Category: Treaty Abuse

Another tax-avoidance scheme is getting scrutiny

While it’s said that death and taxes are inevitable, enough money and clever maneuvering can apparently help sidestep the latter. Witness the so-called dividend arbitrage, which is raising concerns from regulators thanks to its ability to allow big banks to create $1 billion per year in revenue, according to The… – Continue reading

Government seeks banking information on 97 cases from Mauritius in one year

PORT LOUIS: Mauritius has provided details on majority of information requests received from Indian authorities in the last one year, according to a government official. India has concerns that Mauritius, which is one of the top sources of foreign direct investments into the country, is being used for round-tripping of… – Continue reading

OECD: tax avoidance rules must avoid “collateral damage” on fund management industry

The fund management industry could be exempted from new global rules intended to combat tax avoidance by multinational companies if further work finds that they may “hamper legitimate transactions”, according to the Office for Economic Cooperation and Development (OECD).26 Sep 2014 Corporate Tax Corporate tax Tax Disputes and Investigations Investment… – Continue reading

Study: Uganda Losing Money to Double Taxation Treaties

Multinational companies could be robbing Uganda of billions of shillings through double taxation treaties (DTTs), a new survey has revealed. The study, DTTs in Uganda: Impact and Policy Implications, by Seatini Uganda and ActionAid, shows that many companies are extracting resources and selling their goods and services in Uganda, but not… – Continue reading

Big economies take aim at the firms running circles around their taxmen

POLITICIANS in the rich world like to splutter about the ever more elaborate dodges that big multinational firms undertake to minimise their tax bills. But doing something about them is trickier. America’s Congress is struggling to agree on ways to stop companies “inverting”—switching domicile to reduce tax bills (see article)…. – Continue reading

Global watchdogs take on the corporate tax dodgers

As the finance ministers and central bank governors from the world’s 20 largest economies gather in a convention centre in the Australian city of Cairns this weekend, anti-capitalist protesters will likely accuse them of doing the bidding of the globe’s all-powerful multinational corporations. But the Group of 20’s financial chieftains… – Continue reading

International Tax Alert: OECD Releases BEPS Papers

Yesterday saw the release of the first set of deliverables under the OECD’s project on base erosion and profit shifting (BEPS).  These constitute the “building blocks” for an internationally agreed and co-ordinated response to government and media concerns in recent years about the perceived way in which shortcomings in relevant… – Continue reading

OECD outlines anti-tax avoidance plan

THE CLAMPDOWN on tax avoidance by multinational corporations has been bolstered by a series of recommendations made by the OECD. Companies including Google, Amazon and Starbucks have been in the firing line for their use of offshore jurisdictions to drive down their UK tax liabilities. In particular, the companies have… – Continue reading

OECD to publish first proposals on tax avoidance; Big tech on backfoot

The OECD will today publish its first recommendations for a co-ordinated international approach to combat tax avoidance by multinational enterprises under the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project. Meanwhile there is already evidence in Europe that the confluence of massive tax avoidance and increased concerns about privacy is… – Continue reading

OECD releases 2014 BEPS deliverables

On September 16, 2014, the Organisation for Economic Co-operation and Development (OECD)  released its first seven of 15 deliverables under the OECD/G20 base erosion and profit shifting (BEPS) project (the 2014 BEPS Package). The 2014 BEPS Package arises from the Action Plan on Base Erosion and Profit Shifting (the BEPS Action Plan),… – Continue reading

Corporations vs. Canada: The threat of treaty shopping

With an eye to next year’s federal election, the Harper government has begun to sprinkle tax-relief treats across the country. Small businesses got theirs last week with a break on employment insurance premiums. Sometimes, however, what governments don’t do can be as telling as their actions. The Finance Department has… – Continue reading

Delhi HC joins dots on indirect transfer debate

The verdict serves as reference for invoking treaty abuse provisions in the absence of General Anti-Avoidance Rules Mukesh Butani  September 7, 2014 Last Updated at 22:33 IST In a ruling demonstrating wise judicial discipline, the Delhi High Court (HC) recently upheld non-taxability of sale of shares in an offshore company… – Continue reading

Now tax what I call music – the fantasy festival line-up

Three members of Take That are reported to have invested in a tax avoidance scheme – so will they join our festival line-up of stars who, through schemes or leaving the country, have avoided tax? Whether by moving country or through schemes and accountants, celebrities finding ways to avoid tax… – Continue reading

Canada: Treaty Shopping Proposals – A Review Of 2013 And 2014 Developments

In Budget 2013, the Government announced its intention to consult on possible measures to combat treaty shopping. Eleven months later, in Budget 2014, the Government invited comments on a proposed domestic anti-treaty abuse rule. This article briefly reviews developments arising between the two budgets and provides high level comments in… – Continue reading

India, Switzerland spar over access to bank accounts information

NEW DELHI: The Indian Tax authorities and the Swiss government could be headed for a showdown over what the Indian side regards as lack of co-operation from the Alpine country over access to information on bank accounts. Last week Finance Minister P Chidambaram wrote to his Swiss counterpart – officials… – Continue reading

Move to revamp tax treaty with Mauritius: Govt

The Government on Tuesday said efforts were being made to find mutually acceptable solution to address India’s concerns while revising the tax treaty with Mauritius. The Government has proposed to review the India-Mauritius Double Taxation Avoidance Convention (DTAC) to incorporate amendments to the pact for prevention of treaty abuse and… – Continue reading