Category: Tax Authority

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… – Continue reading

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… – Continue reading

Google loses 6 year battle, must pay tax on remittances made to Google Ireland

Bad news for the world’s favourite search engine. On Tuesday, the Indian tax office gained an upper hand in its six-year-long battle with Google India in a ruling that would set a precedence for some of the other multinational companies. The rift owes its origin to the arrangement and fund… – Continue reading

Football tours operator banned over tax avoidance

Kenneth Moyes, brother of Manchester United’s former manager David Moyes, has been disqualified as director for five years after the Insolvency Service found he withdrew cash from his company to avoid paying tax Moyes was the owner of Glasgow-based Professional Pre Season Tours, which was involved in arranging pre-season tours… – Continue reading

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… – Continue reading

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,… – Continue reading

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… – Continue reading

Russian Tax Service approves British Virgin Islands’ removal from offshore list

The Federal Tax Service (FTS) removes the British Virgin Islands (BVI) from the black list of ‘tax havens’. This change will affect the interests of Russian owners of the local companies. Leaving BVI for another offshore may help them keep their secrets, but not forever. Removal of the BVI from… – Continue reading

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… – Continue reading

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… – Continue reading

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… – Continue reading

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… – Continue reading

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… – Continue reading

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… – Continue reading

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… – Continue reading

Partnership tax rules overhaul by 2018

Changes to partnership taxation are to go ahead with draft legislation now published, effectively clarifying the tax treatment for partnerships to ensure that the principle of taxing the beneficiary of partnership profit applies and to prevent a double reporting burden on investment partnership This measure makes changes to the income… – Continue reading

I-T steps up drive against cash abroad; charges fixed against 5 businessmen

Dept starts prosecution against 5 people with Rs 5k cr of unaccounted wealth in British Virgin Islands. The income-tax (I-T) department has established charges against five persons with unaccounted foreign assets of Rs 5,000 crore in the British Virgin Islands (BVI), a Caribbean tax haven. Investigations are on in more… – Continue reading

Panama: Panama Tax Treaties

The Panamanian Government with the aim of improving the competitiveness of the international services industry in Panama and, at the same time, comply with international standards for the effective exchange of information, initiated in 2009 a decisive agenda for the selection of countries with whom tax agreements were going to… – Continue reading

India slaps tax demand on Hutchison for Vodafone deal

India’s income-tax department has raised a tax demand for Hutchison’s capital gains during its sale of India mobile business to Vodafone in 2007 India’s income-tax department has now trained its guns on Hong Kong-based Hutchison Telecommunications International Ltd (HTIL) in connection with its alleged capital gains during the US$ 11-billion… – Continue reading

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… – Continue reading

Singapore sees tax revenue up 5 pct in 2016/17 financial year

SINGAPORE, Aug. 24 (Xinhua) — The Inland Revenue Authority of Singapore (IRAS) publicized its annual report on Thursday, showing it collected 47 billion Singapore dollars (about 34.53 billion U.S. dollars) in tax revenue in Financial Year 2016/17, up 5 percent from the past financial year. IRAS attributes the revenue collection… – Continue reading

African tax authorities consider how to boost revenue

African nations will have more resources at their disposal to meet the Sustainable Development Goals if their national revenue authorities can boost tax collection. The United Nations Economic Commission for Africa estimates that the continent loses more than $50 billion through illicit financial outflows per year, much of this linked… – Continue reading

IRD moves to audit maximum 25,000 income tax files to detect evasion

The Internal Resources Division (IRD) has issued a directive to audit maximum 25,000 income tax files of both individuals and corporate taxpayers to detect tax evasion and concealment of actual income, officials said. The income tax authority has received the directive from the IRD not to exceed this number of… – Continue reading

Indian authorities investigate Amitabh Bachchan’s name in Panama Papers

Indian income tax department started probe into Amitabh Bachchan’s overseas transactions in the light of his name in Panama Papers. The I-T department sent officer to the British Virgin Islands in order to collect his financial information. The authorities received criticism for lack of action against the Bollywood actor after… – Continue reading

Mexico: New Substance-Over-Form Litigation Procedures In Mexico

Mexico has introduced new substance-over-form procedures that change the country’s formal approach into one more compliant with the BEPS Project. Taxpayers should take note of these developments as they may impact tax disputes, writes Bernardo Ramírez and Valentín Ibarra of Chevez, Ruiz, Zamarripa y Cía. Resulting from a G20 world… – Continue reading

UK Issues Guidance On Preparing CbC Reports

The UK tax authority, HM Revenue and Customs (HMRC), has issued guidance for businesses on the preparation of country-by-country reports in the required format. The CbC report is one element of a new three-tiered standardized approach to transfer pricing documentation proposed under Action 13 of the OECD’s base erosion and… – Continue reading

Jersey property companies lose tax residence case

INTRODUCTION HMRC have successfully challenged the offshore residence of Jersey companies holding UK real estate. In the case of Development Securities, the First Tier Tribunal held that Jersey companies set up to hold UK real estate were resident in the UK for tax purposes. This case serves as a timely… – Continue reading