The present French Tax Update will focus on an overview of several noteworthy French tax court decisions issued during the past few months. BUYBACK AND CANCELLATION OF OWN SHARES The tax treatment of buybacks, from the shareholders’ point of view, has now been simplified through a change of legislation, i.e.,… – Continue reading
With a new government at India’s center and positive macroeconomic fundamentals working in its favor, the private equity industry is expected to invest more actively into India over the short to medium term. In the past year, inflation has steadily tapered, the fiscal deficit has been reduced, domestic demand has… – Continue reading
Taxes covered The agreement applies to taxes on income imposed by either country. In Bahrain these are currently the income tax payable under Legislative Decree No. 22/1979 (“the Oil Tax”); in Cyprus they are income tax, corporate income tax, Special Contribution for Defence (known as SDC tax) and capital gains… – Continue reading
VANCOUVER, July 6, 2015 /PRNewswire/ – Silver Wheaton Corp. (“Silver Wheaton” or the “Company”) (TSX:SLW) (NYSE: SLW) announces that it has received a proposal letter dated July 6, 2015 (the “Proposal”) from the Canada Revenue Agency (the “CRA”) in which the CRA is proposing to reassess Silver Wheaton under various… – Continue reading
Calcutta, July 5: Singapore and Hong Kong, with their low corporate tax rates, have started to hove into view on the radars of multinational companies that are looking to lower their tax burdens through profit shifting. Profit shifting is a perfectly legal way of moving the earnings of an MNC… – Continue reading
The Automatic Exchange of Information is fast becoming widely recognised as the most effective instrument to fight against tax evasion. With cooperation between tax administrations being high on the agenda in the ongoing fight against tax evasion, protection of integrity of tax systems, and transparency processes seem to be infiltrating… – Continue reading
The Cyprus government has introduced radical tax reforms that aim to attract foreign direct investments and non-domiciled individuals, simplify levies for properties, return tax-collection to local municipalities and encourage tax-breaks for direct injections where local companies are strained for cash-flow, reports the Financial Mirror. Finance Minister Haris Georghiades said that… – Continue reading
New Zealand-Canada double tax agreement to help investors WELLINGTON, July 2 (Xinhua) — A new double tax agreement between New Zealand and Canada is set to facilitate investment and trade between the two nations, Revenue Minister Todd McClay said Thursday. The new agreement will lower withholding taxes on dividends, interest… – Continue reading
Florida governor releases 33 years of tax returns. Jeb Bush made $29 million in the first seven years after he left public office, dramatically increasing his wealth during a recession, a financial crisis and the Obama presidency he has criticized. Bush’s tax returns, released Tuesday, show how the former Florida… – Continue reading
OECD and G20 Action Plan on Base Erosion and Profit Shifting (BEPS) was adopted in 2013. It consists of 15 actions including transfer pricing, taxation of controlled foreign corporations (CFC), digital commerce, hybrid instruments, international information exchange, tax treaty shopping etc. In 2013, OECD working group prepared draft documents regarding… – Continue reading
A ruling at the First-tier Tribunal has allowed different form of tax credit relief on certain types of offshore dividends taxed in the UK. Overpayment claims for 2010/11 and later years should be considered immediately. Shirley v HMRC A UK resident who benefited from an overseas trust has successfully claimed… – Continue reading
MUMBAI: India 0 Vs Pakistan 1. It’s not the outcome of a ODI series between the traditional rivals but a progress card on reforms in the world of real estate. At a time Indian realtors and investors are struggling to roll out real estate investment trusts (REIT) amid regulatory complications… – Continue reading
A new treaty makes it more difficult for companies to take advantage of tax loopholes to avoid their financial obligations. Globally, initiatives are afoot to close tax loopholes and South Africa is one of the frontrunners – its new treaty with Mauritius removes the allure for tax-shy corporates doing business… – Continue reading
The South African Revenue Service (SARS) has extended its Third Party Business Requirement Specification (BRS) for data submissions via Direct Data Flow (DDF) to include withholding tax on interest and tax-free savings and investments. The extension will be available for year-end data submissions due on May 31, 2016 (for the… – Continue reading
A recent report by Americans For Tax Fairness looks at how Walmart, the world’s largest corporation, uses a vast network of subsidiaries and branches in overseas tax havens with two purposes: 1.) to minimize taxes owed on its foreign operations. 2.) most importantly, to avoid United States taxes on those… – Continue reading
Companies registering their intellectual property in Israel will be charged only 5% tax on dividends. The committee considering changes in the Law for the Encouragement of Capital Investments, headed by former Ministry of Finance director general Yael Andorn, is recommending extension of the tax break granted under the law to… – Continue reading
The United States has been criticized on more than one occasion for failing to be a meaningful participant in the OECD’s multi-pronged initiative to address base erosion and profit shifting (BEPS). Some commentators have even gone so far as to accuse the United States of actively working against the BEPS… – Continue reading
With less than seven weeks between signature on 13 November 2014 and entry into force on 22 December, the new DTA between Cyprus and Iceland set a new standard for timeliness. Like most of Cyprus’s recent double taxation agreements, the DTA closely follows the form of the 2010 OECD Model… – Continue reading
International tax rules will soon change, but companies’ behaviour may change sooner. There will soon be fewer places for multinational companies and ultra-rich individuals to squirrel away money. In November leaders of the G20 are expected to adopt a full range of measures to curb the practices of base erosion… – Continue reading
In the last few years, particularly following the credit crunch, there has been a tangible focus on tax avoidance and clamping down on tax planning. Overnight, the rules of the game were changed and what was previously considered to be legitimate tax planning was condemned as being aggressive and morally… – Continue reading
Abstract Over the past 25 years, Cyprus has become the portal of choice for investment into and out of Russia and Central and Eastern Europe. The new Russian de-offshorization law, which took effect on 1 January 2015, will have significant implications for users of overseas structures. This article examines the… – Continue reading
Effective from January 1st next year, personal income tax in Hungary will be paid at a flat tax rate of 15%. Consequently, the standard withholding tax rate on all Hungarian securities (debt securities and equities) will also be reduced from the current 16% to 15%, says Clearstream Banking in a… – Continue reading
The U.S. Model Income Tax Treaty (the U.S. Model Treaty) generally represents the United States’ opening position in treaty negotiations. As a result, when changes to the treaty are proposed, international tax practitioners should be aware of the potential impact those changes can have on their existing inbound U.S. structures…. – Continue reading
Following the implementation of the EU Alternative Investment Fund Managers (AIFM) Directive (2011/61/EC) and associated legislation, Cyprus now lays claim to being a growth jurisdiction within the European Union for the establishment and servicing of boutique and low cost alternative investment funds based locally or offshore. The choice of fund… – Continue reading
A country which is small in size but a giant in stature, Malta is rapidly gaining more and more attention on the global stage. With a rapidly expanding financial services sector which rivals some of the most established economies in the world, Malta is an extremely attractive place to do… – Continue reading
MUSCAT: Japan-Oman robust economic relationship is set to leap to a new level with the signing of an investment agreement between the two countries, which is expected in the second quarter of this year, says Japan’s ambassador to the Sultanate. “The signing of the Japan-Oman Investment Agreement is expected to… – Continue reading
KARACHI: Federal budget for fiscal year 2015-16 (FY 16) is apparently hinting government is interested in promoting black money or trying to force decent tax paying investors to invest in real estate sector, stock brokers say. Instead of giving incentives, Finance Minister Ishaq Dar has dismayed taxpayer investors by increasing… – Continue reading
The new law on the taxation of controlled foreign companies (the ‘CFC’ law) and other anti-offshore measures effective as of 1 January 2015 have raised a number of questions for clients and advisers. A number of changes to the new laws were long anticipated and have now been passed by… – Continue reading
Issues of tax domicile have figured in the UK election, with arguments over ‘non dom’ status and the transparency of overseas territories. However, as the dust settles on some of the rhetoric, it is essential that this does not cloud the legitimate benefits that offshore jurisdictions have brought to the… – Continue reading
A special scheme is provided for foreign-securities holding companies or ETVEs (Entidades de Tenencia de Valores Extranjeros) in the Corporate Income Tax (“CIT”) Act 27/2014. ETVEs are regular limited liability companies (S.L., S.A. or other company forms), subject to the normal CIT on its income, but exempt from taxation on… – Continue reading
Proposed Amendments To Cyprus’s Assessment And Collection Of Taxes Law The Cyprus Government has published a draft law amending the Assessment and Collection of Taxes Law (Law 4 of 1978) in order to facilitate implementation of agreements for automatic exchange of information with other countries. When it is enacted, the… – Continue reading
OVERSEAS investment by Thai companies has been surging in recent years and this trend is almost certain to continue. One of the questions frequently asked by Thai investors when seeking to acquire foreign operating companies or establish overseas subsidiaries is what type of funding structure would be the most tax… – Continue reading
The Swiss Federal Council has adopted a dispatch on the Corporate Tax Reform Act III (CTR III), a package of reforms it said will strengthen the country as a business location and ensure companies make an appropriate tax contribution. The Council agreed on the parameters of the CTR III on… – Continue reading
A Malta-based shell company is linked to financial transactions which likely saw Azerbaijani President Ilham Aliyev and his family amass hundreds of millions of euro at the expense of the country he leads and its citizens. FA Invest (Malta), whose registered address is in the Cornerstone Complex in Mosta, has… – Continue reading
TRENTON – A New Jersey think tank says the state could reap hundreds of millions of dollars by changing tax rules to close loopholes and make multi-state corporations pay what they owe. The left-leaning New Jersey Policy Perspective called on lawmakers to enact combined reporting to thwart businesses that operate… – Continue reading
In a note to investors published today, Bernstein analyst Toni Sacconaghi weighed in on why Apple Inc. (NASDAQ:AAPL) has chosen to keep a large offshore cash balance and not repatriate to the US. Mr. Sacconaghi noted activist investor Carl Icahn’s notion that Apple’s real tax rate is roughly 20% below… – Continue reading
The present French Tax Update will focus on an overview of several noteworthy French tax court decisions issued during the past few months, in particular in relation with double tax treaty conditions to benefit from a tax credit, abuse of law challenges, increased amortization rates, and priority preliminary ruling requests… – Continue reading
Argentina and Chile have signed a new double tax treaty to replace the treaty unilaterally terminated by Argentina in 2012. Ignacio Rodriguez and Andres Edelstein of PwC in Argentina outline the new structuring opportunities that are available for taxpayers. Argentina and Chile signed a new double tax treaty on May… – Continue reading
It is not uncommon for affluent families from certain countries to maintain offshore structures to hold a portion, and often times a significant portion, of their wealth. The reasons for holding assets outside of their country of residence are many, and such assets are frequently held in foreign corporations. As… – Continue reading
Investments Derived From Structural Reforms The approved structural Reforms are an unprecedented opportunity for a transformational economic growth in Mexico, being the most relevant from an investment point of view the reforms related to Energy, Telecommunications and Antitrust, which have put Mexico in the radar of Multinational companies seeking to… – Continue reading
The first fiscal amendment of the Juan Carlos Varela government was passed earlier this month on May 4, by Law 27 of 2015. Here are two important pointers of the fiscal reform: 1. TAXABLE INCOME PRODUCED IN PANAMA Article 694 of the CF originally included as taxable income the income… – Continue reading
On May 20, 2015, the US Department of the Treasury released for public comment draft updates to the US Model Income Tax Convention, including provisions to deny treaty benefits to companies that change their tax residence via inversion transactions. The Treasury said other changes are intended to ensure that the… – Continue reading
On 22 May 2015, Switzerland and Oman signed an Income Tax Treaty. The treaty will come into force after the two countries exchange ratification instruments. The provisions of the treaty will have effect from 1 January of the calendar year next following that in which the agreement enters into force…. – Continue reading
Belgium and the Russian Federation announced in March 2007 that they would negotiate a new double tax treaty (the “Treaty”). Nearly seven years after discussions began on 20 November 2008, the Treaty was finally signed on 19 May 2015 in Brussels. This newsflash is based on an unofficial version of… – Continue reading
It has become a $2 trillion question. Why don’t companies have to make clear exactly how much of their profits are generated offshore each year and not taxed in this country? Why must investors engage in jujitsu to estimate these figures and the risks associated with them? Companies, like individuals,… – Continue reading
Tax Treaty Details Become Available The details of the Income Tax Treaty between Mauritius and the Republic of Congo have become available. The treaty will come into force after the two countries exchange ratification instruments. The provisions of the treaty will have effect from 1 January of the calendar year… – Continue reading
Details of new Tax treaty Become Available The details of the new Income Tax Treaty between Netherlands and Germany have become available following its ratification by Netherlands on 15 May 2015. The new treaty was signed on 12 April 2012. Once in force and effective, the new treaty will replace… – Continue reading
The finance ministry will in the near future add Controlled Foreign Corporation (CFC) rules to the Income Tax Act in order to prevent the tax deferral that many Indian multinational companies resort to by not repatriating the profits of their foreign subsidiaries for long periods. The proposed rules will come… – Continue reading
Introduction Tax avoidance, however legitimate its mechanism, has become the new focus for public opprobrium in parts of the world. High-profile cases and media attention examining the tax strategies of major global companies operating primarily in the digital economy have all contributed to this shift of focus. How are the… – Continue reading
INTRODUCTION On May 5, 2015 the Swiss Federal Supreme Court held a public hearing about two cases relating to the reclaim of Swiss withholding tax (WHT) in connection with arbitrage cases and issued its long awaited decisions. Two Danish banks issued the question on treaty entitlement for the refund of… – Continue reading
