Islamabad Around 152,518 financial information of Pakistan tax residents have been received through Common Reporting Standard Exchange (CRSE) on various dates – from October-2018 onwards. This data is being analyzed from taxation point of view and it has been shifted to identify in first instance, cases which are of a...
The UK has published a policy paper setting out the direction for HMRC’s updated strategy for offshore tax compliance, offshore tax compliance strategy: No Safe Havens 2019. In the document, published alongside the chancellor’s Spring Statement, HMRC said it will use hefty punishments for those who enable offshore tax avoidance....
Introduction In July 2015, a number of bills relating to the Cyprus taxation system were approved by the Council of Ministers and subsequently enacted into legislation by the Parliament1. The key highlight of these new bills is the introduction for the very first time of the “non-dom” status for Cyprus...
India has one of the largest networks of tax treaties for the avoidance of double taxation and prevention of tax evasion. The country has Double Tax Avoidance Agreements (DTAAs) with over 85 countries under Section 90 of the Income Tax Act, 1961. The purpose of such tax treaties is to...
In December, the Virgin Islands implemented a new Base Erosion and Profit Shifting (BEPS) measure, according to Government Information Services. The Organisation for Economic Co-operation and Development created a BEPS “action plan” in 2013 to combat “tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift...
During 2017 the Italian Government introduced a new tax regime: The Resident Non-Domiciled Tax Regime(also known as the “Flat Tax Regime”), with the aim of attracting high net worth individuals who want to relocate to Italy. The new legislation introduced a key change to the general principle of worldwide taxation...
Background Portugal is being re-discovered as a destination to relocate to, with iconic cities such as Lisbon and Porto, and stunning coastal areas, for example, the Algarve. It also offers very easy access to the rest of Europe. Portugal is increasingly recognised as an international hub with 71 Double Taxation...
The announcement by National Treasury and SARS in 2017 that the tax exemption on South African expatriates is set to change, has resulted in the lifestyle of many South Africans, who are employed by companies abroad, to rapidly change from a South African tax liability point of view. By Claudia...
The Government yesterday broke down the divide between Bahamian domestic and international financial institutions to meet European Union (EU) demands. KP Turnquest, the Deputy Prime Minister, in unveiling a radical regulatory shift said the Government will “make the playing field level for all financial institutions in The Bahamas” by enabling...
The United States Department of Justice has charged four people with crimes allegedly brought to light by the International Consortium of Investigative Journalism’s Panama Papers expose, according to a DOJ announcement published earlier this month. They are the first US criminal charges stemming from the ICIJ’s 2016 investigation, which reported...
The Cayman Islands government has published draft tax legislation that will have far-reaching impact for the offshore finance industry operating in the jurisdiction by demanding that certain Cayman-registered companies have an adequate level of economic substance locally. The International Tax Co-operation (Economic Substance) Bill 2018 introduces a substance test for...
After global index puts Israel in top third of most financially secretive countries, NGO calls for more public scrutiny and regulations to stop rich from hiding their assets Israel must immediately move to pass regulations against tax evasion and money laundering if it is to protect its credit rating and...
General UK Tax Developments Finance Bill The Finance (No 3) Bill 2018-19 (which will become the Finance Act 2019) was published on 7 November and includes legislation to enact the changes highlighted in our UK Budget blog post ( UK Budget Blog). Another key area covered by the Finance Bill...
Ireland and Malta have agreed to close the “Single Malt” – an aggressive tax planning structure in which some multinational corporations use a company incorporated in Ireland but tax-resident in Malta. The Competent Authority Agreement – entered into as per the provisions of Article 24 (mutual agreement procedure) of the...
There is confusion among taxpayers regarding taxability of foreign rental income in Pakistan and filing of income tax returns in view of avoidance of double taxation treaties signed between Pakistan and UAE, UK and Canada. A leading tax consultant Shahid Jami has approached the Federal Board of Revenue (FBR) for...
The Income-Tax Appellate Tribunal (ITAT) has said NRIs do not need to reveal details of their foreign bank accounts and assets to Indian authorities. The tribunal has also ruled that the onus is on the I-T Department to prove an assessee has parked undeclared income arising from India in foreign...
Introduction – Offshore funds and Canada Revenue Agency’ reach Gone are the days when offshore bank accounts were outside the Canada Revenue Agency (CRA)’s reach. With the advent of the Common Reporting Standard (CRS), CRA automatically receives financial information of Canadian taxpayers who own bank accounts or assets in other...
Barbados is to scrap its international business company (IBC) regime in response to the OECD labeling the policy as “harmful” to competition, and being in breach of rules governing international taxation. Last year the OECD included Barbados on its list of jurisdictions with a “harmful” preferential tax regime, and said...
Government officials have devised what they believe is a solution to the looming European Union blacklist threat, according to Neil Smith, the executive director of government’s Office of International Business (Regulations). The EU has threatened to place the Virgin Islands on an anti-tax avoidance blacklist at the end of the...
Trusts still remain under public scrutiny, but can their reputation be safeguarded, asks Stuart Price A recent government consultation on the law of trusts brought out some interesting issues concerning how the status quo aligns with the principles of transparency, fairness and simplicity (the principles that, at least in the...
The Swiss bank is on trial in France for its role in a tax evasion scandal Swiss bank UBS Group could be forced to pay up to €5.3bn in fines over allegations that it helped wealthy French clients conceal money from tax authorities. The double-pronged lawsuit has been brought against...
Bahamas-based developers have blasted the OECD’s “cynical” attempt to “”de-legitimise” this nation’s key investment product by suggesting it threatens the global fight against tax evasion. The newly-formed Bahamas Developers Association (BDA), in a recent statement, argued that the Organisation for Economic Co-Operation and Development (OECD) was wrong to list this...
Since January 1, 2009, federal tax law limits the amount of gain eligible for exclusion from taxation (known as the “Primary Residence Exclusion”) when you sell a house used as a primary residence, if you also used the house for another purpose, such as a rental. Under Section 121 of...
Introduction A person’s status as a tax resident determines the extent to which Canada may tax that person’s income. The test for whether an individual—i.e., a natural person—is a Canadian tax resident turns on the individual’s particular circumstances. Every detail counts. But Canadian courts and the Canada Revenue Agency both...
Jersey has tabled new laws to address the EU’s concerns over ‘economic substance’, the degree of real business activity carried out by companies registered in the Island. The new proposed requirements for an economic substance test for Jersey tax-resident entities have been published and are set to come into force...
KARACHI: A global investment migration association on Wednesday termed Pakistanis among high-risk nationalities who could exploit loopholes in the OECD’s common reporting standard (CRS) developed to curb offshore tax evasion and avoidance. “Of those nearly one million citizenships granted by the EU each year that are not related to CBI...
On the list of countries operating CBI/RBI schemes, that the OECD feels have the potential to be used for tax dodging, are 2 tax havens that are popular with wealthy Canadians and large Canadian companies. These are Barbados and Panama. Ottawa (19 Oct. 2018) — New information from the Organization...
In Greece, an individual who has moved abroad must file an application to the local authorities in order to demonstrate a new address should they wish to change their status from resident to non-tax resident. Such an application is typically filed by March 10th of the year following the year...
The Lion City will not hesitate to impose action against firms with cross-border tax evasion. Singapore’s Ministry of Finance refuted a news article by CNBC Indonesia which claims that its Double Taxation Agreement (DTA) with Indonesia ‘indulges Singapore’. “Provisions under the DTA are reciprocal, like any other DTA,” the ministry...
The New Delhi bench of Income Tax Appellate Tribunal (ITAT) in Global Academy of Emergency Medicine versus CIT(E), held that under the Income Tax Act appointing of NRIs as trustees of valid Indian trusts are permissible. The sole issue in the instant case was CIT (E) held that the owner...
Chinese superstar Fan Bingbing has been ordered to pay more than US$129 million in overdue taxes and fines. Tax evasion cases involving celebrities are seldom heard of in Hong Kong, thanks to our simple tax regime and low tax rate. Hong Kong’s income tax rate is capped at 15 percent,...
7.What are Mutual Administrative Assistance Agreement (MAAAs) The new IRA defines the “Mutual Administrative Assistance Agreement” to mean a tax information exchange agreement or other international agreement for mutual administrative assistance in relation to taxation matters. Section 75 (5) of new IRA “Mutual administrative assistance agreement” means a tax information...
1.Introduction Due to the influence of International Monetary Fund, the income tax law of Sri Lanka witnessed a near paradigm shift with the introduction of Inland Revenue Act No.24 of 2017 (new IRA) by repealing Inland Revenue Act No.10 of 2006 with effect from 1 April 2018. Unlike the Inland...
Our previous article about the taxable basis for the taxation of companies in the Macau territory made reference to the fact that the courts in Macau, notably the Court of Second Instance (TSI) and the Tax Administration, do not seem to share the same view regarding income considered as the...
KARACHI: The Federal Board of Revenue (FBR) is all set to launch a major crackdown against individuals with concealed and untaxed offshore assets from next week as the revenue body bets on financial information shared under an international treaty, officials said on Friday. The officials said the FBR finalised the...
Hukou (户口) is a system of household registration in China. Each citizen is issued a household register under supervision of the Ministry of Public Security, China’s police. Hukou serves as an identity proof for citizens, recording their basic information and permanent residence. The hukou registration also determines access to housing,...
The new Tax Identification Number (NIF) of Angola for individuals and companies goes into effect on 1 October, said on Friday in Luanda, the head of the Registration and Collection Directorate of the General Tax Administration (AGT). The entry into operation of the new NIF, which will be the same...
On September 13, South China’s Guangdong province announced a series of investment incentives and cost-cutting measures to offset the impact of the worsening trade war with the US. The measures, outlined in the Policy Measures for Expanding Opening-up and Using Foreign Investment, consist of a 10-point plan to attract foreign...
The Australian Taxation Office (ATO) is increasing its efforts to identify taxpayers who fail to report all their income this tax time, as it strives to recover an annual tax shortfall of nearly $1.4 billion caused by individuals who leave income out of their return. “Tax lost from under-reported income...
Spain’s Prime Minister Pedro Sánchez is scheduled to meet with the European Union’s chief negotiator Michel Barnier to push for an annex addressing smuggling in the British territory, as well as cross-border workers and tax evasion. Gibraltar is also on the agenda. As for Gibraltar, however, Spain will reportedly not...
PARIS – France is watering down its punitive tax on the assets of wealthy individuals who leave the country. The government of France is altering the conditions of its infamous “exit tax” and limiting the conditions under which ex-taxpayers of France are liable to pay a tax on the capital...
In June this year, the Chinese government announced much-anticipated revisions to the country’s individual income tax laws. KPMG Partner and Senior Advisor Michael Olesnicky says that these new revisions will likely have ‘profound implications’ within the wealth management community in Asia. Hubbis CEO Michael Stanhope recently spoke with him about...
(Second of two parts) Embracing the Automatic Exchange of Information (AEoI), whether in the form of FATCA and/or CRS, affects stakeholders ranging from the government and businesses down to the ordinary consumers of financial products and services. As such, the uncertainties arising from the supposed implementation are definitely not in...
In June this year, the Central Board of Direct Taxes (CBDT) came out with final clarifications regarding the rules on Place of Effective Management (POEM). POEM is an internationally recognized test for determining the residence of a company incorporated in a foreign jurisdiction with a view to assessing its tax...
The first companies to enter Russian offshores are those that face pressure on the part of foreign authorities, the Head of the Ministry of Economic Development believes. Also, the first residents of the Special Administrative Region (SAR) will be those that will not entail significant costs. The first residents of...
IN 2015, the ASEAN Economic Community (AEC) Blueprint 2025 was adopted as part of the ASEAN 2025: Forging Ahead Together plan. This collaboration charts the broad trajectories of ASEAN economic integration from 2016 to 2025. It aims to strengthen and reinforce by 2025 these five AEC characteristics: 1. A highly...
(Yicai Global) Sept. 5 — China’s tax authority will begin sharing residents’ financial investment data with around 100 countries this month in a bid to crack down on tax evasion. The State Administration of Taxation will begin exchanging data to learn more about what Chinese citizens are doing with their...
BEIJING, Aug. 31 (Xinhua) — China’s top legislature on Friday voted to adopt the revised Individual Income Tax Law in an effort to pursue fairer income distribution. Lawmakers approved the legislation at the end of a five-day bimonthly session of the National People’s Congress (NPC) Standing Committee. The new law...
The Bangalore bench of the Income Tax Appellate Tribunal (ITAT) held that the assessee is entitled for capital gain exemption under section 54F of the Income Tax Act in respect of the properties acquired outside India. In the instant case, the Revenue approached the Tribunal contending that for granting benefit...
THE VALLEY, Anguilla — The government of Anguilla is to implement a “Residency by Investment” programme as part of its medium-term agenda. It will allow foreign nationals to acquire permanent residency status in Anguilla by making a financial contribution to the island and after proving to be of good health...
