Category: Statutory

FATCA privacy singapore bermuda cayman islands jersey canada usa legislation tax information exchange agreements statutory iga

Despite the inevitable move towards automatic exchange of tax information and Common Reporting Standards internationally, there continues to be a steady flow of litigation in the Courts of International Financial Centres such as Bermuda, the Cayman Islands, and Singapore relating to challenges to inter-governmental Tax Information Exchange Agreement (TIEA) requests…. – Continue reading

Switzerland: TAX NEWS: Swiss Voters Reject Introduction Of Swiss Federal Inheritance Tax – Current Cantonal Inheritance And Gift Tax System Remains Unchanged

After a controversial political debate, the Swiss voters have decided to reject the popular initiative to introduce a federal inheritance tax with a vast majority of 71.7% in the popular vote of 14 June 2015.. The 26 Cantons also unanimously rejected the the popular initiative. The clear result shows that… – Continue reading

C’tee recommends tax breaks on IP brought to Israel

Companies registering their intellectual property in Israel will be charged only 5% tax on dividends. The committee considering changes in the Law for the Encouragement of Capital Investments, headed by former Ministry of Finance director general Yael Andorn, is recommending extension of the tax break granted under the law to… – Continue reading

U.S. Treasury attempts to influence OECD’s BEPS initiative via proposed changes to U.S. model treaty

The United States has been criticized on more than one occasion for failing to be a meaningful participant in the OECD’s multi-pronged initiative to address base erosion and profit shifting (BEPS). Some commentators have even gone so far as to accuse the United States of actively working against the BEPS… – Continue reading

Transactions between Raje’s son Dushyant and Lalit Modi under scanner

Amid a swirl of allegations involving Lalit Modi’s business interests, the government is examining evidence of tax evasion and unlawful foreign exchange transactions between the ousted IPL commissioner and BJP MP Dushyant Singh. Sources told HT the Enforcement Directorate (ED), which tracks overseas transactions and money laundering deals, is scrutinising… – Continue reading

Mauritius to act against black money: Finance Minister Seetanah Lutchmeenaraidoo

NEW DELHI: Mauritius has offered to put in place stringent conditions for investors seeking benefits under its tax treaty with India to weed out post-box operations, addressing a key concern of New Delhi that has been attempting to amend the agreement for years. “We don’t want investors to open shell… – Continue reading

Mauritius assures India will not allow shell companies

Lutchmeenaraidoo, who met foreign minister Sushma Swaraj, played down the issue of misuse of the India- Mauritius Double Taxation Avoidance Convention (DTAC). Mauritius will make it difficult for shell companies using a liberal and controversial bilateral tax treaty with New Delhi to evade taxes in India, said the island nation’s… – Continue reading

FATCA – Which Countries Are In And Out

FATCA – Which Countries Are In And Out The controversial US Foreign Account Tax Compliance Act (FATCA) law is set to start from July 1, 2014, so with less than 21 days to go, here’s a look at which countries are in and who is outside of the tax network…. – Continue reading

Will local budgetary deadlock derail campaign for 12.5% tax rate in North?

Business and politicains all want it but welfare reform demand from London has thrown up an unexpected hurdle If corporation tax were cool, Eamonn Donaghy of KPMG in Belfast would be the Bono of his world – half quiet tax accountant, half buccaneering campaigner with a nifty sideline in high-level… – Continue reading

What would real welfare reform look like?

Britain’s welfare bill can be reduced without eliminating the safety net – but not with a series of crude caps or freezes, explains Spencer Thompson. Today’s public finance statistics show progress towards reducing the deficit. Net borrowing has fallen by almost a quarter on a year ago, partly driven by… – Continue reading

Cyprus: The Potential Impact Of Russian De-Offshorization Legislation On Cyprus Holding And Finance Structures

Abstract Over the past 25 years, Cyprus has become the portal of choice for investment into and out of Russia and Central and Eastern Europe. The new Russian de-offshorization law, which took effect on 1 January 2015, will have significant implications for users of overseas structures. This article examines the… – Continue reading

FATCA documentation for disregarded entities

Introduction The Foreign Account Tax Compliance Act (FATCA) requires entity account holders to document their status for US withholding tax purposes (Chapter 3 status) and their status for FATCA due diligence purposes (Chapter 4 status). In the case of a non-US entity account holder that has made an entity classification… – Continue reading

New tax treaty with Mauritius may affect cross-border investment

THE new double-tax treaty between SA and Mauritius is set to come into force in January next year, following a controversial renegotiation to better protect the South African tax base. However, tax experts have warned that sweeping changes to the treaty, including withholding taxes for interest (10%) and royalties (5%)… – Continue reading

Birth of a New Era in Private Wealth

As the financial world continues its march towards a more transparent and open environment, regulations governing private wealth are under scrutiny. The traditional is changing for good while new players emerge. Once was a time, not too long ago, the words “Swiss bank” conjured up evocative imagery: secret deals; bank… – Continue reading

Frustrated by Rs 20,495-crore tax demand on Cairn: Vedanta

MUMBAI: With its subsidiary Cairn India facing Rs 20,495-crore tax notice, billionaire Anil Agarwal-led Vedanta Group today said it is “frustrated” by the tax demand raised on it using retrospective legislation. The Income Tax Department had in March slapped a Rs 20,495 crore tax demand on Cairn India for failing… – Continue reading

Russian Federation: Russian De-Offshorisation Legislation And Voluntary Disclosure: Which Way Now?

The new law on the taxation of controlled foreign companies (the ‘CFC’ law) and other anti-offshore measures effective as of 1 January 2015 have raised a number of questions for clients and advisers. A number of changes to the new laws were long anticipated and have now been passed by… – Continue reading

Canada: The Estate Planner: The Effective Use Of Trusts In Connection With Income Splitting – Part IV Of IV

Part I of this series of articles reviewed some of the basic tax requirements for using trusts to split income, Part II discussed a number of tax planning opportunities that can be accessible through the use of trusts, and Part III reviewed traditional testamentary trust income splitting planning and the… – Continue reading

G7 fails to stop the dirty money trail, tax evasion

Dirty money resulting from crime, corruption and tax evasion is estimated to cost over one trillion dollars every year. It exacerbates poverty and inequality, and should be regarded as one of the most pressing issues globally. An Oxfam report found that G7-based companies and investors cheat Africa out of tens… – Continue reading

Offshore incorporations continue to grow

The Cayman Islands saw a 17 percent increase in new company registrations in 2014 over the previous year, according to a report released today by offshore law and fiduciary firm Appleby. In 2014, 11,010 new companies registered in Cayman, noted the firm’s latest ‘On the Register’ report, which provides insight… – Continue reading

Update: key ruling affecting Maryland taxpayers with out-of-state income – tax refund opportunity now available

Maryland residents who pay income tax to other states may be entitled to a refund of local income taxes paid in prior tax years. The U.S. Supreme Court in Comptroller of the Treasury of Maryland v. Wynne et ux. recently affirmed a Maryland Court of Appeals ruling that the state’s… – Continue reading

Israel: Renewing Your US Passport? The IRS Will Know About It

Individuals who renew their US passport need to take into consideration that their Social Security Number (SSN) and country of residency will be forwarded to the IRS. Since July 2014, the passport renewal instructions forms have dedicated a specific paragraph detailing this new procedure: “Section 6039E of the Internal Revenue… – Continue reading

ETVEs (Spanish foreign-securities holding companies)

A special scheme is provided for foreign-securities holding companies or ETVEs (Entidades de Tenencia de Valores Extranjeros) in the Corporate Income Tax (“CIT”) Act 27/2014. ETVEs are regular limited liability companies (S.L., S.A. or other company forms), subject to the normal CIT on its income, but exempt from taxation on… – Continue reading

China’s trust industry debuts offshore bond

Zhongrong International Trust became the first issuer from the Chinese trust industry to venture into the offshore bond markets on Monday with a $225 million three¬year transaction. Over the past decade trust companies have become the second largest segment of China’s financial sector behind commercial banks, racking up assets of… – Continue reading

BEPS: The impact of the interest limitation rule on investment

OVERSEAS investment by Thai companies has been surging in recent years and this trend is almost certain to continue. One of the questions frequently asked by Thai investors when seeking to acquire foreign operating companies or establish overseas subsidiaries is what type of funding structure would be the most tax… – Continue reading

Malta shell company helps Azerbaijan’s ruling family gain millions at country’s expense

A Malta-based shell company is linked to financial transactions which likely saw Azerbaijani President Ilham Aliyev and his family amass hundreds of millions of euro at the expense of the country he leads and its citizens. FA Invest (Malta), whose registered address is in the Cornerstone Complex in Mosta, has… – Continue reading

Investment Funds Update – Europe: Legal and regulatory updates for the funds industry from the key asset management centres and primary European fund domiciles: UK

MiFID II – FCA Issues Discussion Paper on MiFID II Implementation Measures The FCA issued a discussion paper (DP15/3) on 26 March 2015, asking firms for their views on a range of MiFID II implementation measures, including on: The revised inducements standards. Receipt of commissions and other benefits by discretionary… – Continue reading

London based Investment Association, ASIFMA seeks to be party in Castleton case over MAT

MUMBAI: Two associations representing foreign portfolio investors are seeking to join the battle over minimum alternate tax in the Supreme Court, although analysts are unclear if entities without a tax treaty will benefit. Investment Association, based in London, and Hong Kong-based Asia Securities Industry & Financial Markets Association (ASIFMA) plan… – Continue reading

Offshore Status of Hong Kong Companies

Hong Kong is often seen as a favorable business location, due to its low tax rates, easier access to the Asian market, as well as a relatively stress-free establishment procedure. The region’s stable political environment and excellent finance and banking services also provide investors with a better business environment. Moreover,… – Continue reading

JERSEY SEES 10% RISE IN NEW COMPANY INCORPORATIONS IN 2014

Jersey experienced a 10% increase in new company incorporations in 2014 over the previous year, according to a report released today by Appleby, one of the world’s largest providers of offshore legal, fiduciary and administrative services. Last year also saw the total number of active companies on Jersey’s registry rise… – Continue reading