The Government has introduced the Advance Pricing Agreement (APA) Scheme through Finance Act, 2012 and Income Tax (Tenth Amendment) Rules, 2012 notified vide S.O. 2005(E) with effect from 30th August, 2012. The APA Scheme endeavours to provide certainty to taxpayers in the field of transfer pricing through an agreement in… – Continue reading
The Federal Board of Revenue (FBR) has received a budget proposal of the Overseas Investors Chamber of Commerce & Industry (OICCI) regarding reduction in activation tax on mobile phones from Rs 250 to Rs 150 and withdraw sales tax on SIM card issuance and IMEI tax to avoid double taxation… – Continue reading
Where applicable, foreign landlords with property in Turkey are required to file tax returns to Turkish financial authorities by March 25 The tax treatment of income elements earned by foreigners from any source of income usually tops the international tax agenda and is extensively debated worldwide by experts, academics and… – Continue reading
Owning real property on both sides of the border can create a confusing tax situation. Consider this example. Stefan and Jane are married and live in Vancouver. Jane is a Canadian citizen while Stefan holds both U.S. and Canadian citizenship. In 1994, shortly after getting married, they bought a house… – Continue reading
Rafal Mikulski of Dentons explains why Cayman Islands’ investment funds may be entitled to a tax exemption in Poland and to claim for overpaid tax from the Polish tax authorities The Agreement for the Exchange of Information Relating to Tax Matters signed on November 29, 2013, by and between the… – Continue reading
The Central Board of Direct Taxes (CBDT) will issue detailed guidelines to ensure that non-resident companies holding a board meeting or two in India do not get any tax demands on their global income on account of New Delhi’s new wider definition of a resident company. Sources said the new… – Continue reading
Tough tax disclosure laws introduced by the former Labor Government represent “an invasion of privacy and intrusion for Australian private companies,” Prime Minister Tony Abbott has said. Abbott made the comment during a joint press conference with the Assistant Treasurer Josh Frydenberg. The press conference followed a meeting of the… – Continue reading
The government has moved to legislate in haste to close tax loopholes. But history suggests this is unwise. One legal figure to crop up in the chancellor’s budget statement published yesterday was the ubiquitous Sir Brian Leveson. The president of the Queen’s Bench Division receives a namecheck in the budget’s… – Continue reading
While the problems with our international tax system are complex, the solution is relatively simple: U.S. corporations should pay the same tax rate, at the same time, on their domestic and foreign profits. The ranking member of the Senate Finance Committee, Sen. Ron Wyden, made the case for this reform… – Continue reading
The Organisation for Economic Cooperation and Development (OECD) has welcomed Switzerland’s recent moves towards greater tax transparency, admitting the country to phase 2 of the peer review process. Jacques de Watteville, head of Switzerland’s State Secretariat for International Financial Matters, said: “We are delighted about this decision. It is the… – Continue reading
GENEVA: Facing a global crackdown including from India on their ‘safe haven’ tag, Swiss banks today asserted that “bank-client confidentiality” will not disappear and ‘automatic information exchange’ is not the only solution to the black money menace. The assertion comes at a time when Switzerland is in the process of… – Continue reading
BENGALURU, MARCH 19: IT major Wipro has won a legal victory with the Karnataka High Court allowing it to save a significant amount in taxes from its overseas operations. The judgment is likely to have an impact on Indian companies that have overseas operations. US taxes In a ruling on… – Continue reading
Tax Commissioner Chris Jordan says information sharing with foreign nations has allowed it to raise $730 million worth of tax liabilities over the past two financial years. In a speech to be delivered at the Tax Institute’s annual conference in Gold Coast on Thursday morning, Mr Jordan says he is… – Continue reading
ACCA takes note of the publication of the first of two tax transparency packages promised by the EC and welcomes, in principle, the proposal to extend the automatic exchange of information on tax rulings with some reservations. As part of its announced agenda to tackle corporate tax fraud and harmful… – Continue reading
The recent cases of FCT v Darling [2014] FAM CAFC 59 (Darling) and International Litigation Partners Pte Ltd v FCT [2014] FCA 671 (Litigation Partners) have cast the spotlight on the Commissioner of Taxation’s (Commissioner) ability to access information from the contents of Family Court files in order to assist… – Continue reading
Opposition firebrand Alexey Navalny called Tuesday for the dismissal of hockey legend Slava Fetisov from Russia’s Federation Council, alleging that the senator owns offshore assets in Cyprus in violation of Russian law. Navalny, the head of the Anti-Corruption Foundation, uploaded to his blog a series of documents allegedly evidencing Fetisov’s… – Continue reading
MINSK, 18 March (BelTA) – Belarus and the United States of America signed an intergovernmental agreement to improve international tax compliance and to implement the U.S. Foreign Account Tax Compliance Act (FATCA), BelTA learned from the press service of the Belarusian Foreign Ministry. The signing ceremony took place at the… – Continue reading
The measure The Chancellor confirmed that the new diverted profits tax (DPT) will be introduced from 1 April 2015. DPT will apply in two distinct situations, being: Where a foreign company has artificially avoided having a taxable presence in the UK; and Where a UK company (or a UK permanent… – Continue reading
The Cook Islands has been rated “largely compliant” in a phase two peer group review conducted by the Organisation for Economic Co-operation and Development’s (OECD’s) Global Forum on Transparency and Exchange of Information for Tax Purposes. The key findings of the review were that the Cook Islands has adequate laws… – Continue reading
(Bloomberg) — Luxembourg’s status as a fortress of wealth in the heart of Europe is in peril. The country transformed itself from a rural economy into the European Union’s richest in less than a century by swapping fields and steel mills for hedge funds and multinationals. That model may now… – Continue reading
Following a public consultation, the Inland Revenue Authority (IRAS) of Singapore has issued final regulations and an e-Tax Guide regarding the US Foreign Account Tax Compliance Act (FATCA) requirements for financial institutions (FIs) in Singapore. FATCA requires all FIs outside of the United States to submit regular information on financial… – Continue reading
BANGKOK: — The cabinet has approved the Finance Ministry’s draft bill to amend the Revenue Code to give more teeth to taxmen in dealing with tax evasion by business operators. Government deputy spokesman Maj-Gen Sansern Kaewkamnerd said today that the bill seek to impose penalties against legal entities such as… – Continue reading
Many immigrants who acquire lawful permanent resident (LPR or green card) status believe that as long as they pay their U.S. taxes as a resident, do not break any laws, and spend at least some time each year in this country, they cannot lose their LPR status. Unfortunately, maintaining LPR… – Continue reading
European states including Ireland and Luxembourg will be compelled to share information on private tax deals they have granted to multinational businesses under proposals from Brussels to clamp down on corporate tax avoidance. The European Commission was due today to publish reforms aimed at bringing into line rogue member states… – Continue reading
The Abbott government is pushing ahead with a Labor budget measure to close a loophole that will stop giving offshore-based multinationals “systemic tax advantages” that are not available to Australian-owned companies. The loopholes in current law mean that multinationals can, with the use of subsidiaries, structure their affairs to avoid… – Continue reading
1.GENERAL QUESTIONS 1.1 Why is the Commission presenting a Tax Transparency Package? The Commission has made the fight against tax evasion and corporate tax avoidance a political priority, with a view to creating a socially and economically more efficient Single Market. While much has been done to advance this agenda… – Continue reading
(Bloomberg) — Switzerland has frozen $400 million of assets in more than 30 banks as the country’s attorney general probes money laundering related to Petroleo Brasileiro SA’s widening corruption scandal. Nine investigations have been opened since last April based on allegations of corruption involving eight Brazilian citizens, the Bern-based Federal… – Continue reading
The International Chamber of Commerce (ICC) has responded to announcements in the Budget speech by the UK Chancellor, George Osborne. On the new diverted profits tax, John Danilovich, ICC Secretary General, said: “We welcome the UK Government’s efforts to consult business on the introduction of a ‘diverted’ profits tax in… – Continue reading
Russian Prime Minister Dmitry Medvedev has ordered the signing of a protocol to the Russian-Chinese agreement aimed to eliminate double taxation and prevent tax evasion, the government said on its website on Wednesday. “Under the sanctions imposed on Russia by the European Union, US and other countries, the signing of… – Continue reading
Azerbaijani and Sudanese officials have voiced readiness to further expand cooperation between the two countries. President Ilham Aliyev received a delegation led by Ali Ahmed Karti, Sudanese Foreign Minister on March 18. The head of the state expressed confidence that the visit of the Sudanese delegation will be fruitful and… – Continue reading
BELGRADE — Serbia and Portugal have “very good political and friendly relations” with Lisbon “strongly supporting” Serbia’s EU integration, it has been said in Belgrade. Portugal also supports Serbia’s bid to open accession negotiations chapters with the EU, the country’s Foreign Minister Rui Machete said during a joint news conference… – Continue reading
The agreement under the Foreign Account Tax Compliance Act will enable exchange of information on cases of tax avoidance through overseas entities The Cabinet on Tuesday approved the signing of an inter-governmental agreement between India and the US seeking to impose higher withholding tax on Indian companies on their US… – Continue reading
Two Calgary men have been convicted of defrauding the federal government of $14.1 million in taxes that should have been paid on registered retirement plans, in which the money was used for offshore investments. Steven Kendall and Christopher Houston were found guilty on Wednesday on one of four charges by… – Continue reading
islamabad Pakistan and Austria here on Tuesday signed additional protocol amending the agreement on avoidance of double taxation (ADTA). FBR Chairman Tariq Bajwa and Austrian Ambassador Ms Brigitta Blaha signed the document on behalf of their respective governments. Finance Minister Ishaq Dar witnessed the signing ceremony. Austria and Pakistan, it… – Continue reading
UK financial institutions (FIs) that have no US-reportable accounts will not be required to submit annual ‘nil returns’ in order to ensure compliance with new rules designed to prevent tax evasion by US citizens, HM Revenue and Customs (HMRC) has confirmed. The change comes after the US Internal Revenue Service… – Continue reading
In the recent case of Herefordshire Property Company Ltd v HMRC1, the First-tier Tribunal (Tax Chamber) (“FTT”) allowed the taxpayer’s appeal against the imposition by HMRC of a penalty, which was based on an allegation of negligent implementation of a tax planning scheme by the taxpayer. Regular readers of our… – Continue reading
The disclosure period for the Liechtenstein Disclosure Facility (LDF) is to be shortened and will now end in December 2015 rather than April 2016, the UK chancellor announced in today’s Budget. The LDF allows those with UK tax irregularities to make a disclosure to HMRC on a voluntary basis in… – Continue reading
GRAND CAYMAN, Cayman Islands, March 18, 2015 /PRNewswire/ — DMS Offshore Investment Services Ltd., (DMS) the world’s largest fund governance firm, is expanding its International Tax Compliance Group to better serve private investment funds in meeting their compliance obligations under various international tax initiatives worldwide. DMS announces the recent addition… – Continue reading
From 1 January 2015 the list of information about clients which banks must provide to the tax authorities is expanded (Law of the Republic of Belarus of 30 December 2014 No. 224-Z). In particular, information about client bank account activity must be provided to the Belarusian tax authorities in response… – Continue reading
Date: 18-Mar-15 to 19-Mar-15 Location: The Johannesburg Country Club (Woodmead) / Johannesburg / South Africa Category: Banking, Finance & Investment Conferences & Trade Fairs In response to an increasing awareness of the importance of Mauritius, and in light of the recent DTA agreements coming into effect 1 January 2015, now… – Continue reading
Delhi HC noted while treating advertising, marketing & promotional expenses by Indian arm of an MNC as int’l transactions, ‘the exercise undertaken should not result in over- or double-taxation In a reprieve to multinational companies (MNCs) and their subsidiaries operating out of India, the Delhi High Court has laid out… – Continue reading
Towards the end of last December, the cabinet passed resolutions representing the latest attempt to turn Thailand into an attractive location in which to establish an international headquarters (IHQ). This is the third attempt in a little over a decade to lure multinational companies to Thailand. The first regional operating… – Continue reading
Irish eyes are smiling in corporate America. The Emerald Isle has emerged as the world’s top recipient of U.S. foreign direct investment, according to a report from the American Chamber of Commerce Ireland. In the first nine months of 2014, Ireland beat the likes of Canada, Mexico, the U.K. and… – Continue reading
A top insurance industry boss believes that a tax on company profits is inevitable – and would be in the long-term interests of the Island’s people and its economy. John Charman, the chairman and chief executive officer of Bermuda-based Endurance Specialty Holdings Ltd, said the levying of corporate tax would… – Continue reading
(Seychelles News Agency) – Seychelles and Singapore are looking to increase their collaboration in a number of economic sectors from trade, financial services, port development – including transshipment and fuel bunkering – to public-private partnerships. This follows the recent official visit to Singapore by the Minister of Finance, Trade and… – Continue reading
In a development that will usher in relief to multinational companies and reduce litigation, the central board of direct taxes (CBDT) on Monday notified rules for implementation of roll back provisions of advance pricing agreements (APAs). The provisions for roll back of APAs were announced by finance minister Arun Jaitley… – Continue reading
On March 13, 2015, New Zealand’s Minister of Revenue, Todd McClay, announced the Government’s tax policy work program for 2015/16, which includes key international tax reforms aimed primarily at countering base erosion and profit shifting (BEPS). In particular, the Government intends to focus on the following areas of reforms: •… – Continue reading
As the OECD/EU project on Base Erosion and Profit Shifting (“BEPS”) moves towards its next set of reports in autumn 2015, Ireland Inc.’s low tax offering has been, and will be, further refined. While the 12.5% corporate tax rate remains beyond approach both domestically and internationally, the BEPS initiative has… – Continue reading
Transactional work varies from jurisdiction-to-jurisdiction with the ebb and flow of various economic cycles, but a prevailing theme across the EMEA region has been that more and more advisory firms are urging taxpayers to prepare for the impact of the OECD’s base erosion and profit shifting (BEPS) action plan. Joe… – Continue reading
KUALA LUMPUR: The Goods and Services Tax will not be imposed on rentals of commercial units below RM500,000 a year, says Najib Tun Razak. The prime minister said the government had also decided that supply services for all stratified residential houses would be GST-exempt. He said under subsection 18(2) of… – Continue reading
