Pretoria – South African financial institutions, which include banks, long-term insurers and asset managers, will have to exchange financial account information in terms of the common reporting standard for the first time this year. Financial institutions, although having to do similar exchanges in terms of the US’s Foreign Account Tax...
You may be liable for capital gains tax. Here’s how. There is a common misconception that the sale of a person’s primary residence will never result in capital gains tax being payable; this is incorrect. For most taxpayers the sale of a primary residence will not result in a taxable...
Kosovo and Switzerland signed on Friday an agreement regulating taxation of income and capital, which is beneficial for both countries, the Swiss federal government said. Under the agreement on double taxation dividends will be taxed at source at a maximum rate of 15%, while qualified participations – at no more...
The deadline for submitting automatic exchange of information (AEOI) returns for the year ended 31 December 2016 is 31 May 2017 for financial institutions, and that this is the first year for common reporting standards (CRS) filing Returns should include reportable accounts for the financial accounts tax compliance act (FATCA),...
Apartment construction is booming as the wealthy rush to invest in rental housing as a way to reduce inheritance tax and banks hand out easy mortgages, but concerns are mounting that excessive supply paired with a shrinking population could soon lead to the bursting of the bubble. New starts on...
Grandfathering is term for alteration of rules that apply to a certain investment technique Foreign portfolio investors (FPIs) based in Mauritius and Singapore had, it now appears, rushed to take advantage of the ‘grandfathering’ clause in the new Double Tax Avoidance Agreement signed between both the governments of the two...
REVENUE generated from taxing offshore gaming operations here is expected to double in 2017, or less than a year since the industry was regulated, with the Philippine Amusement Gaming Corporation’s (PAGCOR) online gaming arm noting high demand for licenses. PAGCOR’s recently established Philippine Offshore Gaming Operators (POGO) estimates that it...
The Union Cabinet has given its approval for the signing of multilateral convention to implement tax treaty-related measures to prevent base erosion and profit shifting. A product of OECD/ G20 BEPS Project, this convention is aimed at tackling baseerosion and profit shifting through tax planning strategies that exploit gaps and...
The Common Reporting Standard (the CRS) is, like FACTA (the Foreign Account Tax Compliance Act), an information exchange regime aimed at realising international tax transparency. Exchange of information under CRS is achieved by requiring certain bodies including banks and other “Financial Institutions”, to collect data and report some of it...
The Indonesian government on Tuesday issued a regulation in lieu of law (Perppu) to end bank secrecy in the country, with officials of tax offices allowed to directly access bank accounts owned by both Indonesian citizens and foreigners. Perppu No. 1/2017 on financial information access for taxation purposes was signed...
The Revenue Commissioners have today, 16 May 2017, issued detailed user guides on automatic exchange of information reporting requirements for Irish financial institutions covering both FATCA and CRS/DAC2 reporting obligations. The new guidelines set out in detail the process for filing FATCA and CRS/DAC2 returns, including the new functionality for...
FATCA is unfair to Europe because the US government is not playing fair with tax information by failing to swap data. Members of the European Parliament are calling for the American IRS to give them information on European taxpayers with cash and investments in the US. The argument hinges on...
The South African Revenue Service (SARS) launched the Special Voluntary Disclosure Programme (SVDP) in October 2016, providing taxpayers with the opportunity to make good on any tax and/or exchange control contraventions of which they may be guilty in relation to offshore investments. The nine-month window period opened on October 1,...
The IMF has urged Ireland to ensure that it has a broad tax base, particularly in the context of international tax reform and domestic pressures to reform the Universal Social Charge (USC). The IMF has published the findings of its latest mission to Ireland. It noted that healthy economic growth...
The U.K’s diverted profits tax was dubbed the ‘Google Tax’ even before its introduction in April 2015. Yet instead of netting foreign tech companies engaged in complex tax planning such as California-based Google Inc., only U.K. multinational companies outside the technology sector have issued warnings so far over the tax...
Major U.S. multinationals are pushing the Trump administration to deepen the tax break it has already tentatively proposed on $2.6 trillion in corporate profits being held offshore, a key piece in Washington’s intricate tax reform puzzle. As President Donald Trump tries to deliver on his campaign promise to overhaul the...
Norway’s Ministry of Finance has released a consultation on a proposal to further strengthen the nation’s restrictions on interest deductions within groups. The regime, introduced in 2014, is intended to prevent groups from establishing subsidiaries in lower tax territories from which to lend capital to companies in a higher tax...
Malaysian individuals and entities that have bank accounts overseas will soon see their financial information being shared with other countries and tax authorities in an effort to boost global transparency and tax compliance. This requirement is part of the automatic exchange of financial account information set out by the Organisation...
Newly-elected French president Emmanuel Macron has committed to reducing the rate of corporation tax from its current level of 33.3% to 25%, with the aim of bringing it in line with the EU average within five years Reductions in the rate of corporate tax will begin in stages from 2018...
Australian Treasurer Scott Morrison’s 2017 Budget focused on measures to cool the housing market and crack down on tax avoidance. Morrison handed down the Budget on May 9. He said the the budget would return to a surplus in 2020-21 and remain in surplus over the medium term. The Budget...
The federal government has pledged to create more fairness for businesses and “level the playing field” through a series of budget measures directed at tackling Australia’s so-called “black economy”. The government gave its “black economy taskforce” the job of investigating how individuals and businesses use cash payments in December 2016,...
The United States continues to be a magnet for immigration, with nearly 8 million new immigrants settling here between 2008 to 2014 — and some of these new immigrants are high-net-worth individuals who are unprepared for the intricacies of the U.S. tax law, according to Seth Entin, a shareholder at...
European Union presidency holder Malta has launched a new attempt to salvage pending EU legislation designed to eliminate withholding taxes for cross-border interest and royalty payments in the EU single market. One of the key hurdles the Interest and Royalties Directive has faced in the Council of Economic and Financial...
Foreign ownership of new developments will be restricted, there will be steeper charges applied to purchases, less favourable tax treatment and charges on those with empty properties, in a raft of measures in the federal budget aimed at taking the sting out of the housing market. One measure to be...
This article is the first of a series of articles that looks at tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors. An essential feature of...
Four of the most significant transnational organizations are working together to eliminate transfer pricing schemes and abuses. The four organizations—the International Monetary Fund, the Organization for Economic Co-operation and Development, the United Nations and the World Bank Group—are seeking to achieve global cooperation in tax matters. Transfer pricing is one...
Only a few days left for this financial year to end and tax filing deadline is striking the calendar. Indian Government has already taken many initiatives to simplify the tax filing process by introducing new ITR forms, online filing facility etc. Yet many taxpayers tend to make silly mistakes while...
Kuwait became the 110th jurisdiction to sign the Multilateral Convention on Mutual Administrative Assistance in Tax Matters on May 5, 2017. The OECD describes the Convention as the most powerful instrument for international tax cooperation. It provides for all forms of administrative assistance in tax matters: exchange of information on...
NEW DELHI: A complex web of 393 shell companies used for allegedly diverting funds unscrupulously to the tune of Rs 2900 crore has been unearthed by the CBI during its probe into such cases over the last three years. CBI sources said the shell companies were allegedly being used by...
It has been more than a year since the Australian government committed itself to remedying the nation’s double taxation scheme for cryptocurrencies. The delay in crafting a fix has left some observers wondering whether the issue had been set aside entirely. In a statement released this week, the government has...
NEW DELHI: India’s apex body for direct taxes has proposed new rules for bringing the value of unquoted shares on a par with the fair market value of underlying assets, seeking to prevent tax avoidance by firms that use the historical acquisition cost to set the price of unlisted stock....
NEW DELHI: The Pension Fund Regulatory and Development Authority has clarified that NPS accounts of investors who have not submitted the Foreign Account Tax Compliance Act (FATCA) self certification will not be blocked. The clarification, sent to the registered email addresses of NPS investors on Thursday, comes as a relief...
HM Revenue and Customs has updated the International Tax Compliance Regulations to include provisions on new automatic tax information exchange agreements and to clarify how non-compliance penalties will apply. The amendment clarifies due diligence and reporting requirements for financial institutions, to ensure the UK complies with international tax reporting standards,...
KARACHI: The Federal Board of Revenue (FBR) has initiated audit of all those taxpayers who have made offshore transactions during the last six years, sources said on Tuesday. “All corporate and individual taxpayers, who have made offshore investments, have been selected for audit to check the tax concealment,” an official...
Governments are expanding their use of tax incentives to maintain their country’s international appeal to businesses, alongside the adoption of anti-base erosion and profit shifting measures, according to a survey from EY. EY’s survey of tax policy professionals in 50 countries found that, “While the long-term trend for countries to...
Germany will introduce “license barrier rules” as of January 2018. The new rules will limit the tax deductibility of license fees or royalty payments to foreign related parties that benefit from preferential regimes (“Patent Box”, “IP-Box”, “License Box”) which are incompatible with the “OECD nexus approach” (“unqualified preferential regimes”) (sec....
The total loss to EU member states from the schemes revealed in the Panama Papers could be in the region of between EUR109bn (USD119bn) to EUR237bn, according to a new study commissioned by the European Parliament’s PANA committee. The Committee of Inquiry into Money Laundering, Tax Avoidance, and Tax Evasion...
In a world of data breaches and political unrest, the concept of confidentiality faces a certain death, warned British Virgin Islands lawyer Tim Prudhoe on Tuesday. Rather than fear the future, the Kobre & Kim partner advised offshore tax jurisdictions to embrace transparency and find benefit in a turbulent world....
Starting on April 27, and finishing on May 2, the European Parliament (EP)’s Committee of Inquiry into Money Laundering, Tax Avoidance and Tax Evasion (PANA) is holding two meetings to present several related studies which address the impact of, and the fight against, tax evasion and money laundering, particularly in...
A newly published federal draft law introduces Russia to a three-tiered approach to transfer pricing documentation and brings Russian regulations in this area in line with the OECD minimum standards under Action 13 of the Base Erosion and Profit Shifting (BEPS) Action Plan. The draft law, published by the Ministry...
New transfer pricing regulations issued by the State Administration of Taxation (SAT), the Measures for Administration of Special Tax Investigation Adjustment and Mutual Agreement Procedures (“the Measures”), came into effect on May 1, 2017. The Measures consolidate China’s pre-existing regulations regarding self-adjustment and outbound payments with the new transfer pricing...
(Second of two parts) In last week’s article, we discussed the revised procedure to avail of tax treaty benefits for dividend, interest, and royalty payments under Revenue Memorandum Order (RMO) No. 8-2017. Under the amended rules, a tax treaty relief application (TTRA) is no longer required and withholding agents can...
The European Court of Justice (ECJ) has ruled in favor of Austria in its dispute with Germany relating to the taxation of interest from profit-participation certificates received by an Austrian bank from a German bank. The case involved the interpretation and application of Article 11 of the 2000 double tax...
It often occurs that a multinational company employs a foreign manager based on an employment contract or secondment. In the first case, the Hungarian company is considered as the legal and economic employer, therefore the salary is payed directly by it. In the second case, the employee maintains the employment...
President Trump has signed three executive orders to spark reviews of tax and financial regulations so taxes on businesses and individuals can be cut. The approach would be different from Trump’s earlier plan, which was criticized as an approach that would mostly benefit higher earners. Michael Zezas, a strategist at...
East Africa tax experts have raised concerns over increasing cases of tax evasion and fraud by some tax payers in the region which is crippling the economies. They made the remarks on Wednesday during the 6th East Africa regional meeting on tax investigation and enforcement in the Rwandan Capital Kigali....
Witnesses call for repeal of Foreign Account Tax Compliance Act An agreement that has resulted in hundreds of thousands of Canadian banking records being sent to the U.S. Internal Revenue Service could violate the U.S. constitution, a congressional subcommittee heard Wednesday. Testifying before a subcommittee of the House Committee on...
The Federal Inland Revenue Service (FIRS) and the Economic and Financial Crimes Commission (EFCC) are putting a new breath to the fight against tax fraud and evasion in Nigeria, as the two agencies will soon launch an anti-tax fraud and evasion team. This collaboration, according to the FIRS Executive Chairman,...
Deloitte survey highlights tax predictability as key to driving investment growth in Asia Pacific New Zealand well placed against backdrop of increased uncertainty in Asia Pacific’s tax landscape New Zealand’s tax policies are seen as relatively straight forward, consistent and predictable compared to other countries in the region, according to...
Many of the data submissions made by early adopters over the next two months under the new common reporting standard (CRS) are likely to be rejected and returned for correction and resubmission, adding to compliance costs, according to predictions from Sovos, a global tax compliance solution provider The UK is...
