Category: Shares

Withholding tax on dividends – A bagful of uncertainties and complexities?

Muscat: One of the many changes that the Royal Decree 9 of 2017 (RD) has made in the Oman Income tax law is the introduction of withholding tax (WHT) on payment of ‘dividends on shares’ by Omani companies. This amendment requires Omani companies distributing dividends on shares to foreign persons...

Credit Suisse (CS) Faces Tax Fraud & Money Laundering Probes

Credit Suisse Group AG (CS – Free Report) is facing money-laundering and tax-evasion investigations involving thousands of account holders. In addition to the homeland, the investigation covers the Netherlands, Britain, Germany, France and Australia. The probes were triggered after FIOD, the Dutch office for financial crimes prosecution, got a tip...

Time to tackle the shell companies

Hyderabad: Shell companies are becoming a common phenomenon globally and even in India. These companies are posing several challenges to governments and regulators for various reasons had been probing their involvement in large scale money laundering and tax avoidance cases. A shell company is a non-trading organisation that does not...

Five things agents and developers need to know about the non-dom tax changes

From 6 April 2017, non-dom owners of UK property will be liable to inheritance tax (IHT) at 40% on any UK residential property they own. This has always been the case where a non-dom (broadly an individual who is resident in the UK but who has their permanent home abroad)...

Russian Federation: Confirmation Of Direct Investment In Capital To Apply A Reduced Tax Rate On Payment Of Dividends

On 30 December 2016 the Commercial Court of Voronezh Oblast delivered a judgement in case No. А14-10190/2014 (the “Decision”) under the claim of Ilyushin Finance Co. Open Joint Stock Company (the “Company”). The case is an example of a broad interpretation of the list of documents confirming entitlement to a...

Companies Get Draft Instructions for U.S. Global Tax Reports

U.S. multinational companies with more than $850 million in annual consolidated gross income now have draft instructions for filing IRS reports on their global tax and profits. The Internal Revenue Service added instructions to the draft Form 8975 and accompanying draft Schedule A it released in December 2016, companies that...

New tax measure takes aim at Offshore Trusts

A bombshell hidden in the detail of the 2017 Budget review relates to the taxation of offshore trusts. It refers to the 2015 Budget review in which it was announced that measures would be introduced to the tax treatment of foreign companies held by interposed trusts. No specific countermeasures were...

Amendments to Profit Tax Law in Republic of Srpska of Bosnia and Herzegovina

The National Assembly of the Republic of Srpska (RS) adopted amendments to the Profit Tax Law on 28 December 2016. The main changes have become effective as of 1 January 2017 and will be briefly presented in this article. With the amendments, the Law clarifies the definition of “taxable person”...

The ‘indirect transfer provisions’ monster

The most important task of the Finance Minister in the 2017-18 budget is to tame the “Indirect Transfer Provisions” monster born out of amendments to Section 9 of the Income Tax Act, 1961. In response to the Supreme Court’s judgement in the famous Vodafone case, the Finance Act, 2012 amended...

From Israel to Canada: New Tax Treaty to Help Structure Investments

On December 21, 2016, the new Canada–Israel tax treaty entered into force. The new treaty was signed on September 21, 2016 in New York, and replaces the existing treaty that dates from 1975. For most purposes, the provisions of the new treaty took effect as of January 1, 2017. Overall,...

The favourable tax regime of new Italian residents

The 2017 Budget Law introduced (starting from fiscal year 2017) favourable provisions for people wishing to become tax residents in Italy. It is aimed at wealthy individuals who wish to bring in new capital resources. The regime is inspired by the non-domiciled resident regime which is in force in the...

India may leave tax treaty with Netherlands unchanged

India is unlikely to amend its tax treaty with the Netherlands as it did with Mauritius, Singapore and Cyprus and this could shape the investment strategy of foreign portfolio investors (FPI) and private equity (PE) funds investing in India, said three people in the know. “There were talks to amend...

Swedish Bank Merger Rules Aim to Limit Risk of Tax Imbalance

A plan by Nordea Bank AB to merge with subsidiaries in Denmark, Finland and Norway has prompted Sweden to revise its laws to minimize the risk of a tax imbalance when a foreign company’s shares and other financial instruments are merged with those of domestic company. Effective Jan. 1, the...

A Classic Case Of Double Taxation?

The Central Board of Direct Taxes in India issued Circular Number 41 on December 21, 2016 providing clarifications on applicability of ‘indirect transfer’ provisions under the Indian Income Tax Act, 1961 to investors of Foreign Portfolio Investors (FPIs) – earlier known as Foreign Institutional Investors (FIIs) in India. The circular...

Singapore Goes The Mauritius Route, Loses Right To Tax Equity Capital Gains Arising In India

Starting April 1, 2017, India will have the right to tax capital gains arising on Indian equity shares sold by a Singapore resident. The governments of India and Singapore have amended the double taxation avoidance treaty between the two countries, in line with the changes India recently made to a...

South African Tax Bills Approved By Parliament

South Africa’s Ministry of Finance has published the 2016 Taxation Laws Amendment Bill (TLAB), which has received parliamentary approval and gives effect to the tax changes announced in the Budget in February this year, together with legislation confirming the final details of the Special Voluntary Disclosure Program (SVDP). With changes...

Switzerland eyes AEOI with 21 countries

Switzerland, which has been working to end its years-long practice of banking secrecy, on Thursday said it aimed to dramatically increase the number of countries it cooperates with toward international fiscal transparency. The Swiss government said in a statement that it wanted to extend the automatic exchange of information (AEOI)...

Implementation of Common Reporting Standard in Hong Kong – Implications for Family Trust with a Private Trust Company as Trustee

The Organization for Economic Co-operation and Development (OECD) issued the Standard for Automatic Exchange of Financial Information in Tax Matters (Standard for AEOI) in July 2014, which aims to prevent offshore tax evasion and maintain the integrity of tax systems. Over 100 jurisdictions have committed to comply with the Standard...

India, Cyprus ink new Double Tax Avoidance Agreement

New Delhi– India on Friday signed a revised double taxation avoidance agreement (DTAA) with Cyprus, an official statement said here. “A revised agreement between India and Cyprus for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion (DTAA) with respect to taxes on income, along with its protocol,...

High Court confirms tax evasion by companies linked to wealthy businessman Vanda Gould

A series of companies associated with high-flying Sydney accountant who had scores of wealthy clients in Sydney’s eastern suburbs have been found to have avoided paying tax by the High Court, in a case that the tax office has described as “blatant tax evasion”. Four companies linked to accountant, Vanda...

Penny stocks may come under long-term capital gains tax net

Mumbai: The government plans to withdraw tax exemption on long-term capital gains (LTCG) made on the sale of penny stocks to end the use of stock markets for tax evasion as part of a series of steps to eradicate black money, two people familiar with the development said. “The government...

India-Korea DTAA notified, capital gains to be taxed at source

India has notified the revised double tax avoidance agreement with South Korea under which capital gains tax will be levied at the source with effect from April 1, 2017. The existing Double Taxation Avoidance Convention, which has been in vogue for three decades, provides for residence-based taxation of capital gains...

China’s tax authorities to begin financial data collection on foreign residents from January

Days of underpaying taxes to end soon as China takes part in worldwide scheme on swapping information on foreign residents’ financial assets The mainland tax agency wants to collect the financial information of non residents who live in China as it takes part in a multilateral scheme to crack down...

Tax haven: The devil is always in the detail

In July 2016 the then Indonesian finance minister Bambang Brodjonegoro, in conjunction with the launch of the widely publicized tax amnesty program (TAP) for undeclared offshore assets, also laid out less publicized plans for a new tax haven on the islands of Bintan and Rempang (Proposed Tax Haven). A key...

Facebook pays just £4million in tax while lavishing British staff with £165MILLION

Accounts show each of the firm’s 682 workers took home average of £242,000 each in 2015 Facebook lavished £165million on its UK staff last year, while handing the taxpayer just £4million. Accounts show each of the firm’s 682 workers took home average of £242,000 each in 2015. The bumper payout...

Singapore wants to delay revision of tax treaty with India

Singapore is seeking more time to revise the two-decade old tax treaty with India, saying its investors need more time to shift to source-based taxation. India has, however, rejected any deferment in the revision of the treaty that will help prevent Singapore, which is the top source of FDI into...

Bahamas files: New leak exposes offshore ‘tax haven’ dealings of politicians, companies

Five months after the Panama Papers exposed the offshore dealings of government leaders and influential people, a new leak of 1.3 million files has revealed the names of individuals associated with companies registered in the Bahamas, a notorious tax haven. The files – received by the German newspaper Süddeutsche Zeitung...

India, Mauritius to discuss revival of FTA, two-way investments today

Top officials from India and Mauritius will meet in Port Louis this week to discuss revival of free trade agreement (FTA) negotiations that were suspended three years ago by New Delhi. The talks were suspended to build pressure on Mauritius to expedite the double taxation avoidance agreement. Deliberations on two-way...

Bank secrecy rules face ‘lethal blow’ in Uruguay

Gov’t sends bill to Congress to force banks to share account data automatically Described by government officials as a “lethal blow” to bank secrecy, Uruguay has sent a bill to Congress that will force banks to automatically provide the DGI tax bureau information on the accounts held by individuals and...

EU tax probes could threaten international agreements, US warns

The US has warned the EU that it risks damaging international agreements on tax reform if it continues to act as a “supra-national tax authority”. The US Treasury Department “shares the European Commission’s concern with tax avoidance by multinational firms. The international community, including the EU and its member states,...

Cabinet approves signing of revised DTAA with Cyprus

The Union Cabinet on Wednesday gave its nod for signing of revised double taxation avoidance agreement (DTAA) with Cyprus, a popular tax haven. It is also learnt to have approved the removal of island nation as a non-cooperative jurisdiction for income-tax purpose. Cyprus was the only country to have been...

What is the future of corporate tax reform?

On June 7, AEI hosted two panels on how the US could reform the corporate tax code, the first focusing on business-level taxation and the second focusing on shareholder-level taxation. Christopher H. Hanna of the Senate Finance Committee delivered the symposium’s opening remarks, with a major focus on how the...

Pakistan mulls providing tax-free zones to stimulate investment

In order to encourage foreign investment in Pakistan, the federal government has decided to provide facilities like Panama and Virgin Islands to foreign investors in Pakistan. According to documents available with Daily Times that government is going to introduce the companies’ bill 2016 in parliament soon according to which incumbent...

Changes to India-Mauritius-Singapore Tax Treaties – Mind the Gap?

As many are now aware, the double tax avoidance arrangement (DTAA) between India and Mauritius was amended through the protocol released last month. The direct impact summarized in one line is as follows: India shall now tax capital gains arising from alienation of shares by a Mauritius investor acquired on...

Swiss get ‘largely compliant’ rating for tax assistance – finance ministry

Neutral Switzerland has got an overall rating of “largely compliant” in an international review of how well it shares information with other countries on tax matters, the finance ministry said on Tuesday. Swiss officials hailed the outcome as crucial recognition of their efforts to shed the country’s reputation as a...

India Revamps Its Treaty Provisions With Mauritius

The Government seeks to curb revenue loss, prevent double non-taxation, streamline the flow of investment, and stimulate the flow of exchange of information between India and Mauritius The India – Mauritius double taxation treaty was under negotiation for the last 4 years. The Treaty has now been amended by way...

Brexit – The UK and International Tax Consequences

The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications of Brexit, this OnPoint also considers some of the potential tax implications from the perspective of...

India, Cyprus finalise DTAA; capital gains to be taxed at source country

India and Cyprus have reached an in-principle agreement on all pending issues on Double Taxation Avoidance Agreement, including taxation of capital gains, which once implemented would help remove the island-nation from a non-cooperative jurisdiction for income tax purposes. An official level meeting between India and Cyprus in New Delhi last...

Tax conundrum for Indian-focused offshore private equity funds

Foreign private equity investors typically set up offshore pooling vehicles for routing investments into India, which offer them twin advantages of ease of administration and single window compliance with the Indian regulatory regime. Setting up such pooling vehicles in a tax favourable jurisdiction ensures that the interposition of the pooling...