Category: Activity

Income-tax dept issues norms to determine residency status of companies

New guidelines aim to check tax evasion, ensure foreign firms are not taxed on their global income. New Delhi: The income-tax (I-T) department on Tuesday issued the final guidelines for place of effective management (PoEM) rules that seek to determine the residency status of a firm for calculating its tax liability. The… – Continue reading

Tax Topics: Border-Adjustments And Tax Avoidance

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

Withholding tax returns come under crosscheck

Revenue appraisers began crosschecking the withholding tax returns from some companies to determine propriety of the pay disbursed to their foreign and local employees and consultants. In recent times, the submitted accounts on the pay-as-you-earn tax of some multinational companies (MNCs) and domestic firms have been under surveillance of the… – Continue reading

Canada: New Principal Residence Exemption Rules

On October 3, 2016 the Federal Government proposed changes to the Income Tax Act (the “Act”) and administrative policies that will impact claiming the principal residence exemption. 1. All dispositions of principal residences must now be reported. Previously, the CRA did not require taxpayers to report the sale of a… – Continue reading

SECP seeks amnesty scheme for offshore company owners

ISLAMABAD – The Securities and Exchange Commission of Pakistan (SECP) has proposed the government to give one time amnesty scheme for the owners of offshore companies to declare their hidden assets by paying nominal tax. “I have asked the Finance Minister Ishaq Dar to give one opportunity to offshore companies… – Continue reading

Bermuda – the world’s former ‘No.1 tax haven’ – joins fight against multinationals

Bermuda – the world’s former “top tax haven” – has joined the Organisation for Economic Cooperation and Development’s fight against multinational profit shifting. Bermuda disputes it is a tax haven despite companies such as Apple and Google in the past being accused of using the British overseas territory to minimise… – Continue reading

BDI lobby group opposes end of ‘patent box’ tax breaks

Germany’s BDI industry group has come out against a government plan to unilaterally close so-called ‘patent box’ tax loopholes used by foreign companies to avoid paying full taxes on profits earned in Germany. The Association of German Industrialists, BDI, said Tuesday that the government’s unilateral move would send a negative… – Continue reading

‘Tax haven’ Canada being used by offshore cheats, Panama Papers show

Country’s reputation being exploited for ‘snow washing’ global money trails, experts warn Far from the palm-fringed beaches of the usual offshore tax havens, Canada has quietly become a go-to destination for international tax cheats eager to exploit the country’s twin benefits of a sterling reputation and rules that allow private… – Continue reading

OECD’s MLI: will tax treaty benefits apply to private equity investors?

The OECD recently released a public discussion draft entitled the “BEPS Action 6 Discussion Draft on non-CIV examples” to clarify when investors like private equity funds, real estate funds and hedge funds should be entitled to tax treaty benefits. The release of the 2017 Discussion Draft is timely, given that… – Continue reading

Bahamas on Track to Implement Common Reporting Standard (CRS)

Nassau, The Bahamas – The Bahamas has taken many steps to comply with global standards in the financial services sector. One such step is the implementation of the Common Reporting Standard (CRS). The Common Reporting Standard (CRS), developed in response to the G20 request and approved by the OECD Council… – Continue reading

Vizor Software’s Solution for FATCA & AEOI Selected by Government of Kuwait

Ministry of Finance – State of Kuwait recently “went live” with the Vizor Software for FATCA & AEOI solution to meet its FATCA obligations under the terms of its Intergovernmental Agreement (IGA) with the United States of America’s Internal Revenue Service (IRS). Today, Vizor Ltd. announced the Kuwaiti Ministry of… – Continue reading

BEPS – Germany on the way to limit the tax deductibility of royalties

A new legislative approach of the German tax authorities leaked last December 19 will have a significant impact on the tax deductibility of royalties owed to related persons being subject to a preferential back end tax regime for IP not being in compliance with the Organisation for Economic Co-operation and… – Continue reading

Canada: Report On The Voluntary Disclosures Program (VDP) – Canadian Tax Consultant Analysis

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

From Israel to Canada: New Tax Treaty to Help Structure Investments

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

Agreement to implement FATCA signed with US

Manama, Jan. 22 (BNA): An agreement was signed between the Government of the Kingdom of Bahrain and the Government of the United States of America to improve international tax compliance and implement the Foreign Account Tax Compliance Act (FATCA). The agreement was signed by the Minister of Finance, H.E. Shaikh… – Continue reading

Multilateral Instrument: The new dilemma of foreign investors

MUMBAI: The Multilateral Instrument (MLI), a new global tax avoidance agreement, that is in the process of being signed by 100 countries, is now causing a lot of anxiety among foreign portfolio investors (FPIs). MLI is an agreement put out by OECD, the intergovernmental economic organisation, to stop Base Erosion… – Continue reading

Automatic information exchange to start from 2018

KARACHI: Finance minister Ishaq Dar on Friday said that tax evaders will find no place to park their ill-gotten money, as Pakistan will begin automatic-exchange of information from next year. “As per international agreement with OECD (Organisation of Economic Cooperation and Development), Pakistan will start automatic exchange of information regarding… – Continue reading

2017 Budget Law: tax relief for individuals who decide to fix their tax residence in Italy

The 2017 Italian Budget Law introduces a tax relief for individuals transferring their tax residence to Italy, in accordance with similar regimes adopted by other countries such as the United Kingdom, Switzerland and Portugal. The relief is part of a package of measures intended to facilitate investment in Italy and… – Continue reading

Davos 2017: Oxfam attacks failing global tax avoidance battle

World Economic Forum debate hears how fight to make companies ‘pay their fair share’ is being undermined by race to cut corporation tax rates Efforts to tackle global tax avoidance are being undermined by a “race to the bottom” on corporate tax rates led by Britain and the US, the… – Continue reading

International tax-avoidance rules may override GAAR, other tax treaties

There is a possibility that the General Anti-Avoidance Rules (GAAR, on taxes) and the tax treaties signed by the government with those of Mauritius, Singapore and Cyprus, and even other nations such as Netherlands, could be overtaken by another event. These could, say experts, be partially or fully overridden by… – Continue reading

New tax regime for Ukrainian loan participation notes issued on international capital markets

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

German Multinationals Fear Disclosure of Global Tax Reports

Multinational companies headquartered in Germany worry that when they report their global tax and profits for 2016, some countries will leak their country-by-country reports to the press. German parents of multinational groups with annual consolidated group revenue of at least 750 million euros ($797 million) are required to file, with… – Continue reading

Panama Papers: India eyes tax information exchange deal by June

If the tax deal is not signed, India can opt to label Panama as ‘non-cooperative’ and levy a higher tax on it Mumbai: The government is continuing its efforts to retrieve money stashed away illegally in foreign banks, including those in Panama, even as it hunts black money evaders at… – Continue reading

Global crackdown on tax evasion signals the end of bank secrecy era

Unknown to many Kenyans, Parliament’s passing of Finance Bill, 2016 that granted amnesty to Kenyan residents who have offshore incomes and assets in foreign banks had a very global agenda. The foreign income that is subject to amnesty is for the year ended December 31, 2016 and offers a waiver… – Continue reading

U.S. tax reform plan “not likely” to badly impact Canada: Expert

WASHINGTON — An American tax authority who helped champion a reform now being considered by the U.S. Congress says Canada would not be among the countries hardest hit by the introduction of so-called border adjustments. Alan Auerbach is among the leading proponents of the push to restructure corporate taxes so… – Continue reading

Tackling aggressive tax planning

THERE was a time when a tax professional would confidently tell you that tax avoidance would not get you in trouble. You might be bending the rules a little to minimise your tax liability, but as long as you followed the letter of the law, you would be fine. On… – Continue reading

Austria: Ministry Of Finance Issues Guidance On The Alienation Of A Partnership Stake In A Trilateral Setting

On 29 October 2016, the Austrian Ministry of Finance provided interesting guidance on the tax consequences of an alienation of a participation in a Hungarian partner- ship by an Austrian partnership consisting of German partners. The case revolved around an operative Austrian partnership (GmbH & Co KG) with German resident… – Continue reading

New Double Tax Treaty signed between Montenegro and Portugal

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

Customs mulls amending GST Act to tax foreign online service suppliers

KUALA LUMPUR: The Royal Malaysian Customs Department is considering amendments to the Goods and Services Tax Act (GST Act) to start taxing foreign online service suppliers, said deputy director-general Datuk Subromaniam Tholasy. “E-commerce is pretty much catered for, except business-to-consumer (B2C) for example, downloads from overseas, how do we tax… – Continue reading

Inland Revenue audits Microsoft NZ over transfer pricing practices

Microsoft New Zealand is bracing for possible action from the taxman. The company said in its annual accounts that Inland Revenue was auditing payments charged to it by Microsoft companies overseas over the two years to June 2015. Microsoft NZ listed the Inland Revenue audit as a “contingent liability” for… – Continue reading

Israel and U.S. Begin Sharing Data in Crackdown on Tax Evasion

The Israel Tax Authority says Americans have provided information on 35,000 accounts held by Israelis in the U.S. and on an unspecified number of American accounts in Israel. The Israel Tax Authority said Monday it had begun passing on data on Israeli bank accounts held by American citizens and Green… – Continue reading

ATO warns energy giants over offshore profit hubs

The Australian Taxation Office has its sights on a $30 billion-a-year natural gas export bonanza expected over the next few years, warning oil and gas giants not to follow the lead of the big miners and “inappropriately shift profits” by selling through tax haven Singapore. At the same time, it… – Continue reading

Plans for Australia to adopt a ‘Google tax’ welcomed by advocacy group

Coalition’s proposed diverted profits tax could capture billions in revenue from multinationals using profit-shifting practices, says Tax Justice Network One of the biggest critics of multinational tax avoidance has welcomed the Coalition’s proposed “Google tax”, saying a similar tax in the UK looks likely to increase corporate tax payments by… – Continue reading

Budget 2017: Tax Reform For Financial Services

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

Israel Tax Authority Deems Bitcoin a Taxable Asset

The Israeli Tax Authority has issued an official draft circular to clarify the tax guidelines that apply to bitcoin adopters. In an announcement last week, the Israel Tax Authority released its draft [PDF] on the proposed taxation of virtual currencies which are considered “assets”. Pointedly, the announcement also cites the… – Continue reading

India-Japan Agree New Advance Pricing Agreement

India has signed a bilateral advance pricing agreement with the Indian subsidiary of a Japanese company, India’s Central Board of Direct Taxes (CBDT) has announced. The APA was signed on January 13. With this, India and Japan have concluded three bilateral APAs, all of which include roll-back provisions. Overall, the… – Continue reading

Moving towards a simplified tax regime

As per the Economic Survey 2016, the ratio of Indian taxpayers to voters is 4%; ideally it should be roughly 23% at existing levels of economic and political development. The tax to GDP ratio at 16.6% is well below the emerging market economy norm of 21% and OECD average of 34%…. – Continue reading

Britain may become tax haven after hard Brexit, Hammond says

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

Netherlands ‘will block UK-EU deal without tax avoidance measures’

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

Russia Removes Hong Kong From List of Offshore Tax Zones

The Russian government will no longer consider Hong Kong a Chinese-affiliated tax haven that doesn’t share tax information. Russia will strike Hong Kong from its list of offshore jurisdictions following ratification of a double tax treaty signed by the two parties last January and ratified by Russia in July, according… – Continue reading

Australia Consults On Failure To Disclose Penalties For MNEs

The Australian Treasury is consulting on plans to increase administrative penalties for multinationals that fail to adhere to tax disclosure obligations. The new rules will apply to companies with global revenue of AUD1bn (USD749.7m) or more. From July 1, 2017, penalties relating to the lodgment of tax documents to the… – Continue reading

Expose the true beneficiaries

THE Panama Papers, the world’s biggest leak, highlighted the complex ways used by companies and individuals to conceal who the actual beneficiaries of a company are. Some of them put their money into offshore accounts such as in Labuan, which is also an off-shore financial centre and tax haven. One… – Continue reading

Special tax regime for Non-Habitual Portuguese Resident individuals

Portuguese income tax law provides for a 20% reduced rate and, in respect to income obtained abroad, a full tax exemption, for certain types of income derived by individuals having the status of Non-Habitual Portuguese Residents (NHPR). Any individual that in a certain year becomes tax resident in Portugal will… – Continue reading

The favourable tax regime of new Italian residents

The 2017 Budget Law introduced (starting from fiscal year 2017) favourable provisions for people wishing to become tax residents in Italy. It is aimed at wealthy individuals who wish to bring in new capital resources. The regime is inspired by the non-domiciled resident regime which is in force in the… – Continue reading

Cayman Islands: Cayman Islands AEOI Update – Second Tranche of CRS Regulations Released

The Cayman Islands Government issued the second tranche of the Common Reporting Standard (“CRS”) regulations at the end of December 2016. Updated Guidance Notes will be issued in Q1 2017 by the Cayman Islands Tax Information Authority (“TIA”) to assist with the implementation of the regulations. Furthermore, TIA stated in… – Continue reading

Malta denounced as tax haven as it assumes EU presidency

Malta was today (11 January) accused of being a tax haven as it took over the rotating presidency of the EU. Some companies in the EU’s smallest country pay as little as 5% tax on their profits. The small Mediterranean island would have been included in the list of tax… – Continue reading

India may leave tax treaty with Netherlands unchanged

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