Category: Activity

FATCA blamed for one in five US expats planning to give up passport

One in five US citizens living abroad are on the verge of giving up their passports according to a survey published by US tax consultants Greenback. The Greenback survey – which was conducted by more than 3,000 US expats – studies the expat community’s opinions on taxation, citizenship renunciation, and… – Continue reading

Villanueva urges DILG to crack down on tax-evading POGOs

Senator Joel Villanueva has urged the Department of Interior and Local Government (DILG) to order local government units and police to crack down on Philippine offshore gaming operations (POGOs) that refuse to comply with the country’s tax laws. Villanueva also backed the Department of Finance’s (DOF) order to shut down… – Continue reading

EU Commission to investigate 39 Belgium “excess profit” tax rulings for potential State aid violations

The European Commission today announced that it has opened 39 in-depth investigations to assess whether Belgian “excess profit” tax rulings granted to multinationals between 2005 and 2014 provided benefits that are contrary to EU State aid rules. ... - Continue reading

IRS offers tax break to some American expats

The Internal Revenue Service (IRS) has outlined new procedures for some “accidental Americans,”, giving them the chance to comply with their US tax and filing obligations and in turn qualify for relief from back taxes, penalties and interest. The changes would allow people with less than $2m in net worth… – Continue reading

US-born British citizen launches crowdfunding campaign to stop FATCA

A US-born British citizen has started a crowdfunding campaign to stop HMRC sharing her personal information with the US Internal Revenue Service (IRS) under the US Foreign Account Tax Compliance Act (FATCA). Law firm Mishcon de Reya has taken on the UK case for a client who alleges HMRC is… – Continue reading

Saint Amans provides update on digital tax reform effort

The preliminary results of an impact assessment reveal that proposals advanced in an OECD-led effort to update the global rules for taxing digital businesses would not create large changes to countries’ existing taxing rights, Pascal Saint-Amans, OECD Director of the Centre for Tax Policy and Administration, said September 11. ... - Continue reading

Colombia: Colombia Publishes Guidelines On Advance Pricing Agreements

Colombia's National Directorate of Taxes and Customs (DIAN) released detailed guidelines (the Guidelines) to clarify the procedure for Advanced Transfer Pricing Agreements (APAs) requests in order to ensure certainty between the parties regarding their transfer pricing arrangements. ... - Continue reading

Ukrainian government approves bill ratifying FATCA

The Cabinet of Ministers has approved a bill to ratify the Agreement between the governments of Ukraine and the United States to improve tax compliance and application of provisions of the U.S. Foreign Account Tax Compliance Act (FATCA) and related bills, the Ukrainian Finance Ministry’s press service reported. “On September… – Continue reading

OECD sees progress in 116 nations’ implementation of country-by-country reporting

The OECD said its initiative to have minimum standards on the collection and exchange of country-by-country (CbC) reports on large multinational businesses has reached 116 jurisdictions and has shown major progress in the delivery of international tax transparency. The OECD’s second annual peer review report on the base erosion and… – Continue reading

Canada: Canada Ratifies The Multilateral Instrument

On June 7, 2017, Canada along with numerous other jurisdictions signed the Organisation for Economic Co-operation and Development’s (“OECD”) Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “MLI” or “multilateral instrument”). The multilateral instrument is the culmination of work undertaken as part of the OECD/G20 BEPS Project to equip governments with domestic and international instruments to address tax avoidance.   ... - Continue reading

Cyprus: The Cyprus Investment Programme And The Benefits

The Cyprus Investment Programme is rapidly becoming one of the EU’s most popular residence schemes.

  • Non Cypriot citizens (and their families) can acquire Cyprus Citizenship by investing €2.5 million* in Cyprus.
*In one specific set of circumstances as detailed below in the financial criteria, the investment required is €2.0 million. A non-Cypriot citizen who meets one of the financial criteria detailed below can apply for Cypriot citizenship ‘through naturalization by exception’.
  • Following the application, Cyprus citizenship will be granted in six months, assuming the application has been completed accurately and the correct documentation filed.
  • The applicant needs to be in posession of a residence permit for a period of six months before obtaining the citizenship.
... - Continue reading

Canada: Transfer Pricing: What’s New In Canada (Part II)

Transfer pricing disputes in Canada have, predominately, been resolved through either a request for competent authority assistance under the Mutual Agreement Procedure ("MAP") of a treaty, or, to a much lesser extent, through the notice of objection process with CRA Appeals.  Regardless of the recent increase in transfer pricing cases being brought before the Courts, the MAP will likely continue to be the dispute resolution process most often utilized by a Canadian corporation in transfer pricing cases because, in the absence of a 100% reversal of a transfer pricing adjustment by either CRA Appeals or a Canadian court, economic double taxation may still exist as a consequence of the CRA upward transfer pricing adjustment. The correlative relief provided by the treaty partner under a MAP settlement resolves that double taxation. ... - Continue reading

Australia provides arm’s length debt test guidance

The Australian Tax Office on 28 August, released its awaited draft guidance contained in Practical Compliance Guideline 2019/D3, on applying the arm’s length debt test contained in Division 820 of the Income Tax Assessment Act 1997, Australia’s thin capitalization statutory provisions.   ... - Continue reading

FBR demands Rs992m from TV channel in alleged tax evasion case

ISLAMABAD: The Federal Board of Revenue (FBR) has served a notice on ARY Communications Limited (ARY) and raised a tax demand of Rs992 million – alleging that the entity had evaded tens of millions in taxes through misrepresentation, concealment and misuse of exemptions, thereby causing a substantial loss to the… – Continue reading

HMRC collects record £191bn in income tax

The taxman is raking in record amounts in income tax as the latest figures reveal Britons paid an extra £11bn in 2018/19. Income tax receipts have soared to a record £191bn, according to figures published, a 6% increase from the previous year. Britons are paying almost 30% more income tax… – Continue reading

ICAB happy with Barbados’ removal from the EU’s blacklist

Barbados’ removal from the European Union’s (EU) blacklist has been welcomed by the Institute of Chartered Accountants of Barbados (ICAB). During her welcome remarks at the 15th Annual ICAB International Business Workshop, at the Barbados Hilton Resort, ICAB’s Executive Director, Kathy-Ann Hewitt, stated: “We are indeed happy that this change… – Continue reading

Canada, Switzerland ratify instrument to tackle tax avoidance

Canada and Switzerland on August 8 deposited with the OECD their instruments of ratification for the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS MLI). The BEPS MLI, negotiated by over 100 countries and jurisdictions, updates the existing network of tax treaties and… – Continue reading

OECD’s minimum tax to apply by jurisdiction

The Organisation for Economic Co-operation and Development is going to propose a global minimum tax that would apply country by country before the next meeting of G‑20 finance ministers and central bankers set for 17 Oct. in Washington, DC. G7 leaders announced at their Biarritz summit meeting this week a… – Continue reading

British citizens born in America face having bank accounts frozen

Tens of thousands of British citizens born in the US but only lived there for a few months or years face having their bank accounts frozen as part of a crackdown by the US tax authorities.    The Internal Revenue Service (IRS) is ordering British banks to hand over the… – Continue reading

United States: D.C. Circuit Expands U.S. Prosecutors’ Reach Over Foreign Bank Documents

In a recent decision, the U.S. Court of Appeals for the D.C. Circuit unanimously affirmed a district court order compelling three Chinese banks (not currently identified) to produce financial records in response to subpoenas issued by U.S. federal prosecutors, including records that were unrelated to the banks' U.S. operations or U.S. correspondent accounts. ... - Continue reading

Transfer pricing: DGIT starts analysing potential cases of MNCs

The Directorate General of International Taxes of the Federal Board of Revenue (FBR) has started analysing a few potential multinational companies’ cases of transfer pricing where companies are directly involved in shifting their profits outside the country without payment of any taxes. In this regard, Directorate General of International Taxes… – Continue reading

Govt launches crackdown on benami assets

ISLAMABAD: The government has kicked off a far-reaching crackdown against benami assets directing the departments concerned at the federal level and the provincial governments to track benami properties, harvesting the Benami Act, 2019 in the national and global contexts. Prime Minister Imran Khan chaired a meeting on August 20 on… – Continue reading

Gaming Companies Call for Reaching USA-Croatia Double Taxation Avoidance Deal

ZAGREB, August 21, 2019 – Computer gaming is the most propulsive segment of the IT industry worldwide, and this trend is present in Croatia, too, where local gaming companies export all their products, however the biggest challenge in doing business is the absence of a Croatia-USA double taxation avoidance agreement,… – Continue reading

German economics minister sees SMEs as “secret weapon”: report

German Minister for Economic Affairs and Energy Peter Altmaier had developed a strategy for the “Mittelstand” or small and medium-sized enterprises (SMEs), the newspaper Handelsblatt reported on Wednesday. “In the eyes of foreigners, SMEs are Germany’s secret weapon and, unlike the Dax 30 companies, SMEs are proving to be extremely… – Continue reading