Category: Tax Authority

UK Offshore tax evaders face much higher penalties for non-compliance under new HM Revenue and Customs rules

UK Offshore tax evaders face much higher penalties for non-compliance under new HM Revenue and Customs rules. The legislation requires those with undeclared offshore tax liabilities to disclose them to HMRC before the 30th of September next year. When the Right to Correct rules come into force, offenders can expect...

Hapoalim Canadian customers say bank aided tax evasion

114 taxpayers in Canada’s voluntary disclosure program say that the Israeli bank helped them evade taxes. As if the headache of the investigation by US authorities were not enough, Bank Hapoalim (TASE: POLI), managed by CEO Arik Pinto, discovered two days ago that Canada was also taking aim at it....

Japan’s National Tax Agency releases guidance on requesting Mutual Agreement Procedure assistance

The Japanese National Tax Agency (NTA) has released guidance for taxpayers on the mutual agreement procedure (MAP), in line with the recommendations of the OECD’s Base erosion and profit shifting (BEPS) Action 14 Final Report. The guidance is intended to supplement the Commissioner’s Directive on the Mutual Agreement Procedures, which...

EU to investigate UK tax loophole for multinationals

Inquiry to centre on George Osborne’s 2013 rule change that allows resident multinationals to shift income offshore The EU is to launch an investigation into a British government scheme that may help multinational firms pay less tax, the Guardian has learned. Margrethe Vestager, the EU competition commissioner, will announce on...

Warning bells till Christmas for foreign account holders

MUMBAI: Since last month, Indians with overseas bank accounts are receiving letters from offshore financial institutions, asking them to disclose ‘tax residency status’ before Christmas. If they don’t, banks holding these accounts would share whatever information they have on such account holders with the Indian government. Many account holders are...

ATO’s tax gap figures revealed: $2.5 billion missing from corporates, multinationals

An estimated $3.5 billion in revenue from large corporates and multinationals is at risk to the economy, but through audit activity this will reduce to $2.5 billion, according to the Australian Taxation Office. On Wednesday the agency is releasing the first tranche of its long-awaited highly anticipated “tax gap” figures,...

New Private Tax Ruling Clarifies the Conditions for New Immigrants to Obtain an Israeli Residency Certificate

Under Israeli tax law, New Immigrants are entitled to various tax benefits, including an exemption from taxation with respect to non-Israeli sourced income. Due to these benefits, many taxpayers have argued that since they immigrated to Israel, they are entitled to Israeli tax residency certificate, even though they have not...

Indian Authorities Sign Two New APAs

India’s Central Board of Direct Taxes (CBDT) on October 6 announced that it entered into two unilateral Advance Pricing Agreements (APAs) in September. The new APAs bring the number of such agreements signed to date to 177, comprising 164 unilateral APAs and 13 bilateral APAs. During the current financial year,...

Will the new corporate offence of failure to prevent tax evasion and enhanced international tax transparency change the landscape for tax investigations?

The 30 September 2017 is an important date for HMRC and its “relentless” clampdown on global tax evasion. First, it marks the coming into force of the landmark corporate offence of failure to prevent tax evasion under Part 3 of the Criminal Finances Act 2017. Secondly, it is the commencement...

Daily Tax Update – September 25, 2017: IRS Issues FATCA Taxpayer Identification Number Guidance

IRS Issues FATCA Taxpayer Identification Number Guidance: Today, the IRS issued Notice 2017-46, which modifies the requirements for financial institutions to collect taxpayer identification numbers (TINs) as part of the Foreign Account Tax Compliance Act (FATCA). The notice provides that foreign financial institutions (FFIs) required to report TINs for US...

VAIDS: The Tax Game Changer

A seismic change began in the country’s tax system on 29 June, when an Executive Order signed by Vice President Yemi Osinbajo (then Acting President) gave life to the Voluntary Assets and Income Declaration Scheme (VAIDS). The scheme provides a platform for tax defaulters to regularize their tax statuses and...

Solicitors face scrutiny over tax planning advice

Solicitors providing tax planning services could face greater scrutiny from the Solicitors Regulatory Authority (SRA) and HMRC as government begins to clamp down on aggressive tax avoidance schemes The SRA has expressed its concerns that avoidance schemes previously deemed legitimate may no longer be accepted by HMRC. Solicitors and firms...

Interpreting double tax treaties in light of the BEPS multilateral instrument

Some double tax treaties are being amended by a multilateral instrument Establishing how a particular treaty is affected can be a complicated process The UK intends to publish amended DTTs and this will help, but the MLI has added an additional layer of complexity 18 Sep 2017 Speed Read LEGAL...

The Finnish Supreme Administrative Court confirms that the business model chosen by parties must be respected in transfer pricing context

The Finnish Supreme Administrative Court published on 13 September 2017 precedent 2017:145 that further clarifies the scope of application of the Finnish transfer pricing adjustment provision (Act on Assessment Procedure (“AAP”) Section 31). In its previous landmark precedent KHO 2014:119 the Supreme Administrative Court stated that the so-called re-characterization of...

US Hearing On Improving IRS Appeals Process

On September 13, the US Ways and Means Oversight Subcommittee launched a hearing on improving the resolution process for taxpayer disputes and appeals with the Internal Revenue Service. The hearing is said to be the fourth in a series of attempts to reform and improve the IRS appeals process. “In...

Tax evaders set to face action: CBDT chairman Sushil Chandra

CBDT chairman Sushil Chandra says income tax dept will soon conclude probe into financial dealings of about 100,000 individuals suspected of tax evasion New Delhi: The income tax department will conclude its investigations into the financial dealings of about 100,000 individuals suspected of tax evasion and persuade many other assessees...

Tax Avoidance Firm Loses ‘HMRC Approved’ Ad Challenge

A ruling from advertising watchdogs that carrying the HM Revenue & Customs on advertising materials is misleading leaves the way open for government departments to challenge firms over misleading consumers. The Advertising Standards Authority (ASA) investigated a web site and leaflet published by tax and wealth advisors Knight Wolffe after...

SARS to crack down on multinational companies and subsidiaries’ tax returns

MEDIUM and large businesses with multinational ties will soon have to start supplying the South African Revenue Service (SARS) with more detailed reports of their relationships and transactions with connected entities residing in other countries. SARS has beefed up its Transfer Pricing Division and is now actively involved in the...