Category: Government Bodies

Google And The UK Tax System – Tax Avoidance?

For several years now Google has been facing what appears to be a case of tax avoidance in the UK, at some point in time, the company went as far saying it did not make any money from business in the UK all in a desperate attempt to pay less… – Continue reading

BEPS Action Plan 4: Limiting base erosion arising from interest deductions

Debt planning and restructuring is a common mechanism to minimize taxable income by increasing deductions among different entities in a multinational group of companies. As interest on debt is generally a deductible expense of the payor and taxed in the hands of the payee, groups may create intercompany loans to… – Continue reading

Luxembourg set for a “huge change”

Governments around the world want more tax income. There is a widely held feeling that many international companies are basing themselves in places like Luxembourg, Ireland, and the Netherlands to avoid tax. The world’s largest countries have a plan and things will change. What will be the effect on Luxembourg,… – Continue reading

Showdown looming over Singapore bank secrecy laws in UBS tax evasion case

NEWARK, NEW JERSEY (BLOOMBERG) – The US Internal Revenue Service (IRS) sought to make UBS Group turn over records on an account in Singapore held by a US citizen, setting up a showdown with the city-state over its bank-secrecy laws and potentially opening a new front against offshore tax evasion… – Continue reading

India clicks on digital economy with equalisation levy

While equalisation levy appears to be a step to counter double non taxation and protect India’s share of taxation, in its current form it may impact an Indian taxpayer more than foreign MNCs The growth of digital economy entails many benefits, but also poses various tax challenges. These include the… – Continue reading

Forget Panama, try Belgium for a cozy tax deal

The European Commission has concluded that selective tax advantages granted by Belgium under its ‘excess profit’ tax scheme are illegal under EU state aid rules. The European Commission is looking at Member States to assess compliance with EU state aid rules in the context of aggressive tax planning by multinationals,… – Continue reading

South Africa CRS Regulations Come Into Effect

The South African Revenue Service (SARS) has issued final regulations that require certain financial institutions (FIs) to report on accounts held or controlled by foreign residents from March 1, 2016. The OECD’s automatic tax information exchange standard, the Common Reporting Standard (CRS), which the regulations are in response to, obliges… – Continue reading

ICC Chamber of Commerce : welcomes OECD plan to include developing countries in implementation of BEPS

The International Chamber of Commerce (ICC) welcomes the Organisation for Economic Co-operation and Development’s (OECD) plan to allow all countries to participate on an equal footing with OECD and G20 countries in the implementation of the OECD/G20 Base Erosion Profit Shifting (BEPS) plan. The framework announced by the OECD early… – Continue reading

IRS Issues 2016 Non-Resident Withholding Tax Guide

The US Internal Revenue Service (IRS) has updated Publication 515, Withholding of Tax on Nonresident Aliens and Foreign Entities, which covers the obligations of the persons responsible for withholding tax (withholding agents). It is specified that the Publication is for withholding agents who pay income to foreign persons, including nonresident… – Continue reading

No double taxation agreement with Panama; Maltese domicile subject to tax on worldwide income

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

Union Budget 2016 – International tax proposals

With the adoption of the BEPS package, OECD and G20 countries laid the foundations of a modern international tax framework under which profits would be taxed where economic activity and value creation occurs. It is now time to focus on implementation of the recommended changes in a consistent and coherent… – Continue reading

Budget 2016: 9% tax rate regime for India’s first International Financial Centre

The pet project of Prime Minister Narendra Modi – the International Financial Services Centre (IFSC) – housed in the Gujarat International Finance Tec City – has received a boost in the Union Budget 2016/17. The long pending tax issue has been decided with 9 per cent minimum alternate tax (MAT),… – Continue reading

Talking Tax in Shanghai

In Shanghai, Wolfgang Schäuble is urging his fellow G20 countries to put new rules to tackle tax avoidance into law. Back home, business leaders worry that German companies could be left exposed by the new rules if they are introduced unilaterally or go too far. The finance ministers of the… – Continue reading

Important changes and developments in German double tax treaties

1. New double tax treaty between Germany and the Netherlands: tax authorities now bear burden of proof regarding tax- evading or tax-avoiding arrangements A new Double Tax Treaty (DTT) has been in place between Germany and the Netherlands since 01 January 2016. Art. 23 of the DTT introduces an important… – Continue reading

Using tax money to raise taxes

If a member of Congress told you that he was going to use some of your hard-earned tax dollars to support an international organization that demands that you pay higher taxes, what would you say? Unfortunately, the question is not hypothetical, because that is exactly what is now happening. Congress… – Continue reading

BEPS Action Plan 3: Designing effective controlled foreign company rules

A “controlled foreign company” (CFC) is, as the name implies, a foreign company or subsidiary owned by a parent company which is situated in a country different from the parent company’s country of residence. The tax laws of many countries, including the Philippines, do not tax the CFC’s parent company… – Continue reading

Budget 2016: How base erosion and profit shifting (BEPS) brings HR function into focus

Tax function of an organisation was traditionally run from the tax director’s room. Transfer Pricing (TP) was governed by contracts between related parties and this at times resulted in profits moving to legal entities that had contractual rights but had no significant people functions. There were instances of IP Holding… – Continue reading

TIGHTENING THE GLOBAL TAX NET

Its official name is the global standard for automatic exchange of financial account information – these nine words are a simple distillation of an ambitious project to tackle global tax evasion. Known more regularly as the Common Reporting Standard (CRS), it will see government-to-government sharing of account holder information and… – Continue reading

Would the real tax havens please stand

“It is tantamount to an economic blockade”. That’s how Antigua and Barbuda’s Prime Minister, Gaston Browne, described the current withdrawal from Caribbean indigenous and offshore banks of correspondent relationships by US banks. His sentiments were echoed by Dean Barrow and Freundel Stuart, the prime ministers of Belize and Barbados respectively…. – Continue reading

Zambia signing its way out of tax revenues-ActionAid Zambia

A new report from ActionAid titled ‘Mistreated’ released this week has revealed that Zambia has 13 restrictive tax treaties that dramatically restrict the government’s power to tax global companies doing business on our soil and therefore unfairly limit our country’s potential to collect tax revenue. The report also found that… – Continue reading

Treasurers reassess internal structures under BEPS

The OECD’s base erosion and profit shifting (BEPS) project – which is aimed at closing gaps and mismatches in tax laws that conspire to reduce corporate tax liability – is a game-changer for treasury planning. The final reports of the BEPS Action Plan, announced by the Organization for Economic Cooperation… – Continue reading

The ANC’s wealth tax: Double rigging a rigged game

When a rock-star French economist comes to our country to tell us that the surest way to fix inequality is to tax the hell out of the privileged, they are guaranteed a sympathetic audience. And so we will partly have Thomas Piketty to thank when Pravin Gordhan introduces tax hikes… – Continue reading

‘Tax me if you can’: Tax activism of a different kind

It’s unlikely anybody was particularly surprised when Finance Minister Pravin Gordhan announced a number of initiatives to increase the amount of tax revenue; from sugar tax to a “tyre levy” to an increase in a number of existing sin taxes. But it’s perhaps the relaxing of voluntary disclosure rules that… – Continue reading

Who’s got guts enough to go after Canada’s tax-dodging corporations?

In its time, the Irving empire has had plenty of federal contracts — all of them lucrative, many of them controversial. So it wasn’t a surprise to hear that a federal cabinet committee is reviewing Irving’s $26 billion sole-source (but still unsigned) contract to build a fleet of warships for… – Continue reading

UK tops global table of damaging tax deals with developing countries

Treaties limit the tax poorer nations can place on British companies doing business within their borders, says ActionAid. The UK has signed a high number of tax deals with some of the world’s poorest countries, potentially depriving those states of millions in tax revenues every year, according to an analysis… – Continue reading

Country by Country Reporting – Any contours?

Transfer pricing (TP) issues have never been such a critical part of the global economic agenda as they are today. Following the release of the report addressing Base Erosion and Profit Shifting (BEPS) in February 2013, OECD and G20 countries (including India) adopted a 15-point Action Plan to address BEPS… – Continue reading

Budget 2016: Will the govt amend domestic tax laws to help the bleeding infrastructure sector

If January is a month of New Year resolutions, February can be said to be a month of New Financial Year expectations with Indian Government announcing its fiscal policy strategy, including taxation regime for the next financial year. The Union Budget of 2015-16 was the first full budget presented by… – Continue reading

IRS Releases Dirty Dozen Scam List: Don’t be a Victim

Each year, people fall prey to tax scams. That’s why the IRS sends a list of its annual “Dirty Dozen.” Stay safe and be informed – don’t become a victim. If you get involved in illegal tax scams, you can lose money or face stiff penalties, interest and even criminal… – Continue reading

Countries that accept BEPS minimum standards may participate in global tax effort, OECD says

Any country that agrees to adopt the OECD/G20 base erosion profit shifting (BEPS) project minimum standards and pay an annual fee will be allowed to participate in future BEPS project work, according to a plan agreed to by the OECD today. The OECD’s framework for BEPS plan implementation, to be… – Continue reading

Budget 2016: Foreign investors seek a non-adversarial and stable tax regime

Is India back on the world map as a lucrative investment jurisdiction? Does the world see the Make in India dream becoming a reality? Well, the $222 billion investment pledges received during the Make in India week do resonate the revived positive sentiment! In fact, recent policy measures have clearly… – Continue reading

Ding ding, seconds out on Malta’s fight to stop Brussels’s tax plans

Malta has always insisted it is no tax haven, but it employs a system which allows foreign shareholders to claim a six-sevenths’ refund on their taxed dividends, taxed at the maximum 35%. There’s a new battle lining up for the Maltese government inside Brussels: an aggressive fight against tax avoidance… – Continue reading

Wind of Change: IMF Chief Calls For New International Taxation System

Governments globally should take steps to adjust taxation systems to close loopholes allowing multinational corporations to avoid paying taxes in countries of their origin, International Monetary Fund (IMF) Managing Director Christine Lagarde said on Monday. WASHINGTON (Sputnik) – The IMF chief said taxation allows governments to mobilize their revenues. She… – Continue reading

Govt seeks feedback on NZ implementation of OECD, G20 push to ‘end banking secrecy as we have known it’

The Government has released an issues paper on New Zealand’s implementation of an OECD initiative the OECD claims will “end banking secrecy as we have known it.” The OECD’s Automatic Exchange Of Information (AEOI) initiative is setting a global standard for sharing information between countries with the aim of reducing… – Continue reading

Sebi bars 22 brokers for ‘tax evasion’ trades of Rs 8,100 crore

NEW DELHI: Continuing its crackdown on misuse of stock exchange system for tax evasion, regulator Sebi on Wednesday barred 22 brokers from securities market for executing ‘reversal trades’ worth over Rs 8,100 crore to generate fictional profits or losses. However, these trading members would be allowed to function as stock… – Continue reading

Google Paid Just $3.1m EU Tax on $13 Billion Revenue: Report

Search giant Google – now a subsidy of Alphabet Inc. (NASDAQ:GOOG) – transferred around 11.7 billion euros ($13 billion) from its European operations to its accounts in Bermuda in 2014, in order to limit the tax burden on this income. This tax avoidance practice is often known as “Double Irish… – Continue reading

Gulf oil dilemma drives tax reforms to shore up deficits

The oil price slide is driving tax reforms across the region as Arabian Gulf economies seek to shore up a potential US$700 billion deficit. All six Arabian Gulf states are planning to introduce Value Added Tax (VAT) collectively. Various other tax reforms are also underway. The IMF warned in October… – Continue reading

A tax haven professes to stand on principle, risking pariah status

PANAMA’S most notorious moment as a haven for tainted cash came with the nationalisation of money-laundering in the 1980s under Manuel Noriega, a military strongman. It has since clamped down on egregious financial criminality, but remains home to thousands of secretive firms and famous for the discretion of its bankers… – Continue reading

Malta retains Fitch ‘A’ rating with 3.2% growth that outperforms eurozone

Malta’s deficit will go down to an unprecedented 1% of GDP and debt will be cut to 64.3% of GDP in 2017. Minister for Finance Edward Scicluna has welcomed Malta’s stable ‘A’ Fitch Rating , saying the latest report, published last night, “shows that Malta’s economy will keep on growing.”… – Continue reading

EU and Andorra sign deal to curb tax evasion

The EU and Andorra have signed a new tax transparency agreement that will make it harder for EU citizens to stash undeclared income in financial institutions in Andorra. The agreement is in line with EU’s effort to increase tax transparency and tackle tax avoidance and evasion. This deal complies with… – Continue reading

Tanzania: Information Exchange With Tax Bodies

Double tax treaties enable competent authorities of the treaty partners to exchange important tax information necessary for implementing the treaty or the domestic laws on taxes of every kind and description imposed. For instance, exchanges of information may be made regarding tax avoidance by companies of the contracting states.Nevertheless information… – Continue reading

Revealed: how Project Goldcrest helped Amazon avoid huge sums in tax

Documents released during the internet giant’s court battle with the US Internal Revenue Service over a possible $1.5bn in unpaid taxes detail a complex restructuring and a deal with Luxembourg that delivered Amazon multimillion-dollar savings Amazon is facing a landmark court ruling in the US that could prise open its… – Continue reading

A global revolution in corporate tax is taking place but it will not be televised

A quiet revolution is taking place across Europe. It isn’t playing out on the streets of capital cities or in the debating chambers of national parliaments. It has been slowly happening with every newspaper headline about how little corporation tax some companies pay relative to their size. It is also… – Continue reading

Cayman Islands: Getting Up To Date On FATCA – A Recap And Update

What is FATCA? FATCA refers to US legislation more fully known as the Foreign Account Tax Compliance Act and includes the US Treasury regulations implementing it. It was enacted as part of the Hiring Incentives to Restore Employment Act of 2010 (otherwise known as the, “HIRE Act”) on 18 March… – Continue reading

A New Set of Amendments to the Russian CFC and Beneficial Ownership Rules

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

The biggest loophole of all

Having launched and led the battle against offshore tax evasion, America is now part of the problem DEVIN NUNES raised eyebrows in 2013 when, as chairman of a congressional working group on tax, he urged reforms that would make America “the largest tax haven in human history”. Though he was… – Continue reading

The OECD Action Plan – What’s Next?

The 15 part action plan aims to tackle global inequalities in taxation income, increasing transparency for tax administrators and significantly improving Multinational Enterprises’s compliance. With tax regulations of large corporations at the forefront of all policy makers’ minds, this latest endeavour from the OECD and G20 will address the varying… – Continue reading

EU tax changes vs Singapore’s sovereignty

Last month the European Commission launched its Anti Tax Avoidance Package, propelled by unprecedented political support for the fight against perceived tax avoidance by multinationals. In it the European Union stresses its full support for recent recommendations of the Organisation for Economic Cooperation and Development’s (OECD) BEPS project and it… – Continue reading

Kenya makes strides in tackling illicit financial flow

As part of strategic effort to tackle cases of international tax avoidance and evasion, Kenya has joined the league of 93 global nations; united to address the economic vices and has now signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. The signing of the crucial agreement, last… – Continue reading