Category: Tax treaties

Government of Canada Strengthens Collaboration With the United Kingdom

Minister of National Revenue concludes two days of meetings in London LONDON, ENGLAND–(Marketwired – Sept. 9, 2014) – Canada Revenue Agency The Honourable Kerry-Lynne D. Findlay, P.C., Q.C., M.P., Minister of National Revenue, today wrapped up a successful two-day trip to London, England. During her visit, Minister Findlay met with David… – Continue reading

Scrap Withholding Tax & MAT on Japanese Companies In India: Suggests Minister, Embassy Of Japan

Minister, Embassy of Japan Mr. Isomata Akio asked India to exempt Japanese manufacturers, operating in India from withholding tax and Minimum Alternate Tax (MAT) so that these do not evolve into being one of the trade barriers and stagger Japan from becoming India’s largest trade partner in times to come. Japan investments and technology… – Continue reading

The Abrahamsens’ Case Did Not ‘Finnish’ Well: Taxation of Government Employees

A recent Tax Court decision1 addressed the tax consequences to a Finnish citizen of wages she received while working as an employee in the United States on behalf of her country’s Permanent Mission to the United Nations. The case involves Sole Abrahamsen, a Finnish citizen, who began working at Finland’s Permanent… – Continue reading

Doubts mount about Valeant Pharmaceuticals’ tax structures

MONTREAL – The disclosure by Valeant Pharmaceuticals International Inc. that it is under audit by the U.S. Internal Revenue Service is raising further doubts among tax specialists about the future of the Quebec-based drug company’s tax strategies. Valeant estimates it has achieved US$2.5-billion in tax and other “corporate structure” savings… – Continue reading

Delhi HC joins dots on indirect transfer debate

The verdict serves as reference for invoking treaty abuse provisions in the absence of General Anti-Avoidance Rules Mukesh Butani  September 7, 2014 Last Updated at 22:33 IST In a ruling demonstrating wise judicial discipline, the Delhi High Court (HC) recently upheld non-taxability of sale of shares in an offshore company… – Continue reading

Who owes where?

This article was first published in the 2nd quarter 2014 edition of Personal Finance magazine. Your tax liability in the country in which you live and/or work depends on the tax laws of that particular country. Countries can levy taxes on a residence basis, because you live in the country,… – Continue reading

India Eyes Tax On £350 Billion Cash Hidden Offshore

The Indian government’s bid to unearth black money stashed away in hidden offshore accounts is starting to pay off. The government believes around £350 billion is hidden in undeclared bank accounts and investments outside the country and wants to bring the tax owed on the money back to India. Nine… – Continue reading

Crackdown on Tax Treaty Abuses

Tax authorities throughout the world are cracking down on taxpayers – individuals and corporations – that utilize some aggressive tax planning strategies. While most of these schemes are perfectly legal and merely take advantage of loopholes in theinternational tax system, there is a growing concern that they not only threaten… – Continue reading

The Real Tax Benefits of Inverting to Canada

On August 26, Burger King announced that it entered into an agreement to acquire Tim Hortons, Inc., the Canadian coffee-and-doughnut chain, in a transaction that will be structured as an “inversion” (i.e., Burger King will become a subsidiary of a Canadian parent corporation).  The deal is expected to close in 2014… – Continue reading

The cost of cutting ties with Uncle Sam soar: Tim Harper

Americans living in Canada are in a rush to renounce their citizenship in the face of Washington’s invasive tax grab. OTTAWA – Thomas Jefferson is famously believed to have defined the price of freedom as eternal vigilance. The price of freedom from Uncle Sam is a lot steeper. Faced with… – Continue reading

No request to retrieve ‘$200 billion’ in Swiss banks, says Swiss envoy

ISLAMABAD: Pakistan has not requested for negotiations on exchange of information for restitution of any ill-gotten money presumably stashed in Swiss banks, said Swiss Ambassador to Pakistan and Afghanistan Marc George on Monday. The statement from the Swiss ambassador follows claims by Finance Minister Ishaq Dar that talks would be held with… – Continue reading

Bern talks to focus on taxation treaty

ISLAMABAD: Pakistan and Switzerland will begin technical level negotiations in Bern on Tuesday for revision of ‘Swiss-Pakistan Convention for the Avoidance of Double Taxation’ to enable the treaty to create an environment for better trade and investment between the two countries. The three-day meeting is being held on the request… – Continue reading

Germany-Israel Update Double Tax Arrangements

Israeli Finance Minister Yair Lapid and his German counterpart, Wolfgang Schäuble, signed a revised German-Israeli double taxation agreement in Berlin on August 21, 2014, according to a recent announcement from the German finance ministry. The convention, which was last amended in 1977, has been adapted to make it correspond to… – Continue reading

Govt eyes more tax holiday deals

FRANCISTOWN: Government’s negotiations with other countries to sign Double Taxation Avoidance Agreements (DTAA) are underway to ensure investor benefits from tax holiday incentives continue, Boniface Mphetlhe of Ministry of Trade and Industry (MTI) has said. The Deputy Permanent Secretary in MTI, Mphetlhe, was speaking on the topic of Botswana Investment… – Continue reading

The Global Crackdown on Profit Shifting

CFOs of multinationals need to prepare by assessing how much their companies engage in profit shifting to cut their taxes. Do you have responsibility, whether direct or dotted line, for the tax function in your company? Does your company have, or plan to have, operations outside the United States? If… – Continue reading

Double Tax Arrangements in Nigeria: Imperatives for a wider network

THE National Tax Policy (NTP) has identified double taxation as one of the major hindrances to the growth of the Nigerian economy. Double taxation has become an issue paramount to investors and top executives of multinationals as income is generally taxable both in source and residence countries. In order to… – Continue reading

FATCA Alert: IRS Issues Final Version of the Form W-8BEN-E and Accompanying Instructions

On June 25, 2014, the IRS finally issued the instructions to the new version of Form W-8BEN-E, an 8-page withholding certificate to be completed by foreign entities. Previously, foreign individuals and most foreign entities would provide a one-page Form W-8BEN to withholding agents to certify the foreign entity’s entity classification… – Continue reading

Billionaire Eugene Melnyk: I’m a ‘whistleblower’ on tax allegations against Valeant

MONTREAL • Eugene Melnyk, the billionaire owner of the Ottawa Senators and founder of drug maker Biovail Corp., is waging war against the company that now controls his one-time business. Mr. Melnyk alleges that Valeant Pharmaceuticals International Inc. is masquerading as a Canadian company to make use of this country’s… – Continue reading

The implications of FATCA in South Africa

The Foreign Account Tax Compliance Act (FATCA) was enacted in 2010 by the US to target non-compliance by US taxpayers using foreign accounts. FATCA essentially requires foreign financial institutions to report information about financial accounts held by US taxpayers, or by foreign entities in which such taxpayers hold a substantial… – Continue reading

Another French footballer on tax evasion radar

Switzerland is cooperating with French tax authorities over an investigation of alleged tax fraud involving former French footballer Marcel Desailly. The notice of Swiss cooperation was published on Tuesday in the Federal Gazette. Desailly, captain of the French football team from 2000 to 2004, allegedly holds or has held assets… – Continue reading

Our Swiss dilemma

With new laws in place, recovery from Swiss banks can be little easier provided the government shows sincerity in taking action against tax dodgers   Finance Minister Senator Ishaq Dar in recent days has expressed the government’s firm conviction to bring back untaxed money of “US$ 200 billion” stashed in… – Continue reading

Franking credits a key part of Australia’s economic machine

The sharemarket has settled into a consolidation phase at between 5400 and 5600 index points, mirroring changes in overseas markets. While analysts are confident the current reporting period will not produce unexpected changes to their forecasts, international political instability makes further upward movement in prices unlikely. Compared with overseas markets… – Continue reading

Stock options in an international context: treatment of an indemnity for waiving stock options, received by a corporate officer within the meaning of the tax treaty between France and the United Kingdom

In its October 4, 2013 decision, no. 351065, Mr. Clive Worms, the French Administrative Supreme Court reiterated that, under domestic tax law, an indemnity received by a French tax resident in compensation of his cancelled stock options qualifies as a compensation for work. On the day the options were granted, the… – Continue reading

Expats urged to review sources of UK income amid tax raid plans

Property owners and pensioners who face losing their personal tax allowances can take steps now to protect themselves, say experts Expats facing the possibility of losing their personal allowance under a tax raid proposed by George Osborne should not panic but look carefully at where their UK sources of income… – Continue reading

Black money: India gets 24,000 pieces of secret foreign data

New Delhi: In its effort to unearth black money stashed away abroad, India has received data on over 24,000 instances of alleged tax evasion and dubious funds, which has been detected in foreign shores in the last financial year. These cases are now under investigation by the taxman even as… – Continue reading

Local Law Shopping Through “Derivative Benefits” re: Tax on Foreign Income

Unlike U.S. persons who are subject to U.S. federal income tax on their worldwide income, foreign persons generally are subject to U.S. taxation on two categories of income: (i) certain types of passive U.S.-source income (e.g., interest, dividends, royalties and other types of “fixed or determinable annual or periodical income,”… – Continue reading

Asia-Pacific Tax Forum proposed

BANGKOK: The United Nations’ Economic and Social Commission for Asia and the Pacific (ESCAP) has proposed to the regional countries creation of an ‘Asia-Pacific Tax Forum’ to monitor tax legislation and regulations across the region. This is to help develop regional best practice and address issues such as avoidance of… – Continue reading

Profit shifting ‘just a part’ of Africa tax loss

MULTINATIONAL companies shifting their profits from Africa to low-tax jurisdictions are only partly responsible for the erosion of the continent’s tax revenue bases. The African Tax Administration Forum (Ataf) believes some countries have signed away their tax revenue because of weak domestic policies, and ill-conceived tax incentives and mining contracts…. – Continue reading

Russian FM Provides Anti-Offshore Law Update

Russia’s Finance Minister, Anton Siluanov, has told President Vladimir Putin that a new bill to deter Russian tax residents from hiding income offshore is expected to raise about RUB30bn (USD844m) from overseas accounts in Cyprus and the Netherlands. During a Government meeting on July 30, 2014, Siluanov explained that entrepreneurs… – Continue reading

Singapore becomes the fourth signatory of double taxation agreement with Seychelles this year

Seychelles News Agency) – The Seychelles islands and Singapore have concluded a double taxation avoidance agreement, which will allow businesses operating in the two countries to pay tax in one of the jurisdictions and avoid taxation in the other, which is expected to encourage trade and investment between the two… – Continue reading

Polish Lower Chamber Approves Proposals on Tax Treatment of Foreign-Controlled Companies

June 30 — Poland’s Sejm, the lower house of parliament, June 26 approved proposals to introduce guidelines to distinguish a foreign-controlled company for tax purposes, and approved Poland’s agreement for the avoidance of double taxation with the United Arab Emirates, as well as its tax information exchange agreements with Bermuda,… – Continue reading