Boris Johnson has a point about his U.S. tax bill, but he should still cough up. The London mayor objects to the fact that his dual UK and U.S. citizenship means he has been issued with an American tax bill, and he says he won’t pay. Though many U.S. expats… – Continue reading
DOUBLE taxation for companies and individual investors at the securities market could be scrapped in 2016, if a plan by the Capital Markets Authority is adopted. In a move to attract and grow investments, the Capital Markets Authority has initiated talks on a transparent tax regime, to eliminate multiple taxes… – Continue reading
New Delhi: Aiming to intensify government’s drive on black money, the PMO has asked the revenue department to look for ways other than bilater24al tax treaties to bring back funds stashed abroad. The Prime Minister’s Office (PMO) has suggested the tax department to think of other ways to tackle the… – Continue reading
The concept of base erosion and profit shifting (BEPS) has been debated at various international forums following discussions at the G20 Finance Ministers and Central Bank Governors meeting and the G20 Heads of State summit in Russia last year. The Organisation for Economic Co-operation and Development’s (OECD) BEPS Action Plan… – Continue reading
The concept of base erosion and profit shifting (“BEPS”) has been much discussed at various international forums including the G20 Finance Ministers and Central Bank Governors meeting in July 2013 in Moscow as well as the G20 Heads of State meeting in September 2013. From a South African perspective, the… – Continue reading
By closing the tax gap, South Africa can reap billions of rands to benefit the economy. A global crackdown on tax avoidance has begun and South Africa is forging ahead in a bid to tackle wealthy individuals and corporates who practise this tactic. The initiative is better poised to succeed… – Continue reading
Former treasurer Peter Costello and Future Fund chairman appears before the Finance Estimates committee at Parliament House. Photo: Andrew Meares Former treasurer Peter Costello has offered some veiled advice to the Abbott government on how to collect more tax revenue, saying it would be easier to tighten Australia’s domestic tax… – Continue reading
Cyprus and Iceland have released the text of a new double tax agreement signed between the two nations on November 14, 2014. The signing took place at the Embassy of Cyprus in Stockholm. The agreement caps the withholding tax on dividends income at source to five percent, if the recipient… – Continue reading
President Yahya Jammeh and the Emir of Qatar have signed two agreements on avoidance of double taxation and prevention of fiscal evasion on income and air services between The Gambia and Qatar. According to Qatar News Agency (QNA), the signing of the agreements between “the governments of the State of… – Continue reading
Washington, DC – Credit Suisse AG was sentenced today for conspiracy to aid and assist U.S. taxpayers in filing false income tax returns and other documents with the Internal Revenue Service (IRS). Credit Suisse pleaded guilty to conspiracy on May 19. The sentencing of the Swiss corporation is the result… – Continue reading
On September 16, 2014, the Organisation for Economic Cooperation and Development (“OECD”) released seven reports addressing certain aspects of the base erosion and profit shifting (“BEPS”) project. The seven BEPS reports released by the OECD include tax challenges of the digital economy (Action 1), hybrid mismatch arrangements (Action 2), countering… – Continue reading
Action 6 of the BEPS Action Plan identified treaty abuse as one of the most important sources of BEPS concern. The report offers alternative model provisions for the prevention of treaty abuse given constitutional and other restrictions that may apply to some treaty countries. Notwithstanding, each alternative shares a common… – Continue reading
Background In July 2013, the G20 Finance Ministers, including Australia, fully endorsed the base erosion and profit shifting (BEPS) Action Plan. As a result of the Action Plan, the Australian government encouraged a new commitment to focus resources on investigating international business structures to ensure companies pay tax in the… – Continue reading
People curious to know the amount of “black money” stashed by Indians in foreign banks may be in for yet another disappointment after the Supreme Court monitored Special Investigation Team (SIT), submits its findings. After six months in office, the Narendra Modi Government has not been able to lay its… – Continue reading
REGIONAL businesses continue to suffer from double taxation three years after a plan to harmonise taxes was approved, causing a delay in realisation of East Africa Community integration benefits. Kenya Association of Manufacturers CEO Betty Maina said the tax issue needs to be urgently addressed by ensuring all member countries… – Continue reading
Canada and Spain have signed a Protocol to their income tax convention which, when implemented, will reduce the withholding tax rates applicable on payments of dividends and interest. The Protocol was inked on November 18, 2014, by Canada’s Ambassador to Spain, Jon Allen, and Spain’s Finance Minister, Cristóbal Montoro. The… – Continue reading
UK and multinational enterprises are starting to consider (re)organising themselves under a UK holding company for their global operations, rather than using other traditional onshore holding company jurisdictions. This new trend is the result of a number of factors, which have moved the UK from an outside choice as an… – Continue reading
The Finance Bill 2014 (the “Bill”), which was published 23 October 2014, proposes a package of measures which focuses on Ireland’s tax rate, regime and reputation. The changes seek to reinforce Ireland’s position as a top destination for multinational companies and emphasise the importance of real and substantive foreign direct… – Continue reading
Thirty-five-year-old Rocky Martin travelled from his home in Sundre, Alta., to Tijuana, Mexico to get rid of his U.S. citizenship. And he saved himself about $1,800 by doing so. Martin, born in Canada, inherited U.S. citizenship from his mother, who registered him as an American born abroad when he was… – Continue reading
The United States has treaty language that allows us to work with the taxing authorities in other countries to collect U.S. taxes owed from U.S. Citizens or their property located in those countries and to allow those countries to have IRS collect from their citizens or property located in the… – Continue reading
A recent binding tax ruling recognised that the historical background of a multinational group is a key factor in considering whether a non-EU ultimate parent should trigger the anti-abuse rule which applies to exemption from dividend withholding tax. In a nutshell, the Spanish Non Resident Income Tax Law (NRIT), provides… – Continue reading
The New York Times’ report on prominent American think tanks receiving some $92 million from a minimum of 63 governments since 2011, prompted Rep. Frank Wolf (R-Va.) to ask Attorney General Eric Holder, a long overdue question: “Should think tanks be allowed to take undisclosed donations from foreign governments?” According… – Continue reading
A publication in the Economic Times has caused much debate in India since after blacklisting Cyprus for not sharing information on tax evaders, India is now looking to take away the favourable tax treatment available to investors from the European tax heaven under the bilateral tax treaty between the two… – Continue reading
The G20 Communique is good news on the international tax reform front. As part of the G20 commitment to boost economic resilience the Communique commits G20 nations to taking action to ensure fairness in the international tax system. This means they are looking at ways to ensure profits are taxed… – Continue reading
Recent months saw various important developments that are relevant to Sino-European trade and investment. These include (i) changes to the EU Parent-Subsidiary Directive, (ii) the entry into force of the double tax treaty between Luxembourg and Taiwan, and (iii) proposed changes to China’s Foreign Investment Catalogue and the Governmental Verifications… – Continue reading
Apex industry body ASSOCHAM has urged the Centre to amend the Indian income-tax law so as not to introduce the general anti avoidance rules (GAAR) from assessment year 2016-17 as India’s economy is neither mature enough to stand up to its exacting standards nor is the tax administration ready to… – Continue reading
ITR Correspondent In an effort to provide taxpayers with an integrated procedural framework for the negotiation of advance pricing agreements (APAs), the Greek Ministry of Finance recently released template application forms for both preliminary consultations and formal negotiations, as well as additional guidelines on the overall APA procedure. The forms… – Continue reading
Technical negotiations over an agreement to avoid double taxation by Taiwan and China have been completed, officials said on Thursday in Shanghai. Finance officials from both sides of the Taiwan Strait expressed their hopes for an early signing of the pact during a seminar on a global campaign against tax… – Continue reading
BRISBANE: Australia has vowed a “very aggressive” crackdown on tax avoidance at weekend G-20 talks, as a row rages over Luxembourg’s sweetheart arrangements with multinationals. Closing corporate tax loopholes and endorsing a common reporting standard to increase transparency are set to be a primary focus of the G-20 summit in… – Continue reading
(AFP) The OECD Friday forecast competition heating up among countries wanting to attract revenue from big digital companies like Apple and Google, even as a row rages over Luxembourg’s arrangements with multinationals. Closing corporate tax loopholes and endorsing a common reporting standard to increase transparency are set to be a… – Continue reading
Hybrid entities have long been a tool for corporate tax planning. While tax authorities have fought the use of such hybrid mismatches for tax planning purposes, national efforts to prevent the use of hybrid mismatches have not proven to be very efficient, explain Michael Graf and Timothy Santoli, of Dentons… – Continue reading
Cyprus and Iceland have signed a double taxation agreement based on the OECD Model Convention for the Avoidance of Double Taxation on Income and on Capital, the Finance Ministry said in a statement on Friday. By signing this agreement both countries aim to strengthen their trade and economic relations. “Updating,… – Continue reading
The Swiss Federal Council has adopted dispatches on five double taxation agreements, which will now be submitted to Parliament for approval. The treaties with Estonia, Ghana, Iceland, and Uzbekistan either replace or revise the current deals, while the agreement with Cyprus is Switzerland’s first with the territory. All of the… – Continue reading
Taipei, Nov. 14 (CNA) Taiwan and Canada have concluded negotiations on an agreement to avoid double taxation and are expected to sign the pact soon, President Ma Ying-jeou said Friday. Ma said during a meeting with visiting Canadian parliamentarians that Taiwan hopes to ink further bilateral agreements including an investment… – Continue reading
Y20 head on youth unemployment mission Countries may have to battle for revenue from digital companies once the global plan to stop tax avoidance succeeds, says the OECD’s head of tax Pascal Saint-Amans, but at least they now have something to fight for. In an exclusive interview with Fairfax Media… – Continue reading
Brisbane (Australia) (AFP) – The Organisation for Economic Co-operation and Development on Friday forecast competition heating up among countries wanting to attract revenue from big digital companies like Apple and Google, even as a row rages over Luxembourg’s arrangements with multinationals. Closing corporate tax loopholes and endorsing a common reporting… – Continue reading
The Federal Board of Revenue (FBR) has proposed that no exemption whatsoever from withholding tax under Eighth Schedule (Capital Gains Tax) of the Income Tax Ordinance 2001 is available to foreign institutional investors either on the basis of avoidance of double taxation treaties or for any other reason. Through an… – Continue reading
NEIL CHENOWETH Global accounting firm PwC was advising the Australian Taxation Office how to run its transfer pricing unit at the same time that its Luxembourg office was cutting favourable tax agreements for Australian companies. Luxembourg documents show PwC obtained secret tax agreements for more than 30 Australian companies in… – Continue reading
To help in its efforts to crack down on suspected black money stashed abroad, India has entered into an information exchange pact with Saint Kitts and Nevis, a two-island Carribean country, perceived as a safe haven for offshore funds. The agreement was signed by India’s Permanent Representative to the UN… – Continue reading
The ability of multinational companies to shift profits into low-tax jurisdictions is undermining governments’ ability to raise revenue. But the cross-border policy solutions are complex. Curbing international tax avoidance has become a focus of G20 discussion this week, after last week’s revelation that major companies including Ikea, AMP and Pepsi… – Continue reading
THE WORLDWIDE increase in digital commerce has alerted many countries to the unique tax challenges it presents. Facing up to tax challenges in the age of digital economy THE WORLDWIDE increase in digital commerce has alerted many countries to the unique tax challenges it presents. There is now a common… – Continue reading
New Delhi: Absence of criminal legal treaties between India and tax haven nations have been cited by probe agencies working in the SIT on black money as one of the major impediments in initiating steps to bring back illegal funds stashed abroad by Indians. These agencies, including the Central Board… – Continue reading
MINSK, 12 November (BelTA) – Belarus President Alexander Lukashenko has approved a draft intergovernmental agreement between Belarus and Georgia on avoidance of double taxation and prevention of evasion of income and capital taxes as a basis for further talks, BelTA learned from the presidential press service. The Ministry of Taxes… – Continue reading
Spain negotiated the largest rate reductions in its tax treaties with developing countries, out of 15 EU nations scrutinised for their record on international tax-dodging in the wake of the Luxembourg Leaks scandal. Developing countries were missing out on billions of much needed-revenue as a result of the tax rate… – Continue reading
HCMC – Foreign exchange control is a paramount concern of all foreign investors entering into Vietnam, as regulations on capital inflows and outflows have a great influence on operations and profit. Foreign exchange control includes transferring capital into and out of the country, opening and using bank accounts, borrowing foreign… – Continue reading
According to Bill Thompson, tax partner at Minter Ellison, Base Erosion and Profit Shifting (BEPS) — the base erosion referred to as the tax base and its implications for future tax structures — will be a key focus at the G20 Summit in Brisbane, with possible rapid changes to the… – Continue reading
With American taxpayers newly able to easily secure more favorable US tax treatment for Canadian retirement plans, American Citizens Abroad had requested that such treatment should be extended worldwide to all foreign pensions and retirement savings. Under the recent change, many Americans and Canadians with registered retirement savings plans and… – Continue reading
With the change in government in India, the world is looking up to its new Prime Minister Narendra Modi to revive the country’s economy, who recently launched his flagship ‘Make in India’ campaign to propel the country into top 50 of World Bank’s Ease of Doing Business rankings by 2016…. – Continue reading
Another sophisticated loophole in the tax system means the removal of the “Double Irish” tax-avoidance strategy won’t actually have any real impact for US firms in Ireland seeking to lower their tax bills. An influential US tax journal has found that the Irish subsidiaries of US companies can easily opt… – Continue reading
NEW DELHI: India’s attempts to amend tax treaties with countries such as Mauritius may have drawn a blank so far, but its efforts are about to get a huge boost with several nations getting together to ramp up work on a global convention to plug treaty abuse. “Multilateral convention will… – Continue reading
