Category: Investments

MoF signs two agreements on avoidance of double taxation, protection and promotion of investment with Burundi

ABU DHABI, 16th February, 2017 (WAM)–The Ministry of Finance, MoF, has signed two final agreements on the avoidance of double taxation and the protection and promotion of investment with Burundi. The agreements came as part of the Ministry’s strategy to expand its international relations and to protect and promote Emirati… – Continue reading

Cayman Islands’ investment in S. Korea tops 9.2 tln won

SEOUL, Feb. 16 (Yonhap) — The Cayman Islands became the largest investor as a tax haven country in the South Korean market last year, data showed Thursday, amid suspicions that some of the money could be owned by South Koreans disguised as foreign investors in an attempt to avoid taxes…. – Continue reading

ANCA and Senator Menendez Discuss Benefits of a U.S.-Armenia Double Tax Treaty

Bilateral Economic Accord Key to Growing Trade and Investment WASHINGTON—Armenian National Committee of America (ANCA) Chairman Raffi Hamparian recently held a working meeting on Capitol Hill with U.S. Senator Robert Menendez (D-N.J.) on a range of shared priorities, including the negotiation of a new U.S.-Armenia Double Tax Treaty. This bilateral… – Continue reading

‘Survival Of Financial Services Not An Option’

A prominent QC yesterday backed calls for the Bahamas to switch to a ‘low tax’ business model, warning: “The survival of financial services is not an option.” Brian Moree QC, senior partner at McKinney, Bancroft & Hughes, said the Bahamas had to “figure out how to adjust its business model”… – Continue reading

Indonesia – Key Indonesian Law Considerations For International DCM Issues

Following Moody’s Investors Service affirmation of Indonesia’s sovereign credit rating at Baa3 with a stable outlook in January 2016, there has been renewed interest in the international bond market for Indonesian credits. This bulletin seeks to summarise the regulatory changes in Indonesia over the last 24 months as well as… – Continue reading

Japan, China, Ireland biggest foreign holders of US government bonds

In the latest published data from the US Treasury Department and Federal Reserve Board in respect of November 2016, the value of Treasury Securities held by foreigners was $5.9tn with Japan’s holdings at $1.1tn and China at $1.0tn, followed by Ireland at $275bn. However, some further data show that the… – Continue reading

Parliament passes FATCA

The Foreign Account Tax Compliance Act (FATCA) United States of America Implementation and Enforcement of the Inter-Governmental Agreement was passed in Parliament without opposition, making it mandatory for Antigua & Barbuda’s banks to provide the banking information of US citizens to the Internal Revenue Service (IRS). The Act requires local… – Continue reading

China’s banking regulator issues guidelines on outbound investment

China’s banking regulator issued guidelines on Wednesday calling for the country’s financial institutions to strengthen their control and management of funding for outbound investment. The guidelines are the latest new rules on overseas investment as Beijing moves to clamp down on cross-border capital outflows and halt questionable investments. The China… – Continue reading

The ‘indirect transfer provisions’ monster

The most important task of the Finance Minister in the 2017-18 budget is to tame the “Indirect Transfer Provisions” monster born out of amendments to Section 9 of the Income Tax Act, 1961. In response to the Supreme Court’s judgement in the famous Vodafone case, the Finance Act, 2012 amended… – Continue reading

Tax Topics: Border-Adjustments And Tax Avoidance

The new administration and Congress have signaled their intention to undertake fundamental tax reform in the coming months. Lawmakers will need to weigh the costs and benefits of numerous policy trade-offs as they undertake this effort. Among the most visible debates already underway concerns “border adjustability,” or moving the U.S…. – Continue reading

OECD’s MLI: will tax treaty benefits apply to private equity investors?

The OECD recently released a public discussion draft entitled the “BEPS Action 6 Discussion Draft on non-CIV examples” to clarify when investors like private equity funds, real estate funds and hedge funds should be entitled to tax treaty benefits. The release of the 2017 Discussion Draft is timely, given that… – Continue reading

From Israel to Canada: New Tax Treaty to Help Structure Investments

On December 21, 2016, the new Canada–Israel tax treaty entered into force. The new treaty was signed on September 21, 2016 in New York, and replaces the existing treaty that dates from 1975. For most purposes, the provisions of the new treaty took effect as of January 1, 2017. Overall,… – Continue reading

Multilateral Instrument: The new dilemma of foreign investors

MUMBAI: The Multilateral Instrument (MLI), a new global tax avoidance agreement, that is in the process of being signed by 100 countries, is now causing a lot of anxiety among foreign portfolio investors (FPIs). MLI is an agreement put out by OECD, the intergovernmental economic organisation, to stop Base Erosion… – Continue reading

Senators tell new US treasury secretary nominee to eliminate Cayman Islands and other tax havens

WASHINGTON, USA — Members of the United States Senate, questioning the new Trump administration nominee for Treasury Secretary on Thursday, asked Steve Mnuchin how he intends to close down Caribbean tax havens, specifically naming the Cayman Islands. The Senate panel demanded details on how the new secretary expects to close… – Continue reading

Latvia and Japan sign agreement intended to promote investment and make investors’ work easier

RIGA – Latvian Finance Minister Dana Reizniece-Ozola (Greens/Farmers) and Motome Takisawa, Parliamentary Vice-Minister for Foreign Affairs of Japan, today signed a convention for the elimination of double taxation with respect to taxes on income and the prevention of tax evasion and avoidance, BNS was told at the Finance Ministry. The… – Continue reading

Budget 2017: Tax Reform For Financial Services

Given the recent developments in the Indian economy, the upcoming Union Budget will certainly be critical and important in determining the future outlook of the economy. The financial services industry has been one of the key drivers of growth due to its strong cause and effect relationship with the economy…. – Continue reading

UK/Uruguay double taxation convention takes effect

The comprehensive Double Taxation Convention between Uruguay and the United Kingdom has taken effect from 1 January 2017. The United Kingdom and Uruguay signed a convention to avoid double taxation and prevent fiscal evasion related to taxes on income and on capital on 24 February 2016 in Montevideo. The document… – Continue reading

Expose the true beneficiaries

THE Panama Papers, the world’s biggest leak, highlighted the complex ways used by companies and individuals to conceal who the actual beneficiaries of a company are. Some of them put their money into offshore accounts such as in Labuan, which is also an off-shore financial centre and tax haven. One… – Continue reading

The favourable tax regime of new Italian residents

The 2017 Budget Law introduced (starting from fiscal year 2017) favourable provisions for people wishing to become tax residents in Italy. It is aimed at wealthy individuals who wish to bring in new capital resources. The regime is inspired by the non-domiciled resident regime which is in force in the… – Continue reading

India may leave tax treaty with Netherlands unchanged

India is unlikely to amend its tax treaty with the Netherlands as it did with Mauritius, Singapore and Cyprus and this could shape the investment strategy of foreign portfolio investors (FPI) and private equity (PE) funds investing in India, said three people in the know. “There were talks to amend… – Continue reading

Swedish Bank Merger Rules Aim to Limit Risk of Tax Imbalance

A plan by Nordea Bank AB to merge with subsidiaries in Denmark, Finland and Norway has prompted Sweden to revise its laws to minimize the risk of a tax imbalance when a foreign company’s shares and other financial instruments are merged with those of domestic company. Effective Jan. 1, the… – Continue reading

Worldwide: The OECD’s Conquest Of Domestic Tax Codes: Understanding The Costs And Consequences Of The BEPS Project

Authored by IFC Media Recent global events from the release of the Panama Papers to a series of high-profile inversions have given international tax regulators both rhetorical ammunition and public support to execute a global crackdown on multinational tax planning. The goal is to increase total taxes paid by global… – Continue reading

Singapore-based FIs must establish tax residency status of account holders: IRAS

SINGAPORE: Under the Common Reporting Standard (CRS) which has been in effect since Jan 1, Singapore-based Financial Institutions (FIs) are now required to establish the tax residency status of all their account holders, the Inland Revenue Authority of Singapore (IRAS) said on Friday (Jan 6). The CRS is an internationally… – Continue reading

A Classic Case Of Double Taxation?

The Central Board of Direct Taxes in India issued Circular Number 41 on December 21, 2016 providing clarifications on applicability of ‘indirect transfer’ provisions under the Indian Income Tax Act, 1961 to investors of Foreign Portfolio Investors (FPIs) – earlier known as Foreign Institutional Investors (FIIs) in India. The circular… – Continue reading

Singapore Goes The Mauritius Route, Loses Right To Tax Equity Capital Gains Arising In India

Starting April 1, 2017, India will have the right to tax capital gains arising on Indian equity shares sold by a Singapore resident. The governments of India and Singapore have amended the double taxation avoidance treaty between the two countries, in line with the changes India recently made to a… – Continue reading

Mauritius: Joint Statement By The FSC & The FSPA

The Mauritius IFC: Driving Growth in Africa As a jurisdiction of substance, the Mauritius International Financial Centre (Mauritius IFC) has been instrumental in driving quality investments in Africa, leading to sustained growth and prosperity across the continent. It is therefore with deep regret that we take note of the misperceptions… – Continue reading

MOF rejects claim of Singapore as tax haven

A recent report has revived claims Singapore is a tax haven but the Singapore Government and experts here reject the label emphatically. They say the report contains inaccurate assertions and fails to recognise recent steps here to crack down on tax evasion. The Republic ranked fifth on a list of… – Continue reading

PBC urges Dar to ask FBR to go easy on super tax

Pakistan Business Council (PBC) has approached Finance Minister Ishaq Dar to stop the Federal Board of Revenue (FBR) from recovery proceedings of Super Tax against non-resident companies on dividend income from their investments in Pakistan. Sources told Business Recorder here on Tuesday that the PBC has urged the Finance Minister… – Continue reading

Double taxation: Ecuador, Italy sign agreement to foster private investements

Ecuador signed an agreement with Italy to define the tax obligations of the citizens of the two countries, in order to avoid double taxation on income taxes and equity and prevent tax evasion, the Ecuadorian Foreign Ministry said. “This protocol modifies the agreement signed in Ecuador and Italy in 1984… – Continue reading

Rate Competition Is New International Tax Planning Reality

Lower corporate tax rates around the world are expected to play an important part in multinational companies’ tax planning in 2017, with a rate as low as 15 percent on the table in the U.S. and countries such as the U.K. planning to maintain or lower their current rates. A… – Continue reading

DOUBLE TAXATION AGREEMENT BETWEEN SWITZERLAND AND OMAN

MUSCAT -The Double Taxation Agreement (DTA) between Switzerland and Oman aiming to increase economic ties officially came into force last month, according to the Swiss government. Its provisions will be applicable from January 1, 2017, according to the government. The agreement was originally signed on May 22, 2015 before going… – Continue reading

HUNGARY COULD BE A CORPORATE PROFIT TAX HAVEN IN THE EUROPEAN UNION

The new 9 percent flat corporate profit tax – to be introduced 1st of January 2017 – will put Hungary in a very good position in the international race for investments as Hungary will offer even better conditions than Ireland and Cyprus, which are both often regarded as the European… – Continue reading

Can current offshore wealth management centres survive?

After recent scandals, many financial and wealth management centres are losing their allure and ‘mid-shore’ options are taking their place, argues Philip Marcovici. Will all existing financial and wealth management centres survive? Are tax-free secrecy havens (the “offshore world”) a feature of the past? Is there room for entry of… – Continue reading

‘Revenue will look for you – and it will find you’

Taxpayers with offshore assets urged to get affairs in order before May clampdown Taxpayers with offshore assets ranging from foreign properties to deposit accounts or structured investments are being urged to get their affairs in order ahead of a May clampdown by the Revenue Commissioners – even if they believe… – Continue reading

Implementation of Common Reporting Standard in Hong Kong – Implications for Family Trust with a Private Trust Company as Trustee

The Organization for Economic Co-operation and Development (OECD) issued the Standard for Automatic Exchange of Financial Information in Tax Matters (Standard for AEOI) in July 2014, which aims to prevent offshore tax evasion and maintain the integrity of tax systems. Over 100 jurisdictions have committed to comply with the Standard… – Continue reading

US AND GRENADA FATCA AGREEMENT GOES INTO EFFECT

The Governments of the United States and Grenada have signed the Foreign Account Tax Compliance Act (FATCA) that will enforce a requirement for US citizens to file yearly reports on their non-US financial accounts. “This allows us to work together to ensure that financial institutions here in Grenada can help… – Continue reading

OECD Says Trump Tax and Spending Plans Will Boost Global Economy

A resurgent U.S. economy would help offset softness elsewhere in the world. Global growth will pick up faster than previously expected in the coming months as the Trump administration’s planned tax cuts and public spending fire up the U.S. economy, the OECD said on Monday, revising up its forecasts. In… – Continue reading

Belize Financial Regulator Warns Against Fraudulent Bitcoin Investment Company

The financial regulator of Central American nation Belize has issued a public warning against XMAXBIT, a company that claims to provide returns for investors by investing in cryptocurrencies like bitcoin. Published on Monday, the Office of the International Financial Services Commission (IFSC), Belize’s financial regulator, has warned users against dealing… – Continue reading

India, Cyprus ink new Double Tax Avoidance Agreement

New Delhi– India on Friday signed a revised double taxation avoidance agreement (DTAA) with Cyprus, an official statement said here. “A revised agreement between India and Cyprus for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion (DTAA) with respect to taxes on income, along with its protocol,… – Continue reading

Federal government moves to stop double taxation, evasion

The Federal Executive Council, FEC, on Wednesday approved a bilateral agreement for the avoidance of double taxation and the prevention of physical evasion of taxes on income and capital benefits between Nigeria and Singapore. The Minister of Finance, Mrs. Kemi Adeosun disclosed to State House Correspondents, after the FEC meeting… – Continue reading

Govt poised to regulate offshore investments

ISLAMABAD: The government has stepped up to check corruption and regulate offshore investments in a bid to promote transparency and good governance, finance minister said on Tuesday. “New measures, such as the companies’ global register of beneficial ownership, will curb corruption, help (government) address challenges related to offshore investments and… – Continue reading

Malaysia demands foreign banks commit to stop offshore ringgit trading: sources

Foreign banks have been asked to make a written commitment to Malaysia’s central bank to stop trading the ringgit in the offshore non-deliverable forwards market in the bank’s latest move to protect a weakening currency, banking sources said. Foreign banks have been sent a form letter to sign, which asks… – Continue reading

High Court confirms tax evasion by companies linked to wealthy businessman Vanda Gould

A series of companies associated with high-flying Sydney accountant who had scores of wealthy clients in Sydney’s eastern suburbs have been found to have avoided paying tax by the High Court, in a case that the tax office has described as “blatant tax evasion”. Four companies linked to accountant, Vanda… – Continue reading

Vancouver Announces Empty-Home Tax to Take Pressure Off Rental Market

New tax takes effect on Jan. 1; highest penalties could reach C$10,000 a day Vancouver is implementing a new tax policy to rein in an overheated real estate market by forcing absentee landlords to make their vacant homes available for lease. Starting Jan. 1, the Empty Home Tax will be… – Continue reading

Significant Change In CRA Policy Harms Canadian Investors In US LLPs And LLLPs

Earlier this year the Canada Revenue Agency (“CRA”) announced its new administrative position that limited liability partnerships (“LLPs”) and limited liability limited partnerships (“LLLPs”) formed under the laws of Delaware and Florida are properly viewed as corporations for Canadian income tax purposes. It is widely expected that LLPs and LLLPs… – Continue reading

The coming abolition of cash

The Indian Government’s dramatic cancellation of large banknotes on the same day as the US election last week looks like the drastic solution to a very Indian problem with tax avoidance and the black economy, but it might turn out to be a harbinger of things to come everywhere. In… – Continue reading

Trump’s Corporate Tax Reforms: What CFOs Need to Know

While Trump wants to close loopholes, many of them stem from public policy concerns — not “special interests.” After a dramatic upset victory in one of the most bitterly contested presidential races in recent history, Donald Trump now has some serious work to do. His corporate tax policies—which are vital… – Continue reading

Australian Practitioners Urge Zero Withholding for Pooled Funds

Practitioners in the managed funds industry are calling for a zero-rate for withholding tax in Australia amid the government’s proposals for new tax concessions to boost it, saying the proposed measures don’t go far enough. The government released a consultation paper Nov. 3 on non-resident withholding taxes for pooled funds—or… – Continue reading