Category: Tax treaties

India studying info provided by Cyprus on tax evaders

NEW DELHI, DEC 25: India will look at removing Cyprus from the blacklist of countries that do not share details about tax evaders after examining information given the island nation. India had blacklisted Cyprus last year for not sharing information about tax evaders. “They (Cyprus) have given some information. We are… – Continue reading

The Vatican Bank, Christmas Cheer, And FATCA

For centuries the inner workings of the Vatican Bank have been cloaked in secrecy. That was before Pope Francis, who has pledged to restore public confidence in the administration of the Roman Catholic Church. This week we learned the United States and the Holy See have brokered a FATCA agreement… – Continue reading

How Middle East Tax Laws Impact Foreign Businesses

Nilesh Ashar, partner and head of Tax for KPMG in the UAE, analyses the impact of investment regulations and tax laws on foreign businesses foraying into the Middle East. In the last decade, the Middle East region has witnessed significant economic growth, primarily driven by the surge in oil revenues…. – Continue reading

Japanese investment in Pakistan

Japan has remained a cornerstone of Pakistan’s economy for the past many years. Japanese Companies have invested in all sectors across Pakistan. Be it auto, trading, manufacturing, infrastructure development, packaging, steel manufacturing, indenting, etc a large number of Japanese Companies have a strong presence in Pakistan. Pakistan’s Investment and Corporate… – Continue reading

Yatseniuk: Dissolving convention with Cyprus over double taxation avoidance will not instantly end it

The decision by the Cabinet of Ministers of Ukraine and the possible future adoption by parliament of the bill dissolving a convention between the governments of Ukraine and Cyprus on the avoidance of double taxation and the prevention of tax evasion regarding income tax and the related protocol does not… – Continue reading

Business Lobby Urges Tax Amnesty for Reinvestment in Indonesia

Jakarta. A leading business lobby with strong ties to the administration of President Joko Widodo has called for a tax amnesty, in which the authorities will waive off past taxes and penalties to conglomerates and individuals parking billions of dollars worth of funds overseas, in a bid to reinvest that… – Continue reading

Lots of BEPS Output – What Outcome?

*Ernst & Young LLP, New York, NY The BEPS beat plays on. Congratulations to the OECD for meeting (mostly) the ambitious goals for release of their reports on seven action items in September 2014 – right on schedule on September 16. The documents released on September 16 relate to Action… – Continue reading

Gearing up for Obama’s visit: Finance Ministry to rush Cabinet note to sign US FATCA

NEW DELHI: The finance ministry is planning to rush through a Cabinet note seeking permission to sign an accord with the US on exchanging investment information before a December 31 deadline, ahead of President Barack Obama’s visit to Delhi at the end of January. The government has got the goahead… – Continue reading

The Year of Transparency’s Tipping Point

More countries are requiring an exchange of client information In 2014, we saw a marked increase in transparency regarding foreign assets. The United States took the lead, and other countries followed suit. It looks like we’ve reached the tipping point, that is, “the magic moment when an idea, trend, or… – Continue reading

Taiwan and South Korea may open negotiations on economic agreements: officials

TAIPEI, Taiwan — Taiwan and South Korea are now more prepared to sign economic agreements, such as investment insurance and double taxation prevention pacts, South Korea’s representative to Taiwan Cho Baek-sang said yesterday. Cho made the comment at the first Taiwan-South Korea humanities exchange conference, held by the de facto… – Continue reading

OECD document on international tax dispute resolution is “disappointing”, says expert

A discussion document on making dispute resolution mechanisms in international tax disputes more effective is does not provide enough answers to the questions it raises, an expert has said.19 Dec 2014 Tax Disputes and Investigations Tax Corporate tax International tax Europe Asia Pacific Middle East Africa It is “a disappointing… – Continue reading

Tax Inversions Wrap Up

There has been a recent surge in anti-tax inversion legislation discouraging companies attempting to shift corporate subsidiaries or headquarters to low-tax or tax-free countries. The issue was subjected to a great deal of publicity in April 2014 during the failed hostile takeover by Pfizer (NYSE:PFE) for AstraZeneca (NYSE:AZN) when Pfizer… – Continue reading

Luxembourg budget 2015 – main tax measures at a glance

Advance Agreements The so-called tax rulings and advance pricing agreements will be formalised by the introduction of appropriate provisions in the Luxembourg tax laws. By this means, Luxembourg will be able to offer as from 1 January 2015 a unified system providing taxpayers with legal certainty and a consistent and egalitarian… – Continue reading

US Business Attacks Proposed UK Diverted Profits Tax

The United States Council for International Business (USCIB) has warned that the United Kingdom’s proposal to impose a new tax on so-called “diverted profits” (DPT) would, if implemented, have a major impact on US-based multinational companies. The rules, contained in UK Government’s recent Autumn Statement, propose a 25 percent DPT… – Continue reading

Singapore, Indonesia on track to curb cross-border tax evasion

An agreement to help crack down on cross-border tax evasion is being worked on by Singapore and Indonesia. The two nations are working on implementing the framework for the automatic exchange of information (AEOI) on tax matters, as they look to keep improving trade and investment ties. The move was… – Continue reading

Netherlands – Tax regulation with Curaçao not effective before 2016

December 17:  The Dutch Ministry of Finance announced that a new regulation for the avoidance of double taxation between the Netherlands and Curaçao is expected to be effective beginning 1 January 2016. The Dutch government bill concerning this regulation is pending consideration by the Lower House. Once approved, the bill… – Continue reading

Japan, Qatar reach tax treaty agreement

TOKYO, Dec 17 (KUNA) — Japan and Qatar have reached a substantive agreement on a bilateral tax treaty that will help businesses and investors avoid double taxation involving the two countries, the Foreign Ministry announced Wednesday. The agreement aims to clarify the taxation on cross-border investment and economic activities between… – Continue reading

Government renegotiating tax treaties to curb flow of black money abroad, says Finance Ministry

To check illicit financial flows across borders, the government is renegotiating bilateral treaties with many countries to limit tax benefits to genuine investments and curb the routing of Indian money to safe havens, a senior Finance Ministry official said on Wednesday. While noting that the quantum of domestic black money… – Continue reading

OECD tax proposals threaten Irish deals with multinationals

Think tank targets key aspects of Republic’s role in multinationals’ tax affairs Key features of Ireland’s role in the tax affairs of major technology companies such as Google and Microsoft are being targeted by the OECD’s base-erosion and profit-shifting (Beps) project, it has emerged. Ideas being worked on by the… – Continue reading

Singapore, Indonesia to enhance cooperation on sharing tax information

Singapore’s Ministry of Finance say both parties enjoy “excellent cooperation” regarding tax matters, and have agreed to update the existing Avoidance of Double Taxation Agreement as the next step. SINGAPORE: The Republic and Indonesia will be looking to increase cooperation on the sharing of tax information in the coming days,… – Continue reading

New bilateral investment treaties will help India avoid arbitration

NEW DELHI: Bilateral investment treaties that the government will enter into from now on will have a provision preventing foreign investors to drag India to arbitration on any issues that have been settled by a judicial authority. Wiser from being dragged to arbitration in numerous cases, such as the Vodafone… – Continue reading

Tax transparency applied to all is Odier message from Swiss banks

Defending the interests of the Swiss banking industry has not been the easiest challenge in recent years, particularly when it comes to tax. The role has fallen for the last five years to Patrick Odier, chairman of the Swiss Bankers’ Association (SBA), which has 317 institutional members and about 18,500… – Continue reading

1 FATCA Update: Treasury Extends Time for Jurisdictions with Agreed-in-Substance IGAs to be Treated as if They Had an IGA in Effect

On December 1, 2014, Treasury and the IRS issued Announcement 2014-38 which provides relief to those countries which have reached FATCA Intergovernmental Agreements (IGAs) in substance, but have not signed such agreements. Background In 2012, Treasury and the IRS released Model 1 and Model 2 IGAs to implement the Foreign… – Continue reading

Saudi- Ernst 1amp Young hosts seminar on Zakat regulations

(MENAFN – Arab News) Ernst & Young one of the world’s leading professional services organizations hosted the 12th annual tax seminar on recent updates on Saudi Arabian zakat regulations and corporate income tax Law and its bye-laws in Jeddah on Thursday. Over 100 executives bankers and accountants attended this Seminar…. – Continue reading

The inversion backlash

Something strange happened in 2014 — Americans became very interested in corporate tax policy. It started in the spring, when U.S.-based pharmaceutical giant Pfizer, which produces blockbuster drugs like Lipitor and Viagra, floated a possible merger with its British-based rival AstraZeneca. Normally a merger of that size would make a… – Continue reading

United States: Foreign Entity Payees Of U.S. Source Income: Learn How To Fill Out IRS Form W-8BEN-E

In prior advisories, we have discussed the new withholding tax law commonly known as “FATCA” (standing for “Foreign Account Tax Compliance Act”). (See “FATCA’s July 1 Effective Date Has Arrived; Last-Minute Guidance Has Been Issued” and “Last Substantial Package of FATCA Regulations Released; Deadlines Approaching”.) To help implement FATCA, the… – Continue reading

OECD Wants Broad Access For BEPS Transfer-Pricing Reports

Law360, New York (December 15, 2014, 5:52 PM ET) — Coming guidance from the Organization for Economic Cooperation and Development’s base erosion and profit shifting project on the implementation of the country-by-country reporting of financial information for transfer-pricing purposes will seek to make those reports as broadly accessible to governments… – Continue reading

ACCA raises concerns with Diverted Profits Tax

The government’s plans to implement a Diverted Profits Tax (DPT) have been questioned by the Association of Chartered Certified Accountants (ACCA). Chas Roy-Chowdhury, head of taxation at the body, said nobody wants profits that should be subject to UK tax “escape the net”. As a result, he believes it is… – Continue reading

Foreign Holders of Mexican Debt Securities Should Hold a Little Longer

Gains derived from the sale of Mexican public debt instruments listed abroad between two foreign tax residents will soon be exempt from Mexican tax. Currently, for Mexican income tax purposes, any gains derived from the transfer of publicly-traded bonds, securities and other credit instruments are treated as interest. If the… – Continue reading

Black money conundrum

The wise thing is to forget the past, bring reforms to prevent generation of black money Considering other man’s point of view is Decency — George Orwell This quality seems to be in short supply in India although it is the most needed even to understand any black money retrieval…. – Continue reading

The OECD action plan on Base Erosion and Profit Shifting

IN TAX, the latest global buzzword is “BEPS” or base erosion and profit shifting. BEPS refers to the practice of multinational corporations (MNCs) of shifting profits from high tax jurisdictions to low tax jurisdictions as a tax mitigation strategy. In February 2013, the Organization for Economic Co-operation and Development (OECD)… – Continue reading

How Google and Apple Make Their Taxes Disappear

Around the world, countries are desperately seeking ways to stop multinational companies from earning profits within their borders without paying taxes on them, while stashing trillions in tax havens like the Cayman Islands. The British government, after a search, says it knows how to tax the profits Google earns in… – Continue reading

Exemptions, concessions: FBR suffers Rs 361 billion annual loss

The Federal Board of Revenue (FBR) is suffering massive revenue loss of Rs 361 billion per annum on account of estimated tax expenditure in direct taxes, ie, equivalent to 1.6 percent of the Gross Domestic Product (GDP) as a result of exemptions and concessions to various sectors. Former Finance Minister… – Continue reading

Investor protection agreement negotiations to begin soon

Dubai: Hong Kong and the UAE will soon start negotiations to sign an investor protection agreement on a bi-lateral basis, John C Tsang, Financial Secretary of Hong Kong told Gulf News during his visit to the UAE. “The agreement will create a lot more comfort for people who are investing… – Continue reading

IT’S OFFICIAL: RS4,479 CR STASHED IN SWISS BANKS

The Income Tax Department has informed the Special Investigation Team (SIT) on Black Money that prosecution proceedings for non-furnishing of account details by Indians stashing black money abroad are in progress in 27 cases (under Section 276 D of the I-T Act) and has even filed a case in court… – Continue reading

Bombardier among companies using legal tax havens at expense of home country

MONTREAL – The problem is not that Bombardier Inc. played a complex shell game since at least 2010 by refinancing and redirecting US$500 million of its financing activities to Luxembourg, a notorious tax haven. It’s that it does so legally — and is hurting its home country despite being one… – Continue reading

Taxing Diverted Profits: The Empire Strikes Back

There’s big news from across the pond. The U.K. government’s Autumn Statement (formerly known as the pre-Budget report), released December 3, promises to change how multinational corporations will be taxed – and offers a cautionary tale for would-be U.S. tax reformers. Britain will introduce a “diverted profits” tax, targeting corporations… – Continue reading