Category: Tax treaties

Massie: Stop taxing Social Security recipients

NKY congressman says that current system amounts to ‘double taxation’ on people. His bill could save some seniors thousands of dollars. Are you a higher-income Social Security recipient who must pay federal taxes on your benefits? U.S. Rep. Thomas Massie is your friend. Massie, R-Garrison, last week introduced the latest… – Continue reading

Merge inheritance tax and capital gains tax, says Institute of Directors

Capital Gains tax and inheritance tax should be merged to prevent wealthy homeowners being taxed twice, IoD suggests Capital gains tax and inheritance tax should be merged to prevent wealthy homeowners being taxed twice, according to the Institute of Directors. Taxes raising less than £5billion a year should be merged… – Continue reading

Nepal, Bangladesh to sign DTAA

KATHMANDU, Jan 30: Nepal and Bangladesh on Thursday agreed to sign Double Taxation Avoidance Agreement (DTAA). Issuing a statement on Thursday, Inland Revenue Department (IRD) said the fourth round of meeting for DTAA held in Kathmandu took the decision. Director General of Inland Revenue Department (IRD) Chudamani Sharma and Head… – Continue reading

Nepal, Bangladesh to sign DTAA

KATHMANDU, Jan 30: Nepal and Bangladesh on Thursday agreed to sign Double Taxation Avoidance Agreement (DTAA). Issuing a statement on Thursday, Inland Revenue Department (IRD) said the fourth round of meeting for DTAA held in Kathmandu took the decision. Director General of Inland Revenue Department (IRD) Chudamani Sharma and Head… – Continue reading

EU Signs Off On Enhanced Parent-Subsidiary Directive

On January 27, 2015, the Council of the European Union formally adopted a decision to add a binding anti-abuse clause to the EU Parent-Subsidiary Directive. The anti-abuse clause, which was agreed by the Economic and Financial Affairs Council on December 9, 2014, aims to prevent misuse of the Directive and… – Continue reading

Grappling with inversions: UK “Google tax” addresses corporate diverted profits

In November 2012, a startled TV audience watched coverage of the House of Commons Select Committee questioning Google’s chief executive about why his business, with ostensibly billions of pounds in sales generated in the UK, accounted for UK corporation tax in an amount equivalent to the price of a single… – Continue reading

Grappling with inversions: UK “Google tax” addresses corporate diverted profits

In November 2012, a startled TV audience watched coverage of the House of Commons Select Committee questioning Google’s chief executive about why his business, with ostensibly billions of pounds in sales generated in the UK, accounted for UK corporation tax in an amount equivalent to the price of a single… – Continue reading

Important royalty withholding tax decision

Introduction The taxpayer, Seven Network Limited, has won a recent decision (22 December 2014) in the Australian Federal Court, Seven Network Limited v Federal Commissioner of Taxation (2014) FCA1411, which is significant to all broadcasters, particularly involving the delivery of live sport and other entertainment. Briefly, the key issue raised… – Continue reading

Global Tax Transparency Rising in 2015 As FATCA, OECD Initiatives Gain Momentum

Jan. 23 — The growth of global tax transparency is expected to leap ahead in 2015—meaning companies, individual taxpayers and financial institutions must exercise new levels of caution, practitioners told Bloomberg BNA. With more than 100 intergovernmental agreements under the Foreign Account Tax Compliance Act and dozens of countries signing… – Continue reading

Gibraltar ‘very well positioned’ for fully-flexible QROPS

A legislative amendment leaves Gibraltar “very well positioned” to follow Malta’s lead in adapting to HM Revenue & Customs introduction of full flexibility to Qualifying Recognised Overseas Pension Schemes (QROPS). At the end of December last year, HMRC issued draft legislation to allow QROPS full flexibility in drawing pension benefits… – Continue reading

UK Patent Box regime – update

On 11 November 2014, the UK and German governments issued a joint statement on proposals for new rules for preferential intellectual property (IP) regimes within the G20/OECD base erosion and profit shifting (BEPS) project. Germany currently does not have a special regime for Patent Boxes, but suffers from structures that… – Continue reading

January Global Tax-News Update

This edition of the Tax-News monthly feature takes in noteworthy events in the international tax arena, including attempts to inject new life into the campaign for comprehensive tax reform in the United States, and developments in the areas of free trade, indirect taxation, BEPS and tax transparency and compliance. US… – Continue reading

Neutralizing the effects of Hybrid Mismatch Arrangements

IN THIS second installment of the series on Base Erosion and Profit Shifting (BEPS) 2014 deliverables, we will discuss the recommendations of the Organization for Economic Co-operation and Development (OECD) on how to neutralize the effects of Hybrid Mismatch Arrangements. A Hybrid Mismatch Arrangement refers to an arrangement whereby companies,… – Continue reading

How to navigate Obama’s new tax proposals if you own property in the U.S.

While President Barack Obama’s new tax proposals may never see the light of day, given the Republican majorities in both the House and Senate, they have generated discussion among cross-border tax practitioners. Dual citizens living in Canada or Canadians who own U.S. properties may wonder whether they need to reopen… – Continue reading

Agreement delivers new protocol to Switzerland-Italy tax treaty

A year in review: the far reach of the IRS in Canada – Foreign Account Tax Compliance Act What is FATCA? The Foreign Account Tax Compliance Act1 (“FATCA”) was enacted by the United States Congress in order to deal with non-compliance by US taxpayers using foreign bank accounts. FATCA requires… – Continue reading

Tax cafe: The FATCA conundrum deepens for India

The Foreign Account Tax Compliance Act (FATCA) is a new chapter in the US Internal Revenue Code. Chapter 4 was added by the Hiring Incentives to Restore Employment (HIRE) Act. It seeks to identify US taxpayers having accounts at foreign financial institutions (FFIs) and attempts to enforce reporting of those… – Continue reading

Keen interest in DTA with Israel

NEGOTIATING A DOUBLE  Taxation Agreement (DTA) with Israel was a major talking point when that country’s Ambassador to Barbados, Mordehai Bivas, paid a courtesy call on Minister of Foreign Affairs and Foreign Trade, Senator Maxine McClean at her Culloden Road headquarters. Senator McClean told the Ambassador: “One of the things… – Continue reading

Techie fee thorn in US ties

New Delhi, Jan. 23: India and the US have failed to make much progress in the totalisation pact that addresses the the problem of the double payment of social security taxes by Indian software professionals in America, dampening expectations surrounding President Barack Obama’s visit this weekend. Top officials said discussions… – Continue reading

Corporate Tax Deal to be Signed With U.S.

India has worked out a bilateral tax agreement with the United States, which could be signed during U.S. President Barack Obama’s visit, that would boost foreign investment and ease investors’ concerns raised by high profile cases against Vodafone and Shell. The pact, which industry executives say would specifically target the… – Continue reading

China, Switzerland to enhance financial cooperation

Premier Li Keqiang (Left) meets with Simonetta Sommaruga, president of the Swiss Confederation, in Davos, Switzerland, Jan 21, 2015.[Photo/english.gov.cn] China will give Switzerland an investment quota of 50 billion yuan ($8.05 billion) under its Qualified Foreign Institutional Investors (QFII) scheme to support the establishment of the Zurich offshore renminbi market,… – Continue reading

Tax Agreements with France and Uruguay will benefit Singapore companies looking to Expand, says Singaporecompanyincorporation.sg

With the city-state revising its earlier avoidance of double taxation agreement with France and signing a new one with Uruguay recently, a boost in cross-border trade is inevitable. Singapore (PRWEB) January 22, 2015 In what can be termed as two important milestones in Singapore’s trade relations with Europe and Latin… – Continue reading

A Guide to India’s Transfer Pricing Law, Part 2: Should BEPS be on India’s Radar?

In the first of this two part article, we outlined what businesses must do to comply with India’s transfer pricing laws, while stressing the key reforms introduced by the new government to bring certainty to the domestic tax system. Here, we discuss if and how India should respond to the… – Continue reading

Obama in India: India, US finalise framework to resolve transfer pricing cases

NEW DELHI: India and the US have finalised a framework to resolve transfer pricing cases, some of them pending for five years, in what could end tax trauma for more than 50 American MNCs such as Microsoft, IBM and Oracle by the fiscal year-end and send a strong signal to… – Continue reading

Stakeholders see double taxation as challenge to REITs investment

Stakeholders in Real Estate Investment Trusts (REITs) have identified double taxation as challenge to investment in the sector, even as they clamour for enabling legislation. In order to make the Real Estate Investment Trusts (REITs) a tax-effi¬cient vehicle for invest¬ment, there is an urgent need for an enabling leg¬islation, they… – Continue reading

North East business and airport leaders concerned region to be made guinea pig for tax reforms

SUCCESSFUL INTERNATIONAL STRUCTURES in most cases begin with choosing the right jurisdiction to host a company that will form part of an international business. Depending on the company’s activities, the choice will depend on the range of double taxation treaties and the availability of tax reliefs followed by a host… – Continue reading

Secrecy must be respected in tax information exchange: Germany

The thrust of the Indian government’s economic policy is encouraging, particularly the tax reform of proposed introduction of goods and services tax. NEW DELHI, JAN 20: Germany has made a case for ‘respecting the secrecy’ of any information shared with India for tax administration purposes. This stance assumes significance given… – Continue reading

Turning the black money tide: It will require reforms in taxation and real estate transactions

Voltaire wrote “If you see a Swiss banker jumping out of a window, follow him, there is sure to be a profit in it”. Following this train of thought India is seen to be ruined by a cartel of Swiss bankers, terrorists and corrupt industrialists. Unlimited black money is apparently… – Continue reading

Turning the black money tide: It will require reforms in taxation and real estate transactions

Voltaire wrote “If you see a Swiss banker jumping out of a window, follow him, there is sure to be a profit in it”. Following this train of thought India is seen to be ruined by a cartel of Swiss bankers, terrorists and corrupt industrialists. Unlimited black money is apparently… – Continue reading

New bilateral tax Treaty agreed in principle between Italy and Switzerland

After almost three years’ negotiations over untaxed Italian assets in Swiss banks, Switzerland and Italy have reached an agreement in principle on future cooperation in tax matters. The agreement between Switzerland and Italy was initialled on 19 December 2014 The two governments are currently preparing the signature of a Protocol… – Continue reading

Cayman Islands: Caribbean IFCs: Well Regulated Parts Of The International Furniture

Observers of offshore financial centres will know that post 2008 they have been weathering a perfect storm. Firstly, reduced transactional flows, simply because there is less money available for structured finance and investment generally. Secondly, a constant barrage of negative publicity, which deliberately seeks to conflate tax evasion and tax… – Continue reading

Malta: Taxation Of Private Pensions

Introduction Malta is increasingly becoming a financial services centre of repute looked at by a number of financial services operators as the ideal platform to set up their private pension schemes. Malta’s success is attributable to the flexible and prudent manner in which the industry is regulated, providing the desired… – Continue reading

Switzerland, Italy Reach Agreement On Tax Treaty

Italy and Switzerland have agreed an amendment to their double tax agreement to enhance tax information exchange provisions. It is hoped that the agreement will be signed before the March 2 deadline set by Italy’s new voluntary disclosure program to enable Switzerland’s removal from Italy’s “black list.” After three years… – Continue reading

Agreement reached on Swiss-Italian tax issues

Switzerland and Italy have reached an agreement in principle on future cooperation in tax matters. Negotiations with Italy over untaxed Italian assets in Swiss banks have been running for two and a half years. The agreement will facilitate the processing of the Italian voluntary disclosure programme recently adopted by Italy’s… – Continue reading