled by a UK resident, non-UK domiciled settlor (with no UK origins) for the benefit of himself and his family. He previously opted to be taxed on the remittance basis. The trust holds only offshore investments. The settlor lent monies to the...
Luxembourg Finance Minister Pierre Gramegna has introduced legislation into parliament that would establish a new intellectual property tax regime in Luxembourg. The bill was submitted to the Chamber of Deputies on August 4, 2017, and is designed to be aligned with the “modified nexus” approach to special IP tax regimes...
The Government of Hong Kong has said that it will introduce legislation into the Legislative Council by the end of this year to implement the minimum standards proposed by the OECD as part of its base erosion and profit shifting project. The BEPS framework, proposed by the OECD at the...
On August 3, 2017, the Irish Revenue published Revenue e-Brief No. 74/17, which contains guidance for taxpayers on complying with Ireland’s transfer pricing documentation requirements. The guidance notes that companies are legally required to maintain transfer pricing documentation. However, there is no requirement for documentation to be kept in a...
Global consultancy EY among firms now offering advanced services that redefine how companies face new developments in tax, audit and compliance Rigid new global initiatives to increase transparency of business data are giving rise to more advanced professional tax services, which employ innovative tools that include cloud computing, financial technology...
Paying employees in gold bullions to avoid tax will not be permitted under the first use of the general anti-abuse rule (GAAR). The GAAR advisory panel stated that the use of gold as payments for employees is “abnormal and contrived” and “not a reasonable course of action”. “We can see...
APAs were recently implemented in the Croatian tax legislation. Our Transfer Pricing team briefly presents the main points of the Croatian legislation related to an APA. Transfer pricing legislation was introduced in Croatia by way of the Corporate Income Tax Act (CIT) on 1 January 2005. However, the Croatian tax...
Italy is the most complex jurisdiction in Europe and comes in first place globally for ‘tax’ complexity, while Greece is most complex in the world for ‘compliance.’ Italy and Greece are among the five most complex jurisdictions in the world for Accounting and Tax compliance, according to TMF Group’s inaugural...
The OECD has praised Luxembourg’s tax regime for its predictability, although it sounded a warning about the volatility of tax revenues from the financial sector. In its latest assessment of the Luxembourg economy, the OECD said that Luxembourg’s strong economic performance was due partly to “business-friendly regulations, a predictable tax...
THE BENEFITS OF NON-DOMICILE STATUS An individual who is resident but not domiciled in the UK does not pay tax on overseas income and gains, as long as they are kept outside the UK and are not used to provide benefits in the UK. This is called the remittance basis...
The European Commission launched legal proceedings against Portugal, Bulgaria, and Cyprus for not adopting, in their national laws, European Union legislation requiring all EU countries to exchange tax rulings granted to multilateral companies. The legislation was adopted in the wake of the 2014 LuxLeaks scandal that revealed more than 100...
Switzerland has signed an agreement on the automatic exchange of tax information with Singapore, and is this week hosting a working meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes. The agreement with Singapore was signed by the Deputy State Secretary of Switzerland’s State Secretariat...
Irish Finance Minister Paschal Donohoe has explained the country’s approach to tax evasion during a hearing of the European Parliament’s PANA Committee, and said Ireland is “a strong supporter of international tax reform efforts.” Donohoe was one of several European finance ministers who appeared before the committee on July 11....
German Finance Minister Wolfgang Schaeuble defended his opposition to pending European Union legislation that would force large multinational companies to publicly disclose, on a country-by-country basis, their taxes paid and profits. Schauble, who testified before the EU Parliament’s Panama Papers investigative committee July 11, said public reporting of companies’ tax...
Among the products purchased by the Ministry are: Onesource Benchmark and Onesource TP Loan Module. Thomson Reuters and Ministry of Taxes of the Republic of Azerbaijan have signed an agreement under which the Ministry will use Thomson Reuters tax solutions aimed at implementing tax control in the sphere of transfer...
Tax executives are worried about some of the risks to their companies from the Organization of Economic Cooperation and Development’s Base Erosion and Profit Shifting project and U.S. tax reform proposals. A recent survey by Ernst & Young polled 901 tax and finance executives in 69 jurisdictions around the world...
Sri Lankan companies that violate transfer pricing rules can be fined up to two percent of the total value of transactions between related parties in case of non-disclosure of any required information under the new tax law. The new law also provides for the Commissioner-General of Inland Revenue to impose...
The OECD has released for stakeholders’ comments two new discussion drafts as part of its base erosion and profit shifting work. The first draft builds on the OECD’s final report on BEPS Action 7 (on preventing the artificial avoidance of permanent establishment status). The final Report on Action 7 of...
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...
