Category: Tax Laws

Black money: Keep foreign information strictly secret, CBDT tells its officials

NEW DELHI: CBDT has issued fresh instructions to the taxman to ensure that information on individuals holding black money abroad is strictly kept secret as it stressed that any “careless” act could give an excuse to the data supplying country for not helping India in the future. “In many countries,… – Continue reading

deVere: Presidential candidates owe it to America to explain their stance on controversial FATCA

Presidential candidates must come clean on America’s highly controversial global tax law – and more must urgently be done to repeal it, not least because it is “a blue print for worse to come”, warns the boss of one of the world’s largest independent financial advisory organisations. Nigel Green, founder… – Continue reading

Business group warns on offshore tax measures

A powerful business lobby is sounding the warning to lawmakers about a global effort to crack down on offshore tax evasion. The National Association of Manufacturers warned the top congressional tax writers that the so-called Base Erosion and Profit Shifting project “could have a negative impact on the global competitiveness… – Continue reading

United States: U.S. Treasury Department Releases Proposed Model Treaty Provisions

On May 20, 2015, the U.S. Treasury Department released for public comment draft updates to the U.S. model income tax convention and its accompanying Technical Explanation (collectively, the “Model Treaty”), which was last updated in 2006. The Model Treaty is the template that Treasury uses as its starting point in… – Continue reading

Asia: Tax & Trust Developments Taking Center Stage

Developments in Asia over the last year have been continuous with the biggest generic development relating to the exchange of information. Asian countries have put their FATCA reporting systems in place (even though not all have yet signed an inter-governmental agreement with the US IRS), and most have now committed… – Continue reading

The Bahamas Chooses the Path of Innovation, Compliance

The past decade or more has not been an easy road to manoeuvre for IFCs. The Bahamas like other IFCs has faced the combined challenges of international initiatives, increased competition, industry consolidation, changing client demographics, emerging market requirements; legacy market stagnation and of course the financial crisis just a few… – Continue reading

Hong Kong: Will The Very Efforts Designed To End The Offshore Industry Finally Legitimise It?

Since the beginning of the global financial crisis, politicians, the media and people on the street have engaged in a series of “blame games” to point fingers and punish those responsible for their own economic ills. For the past few years, one “culprit” has been firmly in the spotlight –… – Continue reading

GE’s Record Of Tax Avoidance

It is rich to see General Electric lead the pack of companies complaining about oppressive taxes. GE notoriously paid no federal income taxes from 2008 to 2013, according to the U.S. Public Interest Research Group. In fact, its corporate tax rate was negative 9 percent; GE got back from taxpayers… – Continue reading

French tax updates – recently published noteworthy publications

The present French Tax Update will focus on an overview of several noteworthy French tax court decisions issued during the past few months, in particular in relation with double tax treaty conditions to benefit from a tax credit, abuse of law challenges, increased amortization rates, and priority preliminary ruling requests… – Continue reading

New Argentina­Chile tax treaty creates fresh structuring opportunities

Argentina and Chile have signed a new double tax treaty to replace the treaty unilaterally terminated by Argentina in 2012. Ignacio Rodriguez and Andres Edelstein of PwC in Argentina outline the new structuring opportunities that are available for taxpayers. Argentina and Chile signed a new double tax treaty on May… – Continue reading

Pharmaceutical companies called on to explain tiny tax contribution

The five biggest suppliers of publicly subsidised medicines in Australia recorded sales of nearly $5 billion last year but paid an average of just $10 million each in company tax. Research by the Parliamentary Library, obtained by Fairfax Media, has disclosed the tax contribution of multinational pharmaceutical companies, including Pfizer… – Continue reading

POLAND TAKES GIB OFF ITS TAX HAVEN BLACK LIST

Poland has removed Gibraltar from its schedule of countries and territories that it considers to be non-cooperative tax havens, the latest in a string of countries to do the same. The move means Gibraltar companies have been freed from previously held restrictions when doing business with Polish companies. It follows… – Continue reading

What Nigeria, Singapore stand to gain from investment promotion, protection pact –Ambassador Rajis-Opara

From today, negotiation on the Investment Promotion and Protection Agreement (IPPA) between Nigeria and Singapore will start in Abuja, aimed at enhancing business between the two countries. Revealing this in an interview with the African Independent Television (AIT), Nigerian High Commissioner to Singapore. Mrs. Nonye Rajis-Opara, said there would be… – Continue reading

UK FATCA – Alternative reporting regime for UK resident non-domiciled individuals

The British Virgin Islands and the Cayman Islands have entered into agreements with the UK for automatic disclosure of information in respect of interests in financial accounts held by UK residents. Most UK residents are taxed on the “arising” basis meaning they are liable to pay UK tax on worldwide… – Continue reading

Gibraltar Meets With New EU Tax Ruling Commitee

Gibraltar’s Chief Minister, Fabian Picardo, has met with the new TAXE committee of the European Parliament and defended the territory’s tax ruling regime. The TAXE Committee was established earlier this year in the wake of the leak of confidential tax rulings provided by EU member states to certain multinationals. The… – Continue reading

Irish with Swiss bank accounts will lose their secrecy – MEP

Irish citizens holding bank accounts in Switzerland will no longer be able to avail of the traditional secrecy pertaining to Swiss bank accounts, MEP Marian Harkin has said. The European Commission and Switzerland this week signed an agreement that is intended to clamp down on tax evasion. Both sides will… – Continue reading

BBC uncovers ‘aggressive’ tax avoidance scheme

Anderson Group, one of the recruitment industry’s most high-profile companies, is promoting an “aggressive” tax avoidance scheme which experts are calling “abusive”. The scheme works by exploiting the government’s Employment Allowance. The scam could deprive the Treasury of tens of millions of pounds of National Insurance payments. Anderson Group says… – Continue reading

Guernsey: Guernsey Issues Amended Legislation And Updated Draft Guidance Notes On FATCA-Based Reporting

On 31 March 2015 amendments were made to the Income Tax (Approved International Agreements) (Implementation) (United Kingdom and United States of America) Regulations, 2014 (the “2014 Regulations”) which brought FATCA-based reporting into force under Guernsey law. FATCA-based reporting is implemented in Guernsey pursuant to the UK-Guernsey IGA, signed on 22… – Continue reading

Switzerland, Italy Talk Tax Cooperation

Swiss and Italian foreign ministers recently met to discuss taxation, finance, transport, and other cross-border issues. Didier Burkhalter, head of Switzerland’s Federal Department of Foreign Affairs, received Italian Foreign Minister Paolo Gentiloni for official talks in Bern on May 28. The ministers welcomed the bilateral agreement on finance and taxation… – Continue reading

Elite group of British-born residents enjoy ‘non-dom’ tax haven

At least 800 British-born United Kingdom residents enjoy “non-domiciled” status, a tax break intended for temporary residents, according to data released in response to a Freedom of Information Act request by Reuters. Lawmakers said the information highlighted the need to change the tax rules to ban so-called “hereditary non-doms”, where… – Continue reading

After Switzerland, government talking to other havens

After securing Switzerland’s cooperation in getting information about people with undisclosed income in bank accounts, the tax department is now focusing on other such destinations. According to sources, other countries have also begun sharing information on assets held there by Indians, and the I-T department will investigate this and issue… – Continue reading

Is it US taxable income? Unintended consequences when US residents receive assets from their family’s foreign corporations

It is not uncommon for affluent families from certain countries to maintain offshore structures to hold a portion, and often times a significant portion, of their wealth. The reasons for holding assets outside of their country of residence are many, and such assets are frequently held in foreign corporations. As… – Continue reading

Tax Planning And Portugal’s Non Habitual Residence Scheme

Portugal can be a very attractive country to live in from a tax point of view. The inheritance tax regime is very benign here, and there is no wealth tax. Tax efficient arrangements can lower tax liabilities on your investment and pension income. And if you are a new resident,… – Continue reading

Common tax base proposed for EU by Brussels

Brussels competition arm investigating Ireland for use of ‘comfort letters’ to companies The European Commission is to propose a mandatory common corporate tax base next month as part of a wide-ranging clampdown on corporate tax avoidance. Under a discussion document to be looked at by EU commissioners in Brussels today,… – Continue reading

European Commission Proposal: automatic exchange of cross-border advance tax rulings

On March 18, 2015, the European Commission (the “Commission”) published a package of tax transparency measures. The tax transparency package is the result of the Commission’s ambitious agenda to confront harmful tax competition and perceived corporate tax avoidance in the European Union. The Commission has prepared a proposal for a… – Continue reading

Oman: Taxpayers set to face more scrutiny

Muscat: Taxpayers across the globe, including Oman, are facing increased scrutiny of their tax returns and positions taken as the pressure on governments increases to raise revenues from taxes, says an expert at KPMG. Ashok Hariharan, partner and head of tax for KPMG in the Middle East and South Asia… – Continue reading