Category: Double Taxation

Switzerland: TAX NEWS: Swiss Voters Reject Introduction Of Swiss Federal Inheritance Tax – Current Cantonal Inheritance And Gift Tax System Remains Unchanged

After a controversial political debate, the Swiss voters have decided to reject the popular initiative to introduce a federal inheritance tax with a vast majority of 71.7% in the popular vote of 14 June 2015.. The 26 Cantons also unanimously rejected the the popular initiative. The clear result shows that… – Continue reading

U.S. Treasury attempts to influence OECD’s BEPS initiative via proposed changes to U.S. model treaty

The United States has been criticized on more than one occasion for failing to be a meaningful participant in the OECD’s multi-pronged initiative to address base erosion and profit shifting (BEPS). Some commentators have even gone so far as to accuse the United States of actively working against the BEPS… – Continue reading

Jaitley assures US investors of a stable policy regime

Washington, June 21 (IANS): Indian Finance Minister Arun Jaitley is wooing American investors with twin assurances — more economic reforms and a stable policy regime with no intention to legislate or apply laws retrospectively. Jaitley has held talks with US Treasury Secretary Jacob Lew, Commerce Secretary Penny Pritzker and US… – Continue reading

Mauritius to act against black money: Finance Minister Seetanah Lutchmeenaraidoo

NEW DELHI: Mauritius has offered to put in place stringent conditions for investors seeking benefits under its tax treaty with India to weed out post-box operations, addressing a key concern of New Delhi that has been attempting to amend the agreement for years. “We don’t want investors to open shell… – Continue reading

Mauritius assures India will not allow shell companies

Lutchmeenaraidoo, who met foreign minister Sushma Swaraj, played down the issue of misuse of the India- Mauritius Double Taxation Avoidance Convention (DTAC). Mauritius will make it difficult for shell companies using a liberal and controversial bilateral tax treaty with New Delhi to evade taxes in India, said the island nation’s… – Continue reading

European Union Blacklists Panama as Tax Haven

The European Commission has added Panama to its blacklist of countries designated as tax havens over a lack of support for anti-tax fraud and evasion efforts. The European Union’s executive Commission unveiled the list in the introduction to its action plan to fight tax fraud. The blacklist consists of 30… – Continue reading

Cyprus: The New Cyprus-Iceland Double Taxation Agreement

With less than seven weeks between signature on 13 November 2014 and entry into force on 22 December, the new DTA between Cyprus and Iceland set a new standard for timeliness. Like most of Cyprus’s recent double taxation agreements, the DTA closely follows the form of the 2010 OECD Model… – Continue reading

Global net closes on tax dodgers

International tax rules will soon change, but companies’ behaviour may change sooner. There will soon be fewer places for multinational companies and ultra-rich individuals to squirrel away money. In November leaders of the G20 are expected to adopt a full range of measures to curb the practices of base erosion… – Continue reading

Cyprus: The Potential Impact Of Russian De-Offshorization Legislation On Cyprus Holding And Finance Structures

Abstract Over the past 25 years, Cyprus has become the portal of choice for investment into and out of Russia and Central and Eastern Europe. The new Russian de-offshorization law, which took effect on 1 January 2015, will have significant implications for users of overseas structures. This article examines the… – Continue reading

‘Surprise’ at Guernsey inclusion on EU ‘non-cooperative’ blacklist

Guernsey’s Chief Minister and Commerce and Employment Minister have expressed their astonishment that Guernsey has been included on a list of 30 so-called ‘non-cooperative’ non-EU jurisdictions, which was published today, reports Guernsey Finance. The list consolidates national tax ‘blacklists’ as they stood six months ago, and includes any jurisdiction on… – Continue reading

Allegation of Hong Kong as non-cooperative tax jurisdiction totally unfounded

Hong Kong (HKSAR) – The Hong Kong Special Administrative Region Government today (June 18) expressed regret over the inclusion of Hong Kong in the list of non-cooperative tax jurisdictions published by the European Commission. “Hong Kong has all along been supportive of international efforts to enhance tax transparency and combat… – Continue reading

New tax treaty with Mauritius may affect cross-border investment

THE new double-tax treaty between SA and Mauritius is set to come into force in January next year, following a controversial renegotiation to better protect the South African tax base. However, tax experts have warned that sweeping changes to the treaty, including withholding taxes for interest (10%) and royalties (5%)… – Continue reading

Australia, Germany in tax talks

AUSTRALIA and Germany are starting negotiations to update a tax treaty between the two countries that stretches back 40 years. TREASURER Joe Hockey says the discussions will focus on maximising the efficiency of the trade and investment relationship with the world’s fourth largest economy and Australia’s tenth largest trading partner… – Continue reading

FactCheck: Christie’s tax dodge

He has distorted the facts about the nation’s current tax system. Chris Christie repeatedly has said that U.S. corporations are taxed twice on income earned abroad, claiming in one speech that IRS officials “don’t recognize the tax you paid to a foreign country.” That’s false. It’s true that the U.S…. – Continue reading

Russian Federation: Russian De-Offshorisation Legislation And Voluntary Disclosure: Which Way Now?

The new law on the taxation of controlled foreign companies (the ‘CFC’ law) and other anti-offshore measures effective as of 1 January 2015 have raised a number of questions for clients and advisers. A number of changes to the new laws were long anticipated and have now been passed by… – Continue reading

Bermuda: Minister Richards examines global tax threats

Speaking at the Insurance Day 2015 Summit on 10 June 2015, Minister of Finance Bob Richards told attendees that “the more we drive home that the insurance sector in Bermuda is not a stereotypical tax haven gimmick to key onshore decision makers the less the threat from IRS and other… – Continue reading

G7 to Clamp Down on Tax Avoidance Via Transfer Pricing

Multinational firms said to be ‘cheating’ African countries out of billions of dollars that could be used for health care and education. G7 leaders Monday pledged to reform the international tax system by minimizing transfer pricing, according to Public Finance International. Transfer pricing involves internal transactions between a large company’s… – Continue reading

Update: key ruling affecting Maryland taxpayers with out-of-state income – tax refund opportunity now available

Maryland residents who pay income tax to other states may be entitled to a refund of local income taxes paid in prior tax years. The U.S. Supreme Court in Comptroller of the Treasury of Maryland v. Wynne et ux. recently affirmed a Maryland Court of Appeals ruling that the state’s… – Continue reading

G7 leaders move toward automatic exchange of tax information

Heads of state meeting at the G7 Summit in Bavaria, Germany committed to promoting automatic exchange of tax information and tax rulings to discourage multinational companies from shifting profits from country to country to avoid taxes, reports Accounting Today. In a joint declaration, the G7 leaders reaffirmed their commitment to… – Continue reading

Hong Kong needs to catch up with latest global tax standards

Hong Kong, as a world financial centre, will undertake legislative changes to implement automatic exchange of information of account holders Exchange of information is a recognised tool to enhance tax transparency and combat cross-border tax evasion. As a major financial centre, Hong Kong is committed to following global standards. While… – Continue reading

Recent Tax Treaty Developments In Cyprus

Proposed Amendments To Cyprus’s Assessment And Collection Of Taxes Law The Cyprus Government has published a draft law amending the Assessment and Collection of Taxes Law (Law 4 of 1978) in order to facilitate implementation of agreements for automatic exchange of information with other countries. When it is enacted, the… – Continue reading

Tax consequences of foreign companies rendering services in South Africa

Where a foreign company renders professional services to a South African company, it is important that the foreign entity considers whether, as a result of rendering such services, the foreign company will create a permanent establishment in South Africa. The reason why this becomes important is that where a foreign… – Continue reading

Govt aims at documentation of economy

ISLAMABAD: The government has proposed several provisions in the Finance Bill 2015 for documentation of economy. The bill empowers the government to obtain or render information related to transactions undertaken in and outside Pakistan regarding both resident and non-resident taxpayers. Legal cover has been provided to allow government to enter… – Continue reading

The New Rules of Offshore Accounts

Crucial deadlines are approaching for millions of U.S. taxpayers who live abroad or have offshore financial ties. For expatriates, the annual income-tax filing deadline is normally June 15, instead of April 15. In addition, all U.S. taxpayers with offshore accounts totaling more than $10,000 in 2014–regardless of where they live–have… – Continue reading

London based Investment Association, ASIFMA seeks to be party in Castleton case over MAT

MUMBAI: Two associations representing foreign portfolio investors are seeking to join the battle over minimum alternate tax in the Supreme Court, although analysts are unclear if entities without a tax treaty will benefit. Investment Association, based in London, and Hong Kong-based Asia Securities Industry & Financial Markets Association (ASIFMA) plan… – Continue reading

Preventing Double Taxation of Interstate Income: Supreme Court’s “Wynne” Decision is a Win for Taxpayers

In a five-to-four decision, the United States Supreme Court held that the dormant commerce clause protects in-state residents from the double taxation of their interstate income. This is a complicated decision and the margin favoring the taxpayers was razor-thin, one vote. The decision is complicated because the tax involved was… – Continue reading

Bonus shares: SECP suggests FBR to withdraw 5 percent tax, apply 12.5 percent CGT

The Securities and Exchange Commission of Pakistan (SECP) has proposed to the Federal Board of Revenue (FBR) to withdraw 5 percent tax on bonus shares and apply current capital gains tax (CGT) rate of 12.5 percent irrespective of its holding period. According to the budget proposals of the SECP received… – Continue reading

Accord to Avoid Double Taxation with Norway Now Before Bulgarian Parliament

Bulgaria’s government has proposed to parliament to ratify the agreement with Norway to avoid double taxation of income. The agreement was signed in July of last year to update the regulation framework governing the bilateral economic relations, the cabinet said in a statement on Wednesday. The previous agreement had been… – Continue reading