Cyprus transposed the EU Parent-Subsidiary Directive1 into domestic legislation when it updated its tax laws in preparation for EU membership in 2004. The Income Tax Law and the Special Contribution for the Defence of the Republic Law provide a liberal system of double taxation avoidance, which also extends to non-EU countries,… – Continue reading
The Organization for Economic Cooperation and Development has released its first set of recommendations for a coordinated international approach to combat tax avoidance by multinational enterprises, under the OECD/G20 Base Erosion and Profit Shifting Project. The OECD and the Group of 20 finance ministers hope to create a single set… – Continue reading
India has seemingly reached an impasse with both Cyprus and Mauritius over the re-negotiation of their respective double taxation avoidance agreements (DTAA). For the former, the disagreement relates to Cyprus’s status as a notified jurisdictional area (NJA) in India, whilst for the latter, it pertains to the update of their… – Continue reading
A proposed clampdown on global tax avoidance took a step forward on Tuesday with a leading global think tank releasing key recommendations ahead of a G-20 meeting later this month. The practice of companies shifting their profits to other country’s jurisdictions to avoid paying tax has drawn criticism from governments… – Continue reading
While Senate Democrats continue to examine specific legislative proposals to deter US multinationals from using corporate inversions to move their tax residence abroad, Republicans remain insistent that any specific anti-inversion legislation should be explicitly linked to comprehensive tax reform. A new bill has been put forward by Charles Schumer (D… – Continue reading
On September 16, 2014, the Organisation for Economic Co-operation and Development (OECD) released its first seven of 15 deliverables under the OECD/G20 base erosion and profit shifting (BEPS) project (the 2014 BEPS Package). The 2014 BEPS Package arises from the Action Plan on Base Erosion and Profit Shifting (the BEPS Action Plan),… – Continue reading
Platforms could be hit with a £10m bill in order to make sure they comply with new EU tax rules, the Tax Incentivised Savings Association (Tisa) has warned. Tisa technical director Jeffrey Mushens said the incoming EU VAT law, which goes live in January 2015 and is aimed at online… – Continue reading
Over the past six years, the United States has become increasingly concerned that Americans are stashing money offshore, essentially evading U.S. tax. The IRS has increased filing requirements around foreign assets through the Foreign Account Tax Compliance Act (FATCA), which requires financial institutions around the world to report activities of… – Continue reading
Introduction On July 25, 2014, Switzerland and Cyprus signed a new agreement for the avoidance of double taxation (DTA) with respect to taxes on income and capital. It is the first DTA between the two countries, and will contribute to the development of bilateral economic relations. The agreement will come… – Continue reading
With an eye to next year’s federal election, the Harper government has begun to sprinkle tax-relief treats across the country. Small businesses got theirs last week with a break on employment insurance premiums. Sometimes, however, what governments don’t do can be as telling as their actions. The Finance Department has… – Continue reading
HONG KONG, Sept. 15 (Xinhua) — China’s Hong Kong Special Administrative Region government supports the new global standard for automatic exchange of financial account information which can enhance tax transparency and combat cross-border tax evasion, Secretary for Financial Services and the Treasury KC Chan said here Monday. “It… – Continue reading
ALTHOUGH Finance minister Patrick Chinamasa’s 2014 Fiscal Policy Review statement announced last week seeks to widen government’s revenue inflows, analysts contend that there is need to seriously curb illicit financial flows (IFFs) from Zimbabwe if the economy is to experience the anticipated growth. Illicit financial flows through tax evasion, bribery,… – Continue reading
The Centre is likely to take a final call on the controversial General Anti Avoidance Rule (GAAR) only by next February. The decision may well be announced by finance minister Arun Jaitley in his next Budget presentation. “The finance ministry has started holding discussions on the issue but no hurried… – Continue reading
New Delhi: Talks between India and Cyprus on amending their bilateral tax treaty appear to be deadlocked over India’s demand to include a limitation of benefit (LOB) clause, which restricts benefits under the agreement to genuine resident investors of the Mediterranean island-nation. As a result, it may take longer than… – Continue reading
Non-doms would only have to have a father born in Scotland, expert warns Status only worthwhile for those with assets worth several million Scottish independence could see thousands of wealthy people start to claim ‘non-domicile’ tax status, experts predict. Mark Davies, a tax expert at website Nondom, said: ‘To claim… – Continue reading
As a small island nation, with a vibrant insurance sector and relatively low tax rates, Bermuda can be a target for political leaders and pundits in the United States. But history shows that our nations are natural friends, allies and economic partners. Seventy years ago, fighting against Imperial Japan and… – Continue reading
Using foreign stocks to diversify your portfolio can be a good move for investors looking to collect dividends and protect capital. But owners of dividend paying foreign stocks can find themselves being hit by another type of tax: foreign dividend withholding tax. Keeping as much of your dividends as possible… – Continue reading
On Monday the 11th of August, an appeal was filed with the Federal Court of Canada in Vancouver seeking a declaration that the enforcement by the Canadian Government of the United States’ Foreign Account Tax Compliance Act (“FATCA”) on Canadian soil is unconstitutional. Under FATCA financial institutions enter into an… – Continue reading
Factors to consider in deciding which type of incorporation is best for you AS TAX LAWS continue to evolve, so do choices of entity. Being mindful of the alternatives is critical to achieving tax benefits. Both S corporations and Limited Liability Companies (LLC’s) are flow-throughs, which have long been a… – Continue reading
A senior Democratic tax writer said Friday that the Obama administration could take unilateral action targeting offshore tax deals before Congress leaves town for the midterm elections. Rep. Sandy Levin (D-Mich.) said that Treasury Secretary Jack Lew told a group of House Ways and Means Democrats on Wednesday that the… – Continue reading
Labor has accused the government of procrastinating on a key measure to stop multinational companies shifting profits offshore. It comes as the government prepares to chair the G20 finance ministers meeting in Cairns next week. The information-sharing deal, part of the global push to tackle tax avoidance, has been signed… – Continue reading
The Obama Administration, along with a couple senators, have been leading a campaign of moral indignation against “inversions.” In tax terms, inversions are a U.S. incorporated company changing its residence to a lower tax country to reduce the tax burden on its income. Because U.S. companies are taxed in the… – Continue reading
Although the Foreign Account Tax Compliance Act (FATCA) went “live” July 1, 2014, guidance continues to fall into place. On July 16, the IRS issued instructions for the requester of various Forms W-8 and continues to update its FAQ website. The Cayman Islands Tax Information Authorityissued regulations effective July 4, 2014 addressing the… – Continue reading
The French and Luxembourg Finance Ministers signed, on 5 September 2014, a Protocol amending Article 3 (the “Protocol”) of the France-Luxembourg double tax treaty for the avoidance of double taxation and the establishment of rules of reciprocal administrative assistance with respect to taxes on income and fortune (the “Tax Treaty”)…. – Continue reading
A political advisor for the government of the former Vanuatu Prime Minister Moana Carcasses, French national Gilles Daniel, has had his Vanuatu citizenship revoked. Mr Daniel has already been deported from Vanuatu in 2005, but challenged his deportation, with the court ruling in his favour. The secretary of the Vanuatu… – Continue reading
Withholding on US source income under FATCA started on 1 July 2014. The withholding will apply to gross “proceeds of sale” of securities bearing US source income (which includes repayment of principal on a loan to a US borrower) and, potentially, to “foreign passthru payments” from January 2017. Now that… – Continue reading
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Rep. Mark Pocan, D-Wis., has introduced three pieces of legislation to close tax breaks that enable U.S. multinational corporations to use so-called “inversions” in which they merge with a foreign company and move their tax domicile abroad to a low-tax country to reduce corporate taxes. Corporate inversions are used by… – Continue reading
On 5 September 2014, the Governments of France and Luxembourg signed an amendment to the France-Luxembourg treaty dated 1 April 1958 (the “Treaty”), which will have an impact in the future for certain investments in French real estate. Indeed, the amendment introduces new provisions under Article 3 paragraph 4, allocating… – Continue reading
Outsourcing the responsible officer (RO) function under the Foreign Account Tax Compliance Act (FATCA) offers limited value to Cayman-Islands’ domiciled fund managers.The Model one Intergovernmental Agreement (IGA) between the Cayman Islands and the US does not stipulate that a responsible officer is required. The responsible officer title is a feature… – Continue reading
EVEN MORE Philippine companies have complied with a US tax law since a July 1 deadline, after which foreign financial institutions (FFIs) not yet registered with the US Internal Revenue Service (IRS) faced penalties. A list published by the IRS earlier this month showed that a total of 197 Philippine-based… – Continue reading
The tax authorities of the United Kingdom and Canada are to deepen cooperation to establish a stronger mutually beneficial relationship, senior officials from both Government have said. Canada’s Revenue Minister, Kerry-Lynne D. Findlay, met with David Gauke, the UK’s Financial Secretary to the Treasury, in London on September 8. Findlay… – Continue reading
Sen. Charles Schumer (D-N.Y.) released legislation Wednesday seeking to roll back the tax benefits for companies that reincorporate abroad. Schumer’s bill takes aim at a maneuver known as earnings stripping, a process by which U.S. subsidiaries can take tax deductions on interest stemming from loans from a foreign parent. The… – Continue reading
Retroactive legislation curtails tax-avoidance schemes but undermines faith in a government that changes the rules of game after an investment is made The temperature is rising in the United States over corporate inversions. U.S. Treasurer Jacob Lew is looking to pass retroactive law to undo recent corporate restructurings and, with… – Continue reading
On 1 August 2014, the “Provisional Measures on the Collection of Tax on Non-Resident Taxpayers Engaged in International Transportation Business” (2014 No.37 Notice, the “New Regulations”) came into force. The New Regulations could have a significant impact on owners as they seek to streamline and tighten up the regulations in respect of… – Continue reading
The Federal Court has handed down its decision in the case of Task Technology v Commissioner of Taxation in relation to the tax treatment of specific software payments. The case related to payments made by Task to CaseWare International Inc (CWI) for the right to market and distribute CWI software to end users… – Continue reading
Now that we have new cabinet ministers to drive the economy forward, the next expectation is for martial law to be lifted so that foreign investors and tourists can feel more comfortable about returning to Thailand. Meanwhile, the junta is determined to quickly show the people some signs of genuine… – Continue reading
Minister of National Revenue concludes two days of meetings in London LONDON, ENGLAND–(Marketwired – Sept. 9, 2014) – Canada Revenue Agency The Honourable Kerry-Lynne D. Findlay, P.C., Q.C., M.P., Minister of National Revenue, today wrapped up a successful two-day trip to London, England. During her visit, Minister Findlay met with David… – Continue reading
The DTA between Cyprus and United Arab Emirates took effect on 1 January 2014 The double taxation agreement between Cyprus and the United Arab Emirates took effect on 1 January 2014. For a detailed analysis of the new agreement, the first between the two countries, please follow this link. The… – Continue reading
Noble Energy and Jordan recently signed a nonbinding agreement for the sale of 8.5% of Leviathan’s gas over the course of 15 years, for as much as $15 billion. By Avi Bar-Eli | Sep. 9, 2014 | 2:47 AM The preliminary deal for the sale of gas to Jordan from… – Continue reading
A former Chinese citizen, Ruihua Yau, has been declared stateless by the Vanuatu government. The Secretary General of the Citizenship Commission, John Enock Ware, has confirmed that the agency revoked Mr Yau’s certificate of Vanuatu citizenship last month. Mr Ware says the Commission found Mr Yau got Vanuatu citizenship after… – Continue reading
A multi-count indictment was unsealed this morning in federal court in Brooklyn, New York, against six individual defendants: Robert Bandfield, a U.S. citizen; Andrew Godfrey, a citizen of Belize; Kelvin Leach, a citizen of the Bahamas; Rohn Knowles, a citizen of the Bahamas; Brian De Wit, a citizen of Canada;… – Continue reading
The Irish tax authority, the Revenue Commissioners, has released eBrief No. 75/14 on double tax relief for individuals subject to the High Earners Restriction, following changes in the Finance (No. 2) Act 2013. The 2006 and 2007 Finance Acts introduced, with effect from January 1, 2007, measures to limit the… – Continue reading
U.S. companies are shifting their addresses abroad to reduce their taxes Treasury Secretary Jacob Lew said Monday the Obama administration will decide “in the very near future” what actions it can take to make it less profitable for U.S. companies to shift their legal addresses to other countries. A growing… – Continue reading
Minister, Embassy of Japan Mr. Isomata Akio asked India to exempt Japanese manufacturers, operating in India from withholding tax and Minimum Alternate Tax (MAT) so that these do not evolve into being one of the trade barriers and stagger Japan from becoming India’s largest trade partner in times to come. Japan investments and technology… – Continue reading
The Irish tax authority, the Revenue Commissioners, has released eBrief No. 75/14 on double tax relief for individuals subject to the High Earners Restriction, following changes in the Finance (No. 2) Act 2013. The 2006 and 2007 Finance Acts introduced, with effect from January 1, 2007, measures to limit the… – Continue reading
A recent Tax Court decision1 addressed the tax consequences to a Finnish citizen of wages she received while working as an employee in the United States on behalf of her country’s Permanent Mission to the United Nations. The case involves Sole Abrahamsen, a Finnish citizen, who began working at Finland’s Permanent… – Continue reading
MONTREAL – The disclosure by Valeant Pharmaceuticals International Inc. that it is under audit by the U.S. Internal Revenue Service is raising further doubts among tax specialists about the future of the Quebec-based drug company’s tax strategies. Valeant estimates it has achieved US$2.5-billion in tax and other “corporate structure” savings… – Continue reading
From 6 April 2013 an individual’s residence status for UK tax is determined using the statutory residence test (SRT). The SRT flowchart overleaf is designed to assist in determining the residence status of individuals. The legislation and guidance is lengthy and the flowchart and notes can only give a brief… – Continue reading
The Isle of Man has signed a Tax Information Exchange Agreement (TIEA) with the Kingdom of Swaziland.The TIEA was signed by Eddie Teare MHK, the Isle of Man’s Treasury Minister, in the Isle of Man, and by Senator Martin G. Dlamini, Swaziland’s Minister for Finance, in Swaziland, and exchanged by… – Continue reading
