Category: Debt

BIR files tax evasion charges against 15 Metro Manila business taxpayers

The Bureau of Internal Revenue filed Thursday separate criminal cases against 15 business taxpayers in Metro Manila for alleged refusal to pay tax debts totaling to more than P493 million. This brought to 482 the number of tax evasion charges lodged by the bureau under its Run-After-Tax-Evaders (RATE) program under… – Continue reading

German gov’ts to have less-than-expected tax revenue in coming years

BERLIN, May 9 (Xinhua) — According to current tax estimates, the German federal, state and local governments will have 124.3 billion euros (139.5 billion U.S. dollars) less to spend by 2023 than previously predicted, the Federal Ministry of Finance announced on Thursday. According to the German finance ministry, expectations about… – Continue reading

Australia Announces Upcoming Guidance On Int’l Tax Matters

The Australian Tax Office has updated and added to its list of the guidance on international tax matters it intends to release this year. This month, the ATO intends to release a guide on corporate residency – central management and control in Australia [reference code 3838], to provide the ATO’s… – Continue reading

Poland’s PM designate says will continue fighting tax evasion

WARSAW (Reuters) – Poland will continue fighting tax evasion, allowing the government to keep public debt in check and finance its public spending agenda, Prime Minister-designate Mateusz Morawiecki said on Friday. He also told the Catholic Trwam television that value added tax revenue would most likely increase by 30 billion… – Continue reading

Government reduces tax load on MFIs receiving money from abroad

The Ministry of Economy and Finance (MEF) recently decided to shrink the tax burden for local microfinance institutions (MFIs) by lowering withholding tax on interest from loans acquired from abroad from 14 to 10 percent, a move that the government claims will keep the massive sector sustainable. This is the… – Continue reading

Cayman Budget Targets Budget Surpluses

The Cayman Islands’ Premier, Alden McLaughlin, recently delivered the territory’s first two-year budget, which was notable for the absence of new borrowing or revenue-raising measures. McLaughlin said his administration will continue to pay down debt and deliver operational budget surpluses to fund capital investment plans and provide for contingency against… – Continue reading

Philippine Government `On a Roll’ Against Tax Evaders: Dominguez

(Bloomberg) — The Philippine government plans to target additional companies in its crackdown on tax evasion, said Finance Secretary Carlos Dominguez “We are on a roll, and this is part of the president’s program to make our country more law abiding,” Dominguez told Bloomberg Television’s Kathleen Hays in an interview… – Continue reading

Vodafone Ghana sues GRA over GH¢160m transfer pricing assessment

…as tax dispute escalates Vodafone Ghana has filed a motion at the High Court of Justice, Commercial Division in Accra, against the Ghana Revenue Authority (GRA) disputing tax assessments of GH¢160 million, according to the Writ obtained by ghanabusinessnews.com. The GRA has asked Vodafone to pay 30 per cent of… – Continue reading

ATO’s finance ruling puts companies the ‘red zone’

The Australian Tax Office is preparing to take several companies to court over abuse of thin capitalisation rules and will start a wave of audits of large multinationals with complex cross-border loans, as it continues to take a hardline approach in the wake of its win against Chevron. The ATO… – Continue reading

ECJ Rules In Austria’s Favor In Tax Dispute With Germany

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… – Continue reading

Chevron: a game-changer for multinational tax avoiders

The Australian Tax Office had a superb win against Chevron in the Federal Court last week, but there is something everyone is missing, something that will turn the art of tax avoidance on its head; a game-changer for multinationals. Put simply, Chevron borrowed US$2.5 billion in the US at less… – Continue reading

Tax residency certificate is vital for claiming relief under DTAA

Tax residency certificate is required from the resident country tax authorities to claim applicable relief under the DTAA What is the purpose of a tax residency certificate? —Srivats Typically, source of income lies where the services are performed, or where the asset, from which the income arises, is located. Residential… – Continue reading

Next off the block – AEOI

You might have thought you have enough on your plate getting to grips with anti-money laundering rules closely followed by FATCA – but it’s not over yet! Next off the block is the Automatic Exchange of Financial Account Information in Tax Matters (AEOI). The AEOI, which we first provided an… – Continue reading

Chinese companies seek cheaper offshore debt after rule change

[HONG KONG] More Chinese companies are looking to raise debt offshore after Beijing approved a new funding structure last month that makes it easier and cheaper to tap foreign lenders. China’s foreign exchange regulator in January let domestic companies bring home cash raised through offshore bonds secured by onshore guarantees,… – Continue reading

Indonesia – Key Indonesian Law Considerations For International DCM Issues

Following Moody’s Investors Service affirmation of Indonesia’s sovereign credit rating at Baa3 with a stable outlook in January 2016, there has been renewed interest in the international bond market for Indonesian credits. This bulletin seeks to summarise the regulatory changes in Indonesia over the last 24 months as well as… – Continue reading

Abusive Tax Structures, Make Way For Budget 2017’s Transfer Pricing Combat Weapons

Among other things, Union Budget 2017 will be remembered for two firsts – the introduction of secondary adjustment and thin capitalisation rules. Both are transfer pricing provisions which will have a far-reaching impact on corporates. Secondary Adjustment Since the concept of secondary adjustment is introduced for the first time in… – Continue reading

OECD’s MLI: will tax treaty benefits apply to private equity investors?

The OECD recently released a public discussion draft entitled the “BEPS Action 6 Discussion Draft on non-CIV examples” to clarify when investors like private equity funds, real estate funds and hedge funds should be entitled to tax treaty benefits. The release of the 2017 Discussion Draft is timely, given that… – Continue reading

Automatic information exchange to start from 2018

KARACHI: Finance minister Ishaq Dar on Friday said that tax evaders will find no place to park their ill-gotten money, as Pakistan will begin automatic-exchange of information from next year. “As per international agreement with OECD (Organisation of Economic Cooperation and Development), Pakistan will start automatic exchange of information regarding… – Continue reading

Budget 2017: Tax Reform For Financial Services

Given the recent developments in the Indian economy, the upcoming Union Budget will certainly be critical and important in determining the future outlook of the economy. The financial services industry has been one of the key drivers of growth due to its strong cause and effect relationship with the economy…. – Continue reading

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… – Continue reading

Double taxation: Ecuador, Italy sign agreement to foster private investements

Ecuador signed an agreement with Italy to define the tax obligations of the citizens of the two countries, in order to avoid double taxation on income taxes and equity and prevent tax evasion, the Ecuadorian Foreign Ministry said. “This protocol modifies the agreement signed in Ecuador and Italy in 1984… – Continue reading

OFFSHORE TAX HAVENS COST SMALL BUSINESSES ON AVERAGE $5,128 A YEAR

Small businesses in the U.S. have to shoulder, on average, an extra $5,128 in taxes to make up for the revenue lost due to the abuse of offshore tax havens by multinational corporations, according to a new report by U.S. Public Interest Research Group Education Fund. As a new administration… – Continue reading

Taxman targets Real and Barca over fraud, says report

Giants Real Madrid and Barcelona are among five La Liga clubs from whom the Spanish taxman is looking to recover €52 million (RM244 million), online newspaper El Confidencial claimed yesterday. Alongside Atletico Madrid, Sevilla and Valencia, the big two are accused of having avoided tax by paying player’s agents directly…. – Continue reading

Trump’s Corporate Tax Reforms: What CFOs Need to Know

While Trump wants to close loopholes, many of them stem from public policy concerns — not “special interests.” After a dramatic upset victory in one of the most bitterly contested presidential races in recent history, Donald Trump now has some serious work to do. His corporate tax policies—which are vital… – Continue reading

Vietnam Set to Update Transfer Pricing Thresholds from 2017

Vietnam’s Ministry of Finance released a draft circular on October 11th which, if passed, is set to become the largest change to transfer pricing (TP) regulation since the implementation of Circular 66/2010/TT-BTC in 2010 – which the draft updates. Touching on conditionality of TP exemption and thresholds for defining related… – Continue reading

Multinationals Dodged Bullet on ‘Earnings Stripping’ Rules

Many kinds of U.S. multinational companies, including S-corporations, REITS, and financial services companies apparently dodged a bullet last month when the U.S. Treasury Dept. issued its final, substantially revised rules aimed at curtailing “earnings stripping.” The revised regulation represents an attempt by Treasury to help “narrow the rule and avoid… – Continue reading

New EU corporate tax rules announced

After five years of negotiations, the European Commission has finally announced its plans to overhaul the way in which companies are taxed in the Single Market. The revised Common Consolidated Corporate Tax Base (CCCTB) is aimed at making it easier and cheaper to do business in the Single Market and… – Continue reading

FinMin to issue rules for norms under BEPS

Applicable to transfer pricing for MNCs whose consolidated annual revenue is over Rs 5,000 crore The finance ministry will issue rules and guidance to address some concerns and ambiguity over mandatory reporting norms with respect to transfer pricing for multinational companies whose consolidated annual revenue is over Rs 5,000 crore…. – Continue reading

After disclosure on Bahamas tax havens, UN experts urge governments to take action

In the wake of the recent disclosure of leaked Bahamas tax haven data, United Nations human rights experts today urged governments to work together on liquidating offshore tax avoidance and establishing tougher financial regulations. In a news release, Juan Pablo Bohoslavsky, the UN Independent Expert on foreign debt and human… – Continue reading

Indonesia is finally cracking down on tax avoidance

The Indonesian government recently launched tax hunt on Google Indonesia. If Google were indeed guilty of tax avoidance, it would have to pay a huge price for its actions. But Google is not alone in avoiding paying tax to Indonesian government. Indonesians and Indonesian companies are squirrelling their wealths in… – Continue reading

Taxation on corporate debt rules out for consultation

Revised rules affecting the way corporate debt and derivative contracts are taxed have now been drafted and are out for a brief consultation, in a bid to avoid double taxation and curb potential abuse HMRC has issued draft legislation for consultation following amendments to the Change of Accounting Practice Regulations… – Continue reading

Here’s the latest on the non-dom reform

What will happen to clean capital, tainted trusts and enveloped assets under the new tax regime? John Goodchild reports. The UK government has at last disclosed further details of the tax changes for UK resident non-domiciled individuals first announced in July 2015. The government remains determined to implement all the… – Continue reading

To really tackle corporate tax evasion we need a public register

The Australian government shouldn’t rely on leaks like that of the Panama Papers to pick up on tax evasion, it should consider stronger action. The federal government showed some leadership earlier this year by announcing the establishment of a public register of beneficial ownership of companies, with the aim of… – Continue reading

New Report Finds Corporate Offshore Tax Avoidance ‎a Growing Problem

According to a new report, secretive offshore tax avoidance practices are on the rise among multinational businesses. The report, released from the Financial Accountability and Corporate Transparency Coalition (FACT), finds that these practices put investors at risk because they are caught off guard when governments act to collect the lost… – Continue reading

Tax reform as new human rights agenda

Today, we see more enthusiasm for tax reform in Indonesia. Although opposed by some civil society groups, President Joko “Jokowi” Widodo’s administration continues to push its fiscal framework reform — which includes a tax amnesty and more incentives for taxpayers. Last year, the Finance Ministry issued a new tax holiday… – Continue reading

Corporations paid no tax at Rio Olympics

Coca-Cola, McDonald’s, Visa and the rest of the corporate sponsors of the August 5–21 Olympic Games in Rio de Janeiro won’t be paying any taxes on the money they earn due to a tax exemption law that is set to cost Brazil hundreds of millions of dollars. The exemption, which… – Continue reading

The U.K.’s Proposed Interest Restriction Rule—Too Much Too Soon?

The U.K. government has been consulting on a proposed “Interest Restriction” rule which will limit the amount of interest expense U.K. companies will be allowed to offset against their income for tax purposes (to 30% of their taxable earnings before interest, tax and amortization). The second consultation phase on the… – Continue reading

Republicans Take New Tack on Taxing Companies’ Overseas Profits

Democrats are likely to object to the House GOP’s and Donald Trump’s plans for sharply lower rates President Ronald Reagan once chided government’s approach to the economy as following this mantra: “If it moves, tax it.” Today’s Republicans are following Mr. Reagan’s ideas by trying the exact opposite approach. The… – Continue reading

Greece to Seek Help from Bulgaria, Cyprus to Find Suspected Tax Evaders

Greece intends to sign agreements with Bulgaria and Cyprus which will allow Athens to look into suspected tax evasion by Greek-owned companies registered in the two countries, Greek newspaper Kathimerini has reported. The closer inspection of Greek-owned companies registered in Bulgaria and Cyprus will aim to find out whether they… – Continue reading

ATO Issues Anti-Avoidance Warnings For Multinationals

The Australian Taxation Office (ATO) has issued a series of taxpayer alerts that caution large companies against using contrived arrangements to avoid their tax obligations. The first alert concerns arrangements where Australian consolidated groups use offshore permanent establishments that have entered into intra-group transactions. Deputy Commissioner Jeremy Hirschhorn explained: “Through… – Continue reading

Developing Nations Seek Tax Body to Curb Illicit Financial Flows

Despite Western opposition, the 134-member Group of 77 is continuing to pursue a longstanding proposal for an inter-governmental UN-affiliated tax body aimed at combating corporate tax dodging and curbing illicit financial flows, including money laundering and off-shore banking. The proposal has already been shot down twice by Western nations, first,… – Continue reading

IMF call for ‘comprehensive reform’ of US tax system

An International Monetary Fund (IMF) review has called for a comprehensive reform of the US tax system, with the aim of removing exemptions, simplifying the system, rebalancing from direct to indirect taxes, and reducing statutory rates for individual and corporate income taxes According to its annual Article IV consultation report… – Continue reading

Corporate tax avoidance: New rules adopted

On 12 July 2016, the Council adopted new rules addressing some of the practices most commonly used by large companies to reduce their tax liability. The directive is part of a January 2016 package of Commission proposals to strengthen rules against corporate tax avoidance. The package builds on 2015 OECD… – Continue reading