Category: United Kingdom

Guernsey: Guernsey Issues Amended Legislation And Updated Draft Guidance Notes On FATCA-Based Reporting

On 31 March 2015 amendments were made to the Income Tax (Approved International Agreements) (Implementation) (United Kingdom and United States of America) Regulations, 2014 (the “2014 Regulations”) which brought FATCA-based reporting into force under Guernsey law. FATCA-based reporting is implemented in Guernsey pursuant to the UK-Guernsey IGA, signed on 22… – Continue reading

British internet giant Telecity falls into hands of tax-avoiding US rival Equinix for £2.35bn

The company that runs a swathe of Britain’s internet service is being bought by an American predator that plans to fold it into a giant international tax haven. Telecity operates data centres all over Europe – which house the wires that make the internet work – including sites in London… – Continue reading

UK banks named in football bribery scandal: Barclays and HSBC ‘handled millions in suspect transactions’

■ Barclays and HSBC have been named in legal papers filed in the US ■ Documents have also named London-based Standard Chartered Bank ■ Allegedly moved suspect transactions linked to Fifa through their accounts ■ Britain’s Serious Fraud Office is understood to be monitoring situation Two of Britain’s biggest High… – Continue reading

Elite group of British-born residents enjoy ‘non-dom’ tax haven

At least 800 British-born United Kingdom residents enjoy “non-domiciled” status, a tax break intended for temporary residents, according to data released in response to a Freedom of Information Act request by Reuters. Lawmakers said the information highlighted the need to change the tax rules to ban so-called “hereditary non-doms”, where… – Continue reading

Plus500 shareholders vent fury as UK customers accounts stay frozen

UNDER fire spreadbetter Plus500 was forced to defend itself against angry shareholders yesterday as it admitted all UK customers were frozen out of their accounts. The Israeli business, which has plummeted in value since the financial watchdog clamped down on its controversial customer recruitment practices, admitted in its annual meeting… – Continue reading

UK: Patent Box – More Detail On The New Regime

Following our article at the end of last year on the potential changes to the UK patent box regime further details have been released on the new regime, timings and additional work to be done. On 6 February 2015, the Organisation for Economic Co-operation and Development (OECD) published a paper… – Continue reading

Officials sign Swiss-EU data exchange deal

Switzerland and the European Union have signed an agreement providing for the automatic exchange of banking information, effective 2018. On Wednesday, Swiss State Secretary for International Financial Matters Jacques de Watteville signed the accord in Brussels along with EU Tax Commissioner Pierre Moscovici and Latvian Finance Minister Janis Reirs. Before… – Continue reading

Banks’ profits recover, but they are paying less in corporation tax

Research shows corporation tax receipts from banks are lower than before crisis despite global tax payments staying constant Britain’s banks are paying far less in corporation tax to the Exchequer than before the crisis, despite their profits improving and global tax payments staying constant. Research from Cambridge Judge Business School… – Continue reading

Gibraltar: Rising Above Regulatory Clouds

The medium-term uncertainty of the UK’s continued membership of the EU remains a cloud on Gibraltar’s financial horizon, for the Rock’s membership of the 27-nation body – and thus her role as a stepping-stone into Europe’s vast financial market – is under Britain’s umbrella. And it is partly in response… – Continue reading

Amazon begins to book revenues in separate countries in what expert says is response to regulatory pressure

E-commerce giant Amazon has begun booking revenue in individual European companies, a move that tax expert Heather Self of Pinsent Masons, the law firm behind Out-Law.com, said is probably influenced by upcoming regulatory changes.26 May 2015 “As of 1 May, Amazon EU Sarl is recording retail sales made to customers… – Continue reading

Germany: Amazon Pays $16M in Tax, Earns $16B

The company decided to declare its revenues since European regulators started to investigate its accounting practices. Internet retailer Amazon paid about US$16 million to Germany in 2014, while the giant multinational recorded a total earning of US$16 billion in that country, according to the country’s regulators. In the past, the… – Continue reading

UK FATCA: ARR deadline approaching for UK resident non-domiciled individuals

In November 2013 the governments of the Cayman Islands and the British Virgin Islands (“BVI”) entered into intergovernmental agreements with the United Kingdom (“UK IGAs”) which contained provisions for the establishment of a framework for the reporting of financial account information. That framework is similar in scope to the framework… – Continue reading

Diverted Profits Tax: counterbalancing the UK’s “open for business” agenda?

The UK’s introduction of the diverted profits tax (DPT) has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) and in effect as of April 1, the DPT seemed intended to appease public anger at multinationals failing to pay their ”fair… – Continue reading

International tax and withholding considerations for US companies and their directors

To staff their board of directors with the best and most diverse talent, multinational companies commonly elect boards with international representation. It is also common for companies to convene periodic board meetings outside the United States. This may be done, for example, to provide board members with an opportunity to… – Continue reading

Government Issues Beneficial Ownership Report

The Cayman Islands Government today issued a report stating that it will continue its current method of providing beneficial ownership information to law enforcement, tax and regulatory authorities, as the method adheres to global standards. As explained in its Consultation Report on Maintenance of Legal and Beneficial Ownership Information, Government’s… – Continue reading

Government Issues Beneficial Ownership Report

The Cayman Islands Government today issued a report stating that it will continue its current method of providing beneficial ownership information to law enforcement, tax and regulatory authorities, as the method adheres to global standards. As explained in its Consultation Report on Maintenance of Legal and Beneficial Ownership Information, Government’s… – Continue reading

British Virgin Islands: When Life Gives You Lemons… The BVI And The Global Push For Tax Transparency

It is quite clear that the more recent past has seen a notable shift in the debate from various supranational initiatives implemented over the years, designed to curtail the activities of smaller offshore financial centres, towards the real issues of tax transparency, regulatory cooperation and managing systemic risk in the… – Continue reading

Jersey: Jersey Described As ‘One Of The First And Best’ In Shaping Transparency Landscape At London Conference

Jersey’s positive role in helping to drive forward and shape the international transparency landscape has been praised by a senior OECD tax expert at this year’s Jersey Finance Annual London Private Client Conference. Addressing an audience of more than 400 senior private client tax, trust and wealth management professionals at… – Continue reading

Jersey: Jersey Described As ‘One Of The First And Best’ In Shaping Transparency Landscape At London Conference

Jersey’s positive role in helping to drive forward and shape the international transparency landscape has been praised by a senior OECD tax expert at this year’s Jersey Finance Annual London Private Client Conference. Addressing an audience of more than 400 senior private client tax, trust and wealth management professionals at… – Continue reading

German tax deferral rules infringe EU law

German tax law allows deferring the tax on certain disposal gains by transferring the hidden reserves in the disposed assets to similar newly acquired or newly produced assets (“Replacement Assets”). The tax deferral requires an allocation of the Replacement Assets to a German permanent establishment. The ECJ has recently ruled… – Continue reading

Tax evasion: FBR probing Axact’s foreign assets, transactions

ISLAMABAD: The Federal Board of Revenue (FBR) has decided to launch an investigation into Axact Pakistan (Pvt) Limited’s assets in foreign countries, including the United Kingdom and the United Arab Emirates, bank accounts, credit card transactions and internet marketing in and outside Pakistan. FBR’s subsidiary Directorate General Intelligence & Investigation… – Continue reading

HMRC ramps up tax avoidance crackdown programme

HM Revenue & Customs (HMRC) has referred 30 per cent more individuals and businesses who it thinks have not paid all the taxes they owe, to its specialist unit for ‘serious defaulters’, signalling a toughening up of its approach to tax avoidance, reports Citywire. According to figures obtained by accountancy… – Continue reading

Indian move to check illegal capital outflows

THE BJP-led National Democratic Alliance government, which had made a lot of noise about black money and the illegal stashing of funds abroad in the run-up to general elections last year, finally got down to some serious work to tax ill-gotten wealth and curb its growth. Last week, the government… – Continue reading

UK: Non-UK Domiciliaries: Inheritance Tax Issues And Opportunities

This note is intended as an introduction to inheritance tax (IHT) issues that need to be covered where a “non-dom” (an individual domiciled outside the UK) is planning on becoming resident in, or is already resident in, the UK. It should be emphasised that this is a complex subject, and… – Continue reading

Unnerved by tax demands on capital gains, foreign funds flee for safety

The minimum alternate tax row has damaged the credibility of government promises to enforce an investor-friendly tax regime and made the Indian stock market Asia’s worst performer this year New Delhi/Mumbai: Castleton Investment Ltd, a unit of GlaxoSmithKline Plc (GSK), in 2012 asked an arm of the Indian finance ministry… – Continue reading

Australia: Federal budget 2015-16: Quick guide – the big business measures

Last night, the Federal Treasurer, Joe Hockey MP, released the 2015-16 Federal Budget. After public self-evaluation of its last budget as over-reaching, the Government has gone back to basics whilst still focussing on repairing the budget deficit in the medium to long term. The budget deficit is projected to be… – Continue reading

Chairman Royce, Rep. Pallone welcome US-Amenia Trade & Investment Framework Agreement

House Foreign Affairs Committee Chairman Ed Royce (R-CA) and Congressional Armenian Caucus Co-Chair Frank Pallone (D-NJ) were among the first Congressional leaders to welcome the May 7th signing of the U.S.-Armenia Trade and Investment Framework Agreement (TIFA), a longstanding policy priority for the Armenian National Committee of America (ANCA). Chairman… – Continue reading

OECD BEPS rules to curb multinational profit shifting ready in November

The OECD plans to have international agreement on new tax rules developed as part of its project to tackle aggressive tax avoidance by multinationals through the Base Erosion and Profiting Shifting (BEPS) project by the next G20 summit in November, with implementation completed before 2020 ‘at the latest’ Pascal Saint-Amans,… – Continue reading

HE Obaid Humaid Al Tayer receives British Ambassador to the UAE to discuss bilateral relations between the two countries

HE Obaid Humaid Al Tayer, Minister of State for Financial Affairs, received HE Philip Parham, UK ambassador to the UAE at the Ministry of Finance (MoF) premises in Abu Dhabi. The two parties discussed the bilateral economic relations between the countries and the latest development regarding the rounds of negotiations… – Continue reading

OECD attacks ‘aggressive tax plans’

Technology companies need to stop “extremely aggressive” tax planning, the man charged with reforming global tax rules has told the BBC. He says these “push the boundaries of what is legal”. Pascal Saint-Amans, who runs the OECD’s Centre for Tax Policy, said that new standards would require companies to pay… – Continue reading

OECD condemns Silicon Valley for “extremely aggressive” tax planning

Head of forum’s tax policy will push for reform to cut down on avoidance. The OECD has attacked the “extremely aggressive” tax planning of companies such as Google, Amazon and Apple as it pushes for reform of global tax rules to cut down on avoidance. Pascal Saint-Amans, who heads up… – Continue reading