Maltese individuals resident and domiciled for tax purposes, that is people whose permanent residence is in Malta, are required to pay tax in Malta on their worldwide income, according to the Income Tax Act. This essentially means that Minister Konrad Mizzi is required to pay tax on foreign earnings. However… – Continue reading
Russian firms that have a controlling stake outside the country can no longer apply for state support, according to a new law signed by President Putin on Monday. This includes Russian legal entities with more than 50 percent in authorized capital abroad. The law applies not only to the principals,… – Continue reading
On February 15, 2016, the President of the Russian Federation signed Federal Law No. 32-FZ “On Amendments to the First and Second Parts of the Russian Tax Code (with Respect to the Taxation of Controlled Foreign Companies and the Income of Foreign Organizations)”, introducing a new set of amendments to… – Continue reading
Kenya will now be able to pursue individuals who use offshore companies to evade taxes and commit other economic crimes, after it signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters last week. The agreement is the most comprehensive multilateral instrument available for all forms of cooperation to… – Continue reading
Russia has come close to blacklisting the UK as a tax haven as concerns grow over Scotland’s booming offshore business. The Kremlin’s Finance Ministry had announced that it would officially equate Britain with traditional “fiscal paradises” like Panama, the British Virgin Islands and the Caymans. Such a humiliating move would… – Continue reading
Rules should require foreign owners of prime London homes to come clean about beneficiary owners, say anti-corruption groups Large parts of London’s Baker Street, including the Beatles store, are owned by offshore trusts. New laws that aim to stop the UK being a magnet for money launderers – by forcing… – Continue reading
Over the last two decades, an increasing number of companies have chosen to register or establish subsidiaries in offshore financial centres. OFCs are characterized by low taxation, flexible regulations, and secrecy policies (see Fig 1 for the list of OFCs, ranked by Offshore Attitude Index). Many companies with subsidiaries offshore… – Continue reading
The Isle of Man has refused London’s call to reveal the ownership of thousands of offshore companies, joining other UK Overseas Territories in resisting David Cameron’s transparency push. The Isle of Man told the Financial Times it is a “red line” issue, joining jurisdictions including Bermuda and the Channel Islands… – Continue reading
The US’s Financial Crimes Enforcement Network has announced it will be investigating the individuals behind secretive all-cash purchases of high-end luxury real estate in a six-month trial programme intended to enhance the treasury’s anti-money laundering efforts. The initiative will focus on all-cash property purchases of over $3 million in New… – Continue reading
A Highland hideaway – situated on a private island in the River Beauly in Inverness-shire – has been snapped up for £7million by the Qatari royal family, it has been claimed. The 545-acre Eilean Aigas Estate comes with it a massive luxury mansion, is described as one of the best… – Continue reading
A web of offshore companies was used to shield controversial builder Tom McFeely’s ownership of an apartment building close to London’s Olympic stadium, an Insolvency Service official has claimed. The allegation was one of several levelled against the Priory Hall developer as part of proceedings issued by official assignee Christopher… – Continue reading
Offshore deposit accounts allow many people to run their business successfully. Monetization of income derived from the use of offshore companies is impossible without such accounts. In addition, security of funds on offshore accounts is much higher than in conventional banks. Each offshore financial institution has its own scheme to… – Continue reading
If the place of effective management of a foreign company is established in India, then it becomes tax resident as per domestic laws The Finance Act, 2015, amended the provisions of the provisions of income tax act relating to determination of residence of a company. According to the amended provisions,… – Continue reading
The Department of Justice announced today that Union Bancaire Privée, UBP SA (UBP), reached a resolution under the department’s Swiss Bank Program. UBP will pay a penalty of more than $187 million. “Today’s agreement marks the final resolution with UBP, which acknowledges its role in conspiring with U.S. taxpayers to… – Continue reading
Non-Belgian shareholders with a participation in a Belgian company with an acquisition value of at least €2.5m (but not reaching the 10 per cent participation threshold under the Parent–Subsidiary Directive) are now entitled to the Belgian participation exemption regime. In C-384/11 (Tate & Lyle Investments), the European Court of Justice… – Continue reading
SEATTLE — When someone in Seattle buys a copy of Office at a Microsoft Store, that cash doesn’t take the short route to the company’s area headquarters. Instead, after accounting for state taxes, the profit goes to a Microsoft sales subsidiary in Nevada. From there, much of that money begins… – Continue reading
A deadline for comments on the draft guidelines to determine the tax residency of a foreign company has been extended to January 9. The government felt the need to determine a company’s place of effective management due to lack of detail in the Income Tax Act leading to the possibility… – Continue reading
VietNamNet Bridge – The agreements on double taxation avoidance that Vietnam has signed with other countries is one of the reasons that have made it impossible for state agencies to clarify the suspected cases of multinational conglomerates conducting transfer pricing. A lot of multinational conglomerates such as Coca-Cola, Metro Cash… – Continue reading
MUMBAI: Many manufacturing and trading subsidiaries of Indian companies that are currently operating independently outside India may have to pay taxes in India as they could fail the new test set under the Place of Effective Management (POEM) guidelines. Not just that, some of the companies could see complications with… – Continue reading
US Democratic presidential hopeful Bernie Sanders has pledged a crackdown on tax avoidance involving Bermuda and other offshore jurisdictions. Mr Sanders, currently trailing Hillary Clinton in the race for the nomination as presidential candidate, made the promise on an online political channel in America. Mr Sanders said he would use… – Continue reading
“Cash Booked Offshore for Tax Purposes by U.S. Multinationals Doubled between 2008 and 2014” In recent years, U.S. multinational companies have sharply increased the amount of money that they book to foreign subsidiaries. An April 2015 study by research firm Audit Analytics found that the Russell 1000 list of U.S…. – Continue reading
A BALANCING ACT in London, folly and redemption in America’s District of Columbia and sheer hypocrisy in Brussels. And in every case, Barbados and many of its Caribbean neighbours were placed in the negative international spotlight at a time when some of the world’s major financial centres are casting about… – Continue reading
Legal experts say court order for restaurant’s parent company based in British Virgin Islands could lead to resolution of more disputes in city Hong Kong’s top court recently gave the go-ahead for the parent company of the famous Yung Kee roast goose restaurant in Central to be wound up, despite… – Continue reading
Apple CEO says the company pays ‘every tax dollar we owe’ amid debate in the US over corporations avoiding tax by using offshore units Apple’s chief executive Tim Cook has dismissed as “total political crap” the notion that the technology giant was avoiding taxes. Cook’s remarks, made on CBS’ 60… – Continue reading
When purchasing a real property overseas, there are situations when it may prove advantageous or even necessary to do so through an offshore corporation, rather than owning the property individually. It is crucial to understand that this can also have significant US tax consequences for US persons. Fortunately, “checking the… – Continue reading
The Department of Justice announced today that Edmond de Rothschild (Suisse) SA and Edmond de Rothschild (Lugano) SA (collectively EdR Switzerland) reached a joint resolution under the department’s Swiss Bank Program. EdR Switzerland will pay a penalty of more than $45 million. The Swiss Bank Program, which was announced on… – Continue reading
Dreyfus Sons & Co. has operated for two centuries as a private Swiss bank, catering to Jewish clients who wanted to hide assets from the Nazis during the 1930s and World War II. More recently, it helped U.S. clients hide assets from the Internal Revenue Service by concealing their true… – Continue reading
Australian tax authorities on Thursday took the unprecedented step of publishing the records of hundreds of companies, including Google Inc (GOOGL.O) and Apple Inc APPL.O, which show they paid little or no tax on their in-country earnings. Of more than 1,500 largely foreign-owned companies which reported total earnings over A$100… – Continue reading
RIGA – The Latvian Financial and Capital Markets Commission (FCMC) on Dec. 11 imposed a record 2-million-euro fine on Ukrainian-owned A/S Privatbank and ordered the dismissal of its CEO and managing board for violations of money laundering and other banking regulatory laws in connection with the alleged plundering and collapse… – Continue reading
For the Socialist Senator Roberto Zanetti, the reform is an open-heart surgery, which must be done with great accuracy. Under pressure from the EU, G20 and the OECD, also Switzerland is obliged to give up his special tax regimes for holding companies and management companies. After years of negotiations with… – Continue reading
Why would anyone object to Uber, the user-friendly online drive-share service? Uber’s many riders obviously love it, but it seems civic officials are having conniptions. Their main complaint is that Uber drivers are unlicensed to carry passengers and might not have adequate insurance. In addition, officials are genuinely concerned that… – Continue reading
Dividend income from foreign companies is not treated the same as dividend from domestic companies, for tax purposes The two key advantages of investing in equities are the possibility of higher returns and tax efficiency. In the long term, equity has outperformed other asset classes. And, according to Income tax… – Continue reading
The Australian Taxation Office (ATO) has released a Taxpayer alert on arrangements involving the use of offshore entities which source goods (procurement hub) on behalf of Australian resident multi-national enterprises (MNEs) (TA 2015/5). In the alert the ATO announces that it is currently reviewing arrangements involving the use of offshore… – Continue reading
The BVI Business Companies Act 2004 (“BCA“) is shortly due to be amended by the BVI Business Companies (Amendment) Act 2015 (the “Amendment Act”). As well as keeping the British Virgin Islands (“BVI“) corporate regime at the forefront of compliance with international standards, the Amendment Act is intended to provide… – Continue reading
(CN) – A Russian nuclear energy official living in Maryland has been sentenced to four years in federal prison on money laundering charges, the Justice Department announced Tuesday. Vadim Mikerin, 56, of Chevy Chase. Md. was also ordered to forfeit more than $2.1 million, after he pleaded guilty to charges… – Continue reading
The UK Government has confirmed that it will legislate for a new criminal offense for corporations that fail to take adequate steps to prevent the facilitation of tax evasion. Tax authority HM Revenue and Customs (HMRC) has published responses to four consultations on anti-evasion measures announced at the March 2015… – Continue reading
FATCA (the Foreign Account Tax Compliance Act) came into force in July 2014. It is far-reaching and may impose a compliance burden on the trustees of New Zealand family trusts, even if no US persons are involved. IRD has recently issued further draft guidance on the application of FATCA to… – Continue reading
On Sept. 3, 2015, a bill to amend the Act on the Protection of Personal Information (APPI)1, the main privacy law in Japan, was passed by the National Diet. This is the first major amendment to the APPI since the original version of the APPI took effect in 2005. The… – 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
Over recent years, Kingdom of Morocco has created a legal and regulatory framework very attractive for foreign investors. In addition to its political stable environment, a recent series of tax treaties with numerous countries and reforms in almost all of its sectors of activities, in conjunction with its creation of… – Continue reading
The Central Board of Direct Taxes (CBDT) has recently entered into eleven (11) more Advance Pricing Agreements (APAs) with Indian subsidiaries for foreign companies. In a major push towards providing certainty to foreign investors in the arena of transfer pricing, the CBDT signed these APAs operating in various segments of… – Continue reading
HM Revenue & Customs (HMRC) today published the results of its consultation, alongside draft legislation, for a proposed criminal offence for companies which fail to prevent the facilitation of tax evasion. The draft legislation lays down provisions for a criminal offence where somebody who is performing services on behalf of… – Continue reading
Many US citizens resident in Jamaica are unaware of the tax compliance requirements of FATCA. Notwithstanding, this article is not about providing full information or professional advice about FATCA. That information can be obtained in a variety of ways. This article is about informing those who do not yet know… – Continue reading
Following persistent demands from the United Kingdom that its Offshore Territories include beneficial ownership information on public central registers, it was agreed at the Overseas Territories Joint Ministerial Council (JMC) that “similarly effective systems” are a permissible alternative. A joint statement after the JMC meeting said: “We agreed to hold… – Continue reading
MUMBAI: India has been an active participant in the Base Erosion and Profit Sharing (BEPS) action plan, the final package of which was rolled out by the Organisation for Economic Co-operation and Development (OECD) in October. The action points, set down by the OECD, aim at closing loopholes that enable… – Continue reading
Explosives maker Orica will take a $36 million hit to its bottom line after the Federal Court found it had avoided tax by using “round robin” financing arrangement it put in place a decade ago to boost its profit and ward off takeover bids. BusinessDay revealed Orica’s battle with the… – Continue reading
The Internal Revenue Service (IRS) continues its focus on perceived abuses in corporate inversion transactions. On November 19, the IRS released Notice 2015-79, which places new limitations on the ability of a U.S. multinational corporation to reduce its U.S. tax burden by inverting its corporate structure. U.S.-based multinationals are subject… – Continue reading
The Circular of the State Administration of Taxation on Strengthening the Administration of Corporate Income Tax on Incomes of Equity Transfers of Non-Resident Enterprises (“Circular 698”) was issued in 2009 to regulate tax treatment of indirect transfers of equity interest in a domestic Chinese company by non-residents. Circular 698 empowered… – Continue reading
The Circular of the State Administration of Taxation on Strengthening the Administration of Corporate Income Tax on Incomes of Equity Transfers of Non-Resident Enterprises (“Circular 698”) was issued in 2009 to regulate tax treatment of indirect transfers of equity interest in a domestic Chinese company by non-residents. Circular 698 empowered… – Continue reading
Tata Steel’s Singapore arm T S Global Holdings Pte raised $1.5 billion debt to settle outstanding loans, the company said in a statement. Tata Steel group executive director-finance and corporate Kaushik Chatterjee said, “Tata Steel actively reviews all its financing options and seeks to continuously optimise its debt based on… – Continue reading
