MUMBAI: HSBC has been asking all “politically exposed persons” (PEP) having accounts with the bank to disclose their source of fund and income. The bank is also refraining from opening accounts of US-based non-resident Indians and persons of India origin in the wake of the Foreign Account Tax Compliance Act… – Continue reading
The Davis Tax Committee’s First Interim Report on Estate Duty (“DTC Report”) was released for public comment on 13 July 2015. In essence, the DTC Report proposes that “a highly progressive tax that patches loopholes, helps provide equality of opportunity and reduces the concentration of wealth, must be implemented”. The… – Continue reading
Two Canadian women begin their Federal Court case in Vancouver on Tuesday, seeking to have a judge declare that Canada’s cooperation in supplying financial information to U.S. tax collectors is unconstitutional. Gwen Deegan, 53, a Toronto graphic designer, and Ginny Hillis, 68, a retired lawyer living in Windsor, were both… – Continue reading
There is nothing in the Reliance Quant Plus Fund to attract an investor. The fund has consistently lagged its category and the benchmark Nifty in the past five years. Its past one year performance is ranked 141 out of 143 large-cap equity funds. Value Research has put it in the… – Continue reading
The Liechtenstein Disclosure Facility (LDF) has been with us for nearly six years. It now only has a limited shelf life as it is due come to an end at the end of 2015, which is earlier than was previously planned. The LDF allows those with undeclared income or gains… – Continue reading
Overpayments are often the result of errors on the part of the Government rather than criminal intent Last month the National Audit Office published a ‘stocktake’ of incorrect payments by Department for Work & Pensions and HM Revenue & Customs to those claiming state benefits, including working tax credits. It… – Continue reading
HC order had exempted Mauritius-based Copal Group from capital gains tax liability in India The income tax department has approached the Supreme Court seeking to quash a Delhi High Court order that exempted a series of transactions by Mauritius-based Copal Group — having assets in the US and in India… – Continue reading
MUMBAI: The Financial Services Commission (FSC) of Mauritius, which is the regulatory body for the Mauritian non-banking financial services sector, has introduced a new application form for obtaining a tax residency certificate (TRC). FSC verifies these applications and recommends issue of the Mauritius tax residency certificate by the Mauritius revenue… – Continue reading
First it was three years, now it’s three months. The Senate’s attempt to pass a multiyear highway bill ran off the road this week after House Republicans announced they will adjourn one day early for the month-long August recess. The House’s early departure forced the Senate to acquiesce to a… – Continue reading
John Goodchild explains the tax position of non-dom clients, and their families, after the Chancellor’s Summer Budget crackdown The Budget on 8 July announced a raft of provisions designed to increase the tax paid to the Exchequer by non-domiciled individuals (non-doms) and their families. Significant changes will be made to… – Continue reading
Donald Trump did not like the tax reform Ronald Reagan signed into law in 1986. In an op-ed in The Wall Street Journal, he called it “one of the worst ideas in recent history.” The reason for his dislike was that the reform put the kibosh on real estate tax… – Continue reading
Companies and govts have been playing the cat-and-mouse game for several decades on transfer pricing Only a naivete would think of Hilary Clinton’s proposal last week to scale up the rate of capital gains tax as a mere concept to streamline America’s tax rate structure. It is being perceived as… – Continue reading
Consultation on the ATO’s practical guide for offshore marketing hub arrangements is kicking off in August. The guide may also assist taxpayers with offshore intellectual property (IP) hubs. Here is what you need to know if you market Australian produced goods offshore or have centralised your IP offshore. Do you… – Continue reading
Just as every new government fiddles around with high school history text books, it also dabbles in Mauritius and P-notes. Both actions have a sharp, short-lived impact, leaving behind a trail of conspiracy theories. Mauritius and P-notes are ghosts that New Delhi and regulators could never quite exercise. They unfailingly… – Continue reading
There is a rising trend that many start-ups incorporate their ultimate holding companies abroad, especially in Singapore for various reasons with tax being one of the top 3 factors for such decisions. Some of them have restructured the holding structures after few months of direct Indian holding to accommodate requests… – Continue reading
There has been much recent focus on tax structures employed by multi-national corporations. This has led to an initiative, spearheaded by the OECD, to combat “base erosion and profit shifting”, or BEPS. The shipping industry is likely to be affected both directly and indirectly by the BEPS initiative – directly,… – Continue reading
Introduction The Cyprus Government has announced a number of proposed tax incentives aimed at encouraging economic activity and attracting inward direct investment. It has also submitted a number of draft laws to the House of Representatives to implement the new provisions of the EU Parent-Subsidiary Directive, to simplify the tax… – Continue reading
In the first 100% Conservative Budget in nearly two decades, chancellor George Osborne has introduced a raft of changes, including significant revisions to UK non-dom status. On 8 July, chancellor George Osborne delivered the first Conservative Government Budget for 19 years. Many headlines had already been flagged up in advance,… – Continue reading
TORONTO, CANADA — (Marketwired) — 07/29/15 — Canadian General Investments, Limited (“CGI” or “the Company”) (TSX:CGI)(TSX:CGI.PR.C)(TSX:CGI.PR.D)(LSE:CGI) has declared a quarterly dividend of $0.14 per share payable on September 15, 2015 to common shareholders of record at the close of business on August 31, 2015 (“the Dividend”). The Dividend is a… – Continue reading
This article deals with the manner in which Canada has complicated, and rendered controversial, what in most other countries is straightforward — the deductibility of business related interest expense. The reasons to write about it are threefold: the almost-concurrent issuance of the Canada Revenue Agency’s administrative views on the matter… – Continue reading
With the focus of 2014 being international tax competition, 2015 shows signs of continuing this trend. The European Commission (COM) and European Parliament (EP) are starting to debate and extensively investigate Member States’ tax ruling policies, partly as a result of the LuxLeaks revelations and partly in relation to the… – Continue reading
The Republic of Cyprus has once again kept its promise to international investors and introduced on the 9th of July 2015 amendments to its tax legislation making the jurisdiction as attractive as never before. The purpose of these amendments is to clearly establish Cyprus as the leading tax jurisdiction in… – Continue reading
NEWS DELHI: It has consistently lagged the large-cap equity fund category and the benchmark Nifty in the past five years. Its past one year performance is ranked 141 out of 143 large-cap equity funds. Mutual fund tracker Value Research has put it in the doghouse with a two-star rating. Yet,… – Continue reading
Black Money Act covers residents with undisclosed foreign assets and income and non-residents who have invested Indian-sourced income in offshore assets Compliance Scheme window open only till 30 September for declaring assets and until 31 December 2015 to pay tax at 30% and penalty at 30%. Revenue recommends disclosure of… – Continue reading
July 27: Japan’s Ministry of Finance announced the exchange of diplomatic notes concerning application of Article 7 (Business profits) under the new income tax treaty between Japan and the United Kingdom. Background Provisions of the amended Japan-UK income tax treaty (signed 17 December 2013) generally were effective 1 January 2015…. – Continue reading
A recommendation by the Davis Tax Committee to stop taxpayers from using trusts to reduce tax could result in people who have established trusts for tax purposes only reconsidering their viability. The trustees of a discretionary trust can cause the income and/or capital gains of the trust to be distributed… – Continue reading
Introduction US tax treaty policy can be affected by pressures for tax reform from within the United States and by major developments in international taxation from without. Talk of US tax reform has been widespread for years, although it is sometimes hard to gauge how much of the talk is… – Continue reading
Hedge fund manager Daniel Loeb was singled out for criticism by labor leaders who are urging the U.S. to limit investors’ ability to lower tax obligations through offshore reinsurance ventures. “When just one hedge fund takes advantage of this loophole, it means hundreds of millions of dollars are lost that… – Continue reading
ABU DHABI: President His Highness Sheikh Khalifa Bin Zayed Al Nahyan has issued a number of federal decrees with respect to ratifying agreements between the UAE and a number of friendly countries and transferring, appointing and promoting a group of diplomatic corps members. The decrees have been published in the… – Continue reading
On July 23, 2015 the Japanese Ministry of Finance issued a press release announcing that on July 22, 2015 the Government of Japan and the Government of the United Kingdom exchanged notes concerning Article 7 of the Convention between Japan and the United Kingdom of Great Britain and Northern Ireland… – Continue reading
July 22: Tax legislative changes in Austria were passed by the parliament, and the effective date for most changes is 1 January 2016. Among the provisions are the following items. Withholding tax on dividend distributions, capital gains The withholding tax rate for dividends and capital gains will be increased to… – Continue reading
Even before the government’s options paper on tax reform is released later this year, many reforms have been taken off the table, at least before the next election. Here’s the expert view on six. Broadening or increasing the GST Some experts say expanding the GST, which is a regressive tax,… – Continue reading
Most South Africans think the prospect of working and living in a foreign country is an exciting adventure. However, the ins and outs of your tax affairs can be enough to make one less adventurous. The first thing to establish is what your “tax residency status” is. This is easier… – Continue reading
New Zealand’s lack of overseas investment regulation is being promoted in Shanghai and Hong Kong to help sell apartments rising on the site of the country’s best-known record store. “NO stamp duties and property purchase tax, NO capital gains tax on residential property if sold after two years of holding,”… – Continue reading
HM Revenue and Customs (HMRC) has launched four consultations on the UK Government’s proposed new approach to tackling offshore tax evasion. Under the proposals, corporates who are deemed to have failed to prevent tax evasion or the facilitation of tax evasion would face a criminal offence. A separate strict liability… – Continue reading
India and Mauritius are set to limit the benefits of their double tax avoidance agreement (DTAA) to only genuine businesses bringing foreign direct investment to India by inserting a new clause in the treaty straight from New Delhi’s yet to be implemented General Anti-Avoidance Rules (GAAR). The revised treaty, however,… – Continue reading
Treasurer Joe Hockey has reaffirmed his commitment to addressing bracket creep in the upcoming tax review, but has refused to include changes to politically sensitive areas like superannuation concessions, negative gearing and GST, pushing back the onus on the states for GST reform. When it comes to the GST, Mr… – Continue reading
Industry body says hedge funds in Britain almost never use the carry system targeted by George Osborne in last week’s Budget, The Telegraph reports Hedge funds have claimed they were unfairly singled out in a Budget crackdown on the “carried interest” tax loophole, arguing that almost no British funds are… – Continue reading
Mauritius’ former finance minister claims that his country has given up the right to tax capital gains. This has raised questions regarding the scope of the renegotiation of the India-Mauritius Double Tax Avoidance Treaty (DTAA) Former finance minister of Mauritius says renegotiated tax treaty with India will have devastating effect… – Continue reading
HypoVereinsbank, the German arm of Italy’s UniCredit, is in talks with German prosecutors to pay a fine to put two tax probes behind it, two people familiar with the matter said. HypoVereinsbank and the Cologne prosecutors declined to comment on the development, which was first reported by German daily Sueddeutsche… – Continue reading
A seismic change in the international private wealth arena is under way. Over 90 jurisdictions have committed to automatically exchange comprehensive financial information on an annual basis under the OECD’s Common Reporting Standard (CRS). The CRS will start in 2016 in over 55 jurisdictions. This article comments on the CRS… – Continue reading
The Union Government on 12 July 2015 appointed international lawyer Rodrigo Oreamuno to arbitrate with the UK telecom major Vodafone in the 20000 crore rupees tax case on its behalf. Oreamuno replaces former Chief Justice of India RC Lahoti, who recused himself in May 2015. Vodafone already named Yves Fortier… – Continue reading
Over the past few months, several foreign portfolio investors registered in India have received notices from the Indian tax authorities demanding payment of Minimum Alternate Tax in respect of transactions which took place over the course of prior assessment years. The Indian Government has indicated that it could raise several… – Continue reading
Experts have warned of the impact of UK Chancellor George Osborne’s decision to abolish permanent non-dom status and tighten non-dom inheritance tax (IHT) rules. The Government will abolish permanent non-dom tax status, meaning that anyone resident in the UK for more than 15 of the past 20 years will have… – Continue reading
Finance Ministry has informed that the negotiations on the double taxation avoidance agreement (DTAA) between India and Mauritius are in advanced stage and the pact would be revised soon. Revenue Secretary Shaktikanta Das has said that “DTAA treaty (with Mauritius) is in very advanced stage of negotiation. It is progressing… – Continue reading
MUMBAI: The Bombay Stock Exchange (BSE) today called for ending exemption of capital gains tax on securities to contain various entities using capital markets to evade taxes and launder money. The government should re-think the exemption on capital gains taxes on traded securities, which listed companies enjoy, in order to… – Continue reading
The US Internal Revenue Service is cracking down on hedge funds, challenging a tax strategy called “basket options” that is used to claim billions of dollars in tax savings, the New York Times has reported. Hedge funds using the options must declare them on their tax returns and they will… – Continue reading
The Australian Government will introduce a withholding tax obligation to ensure that foreign investors comply with Australia’s tax laws. The Government has released exposure draft legislation that provides for the application of a ten percent non-final withholding obligation on the disposal by foreign residents of taxable Australian property. If passed,… – Continue reading
The Australian Taxation Office has warned companies it will be focusing on money attributed to offshore marketing hubs and will use its stronger transfer pricing powers to go after them, reports the Sydney Morning Herald. Australian companies sent more than AU$100 billion to related parties in the low-tax nation of… – Continue reading
How should non resident or non domiciled buyers of UK residential property own or hold residential property? Overseas buyers or owners of UK residential property above £1m in value need to consider carefully in what name or legal structure they should buy or hold property for their protection and to… – Continue reading
