Fundamental to any developed tax policy is knowing who the taxpayer is (or should be) with respect to any particular transaction. Although that can be relatively straightforward in purely domestic situations, a cross-border dimension can present different answers to this question in the jurisdictions involved and lead to issues over… – Continue reading
If you are a foreign executive moving to the United States for work, not only do you have to consider practical concerns like moving your family and finding a new residence, but you also need guidance as to any US tax implications stemming from the move. One of the first… – Continue reading
NEW YORK, Sept. 28 (Yonhap) — Nigerian President Muhammadu Buhari has vowed to make efforts to quickly resolve the issue of double taxation avoidance with South Korea. South Korea and Nigeria signed a double taxation avoidance agreement in 2006 to help boost two-way investment and trade, though the West African… – Continue reading
Efforts to amend details of new rules on corporate profits raise questions, reports the Wall Street Journal. Nearly 50 governments are set to agree this fall to a new set of rules to clamp down on tax avoidance among multinational corporations. Their chance of success, however, is unclear. If the… – Continue reading
Since its inception in August 2014, the SMU-TA Centre for Excellence in Taxation has worked tirelessly with industry practitioners, international academics and various key stakeholders to produce its first set of research works. On September 17, the Centre successfully presented its inaugural conference titled “A New Equilibrium in Tax Competition… – Continue reading
India must align domestic laws with international treaties A recent ruling of the Punjab & Haryana High Court (HC) in the Serco BPO case has once again underlined the need for consistency between tax policies and the jurisprudence that evolves around it, thus, leaving little to interpretational hazards. The HC,… – Continue reading
The UK’s tax treatment of US limited liability companies (LLCs) will remain mostly unchanged despite a recent Supreme Court decision in favour of the taxpayer, HM Revenue and Customs (HMRC) has confirmed.25 Sep 2015 HMRC said that the decision of the UK’s highest court in favour of George Anson, a… – Continue reading
In 2013, the Organisation for Economic Cooperation and Development (OECD) released a series of proposed tax measures for eliminating corporate tax structures that shift profits to foreign jurisdictions. This corporate tax practice is commonly referred to as base erosion and profit shifting or BEPS. Towards this, the OECD and G20… – Continue reading
The Danish tax authority Skat fired several top officials and was given an emergency lifeline from parliament on Friday after been hammered by scandals in recent weeks that could result in the loss of 14 billion kroner. Denmark hit by potential billion-dollar tax fraud (26 Aug 15) Danes face the… – Continue reading
The increasingly international nature of business will lead to complications and disruptions that may plague the future of audit, according to PwC. A recently-released PwC report, Global Tax Transparency and Risk Management – part of the ‘Tax Function of the Future’ series – notes that the number and size of… – Continue reading
Prime Minister Narendra Modi has assured Cyprus President Nicos Anastasiades that he would look into the double taxation agreement to see how he could expedite it and said that Nicosia has always stood by New Delhi on all issues of ‘mutual concern’. “The Cyprus President said that the nation had… – Continue reading
Thousands of Australians head offshore each year to expand their horizons and a lucky few will fund their adventure by working overseas. Some may live overseas and work for an extended period. There can often be confusion about the tax implications for taxpayers who take advantage of such offshore opportunities…. – Continue reading
The Internal Revenue Service has entered into landmark Competent Authority Agreements with authorities in Australia and the United Kingdom to support the implementation of the Foreign Account Tax Compliance Act (FATCA). The US has signed FATCA intergovernmental agreements with both of these nations. Each of these agreements provides that Competent… – Continue reading
Automatic exchange of information for tax law enforcement purposes started first in Europe with the EU Savings Tax Directive, went international with the US Foreign Accounts Tax Compliance Act, and, from 2017, will go global with the recently-agreed Common Reporting Standard, the subject of this feature. Introduction To The Common… – Continue reading
Content supplied by EY New Zealand is one of only a few countries with a dividend imputation regime. Introduced in 1988, New Zealand’s imputation regime removes double taxation on distributions by attributing to shareholders a credit for the tax borne on profits at the company level. Benefits include a single… – Continue reading
Myanmar plans to introduce more laws and regulations to increase its tax income over the coming years, sources said. The Internal Revenue Department (IRD) currently sets polices under the Myanmar Tax Law and the Union Tax Law. Sources at the IRD said they will issue further notifications, if required, to… – Continue reading
Honda’s manufacturing plant in India, one of the emerging countries where many Japanese companies are in disputes with local tax authorities. TOKYO — Many Japanese companies operating in emerging countries are grappling with taxation problems they would never face in major industrial nations. Honda Motor, for instance, has gotten embroiled… – Continue reading
Just under Rs 500 cr declared so far, officials hope for surge in last six days. With only six days to go before a compliance window to declare offshore assets closes, officials say several thousand applications are in but the total amount declared so far seems very little. Until last… – Continue reading
In a big relief to foreign firms, the government on Thursday exempted them from paying minimum alternate tax (MAT) retrospectively from April 2001, provided they did not have a permanent establishment in India. Tax experts said that this government move ends a lot of uncertainty on the controversial MAT issue… – Continue reading
IT Act will be amended with retrospective effectto exempt foreignfirms from MAT In a big relief to foreign firms, government on Thursday said the Income Tax Act will be amended with retrospective effect to exempt from minimum alternate tax (MAT) the overseas companies that covered under double taxation avoidance agreements… – Continue reading
The Minister for the Economy, Investment and Small Business, Dr Chris Cardona attended Malta Day 2015 in Moscow coinciding with the 51st anniversary from Malta’s independence, during which a Maltese-Russian Business Forum was held. Minister Cardona spoke about the good relations Malta has held with Russia, which go back many… – Continue reading
On September 16, 2015, the Honorable Mr. Justice Martineau rendered summary judgment in the matter of Hillis and Deegan v. The Attorney General of Canada, docket T-1736-13 (2015 FC 1082). As a matter of background (and as discussed in a previous post), on August 11, 2014, the plaintiffs, Hillis and… – Continue reading
On 26 February 2015, the Austrian Supreme Administrative Court decided in favor of an appeal filed by WOLF THEISS for a client who received tax exempt interest income from other countries. An Austrian taxpayer received interest from Greek, Brazilian and Argentinian government bonds between 2003 and 2007. According to the… – Continue reading
The IRS recently replaced Rev. Proc. 2006-54 for requesting assistance under the Mutual Agreement Procedure (“MAP”) article of U.S. tax treaties, and Rev. Proc. 2006-9 for requesting Advance Pricing Agreements (“APAs”). The new Rev. Procs. (2015-40 and 2015-41, respectively) largely track draft procedures issued in 2013 (Notices 2013-78 and 2013-79),… – Continue reading
On 31 March 2015, the Austrian Ministry of Finance published a decree dealing with, inter alia, mutual agreement procedures under double tax treaties. Currently, Austria has concluded 85 double tax treaties, all of which contain provisions on mutual agreement procedures (MAPs). However, Austrian statutory law does not provide for procedural… – Continue reading
The IRS has let Americans living abroad wrongly claim tax credits on their foreign income, according to a new report from the agency’s watchdog. The Department of Treasury’s inspector general for tax administration said the IRS allowed taxpayers to wrongly claim around $95 million between 2010 and 2012 in foreign… – Continue reading
The bench comprising justices Anil R. Dave and A.K. Goel said the case would be heard fully New Delhi: The Supreme Court on Tuesday admitted the income tax department’s appeal against a 2013 Andhra Pradesh high court ruling that said that France-based Sanofi SA was not required to pay tax… – Continue reading
Floor traders work during afternoon trading at the Hong Kong Stock Exchange in this November 6, 2013 file photo. Hong Kong is working night and day to launch an initiative that will let global investors trade Chinese stocks from the city for the first time and secure the former British… – Continue reading
Entebbe — Members of African Parliamentarian Network on Illicit Financial Flows and Tax (APNIFFT) want governments across the continent to put more pressure on multinational companies to pay full taxes. According to the parliamentarians, tax evasion and illicit financial flow (IFFs) from Africa can be brought to an end if… – Continue reading
What constitutes an HNI is a tricky question? In general parlance, HNIs are understood to be the individuals with ultra-high networth with deep pockets having surplus investible funds. As per the Credit Suisse global wealth report, currently India is home to around 1,500 ultra-high networth individuals with wealth of at… – Continue reading
The government of Cabo Verde (Cape Verde) approved an agreement to avoid double taxation with Guinea-Bissau, aimed at preventing tax evasion and fostering economic relations between the two countries, according to an official statement issued following a Cabinet meeting. The statement issued Friday said that the approved agreement, signed in… – Continue reading
New Delhi, Sept 22 (KNN) Government will not extend the window for declaration of black money assets held abroad beyond September 30, said Joint Secretary, Central Board of Direct Taxes (CBDT), Ministry of Finance, V Anandarajan. While inaugurating the conference on ‘Black Money Act: Ignorance is not Bliss! – Key… – Continue reading
Foreign institutional investors (FIIs) on Monday sought simplified requirements for making investments in India, during their meeting with Finance Minister Arun Jaitley. Jaitley, who has wrapped up his two-day visit here, highlighted recent initiatives taken by the government to attract investments and told them, efforts were being taken to further… – Continue reading
The UAE and the Republic of Mauritius are linked with a double taxation on income agreement that was signed in 2006. On behalf of the UAE, the Ministry of Finance (MoF), signed yesterday an agreement on mutual encouragement and protection of investments with the Republic of Mauritius. This is following… – Continue reading
As discussed in the previous edition, due to current worldwide developments including the OECD’s move to curb tax Base Erosion and Profit Shifting (BEPS), tax policy is changing significantly. In Ghana for example, a Transfer Pricing Regulations was passed in 2012 which aimed to ensure that the tax base of… – Continue reading
In 28 August 2015, the Chinese State Administration of Taxation issued an Announcement for Granting Tax Treaty benefits to non-residents. The Announcement proposes a new system for granting tax treaty benefits where there pre-approval of the tax authorities is no longer required for withholding tax agents to apply reduced tax… – Continue reading
Prime Minister Hun Sen said Saturday he would like to stop foreign teachers from being required to pay income tax both in Cambodia and their home country in order to attract more highly-skilled educators to work here. Speaking at the official opening of the International School of Phnom Penh’s new… – Continue reading
Global convergence towards higher tax rates globally would be a poor outcome for the base erosion and profit shifting (BEPS) project and a severe impediment to uplifting global growth prospects, Josephine Teo, Singapore’s Senior Minister of State for Finance and Transport, has said. Speaking at the SMU-TA Centre for Excellence… – Continue reading
(Corrects first and sixth paragraphs to make clear Intertrust does not provide tax advice) (Reuters) – Intertrust, which provides tax and regulatory compliance services to 17,000 companies, said on Monday it will seek an initial public offering (IPO) of shares on the Euronext stock exchange. The Amsterdam-based company did not… – Continue reading
New Delhi, Sept. 20: A bilateral investment treaty between India and the US is unlikely to be finalised before Prime Minister Narendra Modi’s visit to America later this week. Both Modi and US President Barack Obama have been pushing their respective bureaucracies to prepare the pact. Modi will be in… – Continue reading
China’s State Administration of Taxation on 17 September 2015 released a discussion draft of proposed guidance relating to “special tax adjustments”—including those concerning transfer pricing—for public consultation. It is anticipated that this guidance could be finalized by the end of 2015, and once final, would replace the existing transfer pricing… – Continue reading
THE proposed Income Tax Bill is not clear whether disbursement cost are also included for charging Withholding Tax, says Fiji National Provident Fund (FNPF) Investment principal legal officer Siteri Saru. FNPF made a submission to the Standing Committee on Justice, Law and Human Rights on the Income Tax Bill in… – Continue reading
Australian Treasurer Joe Hockey: Australian companies can take greater advantage of Israel’s knowledge-based economy. There is no tax treaty between Australia and Israel, but the lack will soon be made good, according to an announcement by Joe Hockey, Treasurer in the Australian government. “As part of the Government’s ongoing efforts… – Continue reading
The Swiss Federal Council has given the Swiss delegation to the OECD, the “go ahead” to accept the final BEPS reports— expected to be released possibly as early as the end of September 2015. This action indicates that Switzerland could implement and apply the new standards in the near future,… – Continue reading
Issues of the Uzbek-Iranian bilateral relations’ development were discussed during the meeting of Uzbek Foreign Minister Abdulaziz Kamilov with Iranian Ambassador Ali Mardoniy Fard, who is completing his diplomatic mission in the country, said the message released Sept.16 by the foreign ministry of Uzbekistan. During the meeting, the sides exchanged… – Continue reading
SINGAPORE first entered a double taxation agreement (DTA) with Thailand in 1975. After 40 years, Singapore and Thailand signed a new DTA on June 11, 2015. The newly signed DTA has not yet been ratified by either country, and will go into force after it is. Below are some of… – Continue reading
Hong Kong’s Financial Services Development Council (FSDC) has released a report setting out recommendations on policies, including tax measures, to enhance the city’s role as a regional and global financial booking center. Financial institutions utilize such centers to enter into contracts for financial products, undertake primary obligations for delivery or… – Continue reading
Past Progress and Prospects Harmful tax practices (e.g., tax havens, preferential tax regimes, tax rulings) are characterised by the propensity to erode tax bases of other countries which allegedly leads to an undesirable race-to-the-bottom on taxation rates. Action 5 of the OECD Action Plan on Base Erosion and Profit Shifting… – Continue reading
Read the full newsletter. The OECD’s recent recommendations1 with respect to transfer pricing documentation and country-by-country reporting may have the most significant impact on multinational enterprises (“MNEs”) of all of the OECD’s BEPS proposals. The adoption of these recommendations, without consensus on effective dispute resolution, is likely to alter the… – Continue reading
In a decision released August 14, the Tax Court of New Jersey ruled that an intangible holding company with no physical presence was required to file a New Jersey corporation business tax (CBT) return and pay the related tax due based on its income.1 No relief was available to the… – Continue reading
