The draft legislation published on 10 December 2014 (see here) devotes almost 30 pages to the new “diverted profits tax” (DPT), which from 1 April 2015 will introduce a new tax at a rate of 25% to profits generated by those multinational corporate groups who, in the eyes of the… – Continue reading
Eleventh-hour legislation in December kept many tax breaks alive for the 2014 tax year, but they weren’t extended beyond that. (See chart on page 26.) So clients who want to take advantage of those breaks need to get with a knowledgeable practitioner—and quickly. “CPA firms nationwide face a staffing challenge… – Continue reading
India and US reach common ground on Mutual Agreement Procedure (“MAP)” and break new ground on Advance Pricing Agreements (“APA”) Suchint Majmudar Just ahead of Obama’s momentous R-Day visit to India, the Competent Authorities of India and US reached a landmark breakthrough in cases involving mutual agreement procedure under the… – Continue reading
Critics question whether Galuteria actually lives in Senate District 12, which he has represented since 2008. State Sen. Brickwood Galuteria admitted Monday that he has improperly claimed a rental property in Palolo as his primary residence and will likely have to pay back taxes on the nearly $1.8 million home…. – Continue reading
The Internal Revenue Service announced in January that its International Data Exchange Service (IDES) is open for enrollment, and that financial institutions and host country tax authorities will be able to use IDES to securely send their information reports on financial accounts held by Americans to the IRS under the… – Continue reading
NEW DELHI: Multinational companies operating in India will soon have to disclose details of their operations at the country of residence and their revenue income to the Income Tax authorities. The Budget for 2015-16 may contain provisions relating to the Global Base Erosion and Profit Shifting (BEPS) rules, which are… – Continue reading
SUMMARY On February 2, 2015, the Obama Administration (the “Administration”) released the General Explanations of the Administration’s Fiscal Year 2016 Revenue Proposals (commonly known as the “Green Book”), which contains significant detail about the fiscal year 2016 revenue proposals. This memorandum discusses certain aspects of the Green Book relating to… – Continue reading
The present French Tax Update will focus on (i) the most salient features of the new double tax treaty signed by the People’s Republic of China (China) and France on November 26, 2013 (New DTT), (ii) the new double tax treaty signed by Singapore and France on January 15, 2015,… – Continue reading
Potential candidates can gain foreign experience and donations in the British capital but expatriate supporters want action on Obama’s onerous tax demands Republican donors in the UK are lobbying the presidential hopefuls visiting London in search of foreign policy credentials and wealthy corporate allies to abandon President Barack Obama’s aggressive… – Continue reading
IN LAST WEEK’S column we talked about the OECD’s BEPS Action Plan on Hybrid Mismatch Arrangements. This week’s column focuses on the OECD’s Action Plan on Harmful Tax Practices (HTP). As the world economy continues the process of globalization and technological advances, tax authorities from various jurisdictions are inevitably faced… – Continue reading
With over 7 million Americans living abroad, many have complained about the rigorous IRS enforcement of global tax reporting, the risk of draconian FBAR penalties for reporting foreign accounts, and FATCA discrimination. FATCA, America’s global tax enforcement law, applies virtually everywhere. It is easy for the IRS to find you,… – Continue reading
NEW DELHI: Getting tough with investment proposals from tax heavens, FIPB has deferred 23 applications in its last three meetings apprehending “treaty abuse”. According to sources, the Department of Revenue has expressed doubt that a few foreign companies were evading tax by routing their investments through tax heaven countries with… – Continue reading
A double tax treaty (“DTT”) was signed between Cyprus and Lithuania in June 2013. The treaty which follows the OECD Model Convention for the avoidance of Double Taxation on Income and on Capital has been ratified by the two Contracting States and has entered into force as of 1 January… – Continue reading
NKY congressman says that current system amounts to ‘double taxation’ on people. His bill could save some seniors thousands of dollars. Are you a higher-income Social Security recipient who must pay federal taxes on your benefits? U.S. Rep. Thomas Massie is your friend. Massie, R-Garrison, last week introduced the latest… – Continue reading
Feb 1 (Reuters) – The Chinese government’s vow to increase tax scrutiny of foreign companies has sent firms rushing to tax advisors ahead of the implementation on Sunday of new rules designed to rein in cross-border tax avoidance. Tax professionals and business lobbies alike have welcomed the move as an… – Continue reading
Capital Gains tax and inheritance tax should be merged to prevent wealthy homeowners being taxed twice, IoD suggests Capital gains tax and inheritance tax should be merged to prevent wealthy homeowners being taxed twice, according to the Institute of Directors. Taxes raising less than £5billion a year should be merged… – Continue reading
KATHMANDU, Jan 30: Nepal and Bangladesh on Thursday agreed to sign Double Taxation Avoidance Agreement (DTAA). Issuing a statement on Thursday, Inland Revenue Department (IRD) said the fourth round of meeting for DTAA held in Kathmandu took the decision. Director General of Inland Revenue Department (IRD) Chudamani Sharma and Head… – Continue reading
KATHMANDU, Jan 30: Nepal and Bangladesh on Thursday agreed to sign Double Taxation Avoidance Agreement (DTAA). Issuing a statement on Thursday, Inland Revenue Department (IRD) said the fourth round of meeting for DTAA held in Kathmandu took the decision. Director General of Inland Revenue Department (IRD) Chudamani Sharma and Head… – Continue reading
Speed read On 16 December 2014, Curaçao and the U.S. signed an intergovernmental agreement (“Curaçao-IGA”) setting out the information reporting and withholding requirements applicable to banks and other financial institutions resident in Curaçao (“FI’s”) under the Foreign Account Tax Compliance Act (“FATCA”). By virtue of the Curaçao-IGA, FI’s will be… – Continue reading
Cash reserves held outside the US for tax reasons by US multinationals are “likely to fuel a big increase in M&A activity over the next year”, said Eloise Walker a tax expert at Pinsent Masons, the law firm behind Out-law.com.30 Jan 2015 Corporate Tax Corporate tax International tax M&A Advanced… – Continue reading
HM Revenue and Customs (HMRC) has published a consultation paper, ‘Strengthening Sanctions for Tax Avoidance’, setting out proposals to tackle the serial use of tax avoidance schemes. Tax avoiders can already face penalties, but this consultation proposes additional financial costs such as a surcharge and additional reporting requirements on users… – Continue reading
On January 27, 2015, the Council of the European Union formally adopted a decision to add a binding anti-abuse clause to the EU Parent-Subsidiary Directive. The anti-abuse clause, which was agreed by the Economic and Financial Affairs Council on December 9, 2014, aims to prevent misuse of the Directive and… – Continue reading
In November 2012, a startled TV audience watched coverage of the House of Commons Select Committee questioning Google’s chief executive about why his business, with ostensibly billions of pounds in sales generated in the UK, accounted for UK corporation tax in an amount equivalent to the price of a single… – Continue reading
In November 2012, a startled TV audience watched coverage of the House of Commons Select Committee questioning Google’s chief executive about why his business, with ostensibly billions of pounds in sales generated in the UK, accounted for UK corporation tax in an amount equivalent to the price of a single… – Continue reading
The Cayman Islands – described by the Financial Times as having “a reputation for clandestine financial activity” – is the latest location for a Savills branch. The office is located in the Caribbean Plaza on Grand Cayman’s Seven Mile Beach and is the first fully branded Savills office in the… – Continue reading
Introduction The taxpayer, Seven Network Limited, has won a recent decision (22 December 2014) in the Australian Federal Court, Seven Network Limited v Federal Commissioner of Taxation (2014) FCA1411, which is significant to all broadcasters, particularly involving the delivery of live sport and other entertainment. Briefly, the key issue raised… – Continue reading
Inter-Governmental Agreement (IGA) with United States of America (US) under Foreign Accounts Tax Compliance Act (FATCA)- Registration Please refer to circular DBR.AML.No.9644/14.07.018/2014-15 dated December 30, 2014, on the captioned subject. 2. In partial modification to the above circular, it is clarified that those RRBs which do not have more than… – Continue reading
A double tax treaty (“DTT”) was signed between Cyprus and Lithuania in June 2013. The treaty which follows the OECD Model Convention for the avoidance of Double Taxation on Income and on Capital has been ratified by the two Contracting States and has entered into force as of 1 January… – Continue reading
BANDAR SERI BEGAWAN – Taiwan is keen on broadening the scope of cooperation with Brunei beyond the areas of oil, gas and organic chemicals. According to Albert Huang, representative at the Taipei Economic and Cultural Office in Brunei, the two parties can explore other trade opportunities. Taiwan is interested to… – Continue reading
Yahoo is taking advantage of a loophole in the tax code to spin off its $40 billion stake in Chinese e-commerce giant Alibaba to shareholders without paying about $16 billion in corporate income tax. That’s how much Yahoo would pay if it sold its Alibaba shares or transferred them to… – Continue reading
Jan. 23 — The growth of global tax transparency is expected to leap ahead in 2015—meaning companies, individual taxpayers and financial institutions must exercise new levels of caution, practitioners told Bloomberg BNA. With more than 100 intergovernmental agreements under the Foreign Account Tax Compliance Act and dozens of countries signing… – Continue reading
NEW DELHI: PHD Chamber of Commerce and Industry on Tuesday asked the government to implement the General Anti Avoidance Rules (GAAR) from April 1, 2016 instead of April this year. The government had earlier proposed imposing GAAR from April 1, 2015, for those claiming tax benefit of over Rs 3… – Continue reading
Each year U.S. multinational corporations avoid an astounding $90 billion in corporate income taxes by booking their profits on paper through international tax havens. At a time of growing inequality and budget austerity, it is outrageous that we allow the world’s richest companies to get away with not paying their… – Continue reading
Jonathan Weiss hasn’t lived in the US for 25 years. But that didn’t keep his foreign bank account from being frozen in the wake of new US tax laws. Find out how you can avoid the same fate at the hands of FATCA. “I had been living in Switzerland for… – Continue reading
Tax avoidance costs developing countries billions every year. So this week 16 domestic and internationally focused organisations have joined forces to launch a campaign for a Tax Dodging Bill. When I mention in the course of a conversation that I work for an international development charity, I often get an… – Continue reading
A legislative amendment leaves Gibraltar “very well positioned” to follow Malta’s lead in adapting to HM Revenue & Customs introduction of full flexibility to Qualifying Recognised Overseas Pension Schemes (QROPS). At the end of December last year, HMRC issued draft legislation to allow QROPS full flexibility in drawing pension benefits… – Continue reading
On 11 November 2014, the UK and German governments issued a joint statement on proposals for new rules for preferential intellectual property (IP) regimes within the G20/OECD base erosion and profit shifting (BEPS) project. Germany currently does not have a special regime for Patent Boxes, but suffers from structures that… – Continue reading
Puerto Rico’s Acts 20 & 22, tax incentive laws aimed at luring wealthy American investors to move there and at reviving the Island’s economy, are celebrating their third anniversary this month. While Puerto Rico’s economic situation remains bleak (it currently has more than $73 billion of “junk” status debt, unemployment… – Continue reading
Co-operatives have joined a call to address tax dodging by multinational companies. The campaign, which is supported by a coalition of 17 British organisations, is asking all political parties to pledge to introduce a new Bill to tackle corporate tax dodging. The Tax Dodging Bill campaign aims to make it… – Continue reading
The chairman of BIAC’s tax committee, Will Morris, made an address to the OECD’s consultation on dispute resolution last week and said success on the dispute resolution action item is crucial to the overall success of the BEPS project as a whole. His comments to the OECD are as follows:… – Continue reading
Trade Ministry insists it will go ahead with the Ghana Conformity Assessment Programme, G-CAP despite resistance from businesses. The program which is being championed by the Ghana Standards Authority, will result in goods imported into the country being subjected to strict inspection at their original destination. G-CAP is intended to… – Continue reading
Senate Finance Committee Chairman Orrin Hatch reiterated his view that the only solution to corporate tax inversions is United States tax reform, during remarks at a conference hosted by the Brookings Institution on January 23. Hatch has long been skeptical of short-term measures – legislative or non-legislative – to deter… – Continue reading
Americans living in Canada fear they may have to pay huge capital gains tax bills when they sell their home as a result of the new US Foreign Account Tax Compliance Act (FATCA). The issue concerns a rule buried in reams of Internal Revenue Service (IRS) tax guidance that states… – Continue reading
Businesses have made their feelings clear about the OECD’s work on preventing treaty abuse, which is a sub-section of the organisation’s work on base erosion and profit shifting (BEPS). Comments made in an address to the OECD by Will Morris, chairman of BIAC’s (business advisory arm to the OECD) tax… – Continue reading
Fatca registration, which is mandatory, could reveal technical violations of three other American laws, with penal consequences The Foreign Account Tax Compliance Act (Fatca) might be a bigger headache for the Rs 11 lakh-crore-mutual fund (MF) sector than earlier believed. Fatca is an American legislation, under which financial institutions (FI)… – Continue reading
The Chinese Ministry of Commerce has released the draft of the proposed new Foreign Investment Law to solicit public opinions. The proposed law will significantly reduce barriers to foreign investment, while increasing scrutiny of foreigners trying to evade the regulations on investing in restricted industries. The draft law proposes five… – Continue reading
This edition of the Tax-News monthly feature takes in noteworthy events in the international tax arena, including attempts to inject new life into the campaign for comprehensive tax reform in the United States, and developments in the areas of free trade, indirect taxation, BEPS and tax transparency and compliance. US… – Continue reading
The Malta Chamber of Commerce, Enterprise and Industry strongly disagrees with the new property tax announced by the government in the 2015 Budget. The Malta Chamber believes the new tax regime will have an adverse effect on the property market, which has been showing signs of recovery after a period… – Continue reading
IN THIS second installment of the series on Base Erosion and Profit Shifting (BEPS) 2014 deliverables, we will discuss the recommendations of the Organization for Economic Co-operation and Development (OECD) on how to neutralize the effects of Hybrid Mismatch Arrangements. A Hybrid Mismatch Arrangement refers to an arrangement whereby companies,… – Continue reading
IF YOU thought the publication of the command paper on “more powers” has brought clarity to the tax levying and reporting regime, think again. It’s all about as clear as a plate of dribbled mince. And businesses in Scotland, I fear, have now been put at a disadvantage to their… – Continue reading
