Category: Tax treaties

The outlook for BEPS in 2015

National tax laws are struggling to keep pace with the rise of the digital economy and the progress of multinational companies. These factors leave gaps that are susceptible to misuse and lead to cases of double non-taxation, which undermine the integrity and fairness of tax systems around the world. The… – Continue reading

100 foreign funds get tax demands; total bill may hit $10 bn

New Delhi/Mumbai: In the biggest-ever tax demand slapped on them, nearly 100 foreign funds have been asked to cough up an estimated USD 5-6 billion for ‘untaxed gains’ made by them in the Indian markets over the past years. The number of affected investors can rise substantially as assessments are… – Continue reading

UFIA Bill could impact Make in India policy: Sonu Iyer

Interview with Partner and National Leader, Human Capital Services, EY India The Undisclosed Foreign Income and Assets (Imposition of Tax) Bill, 2015, popularly called the “anti-black money bill” has been in the news for its stringent and sweeping provisions. Sonu Iyer, partner and national leader, human capital services, EY India,… – Continue reading

ICDS: A possibly taxing reality

The Ministry of Finance has issued ten Income Computation and Disclosure Standards (ICDS), operationalising a new framework for computation of taxable income by all assesses in relation to their income under the heads “Profit and gains of business or profession” and “Income from Other Sources”. The Central Board of Direct… – Continue reading

Joe Hockey’s Google tax could derail international tax treaties: Budget Office

The likely centrepiece of Treasurer Joe Hockey’s assault on multinational profit-shifting – a so-called “Google tax” – risks breaking Australia’s international tax treaties, the Parliamentary Budget Office has found. The independent adviser warned that the unilateral introduction of a “diverted profits tax” like ones being considered by Australia and Britain… – Continue reading

Pensions, Taxes & Fatca: Finance Tips for British (& Other) Expats in the U.S.

We asked Vincenzo Villamena, a New York-based international tax adviser and certified public accountant with Online Taxman, and his British-expat client Ed Zitron of San Francisco, to share personal finance tips for expats, particularly those hailing from the U.K. Here are their top tips: 1. Mind your pensions & QROPS!… – Continue reading

Google, Apple tax crackdown will fail without US support

Jurisdictional issues will limit success. It’s no secret that companies including Apple, Google and Amazon, seem to pay less than their fair share of tax in Australia. Despite booking huge revenues from sales to Australian customers they are able to reduce their profits in this country by shifting profits to… – Continue reading

Cyprus: Negotiations In Progress For A Double Taxation Agreement Between Cyprus And Barbados

The Barbados Government Information Service has announced that negotiations are in progress for a double taxation agreement between Cyprus and Barbados, as well as for co-operation in other areas, such as tourism. At a recent meeting with the Barbadian Prime Minister the Cyprus High Commissioner to Barbados expressed his optimism… – Continue reading

Important lift for Hong Kong’s air finance hub ambitions

An agreement to lower the mainland withholding tax for aircraft and ship leasing is a crucial first step towards realising the Hong Kong government’s ambition of making the city an international centre for financing a global aviation industry that will need US$4.6 trillion worth of planes in the next two… – Continue reading

China ‘Through-Train’ Ends Double Taxation For Equity Investors

The Shanghai-Hong Kong Stock Exchange Connected is working out its kinks and investors are taking notice. Hong Kong and Beijing signed a tax treaty on Thursday that ends double taxation for equity traders, which was one of the sticking points for local brokers hoping to buy into China’s massive mainland… – Continue reading

Tax Authority to impose VAT on foreign Internet cos

A new circular says multinational corporations like Google and Facebook will pay taxes on online business with Israelis. Foreign Internet companies and another other foreign corporation with significant business in Israel must register with the VAT authorities as authorized dealers, and their transactions are liable to VAT. Under certain conditions,… – Continue reading

Greeks target Ireland with corporation tax move

Ireland has been targeted by a new Greek law that the country’s government says is aimed at combating the nation’s widespread corporate tax avoidance, reports the Irish Independent. However, critics say a new tax regime that explicitly targets companies doing business in Ireland, Cyprus and Bulgaria undermines Europe’s common market… – Continue reading

China unveils plans on building Silk Road Economic Belt, 21st-Century Maritime Silk Road

The Bangladesh-China-India-Myanmar (BCIM) economic corridor and China’s proposed ‘Silk Road Economic Belt and 21st-Century Maritime Silk Road’ are “closely” related, Beijing says as it has unveiled action plans on this joint ‘Belt and Road Initiative’. Chinese President Xi Jinping during his visits to Central Asia and Southeast Asia in 2013… – Continue reading

Charting the Limits of Acceptable Tax Planning in Singapore

In 2015, Singapore celebrates its 50th year of independence and also mourns the passing of its first Prime Minister Lee Kuan Yew who steered Singapore’s success for many critical years. From its origins as a British trading post in 1819, Singapore has grown into one of the busiest ports and… – Continue reading

United States: Uncle Sam Wants You (To Pay Tax): Income Tax Pitfalls For Americans Living Abroad

I. Introduction In an effort to crack down on individuals obtaining U.S. citizenship illegally, the U.S. Department of Justice recently raided several “maternity tourism” operations in Southern California.1 These companies cater to wealthy foreigners seeking to give the gift of U.S. citizenship to their children. Since at least 1868, the… – Continue reading

Mainland and HKSAR sign Fourth Protocol to Arrangement for Avoidance of Double Taxation

Hong Kong (HKSAR) – The Secretary for Financial Services and the Treasury, Professor K C Chan, signed the Fourth Protocol to the Arrangement for the Avoidance of Double Taxation and Prevention of Fiscal Evasion with respect to Taxes on Income with the Mainland (the Fourth Protocol) with the Deputy Commissioner… – Continue reading

Hong Kong Tax Breaks To Support Financial Center

Hong Kong’s Secretary for Financial Services and the Treasury, K C Chan, has described the various tax policies that the Government intends to pursue in the coming year. As part of his testimony before the Legislative Council (LegCo) Finance Committee special meeting on the 2015-16 Budget, Chan stressed that the… – Continue reading

Bitcoin A ‘Threat’ To Australia’s Tax Collection System; ATO To Clamp Down On Tax Avoidance Of Multinationals

A recently released discussion paper has found that Australia finds Bitcoin as becoming a threat to the country’s tax system. The paper said new technology and globalisation are among the main factors pushing multinational practices to engage in tax avoidance. According to the paper, news ways transacting such as Bitcoin… – Continue reading

Japan companies face pressure to use near-record cash stockpiles to help drive growth

TOKYO: Japan companies have pressure to use their near-record cash stockpiles to help drive growth, with Finance Minister Taro Aso saying Thursday the government should consider a tax to prod businesses into action. “Japan should carefully consider issues like this,” Aso said in Parliament in response to a question from… – Continue reading

Cash-flush corporations at center of income-tax debate

U.S. multinationals represent the healthiest segment of the economy, with higher profits and more than $1 trillion of cash on hand. This has kept corporate tax reform alive as a political issue. ON Semiconductor had a solid 2014, boosting net income by 36 percent to $196 million on revenue of… – Continue reading

Regional co-operation on investment – What does it involve?

CO-OPERATION on investment within the SADC region is an integral part of achieving the overarching objectives of the SADC Treaty. Investment, be it foreign direct investment, cross-border investment or domestic investment is needed to enhance the productive capacity in the region, which is a pre-requisite for increasing trade across borders… – Continue reading

Tax decree and circular guiding the implementation of the new Tax Law effective from 1 January 2015

In order to guide the implementation of the Tax Law on amending key tax laws which was effective from January 20151, the following guidance regulations have been issued: Decree 12/2015/ND-CP dated 12 February 2015 of the Government (“Decree 12”); and Circular 26/2015/TT-BTC dated 27 February 2015 of the Ministry of… – Continue reading

Aussies working in Hong Kong should avoid these tax traps

Australians working in Hong Kong should be aware of the various complexities that affect their residency, super and tax status. Going overseas to work is a grand adventure for many professionals. But the way income earned outside your home country is taxed is a complex area, and it’s worth seeking… – Continue reading

Government still mulling tax hikes

The Ministry of Finance yesterday issued two statements saying the government has yet to reach conclusions on tax rates or an implementation date for a proposed income levy on property gains. The ministry made the clarifications after the Cabinet called a meeting on the proposed tax and gave its go-ahead… – Continue reading

UK tax rules on disguised investment management fees: final legislation published

The UK’s Finance Bill was published on 24 March 2015. It was subsequently enacted on 26 March 2015 without further amendment and became the Finance Act 2015. The “disguised investment management fee” provisions contained in this Act, summarised below, will be effective from 6 April 2015. These rules apply to… – Continue reading

Dividend imputation clears an early tax review hurdle

Government questions dividend imputation and company tax rate Australian investors appear to have dodged a bullet, with the government’s first paper on tax reform discussing the dividend imputation system but falling short of attacking it outright as an idea that has outlived its usefulness. David Murray’s inquiry into the Australian… – Continue reading

Luxembourg: Luxembourg’s Direct Tax Administration Publishes Circular On Residency Certificates For Funds

Luxembourg’s Direct Tax Administration has published a circular on February 12 clarifying issues relating to residency certificates for Luxembourg funds. These are applicable to both UCITS and non-UCITS funds regulated by Luxembourg’s investment fund legislation of December 17, 2010, which transposed the UCITS IV Directive, as well as Specialised Investment… – Continue reading

Greek economic recovery crippled by corporate tax avoidance

Greece’s economic recovery is being undermined by large-scale corporate tax avoidance, whereby companies use loopholes in places like the Netherlands and Luxembourg to pay little or no income tax, according to a new report from Dutch research group, SOMO. Greece has been gripped by harsh austerity measures imposed by the… – Continue reading

BEPS Action Plan 15: Multilateral instrument for bilateral tax treaties

This article continues our series on the Base Erosion and Profit Shifting (BEPS) project, and the Action Plans that have so far been submitted, by the Organisation for Economic Co-operation and Development (OECD). We now look at Action Plan 15 on Developing a Multilateral Instrument to Modify Bilateral Tax Treaties…. – Continue reading

I-T dept sends notices to nearly 150 foreign portfolio investors over MAT

MUMBAI: Income-tax authorities on Friday issued draft assessment orders against nearly 150 foreign portfolio investors (FPIs) asking them to pay minimum alternate tax (MAT), a move that is bound to reinforce India’s reputation for aggressive tax enforcement. The 15-page draft assessment order sent to FPIs provides reasoning as to why… – Continue reading

ANCA calls for increased Artsakh aid during Congressional testimony

Armenian National Committee of America Government Affairs Director Kate Nahapetian testified yesterday before a key Congressional panel in support of increased U.S. assistance to Nagorno Karabakh, Armenia, at-risk Middle Eastern Armenian communities, and the Javakhk region of Georgia. In her opening remarks, Nahapetian thanked House Appropriations Subcommittee on Foreign Operations… – Continue reading

Developments in the Luxembourg financial sector

The Luxembourg supervisory authority, the Commission de Surveillance du Secteur Financier (CSSF), has recently issued FAQs regarding the immobilisation of bearer shares and units, as well as a press release to remind Luxembourg alternative investment fund managers (AIFMs) and non-EU AIFMs that market alternative investment funds (AIFs) in Luxembourg under… – Continue reading

Mauritius to fully cooperate with India to address outstanding issues relating to DTAA

The India-Mauritius Double Taxation Avoidance Agreement (DTAA) may see some headway with the island nation promising full cooperation with India to address outstanding issues relating to their bilateral tax treaty. The development comes days after Prime Minister Narendra Modi visited Mauritius. Its Finance Minister Seetanah Lutchmeenaraidoo in his Budget speech… – Continue reading

Kenya: KRA Wants Foreign Investors’ Tax Incentives Removed

Nairobi — The Kenya Revenue Authority (KRA) wants tax incentives offered to foreign investors withdrawn. The proposal to eliminate tax incentives and concessions offered to foreign investors is aimed at boosting revenue collection to accelerate national development. Speaking at the ongoing Biennial Ambassadors/High Commissioners conference in Kwale, KRA Commissioner General… – Continue reading

Guernsey: Will Guernsey Crack The Enigma Code?

Michael Betley, group chairman of Trust Corporation International looks at how Guernsey has coped in an increasingly transparent and regulated world and how it can adapt to further change in the future. Is Guernsey positioned to navigate its way successfully through the maze of initiatives designed to penetrate the legal… – Continue reading

Ghana and Netherlands sign agreement to fight tax evasion

Ghana and the Netherlands have signed a Memorandum of Understanding (MoU) for the Automatic Exchange of Information to help in efforts to fight tax evasion. The agreement would allow the tax authorities of the two countries to automatically provide each other with information about income from immovable property earned by… – Continue reading