Category: Tax Laws

Seychelles signs multilateral tax cooperation treaty

On February 24, Seychelles became the 85th signatory of the Organisation for Economic Co-operation and Development’s (OECD’s) Multilateral Convention on Mutual Administrative Assistance in Tax Matters, reports Tax News. The Convention is described as a comprehensive multilateral instrument to tackle tax evasion and increase transparency. In a statement, the OECD… – Continue reading

Pharma companies want tax sops, clarity on transfer pricing

Pharmaceutical companies want the finance minister to increase tax concessions across the board as also bring in more clarity on amendment to the rollback of advance pricing agreements (APA), applicability of roll back benefit, impact on on-going assessment, applicability of roll back provisions on bilateral APAs etc. In a pre-budget… – Continue reading

US Business Groups Add To Calls For DTA Approvals

In a February 20 letter to US Senate Majority Leader Mitch McConnell (R – Kentucky), the National Foreign Trade Council and other leading business organizations urged action on pending bilateral double taxation agreements (DTAs) and protocols. A coalition of ten business organizations, including the Business Roundtable, National Association of Manufacturers,… – Continue reading

INSPIRING CONFIDENCE, EMPOWERING CHANGE IN INDIA, SAYS KPMG

KPMG in India through its survey, has tried to understand the expectations of India Inc. on various parameters such as policy reforms, clarity on indirect transfer tax provisions, applicability of MAT on foreign companies, amendment in the tax regime for REITs/ InvITs, deductions allowed to individuals, etc. Over 200 senior… – Continue reading

Taxing times: does the UAE remain unaffected?

Al Tamimi & Company – Advocates and Legal Consultants Surabhi Singhi Kataria Tax planning has always been a topic of international debate and adjudication. The borderlines between permitted tax planning/avoidance and unlawful tax evasion have occupied the centre stage across the globe with several modern economies emphasizing the need for… – Continue reading

Cyprus: Cyprus IP Company: The Breathless Conundrum Solved

The breathless conundrum for IP companies is four-fold: not only should royalties be taxed at a low rate in order to maximise profits; but also research and development (R&D) or acquisition costs should be considered as allowable expenses to the maximum possible effect, whilst also the jurisdiction where the IP… – Continue reading

Leading Offshore Firm: The Inside View on the Cayman Islands Jurisdiction

MCC interviews three attorneys from Mourant Ozannes. Hayden Isbister is a partner and head of the Corporate practice in the Cayman firm. He specializes in investment funds, general corporate and commercial work. James Burch is a partner and leads the Structured Finance/Banks practice in the Cayman Islands, and Tim Dawson… – Continue reading

Hong Kong’s Advance Pricing Arrangement Program

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. This has led to heightened transfer pricing scrutiny from the Hong Kong Inland Revenue Department in recent years. In order… – Continue reading

British Virgin Islands: B.V.I. Company – Corporate Environment Summary

The British Virgin Islands is the most popular offshore jurisdiction, with favourable business regulations, a prosperous economy and a stable political situation. British Virgin Islands IBC, is a limited liability company which conducts its trading and business outside the British Virgin Islands and is intended for offshore activities. It takes… – Continue reading

Italy Expects Tax Influx From Swiss Agreement

The signing of a double taxation agreement (DTA) protocol between Switzerland and Italy, which includes a provision for the exchange of information upon request, has fueled an expectation that the Italian Treasury will be able to collect substantial additional tax revenue this year. While it could take up to two… – Continue reading

The Common Reporting Standard: CRS brings the walls tumbling down

A country known for its clocks, chocolate and most importantly banks, the agreement by Switzerland’s government to share details of those super-secret bank accounts is one that will change the world at large. Gone are the days of the elusive Swiss bank account. The arrival of Common Reporting is upon… – Continue reading

Listed Guernsey and Jersey funds – FATCA reporting deadlines are looming. Are you ready?

INTRODUCTION 2015 is with us and looming is the 30 June 2015 deadline for the first reports of FATCA information under the reporting regimes that have been put in place in both Guernsey and Jersey to ensure compliance with the US/Guernsey and US/Jersey Intergovernmental Agreements regarding FATCA (“the US IGAs”)…. – Continue reading

HSBC chiefs to testify in tax scandal on tax evasion

First there was money laundering, then foreign-exchange rigging and now tax evasion. Politicians and analysts are asking if big banks became too big to manage from being too large to be allowed to fail HSBC Europe’s biggest bank, has endured a string of scandals and paid millions in penalties to… – Continue reading

New Non-adversarial Tax Regime: India Shows a Way

Mr. Akhilesh Ranjan, Joint Secretary Ministry of Finance, and also Competent Authority for the Government of India, spoke this past week at the Pacific Rim Tax Institute, February 19-20, reaffirming India’s commitment to a new non-adversarial tax regime to encourage foreign investment and fair treatment of taxpayers. Mr. Ranjan’s appointment,… – Continue reading

OECD says Italy-Swiss treaty helps end bank secrecy -update2

Pact on information exchange in tax treatment Paris, February 25 – An important tax treaty signed between Italy and Switzerland is evidence of the “change of a crucial paradigm,” in banking secrecy with global implications, Pascal Saint-Amans, director of the center for tax policy and administration at the OECD told… – Continue reading

OECD Seeks Change In Global Taxation

Thanks in part to past concerns that globalization could lead to double taxation, corporations have numerous techniques at their disposal to reduce their tax bills, including the placement of subsidiaries and spinoff holding companies in low-tax jurisdictions. The Group of 20 wants to change that. The Organisation for Economic Cooperation… – Continue reading

FATCA: The End of ‘Shadow Boxing’ in the Offshore Trust Industry

Not long after the U.S. Department of Justice’s Tax Division (“DOJ”) made international headlines in 2009 for its bombshell announcement that it had entered into a deferred prosecution agreement with the United Bank of Switzerland (UBS), lawmakers in Washington, D.C. began reviewing the testimony of hundreds of UBS’s U.S. clients… – Continue reading

Is international tax planning for contractors illegal or immoral?

The differentiation between tax avoidance, tax evasion and the moral duty to pay tax for the betterment of society has been intentionally screwed by politicians and bureaucrats. This is nothing new. I wrote an couple of articles several years ago questioning the terminology of ‘morally repugnant’ tax avoidance when it… – Continue reading

Jersey chief minister ‘disappointed’ at Miliband letter

Jersey’s chief minister Ian Gorst has formally expressed his “disappointment” with statements from Labour Party leader Ed Miliband about tax transparency and disclosure efforts by UK overseas territories. In an open letter to the Opposition leader, Gorst said the Island government had reiterated “many times” in past discussions with the… – Continue reading

Union Budget: Clear the confusion on transfer-pricing norms

The government has been able to instil a positive sentiment in the country. Various policy initiatives like Make-in-India, aimed to make India a manufacturing hub, and the Clean India campaign; updating age-old laws and tweaking the Goods and Services Tax to a more acceptable form, introducing greater clarity in the… – Continue reading

How to navigate transfer pricing in Brazil; Deloitte advises

São Paulo, Brazil. International transfer pricing is able to take place in Brazil, outside of the OECD While Brazil is not a member of the OECD, many multinational groups there are able to successfully navigate international transfer pricing standards, yielding effective results The economic view of Brazil has always been… – Continue reading

Key Bahrain-India deals to bolster ties

Bahrain and India have signed agreements to increase co-operation in the areas of education, investment, defence and other sectors. It took place during the first meeting of the India-Bahrain High Joint Commission (HJC) in New Delhi, said a report in the Gulf Daily News (GDN), our sister publication. The Bahrain… – Continue reading

2 Investments to Avoid in Your IRA

IRA plans can be excellent ways to save for retirement, but there are some investments to avoid if you want to take full advantage of IRA tax savings. Two that come immediately to mind are tax-exempt municipal bonds and high-yielding stocks from foreign countries with dividend withholding taxes. Tax-exempt municipal… – Continue reading

Everything U.S. Expats Need to Know About IRS Tax Forms (But Were Afraid to Ask)

This is the time of the year for millions of Americans to begin the annual ritual of gathering information about income, taxes, charitable giving, health insurance, expenses and sundry other items, and prepare to send mountains of information to the IRS –and to those who prepare their tax returns. Overseas… – Continue reading

‘Don’t over-complicate tax laws’

Attempt to plug every gap makes the system unworkable – Norton Rose Fulbright. JOHANNESBURG – A tax expert has warned against over-complicating tax legislation in an attempt to block every loophole or perceived underpayments of tax, as it makes the tax system “unworkable”. Andrew Wellsted, director at Norton Rose Fulbright,… – Continue reading

Terry Baucher says a ‘rare generational shift’ is taking place in international tax – and the implications will be felt for decades

When I consider what’s likely to have the most impact in tax this year, I keep coming back to the massive shift in attitude by tax authorities in the aftermath of the Global Financial Crisis (GFC). Usually changes in the tax world are incremental, but what is going on now… – Continue reading

US, Dominican Republic start tax info exchange

Santo Domingo.- The US Internal Revenue Service (IRS) and Dominican Republic’s Internal Taxes Agency (DGII) have begun a process to exchange bilateral financial and tax information, as part of the on Foreign Accounts Tax Compliance Law (FATCA). A delegation of the IRS’ International Cooperation Program led by its senior manager… – Continue reading

Ministers sign Italian-Swiss tax treaty

Switzerland and neighbouring Italy have revised a double taxation agreement which includes provisions for the exchange of information in line with the standards of the Organisation for Economic Development and Co-operation (OECD). The accord and a roadmap for the amendment of tax rules on cross-border workers as well as improved… – Continue reading

HSBC Says Gulliver Paid Taxes After Opening Swiss Account

(Bloomberg) — HSBC Holdings Plc, struggling to contain a political storm over the bank’s facilitation of tax evasion through its Swiss unit, said Chief Executive Officer Stuart Gulliver paid taxes after setting up his own Swiss account and keeping his legal residence in Hong Kong. The bank, reacting to an… – Continue reading

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Tax collections, so maintains the Federal Minister for Finance Ishaq Dar, have improved significantly and he cited a healthy growth rate of around 13 percent in one of his recent press conferences. Sources within the Ministry of Finance, however, revealed to Business Recorder, but on condition of anonymity that the… – Continue reading

Many governmentsare legislating nowrather than awaitingfinal OECD BEPS recommendations

According to Peter Willey, EY’s Channel Islands Head of Tax, the Channel Islands are likely to be impacted by decisions being made now in other jurisdictions. EY recently surveyed its tax policy leaders in 32 jurisdictions to ask them to forecast the tax policy outlook for 2015 in their jurisdiction…. – Continue reading

MNCs Beware: Country-By-Country Reporting Is Here!

UK, US, Australia, Brazil, India- governments of developed and developing countries are battling profit shifting by MNCs such as Amazon, Google, Apple and Starbucks. The allegation- MNCs are shifting profits to jurisdictions where there is little or no tax to be paid. The solution- OECD’s BEPS action plan which, among… – Continue reading

TRANSFER PRICING LITIGATION ISSUES NEED TO BE ADDRESSED:PWC

Certainty and reduced litigation on transfer pricing (TP) issues will be the cornerstone of creating a non-adversarial tax regime in India. The authors believe that Budget 2015 ought to lay out a roadmap to achieve this goal for TP issues – Recent positive progress on the Advance Pricing Agreement (APA)… – Continue reading

Pakistan’s finance minister rejects allegations of tax evasion

Islamabad: Pakistan’s Finance Minister Ishaq Dar has rejected allegations by Pakistan Tehreek-e-Insaf (PTI) leader that he transferred $4 million to his son in Dubai to avoid taxes. In an open letter to the PTI chairman Imran Khan, the finance minister also refuted the claim that he has been dragging his… – Continue reading

Budget 2015: With BEPS on the anvil, GAAR may be an overlap

The economic downturn across the world and rising public debt seems to have led various governments, globally, to focus on curbing erosion of the tax base by shifting profits to overseas jurisdictions. Several revenue authorities, globally, were of the view that companies have structured their intra-group contractual arrangements in a… – Continue reading

What Indo-U.S. Bilateral APAs Entail For U.S. Investors

India’s decision to negotiate bilateral advance pricing agreements (APAs) with the U.S. is a welcome move. Prospectively, negotiations will increase certainty and uniformity in the application of India’s transfer pricing laws to related-party transactions carried out by U.S. multinational corporations (MNCs). In this article, we discuss some of the important… – Continue reading

Company bosses are held to account on their tax affairs BCA tells inquiry

The Business Council of Australia says that the Tax Office is holding company directors and management to account about their tax affairs, despite there only being one company in the nation with a top risk rating. “There is ongoing [Australian Taxation Office] scrutiny of corporate boards,” the BCA said in… – Continue reading

DFID-HMRC mission likely to hold meeting with FBR in first week of March

ISLAMABAD: A delegation of British Department for International Development (DFID) and Her Majesty Revenue & Customs (HMRC) will hold dialogue with the Federal Board of Revenue (FBR) on future course of action to further strengthen bilateral cooperation. The DFID is a department of the British government that leads the UK’s… – Continue reading

South Africa: Imminent Changes To Transfer Pricing Documentation Requirements In South Africa

On 17 July 2013 the Minister of Finance appointed a tax review committee, headed by Judge Dennis Davis (the “Davis Committee”) to make recommendations for possible tax reforms in South Africa (“SA”). The Davis Committee was required to take into account recent international developments and, in particular, to address concerns… – Continue reading