Category: Miscellaneous

PE Panorama: Is the UK Budget 2016 really PE-friendly?

Private equity (PE) populism looks to be in the news again – though in a context that’s unlikely to win too many votes for the instigators. This time it’s the UK, and Chancellor George Osborne’s latest budget. The UK Budget 2016 (the Budget) includes a significant reduction in the UK… – Continue reading

Equalisation levy may not be the right move

The ways of doing business in a digital economy have evolved rapidly. Traditional tax norms, effective in addressing issues in a world before high-paced technological and e-commerce, are increasingly becoming outdated. Taxation of e-businesses has been a globally identified challenge with tax authorities acknowledging that corporates in this disruptive environment… – Continue reading

Southeast State & Local Tax: Important Developments – March 2016

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast. VIRGINIA CORPORATE INCOME TAX Conformity with Internal Revenue Code. Virginia Governor Terry McAuliffe signed emergency legislation on February 5, 2016 that advances the state’s… – Continue reading

Budget 2016: Royalty payments – Enhanced withholding tax rights

As part of the Government’s crackdown on profit shifting by multinationals from the UK to low or no-tax jurisdictions, the Chancellor has announced in Budget 2016 a package of enhanced withholding tax measures which are designed to ensure that companies are not able to use intragroup royalty payments for avoidance…. – Continue reading

Income tax cuts will benefit 31 million workers

The amount people can earn before being hit by income tax will rise to £11,500 in April 2017, benefiting millions of workers. The move will cut taxes for 31 million people, according to the Treasury, and will mean 1.3 million low-wage workers are taken out of paying income tax altogether…. – Continue reading

Impact of new tax rules on BEPS?

New tax regulations dealing with the issue of BEPS (Base Erosion and Profit Shifting) may have a disproportionate impact on the real estate development sector as they are implemented in the UK. The concept of BEPS originates from the OECD and the G20 nations. The intention is to deal with… – Continue reading

States vie with feds to punish company moves abroad. But does it work?

State lawmakers are getting into the act of demonizing corporate inversions even though there is not much they can do to stop them. Corporate inversions, in which U.S. companies merge with or are acquired by an overseas business, are a hot topic on the campaign trail and in the halls… – Continue reading

UK Slammed Over Tax Haven Inaction as Report Shows Rich Getting Richer

The UK has been slammed over its failure to crackdown on British-controlled tax havens, with a new report claiming that the wealthiest one percent of the UK’s population have captured more than US$1.4 trillion of the country’s national growth since 2000. The report from Oxfam called on UK officials to… – Continue reading

Vijay Mallya’s secrets buried in offshore tax havens

It’s not just the Indian banks that business tycoon Vijay Mallya has taken for a ride. The chairman of United Breweries (UB) group and promoter of now defunct Kingfisher Airlines also concealed in his election affidavit, filed before the Rajya Sabha, his business interests in offshore tax havens elsewhere. dna… – Continue reading

Google And The UK Tax System – Tax Avoidance?

For several years now Google has been facing what appears to be a case of tax avoidance in the UK, at some point in time, the company went as far saying it did not make any money from business in the UK all in a desperate attempt to pay less… – Continue reading

Luxembourg set for a “huge change”

Governments around the world want more tax income. There is a widely held feeling that many international companies are basing themselves in places like Luxembourg, Ireland, and the Netherlands to avoid tax. The world’s largest countries have a plan and things will change. What will be the effect on Luxembourg,… – Continue reading

EPF tax row: Will it lead to double taxation?

Even employees earning below Rs 15,000 a month will be impacted if the Centre sticks to the plan of taxing 60% of EPF withdrawals The Budget has proposed significant changes on taxation of Employees’ Provident Fund (EPF). Given that EPF is at the core of the Indian social security system… – Continue reading

India clicks on digital economy with equalisation levy

While equalisation levy appears to be a step to counter double non taxation and protect India’s share of taxation, in its current form it may impact an Indian taxpayer more than foreign MNCs The growth of digital economy entails many benefits, but also poses various tax challenges. These include the… – Continue reading

“Relentless in pursuit of tax evasion and avoidance”: HMRC sets out plan to 2020

In its departmental plan for 2015-2020 published last month, HMRC set out it’s role “to help the honest majority to get their tax right and make it hard for the dishonest minority to cheat the system”. One of the headline objectives for this period is: “maximise revenues due and bear… – Continue reading

Further clarity on GAAR for FIIs

The industry was hoping GAAR might be postponed again, especially in the light of slowing down of the world economy In a signal to foreign institutional investors, the Union Budget has made a commitment to implement General Anti Avoidance Rules (GAAR) on taxes only from April 1, 2017. “The investment… – Continue reading

Union Budget 2016 – International tax proposals

With the adoption of the BEPS package, OECD and G20 countries laid the foundations of a modern international tax framework under which profits would be taxed where economic activity and value creation occurs. It is now time to focus on implementation of the recommended changes in a consistent and coherent… – Continue reading

Budget 2016: 9% tax rate regime for India’s first International Financial Centre

The pet project of Prime Minister Narendra Modi – the International Financial Services Centre (IFSC) – housed in the Gujarat International Finance Tec City – has received a boost in the Union Budget 2016/17. The long pending tax issue has been decided with 9 per cent minimum alternate tax (MAT),… – Continue reading

Using tax money to raise taxes

If a member of Congress told you that he was going to use some of your hard-earned tax dollars to support an international organization that demands that you pay higher taxes, what would you say? Unfortunately, the question is not hypothetical, because that is exactly what is now happening. Congress… – Continue reading

Rationalise taxes on media, entertainment sector: Experts

Budget 2016 should rationalise entertainment tax, exempt newsprint from VAT and end double taxation on temporary transfer of movie rights to television channels, experts said. “Currently, entertainment industry players such as DTH and cable service operators are reeling under the heavy burden of multiple taxation and levies such as licence… – Continue reading

Budget 2016: How base erosion and profit shifting (BEPS) brings HR function into focus

Tax function of an organisation was traditionally run from the tax director’s room. Transfer Pricing (TP) was governed by contracts between related parties and this at times resulted in profits moving to legal entities that had contractual rights but had no significant people functions. There were instances of IP Holding… – Continue reading

Zambia signing its way out of tax revenues-ActionAid Zambia

A new report from ActionAid titled ‘Mistreated’ released this week has revealed that Zambia has 13 restrictive tax treaties that dramatically restrict the government’s power to tax global companies doing business on our soil and therefore unfairly limit our country’s potential to collect tax revenue. The report also found that… – Continue reading

TIME IS TICKING ON DISCLOSING YOUR OFFSHORE ASSETS

For those taxpayers with undisclosed foreign assets, time is running out. With the introduction of FATCA and a global standard for the automatic exchange of information between countries’ tax authorities, it is unlikely that undisclosed foreign assets will remain as such for long, resulting in serious consequences for the taxpayer…. – Continue reading

Trump, Sanders Agree on Ending Deferral of Overseas Earnings

During a political season in which populist fury and anger at big business is running high, two presidential candidates want to eliminate the ability of multinational firms to keep earnings overseas and avoid U.S. taxes. They also just happen to be the two most surprising and disruptive candidates in the… – Continue reading

‘Tax me if you can’: Tax activism of a different kind

It’s unlikely anybody was particularly surprised when Finance Minister Pravin Gordhan announced a number of initiatives to increase the amount of tax revenue; from sugar tax to a “tyre levy” to an increase in a number of existing sin taxes. But it’s perhaps the relaxing of voluntary disclosure rules that… – Continue reading

Tony Wickenden: What the Finance Bill 2016 means for tax avoidance

In this final instalment considering the draft clauses from the Finance Bill 2016 most relevant to financial planners, I am going to turn my attention to the ever-popular subject of tax avoidance and evasion. Every Budget and Finance Bill has plenty to say on this subject. As in the previous… – Continue reading

Budget 2016: Will the govt amend domestic tax laws to help the bleeding infrastructure sector

If January is a month of New Year resolutions, February can be said to be a month of New Financial Year expectations with Indian Government announcing its fiscal policy strategy, including taxation regime for the next financial year. The Union Budget of 2015-16 was the first full budget presented by… – Continue reading

US Democrat Bill Takes Further Aim At Inversions

On February 23, US House of Representatives Ways and Means Committee Ranking Member Sander Levin (D – Michigan) and Budget Committee Ranking Member Chris Van Hollen (D – Maryland) introduced legislation aimed at reducing the number of corporate tax inversions by limiting the use of “earnings stripping.” Tax inversion techniques… – Continue reading

BUDGET2016 – IS THERE ROOM TO PAY MORE TAXES?

Anthea Scholtz calls for a careful balance between ‘spending’ and ‘revenue-generating’ activities. All eyes will be on Parliament on 24 February 2016 when South Africa’s annual national Budget will be presented by the newly re-appointed Minister of Finance Pravin Gordhan. The Budget speech has over the years given South Africans… – Continue reading

Corporate close-up : Three legislative tax trends to watch for in 2016

The “power of three” is a principle of writing and joke telling that suggests that events or items presented in threes are somehow funnier or more satisfying than tales organized around other numbers. It will be interesting to see if the theory holds true for the current state legislative sessions… – Continue reading

Poland Plans Battle Against Tax Avoidance to Boost Budget Income

Polish tax authorities plan to increase inspections on companies suspected of artificially increasing their operation costs and sending taxable profits across the borders to stop a trend of falling corporate tax revenue. Audits will start in the second quarter, the Finance Ministry said on its website on Friday, adding that… – Continue reading

Rajan Blames MNCs For Tax Controversies

‘Multinational corporations complain all the time of excessive demand about excessive taxation, but it is also true that MNCs across the world tend to find tax avoidance and sometimes tax evasion as an appropriate technique’ Blaming multinational corporations squarely for tax controversies, Reserve Bank Governor Raghuram Rajan has said their… – Continue reading

Brazil: PRORELIT, CSLL Within International Treaties And Tax Planning Statements: Conversion Of Provisional Measure No. 685/2015 Into Law No. 13,202/2015

On December 8, 2015, law No. 13,202 was published, as a result of the conversion of Provisional Measure No. 685/2015 into law. In addition to providing for the Program for Reduction of Tax Litigation (PRORELIT, for its acronym in Portuguese), said law addressed issues such as the scope of double… – Continue reading

MAP-ping tax reform: Good start to resolving transfer pricing row with US

Though the use of the retrospective tax on Vodafone and Cairn tend to grab the headlines, a large part of the ‘tax terror’ in India has really been the contribution of the high-pitched transfer pricing (TP) additions to the income of the MNCs Though the use of the retrospective tax… – Continue reading

The Italian Patent Box and Its (Non-) Compliance with OECD Recommendations

The Italian Patent Box regime largely complies with the OECD recommendations to prevent base erosion and profit shifting. Its non-compliant features offer a brief window of opportunity for companies able to take swift advantage of its wide range of qualifying intangible assets. Many countries have implemented specific IP regimes through… – Continue reading

Service tax exemption limit to be raised to Rs 25 lakh in Budget

The Ministry of Finance is planning to make the forthcoming general budget people-friendly. According to informed sources, the service tax exemption limit is expected to be increased from Rs 10 lakh at present to Rs 25 lakh. This is being seen as a major step aimed at benefitting traders and… – Continue reading

The tax cut we have to have

Australia must not be blown off course from getting a company tax rate closer to 20 per cent. Corporate tax transparency figures released in December by the Australian Taxation Office should not slow momentum. For the first time, the ATO reported the tax affairs of companies with total incomes of… – Continue reading

President Mukherjee calls for innovation to deal with rising tax disputes

The President highlighted transfer pricing, taxation of digital economy and international taxation as the frontier areas of taxation which require special skill sets to deal with disputes. Stressing on the need to improve India’s ranking in ease of doing business, President Pranab Mukherjee on Sunday said rising tax disputes and… – Continue reading

BEPS rules to be made compulsory from 1 April

India to change laws in Union Budget to make country-by-country reporting mandatory for Indian multinationals New Delhi: India will change laws in the upcoming budget to make country-by-country reporting mandatory for Indian multinationals to ensure they follow so-called base erosion and profit shifting (BEPS) guidelines. The norms were announced in… – Continue reading

Multinationals may have to provide global income, tax details to taxman

Budget to implement some of OECD’s standards on profit-shifting NEW DELHI, JANUARY 21:Large multinational enterprises (MNEs) may be required post-Budget to furnish to Indian tax authorities information on their global incomes and taxes. This move — a fallout of India agreeing to OECD’s Action Plan on Base Erosion and Profit… – Continue reading