THE House of Representatives on Tuesday postponed its vote on the Income Tax (Amendment) (No 2) Act, 2015, which includes provisions for the introduction of transfer pricing rules in Jamaica. Minister of Finance and Planning Dr Peter Phillips agreed to postpone taking a vote on the Bill, also referred to… – Continue reading
The New York billionaire is aiming his financial might at members of Congress who aren’t willing to cut deals on corporate tax policy. Sure, Carl Icahn might make money—lots of money—on his $6 billion stake in Apple Inc. if a political campaign he announced Wednesday to cut taxes on companies’… – Continue reading
Major US investor Carl C. Icahn and the Chief Executive Officer of TechNet, Linda Moore, have both recently written letters to leading lawmakers pointing out that the passage of international tax reform by Congress has become a matter of extreme urgency. In his letter, Icahn announced that “the time has… – Continue reading
On 21 October, the European Commission (“EC”) adopted its first decisions in its investigation into Member States’ tax rulings. The investigation, which began in June 2013, has also targeted tax rulings given to Apple and Amazon as well as Belgium’s so-called “excess profits regime”. Although the investigation is conducted under… – Continue reading
The Dutch Secretary for Finance, Eric Wiebes, has reported to the House of Representatives on the impact of the OECD’s base erosion and profit shifting project on Dutch tax rules. His letter, published on the Dutch Government website on October 19 in English, splits measures into those that concern domestic… – Continue reading
Prime Minister of St. Kitts and Nevis, Dr. the Hon. Timothy Harris, was the featured speaker at the Financial Services Regulatory Commission – St. Kitts Branch’s (FSRC) 2nd annual Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) seminar at the St. Kitts Marriott Resort on Wednesday, October 21, reports SKN Vibes…. – Continue reading
Foreign tax credit available to taxpayers even on a portion of exempt income. Exempt income (under section 10A) is chargeable to tax under section 4 and 5 of the ITA although no tax may actually be payable. Actual payment of the tax is not necessary for claiming foreign tax credits…. – Continue reading
its tax bulletins, the legislation will apply to transactions even between unconnected parties if the non-Jamaican party is in a tax haven. In addition, it will take into account the use of captive insurance companies, that is, insurance companies established by a parent group or groups with the specific objective… – Continue reading
Gibraltar’s Government has released a public consultation on the establishment of private foundations, in a bid to level the playing field with other jurisdictions. As an incorporated body, foundations are able to transact, sue, and be sued in their own name. They are primarily used for private wealth management, succession… – Continue reading
Center-left MEPs turn up the heat on multinationals refusing to exchange views on tax policy. Google, Facebook, HSBC and AB Inbev are among a group of multinationals that have been “banned” from meeting MEPs from the European Parliament’s center-left grouping unless the companies agree to appear before a special committee… – Continue reading
Announcements were made in the 2015 Summer Budget regarding proposed changes to the UK tax rules regarding individuals who are domiciled outside the UK. These included the introduction of new provisions which would deem certain foreign domiciliaries, who are or have previously been UK resident, to be domiciled in the… – Continue reading
Congress needs to lower the corporate tax rate from its current 35% to discourage U.S. insurers from moving offshore, according to the head of Travelers Cos. Inc. “Reducing this rate would end a self-defeating policy that distorts corporate behavior, weakens domestic companies and ultimately harms the U.S. economy,” wrote Travelers… – Continue reading
Tunis, — The process of returning Tunisian property and assets frozen in a number of foreign banks in general and in Switzerland, in particular, has not moved an inch. More than four years have elapsed since the fall of former President Ben Ali without any hope of progress on the… – Continue reading
What has happened? On 5 October 2015 the OECD issued its final paper on BEPS Action 12 Mandatory Disclosure Rules, Action 12 – 2015 Final Report (Paper). In this Alert we highlight the main issues and recommendations for taxation reform raised in the Paper. The Australian Treasurer’s BEPS Press Release… – Continue reading
Ireland’s budget statement for 2016 (Budget) was delivered by the Minister for Finance last week. The Budget’s primary focus was on personal tax matters, which is somewhat unsurprising given the general election early next year. However, the Budget also contained two key announcements on Ireland’s corporation tax system. In line… – Continue reading
Carl Icahn, the iconic activist investor, has shifted, if only for today, his cross-hairs of contempt from the boardrooms of corporate America to the nation’s capital. Icahn sends members of Congress a word of warning Wednesday saw Carl Icahn warn several members of Congress a letter laying out his plans… – Continue reading
Former chair of the UK public accounts committee Margaret Hodge, who has repeatedly attacked the use of offshore tax avoidance schemes, has called for an overhaul of the British tax system. Speaking during an annual Professional Fee Protection (PFP) tax investigations conference, Hodge said the current tax regime in the… – Continue reading
On Oct. 5, 2015, the Organization for Economic Cooperation and Development (OECD) released a set of final reports on its 15 point action plan to address Base Erosion and Profit Shifting (BEPS). In an accompanying explanatory statement, the OECD also included plans for additional work on technical matters and a… – Continue reading
Most of yesterday’s pre-election budget statement for 2016 (the “Budget“) by Ireland’s Minister for Finance (the “Minister“) focused on personal taxation. In the portion of his statement covering corporation tax, two key announcements were made in line with expectations following on from the publication of the final reports under the… – Continue reading
Offshore companies are established for a variety of reasons including a company’s necessity to restructure, create an international business entity as well as protect the assets of the company. The United Arab Emirates (UAE) is home to three authorities that register International or offshore companies. The three UAE authorities that… – Continue reading
The Luxembourg government submitted draft legislative proposals to Parliament—legislation that, if enacted, would both implement certain provisions of the OECD’s base erosion and profit shifting (BEPS) actions and provide for certain EU-compliant measures. The proposals also would be intended to improve the competitiveness of the Luxembourg tax system. The proposals… – Continue reading
KOLKATA (miningweekly.com) – The Indian federal government has zeroed in on the mining sector as the prime repository of “black money” and unaccounted wealth stashed overseas, and was instructing a clampdown by tax authorities. In a directive to tax authorities, including the Income Tax Department (ITD), the Finance Ministry observed… – Continue reading
The Turnbull government has welcomed the support of the Labor party for the new laws that will add more teeth to the government’s crackdown on multinational tax dodgers. The government also offered to consider the suggestions of the opposition in improving the scope of the legislation. Labor formally announced its… – Continue reading
Evading and avoiding tax through the use of offshore structures and arrangements is the source of much tax loss, according to HM Revenue & Customs. No surprise then that the current Government (and the coalition before it) has been relentless in its crackdown on it, with a special focus on… – Continue reading
President Andrzej Duda signed last Friday a bill whose aim is to implement FATCA legislation – said the office of President. The law is designed to prevent US taxpayers hiding income abroad. The Act creates a legal basis that will allow implementation of the provisions under the international agreement ws…. – Continue reading
The BEPS Project involves input from the 34 member countries of the OECD, all G20 members, and more than 40 developing countries. The objective of the BEPS Project is to close gaps in international tax rules, effectively eliminating or substantially reducing BEPS; and to secure government revenues by ensuring that… – Continue reading
On 17 September, 2015, China State Administration of Taxation (SAT) released the Discussion Draft for the Implementation Measures for Special Tax Adjustments (“Discussion Draft”), as a complete revamp to the existing trial version of the Implementation Measures, i.e., Circular 2. Circular 2 has been serving as a backbone transfer pricing… – Continue reading
Shadow Assistant Treasurer Andrew Leigh will tell parliament on Monday that his party plans to support the coalition’s multinational tax avoidance crackdown. The federal government has welcomed support from the opposition for its planned crackdown on multinational tax dodgers. Extending the olive branch, the federal government is also prepared to… – Continue reading
Legislative Activity House Lawmakers Schedule Markup of Transportation Bill Without Revenue Provisions Last week, on Friday, October 16, the House Transportation and Infrastructure Committee released a six-year, $325 billion highway funding bill (the Surface Transportation Reauthorization and Reform Act of 2015); a markup of the legislation is scheduled for Thursday,… – Continue reading
The Irish Government has published an update on its International Tax Strategy, in which Finance Minister Michael Noonan stresses that the country is “well positioned for the post-base erosion and profit shifting (BEPS) world.” According to Noonan, “This is not something that has happened by accident. Difficult but necessary changes… – Continue reading
JAKARTA, Oct 19: As ‘tax-havens’ are now routing some 60 per cent of international trade, multinational corporations (MNCs) have become more aggressive in evading taxes. As the volume of global trade was estimated at $23.5 trillion in 2013, of which $18.5 trillion was trade in goods and the rest was… – Continue reading
The Chartered Institute of Taxation has criticized the UK Government for proceeding with plans for a strict liability criminal offense for failing to declare offshore taxable income or gains. Under the proposals, magistrates would be given the power to impose an unlimited financial penalty and a custodial sentence of up… – Continue reading
KEY POINTS What is the issue? Guernsey will be required to gather data for the calendar year 2016 for reporting under the Common Reporting Standard (CRS) in 2017. What does it mean for me? Practitioners should be aware that due diligence and reporting procedures are set to be amended and… – Continue reading
A little over a week ago the British parliamentarian, Sir Eric Pickles – a cabinet member until May of this year and a former Chairman of the Conservative Party – told the London Guardian that the British Prime Minister, David Cameron, was determined to have the BVI and the Cayman… – Continue reading
With Medtronic being one of Ireland’s largest employers, analysts say there is a new incentive for the medical device maker to prioritize its Dublin headquarters for R&D. In the eyes of developed nations, Ireland has become notorious for baiting multinational firms to its land with the offer of friendly tax… – Continue reading
x At present, says the Government, serial avoiders find themselves in no worse a position than someone who has used only one failed avoidance scheme and has decided not to do it again. They face no additional deterrent to stop them persistently seeking to circumvent the will of Parliament. With… – Continue reading
The Dutch government presented its Tax Bill 2016 on 15 September 2016. Three elements of this bill could specifically affect multinationals, international investors and investment funds with Dutch headquarters or group companies: The anti-avoidance rules in respect of non-resident taxation of foreign corporate shareholders and the dividend withholding tax treatment… – Continue reading
HM Revenue and Customs (HMRC) has succeeded against a £200 million tax avoidance scheme which exploited the UK’s double taxation agreement with the Isle of Man, whereby people are not taxed on the same income in both the UK and the Isle of Man. Those who took advantage of the… – Continue reading
Individuals and families whose tax plans include trusts should take note of the recent decision of the Supreme Court of Newfoundland and Labrador in Discovery Trust v Minister of National Revenue (“Discovery Trust”)1 – the first case to deal with the issue of the residency of a trust for provincial… – Continue reading
A series of recent developments means that tax is now a key part of the Australian foreign investment regime and the foreign investment rules have significantly more bite. When determining whether a foreign investment proposal is “contrary to the national interest”, the Foreign Investment Review Board (FIRB) actively considers the… – Continue reading
On 15 September 2015, the Bulgarian Council of Ministers submitted to the Bulgarian Parliament a proposal to implement the US Fair and Accurate Credit Transactions Act (FATCA) through changes in the Bulgarian Social Security Code. The proposed changes will effectively lead to the creation of an automated system for transfer… – Continue reading
The Organization of Economic Cooperation and Development (OECD) released its final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) Project on Monday October 5th, 2015. The final package of BEPS measures includes new minimum standards on: country-by-country reporting, which for the first time will give tax administrations a… – Continue reading
x Australian Prime Minister Malcolm Turnbull announces his new federal cabinet during a media conference at Parliament House in Canberra, Australia, September 20, 2015. Australia got its fifth prime minister in as many years on Monday after the ruling Liberal Party voted to replace Abbott with former investment banker Malcolm… – Continue reading
The Internal Revenue Service has made progress on implementing the Foreign Account Tax Compliance Act, including explaining the various requirements to the affected stakeholders, according to a new report. The report, from the Treasury Inspector General for Tax Administration, examined FATCA, which was included as part of the HIRE Act… – Continue reading
Israeli importers and exporters, hi-tech and trading groups will all be in the base erosion and profit shifting firing line. On October 5 the Organization for Economic Cooperation and Development published a final comprehensive package of measures aimed at multinational corporations, large and small, that engage in BEPS – base… – Continue reading
The tax world followed with great interest today´s launch of the final package of BEPS. Having the BEPS report finalized is indeed a great achievement and, as pointed out by Mr. Angel Gurría, OECD Secretary General, in his Twitter, “Agreement of #BEPS package is a historic day in our effort… – Continue reading
Gov. Udom Emmanuel of Akwa Ibom has decried what he called the high rate of tax evasion in Nigeria, describing it as inimical for the development of the country. Emmanuel said this at the opening of the Mandatory Professional Training Programme of the Chartered Institute of Taxation of Nigeria (CTIN)… – Continue reading
The Government of India, Ministry of Finance had on August 7, 2015, in order to comply with the information reporting requirements of the US’ Foreign Account Tax Compliance Act (hereinafter referred to as ‘FATCA’), made amendments in the Income-tax Rules, 1962. WHAT IS FATCA’S BACKGROUND? FATCA is a broad set… – Continue reading
The Greek Government has tabled the nation’s 2016 Budget, which includes measures agreed as part of the recently negotiated third bailout. A statement released by the Finance Ministry was vague about the measures proposed. However, it said that authorities will reform the VAT code, amend social security rates, raise corporate… – Continue reading
THE ADVANTAGES OF JERSEY For high net worth individuals considering a relocation, there are a number of factors that will be weighed up in making a choice which is right for both the head and the heart. To be a serious contender, a jurisdiction must certainly be fiscally friendly. But… – Continue reading
