Category: Residence

Regulatory Issues: Financial account information exchange for increased tax compliance

Malaysian individuals and entities that have bank accounts overseas will soon see their financial information being shared with other countries and tax authorities in an effort to boost global transparency and tax compliance. This requirement is part of the automatic exchange of financial account information set out by the Organisation...

Australian Budget Targets Housing, Tax Compliance

Australian Treasurer Scott Morrison’s 2017 Budget focused on measures to cool the housing market and crack down on tax avoidance. Morrison handed down the Budget on May 9. He said the the budget would return to a surplus in 2020-21 and remain in surplus over the medium term. The Budget...

UK: The UK Company: A New Alternative For International Investors?

This article is the first of a series of articles that looks at tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors. An essential feature of...

ECJ Rules In Austria’s Favor In Tax Dispute With Germany

The European Court of Justice (ECJ) has ruled in favor of Austria in its dispute with Germany relating to the taxation of interest from profit-participation certificates received by an Austrian bank from a German bank. The case involved the interpretation and application of Article 11 of the 2000 double tax...

SIX Financial Information launches tax compliance data service for Common Reporting Standard

SIX Financial Information announced that has launched a new Common Reporting Standard (CRS)/ Automatic Exchange of Information (AEoI) data service, enabling financial institutions to meet the requirements which are being phased in from June 2017. The SIX CRS/AEoI service identifies CRS-reportable client income by flagging relevant corporate actions, simplifying resource-intensive...

Sao Paulo Property Secrecy Exposes Continuing Role of UK Tax Havens

A new report from Transparency International has revealed that more than US$2.7 billion worth of property in Sao Paulo, Brazil’s biggest city, is hidden behind shell companies, many of which have close links to the United Kingdom, which has many offshore tax havens in its overseas dependencies. Using newly released...

Sao Paulo Property Secrecy Exposes Continuing Role of UK Tax Havens

A new report from Transparency International has revealed that more than US$2.7 billion worth of property in Sao Paulo, Brazil’s biggest city, is hidden behind shell companies, many of which have close links to the United Kingdom, which has many offshore tax havens in its overseas dependencies. Using newly released...

Tax evasion of more than Rs 1.37 lakh crore detected in last three years

The Revenue Department on Friday said it has detected evasion of more than Rs 1.37 lakh crore in both direct and indirect taxes and identified over 1,000 shell companies which indulged in bogus transactions worth Rs 13,300 crore in the last three financial years. Warning tax evaders, it said the...

Westpac crackdown on foreign buyers and money laundering

Property buyers will be quizzed about their tax residency under new anti-money-laundering rules being introduced by Westpac and its subsidiaries St George Bank, Bank of Melbourne and BankSA. Mortgage brokers, who act as intermediaries between the banks and buyers, are being told that from this week they must also ask...

What happens if you are from the UK or own assets in the UK?

Beware of the dreaded inheritance tax and changes to it from April 2017! Approximately 1.3 million Britons now live in Australia and Brexit may only increase this number! Many think that moving to Australia means they no longer need to worry about UK tax, but often they are not fully...

CARICOM seeks FATCA delay, but law may prove irrelevant

The Caribbean Community is looking at spending nearly quarter of a million dollars on a Washington-based consultant to lobby the Trump administration about the Foreign Accounts Tax Compliance Act. Cayman appears unlikely, however, to be affected by any lobbying – or even FATCA repeal – in the wake of last...

Next off the block – AEOI

You might have thought you have enough on your plate getting to grips with anti-money laundering rules closely followed by FATCA – but it’s not over yet! Next off the block is the Automatic Exchange of Financial Account Information in Tax Matters (AEOI). The AEOI, which we first provided an...

GAAR & POEM- Combating Tax Avoidance

The Central Board of Direct Taxes (CBDT) has on 24th January 2017 issued final guidelines for determination of “Place of effective management”(POEM). On 27th of January, again CBDT released clarifications on “General Anti Avoidance Regulations” (GAAR). POEM is effective April 01,2016 whereas GAAR is effective from April 01,2017.POEM can be...

Combatting Foreign Tax Evasion With New Filing Requirements for Foreign-Owned Disregarded Entities: Tax Update, Volume 2017, Issue 2

The new regulations expand the filing requirements for Form 5472 to include disregarded entities with foreign owners when there are certain reportable transactions. If a non-U.S. person (individual or corporation) owns 100 percent of the stock of a U.S. corporate subsidiary, the subsidiary needs to obtain an employer identification number...

Five things agents and developers need to know about the non-dom tax changes

From 6 April 2017, non-dom owners of UK property will be liable to inheritance tax (IHT) at 40% on any UK residential property they own. This has always been the case where a non-dom (broadly an individual who is resident in the UK but who has their permanent home abroad)...

Inflation: How government is collecting more tax revenues by stealth

These three CGT exclusions have remained unchanged for five years. Over the last few years government has collected a significant amount of tax revenue by not fully adjusting the personal income tax tables for inflationary increases in earnings, thereby increasing the effective tax rate of individuals. A middle-class individual earning...

MPs approved exchange of information

The parliament transposed the EU regulation, whose aim is to secure comprehensive and effective administrative collaboration between tax administrations via mandatory automatic exchange of information. International corporations will be required to submit reports about their activities in every EU country in which they do business. This stems from the amendment...

Bills, cars, bank accounts: the Italian Revenue Service will chase evaders who pretend to be abroad

The Italian Revenue Agency is stepping up its fight against international tax evasion. The tax authority will focus on undeclared funds and income held abroad by Italian taxpayers who have become resident abroad since January 1, 2010. Controls will be based on selected lists, which will first target the most...

3 Key Tax Rules Governing Typical Business Deductions

What is a business expense deduction? A business expense deduction is a deduction allowed for ordinary and necessary expenses paid or incurred in connection with an individual’s trade, business or profession. IRC Section 62(a)(1) operates to assure that all trade or business expenses, deductible as delineated under specific IRC Sections,...

New Zealand: New Zealand To Enact Tighter Foreign Trust Disclosure Rules

The New Zealand Parliament has passed a Bill which, following royal assent, will meaningfully increase disclosure obligations for NZ resident trustees of NZ foreign trusts. The Taxation (Business Tax, Exchange of Information, and Remedial Matters) Bill, was passed by Parliament on 14 February 2017. The Bill contains important provisions relating...

Luxembourg: Luxembourg’s New Transfer Pricing Rules: Some Compliance Required!

On 22 December 2016 the Luxembourg Parliament passed article 56bis of the Luxembourg Income Tax Law (LITL). This provision gives taxpayers and tax authorities more guidance on how to apply the arm’s-length principle. The new article can be seen as a transposition of OECD BEPS reports (actions 8-9-10) released in...

Companies Get Draft Instructions for U.S. Global Tax Reports

U.S. multinational companies with more than $850 million in annual consolidated gross income now have draft instructions for filing IRS reports on their global tax and profits. The Internal Revenue Service added instructions to the draft Form 8975 and accompanying draft Schedule A it released in December 2016, companies that...

New tax measure takes aim at Offshore Trusts

A bombshell hidden in the detail of the 2017 Budget review relates to the taxation of offshore trusts. It refers to the 2015 Budget review in which it was announced that measures would be introduced to the tax treatment of foreign companies held by interposed trusts. No specific countermeasures were...

Amendments to Profit Tax Law in Republic of Srpska of Bosnia and Herzegovina

The National Assembly of the Republic of Srpska (RS) adopted amendments to the Profit Tax Law on 28 December 2016. The main changes have become effective as of 1 January 2017 and will be briefly presented in this article. With the amendments, the Law clarifies the definition of “taxable person”...

Opportunity for Refund of Late Interest charged on Failed Withholding Tax Notifications

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....