The Davis Tax Committee (“DTC”) recently addressed the issue of base erosion and profit shifting (“BEPS”) in South Africa. The international importance of transfer pricing was once again emphasized when 4 out of the 15 actions identified in the OECD Action Plan on BEPS related to transfer pricing. The 15… – Continue reading
The Standing Committee’s recommendation comes after the finance minister announced in the Budget that DTC would not be pursued as most provisions of the code have been incorporated in the existing Act. Even as finance minister Arun Jaitley scrapped the proposed direct taxes code (DTC) in Budget 2015-16, the standing… – Continue reading
Passing between tax administrations Polish and US information on accounts and income tax residents predicts signed by the president Bronislaw Komorowski law on ratification of the agreement with the USA on the use of so-called FATCA Act. As reported by the presidential office, in terms of the Act of 20… – Continue reading
A guide to Spanish taxation in 2015 for expats, with up-to-date information on income tax, VAT, property tax and other taxes for residents and non-residents in Spain. If you are living and working in Spain, you will be liable to pay Spanish taxes on your income and assets and will… – Continue reading
Thailand is expected to introduce new transfer pricing (TP) laws in the near future, which will apply to all companies in the Kingdom with related-party transactions. At a recent Deloitte seminar on “Thailand TP Developments”, with participation from senior officials from the Revenue Department, we shared some valuable insights on… – Continue reading
The CBDT has constituted a high- level committee to secure confidential tax data, obtained under mutual exchange with US authorities, as part of India’s compliance measures for signing the much awaited Foreign Account Tax Compliance Act (FATCA). The seven-member panel will be headed by the Member (Income Tax) of the… – Continue reading
The IRS, the most powerful and least accountable agency of the federal government, is an admitted criminal enterprise. To deal with this, Republican candidates for president are placing tax reform at the top of their agendas. You will have to guess why the Democrats seem not to care. Sen. Ted… – Continue reading
Mauritius and Singapore are both examples of countries with Double Taxation Avoidance Agreements (DTAAs) with India, meaning dividends from corporations that are paid out to shareholders are not taxed further, having already been taxed at the corporate level. This legislation has meant that such countries have been used to “round-trip”… – Continue reading
The patent box regime, adopted at the end of 2014 with Italy’s Stability Law, was recently modified by the Investment Compact Decree and implemented into law at the end of March 2015. A distinctive feature of the Italian regime is that the measure now also covers trademarks and designs. A… – Continue reading
The Tax Foundation released its inaugural “International Tax Competitiveness Index” (ITCI) on September 15th, 2014. The United States was ranked an abysmal 32nd out of the 34 OECD member countries for the year 2014. (See accompanying Table 1.) The European welfare states such as Norway, Sweden and Denmark, with their… – Continue reading
On 21 April 2015, the Danish Parliament adopted a bill, which sets out to deal with certain potential abuses recently encountered by the tax authorities as well as the Danish enactment of the general international anti-abuse initiatives currently considered at EU and OECD level. The new Danish GAAR will take… – Continue reading
A Netherlands-based company threatened to sue the South Korean government for inflicting more than 183 billion won in losses through double taxation during its sale of Hyundai Oilbank shares five years ago, it was revealed Saturday. If a lawsuit is filed, it will mark the second time for South Korea… – Continue reading
Taipei, May 2 (CNA) Taiwan has reached an agreement with Canada on the avoidance of double taxation at an annual bilateral economic consultation, the Ministry of Economic Affairs (MOEA) said Saturday. The double taxation avoidance pact, which will be signed very soon, will be favorable to Taiwan businesses because it… – Continue reading
Fraud claims against Proskauer Rose stemming from a tax shelter scheme it helped sell to the heirs of the Johnson & Johnson fortune will survive a motion to dismiss, the Appellate Division, First Department, ruled Thursday. A unanimous panel, in an opinion written by Justice Angela Mazzarelli, affirmed a ruling… – Continue reading
A year after the signing of the intergovernmental agreement regarding FATCA (Foreign Account Tax Compliance Act) between Luxembourg and the United States, the bill of law was finally introduced on 27 March 2015 to the Luxembourg Parliament. The bill of law relates to the exchange of tax information between the… – Continue reading
MUMBAI: Five Foreign Portfolio Investors (FPIs) on Thursday mainly from the US and the UK have dragged the Indian government and the Income Tax department to the court for levying Minimum Alternate Tax (MAT) on their capital gains for the year 2011-12. The five FPIs — National Westminster Bank Plc,… – Continue reading
With its enviable reputation in offshore trusts, pensions and insurance, Bermuda is an ideal jurisdiction for employers to establish international pension and employee benefit plans (IPPs). Global organisations may consider establishing Bermuda IPPs for employees who work outside their home country or the home country of both the employees and… – Continue reading
The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project is changing the international tax landscape by building a new international consensus on how to tackle BEPS. In September 2014, the first seven of the deliverables under the 15-point BEPS Action Plan were presented to G20 Finance Ministers when they met… – Continue reading
A committee set up by the finance ministry to address industry’s tax concerns has invited trade and industry for talks on the issue. Experts, however, say Finance Minister Arun Jaitley should have in his reply to a debate on the Finance Bill 2015 provided clarity on minimum alternate tax (MAT)… – Continue reading
Iran and the Czech Republic have signed an agreement which allows the two countries’ companies to avoid paying double tax on their trade activities. The agreement was signed on Thursday by Iran’s Minister of Economic Affairs and Finance Ali Tayyebnia and his Czech counterpart, Andrej Babiš, in the Czech capital… – Continue reading
During 2014, Barbados again produced strong evidence of the underlying strength of its financial system. All of the financial stability indicators and stress tests performed for the financial system strongly indicate that the system remains stable with the capacity to withstand a wide variety of severe economic shocks. It is… – Continue reading
The game of cat and mouse between tax authorities and citizens has been played for a very long time. People have been dodging taxes for centuries. But the more nuanced and sophisticated game of avoiding tax is a more recent phenomenon. Indeed, when it comes to tax avoidance the game… – Continue reading
An independent group of tax professionals should report annually to parliament on whether new legislation complies with the rule of law, the Law Society’s tax committee recommended this week. Publishing a position paper on tax and the rule of law, committee chair Gary Richards said that ‘legislative hyperactivity has become… – Continue reading
Hong Kong’s Secretary for Financial Services and the Treasury, K C Chan confirmed that the Government and regulators remain fully committed to combating money laundering and tax evasion, following the latest reports of foreign banks being used to open offshore accounts. In response to a question in the Legislative Council,… – Continue reading
The European Union (EU) needs an “ambitious blueprint for taxation,” Tax Commissioner Pierre Moscovici has said. Speaking at a recent conference, Moscovici said: “The European Union needs an ambitious roadmap to put an end to the distortionary nature of its tax policy and regulatory framework. In my view, the way… – Continue reading
The Supreme Court of Canada has dismissed Conrad Black’s bid to have his multi-million-dollar battle with the Canada Revenue Agency over back taxes heard by the country’s highest court. The Supreme Court of Canada has dismissed Conrad Black’s bid to have his multi-million-dollar battle with the Canada Revenue Agency over… – Continue reading
Big hue and cry from the rich and the powerful against modification of tax return forms has again pushed the govt on back foot John Maynard Keynes famously said the avoidance of tax is the only intellectual pursuit that carries a reward. Historically, tax ‘avoidance’ is understood as an intellectual… – Continue reading
COMPANIES that engaged in tax avoidance practices such as the abuse of transfer pricing should be expropriated without compensation, Economic Freedom Fighters (EFF) MP Floyd Shivambu proposed in Parliament on Wednesday. This was one of a raft of “aggressive” measures that he believed the government should adopt to deal with… – Continue reading
As discussed in our previous briefing, Labour calls time on the remittance basis, Ed Miliband has announced a policy of abolishing what he called the “non-dom tax regime”, to be implemented in the event of a Labour victory in the coming election. Many individuals who are UK resident but non-UK… – Continue reading
The Tax Office is cracking down on what it’s described as “contrived arrangements” that allow hundreds of wealthy individuals with self-managed superannuation funds (SMSFs) to pay no tax on income from shares. Cases are still being reviewed and it’s unclear how much tax revenue may be at stake. But the… – Continue reading
Autumn Statement 2014, Budget 2015 and Finance Act 2015 The UK Chancellor delivered his Autumn Statement on 3 December 2014 and his Budget speech on 18 March 2015. For an overview of some of the key announcements, please see our Autumn Statement 2014 briefing and Budget 2015 briefing. The UK’s… – Continue reading
TEHRAN, Apr. 29 (MNA) – Leading a high-ranking delegation of officials, Iran Minister of Economic Affairs and Finance departed for Prague this morning. Ali Tayyeb Nia is scheduled to hold meetings with his Czech counterpart and Czech vice-president of the Republic Parliament. Discussing development of ties and singing the MoU… – Continue reading
Most people have heard of the Organisation for Economic Co-operation and Development (OECD) and are probably aware it wants to make the world a “better” place. Its work is probably of little interest to most companies based in the UK. But this would change if constitutional arrangements between Scotland and… – Continue reading
There has been a lot of uncertainty with regard to withholding taxes imposed by the South African Revenue Service (SARS) on cross-border payments made by South Africans to offshore recipients, and the ambiguous administrative and compliance procedures relating thereto. Based on the information available directly from SARS, any amounts received… – Continue reading
There is a great need to protect traditional knowledge in order to curb the exploitation of holders of indigenous knowledge, particularly the elderly. It has been observed that the elderly have indigenous knowledge but their wisdom is being stolen from them and used for commercial purposes while they languish in… – Continue reading
Hong Kong (HKSAR) – Following is a question by the Hon Frederick Fung and a written reply by the Secretary for Financial Services and the Treasury, Professor K C Chan, in the Legislative Council today (April 29): Question: It has been reported that an investigation conducted jointly by an international… – Continue reading
The Companies (Amendment) Act 2014 (the “Amendment Act”) which will introduce wide-ranging changes to the Companies Act, will be implemented in two phases. Two-phase implementation: 1 July 2015 and Q1 2016 About 40% of the changes in the Amendment Act will take place in the first phase on 1 July… – Continue reading
If Illinois small business owners were to collectively offset state and federal revenues lost annually due to corporations using offshore tax havens, they would each have to pay $4,570 in additional taxes a year. That what-if scenario is laid out in a recent report from the Illinois Public Interest Research… – Continue reading
Athens: Greek authorities arrested one of the most important businessmen in the country, Leonidas Bobolas on Wednesday, for tax evasion. He was released later after paying €1.8 million in back taxes. This is just one of the Greek government’s attempts to collect money from tax evaders. In Greece, income tax… – Continue reading
The new omnibus bill presented by the Greek ministry of finance will be tabled in parliament on Thursday in order to expedite negotiations with creditors and reach an intermediate deal. The new bill includes several measures and reforms such as methods of tackling tax evasion, revenue increase from value added… – Continue reading
The Italian Minister of the Economy and Finance, Pier Carlo Padoan, has confirmed that he expects additional tax revenue from Italian citizens with undeclared investments in San Marino from the Italian voluntary disclosure program. In a television interview in San Marino, he noted that Italy had definitively removed San Marino… – Continue reading
State Representative Natalie Manley (D-Joliet) is sponsoring legislation that would prohibit Illinois from double taxing income that is earned in another state when the taxpayer’s home office is based in Illinois. “Right now Illinois residents are taxed on most income received in other states, rather than just income earned in… – Continue reading
Starting with 1 June 2015, non-resident taxpayers earning interest income from Romania are allowed to apply the same tax treatment as resident taxpayers. The change in the law results from a European Commission infringement procedure against Romania regarding the discriminatory treatment applied to non-resident legal entities compared to resident taxpayers…. – Continue reading
The regulations require reporting FIs to notify TIA if they have reporting obligations under US FATCA and/or UK CDOT. With respect to US FATCA, Reporting FIs have until tomorrow (April 30th) to file their notification with an initial reporting deadline May 31st. With respect to UK CDOT, Reporting FIs have… – Continue reading
As compared to past federal Budgets, Budget 2015 contained fewer (and arguably less controversial) international tax measures. Nevertheless, Budget 2015 did announce the Government’s intention to address taxpayer concerns relating to (i) the withholding obligations borne by non-resident employers that have non-resident employees that work in Canada, and (ii) the… – Continue reading
Mitsubishi UFJ Fund Services warn managers are up against a time crunch ahead of the April 30 registration deadline The upcoming April 30 deadline for registration on the Cayman Foreign Account Tax Compliance Act (Fatca) portal marks another milestone but could prove a significant test for the industry, according to… – Continue reading
The convention for the avoidance of double taxation and the prevention of tax evasion with respect to taxes on income was signed at the Ministry of Foreign Affairs of Portugal yesterday between the Government of Oman and the Government of Portugal, reports the Oman Observer. The convention was signed on… – Continue reading
The Income Tax department has directed its officers that cases of foreign institutional investors (FIIs) seeking tax exmption under the Double Taxation Avoidance Agreements (DTAAs) with other countries must be decided within a month of claim filing, reports the New Kerala. “It has been decided that in all cases of… – Continue reading
“Why are we doing this to folks? Why are we tormenting them in this way?” IRS Taxpayer Advocate Nina Olson asked in an address to Securities Industry and Financial Markets Association FATCA Policy Symposium in Washington last year. These “folks” are Americans living abroad: NGO workers, English teachers, physicians, taxi… – Continue reading
Although you may be working in China, does the ATO still consider you an Australian resident? It’s just one of the things you need to get absolutely right. The tax requirements for Aussies working overseas vary from region to region. Aussies working in Hong Kong will find last month’s tax… – Continue reading
