The European Union ordered Belgium to recover about 700 million euros ($762 million) in illegal tax breaks given to at least 35 companies, including Anheuser-Busch InBev NVand BP Plc, as regulators continued a crackdown on overly generous tax schemes throughout the 28-nation bloc. The European Commission told Belgium to recoup… – Continue reading
On January 8, 2016 the UK HM Revenue & Customs issued a media release announcing that on December 15, 2015 the Convention between the United Kingdom of Great Britain and Northern Ireland and the Republic of Bulgaria for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with… – Continue reading
THE COMMERCE Ministry’s Business Development Department will this year expand its investigation into the use of Thai nationals as nominees for foreign-controlled companies in nine provinces where it suspects the illegal practice is widespread. This year, three additional provinces will be monitored – Krabi, Trat (Koh Chang), and Chiang Rai…. – Continue reading
Action Plan 6 of the Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) final reports identifies treaty abuse, particularly treaty shopping, as one of the most significant causes of BEPS. It recognizes that existing domestic and international tax rules, including double taxation treaties, should be… – Continue reading
On January 8, 2016 the UK HM Revenue & Customs issued a media release announcing that on November 19, 2015 the Agreement between the United Kingdom of Great Britain and Northern Ireland and the Republic of Croatia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with… – Continue reading
The SNP has been advised to rethink its support for a currency union in any further bids to present a case for Scottish independence. Picture: John Devlin THE man credited as being the author of Labour leader Jeremy Corbyn’s economic policy is to deliver a series of pre-election briefings to… – Continue reading
If the place of effective management of a foreign company is established in India, then it becomes tax resident as per domestic laws The Finance Act, 2015, amended the provisions of the provisions of income tax act relating to determination of residence of a company. According to the amended provisions,… – Continue reading
On January 8, 2016 the UK HM Revenue & Customs issued a media release announcing that on December 16, 2015 the Convention between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Republic of Kosovo for the Avoidance of Double Taxation and… – Continue reading
ISLAMABAD: Pakistan’s hopes to seek information from Switzerland about the presumed $200 billion stashed in Swiss banks have apparently been ruined by tax authorities who mishandled delicate negotiations for amending a convention on avoidance of double taxation. A Pakistani delegation that visited Switzerland in August 2014 to renegotiate the 2005 treaty… – Continue reading
The Government of the Bahamas has recalled that 2015 brought significant challenges for the territory in the area of tax, with the implementation of a VAT regime, adoption of FATCA legislation, and the expansion of duty free concessions to cover the whole of Grand Bahama. The Bahamas Government recently released… – Continue reading
The Irish Revenue has published a statement announcing that on December 23, 2015 the Convention between Ireland and the Republic of Zambia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital Gains (Hereafter: the new DTA) as concluded on… – Continue reading
The international community led by the G20 initiated the Base Erosion and Profit Shifting (BEPS) project a few years ago with the aim of ensuring that profits are taxed where economic activities are performed and where value is created, the Business Standard reports. Governments, tax authorities and social groups have… – Continue reading
Thai consumer goods group TCC Holding Co. Ltd has completed its acquisition of the Vietnamese operations of Metro for 655 million euros (US$704.1 million). TCC’s subsidiary TCC Land International Pte. Ltd. takes over Metro’s 19 stores and related real estate portfolio in Vietnam, the German company said in a press… – Continue reading
The first stage of an un-precedented worldwide crackdown on tax evasion and banking secrecy has got under way, with Irish banks this week starting to collect details of non-resident bank account holders. The collection of information follows on from the agreements brokered by the Organisation for Economic Co-operation and Development… – Continue reading
January 2016 You will find below a summary of some of the most important tax developments that have happened since the release of our last newsletter, at OECD, EU or country level, in the area of tax transparency and the fight against tax avoidance. EU – Tax transparency and anti-BEPS… – Continue reading
Hong Kong (HKSAR) – The Inland Revenue (Amendment) Bill 2016 was gazetted today (January 8). “The Bill seeks to put in place a legal framework for Hong Kong to implement the new international standard for automatic exchange of financial account information in tax matters (AEOI) as promulgated by the Organisation… – Continue reading
Luanda – Throughout the year just ended, as in the previous, the country’s economy “found himself grappling” with a major setback if they can be considered, due to the continued drop in oil prices, which is in the house $ 37 a barrel, far from the historic $ 122 value,… – Continue reading
On 13 November 2015 the Treasurer and Minister of Finance jointly announced that a new double tax treaty had been negotiated with Germany, replacing the 1972 agreement. The new treaty has not yet been formally adopted as part of Australian law, as a change to the International Tax Agreements Act… – Continue reading
With all due respect, the OECD’s BEPS project was a fiasco, accomplishing little of any positive value and opening up a Pandora’s box with its focus on “value creation” in the context of transfer pricing. Despite all the “happy talk” coming out of the OECD and all the talk of… – Continue reading
New Delhi: Mutual Fund houses will have to mandatorily provide compliance details for the new global tax avoidance law FATCA with regard to each client on the stock exchange’s mutual fund trading platform. In a circular, BSE said for each and every transaction mutual fund houses have been asked “to… – Continue reading
We conduct transfer pricing reviews as part of broader risk reviews of businesses under our compliance program. Documenting your transfer pricing: > is important for demonstrating your compliance with Australia’s transfer pricing rules > can be costly, particularly for smaller businesses. We have developed some simplified transfer pricing record keeping… – Continue reading
Several Slovak banks are already preparing for the new obligations arising from the agreement FATCA (Foreign Account Tax Compliance Act). Because it had to make changes in particular in its information systems. “Following the agreement FATCA UniCredit Group has developed separate software for the purpose of fulfilling the obligations under… – Continue reading
Jersey and Guernsey will no longer appear on Italy’s tax blacklist, after the Italian parliament revised provisions in the country’s tax code relating to blacklists on corporate taxation and controlled foreign companies (CFC) rules. Blacklist The Stability Law for 2016 abolished blacklists on the deductibility of costs and CRCs as… – Continue reading
Thousands of entrepreneurs are expected to liquidate their companies over the next three months amid fears that an imminent tightening of the tax rules will more than triple their bills, reports the Financial Times. Advisers said many small company owners were drawing up plans to lock in tax rates as… – Continue reading
Dutch holding companies have been again included on the Brazilian government’s list of “privileged tax regimes.” Accordingly, this action has implications for purposes of the transfer pricing, thin capitalization, and tax deductibility rules. Background Under Brazilian tax law, the concept of “privileged tax regimes” is relevant for determining: Whether Brazil’s… – Continue reading
Jamaica has released information explaining its new transfer pricing regime, with transfer pricing documentation due on March 15, 2016. According to the Government, 2015 amendments to the Income Tax Act were intended to remove any subjectivity in the administration of transfer pricing rules. The Government said: “Taxpayers have always had… – Continue reading
SOUTH African Revenue Service (SARS) commissioner Tom Moyane has been instructed by Finance Minister Pravin Gordhan to halt the implementation of his ambitious restructuring plans. The far-reaching restructuring project for the tax authority was one of the first initiatives undertaken by Mr Moyane following his appointment as commissioner in October… – Continue reading
On 1 January 2016, the Common Reporting Standard (CRS) became effective. The CRS is a new, single global standard on automatic exchange of information. It replaces the EU Taxation on Savings Directive and is essentially a global form of FATCA-like reporting. Under the CRS, Irish funds are now required to… – Continue reading
World Finance spoke to Thierry Afschrift, founder of Afschrift Law Firm and university professor, about how tax lawyers can respond to a changing European environment In keeping with much of Europe, Belgium’s tax system has been subject recently to a shift of important proportions, as policymakers there look to boost… – Continue reading
Adv. Amit Kriegel is suspected of abetting the super-model in evading taxes in Israel. Adv. Amit Kriegel, lawyer for global super-model Bar Refaeli and a former senior Israel Tax Authority official, was questioned under caution by the Tax Authority in the Bar Refaeli criminal investigation. Kriegel, a partner of former… – Continue reading
Despite popular campaign and committee recommendations, tax haven restrictions will not be included in bill AN OVERDUE land reform report from the Scottish Government has categorically refused to bring back a proposal which campaigners say would have tackled the phenomenon of Scottish land being owned in offshore tax havens. Dropped… – Continue reading
Mutual Fund houses will have to mandatorily provide compliance details for the new global tax avoidance law FATCA with regard to each client on the stock exchange’s mutual fund trading platform. In a circular, BSE said for each and every transaction mutual fund houses have been asked “to upload FATCA… – Continue reading
Interest paid by UK companies is generally subject to withholding tax at 20%. Although various exemptions apply, most notably in respect of interest payments to banks and other UK companies, and in respect of securities listed on a recognised stock exchange (so called “quoted eurobonds”), such exemptions are often of… – Continue reading
The Argentine tax authorities (AFIP) posted an updated “white list” of countries, jurisdictions, and territories—that is, a list of countries and jurisdictions that are identified as cooperative for tax transparency purposes. A broader application of Argentina’s transfer pricing rules will not apply to transactions involving entities located in the countries… – Continue reading
The number of legacy bank tax avoidance schemes under investigation by UK tax authority HM Revenue and Customs (HMRC) has fallen since the strengthening of Code of Practice on Taxation for Banks, a new departmental report has shown. The Code of Practice on Taxation for Banks was introduced in 2009… – Continue reading
Now that the final report on BEPS Action 7 has been released, “Preventing the Artificial Avoidance of Permanent Establishment Status” (Final Report), taxpayers are able to consider the final language to be incorporated into Article 5(5) of the OECD Model Tax Convention.1 This language also will be incorporated into the… – Continue reading
On December 18, 2015, the President signed the Omnibus Appropriations Act (the “Act”) into law.1 Notably, the Act contains a number of substantive changes to the tax laws applicable to “real estate investment trusts” (“REITs”). Although several changes will adversely affect certain REITs, on balance REITs and their investors fared… – Continue reading
On October 5, the OECD issued it formal recommendations on the Base Erosion and Profit Shifting (BEPS) Action Plan. These recommendations have been subsequently adopted by the G20. We acknowledge the monumental effort that has been put forth to produce a modernized international system of tax rules through the BEPS… – Continue reading
Twelfth night has come and gone, the Chistmas lights are out but John Lewis has reported a set of sales figures that sparkled. The department store believes it has outperformed its rivals, once again, online in particular. And yet it’s managing director told me the fight with one rival –… – Continue reading
Legislation amending the rules governing transfer pricing documentation—to include country-by-country reporting, as well as master file and local file provisions—has been enacted and has an effective date of 1 January 2016. The Dutch Upper House (Eerste Kamer) on 22 December 2015 passed the legislation (the bill is referred to in… – Continue reading
The Norwegian Ministry of Finance published a public consultation paper regarding country-by country reporting for tax purposes. The proposal suggests that multinational groups—when the ultimate parent company is a resident in Norway—would be required to submit country-by country reports. The reporting requirements could also affect foreign group entities that are… – Continue reading
The Chinese yuan plunged to a five-year low in offshore trading and the gap between it and its mainland counterpart widened sharply on Wednesday, reflecting growing expectations of further weakness in the currency amid an economic slowdown and a slump in stock markets. The offshore yuan fell to 6.6915 against… – Continue reading
A judgment in the Contira case was handed down two weeks ago in the district court which dramatically changes the Cost Plus issues relevant to certain Israeli companies which provide services to a foreign related company. The judgment impacts on the situation where the Israeli company’s employees are granted options… – Continue reading
The Treasury Department and the Internal Revenue Service have proposed regulations setting out a new requirement for certain U.S. persons that are the ultimate parent of a multinational group (a “U.S. MNE group”) having annual revenue of at least $850 million to file an annual report (the “CbC report”). The… – Continue reading
(Reuters) – Texas tycoon Sam Wyly is set to face off against the Internal Revenue Service at trial on Wednesday over more than $2 billion the agency says he owes for using offshore trusts to engage in one of the largest tax frauds in U.S. history. The trial in federal… – Continue reading
Changes to patent box rukes will mean that businesses must now track and trace all of their research and development (R&D) expenditure AFTER the recent government consultation on the UK’s Patent Box scheme, businesses will find it a challenge to comply with the proposed new rules. The changes will mean… – Continue reading
Rules requiring master file and local file reporting—“full” transfer pricing reporting—are advancing in Korea. 5 January 2016 Korea’s parliament on 2 December 2015 approved legislation (released as draft legislation by the Ministry of Strategy and Finance of Korea in August 2015) to implement the OECD’s base erosion and profit shifting… – Continue reading
Spokesman for B.C. finance minister downplays tax loophole issue A new petition urging B.C. politicians to limit offshore investment and exploitation of tax loopholes in Vancouver real estate is getting a cool reception from Victoria as provincial coffers overflow with property transfer tax revenues in a red-hot housing market. The… – Continue reading
(Special) – Winter brings with it the dream of many Canadian snowbirds of owning a piece of property in the sunny south. With the recent rebound in the U.S. housing market and a decline in the value of the Canadian dollar, however, buying vacation property south of the border may… – Continue reading
Doing business in Poland in 2016? Stay on top of changes to transfer pricing and the potential for tighter local tax regulations. Over the past 12 months we have seen improvements in business-related procedures for tax payers in Poland. Setting up a new company is easier and more efficient, and… – Continue reading
