Category: Activity

What qualifies as direct investment under Cyprus-Russia double tax agreement?

Introduction Article 10 of the Russia-Cyprus double tax agreement grants taxing rights over dividends to the state of residence of the company paying the dividends (in addition to the state of residence of the recipient). The tax that may be imposed in the state in which the dividends originate is… – Continue reading

Potato boss Paul Rennie ‘can’t recall’ overseas transactions, Federal Court hears

Potato king Paul Rennie has told a court he is unable to explain why he sent millions of dollars to tax havens in transactions revealed by a Project Wickenby investigation. The Federal Court heard Mr Rennie had been raided by federal police, who seized documents related to his Griffith-area potato… – Continue reading

How widespread is tax evasion?

In round-tripping, U.S. investors move funds to offshore tax havens, then invest in U.S. equity and debt markets with these “foreign” funds. In essence, the U.S. investors are disguising themselves as foreign investors, who are not subject to the same tax rates on capital gains and interest income. The money… – Continue reading

Russia Accelerates Legislation to Avoid Fines as FATCA Talks Stall

The Finance Ministry is drawing up legislation allowing Russian banks to give information about their clients to foreign tax authorities, after U.S. stonewalling halted bilateral negotiations on a  financial information sharing agreement. At the same time, the ministry intends to oblige foreign banks to report similar information to the Russian tax service, Vedomosti reported Wednesday, citing sources in the ministry…. – Continue reading

A New World Tax Regime

To anyone who even casually monitors international agencies — such as the UN, the OECD, and the IMF — it will come as no surprise that those agencies have long wanted stable sources of funding that they could count on, rather than relying on handouts from governments around the world…. – Continue reading

Congress Considers Making Offshore Tax Loopholes Permanent

On Tuesday, the House Ways and Means Committee holds a hearing to discuss making permanent several of multinationals’ favorite tax code provisions, including the Apple loophole. Thus the House, like the Senate, is in the early stages of enacting these expired provisions yet again. That’s how Congress traditionally gives multinationals their offshore tax loopholes: propose… – Continue reading

New Russian Forex Bill: Offshore Regulation To Be Banned

The schedule of the Russian parliament has been updated yet again and it appears that forex dealing regulation is coming back to the fray. According to recent reports by Russian media there might be some key amendments aimed to limit the participation of brokers residing in offshore financial centres (OFCs)…. – Continue reading

Taxation impedes Johnson Report objectives: Macquarie

Australian tax laws are inhibiting the export of financial services and the nation’s development as an “international financial centre”, according to Macquarie Group. In its submission to the Financial System Inquiry, Macquarie said Australia’s tax provisions are becoming “increasingly detailed, complex and hard to interpret, making it difficult for businesses… – Continue reading

Irish Corporate Tax: Government begins publicity offensive on tax with irrelevant paper

Irish Corporate Tax 2014: The Government today issued what it calls a technical paper on effective corporation tax rates to effectively confuse the public by avoiding the key issues about its facilitation of corporate tax avoidance. It’s irrelevant to the core issues as it is simply trying to divert attention… – Continue reading

Ireland’s effective corporation tax at approximately 10.8pc over a decade – report

IRELAND’s effective rate of corporation tax averaged between 10.7pc and 10.9pc over the last decade, a report by the Department of Finance states. It claims that the tax paid by companies is close to the 12.5pc headline rate, amid controversy over the amount paid by multinationals here. The Department commissioned… – Continue reading

Intergovernmental agreement with US over the controversial FATCA tax act secured

All bar the dotting of the i’s and crossing of the t’s appears done in New Zealand’s intergovernmental agreement with the United States over its controversial Foreign Account Tax Compliance Act, or FATCA. An Inland Revenue Department (IRD) spokesman confirmed to interest.co.nz negotiations between the two countries have progressed sufficiently… – Continue reading

Irish Economy 2014: Ibec forecasts robust growth in tax-related services exports

Irish Economy 2014: Ibec, Ireland’s leading business lobby group, in its latest economic forecast today forecasts “continued robust growth in services exports and a recovery in goods exports.” The strong growth in services mainly reflects tax-avoidance related revenue diversions to Ireland that do not reflect local economic activity. If the… – Continue reading

Credit Suisse Faces Threat Of New US Probe For Offshore Tax Evasion

ZURICH (Reuters) – Credit Suisse faces the threat of a new investigation into its role in helping wealthy Americans avoid paying taxes after New York state’s top financial regulator requested documents from the Swiss bank. Switzerland’s second-largest lender had raised expectations it was putting the long-running American tax controversy behind it when it… – Continue reading

Report: Netflix Sets French Headquarters In Luxembourg to Bypass Regulations

PARIS — Netflix is set to follow iTunes and Google’s footsteps: The service is expected to launch in Gaul in the fall but will be headquartered Luxembourg in order to avoid the heavy French regulations. French newspaper Les Echos reported the move will bring Netflix’s French outpost together with its other European headquarters —… – Continue reading

Luxembourg, US Sign FATCA Deal

Luxembourg and the US have signed an intergovernmental agreement (IGA) to implement the Foreign Account Tax Compliance Act (FATCA). Luxembourg and the US negotiated a Model 1 IGA, requiring the Luxembourg Tax Administration and the US Internal Revenue Service (IRS) to exchange information automatically on accounts held by US citizens… – Continue reading

Banking secrecy in the Cayman Islands

The offshore jurisdictions are commonly thought to be highly secretive, with banking secrecy being an important part of what those jurisdictions offer to businesses and individuals who use them. For example, in 2000, the U.S. Treasury Department issued an advisory notice stating that extra vigilance was required in doing business… – Continue reading

Canada: OECD’s New Country-By-Country Transfer Pricing Reporting Template

On January 30, 2014, the Organization for Economic Cooperation and Development (OECD) released a discussion draft for comment on Action 13; the transfer pricing documentation prong of the Base Erosion and Profit Shifting (BEPS) project, which includes country-by-country reporting. As the Committee of Fiscal Affairs believes it is essential to… – Continue reading

Alibaba IPO Appeal Could Make It Target For Scutiny From Beijing

The much-anticipated initial public offering of Chinese Internet giant Alibaba Group could be a double-edged sword for the company: Investors are drooling for a piece of the action in that country’s burgeoning online payment market, but its growing use in illegal transactions could attract scrutiny from Chinese government regulators. Alibaba,… – Continue reading

Bahamas Targets Tuesday For Fatca Deal Completion

The Bahamas is aiming to complete its FATCA Intergovernmental Agreement (IGA) this coming Tuesday when a high-level team visits Washington, a Cabinet Minister yesterday disclosing this nation was pushing for another key product to be exempt from reporting requirements. #While declining to name the product in question, Ryan Pinder, minister… – Continue reading

FATCA Overreach

A correspondent told me that last week’s column on Caribbean response to the US Foreign Account Tax Compliance Act (FATCA) was puzzling. Why didn’t the column expose those wimps – Caribbean ministers of finance and governments? How could they accept this bullying US imposition? My response was that I expressed… – Continue reading

Offshore Companies Banned from Bulgarian Agriculture Land Ownership

Offshore companies can not acquire and have ownership of agricultural land in Bulgaria, according to the latest amendments to the Agricultural Land Ownership and Use Act. The changes to the Agriculture Land Act were passed on second reading, Thursday, Bulgarian BTV reports. The restriction applies to joint-stock companies that have issued bearer shares, as well…. – Continue reading

US Prepares To Enforce 45 FATCA Pacts

The United States Department of the Treasury and the Internal Revenue Service (IRS) have announced that foreign jurisdictions that have reached agreement on the terms of intergovernmental agreements (IGAs) under the Foreign Account Tax Compliance Act (FATCA) can be treated as having such agreements in effect until the end of… – Continue reading

FATCA IGAs Agreed in Substance Treated as in Effect; Deadline Extended

April 2 — The Treasury Department and the Internal Revenue Service announced that countries that have reached intergovernmental agreements (IGAs) in substance under the Foreign Account Tax Compliance Act before July 1 will be treated as having signed agreements through Dec. 31, 2014, winning praise from practitioners. The government also said… – Continue reading

U.S. waits for Azerbaijan’s response on tax information exchange agreement

Baku, Fineko/abc.az. The U.S. is waiting for Azerbaijan’s response on the agreement on the exchange of tax information on the FATCA rules. The U.S. Embassy reports that the US has engaged the Azerbaijani government on this issue. “Now we’re waiting for their response. The US government is negotiating similar arrangements… – Continue reading

OECD targets Macquarie offshore tax-saving schemes

Aggressive tax strategies pioneered by Macquarie Group are under scrutiny both internationally and in Australia, putting at risk techniques the company has used to claim more than $1.3 billion in deductions. The Organisation for Economic Cooperation and Development is targeting ”foreign tax credit generators” as part of its battle against… – Continue reading

Nokia India, Finnish parent discuss tax evasion in emails

The department had slapped a tax demand of Rs 2,080 crore on the company last year while re-opening the assessment for AY 2006-07 and 2007-08. As Finnish phone-maker Nokia strives to meet the April 30 deadline for sealing the $7.2 billion deal with Microsoft, its tussle with the Indian tax… – Continue reading