Category: Loans

Virtual Currency Exchanges and US Customers Beware, IRS is Coming: Expert Blog

In the aftermath of Satoshi Nakamoto’s groundbreaking paper in 2009, money began travelling via a new financial route – virtual currencies. The first Bitcoin exchange was established on February 6, 2010 where Bitcoin traded for the first time for 0.3 cents. Last June, the American Institute of Certified Public Accountants...

Shell transactions under vigil: Serial Income Tax raids on three businessmen

HYDERABAD: Income Tax sleuths on Wednesday conducted simultaneous searches in Hyderabad and Vijayawada on three top businessmen cum-realtors, who were allegedly evading tax, particularly in real estate transactions and unearthed documents pertaining to unaccounted investments running into hundreds of crores of rupees. These are the first big raids after shell...

US set to lose $12bn in tax take by 2027 if multinationals relocate overseas

Tax inversions by US multinationals attempting to shift profits into lower tax jurisdictions could cost the US up to $12bn (£7.4bn) in lost corporate tax revenues by 2027, according to figures released by the US Congressional Budget Office There were 11 major corporate inversions from 2014-2015, although two significant inversions...

Ghana-Morocco double tax agreement to come into force in 2018 – (Part 2)

In our last publication, we discussed the signing of the Ghana-Morocco Double Tax Agreement (“DTA”) and the provisions of the DTA in relation to the taxation of permanent establishments and business income. In the concluding part of the article, we will discuss the taxation of investment, employment and service incomes...

Interpreting double tax treaties in light of the BEPS multilateral instrument

Some double tax treaties are being amended by a multilateral instrument Establishing how a particular treaty is affected can be a complicated process The UK intends to publish amended DTTs and this will help, but the MLI has added an additional layer of complexity 18 Sep 2017 Speed Read LEGAL...

US Think Tank Says Earning Stripping Regs Should Be Retained

Contrary to calls from businesses from the regulation’s withdrawal, the Institute on Taxation and Economic Policy has called on the US Treasury to fully implement and strengthen its final Section 385 anti-earnings stripping debt-equity regulations, designed to reduce the benefits of corporate tax inversions. The final regulations, released in October...

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...

Tax Rule Aimed at Corporate ‘Earnings Stripping’ Under Review

Obama-administration regulation drew criticism as overbroad Trump ordered review of tax rules that may pose undue burdens A federal rule aimed at limiting corporate “earnings stripping’’ for tax-avoidance purposes may pose an undue burden on taxpayers and may be changed or rescinded, according to a U.S. Internal Revenue Service notice....

Enhancing diplomatic and economic ties: Ghana-Czech Republic Double Tax Agreement to come into force in 2018

Ghana signed another Double Tax Agreement (DTA) with the Czech Republic on 11 April, 2017. Ghana already has DTAs in force with Denmark, the United Kingdom, Belgium, Italy, South Africa, Switzerland, Netherlands, France and Germany. DTAs with Mauritius, Singapore and the Czech Republic are in the process of being ratified...

Cyprus: Saying Goodbye To Back To Back Loans And Welcoming Transfer Pricing Regulations

A. Introduction In February 2017 Cyprus Tax Department has announced that the current practice regarding profit margins between related Company loans will be abolished by the 30th June 2017. The announcement indicates that the minimum acceptable margins will apply up to 30th June 2017, and as from 1st July 2017...

Malta Pushes to Ease EU Cross-Border Interest, Withholding Tax

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...

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...

Trump’s tax plan could have rich New Yorkers fleeing for Florida

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...

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...

Cyprus: Abolition Of Profit Margins On Intra Group Loans – Upcoming Transfer Pricing Legislation – Transfer Pricing Studies Requirement

As a rule and according to Article 33 of the Cyprus Income Tax Law, which introduces the arm’s length principle (using wording similar to that of article 9 of the OECD Model Tax Convention), all transactions between companies, including loan agreements/transactions by Cyprus companies, must be undertaken at arm’s length...

Withholding tax on dividends – A bagful of uncertainties and complexities?

Muscat: One of the many changes that the Royal Decree 9 of 2017 (RD) has made in the Oman Income tax law is the introduction of withholding tax (WHT) on payment of ‘dividends on shares’ by Omani companies. This amendment requires Omani companies distributing dividends on shares to foreign persons...

Chile Leads Region to Test Companies’ International Tax Links

Chile is leading a regional push across Latin America to clamp down on tax avoidance and profit-shifting by multinational and local firms, with the country’s tax authority making companies with interests and assets one of its priorities for inspections this year. Outlining its tax enforcement plan for 2017 on March...

Art of the deal: Trump, Dems look for common ground to close tax loopholes

Venture capitalists, investors left unfazed Both President Trump and Capitol Hill Democrats head into negotiations over tax reform vowing to put the squeeze on hedge fund managers by closing the carried interest tax loophole — a point of agreement that held out promise for becoming a foundation for a once-in-a-generation...

Law Society reaches understanding with IRD on FATCA

The New Zealand Law Society says that following discussions with Inland Revenue and the New Zealand Bankers’ Association it has now reached an understanding with Inland Revenue about application of FATCA to lawyers’ trusts accounts. FATCA is the United States’ Foreign Account Tax Compliance Act. Its objective is to reduce...

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...

10-point assessment of tax evasion

PETALING JAYA, Mar 15 (Sin Chew Daily) — Local taxation expert Koong Lin Loong said the Internal Revenue Department’s target was not wealthy people but tax evaders. “Whether a person is evading tax is normally assessed with the ten-point criteria, and assets of unidentified origins will be their focus of...

Switzerland to Exempt Withholding Taxes for Some Group Financing

The Swiss government plans to bolster group financing activities by amending its withholding tax ordinance to exempt interest payments for certain intra-group loans. The goal of the amendment is to encourage Swiss-based multinational companies to pursue targeted financing activities in Switzerland rather than abroad, according to a March 10 news...

Bank transparency, data matching for tax purposes

The government’s plan to issue a regulation in lieu of law (Perppu) concerning banking transparency, which includes allowing the tax authority to access taxpayers’ bank data, has sparked hot public debate. The proponents argue that such an initiative is critical, outlining the fact that the government has to comply with...