Representatives of the governments of Hungary and Luxembourg signed an agreement to eliminate double taxation on the sidelines of a meeting of EU finance ministers, the economy ministry said. The new agreement, signed by Economy Minister Mihály Varga and counterpart Pierre Gramegna, replaces an earlier one signed in 1990. It… – Continue reading
Just before Christmas last year, Justice Bennett handed down the decision in Seven Network Limited v Commissioner of Taxation [2014] FCA 1411 which held that no copyright existed in Channel Seven’s live television broadcasting of the 2006 (Winter) Olympics in Turin, and the 2008 Olympic Games in Beijing, to Australian… – Continue reading
ISLAMABAD: Signing of a Trade and Investment Framework Agreement (TIFA) between Pakistan and the United States has been put on the back-burner since America has become the largest export market for Pakistan with a volume of $3.7 billion, said US Secretary of Commerce, Penny Pritzker on Tuesday. A key member… – Continue reading
No more tax amnesties by the government are envisioned, Prime Minister Joseph Muscat said yesterday during a press conference announcing the government’s acquisition of the Swiss Leaks data. The first tax amnesty was launched in 2002, with subsequent amnesties in 2003, 2005, 2007 and 2014. Asked whether tax evaders on… – Continue reading
East African member states have been advised to make critical assessment of single income tax rates. A law expert, Anatoly Nahayo said recently in Dar es Salaam after launching his book titled “East African Community Tax Harmonisation.” He said the move will ease allocation of capital shares within EAC member… – Continue reading
RIYADH — The Council of Ministers on Monday renewed its commitment to strengthen human rights and their protection, saying that it is part of the Kingdom’s firm approach that is derived from the Islamic Shariah. Custodian of the Two Holy Mosques King Salman chaired the Cabinet’s weekly session at Al-Yamamah… – Continue reading
Cyprus signed four bilateral agreements with Bahrain on Monday, during President Nicos Anastasiades’ state visit to the kingdom where he was be received by ruler Hamad bin Isa Al Khalifa, where the two leaders also discussed issues of cooperation in tourism and the economy, as well as concerns about regional… – Continue reading
André Wilsenach, the executive director of the Alderney Gambling Control Commission (AGCC), has vowed to support those companies impacted by new point-of-consumption (POC) tax laws in the UK. As of November 1, 2014, operators providing remote gambling services to customers in the UK must hold a remote licence from the… – Continue reading
The Maltese Government has said in a statement that it has today acquired from the French Government the data, popularly known as Swiss Leaks, insofar as it relates to Maltese nationals. The data was presented in Paris in the presence of French Finance Minister Michel Sapin to the representative of… – Continue reading
Barbados and Cyprus have announced that they are to begin negotiating a double taxation agreement (DTA) to strengthen economic relations between the two territories. Barbados Prime Minister Freundel Stuart noted that although diplomatic relations between the two countries were established in 1972, economic opportunities have yet to be fully explored…. – Continue reading
Many business owners have substantial personal assets invested in their business. This can have significant implications, not only for you and your business, but also for your family’s financial security. To protect your investment, both business and personal, your business strategy should include carefully structured tax-planning components to ensure you… – Continue reading
NEW DELHI: Indian Central Board of Direct Taxes (CBDT) will outline rules to give relief on foreign pre-paid taxes. Currently, the income tax law does not provide the manner for granting credit of taxes paid in any country outside. Now, this situation is sought to be addressed with the latest… – Continue reading
NEW DELHI: Indian Central Board of Direct Taxes (CBDT) will outline rules to give relief on foreign pre-paid taxes. Currently, the income tax law does not provide the manner for granting credit of taxes paid in any country outside. Now, this situation is sought to be addressed with the latest… – Continue reading
With effect from 1 January 2015, The Income Tax (Guernsey) Law, 1975 was amended so that non-Guernsey residents will now be taxed on their pension benefits paid from an occupational pension scheme approved under section 150 of the Law, irrespective of whether they have performed services in Guernsey or not…. – Continue reading
Republican Senators Mike Lee and Marco Rubio have put forward version 2.0 of their tax reform proposal first released last September. The two men offer a bit more detail to their sweeping plan this time around, and it’s still a strong, pro-growth proposal. The broad strokes of the Lee-Rubio plan… – Continue reading
On December 2, 2014, the State Administration of Taxation (SAT), China’s highest tax authority, issued the Administrative Measures for the General Anti-Avoidance Rules (Trial) (GAAR), which went into effect on February 1, 2015. Prior to this legislation, China had no specific GAAR, only a few general anti-avoidance principles in various… – Continue reading
NEW PACTS WITH AMSTERDAM AND TOKYO BOOST TRANSFER PRICING IN HONG KONG When combined with aggressive tax planning, Hong Kong’s onshore-offshore tax regime often results in a reduced tax burden for taxpayers that operate through Hong Kong companies by pricing intra-group transactions. The Advance Pricing Arrangement agreement with the Netherlands… – Continue reading
Double Tax Avoidance Agreement to be Applied to China Funds Investors no longer have to be worried about double taxation on China-based funds. On Mar. 4, the Korea Financial Investment Association told asset management firms to hand in documents for double tax avoidance agreement applications. Four months ago, when the… – Continue reading
If you have been running your business as a sole proprietor or are planning to be self-employed, you should probably give the idea of incorporating your business a serious thought. Since we are talking about incorporation from the point of view of taxation, you should know that it has its… – Continue reading
India has made a major breakthrough with Swiss tax authorities, who have agreed to provide information in respect of cases independently investigated by IT department whereas first round of talks have reportedly taken place between Pakistan and Swiss government on revision of Convention for the Avoidance of Double Taxation agreement…. – Continue reading
KUALA LUMPUR: Georgia is motivated to enhance economic cooperation with Malaysia, which has one of the most open economies in the world, its Charge d’Affaires ad interim (a.i.) to Malaysia Levan Machavariani said. “Malaysia is one of the world’s most open economies and fully integrated in the world’s trade and… – Continue reading
The outgoing High Commissioner of Pakistan, Major General Ulfat Hussain Shah, paid a courtesy call yesterday on the Prime Minister, Sir Anerood Jugnauth, at the Treasury Building in Port Louis, to bid him farewell after having served for two years in Mauritius. Both parties agreed that there is a need… – Continue reading
An investment registration scheme launched by the government last year attracted a total of 1,469 valid registrations covering an aggregate of €455.8 million worth of eligible assets, The Finance Ministry told The Malta Independent. Of the total amount registered, €69.8 million or 15% of the total was repatriated following registration…. – Continue reading
Global entities liable to pay tax on yearly income if their place of effective management is India even for a single day Shell companies based abroad would have to pay taxes on their global income for a year if their place of effective management (POEM) is India even for a… – Continue reading
Under Article 185, § 2, B of the Belgian Code on revenue taxes, an international group may ask for its taxes to be reduced by so-called excess profits, which are registered in the account of the Belgian entity as a result of the benefits of being part of an international… – Continue reading
The art of taxation, declared King Louis XIV’s Minister of Finances Jean-Baptiste Colbert, is in “so plucking the goose as to obtain the largest amount of feathers with the least amount of hissing”. The Budgets of Singapore and Hong Kong – released two days apart this week – have thrown… – Continue reading
Minister of Finance Martin Dlamini said the proposed revenue measures would assist government in mobilising additional resources for protecting essential services while Southern African Customs Union (SACU) revenues fall in the medium term. He said these initiatives include an amendment of the Income Tax regulations, including removal of the tax… – Continue reading
The income tax department has scaled down its estimate of income suppression by multinational corporations in India in the 2014-15 audit of intra-group cross-border transactions to Rs 47,000 crore, a steep 22% decline from the extra taxable income the department had attributed to the firms in the previous audit. The… – Continue reading
ISLAMABAD: Transparency International (TI) has urged the National Accountability Bureau (NAB) to investigate evasion of tax, and call for information about the Pakistani investors who have succeeded to transfer Rs430 billion investment on the purchases of properties during the year 2013 and 2014. In a letter written to NAB chairman,… – Continue reading
The breathless conundrum for IP companies is four-fold: not only should royalties be taxed at a low rate in order to maximise profits; but also research and development (R&D) or acquisition costs should be considered as allowable expenses to the maximum possible effect, whilst also the jurisdiction where the IP… – Continue reading
When combined with aggressive tax planning, Hong Kong’s onshore-offshore tax regime often results in a reduced tax burden for taxpayers that operate through Hong Kong companies by pricing intra-group transactions. This has led to heightened transfer pricing scrutiny from the Hong Kong Inland Revenue Department in recent years. In order… – Continue reading
The signing of a double taxation agreement (DTA) protocol between Switzerland and Italy, which includes a provision for the exchange of information upon request, has fueled an expectation that the Italian Treasury will be able to collect substantial additional tax revenue this year. While it could take up to two… – Continue reading
Thanks in part to past concerns that globalization could lead to double taxation, corporations have numerous techniques at their disposal to reduce their tax bills, including the placement of subsidiaries and spinoff holding companies in low-tax jurisdictions. The Group of 20 wants to change that. The Organisation for Economic Cooperation… – Continue reading
As for the central message that an NRI/PIO want to hear from Modi’s most important budget of his term can be best summed by what he said during an event in central park New York “May the force be with you “Veni Vidi Vici!” he came, he saw and he… – Continue reading
Close to three dozen private equity firms which used investment entities based in Mauritius to route money into Indian portfolio companies have received income-tax notices for payment of Minimum Alternate Tax (MAT) on the capital gains accrued to them for sale of such shares, according to Business Standard. MAT is… – Continue reading
São Paulo, Brazil. International transfer pricing is able to take place in Brazil, outside of the OECD While Brazil is not a member of the OECD, many multinational groups there are able to successfully navigate international transfer pricing standards, yielding effective results The economic view of Brazil has always been… – Continue reading
Bahrain and India have signed agreements to increase co-operation in the areas of education, investment, defence and other sectors. It took place during the first meeting of the India-Bahrain High Joint Commission (HJC) in New Delhi, said a report in the Gulf Daily News (GDN), our sister publication. The Bahrain… – Continue reading
This is the time of the year for millions of Americans to begin the annual ritual of gathering information about income, taxes, charitable giving, health insurance, expenses and sundry other items, and prepare to send mountains of information to the IRS –and to those who prepare their tax returns. Overseas… – Continue reading
Switzerland and neighbouring Italy have revised a double taxation agreement which includes provisions for the exchange of information in line with the standards of the Organisation for Economic Development and Co-operation (OECD). The accord and a roadmap for the amendment of tax rules on cross-border workers as well as improved… – Continue reading
Switzerland and neighbouring Italy have revised a double taxation agreement which includes provisions for the exchange of information in line with the standards of the Organisation for Economic Development and Co-operation (OECD). The accord and a roadmap for the amendment of tax rules on cross-border workers as well as improved… – Continue reading
Tax collections, so maintains the Federal Minister for Finance Ishaq Dar, have improved significantly and he cited a healthy growth rate of around 13 percent in one of his recent press conferences. Sources within the Ministry of Finance, however, revealed to Business Recorder, but on condition of anonymity that the… – Continue reading
The economic downturn across the world and rising public debt seems to have led various governments, globally, to focus on curbing erosion of the tax base by shifting profits to overseas jurisdictions. Several revenue authorities, globally, were of the view that companies have structured their intra-group contractual arrangements in a… – Continue reading
America is experiencing a significant issue with its number of corporations, with a recent report from the Tax Foundation showing that the number is the lowest it’s been in four decades. The report, titled “America’s Shrinking Corporate Sector,” points to recently released IR data showing there were 1.6 million C… – Continue reading
PARIS: Singapore and France signed an amended Agreement for the Avoidance of Double Taxation (DTA) to lower withholding tax rates for dividends and new anti-abuse provisions. The most notable changes are the following: Withholding tax rate for dividends is reduced to 5 percent (from 10 percent previously) if the beneficial… – Continue reading
Over the past few years we have seen the introduction of various withholding taxes to the South African tax system. We set out below a high-level summary of the various withholding taxes that are levied in terms of the Income Tax Act 58 of 1962 (the “Act”), their rates and… – Continue reading
Probes since 2001 into offshore accounts include €4.6m from Irish HSBC customers The Revenue Commissioners has collected just more than €1 billion since 2001 from various special investigations of offshore bank accounts held by Irish residents. This includes the €4.6 million received to date from the holders of offshore accounts… – Continue reading
This Tax Alert by EY summarizes a recent ruling of the Mumbai Income Tax Appellate Tribunal (Tribunal) in the case of Swiss Re-Insurance Company Ltd. (Taxpayer). The Tribunal ruled that the Taxpayer’s wholly-owned Indian subsidiary (ICo) engaged in carrying out risk assessment services, marketing insurance and providing administrative support for… – Continue reading
The abolition of unfair taxes was one of the foundational principles of Magna Carta, a document that King John assented to on June 15, 1215 at Runnymede, England. Taxation must be fair, and requires the consent of the people. There is no more unfair aspect of fiscal law than retroactive… – Continue reading
Police bosses have been accused of seeking to double tax residents through plans for communities to help fund community support officers. Norfolk Police and Crime Commissioner Stephen Bett yesterday defended his proposal that town and parish councils could contribute 50 per cent of the cost of a PCSO in their… – Continue reading
Every acquisition requires careful tax planning early on in the process, especially when dealing with cross border acquisitions. One important consideration when a foreign company plans to acquire a Canadian company is the impact of any tax treaties that currently exist between the two jurisdictions. Tax treaties effectively reduce tax… – Continue reading
