Category: Statutory

FPI holdings from Singapore, Mauritius surge 25% before DTAA implementation

Grandfathering is term for alteration of rules that apply to a certain investment technique Foreign portfolio investors (FPIs) based in Mauritius and Singapore had, it now appears, rushed to take advantage of the ‘grandfathering’ clause in the new Double Tax Avoidance Agreement signed between both the governments of the two...

Tax on offshore investments: time to come clean

The South African Revenue Service (SARS) launched the Special Voluntary Disclosure Programme (SVDP) in October 2016, providing taxpayers with the opportunity to make good on any tax and/or exchange control contraventions of which they may be guilty in relation to offshore investments. The nine-month window period opened on October 1,...

Labour plans £26billion ‘Robin Hood’ tax raid on the City in a bid to finance its manifesto and ‘restore fairness to the system’

John McDonnell said levy would bring in up to £26billion over next parliament Move likely to face criticism it will undermine competitiveness in financial sector Labour vowed to carry out ‘biggest crackdown in UK’s history’ on tax avoidance Labour is pledging to impose a ‘Robin Hood Tax’ on financial transactions,...

Regulatory Issues: Financial account information exchange for increased tax compliance

Malaysian individuals and entities that have bank accounts overseas will soon see their financial information being shared with other countries and tax authorities in an effort to boost global transparency and tax compliance. This requirement is part of the automatic exchange of financial account information set out by the Organisation...

Australian Budget Targets Housing, Tax Compliance

Australian Treasurer Scott Morrison’s 2017 Budget focused on measures to cool the housing market and crack down on tax avoidance. Morrison handed down the Budget on May 9. He said the the budget would return to a surplus in 2020-21 and remain in surplus over the medium term. The Budget...

Budget 2017: “Black economy”, multinationals in spotlight as government focuses on tax integrity

The federal government has pledged to create more fairness for businesses and “level the playing field” through a series of budget measures directed at tackling Australia’s so-called “black economy”. The government gave its “black economy taskforce” the job of investigating how individuals and businesses use cash payments in December 2016,...

Invoicing scam

THE Fiji Revenue and Customs Authority has uncovered a scam where companies hire graphic artists to manipulate the value of overseas invoices. Speaking on the global move towards greater financial disclosure, FRCA director corporate services Fazrul Rahman said a Fiji company was under the microscope for incorrect invoicing. “This Fiji...

License barrier as of January 2018: Limited tax deductibility for cross license order royalty payments to foreign related parties

Germany will introduce “license barrier rules” as of January 2018. The new rules will limit the tax deductibility of license fees or royalty payments to foreign related parties that benefit from preferential regimes (“Patent Box”, “IP-Box”, “License Box”) which are incompatible with the “OECD nexus approach” (“unqualified preferential regimes”) (sec....

Russia introduces draft law on country-by-country reporting requirements: implications for multinationals

A newly published federal draft law introduces Russia to a three-tiered approach to transfer pricing documentation and brings Russian regulations in this area in line with the OECD minimum standards under Action 13 of the Base Erosion and Profit Shifting (BEPS) Action Plan. The draft law, published by the Ministry...

Trump’s tax plan could have rich New Yorkers fleeing for Florida

President Trump has signed three executive orders to spark reviews of tax and financial regulations so taxes on businesses and individuals can be cut. The approach would be different from Trump’s earlier plan, which was criticized as an approach that would mostly benefit higher earners. Michael Zezas, a strategist at...

Tax predictability is key to driving investment

Deloitte survey highlights tax predictability as key to driving investment growth in Asia Pacific New Zealand well placed against backdrop of increased uncertainty in Asia Pacific’s tax landscape New Zealand’s tax policies are seen as relatively straight forward, consistent and predictable compared to other countries in the region, according to...

Survey: Citizens in G-20 countries favor gov’t cooperation over tax competition

The overwhelming majority of people in G-20 countries believe that cooperation between governments on tax policy is more important than competition to increase national tax revenue. According to a survey by the Association of Chartered Certified Accountants, the preference for cooperation over competition is strongest in Argentina, Australia, Brazil, France,...

Chevron: a game-changer for multinational tax avoiders

The Australian Tax Office had a superb win against Chevron in the Federal Court last week, but there is something everyone is missing, something that will turn the art of tax avoidance on its head; a game-changer for multinationals. Put simply, Chevron borrowed US$2.5 billion in the US at less...

Nigeria Needs to Boost Tax-to-GDP Ratio

ABUJA – Nigeria has begun to take steps to boost its tax-to-GDP ratio beyond the miserly level of 6 percent. Over the weekend at the 2017 Spring Meetings of the IMF-World Bank/IMF in Washington DC the Finance Minister of Nigeria said that the national government must take extra efforts to...

US tax cuts could lead to financial instability: IMF

Report warns that Trump’s proposed corporate tax reforms could spark risk-taking WASHINGTON • The International Monetary Fund (IMF) warned yesterday that United States President Donald Trump’s proposed tax cuts and reduction of financial regulations could spark a new round of financial risk-taking of the type that preceded the last crisis...

IMF Calls On Countries To Better Target Tax Relief

Governments should look to remove tax policies that distort business decisions, to unlock higher economic growth, a new paper from the International Monetary Fund says. “Upgrading the design of their tax systems can help countries chip away at resource misallocation by ensuring that firms’ decisions are made for business and...

Draft Bulgarian tax law reflects EU legislation on mandatory automatic exchange of tax information

At the end of March 2017, the Ministry of Finance called for public discussion on a draft bill (the “Bill”) amending the Bulgarian Tax and Social Insurance Procedural Code (the “Code”). The Bill seeks to improve administrative cooperation in the Bulgarian tax sector. The first set of amendments relates to...

Understanding the taxation of international and expatriate assignments

(Second of two parts) In last week’s article, we discussed how or why taxpayers working on international assignments have to consider the impact of different tax jurisdictions on their individual tax obligations. We also explained how most companies implement a tax equalization (TEQ) arrangement for the employees so that they...

Australia Urged To Scrap GST On Digital Imports

An Australian taxpayer advocacy group has joined forces with a coalition of international taxpayer organizations and academics to condemn the Government’s plans to abolish the low-value goods and services tax threshold on imports. In separate submissions to the Senate inquiry into the proposes GST changes, the Australian Taxpayers Alliance and...

Cyprus: Abolition Of Profit Margins On Intra Group Loans – Upcoming Transfer Pricing Legislation – Transfer Pricing Studies Requirement

As a rule and according to Article 33 of the Cyprus Income Tax Law, which introduces the arm’s length principle (using wording similar to that of article 9 of the OECD Model Tax Convention), all transactions between companies, including loan agreements/transactions by Cyprus companies, must be undertaken at arm’s length...

Withholding tax on dividends – A bagful of uncertainties and complexities?

Muscat: One of the many changes that the Royal Decree 9 of 2017 (RD) has made in the Oman Income tax law is the introduction of withholding tax (WHT) on payment of ‘dividends on shares’ by Omani companies. This amendment requires Omani companies distributing dividends on shares to foreign persons...