On 15 September 2015, the Dutch government released its budget for 2016, containing the Tax Plan 2016, which includes certain amendments to Dutch tax law. One of the proposed amendments was the inclusion of an anti-hybrid rule in the Dutch participation exemption regime (“PER”). On 22 December 2015, the amendments… – Continue reading
Luis E. Benitez VEGAS Already after two years of discussions on the various actions designed by the Organization for Economic Cooperation and Development (hereinafter OECD) to address the problem of the erosion of the tax base and the transfer Benefits under the BEPS project (for its acronym in English Base… – Continue reading
On December 18, 2015 the Inland Revenue Authority of Singapore issued a press release announcing that on that same date the Agreement between the Government of the Republic of Singapore and the Government of the Republic of Ecuador for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading
On September 17, 2015, the IRS issued a statutory notice of deficiency to the Coca-Cola Company, increasing its federal income taxes for 2007-2009 by $3.3 billion, based primarily on transfer pricing adjustments exceeding $9 billion. On December 14, 2015, Coca-Cola petitioned the U.S. Tax Court to overturn the adjustments. This… – Continue reading
The Protocol amending the Multilateral Convention on Mutual Administrative Assistance in Tax Matters will lead to substantially more transnational identity theft, crime, industrial espionage, financial fraud, and the suppression of political opponents and religious or ethnic minorities by authoritarian and corrupt governments. It puts Americans’ private financial information at risk…. – Continue reading
The organization’s new ambassador in the Brazilian capital Brasília claims trade and mutual investment between Arab countries and Brazil can be worked on. São Paulo – Newly appointed to represent the Middle East and North Africa countries in Brazil, the ambassador of the League of Arab States in the national… – Continue reading
In the context of a series of recent developments on the tax treatment of cross border services payments from Brazil, the Superior Court of Justice (STJ) recently ruled that payments for services performed by a Spanish company without permanent establishment in Brazil are not subject to withholding income tax in… – Continue reading
Given that the latest treaty was signed on 15 November 1967, the two countries felt it was appropriate to revise it in full. The new treaty, signed on Tuesday by the Spanish Ambassador to Finland, María Jesús Figa, and the Finnish Minister for Finance, Alexander Stubb, seeks to enable tax… – Continue reading
On the 29th of September of this year, one of the most important and controversial norms of the tax reform: the general anti-avoidance rule came into effect. This norm intends to cutback aggressive tax planning providing new faculties to the Chilean IRS. Indeed, this norm has incorporated what is widely… – Continue reading
Latvian President Raimonds Vejonis on December 15th accepted the credentials of the Japanese Ambassador to Latvia, Mariko Fujii, and noted an increase in Latvia-Japan trade recently but said there was still room for growth in economic cooperation, the Latvian president’s press service reported LETA. He said that a treaty for… – Continue reading
It’s been proved that the Argentina international did not receive money for the matches A Barcelona judge has archived the case against Lionel Messi regarding a claim he committed tax fraud in relation to six charity matches he participated in in 2012 and 2013, concluding that the Argentine international did… – Continue reading
Dec. 14 — The Coca-Cola Co. filed a petition in U.S. Tax Court challenging a proposed $9.4 billion income adjustment related to the company’s transfer pricing for tax years 2007-09 (Coca-Cola Co. v. Commissioner, T.C., petition filed, 12/14/15). If the adjustment is sustained, the company could face a tax bill… – Continue reading
There are a variety of benefits to moving offshore, yet few would argue the assertion that tax neutrality is paramount among them. As anyone familiar with the phrase “tax haven” would surely recognize, many countries offer strongly favorable tax terms as an incentive to draw new business. Written by CT… – Continue reading
Firms over a certain threshold group turnover may be required to give detailed info of financials. MULTINATIONAL companies in India over a certain threshold group turnover may be required to make comprehensive disclosures relating to their revenues, taxes paid, staff strength and assets in different countries where they operate from… – Continue reading
The Department of Justice announced today that Cornèr Banca SA (Cornèr) and Bank Coop AG (Bank Coop) reached resolutions under the department’s Swiss Bank Program. The Swiss Bank Program, which was announced on Aug. 29, 2013, provides a path for Swiss banks to resolve potential criminal liabilities in the United… – Continue reading
SOUTH Africa ranks seventh among developing countries in terms of illicit financial outflows, a Washington-based research organisation has found. Illicit outflows from the country are of great concern to the Treasury, which has introduced a number of measures to curb it, particularly the outflows achieved through profit shifting by large… – Continue reading
More than 50 banks which helped American clients dodge tax in Swiss bank accounts have received immunity from criminal prosecution in the US. The firms, which include UK giant Standard Chartered, Germany’s biggest lender Deutsche Bank, and France’s BNP Paribas, have reached plea bargains with the US Department of Justice…. – Continue reading
Amit Ramnani, director of Ipanema Wealth, an independent financial consultancy firm, discusses year-end tax planning techniques for U.S. expatriates. RIO DE JANEIRO, BRAZIL – Amit Ramnani, director of Ipanema Wealth, reminds U.S. expatriates that they still have time to apply some year-end tax-planning techniques. U.S. citizens who are resident in… – Continue reading
Corporate tax revenues have been falling across OECD countries since the global economic crisis, putting greater pressure on individual taxpayers to ensure that governments meet financing requirements, according to new data from the OECD’s annual Revenue Statistics publication. Average revenues from corporate incomes and gains fell from 3.6% to 2.8%… – Continue reading
Bidness Etc takes a look at how Shell-BG merger is right on track, after receiving approval from Australia’s Foreign Investment Review Board Royal Dutch Shell plc (ADR) (NYSE:RDS.A) is just one step away from closing a merger deal with BG Group plc. On Thursday, December 3, the Anglo-Dutch company received… – Continue reading
Legislative Decree approving the Agreement between Brazil and the United States of America for Tax Information Exchange and Instruction 1571/15 IRS On 26th June 2015, Legislative Decree No, 146/15 (“Decree“), which approved the agreement between Brazil and the United States to allow the exchange of information under the Foreign Account… – Continue reading
WELCOME to Switzerland. A mountainous country where nothing comes cheap but many of the world’s filthy rich come to grow their fortunes. The ongoing relationship between the wealthy and Switzerland looks set to only strengthen as the super rich get richer, according to a report released on Friday. That’s despite… – Continue reading
The new Income and Capital Tax Treaty between Switzerland and Argentina entered into force on 27 November 2015. The new treaty generally applies from 1 January 2015 for withholding taxes and from 1 January 2016 for other taxes and article 25 (Exchange of information). The new agreement will replace the… – Continue reading
Barely a week goes by without Deutsche Bank featuring in the news for some reason, usually a bad one. This time, it’s tax avoidance. The FT reports that Deutsche Bank “has been devising complex tax avoidance strategies for some of its largest corporate clients”. Not that this is illegal, of… – Continue reading
AFIP tax bureau will charge between three and eight percent as a penalty for evasion Amid a shortage of dollars and decreasing foreign-currency reserves at the Central Bank, president-elect Mauricio Macri will try to entice Argentines with undeclared assets and foreign currency to take part in a new tax amnesty… – Continue reading
East African countries expect to collect more revenue under a new code drawn, by the world’s richest economies to stop foreign multinationals from dodging taxes in host countries. The new code — Base Erosion and Profit Shifting (BEPS) — adopted by G20 at its meeting in Turkey two weeks ago,… – Continue reading
The OECD published 13 final reports along with an explanatory statement under its base erosion and profit shifting (BEPS) project on the 5th October 2015. This was endorsed three days later on the 8th October 2015 by the G20 Finance Ministers’ meeting in Peru’. The BEPS project outlines 15 action… – Continue reading
Protecting the tax base of extractive industries, moving toward more responsive and flexible fiscal regimes, and improving international cooperation have become priorities in the Andean region, as commodity prices and revenues from extractive industries continue to decline, participants at a recent IMF conference heard. The three-day conference, Determining the Tax… – Continue reading
Bern, 11.24.2015 – Four additional double taxation agreements (DTAs) have entered into force between Switzerland and Cyprus, Iceland, Estonia and Uzbekistan. They contain provisions on mutual assistance in accordance with the internationally applicable standard. At the same time they promote the development of bilateral economic relations. With Cyprus, Switzerland has… – Continue reading
Bern, 24.11.2015 – On 23 November 2015, Switzerland and Brazil signed in Brasilia an agreement on the exchange of information on tax matters (“Tax Information Exchange Agreement” TIEA). The Agreement with Brazil is the tenth TIEA signed by Switzerland. The agreement deepens the bilateral relations between Switzerland and Brazil. Switzerland… – Continue reading
WILLEMSTAD – A 20-member delegation from Curaçao participated in the STEP Latin America Conference (STEPLatAm) 2015, which was held on the 22nd and 23rdof October at the Renaissance Hotel in Sao Paulo, Brazil. The STEPLatAm conference is a leading conference for wealth structuring and trust and estate practitioners. During the… – Continue reading
The creation of the Group of Twenty (G20) was believed to serve as a remedy to the harsh realities of the world today. The initial formation of the Group of Seven G7 could do little to avert pertinent challenges both the developing and the developed nations face frequently. So a… – Continue reading
In recent days, the new Speaker of the House Paul Ryan (R-Wis.) signaled a priority for international tax reform in 2016. And if the newest recommendations from the Organization of Economic Cooperation and Development (OECD) are any indication of what’s ahead on the global tax scene for American businesses, it… – Continue reading
Brazil’s federal government has submitted a bill to the Senate to establish a voluntary disclosure programme that would allow companies and individuals to regularise any undeclared offshore assets without facing criminal prosecution. The Special Regime for Exchange and Tax Regularisation (RERCT) will levy a 15% fine on top of the… – 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
Eight tax treaties and protocols were passed forward for a ratification vote by the full US Senate at a business hearing of the Committee on Foreign Relations on November 10, reports Tax News. The Committee approved the new US double taxation agreements (DTAs) with Chile and Hungary, and protocols to… – Continue reading
Lionel Messi wants a staggering £600,000 a week to play in the Premier League. The four-time World Footballer of the Year is open to a move to England after falling foul of the tax authorities in Spain. But the Barcelona superstar’s staggering demands look to have priced him out of… – 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
Normative Instruction no. 1.474, of June 20, 2014, excluded Switzerland from the list of Jurisdictions with Favoured Tax Treatment (JTF) and included it in certain cases within the concept of privileged tax regime (RFP). The matter is now governed by Law no. 11.727 which, as well as widening the concept… – Continue reading
Facts A Peruvian company (Company A) offered its services in Chile and had a commercial relationship with a Chilean company (Company B). Both companies were under shared ownership. The Tax Administration decided to assess withholding taxes for services that Company A rendered for Company B, as it considered the latter… – Continue reading
PSDB amendment in Lower House cuts Speaker Cunha out of deal, but Senate still has final say BRASILIA — The Lower House of Brazil’s Congress has approved a controversial amnesty bill for undeclared offshore assets, despite criticism from opposition lawmakers who say it would allow the laundering of illegally gained… – Continue reading
Ahead of a G20 meeting in Turkey this weekend that will tackle, among other issues, the GDP lost to global tax havens, the anti-poverty organization Oxfam is warning that it’s not just poor countries that suffer when corporations evade taxes. Julie Delahanty, Oxfam Canada’s executive director, says the only people… – Continue reading
The Senate Foreign Relations Committee has approved, for a second time, the following income tax treaties and Protocols. 12 November 2015 Switzerland: A Protocol to amend the income tax treaty with Switzerland—the Protocol was signed in 2009. Luxembourg: A Protocol to amend the income tax treaty with Luxembourg—the Protocol was… – 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
BRASILIA, Nov 11 (Reuters) – The lower house of Brazil’s Congress approved amnesty for undeclared offshore assets on Wednesday despite criticism from opposition lawmakers who said it would allow the laundering of illegally gained money. To reduce its budget deficit, President Dilma Rousseff’s government is hoping to raise 11 billion… – Continue reading
In a surprising development, the US Senate Committee on Foreign Relations on November 10 approved without amendment eight pending US tax treaties and protocols. Proposed income tax treaties with Chile, Hungary, and Poland; proposed tax protocols with Japan, Luxembourg, Spain, and Switzerland; and a proposed protocol amending the multilateral mutual… – Continue reading
According to the Brazilian FM Mauro Vieira, the country is in talks for an agreement to avoid double taxation in air transport with Egypt. The Arab country plans on creating the route once the deal is in place. Riyadh – The Egyptian carrier EgyptAir could launch a route to Brazil,… – Continue reading
Riyadh, Muharram 29, 1437, Nov 11, 2015, SPA — Dr. Ibrahim bin Abdulaziz Al-Assaf, Minister of Finance, signed here today an agreement of avoidance of double taxation and prevention of tax evasion with respect to taxes on income with Venezuelan Minister of People’s Power for Economy and Finance Rodolfo Marco… – Continue reading
The Caribbean island says its financial system is all aboveboard, yet it remains a gateway to less scrupulous offshore havens like the Cayman Islands. BRIDGETOWN — Is there “dirty” money strewn across the pristine sands of Barbados? Does something sinister hide beneath the glistening coral reefs of this former pirate… – Continue reading
