‘Multinational corporations complain all the time of excessive demand about excessive taxation, but it is also true that MNCs across the world tend to find tax avoidance and sometimes tax evasion as an appropriate technique’ Blaming multinational corporations squarely for tax controversies, Reserve Bank Governor Raghuram Rajan has said their… – Continue reading
The OECD’s final reports on the Base Erosion and Profit Shifting (BEPS) Project aim to target aggressive tax planning strategies which have the effect of shifting profits from high tax jurisdictions to low tax jurisdictions. The BEPS Project has been divided into 15 Actions, of which one of the most… – Continue reading
Tempur Sealy swung to a loss in the fourth quarter as a tax dispute with Denmark that may take years to resolve continued to weigh on the world’s largest mattress maker. The net loss of $11.3 million, or 18 cents a share, reflected in part a balance sheet charge related… – Continue reading
Democrats are balking at tying up $19 million to fund tax credits in 2016, fearing the money might be needed for more urgent needs. MAINERS ALREADY HAVE BEGUN FILING THEIR TAX RETURNS, BUT THE LEGISLATURE HAS YET TO DECIDE WHETHER IT WILL ADOPT AT THE STATE LEVEL A GROUP OF… – Continue reading
During last year’s Autumn Statement the Chancellor announced that SDLT rates would increase in relation to the purchase of additional residential properties. As with the 2014 Autumn Statement changes to SDLT rates for residential property, it was something of a surprise move. Transactions falling within the new ‘additional dwelling’ regime… – Continue reading
Estonia has become the first country in the world to offer a transnational digital identity. It’s attracted the attention of entrepreneurs and digital nomads worldwide, but there’s still a huge amount of confusion about the benefits of the E-Residency Program and what e-residency actually means. Let’s take a look. What… – Continue reading
While the central government is pursuing its objective to provide a certain and stable tax regime, it is critical that instances of dual levy of VAT and service tax on the same transaction are addressed urgently The levy of service tax as well as Value Added Tax (VAT) on the… – Continue reading
Surge in revenue foregone by exempting family home from capital gains tax – largely driven by higher property prices – fuels fiscal policy debate The budget cost of tax breaks on family homes has reached nearly $55bn a year, fuelling debate about alternative options as the Turnbull government prepares its… – Continue reading
In its 2015 Budget, the Canadian federal government announced its intention to exempt “certified” non-resident employers from the obligation to withhold and remit income tax in respect of certain employees that perform duties in Canada. The Canada Revenue Agency (the “CRA“) recently released the application form that a non-resident employer… – Continue reading
An unnamed Korean, according to the National Tax Service (NTS), was living a luxurious life with properties and investments inherited from his father. This inherited fortune, which included stocks overseas, high-end residences as well as diverse financial assets, was not only unreported to the Korean tax agency but was managed… – Continue reading
In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting out the parameters for automatic exchange of country-by-country reports on large multinational corporations. The agreement — the Multilateral Competent Authority Agreement on… – Continue reading
FATCA. Since July 2014, the five-letter acronym has instilled dread in the hearts of American expats all around the world. “The Foreign Account Tax Compliance Act (FATCA) requires banks to report information to the IRS regarding all financial accounts held by American clients,” Ines Zemelman, expat tax specialist and founder… – Continue reading
Ireland will be forced to ban many of the tax advantages it offers multinationals under proposals to be published by the European Commission tomorrow. This is the first step in an effort to have all EU countries introduce similar tax rules to prevent companies in the 28 member states avoiding… – Continue reading
Anguilla levies a 3% flat rate of personal income tax and is otherwise a tax haven with a stunning climate and amazing Carribean lifestyle Whilst there are various categories of flat tax, including marginal flat tax and Hall-Rabushka flat tax, in its simplest form flat tax is simply a rate… – Continue reading
Car battery and heating equipment maker accused of ‘stranding honest taxpayers’ Johnson Controls, a US maker of car batteries and heating and ventilation equipment, has agreed to buy Irish-based peer Tyco International in a $16.5 billion (€15.23 billion) deal that will lower its tax bill. By redomiciling to Tyco’s headquarters… – Continue reading
A. INTRODUCTION On the 13th of March 2012, the Cyprus VAT Authority has launched a scheme making Cyprus one of the most attractive EU jurisdictions for yacht registration. According to this scheme, a Cyprus company can enter into a lease-sale agreement of a yacht with a third party, paying VAT… – Continue reading
Once the thrill of deciding to retire overseas has subsided, you normally start to think of all the things you need to do before you go. Picking the right removal firm, a lawyer to help you buy a new home are a couple, but the tax & financial implications of… – Continue reading
The redomiciliation of companies (ie, movement of a company incorporated in one jurisdiction to another, retaining its legal character) is not recognised under Chilean law. This means that in order to move to Chile, a foreign company must establish a branch or create a subsidiary there. It cannot move its… – Continue reading
The International Monetary Fund (IMF) has welcomed the Ghanaian Government’s fiscal consolidation efforts, including its various revenue-raising initiatives. The Government is seeking to implement an adjustment of two percent of gross domestic product (GDP). This would bring the country’s deficit to about 5.3 percent of GDP in 2016. Over the… – Continue reading
Mozambique may introduce an LNG-specific tax regime for its giant Rovuma Basin projects if new petroleum tax regulations prove too tough for investors in today’s $30 per barrel oil environment. “Amendments to the tax law framework that were made [when oil prices were high] may serve Mozambique less well right… – Continue reading
One of the biggest financial benefits of owning a home is qualifying for the tax breaks that homeowners are eligible to receive. Many of the tax deductions for home-related expenses are well-known, but others often slip under the radar. Below, we’ll run through the list of deductions for homeowners that… – Continue reading
A group of businesses in the Welsh town of Crickhowell have gone offshore as part of a campaign to try and get HMRC to change tax laws. The Welsh town of Crickhowell is spearheading a unique campaign to get HM Revenue & Customs (HMRC) to change the laws so companies… – Continue reading
The Mauritius Revenue Authority (MRA) has confirmed the first exchanges of information under the Common Reporting Standard will now take place from September 2018, rather than September 2017. The OECD’s CRS, the new global standard for automatic exchange of information for tax purposes, obliges all participating countries and jurisdictions to… – Continue reading
It’s a whopping four and a half thousand miles away from the UK but the Cayman Islands is a slice of British-overseas paradise. Watched over by a Governor appointed from Whitehall, the Caymans are technically British. But there’s a huge difference between that island and the UK: no-one seems to… – Continue reading
As from 1 January 2016, new rules have become effective in the Netherlands that require multinational enterprises (“MNEs“) to comply with new transfer pricing documentation requirements, including the obligation to prepare a Country-by-Country Report (“CbC Report“), a Master File and a Local File. These rules essentially implement Action 13 of… – Continue reading
The term double taxation refers to an exposure to tax more than once on the same profit or income. There are two types of double taxation i.e. economic double taxation and juridical double taxation. Economic double taxation is broad and occurs in a situation where an amount of income is… – Continue reading
The taxation of ‘non-UK domiciled’ individuals has been a thorny political issue as successive governments have sought to crack down on those enjoying what some have seen as an excessively benign tax regime The taxation of ‘non-UK domiciled’ individuals has been a thorny political issue as successive governments have sought… – Continue reading
The implementation of place of effective management (POEM) rules in the current scenario in India could not only hurt the nation’s outbound investments, but also discourage overseas multinational companies from setting up their regional hubs here, feel industry watchers. The draft guidelines for implementing POEM, which was released on December… – Continue reading
FROM April 2017, there will be a new main residence transferable inheritance tax threshold which will apply when a main home is passed on to a direct descendant. A direct descendent broadly means a child or grandchild and includes adopted children, foster children and stepchildren. The inheritance tax threshold, officially… – Continue reading
European Union countries will have to introduce rules from 2017 to speed up tax refunds on cross-border investments, part of a drive to improve the working of financial markets and lift economic growth, according to an EU document seen by Reuters. The executive European Commission wants to simplify “withholding tax”… – Continue reading
In an effort to facilitate non-resident enterprises in applying for tax benefits, China’s tax bureau recently released the SAT Announcement [2015] No.60, which replaced the previous “Administrative Measures on Tax Treatment under Double Taxation Agreement to Non-resident Enterprises (Guoshuifa [2009] No.124)” and simplified the application procedures for a non-resident enterprise… – Continue reading
The American dream can turn into a nightmare for expats wanting to switch their UK pensions to a Qualifying Recognised Overseas Pension Scheme (QROPS). Thousands of expats cross the Atlantic both ways with London home to Americans in sectors such as finance, entertainment and media, while Florida is a popular… – Continue reading
On 1st January 2016, an amendment to the Mutual Legal Assistance (Tax Matters) Act, 2003 came into force which implements the Organisation for Economic Co-Operating and Development (OECD) Common Reporting Standard for the exchange of tax information (CRS) in the British Virgin Islands (BVI). Globally this means that participating jurisdictions… – Continue reading
The change in definition of an Indian resident company under the Income-Tax Act—from one whose affairs are wholly controlled and managed in India to one whose Place of Effective Management (PoEM) is in India—and the subsequent draft guidelines are giving anxious moments to votaries of simplifying the investment climate in… – Continue reading
Court of Appeal decision on tax residence provides more certainty In a case potentially impacting all New Zealanders who move overseas, the Court of Appeal has decided in favour of the taxpayer, finding that property which a person has never lived in nor intends to live in cannot be their… – Continue reading
Main principles of Indirect Taxation In our fifth article in a series of articles on the tax challenges of the digital economy, we shall be providing you hereunder with a brief overview of the principles of indirect taxation, with a focus primarily on the VAT and the destination principle applicable… – Continue reading
Treasurer Scott Morrison could rake in billions of dollars of extra revenue if property tax breaks were removed, according to a new think tank report. The federal government would gain $46 billion per year if the capital gains tax exemption on the primary residence was removed, according to The Australia… – Continue reading
Professional landlords are using Airbnb and other home-sharing websites to avoid taxes and evade planning laws, according to Ufi Ibrahim, chief executive of the British Hospitality Association (BHA) Ibrahim provided evidence to the Business Innovation and Skills committee this week, where he argued that home-sharing websites like Airbnb are made… – Continue reading
Americans living abroad feel that the Foreign Account Tax Compliance Act negatively impacts their professional lives and that compliance with the related tax reporting requirements is overly burdensome, a survey by Americans Abroad Global Foundation and the University of Nevada has found. But most survey respondents believe the U.S. government… – Continue reading
You may be aware that buying a second home or investing in a “buy to let property” is about to become more expensive. The Chancellor of the Exchequer announced in November 2015 the introduction of new higher SDLT rates of 3% above the current residential rates. The higher rates will… – Continue reading
Savills estate agent in Bristol is urging those considering selling in 2016 to put their property on the market sooner rather than later, to ensure a sale is completed before 1st April 2016. After this date, purchasers are likely to be liable for an increased level of stamp duty on… – Continue reading
On 10 December 2015 the remaining changes to the income tax and the capital gains tax laws aiming to improve the tax system of Cyprus and make it more attractive to both the local and international business community were voted. The changes came into effect with their publication in the… – Continue reading
Johannesburg – We can expect 2016 to be an interesting year for tax, with a new Finance Minister promising a focus on fiscal consolidation and several key pieces of tax legislation due to be enacted in the coming months. The volatility of the currency due to events that began in… – Continue reading
If the place of effective management of a foreign company is established in India, then it becomes tax resident as per domestic laws The Finance Act, 2015, amended the provisions of the provisions of income tax act relating to determination of residence of a company. According to the amended provisions,… – Continue reading
The financial regulator has launched a public consultation on plans to create alternative models for banking. Proposals being considered by the Financial Services Authority aim to address the decline in traditional offshore banking. Two additional banking licences are mooted – one for banks serving high net-worth individuals and corporate clients… – Continue reading
Adv. Amit Kriegel is suspected of abetting the super-model in evading taxes in Israel. Adv. Amit Kriegel, lawyer for global super-model Bar Refaeli and a former senior Israel Tax Authority official, was questioned under caution by the Tax Authority in the Bar Refaeli criminal investigation. Kriegel, a partner of former… – Continue reading
The Department of Justice announced today that Union Bancaire Privée, UBP SA (UBP), reached a resolution under the department’s Swiss Bank Program. UBP will pay a penalty of more than $187 million. “Today’s agreement marks the final resolution with UBP, which acknowledges its role in conspiring with U.S. taxpayers to… – Continue reading
On December 18, 2015, the President signed the Omnibus Appropriations Act (the “Act”) into law.1 Notably, the Act contains a number of substantive changes to the tax laws applicable to “real estate investment trusts” (“REITs”). Although several changes will adversely affect certain REITs, on balance REITs and their investors fared… – Continue reading
The international community led by the had initiated the (BEPS) project a few years ago with the aim of ensuring that profits are taxed where economic activities are performed and where value is created. Governments, and social groups have been voicing their concern over the past decade that multinational enterprises… – Continue reading
Official Irish statistics are being fattened up by massive tax inversions and the re-registering of companies, warns Dan White The ESRI estimates that the Irish economy grew by 6.7pc in 2015 and is forecasting GDP growth of 4.8pc for this year. GNP, which is generally regarded as a better measurement… – Continue reading
