TAIPEI — Japan and Taiwan will sign a bilateral tax treaty aimed at improving the flow of people and investment between the two economies, sources familiar with the matter said on Wednesday. The treaty will reduce or eliminate taxes on dividends repatriated from companies’ overseas branches and help avoid issues… – Continue reading
Under Indian foreign exchange regulations, Indian companies having foreign investment participation are generally categorised either as Indian owned and controlled company (IOCC), or foreign owned or controlled company (FOCC). An Indian company in such cases is considered as IOCC where they are owned and controlled by resident Indian citizens and/or… – Continue reading
Notwithstanding the NDA’s election promise to end tax terrorism the dynamics on the ground belie easy fixes The National Democratic Alliance (NDA) government is seeking to prepare a road map to reduce existing tax litigation and look into increasing pecuniary threshold limits to discourage tax departments from launching new cases…. – Continue reading
Fund houses and R&T agents have already started alerting investors to furnish Fatca and KYC details Mutual fund (MF) investors have to submit declarations to their fund houses to comply with the Foreign Account Tax Compliance Act (Fatca), which was passed in the US in 2010 (read more on this… – Continue reading
President Park Geun-hye called Monday for a careful adjustment of monetary policies of advanced countries amid lingering worries over a potential Fed rate hike. Last month, the U.S. Federal Reserve kept interest rates at near zero due to global headwinds but suggested that it could raise rates by the end… – Continue reading
Foreign investors are still concerned about the retrospective taxation in India, but the concerns have alleviated a little due to assurances by the government, says John Hobster, global head (transfer pricing), EY. He tells Dilasha Seth that in terms of transfer pricing, things are changing in India not only at… – Continue reading
The Brazilian Government has submitted to Congress four tax information exchange agreements (TIEAs) concluded with Uruguay, Jersey, Guernsey, and the Cayman Islands, Brazil’s Ministry of Finance said on November 11, 2015. Congress will also consider a protocol to expand and upgrade provisions for the exchange of information with India in… – Continue reading
The Organisation for Economic Co-operation and Development (OECD) has described its newly unveiled Base Erosion and Profit Shifting (BEPS) Action Plan as a “change of paradigm.”1 A few very large global groups aside, a more apt description may be a minefield for the unwary. BEPS has received considerable air time… – Continue reading
A Protocol to Double Taxation Avoidance Agreement between India and Denmark that has entered into force on February 1, 2015, has been notified by Notification No. 45/2015/F No. 503/02/1998-FDI-I, to expand the scope of Exchange of Information (EOI) clause under Article 26 by substituting the same with a new Article… – Continue reading
The fundamental contradiction between IndAS and taxation is that the latter is based on real income theory while the former is based on economic substance of transactions The country is undergoing an overhaul under the present government at the Centre, and so are its corporate laws. The country’s tax regime… – Continue reading
Antalya, Nov. 16: The Group of 20 nations today pledged to adopt sound macroeconomic policies to achieve strong, sustainable balanced growth. The near-term objective would be to support growth, create jobs and put debt as a share of gross domestic product (GDP) on a sustainable path. Data show that several… – Continue reading
On November 13, 2015 the UK HM Revenue & Customs (HMRC) published a policy paper setting out planned negotiations on Double Taxation Agreements (DTAs) and Tax Information Exchange Agreements (TIEAs). According to the policy paper HMRC will begin negotiations on double taxation agreements with: • Nepal • Romania • Trinidad… – Continue reading
MELAKA: Some 180 participants from 47 countries will attend the five-day 36th annual Technical Conference of the Commonwealth Association of Tax Administrators (CATA) here from tomorrow. The Inland Revenue Board (IRB) said among the countries taking part in the conference are Australia, South Africa, Brunei, India, New Zealand, Canada, Pakistan,… – Continue reading
An ED officer said, “In spite of earning a profit in the first few IPL seasons, Shah Rukh failed to provide any satisfactory explanation for selling the equity shares within a year, that too to a company situated in a tax haven”. Mumbai, November 11 (PTI): The Enforcement Directorate has… – Continue reading
It has been a matter of dispute between income tax authorities and tax payers that whether regular assessing officer is required to analyse returns before referring a case to a transfer pricing officer (TPO). Various judicial and quasi-judicial bodies have passed several orders on this issue. Some verdicts may conflict… – Continue reading
US citizenship, Greencard, can no longer be a way of saving tax for some, as India has agreed to provide information for compliance with the Foreign Account Tax Compliance Act (FATCA), which became law in March 2010. Either US citizens or institutions cannot refrain from paying tax on their investments… – Continue reading
Macky Sall, the Senegalese president, tells journalists on the sidelines of the Malta migrants summit that Africa would have no need of handouts if wealthy governments stopped multinationals avoiding legitimate taxation in their countries African leaders have rejected a European Union bid to curb migration with aid payments as “not… – Continue reading
The group, as a whole, will have to contend with adopting the BEPS framework and fulfilling the commitments made under the Brisbane Action Plan 2014 The tenth G-20 meeting at Antalya, Turkey, (that starts day after tomorrow) is gaining momentum. The challenges before the G-20 nations are many and varied…. – Continue reading
Both leaders recently discussed key bilateral issues on the new ‘hotline’ NEW DELHI, NOVEMBER 12: In a major deviation from earlier times, the much-publicised bilateral meeting between Prime Minister Narendra Modi and US President Barack Obama is unlikely to happen on the sidelines on the 10th G20 summit in Turkey…. – Continue reading
The Mumbai Bench of the Income-tax Appellate Tribunal held that an Assessing Officer cannot “mechanically” refer a taxpayer’s international transactions to a Transfer Pricing Officer for a determination of the arm’s length price, but must first independently conclude that the taxpayer did not determine the arm’s length price or did… – Continue reading
Corporate corruption is still prevalent in rich Group of 20 nations despite their pledges last year to close loopholes, according to Transparency International. It has listed Brazil, China and the US among the offenders. Transparency International on Thursday labeled this weekend’s G20 summit in Turkey as a mere “photo opportunity,”… – Continue reading
Tax: Luxembourg among countries helping US firms cut their tax bills by more than a quarter, campaigners say. The abuse of holding company structures in the Grand Duchy, and fiscal regimes in several other countries, allows American firms to avoid paying billions of dollars in corporate profit taxes, two NGOs… – Continue reading
MUMBAI: A US passport doesn’t look like such a priced possession anymore. Some Indians even want to surrender their hard-won green cards. India and the US are set to freely exchange financial information about their citizens, leaving no asset concealed. This could mean US tax officials imposing punitive levies on… – Continue reading
Hyderabad: Customers of several public and private sector banks across the Telangana and Andhra Pradesh are finding fault with their bankers for asking to fill up more forms under Foreign Account Tax Compliance Act (FATCA), and Common Reporting Standard (CRS). The new rules have come into effect from November 1,… – Continue reading
MUMBAI: In a bid to tackle high-pitched and unreasonable tax assessment orders, which result in heavy income tax (I-T) demands, the Central Board of Direct Taxes (CBDT) issued a notification on Monday requiring setting up of local grievance committees across I-T offices in India. The CBDT, in its notification, acknowledges… – Continue reading
Presidency sent to Congress ratification of treaties with Jersey, Guernsey, the Cayman Islands and Uruguay; text follows the G20 guidelines The Presidency referred for evaluation of Congress four agreements for the exchange of tax information (TIEA, which stands for the English term “Tax Information Exchange Agreement”) entered into with Uruguay,… – Continue reading
Headline: G20 among biggest losers in large-scale tax abuse – but poor countries relatively hardest hit G20 countries are the biggest losers when US multinationals avoid paying taxes where they do business. This is the main finding of a new report on the global tax system, ‘Still Broken,’ released by… – Continue reading
NEW DELHI: The forthcoming G20 summit will not be only about the global economy. Host Turkey has said the world’s top 20 nations will have to debate the world’s biggest political and security crisis of the day, Syria, and the mass migration of refugees. According to local media reports, the… – Continue reading
NITI Aayog vice-chairman Arvind Panagariya, who is a sherpa for the G20 Leaders’ Summit to be held at Antalya in Turkey on November 15 and 16, says the member countries recognise that India will continue to grow at high rate that will contribute to the global growth. He tells Indivjal… – Continue reading
The dramatic expansion of international trade and development of new business strategies due to globalisation, converted the world into a large global market. In connection with that, companies have been using complex networks of subsidiaries and branches (e.g. permanent establishments) in order to continue most of their operations. The Multinational… – Continue reading
NEW DELHI: Markets regulator Sebi today barred 15 individuals from securities market on suspected tax evasion and money laundering through stock trading platforms. This is on top of 108 entities already prohibited from the securities in December last year in a case related to Radford Global Limited. These entities misused… – Continue reading
NEW DELHI: Dismissing apprehensions of Mauritius being used to route black money as “misconception”, its Prime Minister Anerood Jugnauth has termed the issue as an aberration in the “very special” ties with India and hoped that revision of their tax treaty won’t harm its interests. Stating that Prime Minister Narendra… – Continue reading
The Union Cabinet chaired by the Prime Minister Shri Narendra Modi, has given its approval today for amending the Double Taxation Avoidance Convention (DTAC) signed between India and Turkmenistan in 1997 for the avoidance of double taxation and for the prevention of fiscal evasion with respect to taxes on income… – Continue reading
The finance ministry is streamlining safe harbour rules and advance agreements, two mechanisms to determine the price of services rendered by a multinational to its subsidiary in India. Safe harbour rules – directives on margins the tax authorities should accept for the transfer price declared by an assessee – have… – Continue reading
Whilst the growth of India as an emerging market for foreign investment is nothing new, we are seeing some new trends in the way in which offshore Cayman vehicles are being used as an avenue for investing in that market – specifically, voluntarily registering master funds as regulated master funds… – Continue reading
Prime Minister of Mauritius, Anerood Jugnauth, on Tuesday said there will be no revisions to the main provisions of its Double Tax Avoidance Agreement (DTAA) with India as both countries are happy with the existing provisions of the tax treaty. “This treaty between our two countries has been there for… – Continue reading
Non-resident Indians (NRIs) have one more investment option to choose from. The Reserve Bank of India (RBI) has allowed NRIs to invest in the National Pension System (NPS), under Foreign Exchange Management Act. NPS will allow NRIs to invest in a mix of equities and debt and save for their… – 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
Claiming that a lot of information on illicit funds is lying unused by the Indian authorities, HSBC whistleblower Herve Falciani said on Tuesday that he is willing to cooperate with the investigative agencies in their black money probe but would need protection in return. He also claimed that millions of… – Continue reading
NEW DELHI: Switzerland has retained its top spot in the financial secrecy index (FSI) 2015, unveiled by the Tax Justice Network (TJN) on Monday. Switzerland is followed by Hong Kong, the US, Singapore and the Cayman Islands. The biggest surprise is the US, which has climbed to third place from… – Continue reading
The trial has begun in Switzerland of banker Herve Falciani, whose leaks helped uncover the HSBC tax evasion scandal. The French-Italian national is accused of financial espionage, among other charges. Herve Falciani’s trial opened on Monday in the southern Swiss town of Bellinzona and will continue despite his refusal to… – Continue reading
Biz-friendly tax regime is one of incentives Belgium, a global hub for international government institutions, wants to attract more Korean investment with its business-friendly tax regime. At the “Belgium: Gateway to Europe” seminar at the Koreana Hotel on Oct. 27, the event host, the Embassy of Belgium, invited Bart Adams,… – Continue reading
There can be no straight jacket formula to determine what is meant by “provision of service,” which may include where services are i) provided; ii) rendered; or iii) utilized. The expression ‘provision of services’ is much wider than ‘provision of rendering of services,’ and covers the services even if they… – Continue reading
Indians nowadays are increasingly buying properties overseas, particularly in London, New York, Singapore and Dubai. It is critical for them to study foreign exchange regulations and tax provisions of the relevant country as well as India before they make buying decisions. Some of the important aspects to be noted 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
IRDA norms on retrocession viewed as being restrictive Top foreign reinsurers, namely Swiss Re, Hannover Re and Scor Re would soon be applying to the insurance regulator for opening branch offices in India. The Insurance Regulatory and Development Authority (IRDA) on Friday came out with the regulations for registration and… – 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
Over the past decade, many Indian business families have organised themselves under trusts — a bankruptcy remote structure — to preserve wealth, protect the rights of various members, and plan for the next generation. Now, this arrangement is coming under strain for families with members staying in the US, the… – Continue reading
