Category: Loans

EU tax treaties draining developing countries

Spain negotiated the largest rate reductions in its tax treaties with developing countries, out of 15 EU nations scrutinised for their record on international tax-dodging in the wake of the Luxembourg Leaks scandal. Developing countries were missing out on billions of much needed-revenue as a result of the tax rate… – Continue reading

Transferring Capital and Profit Into and Out of Vietnam

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

Another Big Year of MLP ETF Inflows

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

Minter Ellison tax partner Bill Thompson says BEPS will be key focus at G20 Summit

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

Wolfgang Schäuble: Not Adopting the FTT Endangers the European Democracy

The Financial Transaction Tax (FTT) ensures that we have learnt the lessons from the banking crisis. Unless we accelerate the work on improving the rules so that they are adequate to an environment of globalisation, we will destroy the support for the European integration and that will be the end… – Continue reading

Bank of Ceylon offers exclusive corporate solutions

Bank of Ceylon, the country’s prominent corporate and trade services provider with 75 years of experience in the banking and financial services industry, has achieved an unassailable position in providing exclusive corporate financial solutions for private and Government sector corporate entities. The vast asset base it possesses has enabled BOC… – Continue reading

CRH subsidiary has €2.5bn in assets and no staff

Subsidiary funds companies within Irish multinational, says spokesman RH did not feature in the leaked files, but accounts for one of its Luxembourg subsidiaries show it had multibillion-euro intra-group loans going in and out of the state. Photograph: Brenda Fitzsimons Ireland’s largest indigenous multinational, building materials group CRH, has a… – Continue reading

Hong Kong steps up China loan probe

The Hong Kong Monetary Authority (HKMA) has launched an onsite examination into Hong Kong-based Taiwanese banks’ loan exposure to mainland Chinese companies, banking sources said last week. The HKMA, which is responsible for maintaining Hong Kong’s monetary and banking stability, has stepped up its supervision of Hong Kong banks since… – Continue reading

India: Sham Transactions: Recent Developments In Indian Tax Law

Delhi Tribunal holds that the mere fact that one of the steps in a transaction resulted in capital loss for the taxpayer would not make the series of transactions a sham. Karnataka High Court holds that shares bought at a premium, and sold at a lower value to individuals (ex-employees… – Continue reading

Luxembourg leaks: G20 alone can’t stamp out tax avoidance

The hollowing out of tax collected for public purposes by rich and poor nations is not confined to technology and mining companies, according to a major leak of secret tax agreements covering more than 340 companies around the world. The documents, published by the International Consortium of Investigative Journalists, include… – Continue reading

COURT CALLS NETHERLANDS TAX HAVEN; SAME AS UK, SWITZERLAND

The Dutch tax rules are attractive to large multinationals. The same is true for countries such as the United Kingdom, Switzerland and Luxembourg. This writes the General Court of Auditors in a report, which was requested by the Second Chamber. The report was published today. Large multinationals search around the… – Continue reading

Medical supplies group used Irish firm in tax deal

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

AIG was avoiding taxes when it was owned by the US government

After the US bailed out the insurance conglomerate AIG in 2008, the company’s employees kept to business as usual—which included setting up complex tax structures to avoid taxes in Europe and Japan. In 2008, the company was on the brink of a bankruptcy that would have created huge losses throughout… – Continue reading

Top British companies using Luxembourg tax avoidance scheme ‘like a magical fairyland’ to save billions

Papers show firms used internal loans and interest payments to cut tax bills Leaked tax documents show arrangements were signed off by EU state They are legal, but are predicted to trigger calls to stop firms avoiding taxes British companies using scheme include Dyson and drugs group Shire Some of… – Continue reading

Leak reveals Future Fund and multinationals’ secret offshore tax deals

Directors of the Australian government’s Future Fund as well as PricewaterhouseCoopers, Macquarie and AMP could be forced to face a Senate inquiry into tax avoidance following a global investigation into secret tax deals in Luxembourg. Thousands of leaked documents published by the International Consortium of Investigative Journalists on Thursday revealed… – Continue reading

Dutch tax regime similar to Luxembourg’s, auditors find

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

1MDB bringing back Cayman Islands fund, says minister

Sovereign fund 1Malaysia Development Bhd (1MDB) is bringing back the RM7.18 billion it had invested in the Cayman Islands, despite making good returns. Deputy finance minister Datuk Ahmad Maslan said the fund had already brought back 60% of its funds, and the balance 40% will return to Malaysia by year-end,… – Continue reading

Aid Funding is Being Routed Through Tax Havens

BRUSSELS – Aid funding intended for private enterprises in developing country is being moved through offshore tax havens, potentially hindering tax collections in the developing countries it was meant to help. Government operated aid and development organizations around the world routinely route investments and funds through entities domiciled in offshore… – Continue reading

hong kong loans offshore banking taiwan China Offshore investment statutory> accounts and audit

Nov 5 (Reuters) – The Hong Kong Monetary Authority (HKMA) has launched an onsite examination into Hong Kong-based Taiwanese banks’ loan exposure to mainland Chinese companies, banking sources said on Tuesday. The HKMA, which is responsible for maintaining Hong Kong’s monetary and banking stability, stepped up its supervision of Hong… – Continue reading

Singapore: Changing Expectations on Transfer Pricing Documentation

Ernst & Young Solutions LLP, Singapore* It has been eight years since the Inland Revenue Authority of Singapore (IRAS) first released its Circular on Transfer Pricing Guidelines. During that time, there have been significant changes in the international tax landscape. In Singapore, we have seen supplementary guidance from the IRAS… – Continue reading

Big 4 Audit Firms Play Big Role in Offshore Murk

For more than a decade, tax gurus at PricewaterhouseCoopers helped Caterpillar Inc., the U.S. heavy equipment maker, move profits produced by its lucrative spare-parts business from the U.S. to a tiny subsidiary in Switzerland. Little changed except the bookkeeping. Parts were still shipped from suppliers to a warehouse in Morton,… – Continue reading

Indian Government Loses Major Tax Case to Vodafone

Vodafone sign in India. Photo: Ishan Khosla. Used under Creative Commons license. Vodafone recently won a rare – but potentially very significant – victory over Indian tax authorities. The Bombay High Court dismissed the government demand for the company to pay 30 billion rupees (about $490 million) for a share… – Continue reading

Development billions channelled through tax havens

Public institutions providing finance to businesses in developing countries are channelling billions of euros through secretive tax havens, a report published today (4 November) has found. Development Finance Institutions (DFIs) in Europe and the World Bank’s lending arm, the International Finance Corporation (IFC), are playing an increasingly dominant role in… – Continue reading

Maine’s largest landowner, billionaire media magnate avoids millions in taxes with inversion deal

NEW YORK — Shifting the address of his Liberty Global Inc. from Colorado to London last year didn’t just put billionaire John C. Malone in a position to reduce his company’s tax bill. He also took precautions to avoid the capital-gains hit that the so-called inversion would trigger for him… – Continue reading

Ex-Mizrahi Octogenarian Banker Acquitted at Tax Trial

A retired senior vice president at Israeli-based Mizrahi Tefahot Bank Ltd. (MZTF) was acquitted in Los Angeles federal court on charges he helped U.S. customers conceal their assets from the Internal Revenue Service. Jurors deliberated four hours yesterday before clearing Shokrollah Baravarian, 82, of conspiring to defraud the U.S. and… – Continue reading

Minnesota companies shelter billions in cash from U.S. taxes

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

Tax revenues are under relentless attack – the government needs to take action

Taxes are the price of a civilised society and without them no state can provide social infrastructure, alleviate poverty, subsidise corporations or rescue distressed banks. But tax revenues are under relentless attack and corporate ingenuity in avoiding taxes shows no limits. Companies have become very adept at shifting profits to… – Continue reading

Europe’s tax haven investments in Africa

In front of European Commissioners, leading politicians, chief executives of huge multinationals, senior bank bosses and billionaires, the Egyptian investment tycoon was asked to set the tone of the forum, a three-day lobbying event funded by the EU. Dr Heikal is founder and chairman of Qalaa, an African investment fund… – Continue reading

Bank Leumi Said to Face $300 Million Demand in Tax Case

New York’s banking regulator will ask for more than $300 million to settle an investigation into whether Bank Leumi Le-Israel (LUMI) BM helped Americans evade taxes, a person familiar with the matter said. Benjamin Lawsky, head of the state’s Department of Financial Services, is seeking more than what the bank… – Continue reading

Japanese Taxation of a PE under the AOA Approach

Background The “Authorized OECD Approach” (“AOA”) rule for taxation of permanent establishments (“PE”) was introduced in Japan’s 2014 tax reform and will be applied to fiscal year commencing April 1, 2016. The new rule includes changes to source rules, the introduction of transfer pricing to intra-company transactions, and the introduction… – Continue reading

Too Big to Tax: Settlements Are Tax Write-Offs for Banks

At the Justice Department, senior officials like to congratulate themselves on the headline-making, big bucks settlements they have imposed upon banks and lenders for their part in causing the 2008 mortgage meltdown that sparked the biggest American financial crisis since the Great Depression. But wait a moment. Those settlement figures… – Continue reading

Fitch: M&A Premiums Fall on Inversion Crackdown

NEW YORK–(BUSINESS WIRE)–Tax inversion deals have effectively been repriced by the US Treasury signaling an end to “hop-scotch” loans and other tax structuring opportunities, according to Fitch Ratings. AbbVie’s purchase of Shire and the planned merger of Salix Pharmaceuticals and Cosmo Technologies, both pulled since the Treasury announcement, were scuttled… – Continue reading

RLPC-Taiwan’s FSC examines Taiwanese banks’ China exposure

Oct 24 (Reuters) – Taiwan’s Financial Supervisory Commission (FSC) has launched an enquiry into 10 Taiwanese banks with the largest exposure to Chinese companies, following a similar investigation by the country’s Ministry of Finance (MoF), bankers said on Wednesday. As a major shareholder, Taiwan’s MoF asked eight Taiwanese state-owned banks… – Continue reading

WHO Meets Behind Closed Doors, Threatens A Global Tax Hike

The sovereignty of individual nations is increasingly under threat from international governance bodies that want to force a range of new regional and international taxes on states. The latest attempt to bypass state sovereignty occurred when the World Health Organization (WHO) met behind closed doors in Moscow last week. In… – Continue reading

Government is considering interest deduction restrictions for infrastructure

Officials from the Treasury and HM Revenue and Customs (HMRC) have been meeting with representatives of the PPP/ PFI industry to discuss the implications for infrastructure projects of possible restrictions to interest relief.24 Oct 2014 Corporate tax Tax Projects Construction Advisory & Disputes Infrastructure UK Europe In a report on… – Continue reading

Liechtenstein joining hunt for Islamic wealth

JAKARTA, Indonesia — Liechtenstein wants to lure wealthy Muslims to its private banks as it seeks to revive an industry hurt by the loss of the nation’s status as a tax haven. The principality of 37,000 people nestled between Switzerland and Austria will hold its first Islamic finance conference on… – Continue reading

Interest deductions: the new war on base erosion

ITR Correspondent • • • The G20 and OECD’s Base Erosion and Profit Shifting (BEPS) project has rarely been out of the headlines during 2014. At the heart of the BEPS project is the assumption international tax rules make it possible for profits to be taxed in countries that are… – Continue reading

Four foreign banks ordered to tighten anti-laundering efforts

The financial regulator said on Tuesday that it has ordered four foreign banks operating in Korea to strengthen their anti-money laundering protections. The Financial Supervisory Service (FSS) inspected some 60 local and foreign banks to check whether they are equipped with relevant safeguards. Among them were the Seoul branches of… – Continue reading

US-driven quest against money laundering: Standard Chartered to close thousands of UAE accounts

Standard Chartered has notified thousands of UAE small and medium enterprise customers it is closing their accounts as it responds to pressure from US regulators to cut its risks following an anti-money laundering settlement. “We regret to notify you that Standard Chartered Bank will no longer be able to provide… – Continue reading

India: Vodafone Victorious In Multi Million Transfer Pricing Battle, Yet Again!

Bombay High Court holds that shares issued at a premium by a resident entity to a non-resident entity is a capital account transaction and does not give rise to any income; Income arising from an International Transaction between AEs must satisfy the test of ‘income; as provided under the ITA… – Continue reading

Texas Billionaire Files for Bankruptcy

DALLAS (CN) – Former Texas billionaire Sam Wyly filed for bankruptcy protection after a federal jury ordered him to pay as much as $400 million for using offshore trusts to hide stock trades.      A noted philanthropist and contributor to Republican causes, Wyly, 77, of Dallas, made his fortune… – Continue reading