The UK Government’s pledge to introduce a criminal offence that could put unintentional offshore tax evaders behind bars has been criticised by the Chartered Institute of Taxation (CIOT). Despite supporting HM Revenue & Customs efforts to tackle tax evasion, CIOT said it is opposed to the government installing a new… – Continue reading
THAI property tycoon Khunying Sasima Srivikorn, who co-owns an English Championship football club, recommends the United Kingdom as the best location for offshore property investment after realising a double-digit yield from a recent investment in the country. Speaking at an exclusive forum recently held by Tisco Wealth and Forbes Thailand,… – Continue reading
A blistering attack on major countries who brand offshore financial centres as tax havens has been launched by Bob Richards. The Minister of Finance warned that pressure on the offshore sector from abroad will continue into the foreseeable future. Mr Richards, speaking at the launch of a British Virgin Islands… – Continue reading
Historically, unlike UK residents who are generally liable to CGT on disposals of UK residential property (other than their principal residence), non-residents have been able to dispose of such property potentially free from UK CGT. The UK government sought to address this inconsistency by introducing a CGT charge in the… – Continue reading
Staff at Facebook’s UK arm took home an average of more than £210,000 last year in pay and bonuses, while their employer paid just £4,327 in corporation tax. Facebook made an accounting loss of £28.5m in Britain in 2014, after paying out more than £35m to its 362 staff in… – Continue reading
The UK government released draft regulations for country-by-country (CbC) reporting, to implement Action 13 of the OECD’s base erosion and profit shifting (BEPS) project. The draft UK regulations broadly reflect the OECD reports, released 5 October 2015, and specifically make reference to the model legislation. Key points of the CbC… – Continue reading
The Government has expressed a commitment to improving levels of UK corporate transparency but a recent Private Eye article [1], documenting the extent of ownership of British Land through offshore entities, shows just how far there is to go. By far the most common reason for owning UK property through… – Continue reading
Chancellor of the Exchequer George Osborne suggested he’ll announce measures next month to enshrine in U.K. law an international plan to crack down on tax dodging. Osborne said Friday the so-called base-erosion and profit-shifting plan will be implemented by Britain at the “next fiscal event,” indicating it will form part… – Continue reading
This French Tax Update will focus on (i) the main provisions of the draft Finance Bill for 2016 (Projet de loi de finance pour 2016) issued by the French Government on September 30, 2015 and to be discussed before the French Parliament between October and December (“Draft Finance Bill for… – Continue reading
A quarter of companies say they won’t meet the first deadline proposed by the Organisation of Economic Co-operation and Development (OECD) in its base erosion and profit shifting (BEPS) action plan, reports Economia. Globally, 74 per cent said they will complete their country-by-country analysis by the first due date, December… – Continue reading
The UK Government has released details of its plans to abolish the permanency of non-domicile status through the introduction of a “deemed domicile rule.”, reports Tax News. In his Summer Budget, Chancellor George Osborne announced plans to abolish the permanent non-dom tax status, meaning that anyone resident in the UK… – Continue reading
HMRC has defeated an avoidance scheme used chiefly by property developers and IT contractors and could now be owed up to £200m in unpaid tax The scheme, which was used by more than 2,000 people, aimed to exploit the UK’s double taxation agreement with the Isle of Man. Those using… – Continue reading
The IRS has posted text of a Competent Authority arrangement (CAA) between the United States and Hungary, pursuant to the intergovernmental agreement (IGA) signed in 2014 to implement the FATCA regime. The CCA with Hungary follows CAAs that were signed by the United States in September 2015 with both the… – Continue reading
Government should look to the example set by Barbados and start charging Value Added Tax (VAT) on betting and gaming activities in Trinidad and Tobago. This was the advice coming from Tax Director of KPMG’s TT operations, Nicole Joseph, during a post-budget forum hosted by the American Chamber of Commerce… – Continue reading
On October 5, 2015, the OECD released its final reports relating to the OECD/G20 base erosion and profit shifting (BEPS) project (the Final Reports). The BEPS project began in 2013 and has received unprecedented attention from governments and the private sector. The Final Reports outline the OECD’s recommendations and the… – Continue reading
In 2016, hundreds of directors, managers, principal points of contact (PPCs), compliance officers, administrators, and Money Laundering Reporting Officers (MLROs) serving Cayman Islands funds, banks, trust companies and other Reporting Financial Institutions (RFIs) will start to feel the full force of ‘a great wind’: global tax transparency. If you are… – Continue reading
A financial adviser and a group of film producers who set up an international scheme are facing a trial for fraud. It is alleged the scheme, which took advantage of the tax relief the UK Government offers the film industry, created the appearance of huge “paper losses”, The Times reported… – Continue reading
While the thought of going abroad to work or retire may be exciting, the months leading up to departure are likely to be highly stressful. It is vital that you pay adequate attention to financial planning. In particular, the tax consequences of leaving the UK are quite complex, so it’s… – Continue reading
The location of a holding company is a significant consideration in any international corporate structure. Choice of jurisdiction for a group holding company (‘Holdco’) is relevant both from the point of view of tax optimisation (maximising withholding tax free dividend, interest and royalty flow up through the group and minimising… – Continue reading
With the bulk of the OECD’s work on the BEPS project complete, attention will now turn to the implementation of the recommendations by member countries and others. Minister for Finance, Michael Noonan said that he welcomed the Base Erosion and Profit Shifting (Beps) report, and that the OECD’s proposals would… – Continue reading
The UK Government’s consultation paper on non-domicile status is “thin on the ground” when it comes to detail and, if introduced as proposed, will fail to treat some ‘non-doms’ fairly, according to tax experts. “It feels like this new legislation is being rushed through,” said Dean Mullaly, managing director of… – Continue reading
Countries should commit to minimum standards on the resolution of international tax disputes, the Organisation for Economic Co-operation and Development (OECD) said in a report published as part of its base erosion and profit shifting (BEPS) project.06 Oct 2015 The standards would include a commitment to “seek to resolve” cases… – Continue reading
Deemed domiciled; long term residents Indefinite non-domiciled status for UK tax purposes will become a thing of the past if the proposals in the Summer Budget are enacted. These are expected to take effect from 6 April 2017. A non-UK domiciliary may elect to be taxed on the remittance basis… – Continue reading
Writing exclusively for SuperyachtNews.com, Patrick Maflin, of Marine Accounts, advises crewmembers on how best to avoid falling foul of the UK/ SPAIN Double Taxation Agreement… The Seafarers Earnings Deduction (SED) is arguably the taxation scheme of choice for most Seafarers nowadays working on foreign going yachts. It is open to… – Continue reading
A financial adviser is one of the five defendants embroiled in a court battle after facing allegations of setting up a £262 million tax avoidance scheme. In a trial at Birmingham Crown Court, financial adviser Norman Leighton, chartered accountant and film producer Keith Hayley, producer Robert Bevan, Charles Savill and… – Continue reading
What is limitation of relief? Here is an actual illustration: A client in Singapore has loans to a Spanish SOCIMI, a real estate investment company equivalent to a REIT. Spain requires tax to be deducted at source when interest becomes payable even if in fact the interest is not actually… – Continue reading
HM Revenue & Customs (HMRC) has defeated a £200 million tax avoidance scheme that took advantage of the UK’s double taxation agreement with the Isle of Man. The scheme exploited the UK’s double taxation agreement with the Isle of Man, whereby people are not taxed twice on the same income… – Continue reading
In a move which is likely to be of interest to those organisations who put systems and procedures in place to comply, the US has recently announced (September 2015) that information on US persons does not now need to be exchanged for certain jurisdictions until September 2016. In Notice 2015-66… – Continue reading
On October 2, 2015, the Internal Revenue Service announced that it had achieved a key milestone in implementation of the Foreign Account Tax Compliance Act (FATCA), a critical anti-tax evasion law passed by Congress in 2010 but not fully implemented until July 2014. The milestone announced by the IRS was… – Continue reading
The IRS has announced that as of September 30, 2015 it will implement the automatic exchange of tax information as set forth in the Foreign Account Tax Compliance Act, (FATCA). The IRS Commissioner in announcing the implementation of the automatic exchange of information stated: “This information exchange is part of… – Continue reading
THE ORGANISATION for Economic Co-Operation and Development (OECD) must win over cynics when it announces its recommendations for a co-ordinated international approach to reform the international tax system later today. The measures will range from debt relief and harmonising rules on subsidiary companies, to linking sales and tax in each… – Continue reading
David Gauke, the Financial Secretary to the UK Treasury, has spoken out in support of the international tax measures being adopted by the UK, and pushed the idea of diverted profits taxes. Speaking at the American Enterprise Institute in Washington DC on September 29, 2015, Gauke said recent reforms have… – Continue reading
Pharmaceuticals group defends use of legal avoidance scheme, after paying no UK corporation tax over two years despite global profits of £3bn AstraZeneca, one of Britain’s largest businesses, is using a multimillion-pound tax avoidance scheme in the Netherlands, set up months after the UK relaxed its tax laws for multinationals… – Continue reading
On Monday (5 Oct) the Paris-based Organisation for Economic Cooperation and Development (OECD) will present its final Base Erosion and Profit Shifting (Beps) project corporate tax reform proposals and on Tuesday the Ecofin council of EU finance ministers, is expected to agree on the exchange of tax rulings between member… – Continue reading
The world’s richest nations will launch a huge crackdown on multinational tax avoidance on Monday as part of the biggest shake-up of international tax rules for decades. The move could lead to a multi- billion pound gain for Chancellor George Osborne and higher tax bills for a raft of blue-chip… – Continue reading
Millions of pounds of British aid money could have been given to known tax havens to fund public services The UK paid out £45m to 13 countries on the European Commission’s tax haven “blacklist” in 2013, according to a report in The Independent. The blacklisted countries that received British aid… – Continue reading
Government’s anti-corruption champion says legislation is one option if British overseas territories fail to adopt public registers of companies The government could legislate to force the UK’s tax havens to reveal for the first time the true owners of offshore companies, anti-corruption champion Sir Eric Pickles has indicated. Pickles described… – Continue reading
It’s not just about the pig’s head. Britain’s headline writers went into high porcine pun mode last month over a suggestion that Prime Minister David Cameron, while still in university, had taken part in a club-initiation ritual that bizarrely incorporated part of a pig carcass. The second-hand allegation appears in… – Continue reading
HMRC has released new Guidance on the disclosure of tax avoidance schemes (DOTAS) and promoters of tax avoidance schemes (POTAS), regimes. The new, revised, Guidance explains changes to the regimes since 2014. In relation to the issue of Conduct Notices, whereas previously the Guidance confirmed that HMRC would meet with… – Continue reading
George Osborne’s plans to tighten tax rules for wealthy foreigners living in Britain will leave many offshore trusts outside the UK tax net, according to proposals published on Wednesday, reports the Financial Times. The Treasury’s consultation on “carefully targeted” changes to the rules for “non-doms” — people who live in… – Continue reading
Prime minister says he is still not happy with way some British overseas territories are resisting financial transparency, reports The Guardian. David Cameron has accused some British overseas territories and crown dependencies of not doing enough to tackle tax evasion and money laundering. The prime minister took the offshore financial… – Continue reading
Using companies incorporated in international financial centres (IFCs) in structuring financial transactions, capital raisings and corporate structures has long been popular in Asia, particularly Hong Kong (itself an IFC). Following the energetic expansion of the PRC economy and assisted in part by the relaxation of PRC regulations in relation to… – Continue reading
HUNDREDS of properties worth more than £300 million in Brighton and Hove are owned by firms based in off-shore tax havens. Care homes, pubs, supermarkets, doctors’ surgeries, petrol stations and shops are all among almost 300 properties owned by firms based in foreign climes with beneficial tax arrangements. Millions of… – Continue reading
NEW DELHI: The finance ministry, seeking to build on the recent success in pitching India as an attractive destination, is looking at burying for good the remaining high-profile acrimonious tax tangles involving Cairn India and Royal Dutch Shell, which have tarnished the country’s administration. North Block is likely to replicate… – Continue reading
Tens of millions of pounds worth of property in St Austell is owned by companies based in offshore tax havens. They include large parts of Fore Street in the town centre; the beaches at Carlyon Bay, and dozens of individual buildings throughout St Austell and the clay country. NHS Kernow’s… – Continue reading
The UK government is unlikely to be able to legislate to speed up the referral of a single issue within a wider tax enquiry to the tax tribunal before 2017 despite the urgent need for such a procedure, an expert has said.30 Sep 2015 Respondents to a recent consultation on… – Continue reading
By: Pinakin D Desai, Partner – Tax & Regulatory services, EY India The term Base Erosion and Profit Shifting (BEPS) refers to tax avoidance strategies which, by exploiting gaps and mismatches in tax rules, shift profits of Multinational Enterprise (‘MNE’) Groups to low or no tax locations where there is… – Continue reading
The Guernsey Association of Compliance Officers (GACO) chair, Mark Dunster, has urged those affected by the introduction of the Foreign Account Tax Compliance Act (FATCA), and other exchange of information regimes, to attend a free seminar hosted by the association next Monday. Guernsey Income Tax office compliance and international manager,… – Continue reading
Tax treaties serve to reduce or eliminate double taxation which, if unrelieved, would be a significant barrier to cross-border trade and investment. At the same time, there was need felt to protect against granting of treaty benefits in inappropriate circumstances. In this background, the work of the OECD and G20… – Continue reading
30 September 2015 -New, detailed examination of the SwissLeaks files by Christian Aid working with the US-based Financial Transparency Coalition (FTC) graphically reveals the harm tax haven secrecy does to the economies of developing countries. The SwissLeaks scandal involves thousands of secret accounts at HSBC’s Swiss subsidiary HSBC Private Bank… – Continue reading
