For the third year on the trot, Shell service stations generated billions of dollars and revenue but not a cent in company tax. In fact the owners of the sunny yellow servos reported tax benefits in all three years despite total sales which may be in excess of $60 billion…. – Continue reading
Australian Taxation Office New or updated materials on ATO website, including: Reminder: Taxable payments annual report due 28 August Remission of penalties: information about remission of penalties following a tax dispute In focus: Procurement hubs of Australian multinational enterprises: the ATO is reviewing arrangements involving offshore entities that are being used… – Continue reading
In order to maintain a competitive edge, Malta offers wealthy individuals and corporations advantageous tax rates, using tax breaks to attract investment or hot money, which could originate from criminal activities Malta is this year expected to register the fastest growth rate in the EU, with property prices rising year… – Continue reading
The UK will help Ghana clamp down on tax avoidance and evasion by sharing expertise to improve their tax system. The UK will work with the Government of Ghana to tackle tax evasion so the country can raise revenues and build stronger public services, International Development Secretary Justine Greening and… – Continue reading
On 16 July 2015, the Government issued four consultation documents on the topic of offshore tax, non-compliance and evasion. The first consultation document discusses an increase in the minimum penalty for offshore non-compliance and evasion. This includes a new asset-based penalty regime which potentially could be so high as to… – Continue reading
A judge’s ruling that the Cayman Islands Tax Information Authority acted unlawfully when it handed over a trove of documents on two Cayman-registered companies to Australian tax authorities has been upheld by the Court of Appeal. The court ruled that the decision to provide documents, requested as part of an… – Continue reading
Tax Administration Jamaica (TAJ) says it is finalising preparations with financial institutions to have Jamaica ready for the August 17 deadline when a US tax reporting law takes effect. Jamaica and the US signed an agreement in 2014 under America’s Foreign Accounts Tax Compliance Act (FATCA), which mandates the sharing… – Continue reading
LONDON–(BUSINESS WIRE)–Three quarters of business leaders would pay more taxes in exchange for greater clarity from authorities on what is acceptable, according to the Grant Thornton International Business Report (IBR), a global survey of 2,580 businesses in 35 economies. And while few expect a global agreement any time soon, the… – Continue reading
MONTRÉAL, Aug. 5, 2015 /CNW Telbec/ – Three quarters of business leaders would pay more taxes in exchange for greater clarity from authorities on what is acceptable for tax planning, according to the Grant Thornton International Business Report (IBR), a global survey of 2,580 businesses in 35 economies. And while… – Continue reading
HMRC has won £45 million in a second tax avoidance case against Abbey National Treasury Services, a subsidiary of Santander. The tribunal ruling means £45 million is now liable to taxation in addition to another £40 million in a second case that will be decided by this ruling. The scheme… – Continue reading
Introduction The Cayman Islands have an extremely open, accountable and transparent government and regulatory system. Despite the dated stereotype, the Cayman Islands have promoted transparency regulations and initiatives for many years. In May 2000, the Cayman Islands made commitments to the Organisation for Economic Co-operation and Development (the “OECD“) to… – Continue reading
Tax Commissioner Pierre Moscovici has said that European Commission law was not breached in the case of a French professional association taxing royalty payments earned by UK musicians in France. In a written question to the European Commission, Julie Girling, a UK Member of the European Parliament (MEP), alleged that… – Continue reading
Business executives are giving mixed predictions on when and if tax reform will finally happen in Washington, in a new survey, reports Accountancy Today. The latest Business Tax Reform Barometer survey from the Tax Council and Ernst & Young polled approximately 1,000 business executives, tax directors, government relations representatives and… – Continue reading
Introduction Following the implementation of the EU Alternative Investment Fund Managers (AIFM) Directive (2011/61/EC) and associated legislation, Cyprus now lays claim to being a growth jurisdiction within the European Union for the establishment and servicing of boutique and low cost alternative investment funds based locally or offshore. The choice of… – Continue reading
On May 20, 2015, the U.S. Treasury Department (“Treasury”) released five sets of proposed revisions to the U.S. Model Income Tax Convention (“Model Treaty”) for public comment. The Model Treaty was last updated in 2006. The purpose of the proposed revisions is to ensure that the United States maintains the… – Continue reading
The Davis Tax Committee’s First Interim Report on Estate Duty (“DTC Report”) was released for public comment on 13 July 2015. In essence, the DTC Report proposes that “a highly progressive tax that patches loopholes, helps provide equality of opportunity and reduces the concentration of wealth, must be implemented”. The… – Continue reading
A challenge by way of judicial review to notices issued by HM Revenue & Customs (HMRC) requiring “accelerated payment” of tax pending the outcome of a tax dispute has been dismissed by Mrs Justice Simler DBE in the High Court.04 Aug 2015 Tax Disputes and Investigations Litigation & International Arbitration… – Continue reading
Two Canadian women begin their Federal Court case in Vancouver on Tuesday, seeking to have a judge declare that Canada’s cooperation in supplying financial information to U.S. tax collectors is unconstitutional. Gwen Deegan, 53, a Toronto graphic designer, and Ginny Hillis, 68, a retired lawyer living in Windsor, were both… – Continue reading
An agreement signed between Kenya and the American government could introduce new drastic measures in curbing corruption and help seal loopholes in the dwindling war against the vice in the government. But the initiative could dampen hopes of Cabinet secretaries mentioned in various corruption scandals of ever getting back to… – Continue reading
The tax and in particular the transfer pricing arrangements of multinationals is currently under the spotlight both internationally, through the OECD/G20 BEPS project, and domestically in Australia, by way of the Senate inquiry into corporate tax avoidance. This has resulted in new legal measures being adopted (such as the DPT… – Continue reading
This article is the third in our current three part series discussing various impacts of the Organisation for Economic Co-operation and Development’s (OECD’s) efforts to address the perceived global tax problem of base erosion and profit shifting (BEPS). The first article provided an overview of the key aspects of the… – Continue reading
On August 3, 2015 the Global Forum on Transparency and Exchange of Information for Tax Purposes published 12 new peer review reports. Phase 1 reports were published on: Albania, Burkina Faso, Cameroon, Dominican Republic, Lesotho, Pakistan and Uganda. The reports assessed these countries’ legal and regulatory frameworks for transparency and… – Continue reading
United Kingdom Budget The Chancellor of the Exchequer delivered his Summer Budget to the United Kingdom (UK) Parliament on 8 July 2015. A number of personal, corporate and indirect tax-related measures were announced in the Budget including a reduced corporate tax rate; introduction of a bank corporation tax surcharge; a… – Continue reading
Maples and Calder and Maples Fund Services representatives explain how US and UK Fatca will impact Cayman-based funds. The implementation of the US Foreign Account Tax Compliance Act (US Fatca) and the less well-known but equally applicable UK equivalent (UK Fatca) have been a topical and core focus for Cayman… – Continue reading
The Barbados Revenue Authority (BRA) was subjected to rigorous assessments by the United States Internal Revenue Service (IRS) recently in a bid to verify the island’s readiness to enact the Foreign Account Tax Compliance Act (FATCA), reports Barbados Today. Anthony Gittens, the BRA’s manager of policy and planning, said as… – Continue reading
The United States finally took its first step toward a more competitive tax position for intellectual property in the United States. Although some might call it a baby step, the release this week of a discussion draft of legislation proposed to lower the tax rate on income from intellectual property… – Continue reading
The tax authorities in Portugal today announced that the initial reporting deadline for foreign financial institutions has been extended to 30 November 2015 (from the original deadline of 31 July 2015). Also, while it has been reported that negotiations for an intergovernmental agreement (IGA) between Portugal and the United States… – Continue reading
Governments that offer multi-national firms sweetheart tax deals should not be allowed to benefit if the European Union orders them to claw back the aid, according to a new report by the European Parliament’s special committee on tax rulings. Instead, the proceeds should be “returned to the member states which… – Continue reading
Canadian financial institutions will be subject to the Organisation for Economic Co-operation and Development’s (OECD) Common Reporting Standard as of July 1, 2017 with the first exchanges of financial account information beginning in 2018. The CRS, known formally as the Standard for Automatic Exchange of Financial Account Information in Tax… – Continue reading
On 9th July 2015, the Cyprus House of Representatives voted in favour of the introduction of a Notional Interest Deduction regime, aimed at encouraging investment into corporate structures, and thus reducing excessive debt financing. Such changes, aimed to further improve Cyprus’ growth prospects, will align the Republic’s system with that… – Continue reading
In the wake of the recent arrests of stakeholders in the Maltese remote gaming sector, it seems that professional firms and the remote gaming authority did not carry out due diligence appropriately on ultimate beneficial owners of the companies they have registered and represented. This failure has seriously tarnished Malta’s… – Continue reading
NEW DELHI: The government today said it’s taking effective steps to deal with black money and will focus on high-impact cases with a view to prosecuting offenders expeditiously for credible deterrence against tax evasion. “While focusing on non-intrusive measures, due emphasis has been given on enforcement measures in high-impact cases… – Continue reading
On 25 July 2015 the Cabinet of Ministers of Ukraine published an order on the conclusion of advance pricing agreements (“APA”) in respect of controlled transactions for transfer pricing purposes* (“the APA Order”). The APA Order replaces the former procedure for the conclusion of APAs which became outdated due to… – Continue reading
Understanding FATCA and having a comprehensive FATCA compliance program is essential for financial firms to limit non-compliance risk and meet obligations with relevant IGA’s. The US has made inroads on the Exchange of Information front and tax havens like Switzerland have declared a willingness to meet or even exceed OECD… – Continue reading
Over the past year, a number of legislative measures have been adopted to ensure that the Cayman Islands remains the leading jurisdiction of choice for structured finance and capital markets transactions and for secured lending transactions generally. This article focuses on two recent key legislative developments. The first is the… – Continue reading
Over the past year, a number of legislative measures have been adopted to ensure that the Cayman Islands remains the leading jurisdiction of choice for structured finance and capital markets transactions and for secured lending transactions generally. This article focuses on two recent key legislative developments. The first is the… – Continue reading
On June 22, 2015, the finance ministry issued Circular 96/2015/TT-BTC, guiding the corporate income tax regime in Decree 12/2015/ND-CP (“Decree 12”) of the government, dated February 12, 2015. Decree 12 provides the details for the implementation of the law that amends and supplements some articles of tax laws, tax decrees… – Continue reading
“People have had ample opportunity to regularise their affairs”, says HMRC as it presents the next move in its “No Safe Havens” strategy. A package of measures was proposed in the Summer Budget 2015 designed to ramp up HMRC’s powers to tackle offshore tax evasion. With civil deterrents and civil… – Continue reading
There has been much recent focus on tax structures employed by multi-national corporations. This has led to an initiative, spearheaded by the OECD, to combat “base erosion and profit shifting”, or BEPS. The shipping industry is likely to be affected both directly and indirectly by the BEPS initiative – directly,… – Continue reading
Introduction The Cyprus Government has announced a number of proposed tax incentives aimed at encouraging economic activity and attracting inward direct investment. It has also submitted a number of draft laws to the House of Representatives to implement the new provisions of the EU Parent-Subsidiary Directive, to simplify the tax… – Continue reading
A U.S. Senate investigative subcommittee, which has used its power for more than a decade to scrutinize corporations and financial institutions for wrongdoing, is shifting its focus to keeping tabs on the government. The U.S. Senate Permanent Subcommittee on Investigations is slated to hold its first hearing under new leadership… – Continue reading
In the first 100% Conservative Budget in nearly two decades, chancellor George Osborne has introduced a raft of changes, including significant revisions to UK non-dom status. On 8 July, chancellor George Osborne delivered the first Conservative Government Budget for 19 years. Many headlines had already been flagged up in advance,… – Continue reading
A litigation suit has been filed against the US federal government arguing the Foreign Account Tax Compliance Act (FATCA) is “unconstitutional” and violates privacy rights, with implications for Australian financial institutions. The controversial FATCA tax legislation – which was introduced by the Obama Administration in 2010 – requires foreign financial… – Continue reading
Globalisation has brought many benefits in terms of cross?border trade, efficiency, competition and the free movement of goods and labour. But it has also allowed multinational corporations (MNCs) much greater freedom to reconfigure the location of manufacturing, operations, sales and corporate services in ways which channel reported profits ? and… – Continue reading
White-collar criminals who launder billions by buying luxury UK properties must be tackled, Prime Minister David Cameron said on Tuesday. Experts warn these fraudsters are distorting the UK property market and pushing up house prices in the process. Cameron’s criticism of money laundering formed part of a broader speech on… – Continue reading
Former Attorney-General Mark Pettingill describes the suggestion he had someone seeking payment of a bribe on his behalf as “ridiculous” A developer’s allegations of Government corruption over the development of the Hamilton waterfront are “farcical” and based on “hearsay, innuendo and lies”, according to Mark Pettingill, the One Bermuda Alliance… – Continue reading
This article deals with the manner in which Canada has complicated, and rendered controversial, what in most other countries is straightforward — the deductibility of business related interest expense. The reasons to write about it are threefold: the almost-concurrent issuance of the Canada Revenue Agency’s administrative views on the matter… – Continue reading
The Republic of Cyprus has once again kept its promise to international investors and introduced on the 9th of July 2015 amendments to its tax legislation making the jurisdiction as attractive as never before. The purpose of these amendments is to clearly establish Cyprus as the leading tax jurisdiction in… – Continue reading
A litigation suit has been filed against the US federal government arguing the Foreign Account Tax Compliance Act (FATCA) is “unconstitutional” and violates privacy rights, reports the Investor Daily. The complaint was officially filed in a federal court in Dayton, Ohio on Tuesday, and names the Treasury Department and Inland… – Continue reading
Black Money Act covers residents with undisclosed foreign assets and income and non-residents who have invested Indian-sourced income in offshore assets Compliance Scheme window open only till 30 September for declaring assets and until 31 December 2015 to pay tax at 30% and penalty at 30%. Revenue recommends disclosure of… – Continue reading
