Category: Corporates

KPMG releases new global tax survey; economic and social pressures expected to impact global tax system

Taxpayers in Romania and throughout the world can expect to pay more tax in the years ahead as governments expand their tax systems to repay debt and pay for increased social welfare, and international efforts to update tax legislation for the 21st century take hold. These are the conclusions of… – Continue reading

Americans In Costa Rica Advised To Ensure US Tax Compliance

QCOSTARICA via Tax-news.com – The inclusion of a passport revocation provision to fund part of the proposed US highway bill would “disproportionately” affect American citizens living overseas, like in Costa Rica, according to a recent release from the deVere Group, a financial consultancy. The provision, which would be effective from… – Continue reading

State may gain up to €620m in Pfizer’s Allergan deal

Pfizer $160bn purchase of Allergan will see firm move HQ to Dublin Ireland’s exchequer is in line for an annual boost of up to €620 million following the announcement that Pfizer is buying rival Allergan in a $160 billion (€151 billion) deal. The takeover will see Pfizer move its corporate… – Continue reading

Previewing US Tax Reform

The latest Tax Reform Business Barometer survey, issued by The Tax Council and Ernst & Young, found that tax professionals expect Congress to approve tax reform legislation no earlier than 2017, with most congressional leaders having all but given up hope that tax reform is achievable in the remainder of… – Continue reading

I-T Dept inks 11 agreements to solve transfer-pricing issues

Of these, one advance pricing agreement has a ‘rollback provision’ The government has concluded 11 agreements to tax multi-national companies via the transfer-pricing mode. Of these, one advance pricing agreement (APA) has a ‘rollback provision’, which means those relating to previous years. The government has signed 22 APAs so far… – Continue reading

Finance Ministry to clean-up trade transfer pricing norms to make doing business easy

NEW DELHI: India proposes a major clean-up of decade-and-a-halfold rules that govern the prices of imports by related parties – such as arms of multinationals from their parent – in an attempt to reduce delays and disputes and make it easier to do business. The finance ministry is not just… – Continue reading

Wealth inequality and tax justice

Wealth inequality is a scourge of many countries. Last year, Credit Suisse reported that the richest 0.7% of adults in the world owned 44% of global wealth. Closer to home, earlier this year, the Lien Centre for Social Innovation’s ‘A Handbook on Inequality, Poverty and Unmet Social Needs in Singapore‘… – Continue reading

Turkey launches golden visa residency scheme

Turkish Economy Minister Nihat Zeybekci says the country is set to follow in the footsteps of Spain, Portugal and Cyprus and launch its own Golden Visa scheme to grant citizenship to those foreigners who invest from €500,000-€1m in property, reports Property Showrooms. Leading Istanbul agent, Universal21, says the move could… – Continue reading

DDM Holding AG: Swiss withholding tax applies in respect of interest payments to holders of the DDM Senior Secured Notes

Following a ruling by the Swiss Federal Tax Administration, payments of interest under the DDM Treasury SEK 300 million Senior Secured Notes with ISIN SE0005280831 (the “Notes”) are subject to Swiss withholding tax since the refinancing executed in June 2015. On 23 June 2015 certain amendments to the documentation in… – Continue reading

Sinarmas Land eyes Reit to unlock value of Indonesian investments

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

PwC Makes UK Autumn Statement Predictions

Professional services firm PwC has predicted that UK Chancellor George Osborne will introduce an “apprenticeship levy” and seek to lessen the impact of tax credit cuts when he delivers his Autumn Statement on November 25. In his Summer Budget, Osborne pledged that the Government would “introduce an apprenticeship levy on… – Continue reading

LUXEMBOURG: STATUS OF RATIFICATION OF PROTOCOL WITH FRANCE

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

New PE Language for BEPS Scales Back Earlier Drafts

Through tweaks to the Model Tax Convention, the OECD believes its work on profit shifting will stem elaborate structures, such as commissionaire arrangements, used by large multinationals to avoid the creation of a permanent establishment. The Organization for Economic Cooperation and Development, however, responded to concerns from taxpayers by narrowing… – Continue reading

Ethical Investors Should Shun Firms Avoiding Tax

Big name companies have faced a lot of criticism from the media about the low taxes they pay in some countries. Lately, the Organisation of Economic Cooperation and Development (OECD) has finalised a set of recommendations to stop base erosion and profit shifting (BEPS). The rules are aimed at curbing… – Continue reading

Americans in Hong Kong, Asia could lose their passports for unpaid taxes

The eight million Americans living overseas, including In Hong Kong and the rest of Asia, should “ensure their financial affairs are in order and compliant” before the New Year, or face having their passports revoked, warns the boss of one of the world’s largest independent financial advisory organizations. Nigel Green,… – Continue reading

Country-by-Country Plan May Be Project’s Greatest Legacy

The OECD’s final report on Action 13 under the base erosion and profit shifting project—which calls for countries to adopt a country-by-country reporting template, master file and local file—has the potential to be one of its “greatest legacies.” Marlies de Ruiter, head of the Organization for Economic Cooperation and Development’s… – Continue reading

Audits: Vanguard income taxes ‘deficient’ for 2010-14

Mutual-fund giant Vanguard Group underpaid taxes on its income in Texas for 2010-14, according to records of the Texas Comptroller of Public Accounts. State-sponsored audits found payment “deficiency” for all four years in Vanguard’s payments of the state’s corporate franchise tax, which charged companies 1 percent percent of a company’s… – Continue reading

IRS Updates FATCA Registration Website

The IRS has upgraded the Foreign Account Tax Compliance Act (FATCA) Online Registration System, enabling sponsoring entities to register their sponsored entities to obtain a global intermediary identification number. The upgraded system also will allow users to update their information, download registration tables and change their financial institution type. The… – Continue reading

‘Dr Ageless’, Shane Charter, chasing missing millions in Cayman Islands

EXCLUSIVE The self-styled biochemist known as “Dr Ageless”, Shane Charter, appears to have shrugged off the Essendon supplements scandal and is pursuing a new business venture — chasing more than $11 million hidden in offshore tax havens by notorious conman Peter Foster. Mr Charter has been negotiating for several months… – Continue reading

ATO takes tighter approach to deals with multinationals on future taxes

Tax Commissioner Chris Jordan has become more picky about entering agreements with multinationals aimed at giving companies certainty about their tax payment requirements in Australia in future years. Taxpayers can lock in their tax payment for a period of about three years via an “advanced pricing agreement”, or APA. Technology… – Continue reading

Insider blows the whistle on multi-million pound tax avoidance ‘factory’

Failed tax avoidance business Welbeck hired young actors to push schemes onto City big earners, and reaped millions in commissions that fuelled lifestyles of fast cars and exotic holidays, according to a whistleblower who worked at the firm. Welbeck Solutions sold pensions and financial products, but it specialised in tax… – Continue reading

Tax transparency: full list of exempt companies revealed as Senate battle looms

Private companies that were given a historical exemption from filing annual financial reports are run by a who’s who of corporate Australia, including Malcolm Turnbull Private companies associated with Australia’s business elite, including prime minister Malcolm Turnbull, are on a list of entities not required to publish tax information under… – Continue reading

Black money: Enforcement Directorate scanner on Indians named in HSBC list

NEW DELHI: Tightening the noose around Indians whose names figured in the ‘stolen’ Swiss HSBC bank black money list, the Enforcement Directorate has begun a preliminary investigation in these cases for an independent hawala and money laundering probe. The agency recently has begun obtaining from various court registries the details… – Continue reading

KPMG REPORT: INITIAL IMPRESSIONS OF NOTICE 2015-79 ON INVERSIONS

Notice 2015-79—released November 19, 2015, by the Treasury Department and IRS—announces their intention to issue regulations relating to inversion transactions and post-inversion restructuring transactions. Notice 2015-79 provides for rules that: Limit the ability of domestic companies to effect an inversion Limit the advantages of certain post-inversion restructuring transactions Clarify certain… – Continue reading

Welbeck Solutions: Whistleblower exposes secretive city firm at the heart of vast tax avoidance operation

Company used actresses including former Alan Partridge star to bombard financial sector workers with cold calls The grey Basinghall Street office building, in the heart of London’s City financial district, gives few clues about the frenzy of activity that was going on inside. But for years, this was the home… – Continue reading

More Banks Spill Tax Evasion Secrets To Avoid Criminal Charges, Account Holders Beware

Lately, the IRS is warning offshore account holders to disclose before it’s too late. Under FATCA, banks everywhere want to know if you are compliant with the IRS. And the cost of compliance for many people is growing. The IRS updated its list of foreign banks where accounts trigger a… – Continue reading

Investors heading abroad for growth

Wrap platforms are increasingly evolving to meet the needs of investors looking offshore for growth, with the addition of managed funds, ETFs and SMAs, Cameron Garrett writes. Traditionally, the investment portfolios of Australians have been heavily weighted towards investing in Australian equities. This is an interesting statistic, especially as the… – Continue reading

Swiss banks to pay $81 mln, avoid U.S. charges on aiding tax evasion

Three Swiss banks will pay a total of more than $81 million to the U.S. Justice Department to avoid possible prosecution for helping Americans to evade taxes, the department said on Thursday. The three banks, the Swiss unit of BNP Paribas SA (BNPP.PA); KBL (Switzerland) Ltd (LU0092281103.BR); and Bank CIC,… – Continue reading

INDONESIA: AEOI GUIDANCE, PROCEDURES FOR EXCHANGE OF TAX INFORMATION

The Ministry of Finance issued a regulation with guidance concerning the procedures for the exchange of financial information with other jurisdictions and countries. The “automatic exchange of information” (AEOI) process will allow for the exchange of data to verify and confirm compliance with tax obligations, including information from financial institutions…. – Continue reading

Clock Ticking for U.S. Holdouts as BNP Joins Swiss Tax Pact

The clock is ticking for American tax dodgers around the world after BNP Paribas SA’s Swiss unit and two other banks joined a U.S. program to avoid prosecution, revealing the exact methods of Swiss bankers’ legendary discretion. BNP agreed to pay $59.8 million in a program that has brought in… – Continue reading

Stricter norms likely for transfer pricing

MUMBAI: India’s forthcoming budget may draw from some of the recommendations, especially in the realm of transfer pricing, contained in the final package of ‘Base Erosion and Profit Shifting’ (BEPS) measures, rolled out in October. Certain anti-abuse measures, such as thin capitalization, which for tax purposes disallows interest payments beyond… – Continue reading

2015- The end of tax neutral jurisdictions

On 18 June 2013, the Progressive led government issued a press release titled, “Cayman’s Action Plan Includes Beneficial Ownership”. The press statement came on the heels of the UK taking over the Presidency of G8, at the 17-18 June 2013 G8 Summit in Northern Ireland. The most interesting part of… – Continue reading

Offshore land ownership secrecy blocks police investigation into wildlife crime

Ownership of Kildrummy Estate creates legal block for police investigators POLICE INVESTIGATIONS into wildlife crime failed in the face of a bureaucratic nightmare identifying the landowner behind a complex structure of offshore land secrecy. The conviction of gamekeeper George Mutch for wildlife crimes committed in 2012 on Kildrummy Estate opened… – Continue reading

China breaks up $64 billion underground banking: state media

Chinese authorities have uncovered the country’s biggest underground banking case involving transactions totalling more than 410 billion yuan ($64 billion), official media reported, part of a drive to combat illegal capital outflows. The investigation, which started in September and focused on the costal province of Zhejiang, found that dozens of… – Continue reading

The Offshore Wrapper: a week in tax justice #71

Now that’s what I call a Big Tax Case A long running court case that has become known as the ‘Big Tax Case’ appears to be reaching a conclusion. It involves Scottish football club Rangers, who went bust in 2012. After it failed, a new company was created. It bought… – Continue reading

The Tories Have Taken More Cash From This Donor Embroiled In Money-Laundering Probes

David Cameron’s party reported fresh donations of £217,500 from Lycamobile weeks after BuzzFeed News revealed the telecoms giant’s “deeply suspicious” business practices. The Tories have accepted a fresh donation of £217,500 from Lycamobile in defiance of calls on the party to sever its ties with the controversial telecoms group. The… – Continue reading

CEE countries must share best practices better to successfully combat VAT fraud

Officials from the ministries of finance and economy of five CEE countries (Czech Republic, Hungary, Poland, Romania and Slovakia) have called for a joint approach to combat VAT fraud and increase VAT collection in a conference hosted by PricewaterhouseCoopers (PwC) in Budapest on Thursday. According to the EU Commission data,… – Continue reading

CE + IT Multinationals Seek Talk With ATO As Avoidance Laws Near

CANBERRA – Several multinational companies have approached the Australian Taxation Office to negotiate before the Coalition Government’s tougher anti-avoidance laws take effect in January, tax commissioner Chris Jordan has said in opening remarks to the Senate inquiry into corporate tax avoidance. While not naming the companies, Jordan said he expects… – Continue reading

Tax functions need to fundamentally change the way they use and gather data

Employees in tax functions need to fundamentally change the way they use and gather data if they are to meet the growing demands on business of tax transparency, reform and technology enabled decision making. PwC’s latest research into the Tax function of the future – Unlocking the power of data… – Continue reading

Base erosion and profit shifting: limiting tax deductions for interest costs

Earlier this week the heads of state of the 20 largest global economies have agreed to adopt the 15 BEPS action points in their respective countries. Ample reason to take a closer look at the details and implications of one of the most far-reaching upcoming tax adjustments. Action 4 of… – Continue reading

Govt in top gear: Coal India stake sale, Vodafone talks signs of a strong resolve to deliver

From FDI relaxations to gas pricing and now disinvestment and Vodafone talks, it is refreshing that the NDA government has gone on an overdrive to push measures to attain a high growth trajectory. The pace at which the NDA government is taking decisions after Bihar assembly election results is commendable… – Continue reading

Crackdown on Caribbean tax havens a surprise boon for Hong Kong

Hong Kong is tipped to become the world’s largest offshore corporate services centre by 2020, helped ironically, by the industry’s own struggles against reform demands coming from western governments and pressure groups. On notice after high profile money laundering and tax avoidance scandals, traditional offshore havens like the British Virgin… – Continue reading

China stocks jump amid global rally on Fed minutes

Fed decision due after December 15-16 meeting Hong Kong and mainland Chinese stocks both closed significantly higher on Thursday, adding to a global stock rally after minutes from the US Federal Reserve’s October meeting sent a stronger signal about a possible December rate increase. The Hang Seng Index advanced 1.4… – Continue reading