Category: Statutory

Profit shifting ‘just a part’ of Africa tax loss

MULTINATIONAL companies shifting their profits from Africa to low-tax jurisdictions are only partly responsible for the erosion of the continent’s tax revenue bases. The African Tax Administration Forum (Ataf) believes some countries have signed away their tax revenue because of weak domestic policies, and ill-conceived tax incentives and mining contracts…. – Continue reading

Cyprus: Cyprus Chapter Of ‘Global Legal Insights – Corporate Tax’ – Second Edition

Despite being among the smallest countries in terms of area and population, over the past 40 years Cyprus has developed into one of the world’s most important financial and business centres. It has numerous advantages, including a strategic location, a mature and transparent legal system based on common law, world… – Continue reading

The difference between a telecoms network and real estate? About $3.2 billion

Tax avoidance, the American way. Little Rock, Arkansas-based telco Windstream has caused a stir by announcing a novel scheme to reduce the amount of federal taxes it has to pay. It intends to spin off certain network assets into a publicly traded real estate investment trust (REIT). In so doing,… – Continue reading

Pfizer refuses to rule out tax inversion deals

High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Emailftsales.support@ft.com to buy additional rights. http://www.ft.com/cms/s/0/b494286e-171e-11e4-b0d7-00144feabdc0.html#ixzz393LkTft5 Pfizer refuses to rule out tax inversion deals By Andrew Ward, Pharmaceuticals CorrespondentAuthor alerts… – Continue reading

Do You Want the Global Destruction of Financial Privacy to Enable Higher Tax Rates and Bigger Government?

It’s a bad idea when governments demand information on your bank accounts and investments so they can impose economically destructive double taxation. It’s a worse idea when they also demand the right to tax economic activity in other jurisdictions (otherwise known as “worldwide taxation“). And it’s the worst possible development… – Continue reading

Denmark – A Tax Haven?

Artur Bugsgang, partner at leading Danish law firm LETT looks at Denmark’s tax advantages. Denmark currently ranks fifth in the world in their ease of doing business index. The country is significantly less bureaucratic than the majority of its European neighbours, especially in regard to establishing and operating companies. Despite… – Continue reading

Offshore participants in government procurements ought to reveal their owners

YEREVAN, July 17. /ARKA/. Russia’s government has approved the package of legislative changes which make offshore companies’ access to the state’s money more complicated. They no longer will be provided by guarantees and they will be obliged to reveal beneficial owners in government procurement auctions. The demands turned out to… – Continue reading

IRS Releases Long-Awaited Instructions to FATCA Form

Foreign entities use this to document their status On June 25, 2014, the Internal Revenue Service released long-awaited instructions to Form W-8BEN-E, used by foreign entities to document their status under both chapter 3 and chapter 4 (the Foreign Account Tax Compliance Act (FATCA)) of the Internal Revenue Code. The… – Continue reading

Parthasarathi Shome’s suggestions on indirect transfer of assets under consideration: Finance Ministry

The finance ministry will soon consider tax expert Parthasarathi Shome’s suggestions on possible instances where offshore sale of Indian assets need not be taxed here, said a finance ministry official. The Shome Committee had in its 2012 ‘Report on Retrospective Amendments Relating to Indirect Transfer of Indian assets’ suggested that… – Continue reading

Ireland: FATCA Update

On Friday, 27 June 2014, the Irish Revenue Commissioners (in conjunction with the Department of Finance) finalised the relevant Regulations with respect to FATCA. These Regulations will come into operation on 1 July 2014. As readers will be aware, the Irish and US Governments signed an intergovernmental agreement (“Irish IGA”)… – Continue reading

Azerbaijani banks permitted to make reports to other states about their customers directly or through mediators

Baku, Fineko/abc.az. Azerbaijan de facto joined the American tax reporting system FATCA (Foreign Account Tax Compliance Act): on July 8 President Ilham Aliyev sanctioned the Azerbaijani banks to report to other states about their customers directly or through mediators. The President of Azerbaijan approved the relevant amendments to the law… – Continue reading

Seychelles: Seychelles Company Incorporation

The Seychelles offer a wide variety of financial services, including offshore banking, investments and insurance. The inexpensive International Business Company (IBC) is the most popular corporate entity and can be used for many purposes with few limitations. The International Business Company IBC is the most widely used vehicle for offshore… – Continue reading

Dropped plans on tax avoidance could have affected legitimate charities, says Treasury minister Nicky Morgan

HMRC and Morgan both say the proposals, announced last year in the Autumn Statement, will not be included in the Finance Bill 2014 The government has abandoned plans to introduce legislation that would make it tougher to set up a charity for tax-avoidance purposes because it would have had a… – Continue reading

Obama signs bill with hidden provisions affecting non-US financial institutions

President Obama yesterday signed into law a bill which contains little-publicised elements that are expected to impact non-US financial institutions, funds and collective investment structures. The bill’s passage on 8 March 2010 represents a success for certain US lawmakers who have been seeking to crack down on Americans who have… – Continue reading

Russia Approves Direct Information Exchange on US Taxpayers

MOSCOW, June 25 (RIA Novosti) – Russia’s upper house of parliament, the Federation Council, on Wednesday authorized the direct exchange of information between Russian banks and US tax authorities on US taxpayers. The US Foreign Account Tax Compliance Act (FATCA) requires foreign banks to supply the Internal Revenue Service (IRS)… – Continue reading

Canadian industry claims win in long fight over U.S. crackdown on tax evasion

Canada’s investment and banking industries hailed a key victory Tuesday in five-year fight to dull the impact of onerous new U.S. tax rules expected to affect about a million Canadian residents and dual citizens. A newly ratified inter-governmental agreement with the United States excludes registered accounts for education, retirement, and… – Continue reading

Your Taxes: Israel to sign tax treaty with Panama

With regard to business operations, a resident of one country (e.g., Panamanian company) may be taxed in the other country (e.g., Israel) if it has a “permanent establishment” (PE) in the other country. Panama is famous for its canal, colorful history and cool offshore tax regime. To that we can… – Continue reading

Russia ready to collect information on its depositors abroad

The Russian authorities are ready to provide the U.S. internal revenue service with information on American depositors, but have drafted a bill for similar measures in the United States. All foreign banks that work with Russian clients will be obligated to disclose information about such clients to Moscow. Primarily, the… – Continue reading

US Congress to deny federal contracts to Bermuda-based offshore companies — plan

Bermuda has again been singled out and labelled “a tax haven” by US legislators as they last week attached an amendment to US federal funding measures, seeking to block federal contracts to former American companies involved in corporate inversions. A leading publisher of financial information, Bankrate Inc, reported at Bankrate.com:… – Continue reading

United Kingdom: The UK Introduces New Criminal Offence For Tax Evaders

The UK Chancellor, George Osborne, announced new sanctions against offshore tax evasion, last month. The UK government intends to introduce a new “strict liability” criminal offence for not declaring untaxed offshore assets. Under the plans announced by the Chancellor, HM Revenue & Customs (HMRC) would no longer need to prove… – Continue reading

Italian Supreme Court ruling maintains arm’s-length principle must apply to related companies within Italy

The Italian Supreme Court ruled, on April 16, that all transactions carried out between companies belonging to the same Group, and all of which have offices in Italy, are subject to the arm’s length principle. Ruling No. 8869 confirmed once more the Supreme Court’s position already expressed through Ruling No…. – Continue reading

TRA starts to apply refined rules in cross-border transactions

The Tanzania Revenue Authority (TRA) has set up new tax determination guidelines aimed at providing consistency in tax administration on both domestic and cross-border transactions.The new system –“Transfer Pricing Regulation” will also provide taxpayers with insights on the procedures followed in determination of income tax, duty and levies in various… – Continue reading

Turning FATCA into a Competitive Advantage

Regulatory compliance is an ongoing, escalating cost that is stifling profitability. Today, the “cost of compliance” is now 85% of a financial institution’s average operational budget, leaving a mere 15% available for programs like business development and customer acquisition. Many institutions continue to rely on disconnected, incomplete approaches to regulatory… – Continue reading

Consultation puts tax law plans in spotlight

THE Department of Finance has launched a public consultation on how Ireland’s tax system might respond to proposed international changes. The Organisation for Economic Cooperation and Development (OECD) is already conducting a public discussion around its Base Erosion and Profit shifting (BEPs) project, which could see tax avoidance loopholes shut… – Continue reading

Don’t delay law for sharing tax information with U.S., Canada’s investment industry urges

The head of Canada’s investment industry association is urging the federal government not to defer legislation that will facilitate handing tax information of U.S. citizens living in Canada to authorities in the United States. Ian Russell, chief executive of the Investment Industry Association of Canada, made his pitch to the… – Continue reading

Asia needs bond tax rethink

Exempting domestic currency government bonds from withholding tax is long overdue in much of South and East Asia as the move would have a significant and beneficial economic impact. The mature economies in Europe and North America (and also Japan, Hong Kong and Singapore) no longer withhold tax on government… – Continue reading