On 14 March 2017 the Parliament of Ukraine ratified the Convention between the Government of Ukraine and the Government of the Grand Duchy of Luxembourg “On Avoidance of Double Taxation and Prevention of Income and Capital Tax Evasion” (the “Convention”) and a protocol to it (the “Protocol”). As we informed… – Continue reading
Online giant wins transfer pricing case against US Internal Revenue Service Amazon. com has won a tax dispute with the US Internal Revenue Service (IRS), involving more than $1.5 billion (€1.39 billion), in relation to the transactions of a Luxembourg unit more than a decade ago. Judge Albert Lauber of… – Continue reading
HM Revenue and Customs (HMRC) is planning to make its Double Taxation Treaty Passport (DTTP) scheme available to all UK borrowers following a consultation on a legislative amendment. The DTTP scheme provides for Double Taxation Relief on UK loan interest payments made by a UK corporate borrower to overseas corporate… – Continue reading
Belgium should reduce its high corporate income and labor taxes and eliminate value-added tax (VAT) concessions, the International Monetary Fund (IMF) has said in its Article IV report for the country. The report notes that Belgium intends to reduce its high personal income tax and social security contribution rates in… – Continue reading
Governments around the world are losing as much as half a trillion US dollars (£400 billion) a year in tax revenue due to so-called “profit shifting” by multinational companies, according to research. The research published by the Tax Justice Network found that poorer countries were hardest-hit by the practice, which… – Continue reading
ISLAMABAD: After Federal Minister for Finance Ishaq Dar took a ‘principled stand’, Pakistani and Swiss authorities are scheduled to ink a revised convention on avoidance of double taxation agreement today (Tuesday) here in the federal capital, enabling the Pakistani authorities to get information about dirty untaxed money of $200 billion… – Continue reading
Swiss bank, UBS Group AG UBS , and its French unit will be facing a trial in France against allegations that the bank helped its clients in that country to evade taxes. Notably, a five-year probe into such allegations was closed last year. Following this, the prosecutor’s office was supposed… – Continue reading
The European Parliament’s Panama Papers investigative committee is preparing for a “fact-finding” visit with counterparts in the U.S. Congress, as well as officials from the Treasury Department and Internal Revenue Service. The European Union lawmakers’ four-day U.S. trip, which begins March 21, will include a visit to Delaware for meetings… – Continue reading
The 2017 Finance Bill was published on Monday 20 March, introducing dozens of initiatives with a focus on improving and modernising the tax system The Treasury said the bill, which is over 700 pages in length, “continues the government’s crackdown on tax avoidance” and “improves the fairness of the tax… – Continue reading
German Economy Minister Brigitte Zypries has said Germany could begin legal action against the US if the Border Adjustment Tax (BAT) is introduced. In an interview with Deutschlandfunk on March 17, 2017, Zypries was asked how Germany would respond if the US were to introduce the measure, which was included… – Continue reading
A committee of the UK’s upper house of Parliament has called on the Government to further delay its Making Tax Digital plans until 2020. Under Making Tax Digital, the Government will require taxpayers with a turnover exceeding GBP10,000 (USD12,370) to maintain digital accounts. Chancellor Philip Hammond announced in the Spring… – Continue reading
Beware of the dreaded inheritance tax and changes to it from April 2017! Approximately 1.3 million Britons now live in Australia and Brexit may only increase this number! Many think that moving to Australia means they no longer need to worry about UK tax, but often they are not fully… – Continue reading
The Caribbean Community is looking at spending nearly quarter of a million dollars on a Washington-based consultant to lobby the Trump administration about the Foreign Accounts Tax Compliance Act. Cayman appears unlikely, however, to be affected by any lobbying – or even FATCA repeal – in the wake of last… – Continue reading
(HP) A new law which was voted last month is set to ensure an exclusive residence permit in Luxembourg to high net worth investors, entrepreneurs and talent from outside the European Union. Due to be published early June, the draft law introduces five new residence permits, putting in place new… – Continue reading
Spain could make its tax system more efficient by scrapping income tax exemptions and by increasing value-added tax and environmental taxes, a new report from the OECD says. The OECD’s latest Economic Survey for Spain added the country should reduce employer social security contributions for low-wage workers on permanent contracts… – Continue reading
Preventing tax fraud and stopping multinationals from seeking out tax havens are important issues for Poland and will be discussed at a G20 summit later this week, Polish Finance Minister Mateusz Morawiecki has said. “We want medium-sized countries as well as smaller countries, which we represent … not to be… – Continue reading
The Swiss government plans to bolster group financing activities by amending its withholding tax ordinance to exempt interest payments for certain intra-group loans. The goal of the amendment is to encourage Swiss-based multinational companies to pursue targeted financing activities in Switzerland rather than abroad, according to a March 10 news… – Continue reading
Gautam Adani’s Australian entity will reportedly be shifting nearly Rs 150 billion from its Carmichael mine in Queensland to a secretive entity based in a tax haven. An analysis of the company’s findings done by the Australian Broadcasting Corporation shows that the company will be shifting up to 3 billion… – Continue reading
Italian and Swiss tax authorities have signed an accord to improve the exchange of information to fight tax evasion, the Italian economy ministry said on Tuesday. The agreement took effect at the start of this month and aims to further enhance transparency following a previous accord which was introduced last… – Continue reading
The LuxLeaks and Panama Papers scandals aroused shock and outrage the world over. However, reaction from Central and Eastern European statesmen and citizens was decidedly more muted. A new report has suggested profit shifting and tax dodging by businesses in the region is endemic – perhaps accounting for the lack… – Continue reading
The Portuguese parliament voted unanimously to pass a draft law by the Left Bloc that makes it mandatory to publish the annual total and destinations of transfers to offshore accounts, regardless of any ministerial decisions. Tax office statistics with the amounts transferred to offshore accounts were not published between 2011… – Continue reading
The repeal or delay to tax increases in the Affordable Care Act (ACA) will “overwhelmingly benefit high-income households,” according to the Urban-Brookings Tax Policy Centre (TPC). The House Ways and Means Committee has already approved the Republican’s proposals to repeal elements of ACA, commonly known as Obamacare. The TPC estimates… – Continue reading
A tax tribunal has ruled against a stamp duty land tax (SDLT) avoidance scheme used by Crest Nicholson, one of the UK’s largest house builders, meaning it will have to pay the £1.3m it owes. HM Revenue & Customs (HMRC) challenged the artificial and complex arrangements made by the FTSE… – Continue reading
A significant cut to the dividend tax allowance announced in the UK Budget will not deter people from incorporating their own business to take advantage of lower corporation tax rates, the Chartered Institute of Taxation (CIOT) has said. The Government will reduce the tax-free dividend allowance, which affects owner managers… – Continue reading
Luxembourg should seek to widen the tax base while ensuring that its corporate tax regime continues to meet international best standards, says the International Monetary Fund. It said that the country could improve its reputation by “promptly transposing” the EU’s Anti-Tax Avoidance Directive into national law and continuing to implement… – Continue reading
It says anyone who has been involved in designing or overseeing tax-avoidance schemes using charities would be unlikely to pass the test People who have been involved in designing or overseeing schemes to avoid tax using charities are likely to be prevented from taking up senior roles in charities, according… – Continue reading
Finance Minister Ishaq Dar on Wednesday told the National Assembly that Pakistan will sign an agreement with Switzerland on exchange of information regarding bank accounts on March 21. “The Swiss government offered to sign such an agreement with Pakistan in the third quarter of the current month that will enable… – Continue reading
From 6 April 2017, non-dom owners of UK property will be liable to inheritance tax (IHT) at 40% on any UK residential property they own. This has always been the case where a non-dom (broadly an individual who is resident in the UK but who has their permanent home abroad)… – Continue reading
New Delhi, March 9 (IANS) India and Belgium have signed a Protocol to amend the double taxation avoidance agreement to curb tax evasion, an official statement said on Thursday. “India and Belgium have signed a protocol amending the existing agreement and protocol between the two countries for avoidance of double… – Continue reading
Romania approved legislation to join the OECD’s base erosion and profit shifting Inclusive Framework on March 2. As an Associate member under the Inclusive Framework, Romania will work on an equal footing with other associates and G-20 and OECD countries in the development of further BEPS standards and the peer… – Continue reading
People still be able to shift pensions overseas tax-free if they and their pot are located in same country Stiff new penalty is aimed at those who retire to one country while parking their pension in an offshore tax haven The Chancellor is to slap a 25 per cent charge… – Continue reading
More tax is lost to onshore evasion or non-compliance than to offshore evasion and avoidance, and HMRC is armed with a raft of tools to curb the practice. In the second of a two part series, Jason Collins, a member of the CIOT’s management of taxes sub-committee and partner at… – Continue reading
Sometimes it can be hard to keep up with the avalanche of government announcements on tax avoidance and evasion. In the first of a two part series, Jason Collins, a member of the CIOT’s management of taxes sub-committee and partner at Pinsent Mason, provides an overview of the rapidly changing… – Continue reading
Loopholes that allow many self-employed workers to pay less tax may be closed in the budget – but their rights should improve Philip Hammond is likely to close loopholes in Wednesday’s budget that mean many self-employed workers pay less tax than their salaried counterparts – but he will come under… – Continue reading
The United States Court of Federal Claims has turned down a claim from an Irish citizen that more than USD5m in US tax withheld on gambling winnings should be refunded under the US-Ireland double tax avoidance treaty. The claim was filed by the plaintiff, John P McManus, after USD5.22m in… – Continue reading
The parliament transposed the EU regulation, whose aim is to secure comprehensive and effective administrative collaboration between tax administrations via mandatory automatic exchange of information. International corporations will be required to submit reports about their activities in every EU country in which they do business. This stems from the amendment… – Continue reading
The Hong Kong Government has put forward a proposal to amend its tax laws to establish a dedicated tax regime for aircraft owners/lessors based in Hong Kong and leasing to offshore (including PRC) lessees/airlines (see Timeline / References below) (“Proposed Regime”). Assuming there are no surprises or drafting issues in… – Continue reading
The Italian Revenue Agency is stepping up its fight against international tax evasion. The tax authority will focus on undeclared funds and income held abroad by Italian taxpayers who have become resident abroad since January 1, 2010. Controls will be based on selected lists, which will first target the most… – Continue reading
The Swiss Federal Department of Finance has said that it is forging ahead with work on a new corporate tax proposal, named “tax proposal 17” (TP17). A steering committee held its first meeting on March 2. It is led by Federal Councillor Ueli Maurer and comprises members from the government… – Continue reading
Accounting firm’s contracts with federal government questioned. A former client of the accounting giant KPMG says a tax dodge that involved wealthy people gifting their money to an offshore jurisdiction was a “facade” designed to hide money from the taxman. The client, who spoke to CBC’s the fifth estate and… – Continue reading
Federal agents raided three Caterpillar buildings near its Illinois headquarters on Thursday, company and law enforcement officials said, in an escalation of an inquiry into the heavy equipment manufacturer’s offshore tax practices. Caterpillar has been dogged by accusations that it slashed its domestic tax bill by shifting corporate profits from… – Continue reading
On 30 December 2016 the Commercial Court of Voronezh Oblast delivered a judgement in case No. А14-10190/2014 (the “Decision”) under the claim of Ilyushin Finance Co. Open Joint Stock Company (the “Company”). The case is an example of a broad interpretation of the list of documents confirming entitlement to a… – Continue reading
The new Residence Nil Rate Band will allow people to pass on property to their descendants tax free. But some people need to take action now or risk missing out. In April, a major change to inheritance tax (IHT) law comes into effect with the launch of the Residence Nil… – Continue reading
India has entered into new bilateral advance pricing agreements (APAs) with the United Kingdom and Japan, India’s Central Board of Direct Taxes (CBDT) announced on February 28. The two APAs were entered into over the last week. The CBDT also signed seven unilateral APAs. The APAs signed pertain to various… – Continue reading
THE ORGANISATION for Economic Cooperation and Development (OECD) initiated the base erosion and profit shifting (BEPS) project in 2013 to address perceived gaps in international tax rules causing a loss of revenues for governments of about US$100 billion to $240 billion (Bt3.5 trillion to Bt8.4 trillion) annually. The OECD’s BEPS… – Continue reading
The Netherlands is slowly but surely steering away from facilitating the use of its corporate income tax system by companies that are set up merely to obtain tax benefits. These companies, which often do not actually carry out activities in the Netherlands, have contributed to the perception among policy makers… – Continue reading
The Canadian Government has said that it will review its tax ruling process and voluntary disclosures program as part of its response to recommendations made last year by a parliamentary committee. In October 2016, the Standing Committee on Finance released its report on the Canada Revenue Agency’s (CRA’s) efforts to… – Continue reading
On 22 December 2016 the Luxembourg Parliament passed article 56bis of the Luxembourg Income Tax Law (LITL). This provision gives taxpayers and tax authorities more guidance on how to apply the arm’s-length principle. The new article can be seen as a transposition of OECD BEPS reports (actions 8-9-10) released in… – Continue reading
New Oxfam report indicates Government measures to tackle tax avoidance are failing Multinationals are continuing to route billions of euro in profit to and through Ireland to avoid tax, according to a new report by Oxfam Ireland. The study, which suggests that Government measures aimed at tackling tax avoidance are… – Continue reading
Global banking giant HSBC has disclosed being probed by tax authorities in India and several other countries, including against its Swiss and Dubai units, for allegedly abetting tax evasion of four Indians and their families. Besides, the bank has been approached by the regulatory and law enforcement agencies of various… – Continue reading
