HM Revenue and Customs (HMRC) has collected more than £4bn through its controversial ‘pay now, dispute later’ accelerated payment notices rules, for people who have used a tax avoidance scheme. HMRC said that more than 75,000 accelerated payment notices (APNs) have been issued to people under enquiry for tax avoidance...
Jakarta. Following Singapore’s willingness to cooperate with Indonesia’s tax authority, the government will move to create a bilateral tax agreement with the autonomous region of Macau “in a matter of days,” an official with the Directorate General of Taxes said on Thursday (13/07). “We just need to match our scheduling,”...
Andrew Howard, Ropes & Gray tax partner, discusses the UK’s new corporate criminal offence of failure to prevent tax evasion, which goes into effect in September 2017. Click here to view video. Transcript: The UK’s new corporate offence of failure to prevent facilitation of tax evasion is quite a mouthful,...
The Revenue received 24% more requests for assistance from overseas governments with probes into taxpayers from overseas jurisdictions last year A freedom of information (FOI) request from law firm Pinsent Masons found that a total of 2,015 requests had been made to HMRC last year, up from 1,619 in 2015....
Companies will have to disclose “uncertain” tax positions, including amounts disputed by the Australian Tax Office, under new accounting rules designed to increase information available to investors. Australia will adopt international accounting guidance with effect from 2019 that RSM Australia national technical director Ralph Martin said would result in some...
Global leader in cross-border information exchange for Tax Authorities has been selected by the Government of Bermuda, Ministry of Finance, Treaty Unit to meet Common Reporting Standards. Today, Vizor Ltd. announced the Government of Bermuda, Ministry of Finance, Treaty Unit has selected the Vizor for FATCA & AEOI Solution for...
Tax Administration Jamaica (TAJ) reported on Tuesday that local financial institutions required to report under the Foreign Account Tax Compliance Act (FATCA) are now 100 per cent compliant. FATCA is United States legislation designed to target US taxpayers holding accounts and assets outside that country and are non-compliant with US...
The Irish Revenue has this year recruited more than 100 additional staff to undertake audit and compliance activities. Prior to his retirement as Finance Minister, Michael Noonan was asked to provide parliament with information on the Revenue staff resources allocated to tax audit and investigation activities. Answering a written parliamentary...
‘Misleading media reports’ Ingenious Film has hit out at “misleading” press reports on its ongoing tax court case and criticised HM Revenue & Customs (HMRC) for painting its partnerships “as nothing more than tax avoidance vehicles”. The film production partnership firm has been in an ongoing court dispute with HM...
New Act due to come into force in September International risk and compliance firm Cordium has launched a solution to help advisory firms cope with the demands of the Criminal Finances Act, which will introduce stricter laws on tax evasion. The incoming law, which is expected to come into force...
The amount of disputed tax relating to the transfer pricing of the U.K.’s largest businesses has risen 60 percent in the past year, according to law firm Pinsent Masons. Her Majesty’s Revenue and Customs, the U.K.’s tax authority, is reviewing as much as 3.8 billion pounds ($4.9 billion) of large...
The first set of ‘hidden’ financial data about Britons living abroad is set to be handed to the UK’s Revenue & Customs later today, as part of the global transparency drive that has been introduced via a series of information sharing agreements across the world’s financial centres. As a result,...
Common Reporting Standard The Government of the British Virgin Islands (“BVI“) has recently announced an extension to the deadlines for the notification and reporting obligations under the Common Reporting Standard (“CRS“). Under the extended deadlines for CRS, all BVI Reporting Financial Institutions now have until 30 June 2017 to enrol...
The deadline for submitting automatic exchange of information (AEOI) returns for the year ended 31 December 2016 is 31 May 2017 for financial institutions, and that this is the first year for common reporting standards (CRS) filing Returns should include reportable accounts for the financial accounts tax compliance act (FATCA),...
About 21 staff of the Ghana Revenue Authority (GRA) have been interdicted for allegedly aiding some private companies to evade duties and taxes. Citi News understands that those interdicted were mostly from the customs division of GRA. Sources close to GRA also told Citi News that the case is currently...
About 21 staff of the Ghana Revenue Authority (GRA) have been interdicted for allegedly aiding some private companies to evade duties and taxes. Citi News understands that those interdicted were mostly from the customs division of GRA. Sources close to GRA also told Citi News that the case is currently...
The Common Reporting Standard (the CRS) is, like FACTA (the Foreign Account Tax Compliance Act), an information exchange regime aimed at realising international tax transparency. Exchange of information under CRS is achieved by requiring certain bodies including banks and other “Financial Institutions”, to collect data and report some of it...
The American Institute of CPAs has sent a list of six tax regulations to Treasury Secretary Steven Mnuchin that it wants the Treasury Department to review under an executive order from President Trump calling for reducing overly burdensome tax regulations. Trump signed an executive order last month on identifying such...
The U.K’s diverted profits tax was dubbed the ‘Google Tax’ even before its introduction in April 2015. Yet instead of netting foreign tech companies engaged in complex tax planning such as California-based Google Inc., only U.K. multinational companies outside the technology sector have issued warnings so far over the tax...
The Criminal Finance Act 2017 received Royal Assent on April 27, 2017, making its way onto the statute book before the halting of Parliamentary business ahead of this year’s general election. As well as giving enforcement agencies further powers to recover the proceeds of crime and tackle money laundering, the...
Norway’s Ministry of Finance has released a consultation on a proposal to further strengthen the nation’s restrictions on interest deductions within groups. The regime, introduced in 2014, is intended to prevent groups from establishing subsidiaries in lower tax territories from which to lend capital to companies in a higher tax...
Malta denies claims A data leak has revealed information about 70,000 offshore companies in Malta, a German state minister claimed this morning. North Rhine-Westphalia finance minister Norbert Walter-Borjans said the data also included information about several German corporations and up to 2,000 German taxpayers. Tax authorities in the city of...
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...
Four of the most significant transnational organizations are working together to eliminate transfer pricing schemes and abuses. The four organizations—the International Monetary Fund, the Organization for Economic Co-operation and Development, the United Nations and the World Bank Group—are seeking to achieve global cooperation in tax matters. Transfer pricing is one...
Finance Minister Euclid Tsakalotos on Monday stressed the need to combat tax evasion in order to increase tax revenues and reduce tax rates. Tsakalotos was addressing a conference of the Independent Public Revenues Authority on the dispute resolution and the protection of tax payers. The Finance Minister explained that the...
NEW DELHI: India’s apex body for direct taxes has proposed new rules for bringing the value of unquoted shares on a par with the fair market value of underlying assets, seeking to prevent tax avoidance by firms that use the historical acquisition cost to set the price of unlisted stock....
Days after it emerged that Italian tax agencies were pursuing online retail giant Amazon for taxes worth EUR130m (USD142m), it was revealed that Google will pay a EUR306m (USD335m) tax settlement. The payment relates to the tax periods between 2009 and 2015 and to an old dispute concerning tax years...
“The ball is in the Bahamas’ court” to meet its automatic tax information exchange commitments, a senior industry executive yesterday saying there is “no alarm” about this nation having to alter its approach. #Tanya McCartney, the Bahamas Financial Services Board’s (BFSB) chief executive, told Tribune Business that the private sector...
KARACHI: The Federal Board of Revenue (FBR) has initiated audit of all those taxpayers who have made offshore transactions during the last six years, sources said on Tuesday. “All corporate and individual taxpayers, who have made offshore investments, have been selected for audit to check the tax concealment,” an official...
A high percentage of UK executives are unaware of the impending introduction of new laws which could make a business’s failure to prevent tax evasion by its employees and agents a criminal offence, according to research by Pinsent Masons, the law firm behind Out-Law.com. In a YouGov poll of more...
A newly published federal draft law introduces Russia to a three-tiered approach to transfer pricing documentation and brings Russian regulations in this area in line with the OECD minimum standards under Action 13 of the Base Erosion and Profit Shifting (BEPS) Action Plan. The draft law, published by the Ministry...
New transfer pricing regulations issued by the State Administration of Taxation (SAT), the Measures for Administration of Special Tax Investigation Adjustment and Mutual Agreement Procedures (“the Measures”), came into effect on May 1, 2017. The Measures consolidate China’s pre-existing regulations regarding self-adjustment and outbound payments with the new transfer pricing...
(Second of two parts) In last week’s article, we discussed the revised procedure to avail of tax treaty benefits for dividend, interest, and royalty payments under Revenue Memorandum Order (RMO) No. 8-2017. Under the amended rules, a tax treaty relief application (TTRA) is no longer required and withholding agents can...
It often occurs that a multinational company employs a foreign manager based on an employment contract or secondment. In the first case, the Hungarian company is considered as the legal and economic employer, therefore the salary is payed directly by it. In the second case, the employee maintains the employment...
Witnesses call for repeal of Foreign Account Tax Compliance Act An agreement that has resulted in hundreds of thousands of Canadian banking records being sent to the U.S. Internal Revenue Service could violate the U.S. constitution, a congressional subcommittee heard Wednesday. Testifying before a subcommittee of the House Committee on...
The Federal Inland Revenue Service (FIRS) and the Economic and Financial Crimes Commission (EFCC) are putting a new breath to the fight against tax fraud and evasion in Nigeria, as the two agencies will soon launch an anti-tax fraud and evasion team. This collaboration, according to the FIRS Executive Chairman,...
Newcastle managing director Lee Charnley released after HMRC investigation Offices at St James’ Park and club training ground raided by tax authorities The offices of Newcastle United and West Ham United were raided on Wednesday morning and Chelsea confirmed they were asked to provide information as part of a wide-ranging...
Many of the data submissions made by early adopters over the next two months under the new common reporting standard (CRS) are likely to be rejected and returned for correction and resubmission, adding to compliance costs, according to predictions from Sovos, a global tax compliance solution provider The UK is...
Indian tax authorities have initiated a $4.75 billion penalty charge against Cairn Energy for failing to pay a capital gains tax demand of $1.58 billion on a 2006 transaction. Under Section 271(1)(c) of the Income Tax Act, Indian tax authorities can levy a maximum 200 percent penalty against transactions after...
Tax residency certificate is required from the resident country tax authorities to claim applicable relief under the DTAA What is the purpose of a tax residency certificate? —Srivats Typically, source of income lies where the services are performed, or where the asset, from which the income arises, is located. Residential...
The Thai Revenue Department announced earlier this month that new legislation effective from April 2 increases penalties for those taxpayers committing tax fraud or evading their tax liability. In a statement accompanying the enactment of the Revenue Code Amendment Act (No.45) B.E. 2560, the Department revealed that such fraudulent activity...
The German Ministry of Finance has published a progress report on its 10-point plan to combat tax evasion, which was first announced in the wake of last year’s Panama Papers leak. The plan, launched on April 12, 2016, outlines the measures that Germany wants to put in place at domestic...
KUALA LUMPUR: The Inland Revenue Board (IRB) plans to increase its penalty to 100% for individuals and companies who evade paying their taxes or misreported tax. IRB chief executive officer Datuk Sabin Samitah said the new penalty scheme, an increase from the current 45% penalty imposed on unpaid tax, will...
As a rule and according to Article 33 of the Cyprus Income Tax Law, which introduces the arm’s length principle (using wording similar to that of article 9 of the OECD Model Tax Convention), all transactions between companies, including loan agreements/transactions by Cyprus companies, must be undertaken at arm’s length...
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...
HMRC is to renew and extend the scope of the double taxation treaty passport (DTTP) scheme, which will now be available to all UK borrowers who are required to withhold income tax at the basic rate on certain loan interest payments to overseas lenders from 6 April 2017 The DTTP...
China’s new transfer pricing rules, effective May 1, endorse the continued use of the arm’s-length standard—the internationally agreed bedrock for pricing transactions within multinational enterprises. The new guidance, Bulletin 6, augurs well for resolving tax disputes between China’s State Administration of Taxation and the U.S. Internal Revenue Service over the...
Ukraine has ruled out major tax reform, in consultations with the International Monetary Fund. The IMF noted that Ukraine has major substantial progress on improving its finances. The IMF said budget execution continues to be strong, over-performing relative to program targets. The 2016 budget deficit has been limited to 2.3...
HMRC has launched a new hotline for the public to report fraud and evasion, replacing the existing two separate tax evasion and customs hotlines with one, in a bid to streamline information gathering on tax fraud. Individuals can report all kinds of tax fraud and evasion on the new hotline,...
Dedicated technical experts from the UK’s HM Revenue & Customs (HMRC) will visit all English Premier League, Championship and Scottish Premier League clubs over a three year period and review all compliance risks including payments to players, the government has said. The statement was made in Treasury Minutes containing the...
