The UK government released draft regulations for country-by-country (CbC) reporting, to implement Action 13 of the OECD’s base erosion and profit shifting (BEPS) project. The draft UK regulations broadly reflect the OECD reports, released 5 October 2015, and specifically make reference to the model legislation. Key points of the CbC… – Continue reading
The Government has expressed a commitment to improving levels of UK corporate transparency but a recent Private Eye article [1], documenting the extent of ownership of British Land through offshore entities, shows just how far there is to go. By far the most common reason for owning UK property through… – Continue reading
The CBDT has clarified that MAT provisions will not be applicable to those FIIs /FPIs which do not have a permanent establishment in India, for the period prior to 1 April 2015. An amendment to the IT Act will be made in the winter session of Parliament and directions have… – Continue reading
As a business leader, EY is proud to announce a seminar from its series of regulatory updates, aimed to keep stakeholders abreast of current changes in legislation. The FATCA and OECD Common Reporting Standard (CRS) seminar will be held on October 20, 2015 at the Hilton, St Julian’s between 08:30… – Continue reading
Emmanuel Mayah, Jeff Mbanga, Francis Kokutse and Nick Mathiason contributed to this joint investigation by the M&G Centre for Investigative Journalism (amaBhungane) and Finance Uncovered, a global reporting project involving journalists in 54 countries. Shortly after Cyril Ramaphosa left MTN to become South Africa’s deputy president last year, he lashed… – Continue reading
The fallout for Australian firms from the BEPS project “won’t be radical in Australia, as we have already moved pre-emptively to strengthen our laws,” Assistant Treasurer Kelly O’Dwyer has said. Commenting on the release of the OECD’s final BEPS reports, O’Dwyer said: “The Coalition Government’s measures line up with the… – Continue reading
Corporate income tax Italian corporate income tax (imposta sul reddito delle società, or IRES) is due by resident companies on their worldwide income. A company is deemed to be resident within the Italian territory when it has any of the following elements located in Italy for the major part of… – Continue reading
(CNS Business): Government faces some serious challenges over the next 18 months to update the regulatory regime that protects the country’s financial service sector ahead of a task force inspection in March 2017. Francis Arana, head of the Anti-Money Laundering Unit in the Attorney General’s Chambers, who is coordinating the… – Continue reading
The Russian government has approved legislation that would conceal property owned by state officials and would hamper anti-corruption investigations, Transparency International (TI) warns. The move to make the state property registry secret is not yet law – it still has to go before parliament. TI, an anti-corruption watchdog, said the… – Continue reading
The global war on corporate tax avoidance doesn’t look like being so gruesome after all. The OECD reckons that governments are losing out on at least €213bn per year from aggressive tax planning by multinationals, reports the Irish Independent. A new book by a Berkeley University economics professor estimates that… – Continue reading
Tax evasion is a real threat to the global economy, and the biggest culprits are large corporations abusing loopholes to avoid paying taxes. According to research estimates, a total of US$240 billion worth of taxes is not being paid by corporations all over the world. Such a vast sum of… – Continue reading
Senior tax executives are preparing for changes in the tax landscape as a result of the Organization for Economic Co-operation and Development’s base erosion and profit shifting project. A new survey by Ernst & Young, presented Thursday at its 34th Annual International Tax Conference, found 88 percent of tax directors… – Continue reading
New Zealand needs to be careful not to get out of step with the rest of the world in implementing tax changes on multinational companies seeking to minimise their tax obligations, Deloitte Dunedin tax partner Peter Truman says. The Government this week released a report on Base Erosion and Profit… – Continue reading
Multinationals selling more than $75k into Australia asked to comply. The Australian government has released its revised exposure draft of legislation that would see GST added to all locally-bought digital products and services sold by overseas vendors by July 2017. In May this year former Treasurer Joe Hockey revealed plans… – Continue reading
Government should look to the example set by Barbados and start charging Value Added Tax (VAT) on betting and gaming activities in Trinidad and Tobago. This was the advice coming from Tax Director of KPMG’s TT operations, Nicole Joseph, during a post-budget forum hosted by the American Chamber of Commerce… – Continue reading
In brief On 18 September 2015, Treasury released exposure draft legislation in relation to the implementation of the Organisation for Economic Co-operation and Development’s (OECD) Common Reporting Standard (CRS) for the automatic exchange of financial account information. The CRS is intended to reduce international tax evasion and represents the next… – Continue reading
On October 5, 2015, the OECD released its final reports relating to the OECD/G20 base erosion and profit shifting (BEPS) project (the Final Reports). The BEPS project began in 2013 and has received unprecedented attention from governments and the private sector. The Final Reports outline the OECD’s recommendations and the… – Continue reading
Hervé Falciani, who exposed the global offshore industry with the HSBC data leak, is facing prosecution under skewed Swiss laws for data theft and espionage. This is his story. Swiss justice hounds those who breach banking secrecy even if in doing so they expose rogue banks. In the past decade,… – Continue reading
The Australian Tax Office will open negotiations with 80 multinational companies to encourage them to “restructure” in order to pay more tax on profits generated in Australia. The move represents a near tripling of the ATO’s multinational watch list after it embedded staff inside 30 companies to learn more about… – Continue reading
Patent box regimes typically apply deeply discounted tax rates to income derived from intellectual property. Recently unveiled draft legislation may pave the way for a US patent box regime and incentivize taxpayers to reevaluate their global structures. Introduction The US imposes the highest corporate income tax rate (35%) in the… – Continue reading
Federal government increases number of companies under tax office scrutiny from 30 to 80 under budget measures announced in May The federal government has widened the scope of legislation aimed at tackling multinational tax avoidance, increasing the number of large companies under the tax office’s microscope from 30 to 80…. – Continue reading
Uber and Airbnb have revealed in submissions to a federal inquiry that they route profit through companies in the Netherlands and Ireland, where taxes are lower. Uber and Airbnb have told a Senate corporate tax avoidance inquiry that while they comply with Australian tax laws, their Australian operations merely provide… – Continue reading
Supporters of a plan to tax overseas profits to pay for U.S. transportation projects said Wednesday the proposal is the “only possible path forward” for passing a highway bill in the House this month. The sponsors of legislation in the House containing the offshore taxes-for-roads proposal said the plan, known… – Continue reading
The government intends to crack down on tax evasion by adopting best practices from other countries, Greek Alternate Finance Minister Tryfon Alexiadis said in Parliament on Tuesday, during the debate on the government’s policy statements. Among others, he announced plans to follow the German model for tax inspections, in which… – Continue reading
The location of a holding company is a significant consideration in any international corporate structure. Choice of jurisdiction for a group holding company (‘Holdco’) is relevant both from the point of view of tax optimisation (maximising withholding tax free dividend, interest and royalty flow up through the group and minimising… – Continue reading
For many years international tax planning for Russian inbound and outbound investments, and wealth planning for Russian resident individuals, was rather straightforward. That was primarily due to relatively simple domestic tax rules and a degree of inexperience amongst the Russian tax and other interested authorities in relation to international tax… – Continue reading
The UK Government’s consultation paper on non-domicile status is “thin on the ground” when it comes to detail and, if introduced as proposed, will fail to treat some ‘non-doms’ fairly, according to tax experts. “It feels like this new legislation is being rushed through,” said Dean Mullaly, managing director of… – Continue reading
Last year at this time, news about “tax inversions” was grabbing headlines – cases where large U.S. multinationals would buy a foreign company in a tax-friendly jurisdiction, and then relocate its headquarters to reap the tax arbitrage benefits. The Obama administration responded to the rash of high-profile inversions with new… – Continue reading
New Zealand’s Inland Revenue Department (IRD) announced on September 23, 2015, that two new acts, the Land Transfer Amendment Act 2015 and the Tax Administration Amendment Act 2015, received Royal Assent to strengthen property investors’ tax compliance. Under the new legislation, three changes will apply from October 1, 2015, for… – Continue reading
A tax avoidance scheme which exploited the UK’s double-taxation agreement with the Isle of Man has been defeated by HM Revenue & Customs. More than 2,000 people signed up to the Isle of Man-based scheme to reduce their rate of income tax to less than 5%. The users of the… – Continue reading
Europe’s stiff-neckedness is difficult to cure. To come to an agreement for supranational treatment of a certain issue there needs to be a large cataclysm or at least a large scandal. In the case of taxation policy the problem begins to gain urgent and most importantly European status after the… – Continue reading
Pharmaceuticals group defends use of legal avoidance scheme, after paying no UK corporation tax over two years despite global profits of £3bn AstraZeneca, one of Britain’s largest businesses, is using a multimillion-pound tax avoidance scheme in the Netherlands, set up months after the UK relaxed its tax laws for multinationals… – Continue reading
By: Jayesh Sanghvi, Partner & National Leader – International Tax Services, EY India Multinational groups can create non-resident affiliates in low tax jurisdictions to which income is shifted, wholly or partly for tax reasons rather than for non-tax business reasons. Such overseas profits are not subjected to tax in the… – Continue reading
Government’s anti-corruption champion says legislation is one option if British overseas territories fail to adopt public registers of companies The government could legislate to force the UK’s tax havens to reveal for the first time the true owners of offshore companies, anti-corruption champion Sir Eric Pickles has indicated. Pickles described… – Continue reading
The four entities tasked with upholding New Zealand’s anti-money laundering law should team up to close off the law’s obvious arbitrage opportunity by stopping financial services companies that only have clients overseas from being able to sidestep the law, a leading lawyer says. As first highlighted by interest.co.nz in August… – Continue reading
On September 18, 2015, the Danish Ministry of Taxation published draft legislation to introduce a new country-by-country reporting obligation for multinational corporations. The draft Bill would introduce the new three-tiered approach to transfer pricing documentation that is to be proposed formally by the OECD as part of the BEPS deliverables… – Continue reading
George Osborne’s plans to tighten tax rules for wealthy foreigners living in Britain will leave many offshore trusts outside the UK tax net, according to proposals published on Wednesday, reports the Financial Times. The Treasury’s consultation on “carefully targeted” changes to the rules for “non-doms” — people who live in… – Continue reading
European Commission list identifies the city as one of 30 non-cooperative tax jurisdictions, reports the South China Morning Post. The European Commission is likely to remove Hong Kong from its list of top 30 tax havens, according to a source familiar with the situation. The source, who cannot be identified,… – Continue reading
On 16 June 2015, the Department of International Tax Cooperation of the Cayman Islands (the “DITC”) announced that it would be implementing the CRS into domestic law. The draft Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations, 2015 are currently under review and it is expected that these… – Continue reading
A stream of people, including those from Rajasthan and Karnataka, walked into the only designated office before the closure of the one-time compliance window The Centre’s efforts to unearth unaccounted money stashed abroad seems to have got a tepid response, with the declarations made under the three-month compliance window that… – Continue reading
In addition to Justice Martineau’s denial of injunctive relief and dismissal of the request for summary judgment in Hillis and Deegan v. The Attorney General of Canada, as discussed in our previous post, U.S. citizens residing in Canada received more disappointing news on September 29, 2015, when Judge Thomas M…. – Continue reading
The UK government is unlikely to be able to legislate to speed up the referral of a single issue within a wider tax enquiry to the tax tribunal before 2017 despite the urgent need for such a procedure, an expert has said.30 Sep 2015 Respondents to a recent consultation on… – Continue reading
A new report by global consulting outfit, Price¬waterhouseCoopers (PwC), released on Monday has indicated that expanding com¬pliance burden, more audits and the potential for increased and double taxation remain key hurdles facing companies due to the rapidly evolving global tax landscape. The report’s findings showed that the demand for greater… – Continue reading
Secret Luxembourg document discussed risks of special tax deals, but Jean-Claude Juncker says he cannot remember discussing it with its author The president of the European Commission faces fresh questions about his role in designing Luxembourg’s controversial system of “sweetheart” tax deals after he released an 18-year old document that… – Continue reading
WASHINGTON, D.C., Sept. 30, 2015 –His Excellency Dr. Eugene Newry, Bahamas Ambassador to the United States, has written a letter to Municipal Officials of the District of Columbia and Federal Congressional Officials protesting “in the strongest terms” The Bahamas’ designation as a “tax haven” by D.C. authorities in the District… – Continue reading
Having saved for most of their life to amass an income to use in retirement, most people get to a certain age and start to think about drawing on those financial reserves as they wind down from the daily grind. When that money is held in an international pension plan… – Continue reading
Efforts to amend details of new rules on corporate profits raise questions, reports the Wall Street Journal. Nearly 50 governments are set to agree this fall to a new set of rules to clamp down on tax avoidance among multinational corporations. Their chance of success, however, is unclear. If the… – Continue reading
If the anti-corruption march goes ahead on Wednesday, it will be remiss if it doesn’t address one of the key issues of 2015: illicit financial flows. Institutions around the world are committing to combatting these and Unite Against Corruption needs to push the government to take action locally while lobbying… – Continue reading
India must align domestic laws with international treaties A recent ruling of the Punjab & Haryana High Court (HC) in the Serco BPO case has once again underlined the need for consistency between tax policies and the jurisprudence that evolves around it, thus, leaving little to interpretational hazards. The HC,… – Continue reading
French economist Gabriel Zucman, a protégé of Thomas Piketty, has a new book outlining how to avoid this. To Gabriel Zucman, protégé of rock star French economist Thomas Piketty, the United States is starting to look a lot like Europe in the late 1800s. “There’s been this great reversal where,… – Continue reading
