Right to levy capital gains tax by India is also part discussions, he said India is engaged in “positive talks” with Mauritius on revision of bilateral tax treaty as some issues still need to be sorted out, an official said today. “Negotiations have been going on. Talks with Mauritius have… – Continue reading
Congress tightens the tax abuse of Americans who live and work abroad Doubling down on Americans living and working abroad is a way for the Internal Revenue Service to squeeze the turnip a little harder in pursuit of a little more blood. The Obama administration, which has never met a… – Continue reading
Holiday home owners and others who inadvertantly break new tax rules could be ‘criminalised’ Holiday home owners who miscalculate tax owed, and those inheriting offshore money, face having their income wiped out entirely due to new penalties and punishments being introduced in the New Year. HM Revenue & Customs has… – Continue reading
“Luxembourg is famous for two things: its steel industry and its rose cultivation industry”. This quote from an Italian guidebook of the 1930s was uttered by Luxembourg’s Finance Minister Pierre Gramegna at the annual conference of the Luxembourg Directors’ Association on 17 June 2015[1]. The economic outlook of the tiny… – Continue reading
Mauritius plans to launch a trading platform to hedge African currencies against the US dollar, part of a bid to expand its role as a financial hub for the continent, the financial services minister said. The Indian Ocean island is also in talks to boost ties with stock exchanges in… – Continue reading
KUWAIT CITY, Nov 29: “The world of taxation has changed tremendously impacted by FATCA, transfer pricing, Base Erosion and Profit Sharing, and others which require dramatic changes in existing operating models and structures,” remarked Fouad Douglas, PwC Country Senior partner, at a tax seminar organised by the PwC in conjunction… – Continue reading
NEW DELHI: With a view to weed out commercial activities under the garb of charity, the tax department has said any general public service that involves trade, commerce or business for a consideration will not be treated as Charity under the Income Tax act. Issuing ‘Explanatory Notes to the Provisions… – Continue reading
The law, at present, is replete with a complex web of cross-references, often causing confusion The clamour for simplifying tax legislations gets louder as a new government, in its interaction with businesses and the civil society, holds out a promise of a non-adversarial tax regime. The reform of indirect taxes… – Continue reading
Tech titans powering the economy shelter money through insane tax-avoidance havens. It’s wrong — and adding up Offshore tax havens enable not only individuals to dodge taxes—they also enable multinational corporations to do so. Often this tax avoidance is done within the letter of the law: multinational groups exploit the… – Continue reading
The Dubai Gold and Commodities Exchange (DGCX) is slated to launch Chinese Yuan Futures, scheduled for the 18th of December 2015, subject to regulatory approvals. The new launch is part of DGCX’s efforts to make the Yuan accessible to regional and global participants as China prioritizes its internationalization and is… – Continue reading
The planned penalty for arrangements subject to the General Anti-Abuse Rule (GAAR) has now been formally set at 60% (in line with the amount proposed in consultation), and the anticipated introduction of rules addressing hybrid mismatch arrangements has been confirmed for 1 January 2017. Civil penalties for those who enable… – Continue reading
In response to the announcement that pharmaceutical firms Pfizer and Allergan would merge, Hillary Clinton released a statement that completely missed the real issue behind these inversions – they are a symptom of the greedy, complex, and inefficient U.S. tax code. “Inversion is a symptom, not a disease,” said Grover… – Continue reading
India’s Supreme Court has asked Vodafone to pay $302 million to the Indian government as part of its plans to merge four of its operating businesses ahead of a public listing in India. Vodafone is contesting charges of around $1.1 billion that the government is seeking to allow the merger… – Continue reading
The new provisions of the 4th Amendment to the France/Luxembourg double tax treaty on profits deriving from sale of real estate assets signed on September 5, 2014 will not be applicable in 2016. Currently, the right to tax the capital gains realized by a Luxembourg company upon the transfer of… – Continue reading
The Governments of the United Arab Emirates and Republic of South Africa have signed an agreement for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income and capital gains, and its annexed protocol. Inked by Hamad Hareb Al Habsi, UAE Ambassador to South… – Continue reading
HMRC introduces new measures to tackle tax avoidance The Chancellor has introduced a new penalty equal to 60% of tax due for all cases successfully tackled by the General Anti-Abuse Rule (GAAR). The GAAR was introduced in 2013 as part of the government’s attempt to crack down on tax abuse…. – Continue reading
Earlier we already reported that Malta and Curaçao had signed a DTA. When we wrote our earlier article we had not yet been able to locate the text of the DTA. Now however, the English version of the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal… – Continue reading
The English version of the Convention for the Avoidance of Double Taxation with respect to Taxes on Income and the Prevention of Fiscal Evasion as concluded on August 24, 2015 between the Government of the Italian Republic and the Government of Barbados (Hereafter: the DTA) has been made available on… – Continue reading
SINGAPORE-listed Sinarmas Land is looking to unlock the value of its investment properties in Indonesia by spinning them into a real estate investment trust (Reit) but has not decided on whether to list in Singapore or Jakarta, with tax benefits on offer likely to be a key determinant. “The unlocking… – Continue reading
A pending Protocol, that would amend the income tax treaty between Luxembourg and France, may not be effective until 2017. RATIFICATION PENDING The Luxembourg Parliament passed a bill to ratify the fourth Protocol to the income tax treaty (1958) between Luxembourg and France. However, it currently appears that the ratification… – Continue reading
The Chancellor could target capital gains tax for extra revenue when he delivers his Autumn Statement next week as gains from investors and landlords hit their highest on record in the past financial year, accountants suggest. George Osborne, who will unveil his spending plans for Britain next Wednesday, is under… – Continue reading
Introduction Withholding obligation Proposed amendment Comment Introduction The 2015 Taxation Laws Amendment Bill proposes an amendment to Section 35A of the Income Tax Act (58/1962), dealing with withholding percentages from payments due to non-resident sellers of immovable property situated in South Africa. The proposed amendment raises interesting questions regarding compliance… – Continue reading
Introduction Tax exemptions Eligibility Trademarks Calculating tax benefits Eligible costs Introduction At the end of 2014, the government presented the 2015 budget, which introduced a ‘Patent Box’ tax regime in line with similar schemes adopted in other European countries. It applies to corporate income tax and regional tax on productive… – Continue reading
Introduction Facts Decision Introduction The European Court of Justice (ECJ) recently ruled that the system of interim taxation for Austrian private foundations does not comply with EU law.(1) A special feature of private foundations is the so-called ‘interim tax’ – a type of corporate income tax. Pursuant to Section 13(3)… – Continue reading
NEW DELHI: Concerned over the misuse of double taxation treaty with Mauritius by certain entities, the government is working on measures to check such practices, a Finance Ministry official said today. The government is in the process of revising the Double Taxation Avoidance Agreement (DTAA) with Mauritius. Tax treaty amendments,… – Continue reading
Plans that would effectively end the UK’s non-domicile status for tax purposes have the potential to do more harm than good and could be contrary to EU law, according to the Institute of Chartered Accountants. The changes, announced by chancellor George Osborne in the 2015 summer budget, mean that non-UK… – Continue reading
If statistics are anything to go by, today India is the world’s fastest growing economy at 7.3% in 2015, outstripping the global average of 3.1%. With a new government in the centre, we do seem to be riding high on the growth trajectory. The Modi government has certainly done its… – Continue reading
Perhaps in theory there are ways to fix tax avoidance, but they aren’t politically feasible. Libertarian anarchists used to say “taxation is theft.” New research by economist Gabriel Zucman suggests that there is some truth to this—when tax havens are taken into consideration. In his new book The Hidden Wealth… – Continue reading
One of the amendments proposed in the Taxation Laws Amendment Bill (TLAB), relates to the revision of the definition of “immovable property.” This definition is significant when considering the potential tax liability of non-resident persons, especially when it comes to capital gains tax (CGT). Paragraph 2 of the Eighth Schedule… – Continue reading
On October 6, 2015 Poland and Sri Lanka concluded a new Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (Hereafter: the DTA). When entering into force this new DTA will replace the existing Double Taxation Agreement (stemming from 1980)… – Continue reading
As a reminder, the international automatic exchange of financial account information is considered by most countries as particularly efficient in the fight against tax evasion and international tax fraud and is becoming the new global standard (considering the US FATCA legislation, the OECD Common Reporting Standard). The Belgian Council of… – Continue reading
Gaborone — Clients of Standard Chartered Bank Botswana should brace themselves for exciting times with the launch of the offshore fixed income proposition under its wealth management portfolio. Speaking at a breakfast launch with clients and media, the head of wealth management for Botswana and Southern Africa at Standard Chartered… – Continue reading
The requirement for capital gains tax to be paid on investment properties bought and sold within two years has passed into law. The so-called ‘Bright-Line’ test for residential land was announced by the Government as part of May’s Budget to try to dampen property speculation and better enforce already existing… – Continue reading
Introduction On September 30 2015 Her Majesty’s Treasury published its long-awaited consultation on two of three proposed changes to the taxation of individuals domiciled outside the United Kingdom. The three measures – announced by Chancellor George Osborne in the 2015 Summer Budget published on July 8 – are intended to… – Continue reading
The New Zealand foreign trust regime – its use in international wealth planning The New Zealand “foreign trust” regime came into being over 25 years ago. It arose from a domestic initiative to make the use of offshore trusts for tax minimisation more difficult for New Zealand residents, by imposing… – Continue reading
Exclusive PM underlines fairness test for GST ‘The fact of the matter is that any changes to the tax system will be fair’ says Prime Minister Malcolm Turnbull in question time on Monday. Australia’s peak union body is preparing for a major political fight with the Turnbull government over tax… – Continue reading
HM Revenue & Customs (HMRC) has launched a new crackdown on tax avoidance with 10 tips on how to stay on the right side of the law. The warning follows recent revelations of 1,500 investors, including celebrities and sports stars, who are being pursued for £200 million for staking cash… – Continue reading
Leave.EU, supported by Ukip and financed by a multimillionaire, vies to lead Britain’s exit from Europe A leading campaign group seeking to take Britain out of the European Union was set up by an offshore company that offers tax avoidance services to “high net worth individuals”, the Observer can reveal…. – Continue reading
Abolishing the UK’s deed of variation legislation as a means of tackling tax avoidance could risk causing distress to bereaved families, warned the Association of Taxation Technicians. A deed of variation gives beneficiaries of an estate a two-year window to alter the distribution of that estate following the death of… – Continue reading
In Canada, taxes are levied at the federal, provincial and municipal levels of government. At the federal level, the government generates most of its revenue by way of income taxes and excise taxes imposed on the distribution and consumption of goods and services in Canada. The provinces and territories also… – Continue reading
Tax authorities in the German state of North Rhine-Westphalia have purchased a USB stick reported to hold evidence of tax avoidance and illegal deals worth more than €600m (£427m). Investigators are believed to have paid more than €5m for the data, the highest amount handed over for such information, according… – Continue reading
The government has been accused of opening a loophole that allows super rich individuals and multinational companies to avoid taxes. The Tax Justice Network (TJN), a lobby group, has sued the government over agreements, which it says are robbing Kenya of the ability to raise revenues domestically, driving the country… – Continue reading
Buying a property overseas is an exciting venture, but also one that requires careful financial consideration. To help ease the process, Chris White, Founding Director of boutique estate agency Ideal Homes Portugal, has compiled his top tax tips for buying property in Portugal. Portugal has been called ‘Europe’s best kept… – Continue reading
The Düsseldorf Finance Ministry has bought a new CD after mirror information – it is shown that an entire group of banksand financial service providers have deliberately harmed the German Treasury. The land of North Rhine-Westphalia for the so far most expensive record has spent five million euros. A few… – Continue reading
Vancouver real estate is a Mainland Chinese buyers’ market, study says Groundbreaking study shows 70 per cent of detached homes sold in a six-month period on Vancouver’s west side went to Mainland Chinese buyers; many of them housewives or students with little income. The dominant influence of Chinese investors in… – Continue reading
Suggest Easwar panel on Income Tax Act should also make safe harbour profit margins more realistic The justice R V Easwar committee on the Income Tax Act set up last week would do well to clarify whether payments for software should attract income tax or service tax, and make safe… – Continue reading
The justice R V Easwar committee on the Income Tax Act set up last week would do well to clarify whether payments for software should attract income tax or service tax, and make safe harbour profit margins more realistic, tax experts said. Tax demands based on ‘excessive’ advertising and promotional… – Continue reading
The most common error NRIs commit while filing tax returns is to use the status of residents in India. Non-resident Indians (NRIs) in the UAE enjoy the twin advantages of not having to pay tax in their country of domicile and most sources of income are exempted from tax in… – Continue reading
MUMBAI: Foreign portfolio investors (FPIs) are yet to exorcise the ghost of minimum alternate tax, or MAT. These offshore asset managers, based out of financial centres like Singapore, Hong Kong and New York, will now have to convince the Indian tax office that they do not have “place of business”… – Continue reading
South African Tax Legislation: Proposed Amendments in an International Tax Context[1] This article sets out a brief summary of some of the proposed amendments introduced by recent South African draft Tax Bills. The article focuses on amendments in the context of international taxation. The draft Taxation Laws Amendment Bill, 2015… – Continue reading
