HM Revenue and Customs (HMRC) is planning to make its Double Taxation Treaty Passport (DTTP) scheme available to all UK borrowers following a consultation on a legislative amendment. The DTTP scheme provides for Double Taxation Relief on UK loan interest payments made by a UK corporate borrower to overseas corporate… – Continue reading
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… – Continue reading
With hardly a fortnight left for the end of the financial year 2016-17, the March 31 deadline remains sacrosanct for several tax-related matters. Leaving things to the last minute has its own share of risks. So, keep a 2-4 days buffer to finish all tax-related tasks. Picture this: A taxpayer… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
From 6 April 2017, non-dom owners of UK property will be liable to inheritance tax (IHT) at 40% on any UK residential property they own. This has always been the case where a non-dom (broadly an individual who is resident in the UK but who has their permanent home abroad)… – Continue reading
The Netherlands is slowly but surely steering away from facilitating the use of its corporate income tax system by companies that are set up merely to obtain tax benefits. These companies, which often do not actually carry out activities in the Netherlands, have contributed to the perception among policy makers… – Continue reading
In the public vote held on February 12, 2017, Swiss voters rejected the Corporate Tax Reform III Law Proposal (CTR III). Nevertheless, this issue is not yet resolved and remains on the table! A «CTR III 2.0» is expected in a timely manner. Information about the newest developments, but also… – Continue reading
On February 16, 2017, the Presidium of the Supreme Court of the Russian Federation approved the Review of Court Practice in the Consideration of Cases Involving the Application of Certain Provisions of Section V.1 and Article 269 of the Tax Code of the Russian Federation (the “Review”). There is no… – Continue reading
Italy must reform its banking system if it is to continue on a “weak” path to recovery, according to the Organisation for Economic Co-operation and Development (OECD). The country should be prepared to force holders of Italian bank debt to lose money rather than using public funds to bail them… – Continue reading
The OECD has recommended that Sweden rebalance its property tax system. In its latest Economic Survey for the country, the OECD said that Sweden’s favorable tax treatment of owner-occupied housing is regressive, benefiting relatively high-income households most and contributing to the high demand for housing. It said it also encourages… – Continue reading
Background Switzerland levies federal withholding tax at the rate of 35% on certain capital income, including dividend distributions of Swiss corporations. The federal withholding tax is fully refundable for Swiss resident recipients, provided that they (i) are beneficially entitled to and (ii) correctly declare respectively account for the taxable income…. – Continue reading
Among other things, Union Budget 2017 will be remembered for two firsts – the introduction of secondary adjustment and thin capitalisation rules. Both are transfer pricing provisions which will have a far-reaching impact on corporates. Secondary Adjustment Since the concept of secondary adjustment is introduced for the first time in… – Continue reading
Main residence exemption costing budget $61.5bn, almost double the $33bn lost to super concessions The federal government’s tax breaks for home owner-occupiers are dwarfing tax breaks for superannuation. New figures show the capital gains tax concession on the family home is now worth $61.5bn, almost double the $33bn lost to… – Continue reading
The most important task of the Finance Minister in the 2017-18 budget is to tame the “Indirect Transfer Provisions” monster born out of amendments to Section 9 of the Income Tax Act, 1961. In response to the Supreme Court’s judgement in the famous Vodafone case, the Finance Act, 2012 amended… – Continue reading
The new administration and Congress have signaled their intention to undertake fundamental tax reform in the coming months. Lawmakers will need to weigh the costs and benefits of numerous policy trade-offs as they undertake this effort. Among the most visible debates already underway concerns “border adjustability,” or moving the U.S…. – Continue reading
The Offshore Compliance Advisory Committee issued a report in December 2016 to the Canada Revenue Agency about the Voluntary Disclosures Program (VDP or tax amnesty). If a taxpayer submits a successful income tax or GST/HST voluntary disclosure program application then generally criminal income tax prosecution and civil tax penalties under… – Continue reading
On December 21, 2016, the new Canada–Israel tax treaty entered into force. The new treaty was signed on September 21, 2016 in New York, and replaces the existing treaty that dates from 1975. For most purposes, the provisions of the new treaty took effect as of January 1, 2017. Overall,… – Continue reading
January 2017 – On 21 December 2016, Ukraine’s parliament adopted the Law “On Amendments to the Tax Code of Ukraine Concerning Improvement of the Investment Climate in Ukraine” No. 1797-19. With effect from 1 January 2017, the legislation introduces new rules for the taxation of interest payable by Ukrainian economic… – Continue reading
Montenegro has concluded double taxation treaties with more than 35 countries, and this number continues to grow. The most recently signed treaty is the one concluded with Montenegro. The agreement affects persons who are residents of one or both of the contracting states and applies to the Portuguese personal income… – Continue reading
Given the recent developments in the Indian economy, the upcoming Union Budget will certainly be critical and important in determining the future outlook of the economy. The financial services industry has been one of the key drivers of growth due to its strong cause and effect relationship with the economy…. – Continue reading
British chancellor Philip Hammond has infuriated German politicians for implying a “hard” Brexit would see London adopt a new role as a tax haven before the gates of the EU. Driving speculation ahead of Tuesday’s Brexit address by prime minister Teresa May, Mr Hammond said he preferred seeing Britain remain… – Continue reading
Trade agreement would have to include strict rules to prevent Britain becoming offshore haven, Dutch deputy PM says The Netherlands will block any EU trade deal with the UK unless it signs up to tough tax avoidance regulations preventing it from becoming an attractive offshore haven for multinationals and the… – Continue reading
India is unlikely to amend its tax treaty with the Netherlands as it did with Mauritius, Singapore and Cyprus and this could shape the investment strategy of foreign portfolio investors (FPI) and private equity (PE) funds investing in India, said three people in the know. “There were talks to amend… – Continue reading
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
Homeowners who have seen their properties rise in value substantially are getting a break from the government when it comes to paying their taxes. The province has announced it is increasing the home owner grant threshold to $1.6 million from $1.2 million, meaning owners of properties valued up to that… – Continue reading
Hong Kong’s Financial Services Development Council (FSDC) has issued a paper setting out key recommendations for the Government to consider in the area of international tax law. The paper, which was issued on December 29, 2016, recommends that the Government should issue clearer guidance on appropriate transfer pricing methodologies for… – Continue reading
The amended double taxation agreement between the UK and the Isle of Man has entered into force, effective from 5 January 2017, following the latest arrangements signed on 8 March 2016. The bilateral agreements between the UK and the Isle of Man concern cooperation in tax matters through the exchange… – Continue reading
The taxman has been accused of sending alarming letters to savers over Christmas. HM Revenue & Customs sent out 10,000 letters warning taxpayers they may have underpaid and reminding them they faced penalties for errors. The letters asked them to ‘reconsider’ the amount of interest they had declared on their… – Continue reading
Jean-Claude Juncker deliberately blocked the EU’s efforts to fight tax avoidance while in office as prime minister of Luxembourg, according to documents revealed by The Guardian and the International Consortium of Journalists. EurActiv France reports. Member states have supposedly spent the last two decades cooperating in the committee on business… – Continue reading
The Central Board of Direct Taxes in India issued Circular Number 41 on December 21, 2016 providing clarifications on applicability of ‘indirect transfer’ provisions under the Indian Income Tax Act, 1961 to investors of Foreign Portfolio Investors (FPIs) – earlier known as Foreign Institutional Investors (FIIs) in India. The circular… – Continue reading
Starting April 1, 2017, India will have the right to tax capital gains arising on Indian equity shares sold by a Singapore resident. The governments of India and Singapore have amended the double taxation avoidance treaty between the two countries, in line with the changes India recently made to a… – Continue reading
South Africa’s Ministry of Finance has published the 2016 Taxation Laws Amendment Bill (TLAB), which has received parliamentary approval and gives effect to the tax changes announced in the Budget in February this year, together with legislation confirming the final details of the Special Voluntary Disclosure Program (SVDP). With changes… – Continue reading
The government announced on Friday details of a more stringent income declaration scheme, a “last chance” for tax evaders who will have to cough up 50% of their unaccounted-for wealth in tax. The scheme– called the Pradhan Mantri Garib Kalyan Yojana (PMGKY) – was announced last month and will be… – Continue reading
A recent report has revived claims Singapore is a tax haven but the Singapore Government and experts here reject the label emphatically. They say the report contains inaccurate assertions and fails to recognise recent steps here to crack down on tax evasion. The Republic ranked fifth on a list of… – Continue reading
Expats in the UAE has been advised that banks and other financial institutions will be contacting some of their customers to collect information about their tax status in early 2017, reports local newspaper Gulf News. CRS requires countries to exchange information about individual and expat bank accounts, as well as… – Continue reading
General On 30 November 2016, Kazakhstan adopted certain amendments to its Tax Code (the Tax Amendments). Most of the Tax Amendments take effect on 1 January 2017. Below we summarize some of the most important Tax Amendments: VAT Registration Threshold Under the Tax Amendments, the existing VAT registration threshold (i.e.,… – Continue reading
MUSCAT -The Double Taxation Agreement (DTA) between Switzerland and Oman aiming to increase economic ties officially came into force last month, according to the Swiss government. Its provisions will be applicable from January 1, 2017, according to the government. The agreement was originally signed on May 22, 2015 before going… – Continue reading
ISLAMABAD – Pakistan and China signed third protocol to the avoidance of double taxation agreement that would allow a Chinese bank and a state-owned investment fund to avail income tax exemption on interest income from loans for energy projects under China-Pakistan Economic Corridor (CPEC). Federal Board of Revenue (FBR) Chairman… – Continue reading
Fast-food chain’s reorganisation means £800m from restaurants in Europe will flow through the UK instead McDonald’s is to scrap its controversial Luxembourg tax structure in a corporate shakeup that means $1bn (£800m) of income from fast-food restaurants across Europe will flow through the UK instead. The move comes 12 months… – Continue reading
In Depth There is mixed news for affected individuals, including far-reaching changes relating to offshore trusts and a further wait (possibly until March 2017) for the rest of the draft legislation. The following are highlights from the government’s response and the draft legislation. Deeming Provisions Deemed Domiciled: Non-doms will become… – Continue reading
Switzerland, which has been working to end its years-long practice of banking secrecy, on Thursday said it aimed to dramatically increase the number of countries it cooperates with toward international fiscal transparency. The Swiss government said in a statement that it wanted to extend the automatic exchange of information (AEOI)… – Continue reading
The United States has not agreed to participate in the Common Reporting Standard (CRS), relying instead on the Foreign Account Tax Compliance Act (FATCA) regime enacted in 2010 and initiated in 2014. United States participation in CRS is highly unlikely. Even with a change in control of Congress, CRS may… – Continue reading
The Organization for Economic Co-operation and Development (OECD) issued the Standard for Automatic Exchange of Financial Information in Tax Matters (Standard for AEOI) in July 2014, which aims to prevent offshore tax evasion and maintain the integrity of tax systems. Over 100 jurisdictions have committed to comply with the Standard… – Continue reading
When introducing the draft legislation for the Diverted Profits or so-called “Google Tax”, Federal Treasurer Scott Morrison claimed it would: …reinforce Australia’s position as having amongst the toughest laws in the world to combat corporate tax avoidance. Australia is the second country to introduce this type of tax, after the… – Continue reading
For myriad reasons, Malta has over the years established itself as an ideal jurisdiction to hold intellectual property rights. The country offers many tax benefits on income derived from Intellectual Property. Apart from the tax exemption on income derived from patents, copyrights and trademarks as will be further explained below,… – Continue reading
The U.K. government said it would investigate bringing nonresident companies’ income into the country’s corporation tax regime. The consultation on the move is expected to begin at Budget 2017 in March, the Treasury said in its Autumn Statement Nov. 23. “The government wants to deliver equal tax treatment to ensure… – Continue reading
On November 22, 2016, the Minister of Finance of Ukraine handed an official letter on Ukraine’s accession to the BEPS (Base Erosion and Profit Shifting) plan to the Secretary-General of OECD. Being the final stage in the process of joining the project, Ukraine is to become a member of the… – Continue reading
Tax authorities across Europe will be able to automatically share information about bank account holders, according to a Council position approved by the European Parliament on November 22. It was passed by 590 votes to 32 votes, with 64 abstentions. According to a European Parliament press release, the new rules… – Continue reading
