Category: Tax treaties

ICC calls for enhanced coordination in the implementation of the G20 OECD BEPS project

The International Chamber of Commerce (ICC) has reaffirmed its active engagement in the second phase of the G20 / Organization for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) project while underscoring the importance of a coordinated and consistent approach to tax law changes. ICC continues to… – Continue reading

Singapore, France revise agreement to avoid double taxation

SINGAPORE: A revised Agreement for the Avoidance of Double Taxation (DTA) was signed between the Republic and France on Thursday (Jan 16). The revised DTA offers improved terms for businesses such as lower withholding tax rates for dividends and includes anti-abuse provisions, according to a joint press release on Friday…. – Continue reading

DEAL BETWEEN ISRAELI BANK AND U.S. GOVERNMENT COULD IMPACT MANY ACCOUNT HOLDERS

Potential impact on American citizens and Israeli citizens living in the United States should not be ignored January 14, 2015, St. Louis, Missouri…A historic agreement between Israel’s second-largest bank and the United States government could lead to substantial financial penalties or even potential criminal prosecution for United States citizens and… – Continue reading

UAE Tax Residents to Enjoy Better Tax Benefits While Funding Singapore Companies Now, says Rikvin in its New Guide

It explains how recent amendments to the Singapore-UAE Avoidance of Double Taxation Agreement will translate to more savings for UAE tax residents when they fund Singapore companies. Singapore (PRWEB) January 14, 2015 With the recent signing of the protocol to amend and improve the Singapore-UAE Avoidance of Double Taxation Agreement… – Continue reading

Budget 2015: Address tax issues, push data centre infra are Infy, Wipros’ request to Arun Jaitley

NEW DELHI: Top officials from IT, BPO and eCommerce sectors today requested Finance Minister Arun Jaitley to address certain issues related to taxation in the Budget 2015-16, and provide incentives for setting up data centres in the country. They also suggested that the minister look at ways to help in… – Continue reading

Ireland: Changes To Irish Corporate Residence Rules

On October 14 2014, Ireland’s Minister for Finance (the Minister) announced changes to Ireland’s corporate residence rules. Following much speculation, the Minister confirmed that Ireland would change its rules to restrict the ability of Irish incorporated companies to be treated as non-Irish resident. Under existing Irish law, an Irish incorporated… – Continue reading

Recent progress in the OECD’s BEPS project

Within the framework of the BEPS (Base Erosion and Profit Shifting) action plan, adopted in July 2013, on last September 16, the OECD published its first recommendations in the form of reports on 7 of the 15 points of the action plan: Address the tax challenges of the digital economy… – Continue reading

Lawmakers Re-introduce Bill to Curb Offshore Tax Havens

A pair of Democratic lawmakers in the House and Senate have re-introduced legislation aimed at preventing the abuse of offshore tax havens by multinational companies. Rep. Lloyd Doggett, D-Texas, a senior member of the tax-writing House Ways and Means Committee, and Sen. Sheldon Whitehouse, D-R.I., a member of the Senate… – Continue reading

American Business Problems with Hong Kong Bank Accounts? Singapore as an Answer

CDE Op-Ed CommentaryGiven the recent problems American trading companies are having in establishing bank accounts in Hong Kong, viable alternatives need to be found. These issues, which are directly related to the American IRS carrying out extensive investigations in Hong Kong concerning breaches of the new FATCA regulations, have made… – Continue reading

Solar Sukuk Marks Australia’s Debut Choosing Labuan Haven

(Bloomberg) — Australia is set to become the newest entrant to the Islamic debt market this year as a solar-power joint venture seeks to sell a debut sukuk in Malaysia’s offshore tax haven of Labuan. SGI-Mitabu, run by The Solar Guys International and Mitabu Australia Pty, has revived a plan… – Continue reading

The OECD’s BEPS Action Plan poses immediate challenges for oil and gas companies

Already on the radar of governments and regulatory bodies around the world, recent developments with respect to the Organization for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) Action Plan are raising further the profile of oil and gas companies globally with both tax authorities and the… – Continue reading

Switzerland, Italy Treaty Announcement ‘Imminent’

An announcement is expected imminently on the terms of the long-awaited revised tax treaty between Italy and Switzerland, reports say. According to a report from the ANSA news agency, the push to complete the treaty follows the parliamentary approval of Italy’s new voluntary disclosure program, which allows Italian residents to… – Continue reading

Business > America’s Shrinking Corporate Sector

SPECIAL REPORT:  IS AMERICA LOSING IT’S CORPORATE SECTOR? Corporate inversions have been the dominant tax issue over the last year and have forced a serious evaluation of the U.S. corporate tax system. While there is widespread agreement that the U.S. corporate tax code is out of step with our global… – Continue reading

UK Parliamentary Hearing Held On BEPS Response

British Members of Parliament (MPs) have questioned the Government’s unilateral decision to push for the introduction of a Diverted Profits Tax (DPT) ahead of the completion of the Organisation for Economic Cooperation and Development’s (OECD’s) work on base erosion and profit shifting (BEPS). In a debate held in Parliament on… – Continue reading

A two-minute nutshell on the UK’s proposed “Google Tax” – the “diverted profits tax” or “DPT”

The UK is proposing to introduce a unilateral, non-OECD co-ordinated anti-BEPS provision, referred to in the media as the “Google Tax”, with effect from 1 April 2015. The draft provision is very complex, and it will be time consuming to assess its potential impact on many common cross-border business structures…. – Continue reading

Voluntary disclosure in Israel- it’s time to become compliant

January 8 2015 As of 2003, Israeli tax residents are subject to tax in Israel on their worldwide income, including passive income (i.e., interest, dividends and capital gains) generated in their offshore bank accounts. Although more than a decade has passed, many Israeli residents have still not reported on income… – Continue reading

The Anti-Inversion Rules of Notice 2014-52: A Trap for the Unwary ‘Blocker’

From Premier International Tax Library With the publication in September of Notice 2014-52, the IRS has made it extremely difficult for any foreign corporation that is not primarily engaged in an active business to acquire a U.S. business in exchange for its stock without risking being transformed into a U.S…. – Continue reading

Singapore updates corporate tax guidelines to better align with West

SINGAPORE (Reuters) – Singapore is updating guidelines on an accounting practice mired in controversy for helping multinational companies minimize their tax bills, as the city-state moves more in line with a crackdown by Western governments on aggressive tax avoidance. International taxation has come under scrutiny since a quirk of “transfer… – Continue reading

A Guide to India’s Transfer Pricing Law and Practice – Part 1

India enacted transfer pricing rules in 2001, which require companies to conclude international transactions with associated enterprises at an arm’s length. The legislation is primarily targeted at large business groups who engage in base erosion and profit shifting to avoid paying corporate income tax in India. This article is the… – Continue reading

Tax Planning Considerations for the Purchase of a Residence in the U.S. by Foreign Buyers

Many factors influence a foreign buyer’s decision to purchase residential real estate in the United States. Generally, most of these decisions tend to be driven by concerns over political and economic uncertainty in the buyer’s home country. Most foreigners do not leave their home country, family, and friends for trivial… – Continue reading

Foreigner premium’ property taxes highest in Singapore and Hong Kong

Overseas property buyers have to pay significantly more tax than domestic buyers in Singapore and Hong Kong, making them the most costly places for foreigners to invest in residential real estate in Asia Pacific, says Knight Frank Singapore and Hong Kong are the most costly places for a foreigner to… – Continue reading

Spain and Andorra to combat tax fraud

PM’s trip to principality comes after Catalan ex-leader’s revelations about hidden accounts Prime Minister Mariano Rajoy is expected to sign an agreement that will include a system for automatically sharing tax information between Andorra and Spain during an official two-day visit to the principality that begins on Wednesday. The agreement… – Continue reading

Italy Introduces Patent Box

As a means of encouraging the development of intellectual property (IP) in Italy, rather than elsewhere, a “patent box” preferential tax regime has been introduced with effect from January 1, 2015, at the same time as a restructuring of the country’s research and development (R&D) tax credit system. Following the… – Continue reading

QROPS Tax Conundrum For Easy Access Drawdown

Easy access drawdown rules for Qualifying Recognised Overseas Pension Scheme (QROPS) come with a twist in the tail. The Treasury and HM Revenue & Customs (HMRC) have confirmed QROPS are included in pension reforms that start from April 6, 2015 – which means retirement savers can access their QROPS fund… – Continue reading

BEPS action plan 1: The digital economy

IN A PREVIOUS column (http://www.bworldonline.com/content.php?section=Economy&title=the-oecd-action-plan-on-base-erosion-and-profit-shifting&id=99561), we wrote about the general framework of the Base Erosion and Profit Shifting (BEPS) initiative, why addressing BEPS is a key priority for many governments across the globe, and the 15-point BEPS Action Plan drafted by the Organization for Economic Co-operation and Development (OECD). The… – Continue reading

Tax evasion by super rich hurts every Australian

We will probably never know their names, but one thing we do know – one in 20 of the richest people in Australia tried to evade paying their fair share of tax in recent years. By what authority do we know this? By none other than the Australian Taxation Office…. – Continue reading

TAX: India considers removing Cyprus from blacklist

India is considering removing Cyprus from the blacklist of countries that do not share details about tax evaders after examining information given the island nation, reports from New Delhi have suggested. India had blacklisted Cyprus in 2013 for not sharing information about tax evaders. “They (Cyprus) have given some information…. – Continue reading

Don’t run before you can walk – Russian deoffshorisation uncertainties

The new deoffshorisation legislation that passed with lightning speed through Russia’s Parliament and then hastingly signed by President Putin in the time span of a week and a half, comes into force on January 1, 2015. The new deoffshorisation legislation that passed with lightning speed through Russia’s Parliament and then… – Continue reading

SA must not miss out on e-commerce tax revenue, says Davis committee

SOUTH Africa’s tax authorities need to beef up the country’s tax laws and regulations to ensure it derives its rightful dues from the digital economy and e-commerce, the Davis committee says. The committee’s interim report on base erosion and profit shifting, released for public comment last week, said gaps in… – Continue reading

Tax systems and the 183 days’ rule

The conditions for becoming tax-resident and tax non-resident vary from country to country and depend on such things as length of stay, type of accommodation, location of family, and nationality. In most tax systems, presence of an individual in a country for 183 days or more in any 12-month period… – Continue reading

Zero corporation tax: the arguments for and against

Once a niche proposal, the recent public focus on corporate tax avoidance has sparked real interest in the idea of eliminating corporation tax altogether. Surprisingly, the statistics suggest that employees and other stakeholders may also benefit from this In winter 2012, hundreds of activists packed inside their local Starbucks after… – Continue reading

Analysis of Asia’s Tax Rates, Part 2: Withholding Tax

A withholding tax is a tax that is kept back from an employee’s salary and subsequently paid directly to the government. Withholding taxes are commonly employed by countries throughout the world to help combat tax evasion. Countries in Asia typically divide withholding tax into dividends, interest and royalties payments, with… – Continue reading

South Africa urged to finalise renegotation of Mauritius tax treaty

CAPE TOWN — South Africa needs to finalise the renegotiation of its tax treaty with Mauritius as soon as possible to prevent the loss of large sums of money through “treaty shopping” the Davis tax committee has urged. The committee released its interim report on ways to prevent base erosion… – Continue reading

News Round Up

Currently, there is a tendency among those who take an interest in international tax developments to look to the future and try to guess how the international tax landscape will look in, say, three of four years, once countries begin to implement the OECD’s base erosion and profit shifting (BEPS)… – Continue reading