Category: Lease

A Huge Tax Break Went to a Politically Connected Company in New Jersey Despite Red Flags

Holtec International told New Jersey regulators that Ohio was competing for its new headquarters. But officials there stripped the firm of past tax awards for failing to create the jobs it promised.n January 2014, as Holtec International explored sites for a new national headquarters and high-tech manufacturing center, the New… – Continue reading

Dutch-built super yachts are being re-sold to tax haven buyers

Luxury yachts built in Dutch shipyards are being sold to suspect buyers around the world through tax havens, Trouw and the Financieele Dagblad reported on Friday. The dubious yacht transactions were revealed through an investigation being carried out into the Paradise Papers by the two Dutch newspapers . The documents… – Continue reading

Monaco added to Italy’s ‘White List’

In early April 2017, an important taxation agreement between Monaco and Italy came into force… As a direct result, Monaco now appears on the Italian ‘White List’ of tax compliant jurisdictions. The Agreement creates both opportunities and challenges for companies or individuals that fall within its scope, and is an… – Continue reading

HK’s proposed dedicated tax regime for offshore aircraft leasing

The Hong Kong Government has put forward a proposal to amend its tax laws to establish a dedicated tax regime for aircraft owners/lessors based in Hong Kong and leasing to offshore (including PRC) lessees/airlines (see Timeline / References below) (“Proposed Regime”). Assuming there are no surprises or drafting issues in… – Continue reading

In Slovakia, 2017 brings new tax legislation

The Slovak Government and Parliament made several changes to the tax system with effect from 1 January 2017. The recently adopted amendments concern – among others – corporate and personal income tax, value added tax, special levy in regulated industries, as well as social security and health insurance contributions. Here… – Continue reading

Panama snubbed SA on data exchange request

PANAMA, widely recognised as one of the world’s tax havens, declined a request by the South African government to enter into a bilateral arrangement for the exchange of information. However, the refusal was made before the huge leak of information about the offshore holdings of wealthy individuals and entities disclosed… – Continue reading

Once A Tax Haven, Gibraltar Now Says It’s Low-Tax

Gibraltar, a tiny British territory at Europe’s southern tip, is famous for its geography — a huge limestone rock — that appears on the Prudential logo. It’s a global center for offshore banking, with the trappings of wealth to prove it: Luxury high-rises tower over super yachts in Gibraltar’s marina. The… – Continue reading

Monitor offshore investments, IMF tells Mauritius

The International Monetary Fund (IMF) has askedMauritius to set up a ‘macro-prudential authority’ to monitor the offshore investments from the island. One of the largest destinations of such offshore investments is the Indian stock market. The proposed authority will have a central role for the banking regulator, the Bank of… – Continue reading

Cyprus Yacht Registration – New Preferable VAT Treatment

A. INTRODUCTION On the 13th of March 2012, the Cyprus VAT Authority has launched a scheme making Cyprus one of the most attractive EU jurisdictions for yacht registration. According to this scheme, a Cyprus company can enter into a lease-sale agreement of a yacht with a third party, paying VAT… – Continue reading

Bloomberg BNA Provides Insights into 2016 U.S and International Tax Policy

ARLINGTON, Va., Jan. 14, 2016 /PRNewswire-USNewswire/ — Bloomberg BNA today announced the publication of the Daily Tax Report’s 2016 Outlook on tax and accounting policy. Dozens of policy experts, along with current and former members of Congress, congressional staffers and federal agency officials provided insights on the year ahead regarding… – Continue reading

India: Foreign branches outside India; development charges on long-term leases

The KPMG member firm in India has prepared reports concerning the following developments (read more at the hyperlinks provided below). Income attributable to taxpayer’s foreign branches not taxable in India: The Bombay High Court held that income attributable to a taxpayer’s foreign branches, permanent establishments (PEs) outside India, is not… – Continue reading

Italian groups seek EU antitrust probe into McDonald’s

BRUSSELS – Three Italian consumer organizations have urged EU antitrust regulators to investigate McDonald’s (MCD.N) franchise system in Europe, a month after the opening of an EU inquiry into the U.S. fast food company’s tax deals with Luxembourg. Codacons, Movimento Difesa del Cittadino and Cittadinanzattiva filed their complaint with the… – Continue reading

United States: Extenders Bill Puts An End To Tax-Free REIT Spinoffs But Includes A Number Of Favorable Changes To The Taxation Of REITs

On December 18, 2015, the President signed the Omnibus Appropriations Act (the “Act”) into law.1 Notably, the Act contains a number of substantive changes to the tax laws applicable to “real estate investment trusts” (“REITs”). Although several changes will adversely affect certain REITs, on balance REITs and their investors fared… – Continue reading

Tax amendments – 2015

INTRODUCTION The Taxation Laws Amendment Act, 2015 and the Tax Administration Laws Amendment Act, 2015 have both now been passed by Parliament, but await signature by the President. Once again, and now for the second year running, the number and scope of the changes to the various fiscal Acts (mainly… – Continue reading

Cyprus: Tax Incentives For Expatriate And High Net Worth Individuals Relocating To Cyprus (In Russian)

INTRODUCTION In the context of changes in the international system of taxation of the company in the choice of jurisdiction for the implementation of operational activities closely fit to the question of economic feasibility, to protect their interests. The strategic location of Cyprus, the presence of the country’s full membership… – Continue reading

Base erosion and profit shifting: limiting tax deductions for interest costs

Earlier this week the heads of state of the 20 largest global economies have agreed to adopt the 15 BEPS action points in their respective countries. Ample reason to take a closer look at the details and implications of one of the most far-reaching upcoming tax adjustments. Action 4 of… – Continue reading

United States: Tax Alert: G20 Leaders Approve OECD Proposals For Comprehensive Global Reform Of The International Tax System, Including Redefinition Of “Permanent Establishment”

Measures Will Impact Financial Services, Investment Fund, Aviation Leasing and Other Sectors G20 finance ministers last week finally approved the wide-ranging “BEPS” reforms to the international tax system. The measures include a proposed new OECD treaty definition of “Permanent Establishment” under which the mere negotiation of contracts could create a… – Continue reading

Canada: Navigating BEPS: What The Tax Function Of Today Needs To Know For Tomorrow

The Organisation for Economic Co-operation and Development (OECD) has described its newly unveiled Base Erosion and Profit Shifting (BEPS) Action Plan as a “change of paradigm.”1 A few very large global groups aside, a more apt description may be a minefield for the unwary. BEPS has received considerable air time… – Continue reading

Opening Bell: Ireland told not to rely on low taxes to grow, NAMA’s dispute with Dunnes, Draghi’s statement on Ireland

The Organisation for Economic Co-operation and Development’s (OECD) chief economist has warned that Ireland cannot rely on low corporation taxes to fuel growth. “Ireland is going to have to seek real investment based on comparative advantages other than tax,” Prof Catherine Mann told a conference hosted by the Irish Department… – Continue reading

Liberia amongst top countries operating in financial secrecy

In a report leased by the international group Financial Secrecy, the group that carries out analysis of how far the legal systems of countries facilitate financial secrecy, Liberia is ranked amongst the top 30 countries in the world that deals in secrecy. While the Government of Liberia continues to boast… – Continue reading

Benefits of UAE-Based Offshore Companies

Offshore companies are established for a variety of reasons including a company’s necessity to restructure, create an international business entity as well as protect the assets of the company. The United Arab Emirates (UAE) is home to three authorities that register International or offshore companies. The three UAE authorities that… – Continue reading

Is a Canada Revenue Agency landlord avoiding taxes via offshore havens?

The Canada Revenue Agency (CRA) rents office space from a Vancouver-based property developer – a company that exploits offshore tax havens in Liechtenstein, the British Virgin Islands and Channel Islands. Larco Investments Ltd. owns three buildings in Montreal, Calgary and Edmonton where they rent office space to the CRA. Larco… – Continue reading

NORWAY: BUDGET 2016; MORE ABOUT PROPOSED TAX REFORM

The Norwegian conservative government on 7 October 2015 published both the proposed state budget for 2016 and a “white paper” containing proposals for tax reform. The proposed tax reform in the white paper is a follow-up action from a report on tax reform, presented by the Tax Commission in late… – Continue reading

Facebook paid £4,327 corporation tax despite £35m staff bonuses

Staff at Facebook’s UK arm took home an average of more than £210,000 last year in pay and bonuses, while their employer paid just £4,327 in corporation tax. Facebook made an accounting loss of £28.5m in Britain in 2014, after paying out more than £35m to its 362 staff in… – Continue reading

Treasury release draft law for implementation of the Common Reporting Standard

In brief On 18 September 2015, Treasury released exposure draft legislation in relation to the implementation of the Organisation for Economic Co-operation and Development’s (OECD) Common Reporting Standard (CRS) for the automatic exchange of financial account information. The CRS is intended to reduce international tax evasion and represents the next… – Continue reading

Some of Plymouth’s most well-known landmarks are owned by offshore companies

SOME of Plymouth best-known landmarks are owned by secretive offshore companies based in tax havens, it has been revealed. Swathes of land all over the city belongs to faceless firms based in places like Luxembourg and the Cayman Islands, The Herald can reveal. They include everything from historic former military… – Continue reading

Revealed: St Austell property owners registered in offshore tax havens

Tens of millions of pounds worth of property in St Austell is owned by companies based in offshore tax havens. They include large parts of Fore Street in the town centre; the beaches at Carlyon Bay, and dozens of individual buildings throughout St Austell and the clay country. NHS Kernow’s… – Continue reading

The Netherlands – Budget 2016

On September 15, the Dutch government released its Budget 2016, containing the Tax Plan 2016 which includes certain amendments to Dutch tax law. The government will discuss the plans the coming weeks in parliament. Further to these discussions, some elements of the Tax Plan 2016 may change. Most proposals will… – Continue reading

The secretive London family at war over its millions

Questions over tax — hotly denied — feature in a row centring on one of the capital’s biggest art collectors One of London’s wealthiest but most secretive families is locked in a bitter feud over the ownership of its empire, which spans high-end London properties to African tobacco-trading businesses. A… – Continue reading

Tax rate on intellectual property profits would be cut to approximately 10% and appreciated intellectual property could be repatriated free of current tax under bipartisan innovation box proposal

On July 29, 2015, Charles Boustany (R-LA) and Richard Neal (D-MA) released a bipartisan discussion draft of proposed Internal Revenue Code (the “Code”) amendments that would cut the United States income tax rate on corporate profits generated from patents and certain other intellectual property to approximately 10% (the “Tax Rate… – Continue reading

New circular introduces key corporate-income tax changes

On June 22, 2015, the finance ministry issued Circular 96/2015/TT-BTC, guiding the corporate income tax regime in Decree 12/2015/ND-CP (“Decree 12”) of the government, dated February 12, 2015. Decree 12 provides the details for the implementation of the law that amends and supplements some articles of tax laws, tax decrees… – Continue reading

UK: Weekly Tax Update – Monday 20 April

1 General news 1.1 HMRC organisation chart HMRC has published its latest organisation chart showing the names of senior management. One point to note is the number of senior people now in roles such as change management as opposed to being in pure technical roles. This clearly demonstrates the direction… – Continue reading

Parliament urged to speed up on attracting foreign investment

The Cyprus Investment Promotion Agency (CIPA) is urging parliament to expedite a batch of bills aimed at facilitating much-needed foreign investment in Cyprus. Chief among the proposals are the establishment of foreign leasing companies and cell companies, opening up the professional provident fund business to foreign concerns, and updating company… – Continue reading

Budget 2015: striking a balance in an election year

Finance Minister Joe Oliver faced formidable challenges, both economic and political, in delivering his first Budget. In a time of depressed oil prices, and mere months ahead of the next federal election, it appears he felt it was imperative to follow through with prior commitments to balance the budget, provide… – Continue reading

Malta: Business, Investments And Residency Opportunities!

TL: What are the main considerations and advantages for doing business in Malta? AB: Malta’s positive approach to business promotion, development and standard of living within the EU makes the island a destination of choice for relocation of business purposes. Malta offers noteworthy benefits to individuals and investors who are… – Continue reading

Dixcart Releases Guide On UK’s Diverted Profits Tax

Dixcart, an international business support services provider, has released a new guide on the UK’s Diverted Profits Tax, which was altered ahead of its introduction on April 1, 2015. The DPT is intended to counter aggressive tax avoidance by multinational companies. It is charged at a rate of 25 percent… – Continue reading

Administration Proposes to Repeal Deferral, Haircut the Foreign Tax Credit and Interest Expense Deductions, Override Treaties, and Abandon Arm’s-Length Transfer Pricing for Intangibles

As the above title indicates (it is only a modest exaggeration), the Treasury Greenbook regarding the FY 2016 budget proposes a radical restructuring of the system for U.S. taxation of foreign income of U.S. multinational enterprises (MNEs). Some Congressional players have suggested that these proposals are an opening bid in… – Continue reading

European Union: European Competition Law Newsletter – April 2015

EU’s Highest Court Rules on Information Exchange On 19 March 2015, the European Court of Justice (ECJ) handed down a significant judgment on the application of EU competition law to information exchange between competitors. The case was an appeal from the European Commission’s 2008 decision to fine banana importers Dole,… – Continue reading

UAE MoF and UAQ FTZ sign MoU on international OECD tax regulations

The Ministry of Finance (MoF) recently signed a memorandum of understanding (MoU) with Umm Al Quwain Free Trade Zone Authority (UAQ FTZ). This agreement has been signed to ensure international standards of transparency in the exchange of information for tax purposes, as per Organisation for Economic Cooperation and Development (OECD)… – Continue reading

New tax treaty between Hong Kong and mainland China which has consequences for shipping, airline and securities trading companies

This is relevant mainly for (1) Hong Kong companies or investment funds selling securities in Chinese listed companies and (2) ship or aircraft leasing companies resident in Hong Kong who (finance) lease vessels and aircraft to lessees in mainland China. On 1 April 2015, Hong Kong and mainland China signed… – Continue reading

France: French Tax Update – Early 2015 Noteworthy Case Law And Tax Transparency Package

The present French Tax Update will focus on (i) several noteworthy French and European Union court decisions issued in the last months of 2014 and in the first months of 2015, and (ii) the recent presentation by the European Commission of a package of tax transparency measures. VALIDITY OF TAX… – Continue reading