The CRA has the power to make a transfer pricing adjustment to any amount for a taxation year under s. 247(2) in respect of a non-arm’s length cross-border transaction. A taxpayer is also liable to a 10% penalty under s. 247(3), which penalty is determined with reference to the taxpayer’s… – Continue reading
We are all familiar with the use of offshore intellectual property holding companies to capitalize on international tax gradients. These companies are designed to take advantage of strategic local tax rules to reduce tax burdens on royalty streams generated from licensing. Because of these favorable tax treatments, countries like Luxembourg… – Continue reading
Finance Minister Edward Scicluna presented amendments to rules against tax avoidance practices within the ECOFIN Council today, amounting to a compromise solution which was accepted. The solution provides rules regarding corporate hybrid mismatches and third countries. The Council agreed its position on rules aimed at closing down ‘hybrid mismatches’ with… – Continue reading
The Government is considering making companies include detail of who their supervisor is under the Anti-Money Laundering and Countering Financing of Terrorism Act (AML/CFT Act) as it strives to clean up the Financial Service Providers Register (FSPR). This suggestion is included in a consultation paper on a Financial Services Legislation… – Continue reading
Irish Finance Minister Michael Noonan has criticized the EU’s proposals for a common consolidated corporate tax base (CCCTB) and public country-by-country (CbC) reporting as “against the BEPS consensus.” In a speech to an event on corporation tax, Noonan said that the consensus over the OECD’s BEPS proposals must hold and… – Continue reading
The Australian Government has introduced legislation to extend the goods and services tax (GST) to low value imports from July 1, 2017. The legislation, introduced on February 16, requires overseas vendors, electronic distribution platforms, and goods forwarders with an Australian turnover of AUD75,000 (USD57,528) or more to register for, collect,… – Continue reading
MPs propose tweaks to the Union Revenue Bill. The solution to widespread tax evasion on land purchases is the creation of a fairer, more even taxation system. This was the prevailing opinion of MPs assembled in Nay Pyi Taw last week to deliberate the Union Revenue Bill prescribing three tax… – Continue reading
Uber is simply providing a taxi service and all its drivers must therefore register to pay goods and services tax, Australia’s Federal Court ruled. The Feb. 17 decision, which could yet be appealed to the full bench of the Federal Court, is “one step in the journey of the tax… – Continue reading
It seems that our tax system is quite the topic of conversation. It has even been called “not European”, “not social” and “a harmful tax practice”. Indeed. The idea that there is some moral code that can be called ‘European’ is as absurd a notion as any I have ever… – Continue reading
ABU DHABI, 16th February, 2017 (WAM)–The Ministry of Finance, MoF, has signed two final agreements on the avoidance of double taxation and the protection and promotion of investment with Burundi. The agreements came as part of the Ministry’s strategy to expand its international relations and to protect and promote Emirati… – Continue reading
ISLAMABAD-Pakistan and Hong Kong on Friday signed the pact on avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income. Pakistan’s Ambassador to China Masood Khalid signed the agreement while the Secretary for Financial Services and the Treasury, Professor KC Chan signed on behalf of… – Continue reading
Thousands of properties in Cyprus that have not been declared to the Tax Department have been discovered during a revaluation exercise by the Department of Lands and Surveys according to the island’s Interior Minister. The general assessment of immovable property valuations formed part of the Memorandum of Understanding between Cyprus… – Continue reading
If the referendum passes, all public servants and elected officials in Ecuador will be barred from holding wealth in offshore accounts. As Ecuador heads to the polls Sunday to elect a new president and National Assembly, deciding the fate of President Rafael Correa’s 10-year Citizens’ Revolution, the small South American… – Continue reading
Azerbaijan and Denmark have signed the convention on avoidance of double taxation and prevention of tax evasion on income taxes. The document was signed by Azerbaijani Minister of Taxes Fazil Mammadov and his Danish counterpart Karsten Lauritzen. Mr. Mammadov said that the document will contribute to the development of trade… – Continue reading
In the public vote held on February 12, 2017, Swiss voters rejected the Corporate Tax Reform III Law Proposal (CTR III). Nevertheless, this issue is not yet resolved and remains on the table! A «CTR III 2.0» is expected in a timely manner. Information about the newest developments, but also… – Continue reading
On February 16, 2017, the Presidium of the Supreme Court of the Russian Federation approved the Review of Court Practice in the Consideration of Cases Involving the Application of Certain Provisions of Section V.1 and Article 269 of the Tax Code of the Russian Federation (the “Review”). There is no… – Continue reading
The Netherlands has signed a protocol to its double tax avoidance treaty with Uzbekistan, designed to prevent the treaty from being inappropriately used to avoid taxes. The anti-abuse provision was signed by the Netherlands and Uzbekistan on February 7, 2017, and “prevents the benefits of the treaty only [being] used… – Continue reading
Greece needs to overhaul its tax system as part of the solution to the country’s economic woes, the International Monetary Fund said in its annual Article IV report for the country. In a report that echoed previous years’ recommendations, the Fund said that Greece must broaden its income tax base,… – Continue reading
SEOUL, Feb. 16 (Yonhap) — The Cayman Islands became the largest investor as a tax haven country in the South Korean market last year, data showed Thursday, amid suspicions that some of the money could be owned by South Koreans disguised as foreign investors in an attempt to avoid taxes…. – Continue reading
The EU has signalled plans to ramp up its work to tackle harmful tax practices internationally, with the Council working group that oversees implementation of the EU’s code of conduct on business taxation finalising a list of jurisdictions that are considered non-cooperative in tax matters to be published shortly. The… – Continue reading
For the third consecutive year, the US Internal Revenue Service (IRS) has placed abusive micro-captive insurance tax shelters on its list of top tax scams to watch out for in the 2017 filing season. The IRS explained that the US tax code generally allows businesses to create captive insurance companies… – Continue reading
The OECD has recommended that Sweden rebalance its property tax system. In its latest Economic Survey for the country, the OECD said that Sweden’s favorable tax treatment of owner-occupied housing is regressive, benefiting relatively high-income households most and contributing to the high demand for housing. It said it also encourages… – Continue reading
Bilateral Economic Accord Key to Growing Trade and Investment WASHINGTON—Armenian National Committee of America (ANCA) Chairman Raffi Hamparian recently held a working meeting on Capitol Hill with U.S. Senator Robert Menendez (D-N.J.) on a range of shared priorities, including the negotiation of a new U.S.-Armenia Double Tax Treaty. This bilateral… – Continue reading
Business leaders are calling on Chancellor Philip Hammond to tackle anomalies in the tax system that see high street shops pay higher rates on small premises than online giants do for vast warehouses. The Institute of Directors said the Chancellor should use next month’s Budget to set up a New… – Continue reading
(Bloomberg Gadfly) — A referendum lost. Voters crying foul at cuts to public services. The threat of financial chaos and businesses sent packing. This isn’t Brexit Britain. It’s Switzerland. The country this weekend voted down a government plan to keep offering tasty tax breaks to multinational companies — while still… – Continue reading
A prominent QC yesterday backed calls for the Bahamas to switch to a ‘low tax’ business model, warning: “The survival of financial services is not an option.” Brian Moree QC, senior partner at McKinney, Bancroft & Hughes, said the Bahamas had to “figure out how to adjust its business model”… – Continue reading
Background Switzerland levies federal withholding tax at the rate of 35% on certain capital income, including dividend distributions of Swiss corporations. The federal withholding tax is fully refundable for Swiss resident recipients, provided that they (i) are beneficially entitled to and (ii) correctly declare respectively account for the taxable income…. – Continue reading
Following Moody’s Investors Service affirmation of Indonesia’s sovereign credit rating at Baa3 with a stable outlook in January 2016, there has been renewed interest in the international bond market for Indonesian credits. This bulletin seeks to summarise the regulatory changes in Indonesia over the last 24 months as well as… – Continue reading
EU lawyers are preparing to mount a legal challenge against President Trump’s hugely controversial US border tax proposals in what could be the biggest case in World Trade Organisation history. Mr Trump’s proposed “border adjustment system” would see US imports subjected to tax, while export revenues exempted. The reforms have… – Continue reading
The federal government forgoes as much as $47.8 billion in uncollected taxes every year, according to a new report that Ottawa has yet to release. These billions represent only a fraction of all taxes that go unpaid because they don’t include taxes owed to the provinces and municipalities — all… – Continue reading
A new paper that calls for the introduction of a US carbon tax has been released by a group of former Republican administration members and economic advisers and leading business representatives. Issued under the auspices of the Climate Leadership Council, the paper proposes that the tax might begin at USD40… – Continue reading
On 7 February 2017, the Minister of Finance of Ukraine and the US Ambassador to Ukraine signed a treaty on Ukraine’s performance of the US Foreign Account Tax Compliance Act (FATCA) (the Treaty). According to the Ministry of Finance of Ukraine, the Treaty is based on the Model 1B Intergovernmental… – Continue reading
Last Autumn, HMRC issued “Measuring Tax Gaps”, an annual report on the estimated UK tax gap. The tax gap being the shortfall in tax estimated by HMRC as being due in any one tax year from that which is eventually collected. In the accompanying press releases and in comments made… – Continue reading
Selection of Foreign Company as a tested party – practical considerations Introduction Transfer pricing regulations adopted by India are based on the arm’s length principle which revolves around the concept that the price or margin determined in a controlled transaction involving two Associated Enterprises (AE) should be commensurate with an… – Continue reading
MARTINSBURG — The Internal Revenue Service has started releasing this year’s top 12 scams targeting consumers known as “The Dirty Dozen.” The annually compiled list features a variety of scams the agency says are common and that taxpayers could encounter anytime, but especially during peak filing season. Phishing schemes lead… – Continue reading
Proposed changes to Switzerland’s corporate tax framework have been rejected in a referendum. Provisional results show that the Corporate Tax Reform III (CTR III) package was opposed by just over 59 percent of voters in the February 12 referendum. CTR III would have abolished corporate tax arrangements that the Swiss… – Continue reading
Summary: NAGPUR: Prominent doctors across the state were raided by income tax department on Saturday suspecting major evasion of tax through cash deals. The income tax department has got a disclosure of Rs30 crore from the action against jewellers. Last month the taxmen covered jewellers across the state. One of… – Continue reading
The Airline Operators of Nigeria (AON) has blamed the poor performance of domestic airlines on multiple taxation by various agencies in the aviation sector. Capt. Nogie Meggisson, Chairman, AON, made the claim on Sunday in Lagos while reacting to the takeover of Arik Air and Aero Contractors by the Asset… – Continue reading
SCOTLAND is being used as a virtual base to help French nationals avoid tax and social security payments. An online agency – registered to a Glasgow shell firm – is offering a range of “offshore solutions” for those who want “zero per cent tax” and “complete confidentiality”. The company –… – Continue reading
In the latest published data from the US Treasury Department and Federal Reserve Board in respect of November 2016, the value of Treasury Securities held by foreigners was $5.9tn with Japan’s holdings at $1.1tn and China at $1.0tn, followed by Ireland at $275bn. However, some further data show that the… – Continue reading
The State Administration of Taxation (SAT) is about to hold Chinese citizens’ foreign account information in 101 countries and regions, as the regulation on the localization of the Common Reporting Standard (CRS) in China was put into effect on January 1, the Xinhua News Agency reported on Sunday. Under the… – Continue reading
A CAMPAIGN has been launched in Washington DC to repeal international tax regulations that lobbyists say have cost Jersey and other finance centres billions of pounds. The controversial Foreign Account Tax Compliance Act, which was introduced in 2010 by President Barack Obama, requires all finance firms outside the US to… – Continue reading
German banks support stricter beneficial ownership rules for companies and trusts, while the leading Scandinavian bank backed an offshore corporate economic substance test to help comply with EU laws against money laundering and tax evasion. Testifying before the European Parliament’s Panama Papers investigative committee, the Association of German Banks told… – Continue reading
YEREVAN, February 9. /ARKA/. The Armenian parliament ratified today an agreement between the governments of Armenia and Argentina on exchange of taxation-related information, signed in 2015 July. According to the deputy head of Armenian State Revenue Committee Vakhtang Mirumyan, this agreement, initiated by the Argentine side, is aimed at providing… – Continue reading
The US taxes its citizens and permanent residents on their worldwide income regardless of where they live or how long they’ve lived outside of the US. There is only one other country in the world that operates like the US – Eritrea – an African nation. According to the IRS:… – Continue reading
HYDERABAD: Tennis player Sania Mirza has been issued notice by the Service Tax department over alleged non-payment or tax evasion. Service Tax office in Hyderabad has issued summons to the tennis star on February 6 and she will have to appear before it in person or by an authorised agent… – Continue reading
The Government has introduced the Diverted Profits Tax Bill 2017 and the 35 page Treasury Laws Amendment (Combating Multinational Tax Avoidance) Bill 2017 into Parliament to implement the Diverted Profits Tax (DPT), as one of its first Parliamentary items of business in 2017, indicating the priority attached to this measure…. – Continue reading
‘Private Banking’ is a term that usually conjures up images of secret banking transactions being carried out on behalf Royal families, the landed gentry and wealthy individuals. That’s how private banking started, but is not a fair reflection of private banking today. Today, it’s not your family tree that matters… – Continue reading
With the arrival of the new year, don’t be surprised if your bank asks for information about yourself and your accounts that you didn’t have to provide before. These questions signal an important development as banks in Hong Kong and around the world prepare to share certain information with tax… – Continue reading
The Foreign Account Tax Compliance Act (FATCA) United States of America Implementation and Enforcement of the Inter-Governmental Agreement was passed in Parliament without opposition, making it mandatory for Antigua & Barbuda’s banks to provide the banking information of US citizens to the Internal Revenue Service (IRS). The Act requires local… – Continue reading
