In September 2014, the Hurun Research Institute published its annual listing of the richest people in China. It showed that IT tycoon Ma Yun had increased his personal fortune during the last year by 500% to $25 billion and in doing so, had climbed to first position on the list…. – Continue reading
The amount big companies set aside to cover disputed tax bills has more than halved over the past three years to £1.7bn this year, reports the Financial Times. Even though businesses fear more disputes as tax authorities become increasingly tough, they are showing reluctance to be drawn into conflicts that… – Continue reading
Government must make good on its vows, says Jamie Livingstone In less than two weeks, leaders from 193 states will meet at the United Nations in New York to formally adopt, in effect, a new plan to fight extreme poverty, tackle inequality and end hunger. The Sustainable Development Goals (SDGs)… – Continue reading
Labour has demanded a review of a new tax that hits smaller banks alongside global behemoths Challenger banks and building societies threatened by George Osborne’s extra bank tax have been offered a lifeline by the Labour Party, which wants to amend the charge to help out the smaller end of… – Continue reading
PHUKET: In 2005 the EU Commission proposed a directive that laid the foundations for a radical change in the portability of an individual’s pension. British, Dutch and Irish nationals were given the flexibility to move certain private pensions to the jurisdiction of their choice, rather than leave it in their… – Continue reading
One of the UK’s leading hedge fund managers must pay nearly £8m in tax after a judge upheld a ruling that Patrick Degorce had attempted to shelter millions in a controversial avoidance scheme. Mr Degorce, co-founder of The Children’s Investment Fund along with Sir Chris Hohn, denied knowing that a… – Continue reading
The National Assembly’s landlord is a shadowy company based in the tax haven of the British Virgin Islands – and AMs have no idea who is benefitting from the annual rent of more than £2m it pays to the owners. Private Eye magazine has launched a section of its website… – Continue reading
On 1 July 2015, the Supreme Court (in Anson v HMRC4) held that a taxpayer was entitled to treaty relief on his share of a Delaware LLC’s profits. This casts doubt on HMRC’s published position (though each case must be judged on its own facts). The taxpayer, a UK “non-domiciled”… – Continue reading
On 13 April 2015, HMRC confirmed that UK financial institutions will not be required to file “nil” returns under the UK’s FATCA regulations, if they do not maintain any US financial accounts. However, UK financial institutions that maintain only US accounts below the applicable de minimis threshold ($50,000 or $250,000,… – Continue reading
A 12-month investigation by a national magaizne has revealed city centre properties in Bath are registered to offshore companies. The Private Eye magazine has produced a map, which details all land and property registered in England and Wales in the name of an offshore company between 2005 and July 2014…. – Continue reading
HMRC have increasingly been targeting the offshore arena in recent years, but it should not be overlooked that they continue to undertake civil and criminal investigations without any overseas angle whatsoever. This is all to evident in a recent case involving a chain of children’s nurseries, where the co-owner, Michael… – Continue reading
Grant Shapps, Foreign Office minister, says on visit that Cayman Islands could use existing systems to help tax authorities The UK government appears to have relaxed its pressure on the Cayman Islands to create a register of company ownership, despite David Cameron’s plea last year for overseas territories to do… – Continue reading
HMRC has published draft regulations which will extend the application of the disclosure of tax avoidance schemes (DOTAS) regime to inheritance tax (IHT) avoidance structures. The draft regulations set out the circumstances in which arrangements will be required to be registered under the DOTAS regime. Registration will be required where… – Continue reading
Schroders Plc’s Swiss bank will pay a $10.4 million penalty to avoid prosecution under a U.S. program that requires participating firms in Switzerland to say how they helped American clients avoid taxes. Schroder & Co. Bank AG’s penalty is the fourth highest among 33 banks that have settled with the… – Continue reading
HM Revenue and Customs’ recognised overseas pensions (Rops) list has one extra fund in the Australian space, a self managed super fund which industry specialists say may cause a reopening of the market down under, reports FT Adviser. This follows the HMRC list being slashed of all Australian funds earlier… – Continue reading
The Cayman Islands are somewhat a tourism paradise. There are crystal blue waters and golden beaches, but the fate of the economy is often overlooked. For years the country has been sustaining itself on the financial services industry, but with the impending issue of tax avoidance in global media, could… – Continue reading
International pensions administrator STM Group is looking to offer QROPS tailored for UK expats in Australia after HMRC scrapped thousands of schemes from its approved list in July. During an interview with International Adviser, STM – which has trading offices in both Malta and Gibraltar – cited plans to expand… – Continue reading
Three-quarters of global business leaders would accept higher taxes in exchange for greater clarity on acceptable tax planning, the Grant Thornton International Business Report has found. The survey of 2,580 businesses in 35 countries noted a significant increase from the last time the question was asked – last year –… – Continue reading
New Zealand: GST and the digital economy The New Zealand Government has released a Discussion Document regarding the proposal to impose goods and services tax (GST) on online purchases of goods and services from offshore suppliers by New Zealand resident consumers. The publication Taxing by the megabyte: New Zealand’s GST… – Continue reading
For hedge funds in most jurisdictions, the first wave of registration and reporting deadlines surrounding the Foreign Account Tax Compliance Act (FATCA) is now in the rearview mirror, but a significant amount of work likely remains. Due to the staggered approach regarding the definition of a reportable investor in 2014… – Continue reading
United Kingdom | August 31 2015 Last month, the UK government announced sweeping changes to the taxation of “resident non doms,” a classification of individuals who receive favorable tax treatment from the UK government. The UK tax obligations of an individual depend in large part on the individual’s “domicile” under… – Continue reading
Acting U.K. Overseas Territories Minister Grant Shapps said Thursday he is hopeful that Cayman and the Mother Country can reach some form of agreement on requirements to list the beneficial owners of companies registered here. “There’s more than one way to skin a cat,” Mr. Shapps said during a brief… – Continue reading
Three-member AP Shah Committee has recommended extending minimum alternate tax (MAT) relief to foreign companies which do not have permanent establishment or public business in India. In an earlier version, the committee had sought to restrict MAT to foreign institutional investors and foreign portfolio investors. The committee had also not… – Continue reading
European Union | August 27 2015 On 16 July 2015, the CJEU released its decision in the joined cases of Larentia + Minerva mbH & Co. KG and Marenave Schiffahrts AG. The CJEU followed Advocate General (AG) Mengozzi’s earlier opinion and held that active holding companies should have the right to… – Continue reading
The Cayman Islands as one of the leading offshore financial centres have a great level of uncertainty in its future with all the recent developments around tax compliance. One looming uncertainty is the European Union’s (EU) Alternative Investment Fund Managers Directive (AIFMD) passport. The AIFMD is one of several measures… – Continue reading
A favourable trip to London by Michael Dunkley has been notable for what did not come up in talks, the Premier said. “One thing that never came up was the European Union blacklist,” Mr Dunkley said of his meeting with British Cabinet ministers. In June, the EU’s executive commission included… – Continue reading
Revenue department’s ‘harsh’ approach criticised as ‘misguided’ and ‘a bit desperate’, writes Sam Burne James Tax avoidance has been a high-profile topic in recent years, and charities have not been immune from the efforts of HM Revenue & Customs to close any perceived loopholes and bring in as much money… – Continue reading
The new head of Barclays Plc’s Swiss unit is pushing private bankers in Geneva and Zurich to double client assets in four years as international competitors exit the world’s largest hub for offshore wealth. James Buchanan-Michaelson, who joined from Coutts International in June, aims to increase Swiss assets, including loans,… – Continue reading
This month’s feature examines proposals for new tax information reporting requirements for large multinational businesses as part of wider and ongoing changes to the international tax system – proposals which have been described by international tax experts as the most significant development in the field of transfer pricing since TP… – Continue reading
Until recently, demonstrating empirically the value of International Finance Centres (IFCs) to global economies has proven relatively difficult. Despite IFCs being able to point to the high quality of their regulation and the endorsement they receive on a consistent basis from global authorities such as the OECD and IMF, this… – Continue reading
Expat contractors who are earning big salaries without paying tax in their home countries are running out of time to put straighten their finances, say recruitment experts. Contractors who are still tax resident in the UK but fail to declare their offshore earnings are one target for global tax authorities…. – Continue reading
After the leak of two major secret documents from HSBC’s Swiss private banking arm that revealed names of roughly 2,000 Indian account holders, the global bank itself has done it now. For the first time ever, HSBC Singapore shared a new list of 1,200 individuals all across the globe of… – Continue reading
WINDS OF CHANGE – GEORGE OSBORNE’S FIRST BUDGET AS THE CHANCELLOR OF A CONSERVATIVE GOVERNMENT BROUGHT SEVERAL SIGNIFICANT ANNOUNCEMENTS. By Mark Wingate Taking a leaf from the Labour Party’s election manifesto, there will be a further tightening of the rules for non-doms. In an attempt to provide a more level… – Continue reading
FOCUS: Banks, professional services firms and trust and company service providers will face particular risks once the UK government’s proposed criminal offence for companies and partnerships whose ‘agents’ facilitate tax evasion comes into force. Agents, including employees but also others who “act on behalf of” a company, already potentially commit… – Continue reading
The Maltese climate, culture, history and lifestyle make Malta an attractive place to live in. The fact that this is coupled with a beneficial tax system for people taking up residence in Malta makes Malta an even more desirable location. Introduction to Malta Situated in the middle of the Mediterranean… – Continue reading
The Association of Tax Technicians (ATT) has expressed serious concern that the proposed new UK Dividend Allowance amounts to a tax rise “by the back door.” Chancellor George Osborne’s Summer Budget provided for the replacement of the Dividend Tax Credit with a new Dividend Allowance. The allowance will be available… – Continue reading
The UK is preparing to triple the number of prosecutions of “serious and complex” tax evaders using an arsenal of proposed new powers, reports the Financial Times. A unit combining the civil and criminal investigations teams at HM Revenue & Customs will spearhead a crackdown that George Osborne, the chancellor,… – Continue reading
The Government has handed HM Revenue & Customs new powers to help it meet tax evasion prosecution targets. In the Summer Budget, the Treasury pledged a £750m investment in HMRC. The Chancellor said the cash would be used to pursue offshore trusts and would triple the number of evaders the… – Continue reading
India will soon settle international tax disputes with close to 120 American companies as well as entities from Japan and other such countries, according to the nation’s Revenue Secretary Shaktikanta Das. Earlier this month, India announced a Framework Agreement under the mutual agreement procedure provision of the India-US tax treaty… – Continue reading
Canada Life’s acquisition of Legal & General International has resulted in a combined 29% share of the offshore bond market into the UK. Managing director of Canada Life International, Sean Christian, revealed the figure in an interview with international Adviser while discussing the details of the deal and the opportunities… – Continue reading
Draft regulations have been published that could see individuals and their tax advisers having to disclose participation in all but the most basic of inheritance tax (IHT) planning. The draft regulations could, says law firm Boodle Hatfield, require even straightforward arrangements to be disclosed, swamping HMRC with information that they… – Continue reading
A new paper shows that British banks engaged in more offshore banking than any other financial centre. Researchers examining the resilience of the world’s financial centres after the global economic crisis conclude that the future stability of the UK is perhaps the most uncertain of all. The paper concludes that… – Continue reading
Ireland has made “little or no” effort over the past four years to create a corruption-free playing field for global trade, violating its “obligation to combat cross-border bribery”, reports the Irish Times. The Transparency International Exporting Corruption report, released on Thursday, found that Ireland, along with countries such as Russia,… – Continue reading
FOCUS: The UK government plans a new criminal offence for companies and partnerships whose ‘agents’ facilitate the evasion of UK tax. The proposal is to make corporations criminally responsible if they fail to take reasonable steps to prevent their agents from taking actions that facilitate tax evasion. Agents include employees… – Continue reading
Management and procurement services not taxable as “fees for technical services” under the India-UK income tax treaty: India’s Authority for Advance Rulings concluded that services rendered by a group director to its group company in India were “managerial services” that, as rendered by the UK procurement team, did not make… – Continue reading
Given the current focus on tax transparency and reporting, and the government’s consultation document with proposals to introduce a legislative requirement for large businesses to publish their tax strategy as it relates to or affects UK taxation, UK companies need to consider establishing a process for determining what content can,… – Continue reading
Introduction Individuals whose domicile of origin is outside United Kingdom Non-UK individuals with UK domicile of origin Consultation and legislation New inheritance tax rules for UK residential property held within offshore corporate envelopes Comment Introduction Individuals domiciled outside the United Kingdom might have been justified in thinking that they would… – Continue reading
HM REVENUE & CUSTOMS has published a factsheet illustrating the overhaul of the way dividends are to be taxed from 2016. The move, announced in July’s Summer Budget, wipes out the tax advantage of taking payment as a dividend. The tax credit applied to dividends is to be replaced with… – Continue reading
The queue of tax disputes awaiting litigation through the UK’s tax tribunals set a new record last year, with almost 30,000 cases waiting to be heard at the end of last year, according to official figures. The number of outstanding appeals by taxpayers to the first-tier tribunal increased by 8.5%… – Continue reading
Anyone with undisclosed overseas income, gains or assets will be wise to make use of the Liechtenstein Disclosure Facility while it lasts, according to tax experts at Baker Tilly, reports FT Adviser. Andrew Hubbard, a partner at the firm, warned advisers that everything he has heard has led him to… – Continue reading
