Category: Investments

Multinational moves could prompt major losses in corporate tax

Action on tax avoidance could see €600m go from the pharma sector, says report International moves on multinational tax could threaten Ireland, with a potential annual loss of corporate tax revenue of €600 million or more from the pharma sector alone, according to a new report from Chartered Accountants Ireland…. – Continue reading

Cyprus: Relocate To Cyprus And Be Tax Exempt On Your Worldwide Income

Provide high-net-worth individuals with (further) incentives to relocate to Cyprus. This is one of the objectives of the introduction of the non-domicile rules (voted on the 9th of July 2015, among other tax reforms) that came into force on the 17th of July 2015 (date of the publication in the… – Continue reading

British Virgin Islands: What Structure Should I Use For My Offshore Fund?

There are a number of ways to structure your offshore fund and the best option for you will depend largely on the location of the manager, your investor base and the type of investments that the fund will make. I have set out a summary of the three most common… – Continue reading

UK releases Finance Bill clauses and consultation documents

Executive summary On 9 December 2015, the UK released draft clauses for Finance Bill 2016 as well as consultation documents. The key items released include: A new requirement for large businesses to publish their tax strategies as they relate to or affect UK taxation. This sits alongside new ‘special measures’… – Continue reading

Australia shuts down investment schemes run by fund linked to 1MDB

The Australian Federal Court has ordered five investment schemes managed by Avestra Asset Management to shut down, The Australian reported today, following the fund’s link to the 1Malaysia Development Berhad (1MDB) controversy. It was reported that the judge made the decision after going through a report from liquidators, who unearthed… – Continue reading

DYK: Dividend from investing in shares of foreign companies is taxable in India

Dividend income from foreign companies is not treated the same as dividend from domestic companies, for tax purposes The two key advantages of investing in equities are the possibility of higher returns and tax efficiency. In the long term, equity has outperformed other asset classes. And, according to Income tax… – Continue reading

Blacklisted HK: The Italian Case

More good news for Hong Kong before the end of 2015: Italy decided to remove Hong Kong from its national blacklist on November 30, 2015. Italy ratified a comprehensive agreement for the avoidance of double taxation (CDTA) signed with Hong Kong on June 18, 2015. Facilitating an early removal of… – Continue reading

Piper Jaffray Sees Renewed Monsanto (MON) Bid for Syngenta (SYT) Near Start of 2016

DuPont and Dow are now officially combining and Piper Jaffray analyst, Brett Wong, thinks further consolidation is coming with Monsanto (NYSE: MON) likely to renew the pursuit of Syngenta (NYSE: SYT) towards the beginning of the year. Piper thinks a renewed bid for Syngenta would be viewed negatively by investors… – Continue reading

ATO to unveil large business hit list, clamps down on Singapore hubs

Hundreds of millions of dollars of revenue could be up for grabs as the Tax Office announces reviews of multinationals using offshore hubs in Singapore to minimise their tax. The ATO has issued a warning to multinationals to come forward immediately to discuss their overseas hub arrangements, if they have… – Continue reading

___uk to modify patent box in line with oecd recommendations__

Its approach includes a new “nexus principle”, as agreed by the multinational Organisation for Economic Cooperation and Development (OECD). This is designed to ensure that the benefits of the UK tax regime are only available where the research and development (R&D) expenditure required to develop that innovation also took place… – Continue reading

Investing in Morocco

Over recent years, Kingdom of Morocco has created a legal and regulatory framework very attractive for foreign investors. In addition to its political stable environment, a recent series of tax treaties with numerous countries and reforms in almost all of its sectors of activities, in conjunction with its creation of… – Continue reading

Tax info sharing kicks in 2017

Come 2017, tax information on all foreign nationals holding bank accounts or other financial holdings in Cayman will be automatically shared with tax authorities in their home countries when the Mutual Administrative Assistance in Tax Matters convention kicks in. Maples, in a Cayman Islands Automatic Exchange of Information update statement… – Continue reading

Senate approves tax treaties with Turkey, Italy & Germany

The Senate concurred, after hearing, the ratification of tax treaties between the Philippines and the governments of Italy, Germany and Turkey that will prevent double taxation. Sen. Juan Edgardo “Sonny” Angara said the approval on third and final reading of Senate resolutions 1540, 1541, 1542 on the double taxation avoidance… – Continue reading

India, Saudi Arabia try to sort out joint fund irritants

NEW DELHI: India and Saudi Arabia are exploring ways to overcome the issue of exemption from capital gains tax on the proposed $750-million joint fund to facilitate investments into the Indian infrastructure sector. “Unfortunately, we have not been able to move forward on our bilateral fund with Saudi Arabia due… – Continue reading

Kuwait, Kyrgyzstan sign cooperation agreements

Kuwait and Kyrgyzstan on Sunday signed a host of bilateral agreements and a MoU, covering various fields of cooperation. The signing ceremony, at Bayan Palace, was attended by His Highness the Amir Sheikh Sabah Al-Ahmad Al-Jaber Al-Sabah, visiting Kyrgyz President Almazbek Atambayev, His Highness the Crown Prince Sheikh Nawaf Al-Ahmad… – Continue reading

Globalisation and regulation driving industry growth

The asset servicing industry is likely to see a growth spurt driven by globalisation and regulatory change, according to an Ernst & Young (EY) report, reports the Asset Servicing Times. The report outlined six key drivers of growth: asset growth and breadth; globalisation; regulation; new products; platform extension and consolidation;… – Continue reading

The Changing Landscape for IP Regimes Around the World

Patent Boxes, Innovation Boxes, Intangible Property Boxes, Knowledge Development Boxes (IP Regimes) – countries may use different names, but all of these regimes are designed to allow a preferential rate of tax to be applied to income generated from intangible property (IP). There are a number of these regimes in… – Continue reading

Worldwide: A Guide To The Top 20 Offshore Fund Locations

There are a variety of benefits to moving offshore, yet few would argue the assertion that tax neutrality is paramount among them. As anyone familiar with the phrase “tax haven” would surely recognize, many countries offer strongly favorable tax terms as an incentive to draw new business. Written by CT… – Continue reading

Coming soon: More disclosures for MNCs in India

Firms over a certain threshold group turnover may be required to give detailed info of financials. MULTINATIONAL companies in India over a certain threshold group turnover may be required to make comprehensive disclosures relating to their revenues, taxes paid, staff strength and assets in different countries where they operate from… – Continue reading

US Justice Department Announces Two Banks Reach Resolutions Under Swiss Bank Program

The Department of Justice announced today that Cornèr Banca SA (Cornèr) and Bank Coop AG (Bank Coop) reached resolutions under the department’s Swiss Bank Program. The Swiss Bank Program, which was announced on Aug. 29, 2013, provides a path for Swiss banks to resolve potential criminal liabilities in the United… – Continue reading

‘Anti-business law’

Samuda blasts Gov’t for transfer pricing policy Opposition spokesman on industry and commerce Karl Samuda addressing the transfer pricing policy in Parliament on Tuesday. KARL Samuda has described the transfer pricing regime, as well as the Government’s push to implement it retroactively, as unfriendly to business, and has predicted that… – Continue reading

PM Gruevski meets with Israeli PM Netanyahu in Jerusalem

Macedonia’s Prime Minister Nikola Gruevski and his Israeli counterpart Benjamin Netanyahu signed Wednesday in Jerusalem a declaration of friendship, as well as agreements on avoiding double taxation and protection of investments. The Prime Ministers affirmed the excellent relations between the two countries, based on mutual friendship and understanding, Gruevski’s Cabinet… – Continue reading

Hong Kong urged to cut tax for asset management

Hong Kong’s Financial Services Development Council (FSDC) has released a number of research reports, including one that addresses tax issues relating to open-ended fund companies (OFCs) and private equity (PE) investments, reports Tax News. One report entitled “A Paper on the Tax Issues on OFCs and Profits Tax Exemption for… – Continue reading

‘India examining how to tax in a digital eco’

Akhilesh Ranjan, joint secretary (foreign tax), who led India’s initiative in the BEPS project, candidly shared his views on India’s plans for its implementation and what lies in the future. The fundamental principle of the BEPS project, is that income of MNCs should be taxed in that country where economic… – Continue reading

Gov’t uses majority to pass ‘bothersome’ transfer pricing provisions

Policy will disrupt investment: Samuda THE Government fell back on its huge majority in the House of Representatives yesterday to approve the back tax provisions included in new transfer pricing regulations despite objections from the Opposition that the measure would strangle businesses and obstruct investments. The 21 Government members (excluding… – Continue reading

Italy to Get $4.4 Billion in Proceeds From Tax Amnesty

ROME—The Italian government will pocket over €4 billion ($4.4 billion) in proceeds from a tax amnesty it launched as part of a broad crack down on Italian money stashed abroad. The additional money will be a boon for the government, as it seeks to meet its budget targets amid a… – Continue reading

Azerbaijan, Israel should pay much attention to private sector for constructive ties (exclusive)

By Anakhanum Khidayatova – Trend: A lot should be left to the private sector to achieve constructive relations between Azerbaijan and Israel, according to Dan Stav, Israeli ambassador in Baku. “In order to encourage business in each country, you need to create conducive environment,” he said speaking to Trend Dec…. – Continue reading

Ministry of Finance issues guidelines for Financial Institutions with US and UK Clients

Providenciales, 08 Dec 2015 – Since December of 2014, the Turks and Caicos signed an Intergovernmental agreement or IGA so that the laws of the US FATCA or Foreign Accounts Tax Compliance Act and the UK equivalent could have force in these islands. Last month, the Ministry of Finance issued… – Continue reading

India Clarifies Tax Law For Foreign Portfolio Investors

The Indian Government has accepted the recommendation of the Shah Committee that the Income Tax Act 1961 be amended to clarify that minimum alternate tax (MAT) does not generally apply to foreign institutions investors (FIIs) and foreign portfolio investors (FPIs). The Committee proposed that Section 115JB of the Income Tax… – Continue reading

Dividend tax raid: what can expats do?

With a new tax on company dividends coming into force from April 2016, a financial planner explains how Britons overseas will be affected, and what steps they should take Investors who receive more than £5,000 from company dividends held outside tax-efficient plans such as Isas will pay more tax from… – Continue reading

IRS continues focus on corporate inversions

The Internal Revenue Service (IRS) continues its focus on perceived abuses in corporate inversion transactions. On November 19, the IRS released Notice 2015-79, which places new limitations on the ability of a U.S. multinational corporation to reduce its U.S. tax burden by inverting its corporate structure. U.S.-based multinationals are subject… – Continue reading

Changes of PRC tax rules on offshore indirect transfers: Circular 698

The Circular of the State Administration of Taxation on Strengthening the Administration of Corporate Income Tax on Incomes of Equity Transfers of Non-Resident Enterprises (“Circular 698”) was issued in 2009 to regulate tax treatment of indirect transfers of equity interest in a domestic Chinese company by non-residents. Circular 698 empowered… – Continue reading

Changes of PRC tax rules on offshore indirect transfers: Circular 698

The Circular of the State Administration of Taxation on Strengthening the Administration of Corporate Income Tax on Incomes of Equity Transfers of Non-Resident Enterprises (“Circular 698”) was issued in 2009 to regulate tax treatment of indirect transfers of equity interest in a domestic Chinese company by non-residents. Circular 698 empowered… – Continue reading

Malta: The Tax Challenges Of The Digital Economy – Article 2

Main principles of direct taxation – Domestic Tax Rules In our second article in a series of articles on the tax challenges of the digital economy, we shall be providing you hereunder with a brief overview of the principles of direct taxation, with a focus primarily on the taxation of… – Continue reading

Cyprus: Tax Incentives For Expatriate And High Net Worth Individuals Relocating To Cyprus (In Russian)

INTRODUCTION In the context of changes in the international system of taxation of the company in the choice of jurisdiction for the implementation of operational activities closely fit to the question of economic feasibility, to protect their interests. The strategic location of Cyprus, the presence of the country’s full membership… – Continue reading

TaxTalk Today- 7th December 2015

Australian Taxation Office New or updated materials on ATO website, including: Class ruling to be released on Wednesday BAS reporting – offshore to offshore supply of goods: Some taxpayers are incorrectly including offshore to offshore supplies of goods in their business activity statements (BAS). This document sets out to clarify… – Continue reading

What CFOs Need to Know About BEPS

The Base Erosion and Profit Shifting (BEPS) project is an initiative being pursued by the Organization of Economic Cooperation and Development (OECD) to curtail perceived exploitation of international tax rules and loopholes by multinational enterprises (MNEs). The OECD’s BEPS project was initiated in 2013 at the request of the Group… – Continue reading

Swaraj calls on Mauritius Prez, discusses range of issues

External Affairs Minister Sushma Swaraj today called on Mauritius President Ameenah Gurib-Fakim and discussed a range of issues of mutual interest including impediments to investment inflows. Gurib-Fakim, the first woman President of Mauritius, who is a distinguished scientist, arrived here yesterday on a three-day visit. In the meeting, Gurib-Fakim and… – Continue reading

Clinton offers new ‘exit tax’ on U.S.-foreign company mergers

WASHINGTON — Hillary Clinton on Wednesday will unveil a proposal for a new “exit tax” aimed at cracking down on corporate inversions, a practice that permits U.S. companies to merge with corporations overseas to lower their tax bill. The new tax would be part of a broader effort to target… – Continue reading

FSDC releases reports to promote Hong Kong’s asset management business

Hong Kong (HKSAR) – The following is issued on behalf of the Financial Services Development Council: The Financial Services Development Council (FSDC) today (December 7) released three research reports to promote Hong Kong’s asset management business, focusing on fund distribution, tax issues relating to private equity investments and an alternative… – Continue reading

Chinamasa hails China mega deals

Ellah Mukwati Herald Correspondent The recent historic visit by the Chinese President Xi Jinping which saw 12 mega deals worth $4 billion being signed cemented the good bilateral relationship between Zimbabwe and China, the Minister of Finance and Economic Development has said. In a statement released yesterday Minister Patrick Chinamasa… – Continue reading