Padoan: “It marks the end of banking secrecy in the European Union” The Council adopted a directive that will help the member states to clamp down on tax evasion and fraud by extending the scope for the automatic exchange of information. The directive brings interest, dividends, gross proceeds from the… – Continue reading
A new leak of confidential documents expands the list of big companies seeking secret tax deals in Luxembourg, exposing tax-saving maneuvers by American entertainment icon The Walt Disney Co., politically controversial Koch Industries Inc. and 33 other companies. Disney and Koch Industries, a U.S.-based energy and chemical conglomerate, both created… – Continue reading
Thousands of rich Australians have come forward to declare billions of dollars in untaxed assets and income stashed in bank accounts in Switzerland and in other countries. The rush comes as what the Australian Taxation office says is the last tax amnesty it will ever offer comes to an end…. – Continue reading
The MT Conferences section did not involve the reporting or the editorial staff of The Moscow Times. Russian business is trembling in expectation of the new year when major changes recently introduced to the tax legislation will enter into force. There has been a lot of discussion regarding the increase… – Continue reading
DAVID Murray’s financial system inquiry has left Australia’s big four banks at the whim of constantly changing global capital rules, analysts say. “By targeting a dynamic benchmark, there is a risk the Australian banking system enters a global ‘race to the top’ of capital levels,” said UBS analyst Jonathan Mott,… – Continue reading
While the dust is still settling from the mid-term elections and the pundits are trying to figure out what it all means, the American people have made their collective voices heard and delivered a message that they do not like the country’s direction. Exit polling data from Election Day showed… – Continue reading
Under transitional relief, certain non-U.S. investment funds, including Cayman Islands funds, that qualify as foreign financial institutions (FFIs), have been permitted to certify their status under the U.S. Foreign Account Tax Compliance Act (FATCA) without registering with the Internal Revenue Service (IRS) to obtain a Global Intermediary Identification Number (GIIN)…. – Continue reading
The Financial Accountability and Corporate Transparency (FACT) Coalition is calling on Congress to reject the tax extenders package that includes two wasteful offshore loopholes that allow U.S. companies to dodge billions worth of taxes. The tax extenders are a set of 54 temporary tax breaks, which are ostensibly designed to… – Continue reading
Dechert Georgia, through the contribution of partners Archil Giorgadze and Nicola Mariani joined by senior associates, Ruslan Akhalaia and Irakli Sokolovski, is partnering with Georgia Today on a regular section of the paper which will provide updated information regarding significant legal changes and developments in Georgia. In particular, we will… – Continue reading
Names of former politicians investigated for alleged tax evasion read into Dáil record Five former politicians named in the Dáil by Sinn Féin TD Mary Lou McDonald as having been in a dossier of alleged offshore account holders have rejected the claims. Former European commissioner Máire Geoghegan-Quinn, former Progressive Democrat… – Continue reading
December 2: A tax commission charged with examining the tax system in Norway today submitted its report—NOU 2014: 13—to the Minister of Finance that describes proposals for changes to the corporate tax system and for adjustments to the tax system, in general. The tax commission’s report will be submitted for… – Continue reading
December 2: A tax commission charged with examining the tax system in Norway today submitted its report—NOU 2014: 13—to the Minister of Finance that describes proposals for changes to the corporate tax system and for adjustments to the tax system, in general. The tax commission’s report will be submitted for… – Continue reading
North East Labour MEP Paul Brannen on why European Commission president Jean-Claude Juncker can crack the tax dodge problem The expression ‘poacher turned game keeper’ sprang to mind this week in the European Parliament as in meeting after meeting Jean-Claude Juncker’s suitability for the top job in the European Union… – Continue reading
Recently approved incentives for companies to set up international headquarters and international trading centres in Thailand could have a positive effect on foreign investment, say foreign executives. “After Singapore, I think Thailand could be the next big attraction for [such offices] to open here,” said Stanley Kang, chairman of the… – Continue reading
Passage by the French assembly on 18 November 2014 of a draft Finance Bill for 2015 (which now will be presented to the Senate) Introduction by the French government on 12 November 2014 of a second draft amended Finance Bill for 2014 In general, the draft Finance Bill for 2015… – Continue reading
* Sistema’s Q3 net income down 71.5 percent * CEO says reporting period “most challenging” (Recasts, adds detail, CEO quotes) Nov 27 (Reuters) – Russian conglomerate Sistema is reviewing its costs, portfolio of investments and future plans, it said on Thursday, after a drop in profits and a “challenging” year… – Continue reading
For foreign investors doing business in China, securing benefits under a double taxation avoidance (DTA) agreement is an important measure for reducing their tax burden as stipulated by Chinese tax law and thereby maximizing profit. In addition to satisfying the specific requirements of a relevant DTA, certain administrative procedures must… – Continue reading
When is a Chinese company not Chinese? When it’s a complex web of offshore vehicles rooted in anonymous tax havens. That description includes some of the People’s Republic’s most successful and innovative companies. It will make the country’s apparent new push on tax evasion hard to enforce. Authorities have extracted… – Continue reading
On November 21, 2014, as part of its Action Plan on Base Erosion and Profit Shifting (BEPS), the OECD released a discussion draft on “Follow-up work on BEPS Action 6: Preventing Treaty Abuse” (the Discussion Draft) for comments. The Discussion Draft deals with a number of issues relating to tax… – Continue reading
The concept of base erosion and profit shifting (BEPS) has been debated at various international forums following discussions at the G20 Finance Ministers and Central Bank Governors meeting and the G20 Heads of State summit in Russia last year. The Organisation for Economic Co-operation and Development’s (OECD) BEPS Action Plan… – Continue reading
The concept of base erosion and profit shifting (“BEPS”) has been much discussed at various international forums including the G20 Finance Ministers and Central Bank Governors meeting in July 2013 in Moscow as well as the G20 Heads of State meeting in September 2013. From a South African perspective, the… – Continue reading
MOSCOW — There is nothing new about offshore tax shelters. In ancient Athens, after the government decided to levy a 2% tax on all trade operations, merchants started avoiding the city, conducting business on the surrounding islands instead. Those Greek islands became the first offshore tax havens. The current offshore… – Continue reading
Canada and Spain have signed a Protocol to their income tax convention which, when implemented, will reduce the withholding tax rates applicable on payments of dividends and interest. The Protocol was inked on November 18, 2014, by Canada’s Ambassador to Spain, Jon Allen, and Spain’s Finance Minister, Cristóbal Montoro. The… – Continue reading
UK and multinational enterprises are starting to consider (re)organising themselves under a UK holding company for their global operations, rather than using other traditional onshore holding company jurisdictions. This new trend is the result of a number of factors, which have moved the UK from an outside choice as an… – Continue reading
KUALA LUMPUR: IT is not against Malaysian law for companies to keep funds in offshore accounts. Malaysian Companies (SSM) acting chief executive officer Zahrah Abd Wahab Fenner said it was not unusual for companies to keep their funds in offshore accounts. She said this when commenting on 1 Malaysia Development… – Continue reading
Nobody likes paying taxes. The rich, however, can reduce the burden more easily than others because capital is more mobile than labour. A clever new paper in the Journal of Economic Perspectives by Gabriel Zucman attempts to measure how much government revenue is lost because of the careful re-routing of… – Continue reading
Russia’s lower house of parliament on Tuesday took aim at the offshore holdings that have become ubiquitous in Russian business, passing in its final reading a bill that will make Russian taxpayers declare and pay taxes on their assets abroad. But once signed into law, this product of President Vladimir… – Continue reading
A recent binding tax ruling recognised that the historical background of a multinational group is a key factor in considering whether a non-EU ultimate parent should trigger the anti-abuse rule which applies to exemption from dividend withholding tax. In a nutshell, the Spanish Non Resident Income Tax Law (NRIT), provides… – Continue reading
Seven of the biggest U.S. corporations received billions of dollars in tax refunds from the Internal Revenue Service, while dolling out an average of US$17.3 million to CEOs. While Congress is set to renew a slew of corporate tax breaks, new research published Tuesday found some of United States’ biggest… – Continue reading
It’s a surprise to many people that MLPs generate taxable income in retirement plans requiring a tax filing and payment of taxes. Traders and investors are interested in using their IRA and other retirement plan accounts (collectively referred to as “retirement plans”) for making “alternative investments” in publicly traded master… – Continue reading
Recent months saw various important developments that are relevant to Sino-European trade and investment. These include (i) changes to the EU Parent-Subsidiary Directive, (ii) the entry into force of the double tax treaty between Luxembourg and Taiwan, and (iii) proposed changes to China’s Foreign Investment Catalogue and the Governmental Verifications… – Continue reading
Hybrid entities have long been a tool for corporate tax planning. While tax authorities have fought the use of such hybrid mismatches for tax planning purposes, national efforts to prevent the use of hybrid mismatches have not proven to be very efficient, explain Michael Graf and Timothy Santoli, of Dentons… – Continue reading
The LuxLeaks scandal is a classical example of the growingly frequent clash between the level of integration of the European economy (and the global for that matter) and the national sovereignty. Greece was first to prove that four years ago when it put to the test the very survival of… – Continue reading
Sears Holdings and Pinnacle Entertainment have become the latest US companies to announce that they are considering establishing real estate investment trusts (REITs), to unlock tax advantages that have been considered by some companies as an alternative to a corporate inversion. REITS do not pay corporate tax as long as… – Continue reading
HCMC – Foreign exchange control is a paramount concern of all foreign investors entering into Vietnam, as regulations on capital inflows and outflows have a great influence on operations and profit. Foreign exchange control includes transferring capital into and out of the country, opening and using bank accounts, borrowing foreign… – Continue reading
With U.S. interest rates remaining at historic lows, yield-starved investors have continued allocating massive amounts of capital to exchange traded products offering exposure to master limited partnerships (MLP). So popular are MLP ETFs and exchange traded notes (ETNs) that the asset class has not endured a month of net outflows… – Continue reading
November 12: Danish companies subject to Danish corporate income tax generally must withhold tax at a rate of 27% on dividend distributions, but the rate of the withholding tax may be reduced to 15% when dividends are distributed to Danish domiciled investments funds that are known as “IMBs” (i.e., investment… – Continue reading
According to Bill Thompson, tax partner at Minter Ellison, Base Erosion and Profit Shifting (BEPS) — the base erosion referred to as the tax base and its implications for future tax structures — will be a key focus at the G20 Summit in Brisbane, with possible rapid changes to the… – Continue reading
In March 2014 the Russian Ministry of Finance published a draft anti-offshore law which is currently submitted for consideration by The State Duma (parliament) with the decision expected to be made by the end of 2014. Russia is aiming to clamp down on the use of foreign offshore tax shelters… – Continue reading
With the change in government in India, the world is looking up to its new Prime Minister Narendra Modi to revive the country’s economy, who recently launched his flagship ‘Make in India’ campaign to propel the country into top 50 of World Bank’s Ease of Doing Business rankings by 2016…. – Continue reading
MOSCOW, November 10. /TASS/. Russia is speeding towards the adoption of anti-offshore legislation. The State Duma (lower house of parliament) on Tuesday will hold the first reading of amendments to the Tax Code obliging both individuals and legal entities to notify the authorities of their foreign properties and profits. This… – Continue reading
Covidien transferred right to $6.9bn loan to new entity Multinational medical supplies group, Covidien, transferred the right to loans totalling $6.9 billion from Luxembourg to a new Irish company as part of an elaborate inter-group tax planning arrangement agreed with the Luxembourg tax authorities in 2009. Under the deal, the… – Continue reading
BRUSSELS – Dividend, interest and royalty payments that companies let pass through the Netherlands to avoid taxation have increased substantially in the past decade, the Netherlands Court of Audit has found. In a report published on Thursday (6 November), the court writes that tax laws and treaties that originally were… – Continue reading
Apple is debuting €2.8bn of bonds as the iPhone maker seeks to fund another round of shareholder rewards without using overseas cash that would be subject to US repatriation taxes. The technology company is offering €1.4bn of eight-year notes and €1.4bn of 12-year securities, a source said. Goldman Sachs Group… – Continue reading
This publication provides a brief overview of the expected impact on entities incorporated in the British Virgin Islands (the “BVI”) of (a) the foreign account tax compliance provisions (“FATCA”) of the Hiring Incentives to Restore Employment Act, 2010 of the United States of America (the “US”); and (b) equivalent rules… – Continue reading
(From left) Stephen Ross, Raghad Al-Khudhari, Kristin Konschik and Husain Al- Ghareeb KUWAIT: A child born in the United States, even taken out of the US after an hour or two after birth, is a US citizen and therefore subject to a recent tax law being implemented by the US… – Continue reading
Apple Inc. (AAPL) is gearing up for its first bond offering in euros as the iPhone maker seeks to fund another round of shareholder rewards without tapping overseas cash that would be subject to repatriation taxes. Banks hired by the world’s most valuable technology company have started gauging investor interest… – Continue reading
PARIS–(BUSINESS WIRE)–On September 2, 2014, under the aegis of the President of the Commercial Court of Paris, LVMH Moët Hennessy – Louis Vuitton (“LVMH”) and Hermès International (“Hermès”) entered into a settlement agreement (the “Settlement Agreement”) aimed at restoring a climate of positive relations between them. “Communiqué – Distribution exceptionnelle… – Continue reading
Foreign profits sit on sidelines as companies seek tax reform. WASHINGTON — They are all companies that call Minnesota home: Medtronic, 3M, St. Jude Medical, General Mills and Ecolab. But they also all hold 90 percent or more of their cash outside the United States. Amid a growing national political… – Continue reading
Financial institutions based in certain British Overseas Territories (BOTs) and Crown Dependencies (CDs) will be subject to stricter reporting requirements covering accounts held with them by UK resident non-UK domiciled taxpayers from 2016 if specific “carve outs” are not negotiated, an expert has said.31 Oct 2014 Private wealth tax Tax… – Continue reading
