Category: Activity

U.S. Citizens Retiring Abroad: “Tax Trigger” Situations and Related Disclosure Forms

The following is a bolded checklist of important situations that may “trigger” a tax review by a skilled United States tax professional. Many of these situations also require a simultaneous review by a foreign tax professional. It is generally best practice for these tax professionals to work together to minimize… – Continue reading

To really tackle corporate tax evasion we need a public register

The Australian government shouldn’t rely on leaks like that of the Panama Papers to pick up on tax evasion, it should consider stronger action. The federal government showed some leadership earlier this year by announcing the establishment of a public register of beneficial ownership of companies, with the aim of… – Continue reading

Pakistan’s taxation crisis

Whether they indulged in legal tax avoidance or evaded taxes under the counter, leaked documents of a Panamanian firm revealed quite a lot in April about a number of Pakistani politicians and businessmen. Tax evasion has of late become synonymous with Pakistan because of its failure to overcome its taxation… – Continue reading

Push for EU mandatory disclosure of tax avoidance schemes

Slovakia, the current president of the EU council, challenges finance ministers from all the EU member states to introduce mandatory disclosure rules for intermediaries including accountants who seek to profit from the promotion, design or implementation of tax avoidance schemes The proposals were outlined in a ‘presidency issues’ note presented… – Continue reading

Tax Havens Impact Canadians Too

Tax havens have become increasingly formidable players in the global economy. With increased globalization and financialization of the global economy, tax havens have become important players in the world economy. According to a report by Tax Justice Network, $21 to $32 trillion is stashed offshore. According to the World Bank, the GDP… – Continue reading

New Report Finds Corporate Offshore Tax Avoidance ‎a Growing Problem

According to a new report, secretive offshore tax avoidance practices are on the rise among multinational businesses. The report, released from the Financial Accountability and Corporate Transparency Coalition (FACT), finds that these practices put investors at risk because they are caught off guard when governments act to collect the lost… – Continue reading

Introduction of Stringent Transfer Pricing Documentation Requirement

A recent 2016 tax reform in Japan (“Reform”) has introduced stringent Japanese Transfer Pricing Documentation Requirements, which require the preparation/filing of: (i) a Master File, (ii) a Country-by-Country Report, and (iii) a Local File, as well as (iv) a “Notification of the Ultimate Parent Entity.” Any ultimate parent company (“Parent… – Continue reading

UK could lose billions by making wealthy non-doms pay more tax, experts claim

Current rules allow over 100,000 wealthy residents to pay a lower rate of tax, even if they have lived in UK for many years. The Government is risking more than £6bn of tax revenue by changing rules governing non-domiciled taxpayers, an international law firm has warned. Pinsent Masons said that… – Continue reading

India, Mauritius to discuss revival of FTA, two-way investments today

Top officials from India and Mauritius will meet in Port Louis this week to discuss revival of free trade agreement (FTA) negotiations that were suspended three years ago by New Delhi. The talks were suspended to build pressure on Mauritius to expedite the double taxation avoidance agreement. Deliberations on two-way… – Continue reading

Israel Joins OECD Tax Treaty

Israel has signed on as a member of the OECD’s international tax treaty, and as a result the Tax Authority will automatically receive information about bank accounts held by Israelis abroad. Israel, meanwhile, will automatically release information about foreign citizens who have bank accounts here to the governments of countries… – Continue reading

MSAR signs tax agreement with Ireland

The Special Administrative Region yesterday signed a Tax Information Exchange Agreement (TIEA) with Ireland, according to an announcement by the Financial Services Bureau. The agreement was inked by the Secretary for Economy and Finance, Lionel Leong Vai Tac and Ireland’s Ambassador to China, Paul Kavanagh. According to the Secretary, the… – Continue reading

Tax evasion challenge Pakistan, Switzerland moving towards greater cooperation

Pakistan and Switzerland would exchange information on tax evasion once the contracting state exhausts all regular sources of information available under the internal taxation procedure. On August 31, 2016, the Federal Cabinet approved initialed draft for revision of the Convention between Pakistan and Swiss Confederation for the avoidance of double… – Continue reading

EU countries eye potential share of Apple windfall

Potential slice of the Apple pie stems from Commission’s invitation to EU tax authorities. BRATISLAVA — The €13 billion clawback of unpaid taxes from U.S. tech giant Apple has piqued the interests of EU finance ministers, who have today asked the European Commission for more details on the potential share… – Continue reading

Government, Opposition to meet on FACTA legislation

PORT OF SPAIN, Trinidad, Sept 10, CMC – Government and opposition legislators are to meet here on Monday as the deadline for meeting the September 30 deadline for passing the Foreign Account Tax Compliance ACT (FATCA). Caribbean financial executives have in the past bemoaned what they deem as an uneven… – Continue reading

UK bill to open details on multinational tax avoidance

A legislative amendment in the UK this week will give the British government the power to publish details of tax payments made by UK-based multinational corporations on a country by country basis, as tax authorities try to clamp down on the abuse of tax laws and aggressive tax avoidance. The… – Continue reading

Foreign portfolio investors approach government to iron out Singapore Treaty, GAAR issues

MUMBAI: Foreign portfolio investors (FPIs) are lobbying the government to resolve problems related to the India-Singapore tax treaty and general anti-avoidance rules (GAAR), worried about their investment in equities. FPIs fear after April 1, 2017, when both the renegotiated India-Singapore treaty and GAAR come into force, they will face challenges…. – Continue reading

President supports implementation of automatic exchange of financial information

President Joko Widodo remarked that Indonesia supports the implementation of automatic exchange of financial information in tax matters between countries. This, he said, would lead to enhanced income for the developing countries. “Indonesia encourages an international tax system that is fair and transparent,” President Joko Widodo said in his speech… – Continue reading

Bahamas Committed to CRS Using a Bilateral Approach

The Common Reporting Standard (CRS) for the Automatic Exchange of Information (AEOI) is the priority initiative for The Bahamas Government in its global regulatory tax compliance regime. The Bahamas committed to the Organization for Economic Cooperation and Development (OECD) CRS for the automatic exchange of Information in 2018. The optional… – Continue reading

Obama warns G20 of risk of tax ‘race to the bottom’

The G20 summit in China has stressed the need for international tax cooperation to achieve ‘a globally fair and modern international tax system’, after US President Obama warned of the risks if countries ‘race to the bottom’ in tax policies At a press conference at the conclusion of the summit,… – Continue reading

EU finance ministers to discuss how to make tax policy more evenhanded

European Union countries should better coordinate tax rules to avoid hitting corporations too hard, the Slovak presidency of the European Union has proposed. This would be an effort to provide more balance to an EU campaign against tax avoidance by multinational companies. The proposal will be discussed at an informal… – Continue reading

Worldwide Disclosure Facility for offshore tax evasion launched

A NEW online disclosure facility has launched today giving offshore evaders a last chance to settle tax on their wealth hidden offshore ahead of new data sharing arrangements and tougher penalties being introduced. The Worldwide Disclosure Facility (WDF) is the final chance for those few still dragging their feet to… – Continue reading

UAE companies to benefit from transfer pricing as profit-shifting plan comes into force

The international tax landscape has been changing rapidly and the Organisation for Economic Co-operation and Development (OECD) has agreed on a base erosion and profit shifting (Beps) action plan that could affect businesses operating in the UAE. The plan addresses the issue of artificial shifting of profits and its proposals… – Continue reading

Businesses Fear Breakdown In BEPS Consensus

The International Chamber of Commerce (ICC) has expressed concern about the possible broader implications of the European Commission’s (EC’s) ruling against Apple. In a statement published on September 1, the ICC warned that unprecedented rulings of this nature fall outside the scope of the recommendations of the OECD’s base erosion… – Continue reading

Israeli government enjoined from disclosing personal account information to the IRS

One disadvantage of United States citizenship is that all income from whatever source, worldwide, is subject to taxation. This is true regardless of how one obtains American citizenship; indeed, there are many “accidental Americans” who, by dint of having been born to a person with American citizenship, are technically American… – Continue reading

Luxembourg may be focus of another Brussels tax inquiry

After state aid inquiries into Amazon and McDonald’s, EU looks again at Luxembourg The European Commission may open a fresh investigation into tax rulings offered by Luxembourg as early as this week, as EU competition commissioner Margrethe Vestager continues her clampdown against corporate tax avoidance. Luxembourg is already awaiting a… – Continue reading

PM to push for G20 tax evasion crackdown

Malcolm Turnbull will push for a crackdown on multinational tax avoidance when he meets with world leaders at the G20 summit in China. But Labor have accused Mr Turnbull of not having a strong plan for confronting corporate tax avoidance at home, let alone abroad. The prime minister will arrive… – Continue reading

India, Vietnam sign protocol on double taxation avoidance agreement

India and Vietnam on Saturday inked a dozen of agreements, including protocol on double taxation avoidance agreement, to foster better ties between the two sides. India and Vietnam on Saturday inked a dozen of agreements, including protocol on double taxation avoidance agreement, to foster better ties between the two sides…. – Continue reading

Tax Agreements: From Double Taxation To Double Evasion

The issue of tax havens is inherently international in scope. As a result, the government can use tax agreements to fight tax avoidance schemes. Unfortunately, tax agreements haven’t been used for that purpose. On the contrary, they have facilitated the outflow of Canadian money to offshore financial centres, and have… – Continue reading

Ghana loses US$2.1 billion to tax evasion annually

Ghana loses nearly $2.1 billion dollars to tax evasion and incentives annually, reveals a study carried out by the Integrated Social Development Centre (ISODEC), a civil society organisation. According to the study, which was conducted on behalf of the National Coordinating Council of the Public Services International (PSI), there was… – Continue reading

No reason for govt to delay reform on multinational tax avoidance, say Greens

The Government is being blasted as weak, for not taking action on companies dodging tax. Apple has been slapped with a $20 billion tax bill in Ireland, which has led to questions about whether tax avoidance is also happening in New Zealand. Prime Minister John Key said we could face… – Continue reading

Relief for banks, as FinMin relaxes ‘FATCA’ compliance norm

Banks and financial institutions in India have got some breather as regards compliance under the US-enacted Foreign Account Tax Compliance Act (FATCA). The Finance Ministry on Wednesday said that banks and financial institutions need not enforce “closure” of accounts by August 31, 2016 in respect of those cases where “self-certification”… – Continue reading

Ashgabat, Berlin sign tax agreement

Turkmenistan and Germany signed an agreement on avoidance of double taxation with respect to income and property taxes in Berlin, the Turkmen Dovlet Habarlary(TDH) state news agency reported. According to the message, the signing ceremony took place as part of the two-day working visit of Turkmen President Gurbanguly Berdimuhamedov to… – Continue reading

Guilty by association

All involved in tax avoidance schemes will be penalised HMRC has recently published a consultation document, ‘Strengthening Tax Avoidance Sanctions and Deterrents: A discussion document’ which proposes sanctions aimed at everyone involved in the birth of tax avoidance schemes which are defeated by HMRC. This follows the government’s announcement at… – Continue reading

Tax reform as new human rights agenda

Today, we see more enthusiasm for tax reform in Indonesia. Although opposed by some civil society groups, President Joko “Jokowi” Widodo’s administration continues to push its fiscal framework reform — which includes a tax amnesty and more incentives for taxpayers. Last year, the Finance Ministry issued a new tax holiday… – Continue reading

Silicon Valley Issues Netherlands With Tax Warning

A coalition of Silicon Valley tech companies has urged the Dutch Government against making changes to the most “attractive” features of its corporate tax regime, warning that it risks damaging its traditionally strong tax competitiveness by doing so. The Silicon Valley Tax Directors Group (SVTDG), which includes more than 80… – Continue reading

Treaty issues on permanent establishments

Recent developments in the global business environment which are characterized by intense competition and rapid growth of multinational enterprises have led to new business models and structuring of business operations in order to meet the increasing demands of expansion on a global scale. Agency arrangements, as a way for enterprises… – Continue reading

CBDT signs 20 Unilateral Advance Pricing Agreements with Indian taxpayers

The Central Board of Direct Taxes (CBDT) entered into twenty (20) Unilateral Advance Pricing Agreements (APAs) with Indian taxpayers. Many of these agreements also have a “Rollback” provision in them, Ministry of Finance said. The 20 APAs signed in these two days pertain to various sectors of the economy like… – Continue reading

Govt to disclose details of disputes under mutual agreement procedures

Disclosures under the MAP are aimed at improving dispute resolution mechanism and are part of global initiative on base erosion and profit shifting. India will soon disclose the number of disputes being negotiated under the mutual agreement procedures (MAP) of tax treaties as well as details of the time being… – Continue reading

Ireland risks being trampled in US/EU corporate tax fight

For the last three years, the international debate on tax policy was all about consensus. Led by the Organisation for Economic Co-operation and Development, countries across the globe agreed that aggressive tax planning by multinational corporations which pushed profits into low-tax countries – or indeed took profits outside the charge… – Continue reading

Bank secrecy rules face ‘lethal blow’ in Uruguay

Gov’t sends bill to Congress to force banks to share account data automatically Described by government officials as a “lethal blow” to bank secrecy, Uruguay has sent a bill to Congress that will force banks to automatically provide the DGI tax bureau information on the accounts held by individuals and… – Continue reading

By singling out Apple over taxes, Brussels is abusing its own rules

Under EU rules it is illegal for countries to give financial help to some companies and not others in a way that distorts fair competition, writes Liza Lovdahl Gormsen. State aid rules were originally designed to protect the internal EU market and avoid retaliation among member states. The US Treasury,… – Continue reading

Corporations paid no tax at Rio Olympics

Coca-Cola, McDonald’s, Visa and the rest of the corporate sponsors of the August 5–21 Olympic Games in Rio de Janeiro won’t be paying any taxes on the money they earn due to a tax exemption law that is set to cost Brazil hundreds of millions of dollars. The exemption, which… – Continue reading

EU tax probes could threaten international agreements, US warns

The US has warned the EU that it risks damaging international agreements on tax reform if it continues to act as a “supra-national tax authority”. The US Treasury Department “shares the European Commission’s concern with tax avoidance by multinational firms. The international community, including the EU and its member states,… – Continue reading

Dublin and Washington enter talks to update Double Taxation treaty

Talks have begun between the US and Irish governments about updating certain elements of the Double Tax treaty between the two countries. The existing treaty was signed in 1997 and a Protocol to the treaty was signed in 1999. The Department of Finance and the Revenue Commissioners are calling for… – Continue reading

Singapore-Africa trade relations set to deepen with new agreements

Trade relations between Singapore and Africa are set to deepen, with several agreements signed on Wednesday (Aug 24) at the fourth edition of the Africa Singapore Business Forum. These include the signing of the Avoidance of Double Taxation (DTA) with Ethiopia, a bilateral investment treaty (BIT) with Mozambique and an… – Continue reading

Why Indonesia’s domestic tax haven is a bad idea

In the latest move to revamp the tax system in Indonesia, the government is considering setting up tax haven areas to entice home money that was stashed abroad. The idea was initiated by former finance minister Bambang Brodjonegoro who believed that the distinct region could facilitate the investment of funds… – Continue reading

HMRC takes aim at tax dodgers hiding foreign income

The taxman plans to crack down on people who hide earnings from offshore investments, with greater powers to impose tougher penalties. People who do not reveal income from foreign accounts and investments to HM Revenue & Customs (HMRC) could be hit with penalties of three times the amount of tax… – Continue reading

Cabinet approves signing of revised DTAA with Cyprus

The Union Cabinet on Wednesday gave its nod for signing of revised double taxation avoidance agreement (DTAA) with Cyprus, a popular tax haven. It is also learnt to have approved the removal of island nation as a non-cooperative jurisdiction for income-tax purpose. Cyprus was the only country to have been… – Continue reading