Category: Tax Relief

Luxembourg: Luxembourg Government Submits Bill To Parliament Implementing The EU Anti-Tax Avoidance Directive 2 Into Domestic Law

Luxembourg corporate income taxpayers, including Luxembourg permanent establishments of foreign entities, will be subject to the Draft Law as from 1 January 2020. In addition, provisions targeting reverse hybrid mismatches will be applicable to Luxembourg transparent partnerships that would be treated as opaque by their nonresident owners as from 1 January 2022. ... - Continue reading

Tax Incentive Bill Clashes With Property Tax Relief In Legislature

A proposal for new corporate tax incentives butted heads with a desire for property tax relief in the Legislature Wednesday. Nebraska’s current corporate tax incentives, the so-called Nebraska Advantage program, expires next year. So Sen. Mark Kolterman said it’s important to put a new program in place. “The time is… – Continue reading

Low Paid Don’t Need Pension Tax Breaks, Claims Think-Tank

Don’t give pension saving tax breaks to the poor – they can’t afford to take advantage of them, says an international think-tank that comes up with financial policy for governments. Instead of wasting the retirement incentives on the poor, they should be aimed at high earners who struggle to save… – Continue reading

Switzerland: Revised Swiss Corporate Tax Reform Will Keep Switzerland A Top Corporate Location

I. The background of the tax reform In connection with the international pressure on the Swiss corporate tax location, especially in relation to the Cantonal exemption of income for holding companies as well as the status privileged companies (“status privilege”) and the need of Switzerland to recover global recognition as… – Continue reading

Canada’s Trudeau Announces $10.5-Billion Fiscal Stimulus to Compete With US

The cabinet of Canadian Prime Minister Justin Trudeau is set to implement tax cuts for the nation’s businesses, which, along with the announced plans to reduce regulation, are highly reminiscent of the economic policies of Canada’s southern neighbour. Kristian Rouz — Canadian Prime Minister Justin Trudeau has unveiled an ambitious… – Continue reading

Has the New Inland Revenue Act paralysed the Double Tax Treaty Network of Sri Lanka? Part 2

7.What are Mutual Administrative Assistance Agreement (MAAAs) The new IRA defines the “Mutual Administrative Assistance Agreement” to mean a tax information exchange agreement or other international agreement for mutual administrative assistance in relation to taxation matters. Section 75 (5) of new IRA “Mutual administrative assistance agreement” means a tax information… – Continue reading

Has the New Inland Revenue Act paralysed the Double Tax Treaty Network of Sri Lanka? Part 1

1.Introduction Due to the influence of International Monetary Fund, the income tax law of Sri Lanka witnessed a near paradigm shift with the introduction of Inland Revenue Act No.24 of 2017 (new IRA) by repealing Inland Revenue Act No.10 of 2006 with effect from 1 April 2018. Unlike the Inland… – Continue reading

Transfer pricing disputes: Interest payout relief coming for MNCs

CBDT issues draft notification on interest computation NEW DELHI, JUNE 20 The Central Board of Direct Taxes (CBDT) proposes to provide a relief to MNCs on the interest payable by them on the untaxed profits stashed abroad, requiring to be repatriated back to India under the transfer pricing regime. It… – Continue reading

Irish Corporate Tax Reform Pushed By MPs, To Shore Up Tax Base

The highly concentrated nature of Ireland’s corporation tax receipts represents “an unacceptable level of risk,” according to parliament’s Public Accounts Committee. The PAC has published a new report on Ireland’s corporation tax receipts. Corporation tax accounted for 15 percent of total tax receipts in 2016, with 70 percent of all… – Continue reading

Surveys Suggest Taxpayers Satisfied With TCJA, Says Hatch

Both large and small businesses in the United States expect the measures included in the recently enacted tax reform legislation, the Tax Cuts and Jobs Act of 2017, to have a positive effect on their operations, according to Senate Finance Committee Chairman Orrin Hatch (R-UT). In a recent statement, Hatch… – Continue reading

SMEs are paying more corporation tax than bigger businesses

According to figures released earlier this year, SMEs are in fact paying more corporation tax than larger more complex organisations. Specifically, the rate paid by SMEs in 2016 was 21.7%, while it was 20% for businesses with a turnover of £1billion. The research was conducted by accountancy firm Moore Stephens,… – Continue reading

Roskam bills to protect taxpayers from unjust seizures clears House as part of IRS revamp package

Legislation led by U.S. Rep. Peter Roskam (R-IL) to reform Internal Revenue Service (IRS) civil asset forfeiture tools and his other priorities to protect taxpayers cleared the U.S. House last week as part of a larger IRS modernization initiative. The House on April 18 passed the Taxpayer First Act, H.R…. – Continue reading

Opportunity Zone Program turns blight sites into tax havens for asset-rich investors

The rich are getting richer in America but that prosperity is not trickling down the economic food chain, with investment capital pooling up in thriving portions of big cities. One reason for this, experts believe, is the amount of wealth tied up in assets—real estate holdings and stock portfolios, primarily—that… – Continue reading

Professional Fee paid by Deloitte India to Its US and Singapore Entities Not Taxable in India, No TDS: ITAT [Read Order]

Granting tax relief to Deloitte India, the Mumbai bench of the Income Tax Appellate Tribunal (ITAT) held that the provisions relating to Tax deduction at Source (TDS) are not applicable to the professional fee paid by them to its Group Entities in US and Singapore. The division bench of the… – Continue reading

Hong Kong and India enter into tax pact

Hong Kong (HKSAR) – The Financial Secretary, Mr Paul Chan, on behalf of the Government of the Hong Kong Special Administrative Region, signed in Hong Kong today (March 19) a comprehensive agreement for the avoidance of double taxation (CDTA) with the Ambassador of India to China, Mr Gautam Bambawale, signifying… – Continue reading

Tax advice under scrutiny: Halsall v Champion Consulting

Introduction As the government continues to grapple with a budget deficit and strained public finances, there remains considerable pressure on HMRC to crack-down not only on tax evasion, which is illegal, but tax avoidance, which HMRC refers to as “bending the rules of the tax system to gain a tax… – Continue reading

Capital Markets Union: Commission announces new tax guidelines to make life easier for cross-border investors

The Commission has today put forward new guidelines on withholding taxes to help Member States reduce costs and simplify procedures for cross-border investors in the EU. The new Code of Conduct offers solutions for investors who, as a result of how withholding taxes are applied, end up paying taxes twice… – Continue reading

India to accept mutual agreement process in transfer pricing cases

NEW DELHI The Indian Income Tax Department will accept applications for Mutual Agreement Procedure (MAP) in transfer pricing disputes, as well as for bilateral Advance Pricing Agreements (APAs), even for entities resident in countries with which India has double taxation avoidance agreements (DTAA), minus the provision to claim corresponding tax… – Continue reading

IRS offers tax relief to hurricane victims in Puerto Rico and Virgin Islands

The Internal Revenue Service released guidance Wednesday to give tax relief to residents of Puerto Rico and the U.S. Virgin Islands who have evacuated the islands or were unable to return because of Hurricanes Irma or Maria. The relief extends the typical 14-day absence period to 117 days (starting Sept…. – Continue reading

Briefing: Proper plan design is way forward

International pension plans involve complex questions of structuring and compliance International Pension Plans (IPPs) are pension plans sponsored and funded by an employer, for employees assigned to work outside their home country, who are expected to receive IPP benefits while they are resident in their home country, or in another… – Continue reading

Government set to crack down on tax perks for well-off investors

Popular investment schemes offering generous tax breaks for wealthier investors are likely to face new restrictions. The Treasury is mulling a crackdown on Enterprise Investment Schemes, likely to be announced in the next Budget on November 22. The scheme allows people to invest in start-ups, either directly or through funds,… – Continue reading

Individual Income Tax in Malaysia for Expatriates

Malaysia uses both progressive and flat rates for personal income tax, depending on an individual’s duration and type of work in the country. As expatriates may fall into either tax category depending on their work, it is important to understand Malaysia’s basic tax structure. The Income Tax Act of 1967… – Continue reading

Tax treaty relief made easy

(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… – Continue reading

FAST FACTS: Avoiding double taxation for nonresidents

The Philippines is currently a signatory to 41 tax treaties that address double taxation situations. MANILA, Philippines – According to Philippine law, nonresidents with income sources in the Philippines are required to file taxes. For these individuals who reside in a different country but receive income from the Philippines, double… – Continue reading

Canada: Report On The Voluntary Disclosures Program (VDP) – Canadian Tax Consultant Analysis

The Offshore Compliance Advisory Committee issued a report in December 2016 to the Canada Revenue Agency about the Voluntary Disclosures Program (VDP or tax amnesty). If a taxpayer submits a successful income tax or GST/HST voluntary disclosure program application then generally criminal income tax prosecution and civil tax penalties under… – Continue reading

2017 Budget Law: tax relief for individuals who decide to fix their tax residence in Italy

The 2017 Italian Budget Law introduces a tax relief for individuals transferring their tax residence to Italy, in accordance with similar regimes adopted by other countries such as the United Kingdom, Switzerland and Portugal. The relief is part of a package of measures intended to facilitate investment in Italy and… – Continue reading

Film industry tax avoiders face multi-million pound bill

Investors in a financing scheme aimed at helping the UK film industry are being asked to repay “multiple millions of pounds” following a court ruling. HMRC is pursuing investors in the Eclipse scheme, including celebrities, financiers and sports stars, for up to 20 times their original investment. Courts ruled that… – Continue reading

Facebook pays just £4million in tax while lavishing British staff with £165MILLION

Accounts show each of the firm’s 682 workers took home average of £242,000 each in 2015 Facebook lavished £165million on its UK staff last year, while handing the taxpayer just £4million. Accounts show each of the firm’s 682 workers took home average of £242,000 each in 2015. The bumper payout… – Continue reading

Wales to switch to Land Transaction Tax

Wales is to replace stamp duty with a land transaction tax as it moves towards devolved tax collection. The new tax on land transactions will be introduced from April 2018 alongside measures to tackle devolved tax avoidance, the Welsh government said. Land transaction tax is paid on the purchase or… – Continue reading

Cabinet approves signing of revised DTAA with Cyprus

The Union Cabinet on Wednesday gave its nod for signing of revised double taxation avoidance agreement (DTAA) with Cyprus, a popular tax haven. It is also learnt to have approved the removal of island nation as a non-cooperative jurisdiction for income-tax purpose. Cyprus was the only country to have been… – Continue reading

ATO Issues Anti-Avoidance Warnings For Multinationals

The Australian Taxation Office (ATO) has issued a series of taxpayer alerts that caution large companies against using contrived arrangements to avoid their tax obligations. The first alert concerns arrangements where Australian consolidated groups use offshore permanent establishments that have entered into intra-group transactions. Deputy Commissioner Jeremy Hirschhorn explained: “Through… – Continue reading

Brexit Risks Losing Corporate Tax Break Worth Billions in U.K.

British multinational companies face new withholding taxes that may cost hundreds of billions of euros a year if U.K. voters decide to leave the European Union, international tax specialists say. A so-called Brexit “would have a major impact” on British corporations that have subsidiaries in the EU, said Daniel Gutmann,… – Continue reading

HMRC to ‘bear down’ on tax planning in updated vision

A CLAMPDOWN on tax planning, a transformation of its services for taxpayers and delivering a professional, efficient and engaged organisation are the three key objectives for HMRC in its updated single departmental plan. The government department has outlined its main visions and objectives for the period between 2015 and 2020,… – Continue reading

EU finance ministers fail to agree on anti tax avoidance directive

The EU’s Economic and Financial Affairs Council (ECOFIN) has been unable to reach agreement on the European Commission’s proposed anti tax avoidance directive. The issue has therefore been postponed until the next ECOFIN meeting in June. The European Commission announced its proposed anti-tax avoidance directive (ATAD) in January. The proposed… – Continue reading