In its continuing effort to keep the BVI Business Companies Act (the “Act”) at the forefront of offshore company law legislation, the BVI Government, in direct consultation with the private sector, has introduced several updates to the Act as follows: To allow weighted voting by directors whereby certain directors may… – Continue reading
(Special) – Winter brings with it the dream of many Canadian snowbirds of owning a piece of property in the sunny south. With the recent rebound in the U.S. housing market and a decline in the value of the Canadian dollar, however, buying vacation property south of the border may… – Continue reading
Although the British Virgin Islands is often seen as an offshore tax haven, a closer look shows such opinions may be overstated There is a stereotypical image of the so-called ‘tax haven’ for ‘shady people to put their money’. While it is true that BVI Finance enjoys warm, sunny weather… – Continue reading
Insurers and financial advisers are required to know the tax information of their customers, according to guidance published by the Association of British Insurers (ABI) and the Association of Professional Financial Advisers (APFA). The new requirement follows UK information exchange agreements including Foreign Account Tax Compliance Act, agreements with Crown… – Continue reading
Representatives of the Cyprus and the Ukrainian governments have signed, in Kiev, on Friday, 11 December 2015, a protocol amending their Double Tax Avoidance Treaty. The protocol is based on the Model Tax Convention for the Avoidance of Double Taxation OECD. The changes need to be ratified by both the… – Continue reading
Non-Belgian shareholders with a participation in a Belgian company with an acquisition value of at least €2.5m (but not reaching the 10 per cent participation threshold under the Parent–Subsidiary Directive) are now entitled to the Belgian participation exemption regime. In C-384/11 (Tate & Lyle Investments), the European Court of Justice… – Continue reading
Here’s our overview of recent Belgian tax developments, including the main new Belgian tax measures adopted by the laws of 18 and 26 December 2015. Speculation tax A ‘speculation tax’ of 33 per cent is introduced on capital gains realised by Belgian resident and non-resident individuals within six months from… – Continue reading
Walmart stock has put up one of its worst performances in recent history. Walmart continues to be plagued by a number of issues including swelling costs and poor e-commerce growth. Against this backdrop, can Walmart stock make a comeback in 2016? Can Walmart Stock Make A Comeback in 2016 Walmart… – Continue reading
Japan, Taiwan January 4 2016 After many years of discussion and negotiation, Taiwan’s Association of East Asian Relation and Japan’s Interchange Association finally signed 「THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVAION WITH RESPECT TO TAXES ON INCOME」(the “DTA”) in Tokyo on 26 November 2015. For the… – Continue reading
The Ministry of Finance has announced a withdrawal of the one per cent withholding tax imposed on interest earned by individuals on any investments. The tax imposition on interests is part of provisions in the new Income Tax Act, 2015 (Act 896) which came into force on January 1, 2016…. – Continue reading
Yet another amnesty scheme mocks honest taxpayers The Federal Board of Revenue (FBR) has once again admitted its failure in dealing with the powerful class of traders in forcing them to file tax returns as other persons do. The government of the day, as expected, is more than keen to… – Continue reading
Two more investment banks have reported paying zero tax in Britain in 2014, prompting the opposition Labour party to urge the government to reverse a tax change it made for banks last year. Citigroup and Credit Suisse disclosed in the past fortnight that their main UK subsidiaries paid no corporate… – Continue reading
LOOPHOLE:The consulting firm said the transfer of shares from one tax shelter to another would theoretically allow their owners to avoid real-estate transaction taxes The government is likely to step up auditing efforts as a number of major tax amendments come into effect this year, diminishing the effectiveness of tax… – Continue reading
Investors in mutual fund (MF) schemes have to provide additional KYC (know your customer) information in the new year. The additional details have been mandated to ensure that India complies with tax information-sharing laws such as FATCA (Foreign Account Tax Compliance Act). The Association of Mutual Funds in India (AMFI)… – Continue reading
This is apropos a Business Recorder news item ‘Investment in Dubai real estate: NAB asks FBR to verify claims of Transparency International-Pakistan ‘. According to the report, the National Accountability Bureau (NAB) has asked the Federal Board of Revenue (FBR) to verify claims of Transparency International-Pakistan on a huge investment… – Continue reading
Dr Peter Phillips, the finance minister, is about to undo all the good he has done with the economy by implementing the proposed transfer pricing regime. The Government assures the country that this unconstitutional transfer pricing mechanism isn’t a tax, but an attempt to get affected businesses to pay their… – Continue reading
THE COUNCIL OF THE DISTRICT OF COLUMBIA (DC) recently enacted, as part of its budget, provisions that force entities doing business in any of 39 arbitrarily designated “tax havens” to report their income on worldwide combined reporting. Eighteen are Caribbean jurisdictions. A tax haven is defined by the DC code… – Continue reading
A deadline for comments on the draft guidelines to determine the tax residency of a foreign company has been extended to January 9. The government felt the need to determine a company’s place of effective management due to lack of detail in the Income Tax Act leading to the possibility… – Continue reading
Although President Barack Obama likes to snarl about the unfairness of income inequality, under his administration, the 400 top earning American families now pay about one-third less of their income in taxes than under President Ronald Reagan. The IRS each year tabulates the effective tax rates paid by 400 individual… – Continue reading
Returns on Treasury Bills or Bonds, will incur 8 percent income tax. Beginning today 1st January, 2016 all foreign investors on Ghana’s local capital or investment markets will pay 8% Withholding Taxes on their returns. This is according to the new Tax Act passed in Parliament in September 2015 and… – Continue reading
ONE | A NEW LIBERAL GOVERNMENT Elected in October 2015, Canada’s new Liberal government has proposed a tax platform featuring significant changes, including a four per cent increase (to 33 per cent) in the federal tax rate for individuals on income over C$200,000 and a 1.5 per cent drop in… – Continue reading
An Inter-Governmental Agreement between India and USA was signed for implementation of Foreign Account Tax Compliance Act (FATCA). The Government of India has also joined the Multilateral Competent Authority Agreement (MCAA) for Automatic Exchange of Information as per Common Reporting Standard (CRS). For implementation of FATCA and CRS, necessary legislative… – Continue reading
As the year comes to an end, the Cyprus Parliament in its last session before the holidays passed a series of tax updates attempting once again a balancing act between flexibility and tax transparency. Some of the most important provisions passed include the FOREX Neutralisation which targets the significant exchange… – Continue reading
Tax cheats are facing a series of year-end deadlines to come clean, as an international dragnet affecting both wealthy Canadians with offshore accounts and Americans in Canada who have failed to file U.S. tax returns keeps tightening. Lawyers say some Canadians with Swiss bank accounts have received letters demanding written… – Continue reading
On 28 December 2015, the revised Luxembourg-Singapore Agreement for the Avoidance of Double Taxation (the New Treaty) entered into force. The New Treaty (1) allows Luxembourg investment vehicles to invoke benefits under the New Treaty, (2) reduces the withholding tax rates for dividends, interest and royalties, (3) increases thresholds to… – Continue reading
MGA executive chairperson Joseph Cuschieri warns organised crime within gaming industry ‘has never been this sophisticated’ Malta Gaming Authority’s executive chairman insisted that the gaming industry will continue to flourish on the island, even if proposed EU legislation to clamp down on tax avoidance goes through. “The threat [of a… – Continue reading
US Democratic presidential hopeful Bernie Sanders has pledged a crackdown on tax avoidance involving Bermuda and other offshore jurisdictions. Mr Sanders, currently trailing Hillary Clinton in the race for the nomination as presidential candidate, made the promise on an online political channel in America. Mr Sanders said he would use… – Continue reading
On 18 December 2015, the Regulations implementing the OECD Common Reporting Standard (“CRS“) in Ireland were approved by the Irish Parliament. This update follows on from previous updates published by Maples and Calder Dublin on CRS and US FATCA and outlines the practical next steps for Irish investment funds and… – Continue reading
On 15 September 2015, the Dutch government released its budget for 2016, containing the Tax Plan 2016, which includes certain amendments to Dutch tax law. One of the proposed amendments was the inclusion of an anti-hybrid rule in the Dutch participation exemption regime (“PER”). On 22 December 2015, the amendments… – Continue reading
Legislation that enacts, as part of Belgian domestic law, the FATCA reporting provisions pursuant to an intergovernmental agreement (IGA) with the United States has been long-awaited. The Belgian tax authorities initially set a FATCA reporting deadline of 30 July 2015. However, without a law transposing the FATCA rules into Belgian… – Continue reading
Foreign Account Tax Compliance Act is a US global tax law. Countries must agree to the law or face the stick Less than 25 per cent of mutual fund (MF) investors have given out details in line with Foreign Account Tax Compliance Act, or Fatca, a US tax law, said… – Continue reading
On Nov. 18, 2015, reforms to the Mexican Income Tax Law (MITL), Tax Code, Excise Tax and Federal Income Law for 2016 (collectively, the Tax Reform) were published in the Federal Gazette. The Tax Reform reestablishes measures to promote savings and increase incentives for doing business in Mexico, some of… – Continue reading
“Cash Booked Offshore for Tax Purposes by U.S. Multinationals Doubled between 2008 and 2014” In recent years, U.S. multinational companies have sharply increased the amount of money that they book to foreign subsidiaries. An April 2015 study by research firm Audit Analytics found that the Russell 1000 list of U.S…. – Continue reading
Luis E. Benitez VEGAS Already after two years of discussions on the various actions designed by the Organization for Economic Cooperation and Development (hereinafter OECD) to address the problem of the erosion of the tax base and the transfer Benefits under the BEPS project (for its acronym in English Base… – Continue reading
According to the CBDT communique, foreign investors and companies will not be liable to pay MAT prior to April 1, 2015. According to estimates, foreign investors have to pay tax of Rs 40,000 crore for the 14-year period since April 1, 2001, when MAT was introduced. Foreign investors and companies… – Continue reading
The Transition Authority has asked counties to stop levying some fees that have seen companies exposed to double taxation. In its advisory opinion dated December 2015 on levying of taxes, fees and charges by county governments, the authority said it has over the transition period received several complaints on the… – Continue reading
Hanoi, December 23 (VNA) – The recognition of the State of Palestine by many countries worldwide and its flag-raising ceremony at the United Nations headquarters signal a positive sign and initial success of the Palestinian administration as well as a bright spot in the Middle East peace process. Chairman of… – Continue reading
(MENAFN – Arab News) RIYADH: Custodian of the Two Holy Mosques King Salman on Monday briefed the Cabinet over the phone call he received from the king of Bahrain the call he made to the president of Nigeria and the results of his talks with the chairman of the Presidency… – Continue reading
The new plan shelves one in the works to spin off Yahoo’s vast holdings in ex-commerce giant Alibaba – which could have exposed it to a huge tax bill – but the tech firm still intends to separate out its activities under the new structure. Yahoo stated it has made… – Continue reading
His Highness Sheikh Mohammed bin Rashid Al Maktoum, Vice-President and Prime Minister of the UAE and Ruler of Dubai, on Monday received Robert Fico, Prime Minister of Slovakia, and members of the accompanying delegation at Zabeel Palace. During the meeting, Sheikh Mohammed accepted an invitation from the Slovak prime minister… – Continue reading
The Irish Revenue Commissioners have confirmed that the necessary statutory instrument to bring the final common reporting standard (CRS) regulations into Irish domestic law was signed 17 December 2015 and is effective 31 December 2015. Other recent developments concerning the automatic exchange of information (AEOI) regimes, include the publication of… – Continue reading
When someone dies owning an unreported financial account, the heirs and executors of the estate are faced with a serious problem. First, assuming there is undeclared income earned with respect to the account, such income will generate a tax liability for the decedent with respect to any tax years that… – Continue reading
On Tuesday 15 December, Deloitte Luxembourg gathered around 150 business professionals from various sectors at Utopolis to this year’s last episode of the conference cycle covering the full spectrum of the Common Reporting Standards (CRS). While cinema technicians were preparing the premiere of the new Star Wars movie next door,… – Continue reading
President Obama signed the Protecting Americans from Tax Hikes Act of 2015 (the “Act”) into law on December 18, 2015. The Act extends retroactively certain provisions of the Internal Revenue Code (the “Code”) that had expired at the end of 2014 and makes a number of other changes to the… – Continue reading
Obaid Humaid Al Tayer, Minister of State for Financial Affairs, received a delegation from Ethiopia at the Ministry of Finance headquarters in Abu Dhabi. The meeting was held to discuss investment opportunities and economic cooperation between UAE and Ethiopia. The agreement on the avoidance of double taxation on income signed… – Continue reading
The Cayman Islands Tax Information Authority (TIA), on December 8, 2015 provided the following implementation updates for the Common Reporting Standard (CRS): 1. Updated Self-Certification Forms ( Individual and Entity) for compliance with CRS, U.S. and U.K. FATCA, which should be used by Cayman Islands funds. From January 1 onwards,… – Continue reading
CF Industries (CF – Analyst Report) and Netherlands-based fertilizers and industrial chemicals producer – OCI N.V. – said that they have amended their merger agreement originally announced in Aug 2015. Under the modified agreement, the jurisdiction of incorporation and tax residency of the new combined company has been changed to… – Continue reading
LONDON (Reuters) – Seven of the biggest investment banks operating in London paid little or no tax in Britain last year, despite reporting billions of dollars in profits, a Reuters analysis of corporate filings shows. In recent months, the seven investment and corporate banks operating in London reported figures showing… – Continue reading
Luxembourg’s long-hidden role as a secret tax haven in the very heart of the European Union has been shattered by one man who happened to be in the right place at the right time to do what he thought was the right thing. Antoine Deltour brought to light how the… – Continue reading
A BALANCING ACT in London, folly and redemption in America’s District of Columbia and sheer hypocrisy in Brussels. And in every case, Barbados and many of its Caribbean neighbours were placed in the negative international spotlight at a time when some of the world’s major financial centres are casting about… – Continue reading
