Category: Statutory

Bonus shares: SECP suggests FBR to withdraw 5 percent tax, apply 12.5 percent CGT

The Securities and Exchange Commission of Pakistan (SECP) has proposed to the Federal Board of Revenue (FBR) to withdraw 5 percent tax on bonus shares and apply current capital gains tax (CGT) rate of 12.5 percent irrespective of its holding period. According to the budget proposals of the SECP received… – Continue reading

Business group warns on offshore tax measures

A powerful business lobby is sounding the warning to lawmakers about a global effort to crack down on offshore tax evasion. The National Association of Manufacturers warned the top congressional tax writers that the so-called Base Erosion and Profit Shifting project “could have a negative impact on the global competitiveness… – Continue reading

Asia: Tax & Trust Developments Taking Center Stage

Developments in Asia over the last year have been continuous with the biggest generic development relating to the exchange of information. Asian countries have put their FATCA reporting systems in place (even though not all have yet signed an inter-governmental agreement with the US IRS), and most have now committed… – Continue reading

What Nigeria, Singapore stand to gain from investment promotion, protection pact –Ambassador Rajis-Opara

From today, negotiation on the Investment Promotion and Protection Agreement (IPPA) between Nigeria and Singapore will start in Abuja, aimed at enhancing business between the two countries. Revealing this in an interview with the African Independent Television (AIT), Nigerian High Commissioner to Singapore. Mrs. Nonye Rajis-Opara, said there would be… – Continue reading

1MDB guilty until proven innocent, Dr M says

KUALA LUMPUR, May 29 — Unless proven innocent, it must be assumed that the management of 1Malaysia Development Berhad (1MDB) had misappropriated the funds invested in Cayman Islands, Tun Dr Mahathir Mohamad said today in his continued tirade against the troubled state investment firm. The former prime minister said although… – Continue reading

Avago’s Pending Broadcom Purchase Taps Arcane Tax Structure

Avago Technologies Ltd.’s pending takeover of Broadcom Corp. taps an arcane tax structure that has being dusted off amid a rise in cross-border mergers. Avago said it is prepared to offer Broadcom shareholders special partnership units that would defer any taxes triggered by the $37 billion tie-up, which was announced… – Continue reading

Is it US taxable income? Unintended consequences when US residents receive assets from their family’s foreign corporations

It is not uncommon for affluent families from certain countries to maintain offshore structures to hold a portion, and often times a significant portion, of their wealth. The reasons for holding assets outside of their country of residence are many, and such assets are frequently held in foreign corporations. As… – Continue reading

Funds diverted from Swiss banks

After Switzerland initiated measures to regulate its banks, most of the unaccounted money stashed in Swiss banks is suspected to have been diverted to countries like Mauritius and Singapore. The Special Investigation Team on black money has taken cognisance of the issue raised by the enforcement agencies. “Although the Swiss… – Continue reading

Raising your next fund: the rising tide of global regulatory change

There has recently been a wave of global regulatory reforms which affect fundraising. These changes are far-reaching and can impact how fund managers structure funds, their proposed investor base, how and where funds are marketed, the remuneration that may be received, registrations that may be required and dealings with investors…. – Continue reading

Foreign investors ask Romania’s Govt. for higher penalties for tax evasion

The Foreign Investors Council (FIC), an association of the leading investors in Romania, has asked the Government to increase penalties against companies that do not pay their taxes and to work on bringing down the subterranean economy, rather than aggressively targeting honest taxpayers. “Penalties for tax evasion should be increased… – Continue reading

Mexico: Risks And Opportunities From A Mexican Tax Perspective

Investments Derived From Structural Reforms The approved structural Reforms are an unprecedented opportunity for a transformational economic growth in Mexico, being the most relevant from an investment point of view the reforms related to Energy, Telecommunications and Antitrust, which have put Mexico in the radar of Multinational companies seeking to… – Continue reading

UAE firm sues Korea over taxation

A state-run United Arab Emirates (UAE) company and its Dutch subsidiary filed a request for arbitration Thursday, seeking compensation from the Korean government over taxation worth US$170 million five years ago, a civic group said Friday, reports the Korea Times. The Lawyers for a Democratic Society said the Abu Dhabi-based… – Continue reading

Regional Co-operation on Taxation: Avoiding harmful tax competition

The objectives of the Southern African Development Community (SADC) Protocol on Finance and Investment include enhancing the productive capacity of the economies in the region and thereby increasing trade opportunities to eventually alleviate poverty. To achieve the objectives, various strategies can be employed, including, among others, improving the investment regime,… – Continue reading

Malta dangles its citizenship for a price

As wealthy foreigners rush to get citizenship in Malta under a new programme, the residency requirement is taking many forms. Russians rent high-end villas, then stay in five-star hotels when they visit. An American financier plans to live in Switzerland but occasionally vacation in Malta. One Vietnamese businessman, eager to… – Continue reading

Malta’s credibility as financial centre takes another hit over battle for Gaddafi’s money

Malta’s credibility as a financial centre has taken another hit as news broke this week about a legal battle for the millions of euros accumulated by Mutassim Gaddafi – son of Libyan dictator Muammar Gaddafi – currently frozen in a Bank of Valletta account. Malta’s role in all this came… – Continue reading

WHY COMPETITION MAY SOMETIMES BE HARMFUL

While marketplace competition is desirable, competition among governments is not always desirable Is more competition always better? Most conventional economists would say yes. And, in the marketplace, that nugget of economists’ wisdom usually holds true. Every student of first-year economics is taught that competition is good for consumers, as it… – Continue reading

Belgium and Russia sign new tax treaty

Belgium and the Russian Federation announced in March 2007 that they would negotiate a new double tax treaty (the “Treaty”). Nearly seven years after discussions began on 20 November 2008, the Treaty was finally signed on 19 May 2015 in Brussels. This newsflash is based on an unofficial version of… – Continue reading

International tax and withholding considerations for US companies and their directors

To staff their board of directors with the best and most diverse talent, multinational companies commonly elect boards with international representation. It is also common for companies to convene periodic board meetings outside the United States. This may be done, for example, to provide board members with an opportunity to… – Continue reading

India to go for ‘face-to-face’ talks with low tax jurisdictions for fast recovery of black money

The finance ministry, after due consultations with the SIT on black money and various financial probe agencies, has decided that a team of senior officials will hold bilateral meetings with foreign jurisdictions either in India or at the locations of their counterparts to thrash out issues quickly, reports the India… – Continue reading

Georgia seeks broader economic ties with Poland

Georgia and Poland held negotiations in Warsaw this week over an agreement on avoiding double taxation on income and capital. At the bilateral meeting the sides initialed the renewal agreement, which is based on the OECD Model Convention 2014 and envisages the introduction of new standards of cooperation in taxation… – Continue reading

Resolving cross border tax disputes through Australia’s investment treaties

1. Global focus on transfer pricing There has been a recent surge in regulatory attention around the world towards pricing arrangements within multinational corporate groups. Regulators are concerned that these pricing arrangements may be used as a means of profit shifting and therefore tax avoidance. The price at which an… – Continue reading

German tax deferral rules infringe EU law

German tax law allows deferring the tax on certain disposal gains by transferring the hidden reserves in the disposed assets to similar newly acquired or newly produced assets (“Replacement Assets”). The tax deferral requires an allocation of the Replacement Assets to a German permanent establishment. The ECJ has recently ruled… – Continue reading

Tax evasion: FBR probing Axact’s foreign assets, transactions

ISLAMABAD: The Federal Board of Revenue (FBR) has decided to launch an investigation into Axact Pakistan (Pvt) Limited’s assets in foreign countries, including the United Kingdom and the United Arab Emirates, bank accounts, credit card transactions and internet marketing in and outside Pakistan. FBR’s subsidiary Directorate General Intelligence & Investigation… – Continue reading