The Treasurer announced this morning that the Government will use the foreign investment system to ensure tax compliance by multinational companies when investing in Australia. Using the FIRB process will add an additional mechanism for the Government to monitor and enforce tax compliance by multinational companies. It has long been… – Continue reading
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
If you think Uncle Sam has too many other problems to worry about what assets you may be hiding overseas, think again. “Governments are catching up to the fact that there is now a global economy and are requiring increasing reporting to ensure they collect ‘their fair share’ of tax… – Continue reading
Bermuda’s international business chiefs said they would swallow increased taxes if the Government continued to cut its costs and pushed ahead with reforms in the public service. Insiders added that the sector wanted to see the Government live up to its pledges to make the Civil Service more accountable, close… – Continue reading
PANAMA’S most notorious moment as a haven for tainted cash came with the nationalisation of money-laundering in the 1980s under Manuel Noriega, a military strongman. It has since clamped down on egregious financial criminality, but remains home to thousands of secretive firms and famous for the discretion of its bankers… – Continue reading
New Delhi :The Central Board of Direct Taxes (CBDT) has issued a clarification with regard to an inter-governmental agreement between India and USA signed for implementation of Foreign Account Tax Compliance Act (FATCA). The CBDT further said in its statement that the Government of India has also joined the Multilateral… – Continue reading
Free-market advocates say retrospective tax claim on the British telecom major sends a negative message to global investors. It seems to be a weak argument Like all tax disputes, the one that involves Vodafone and the government is quite a tangled one. The company has been absolved of tax liability… – Continue reading
Documents released during the internet giant’s court battle with the US Internal Revenue Service over a possible $1.5bn in unpaid taxes detail a complex restructuring and a deal with Luxembourg that delivered Amazon multimillion-dollar savings Amazon is facing a landmark court ruling in the US that could prise open its… – Continue reading
What is FATCA? FATCA refers to US legislation more fully known as the Foreign Account Tax Compliance Act and includes the US Treasury regulations implementing it. It was enacted as part of the Hiring Incentives to Restore Employment Act of 2010 (otherwise known as the, “HIRE Act”) on 18 March… – Continue reading
On February 15, 2016, the President of the Russian Federation signed Federal Law No. 32-FZ “On Amendments to the First and Second Parts of the Russian Tax Code (with Respect to the Taxation of Controlled Foreign Companies and the Income of Foreign Organizations)”, introducing a new set of amendments to… – Continue reading
Having launched and led the battle against offshore tax evasion, America is now part of the problem DEVIN NUNES raised eyebrows in 2013 when, as chairman of a congressional working group on tax, he urged reforms that would make America “the largest tax haven in human history”. Though he was… – Continue reading
Mumbai Tribunal rules buyback transaction taxable as capital gains, exempt under India-Mauritius Tax Treaty; even if considered as dividend, tax withholding does not apply This EY Tax Alert summarizes a recent ruling of the Mumbai Income Tax Appellate Tribunal (Tribunal) in the case of Goldman Sachs (India) Securities Pvt. Ltd…. – Continue reading
Last month the European Commission launched its Anti Tax Avoidance Package, propelled by unprecedented political support for the fight against perceived tax avoidance by multinationals. In it the European Union stresses its full support for recent recommendations of the Organisation for Economic Cooperation and Development’s (OECD) BEPS project and it… – Continue reading
CAN NEPAL IMPOSE CAPITAL GAINS TAX ON NCELL BUYOUT DEAL? This question has been making rounds ever since TeliaSonera, the largest shareholder in Nepali telecom operator, Ncell, announced its decision to sell 60.4 per cent of its stake in the telecom company to Malaysian giant, Axiata, for $1.03 billion. Divergent… – Continue reading
Wealthy taxpayers who split time between states should be prepared to prove where their true home lies. You’re lounging by the pool of your second home in Florida, chuckling as you think of your friends back home braving the blizzard in Massachusetts. And you’re musing: Perhaps it’s time to escape… – Continue reading
Apple has sold $12billion in bonds as part of another scheme to lower its tax bill. The tech giant got itself further into debt even though it has $215billion in the bank, more than the US Treasury. California-based Apple sold the bonds under a complicated scheme which is reportedly designed… – Continue reading
NEW DELHI: The tax department today said it has resolved disputes totalling Rs 5,000 crore with foreign companies in sectors like software and consultancy under the Mutual Agreement Procedure(MAP) in about two years time. The countries with which the cases have been resolved are the US, Japan, the UK and… – Continue reading
(Special) – If you’re planning on leaving Canada soon, don’t give up on contributing to your Registered Retirement Savings Plan (RRSP). If you become a non-resident of Canada, you can still contribute to an RRSP provided you still have accumulated contribution room available. “Your contribution room is determined by your… – Continue reading
Taipei, Feb. 15 (CNA) The Ministry of Foreign Affairs said Monday that Taiwan and Italy have completed an agreement to avoid double taxation and tax evasion. The Ministry of Foreign Affairs said Monday that Taiwan and Italy have completed an agreement to avoid double taxation and tax evasion. The ministry… – Continue reading
Similar trade agreements have been used to facilitate apparent tax avoidance in the past A controversial new trade deal between the EU and the United States could make it more difficult to fight tax avoidance, a new report has warned. TTIP, the Transatlantic Trade and Investment Partnership, is expected to… – Continue reading
On February 15, 2016 the President of the Russian Federation signed Federal Law No. 32-FZ on Amendments to Parts One and Two of the Russian Federation Tax Code (Regarding Taxation of Profits of Controlled Foreign Corporations and Income of Foreign Entities) (the “Law”). The Law introduces a number of amendments… – Continue reading
The 2016 Singapore Transfer Pricing Guidelines on related-party loans The Inland Revenue Authority of Singapore published the 3rd edition of its Transfer Pricing Guidelines on the second working day of the New Year. In this new edition, the IRAS’ expectations concerning related-party loans have been slightly elaborated. The guidelines now… – Continue reading
Russia has come close to blacklisting the UK as a tax haven as concerns grow over Scotland’s booming offshore business. The Kremlin’s Finance Ministry had announced that it would officially equate Britain with traditional “fiscal paradises” like Panama, the British Virgin Islands and the Caymans. Such a humiliating move would… – Continue reading
If the apparent demise of the Coalition’s push to increase the GST shows anything, it’s that Australians are unwilling to accept tax reform unless it is obviously fair. It is right to think that rich people should pay more tax than the poor. Happiness studies show an extra dollar means… – Continue reading
The Australian Treasury on February 11 opened a consultation on whether Australia should adopt into law final OECD/G20 base erosion profit shifting (BEPS) transfer pricing recommendations. The goverment seeks feedback on the adoption of the BEPS report, Alleging Transfer Pricing Outcomes with Value Creation, which has been approved by G20… – Continue reading
Non-competition agreements can be a valuable tool for purchasers who want to protect their investments in new businesses. However, non-competition agreements can have unintended and unexpected tax consequences, particularly to sellers who grant non-competition agreements to purchasers. The Income Tax Act (Canada) (the Act) contains specific provisions regarding the taxation… – Continue reading
China has one of the most archaic corporate tax systems in the world, from which the new value-added tax structure was supposed to provide much-needed relief. China’s tax complexity and inconsistent enforcement has become an efficiency drain on China’s own economy and a roadblock to foreign companies wishing to set… – Continue reading
In tax law, the concept of residency is used to determine tax liability based on whether there is a sufficient connection between an individual or legally recognized entity and a jurisdiction such that the jurisdiction is justified in taxing such individual or legally recognized entity on their worldwide income. Generally,… – Continue reading
The South African Revenue Service (SARS) still does not know the full extent of tax evasion, despite its work probing foreign bank accounts held by South African residents. It has been a year since SARS confirmed some account holders had been using their offshore accounts to evade their tax obligations,… – Continue reading
Australian Treasurer Scott Morrison says overseas companies selling digital products to Australians will not be able to avoid paying the GST. The so-called Netflix Tax that would see overseas-based businesses selling digital products to Australians collect 10 percent GST has entered the House of Representatives. Introduced by Treasurer Scott Morrison,… – Continue reading
Taxing decisions With highly efficient labour markets, a solid institutional environment and a strong banking system, Canada has long been considered one of the most competitive nations in the world. In fact, in its most recent rankings in 2014, Bloomberg declared Canada the second best country in the world for… – Continue reading
Kenya enacted a new law targeting units of foreign companies that escape remitting most of their domestic taxes by allocating income to tax havens while attributing expenses to the East African nation, a practice known as transfer pricing. The Tax Procedures Act gives the Kenya Revenue Authority powers to investigate… – Continue reading
Officials said the Central Board of Direct Taxes (CBDT) has asked the taxman to send across to it all such cases for exchange of information which are getting “time barred” by March 31. With the current financial year coming to a close soon, CBDT has asked the Income Tax department… – Continue reading
Journalist Steve Topple investigates Bermuda-based big business tax avoidance and its links with UK political parties – and even some charities LAST WEEK saw the news emerge that everyone’s favourite search engine, Google, only had to pay £97m in back-tax (not the “major success” of £130m as was first reported)… – Continue reading
More Americans than ever before are turning their backs on the United States. The number of citizens and long-term residents cutting their official ties to Uncle Sam jumped more than 20% last year to 4,279, according to a CNNMoney analysis of the latest government data. It’s a trend that’s been… – Continue reading
A dreaded disease is spreading like wildfire – in all 50 of the United States. It debilitates most successful business owners … then, ravages some or all of his kids and eventually hurts the grandkids. Known by various names, the most common name is “estate-tax-itus”: It drains family wealth. The… – Continue reading
NEW DELHI: As the current fiscal nears its end, Sebi has stepped up its surveillance to check tax evasion attempts through ‘arbitrage’ and bogus losses using stocks and mutual fund investments. Towards the end of every financial year, the manipulators tend to devise new ways of tax evasion, including incurring… – Continue reading
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
‘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
The Authority for Advance Rulings, a quasi-judicial tax body under the finance ministry, has reaffirmed that capital gains earned by a Mauritius-registered company from transfer of shares of an Indian firm shall not be taxable in the country if the foreign corporation doesn’t have a local permanent establishment. In doing… – Continue reading
Tempur Sealy swung to a loss in the fourth quarter as a tax dispute with Denmark that may take years to resolve continued to weigh on the world’s largest mattress maker. The net loss of $11.3 million, or 18 cents a share, reflected in part a balance sheet charge related… – Continue reading
WASHINGTON — Zimbabwe’s central bank governor, John Mangudya, on Thursday blamed the sustained decline of the country’s economy on illicit cash flows, saying more than a billion dollars was externalized last year. Presenting his 2016 Monetary Policy, Mangudya said some $684 million was exported to foreign accounts by individuals while… – Continue reading
McDonald’s Australia was able to more than halve its tax bill last year after routing payments via the low-tax nation of Singapore. Each year McDonald’s reduces its profit, and thus its local tax bill, by paying McDonald’s Asia Pacific based in Singapore, and registered in Delaware, a “service fee” amounting… – Continue reading
The announcement of another tax and exchange control amnesty in this year’s budget is keenly awaited by some South African taxpayers. The looming implementation of the Common Reporting Standard for the automatic exchange of financial information between more than a hundred countries seems to be fueling the desire for another… – Continue reading
Revenue spike sees tech firm’s parent company, Alphabet, valued at $568bn – surpassing Apple’s valuation of $535bn Google has become the world’s most valuable listed company after announcing that its global revenues rose 13% to $75bn (£52bn) last year, and the group’s tax rate fell to just 17%. The group… – Continue reading
Estonia has become the first country in the world to offer a transnational digital identity. It’s attracted the attention of entrepreneurs and digital nomads worldwide, but there’s still a huge amount of confusion about the benefits of the E-Residency Program and what e-residency actually means. Let’s take a look. What… – Continue reading
Regulatory and investor pressure have drastically altered the hedge fund industry in recent years. With managers increasingly looking for fund administrators to provide more middle-office and value-added services, whilst at the same time squeezing them on fees, the situation has become a Gordian Knot. Administrators must find ways to remain… – Continue reading
In the heyday of strict implementation of tax laws, it is a welcome relief to some taxpayers that a tax treaty relief application (TTRA) is after all, what it is supposed to be, a relief. To begin with, tax treaties are entered into by countries to reconcile their respective fiscal… – Continue reading
The British Virgin Islands (BVI) Court tightens up on creditors raising spurious disputes and relying on arbitration clauses to avoid insolvency. There has been a recent trend in the BVI whereby debtor companies have sought to identify what appear to be spurious disputes and then rely upon arbitration clauses in… – Continue reading
European Commission’s tax avoidance plan announced last week includes positives, like country-by-country reporting, but doesn’t go far enough to turn the tide against corporate tax dodging; Such reporting should be made public The European Commission last week announced proposals for new laws to tackle tax avoidance and evasion in the… – Continue reading
