Category: Tax Laws

China’s New General Anti-Avoidance Rules: An Overview

On December 2, 2014, the State Administration of Taxation (SAT), China’s highest tax authority, issued the Administrative Measures for the General Anti-Avoidance Rules (Trial) (GAAR), which went into effect on February 1, 2015. Prior to this legislation, China had no specific GAAR, only a few general anti-avoidance principles in various… – Continue reading

LAW & COMPLIANCE

NEW PACTS WITH AMSTERDAM AND TOKYO BOOST TRANSFER PRICING IN HONG KONG When combined with aggressive tax planning, Hong Kong’s onshore-offshore tax regime often results in a reduced tax burden for taxpayers that operate through Hong Kong companies by pricing intra-group transactions. The Advance Pricing Arrangement agreement with the Netherlands… – Continue reading

Backdating Taxes?

Double Tax Avoidance Agreement to be Applied to China Funds Investors no longer have to be worried about double taxation on China-based funds. On Mar. 4, the Korea Financial Investment Association told asset management firms to hand in documents for double tax avoidance agreement applications. Four months ago, when the… – Continue reading

RAMAPHOSA VOWS TO IMPROVE TAX COLLECTION

Cyril Ramaphosa said government would be improving tax collection and combating illicit financial flows. JOHANNESBURG – Deputy President Cyril Ramaphosa on Wednesday announced that government would be improving tax collection and combating illicit financial flows. Ramaphosa was answering questions in Parliament on Wednesday afternoon. The Economic Freedom Fighters’ Floyd Shivambu… – Continue reading

India makes big strides: Pakistan seeks to follow new Swiss law on black money

India has made a major breakthrough with Swiss tax authorities, who have agreed to provide information in respect of cases independently investigated by IT department whereas first round of talks have reportedly taken place between Pakistan and Swiss government on revision of Convention for the Avoidance of Double Taxation agreement…. – Continue reading

Oregon Tax Haven bill targets 40 countries

Associated Oregon Industries Oregon’s largest business advocate The issue of “tax havens” garnered early interest from the House and Senate Revenue Committees as the Oregon Department of Revenue issued a new report outlining which additional countries should be considered “tax havens” for purposes of Oregon tax law. AOI testified in… – Continue reading

41,000 London properties held by foreign companies – 90% in tax havens

UK official data show that almost 41,000 London properties owned by foreign companies 90% are based in tax havens such as the British Virgin Islands (BVI), which do not have to disclose ownership information. Transparency International, the anti-corruption organisation, used Land Registry and Metropolitan Police data to identify 40,725 properties… – Continue reading

Residence in Malta for Third Country Nationals

Third country nationals may take up residence in Malta in terms of the Global Residence Programme Rules (GRP) Rules.  Such individuals will be granted a special tax status by the Maltese tax authorities and will be subject to tax in Malta at a flat rate of 15% as described hereunder…. – Continue reading

Pushing back GAAR has sound reason’

THIRUVANANTHAPURAM, MARCH 4:   The taxman has taken a headlong plunge into an alphabetic soup to comply/align with emerging tax and jurisdictional requirements, domestic and foreign, of which is GST is only one. Advance Pricing Agreements (APAs); General Anti-Avoidance Rules (GAAR); BEPS (Base Erosion and Profit Sharing); and POEM (Place… – Continue reading

MSPs plan probe on tax ‘gaming’ after Osborne’s stamp duty cut

Claims that the UK Treasury has started “gaming” to protect its own revenues from devolved Scottish tax competition should be given further consideration, a committee of MSPs has recommended. Holyrood’s Finance Committee is seeking further evidence on the Smith Commission’s call for devolution to cause “no detriment” to any part… – Continue reading

How HMRC is tackling tax arrangements similar to Starbucks’

The Public Accounts Committee (PAC) met last month to ask HM Revenue & Customs (HMRC) about its efforts to curb tax avoidance, including how HMRC has developed its transfer pricing approach to counteract tax arrangements such as those by Google, Amazon and Starbucks. Present at the hearing on February 11,… – Continue reading

Govt to ensure safeguards to make sure black money law not used to harass overseas students: Shaktikanta Das, Revenue Secy

NEW DELHI: India will seek to apply its proposed law on black money held abroad fairly, making sure that its stringent provisions aren’t used to harass students, research scholars and professionals going overseas for short stints. “There will be suitable safeguards,” Revenue Secretary Shaktikanta Das told ET in an interview…. – Continue reading

Hong Kong’s 2015/16 budget offers hope and risk for tax competiveness

Hong Kong Financial Secretary, John Tsang delivered his eighth budget speech on 25 February 2015. Key Points: >Expansion of tax exemption for certain offshore investment funds >Tax concession for treasury centre activities on the way >Full steam ahead with implementation of OECD automatic exchange of tax information standard >Addressing Hong… – Continue reading

Imagination at Work? GE Once Again Pays Less Than 1% in Federal Taxes

Notorious tax dodger GE recently released its annual financial report and the only thing eye-raising about the company’s paltry 0.9 percent federal income tax rate is that it’s marginally higher than the 0.4 percent average rate it paid over the past decade. Released without fanfare late in the afternoon last… – Continue reading

IRS Opens FATCA International Data Exchange Gateway

The Internal Revenue Service’s Large Business & International division has opened a gateway that financial institutions and the tax authorities abroad can use to send information on financial accounts held by U.S. taxpayers in accordance with the Foreign Account Tax Compliance Act. FATCA, which was included as part of the… – Continue reading

UHY Global Transfer Pricing Guide 2015 Now Available

The Global Transfer Pricing Guide is created to assist tax and finance professionals responsible for cross-border tax planning and compliance with their inquiries. Sterling Heights, Michigan (PRWEB) March 02, 2015 Global accountancy network UHY releases its 2015 “Global Transfer Pricing Guide” to assist tax and finance professionals responsible for cross-border… – Continue reading

Italy-Monaco in pact against tax evasion

Italy has made a pact with Monaco aimed at clamping down on tax evaders, the finance ministry said in a statement on Monday. The agreement, which will see the two states exchanging information for tax purposes, follows similar ones made recently with Switzerland and Liechtenstein. It is expected to give… – Continue reading

Hong Kong dangles 50 percent off to bait corporate treasury services opportunity

Large businesses require access to finances to fund on-going market development, regional expansion and mergers & acquisitions (M&A) to name a few. Conglomerates in particular have discovered that pooling together the different business units’ assets under treasury operations enables these to better manage the company’s liquidity as well as mitigate… – Continue reading

Swiss Leaks: Malta Investment Registration Scheme attracts 1,469 applications with €455m

An investment registration scheme launched by the government last year attracted a total of 1,469 valid registrations covering an aggregate of €455.8 million worth of eligible assets, The Finance Ministry told The Malta Independent. Of the total amount registered, €69.8 million or 15% of the total was repatriated following registration…. – Continue reading

Tax traps to avoid for Aussies working overseas

Working overseas can lead to tricky tax pitfalls, but seeking expert advice can keep you from paying up twice. Going overseas to work is a grand adventure for many young professionals. It offers the opportunity to experience a different culture, expand your work experience and enhance future career opportunities. But… – Continue reading

Tax residency tweak may hit Indian firms with overseas operations

Foreign subsidiaries may now have to pay tax both in India and the country of their operations At present, a company incorporated outside India is considered a tax resident only if the control and management of its affairs is situated wholly in India. Photo: Pradeep Gaur/Mint New Delhi: A budget… – Continue reading

Deadline Dates for Automatic Exchange of Tax Information under FATCA and CRS

In previous updates we have alerted clients to the introduction of Cayman Islands regulations1, which give effect to the automatic exchange of tax information principles established by the US and UK intergovernmental agreements (the “Cayman US Regulations” and the “Cayman UK Regulations”, respectively). While many Cayman Islands entities will be… – Continue reading

Deadline dates for automatic exchange of tax information under FATCA and CRS

In previous updates we have alerted clients to the introduction of Cayman Islands regulations1, which give effect to the automatic exchange of tax information principles established by the US and UK intergovernmental agreements (the “Cayman US Regulations” and the “Cayman UK Regulations”, respectively). While many Cayman Islands entities will be… – Continue reading

Holes in transfer pricing

GUEST COLUMN- Dinesh Agarwal & Amit Poddar The Finance Act, 2012, had introduced the provisions for specified domestic transactions (SDT), extending the laws of transfer pricing to domestic transactions. One of the criteria for applicability of domestic transfer pricing was that the aggregate value of domestic transactions should be at… – Continue reading

GAAR to incorporate OECD initiative’s norms on tax avoidance

Government proposes to come out with a modified General Anti-Avoidance Rules by incorporating provisions of the OECD’s BEPS project so as to effectively deal with the problem of tax avoidance by MNCs. The BEPS initiative aims to ensure that taxes are paid where profits are made. Multinational companies use a… – Continue reading

The BVI: The Premier Corporate Domicile

The British Virgin Islands (BVI), as one of the world’s leading finance centres and meeting the changing needs of international businesses and high net worth individuals (HNWIs), has managed to create a stable, well-regulated and neutral jurisdiction that makes a significant contribution to the liquidity of the global economy. The… – Continue reading

Govt to introduce capital gains tax

Minister of Finance Martin Dlamini said the proposed revenue measures would assist government in mobilising additional resources for protecting essential services while Southern African Customs Union (SACU) revenues fall in the medium term. He said these initiatives include an amendment of the Income Tax regulations, including removal of the tax… – Continue reading

A new milestone for taxation on Indirect Asset Transfer by Non-Resident Enterprises — a review of the past and present of bulletin 7

After several rounds of revisions and consultations in the past few years, the State Administration of Taxation (“SAT”) has recently promulgated the Bulletin on Several Issues concerning the Enterprise Income Tax (“EIT”) on Indirect Asset Transfer by Non-Resident Enterprises (“Bulletin 7”)[1]. Tax matters occurred but have not been settled before… – Continue reading

Set right the tax climate

As recommended by Tax Administration Reforms Commission (TARC) under Parthasarathi Shome, for taxation, the appellate functions must be housed separately from the field functions, in order to have fair and judicious orders passed. Indian Revenue should be divided into two distinct sets—the operational side and the technical/adjudication side. The quasi-judicial… – Continue reading