Industrial & Manufacturing groups which have operations in Finland, should review their funding arrangements to ensure they remain tax effective following a recent case in Finland which may now be put on a statutory footing. The Finish tax authorities treated a hybrid instrument as equity and the related interest expense… – Continue reading
The UK Government’s goal is to make the UK the best place in the world to locate an international business; it has one of the most open economies globally, a highly skilled workforce, access to capital markets, a first-class infrastructure, and a highly competitive corporate tax system. UK tax policy… – Continue reading
Concerns have been raised that there is an anomaly in the Canadian overseas pension schemes system, as under Canadian law savers are allowed to encash them at any age, irrespective of the UK’s pension age test, reports the FT Adviser. HM Revenue and Customs’ pension age test requires schemes to… – Continue reading
The new banking act, harmonized legislation for the OECS being pushed by the Eastern Caribbean Central Bank got its first reading in the parliament in Basseterre Tuesday. However the parliamentary opposition is crying foul because the debate which was expected to kick off on the act was put off by… – Continue reading
Ukraine’s Cabinet of Ministers will remove Austria from the list of countries transactions with whose counterparties are subject to control under the law on transfer pricing on August 1, 2015. This is stipulated in Cabinet resolution No. 677 dated July 1, 2015, which is available on the government website on… – Continue reading
Lopez Valdes clarifies that only information given by state bodies The implications of the Law Enforcement Tax Accounts Abroad (FATCA for its acronym in English) adopted by the United States in March 2010, has generated unrest globally, because that nation imposes conditionalities that violate laws local. That legislation provides, among… – Continue reading
WITH the aim of promoting tax culture in the country, the government has resurrected a law drafted in 2012 to encourage citizens to expose tax evaders and induce people who have stashed away their wealth offshore to bring home their money. By extending the legal cover to whistleblowers through the… – Continue reading
VANCOUVER, July 6, 2015 /PRNewswire/ – Silver Wheaton Corp. (“Silver Wheaton” or the “Company”) (TSX:SLW) (NYSE: SLW) announces that it has received a proposal letter dated July 6, 2015 (the “Proposal”) from the Canada Revenue Agency (the “CRA”) in which the CRA is proposing to reassess Silver Wheaton under various… – Continue reading
Cleaning the stain off New Zealand’s international reputation put there by misbehaving NZ registered but overseas operating financial service providers could be accomplished quite simply, says Minter Ellison Rudd Watts partner Lloyd Kavanagh. “I think the solution is simple. If you’re on the Financial Service Providers Register (FSPR), I think… – Continue reading
ARBADOS’ CONTROVERSIAL BLACKLISTING by a group of European Union (EU) countries is “hypocritical” and “grossly discriminatory”, says outgoing Barbados International Business Association (BIBA) president Connie Smith. But Smith also thinks the time is right for “engaging in bilateral discussions which could hopefully conclude in double taxation agreements and bilateral investment… – Continue reading
On June 8th 2015, the OECD released a new package of measures for the implementation of a new Country-by-Country (CbC) reporting plan developed under the OECD/G20 Action Plan on Base Erosion and Profit Shifting (BEPS) Project, aimed at improving transparency in international tax matters. The CbC reporting plan was founded… – Continue reading
Ireland’s attractively low rate of corporate taxation is once again under pressure with the recent release of the European Commission’s new action plan to tackle tax avoidance. The commission has been prompted into this politically ambitious move by public outcry over big, usually American, companies avoiding tax in the EU…. – Continue reading
OECD and G20 Action Plan on Base Erosion and Profit Shifting (BEPS) was adopted in 2013. It consists of 15 actions including transfer pricing, taxation of controlled foreign corporations (CFC), digital commerce, hybrid instruments, international information exchange, tax treaty shopping etc. In 2013, OECD working group prepared draft documents regarding… – Continue reading
NEW DELHI, JULY 1: Anyone with undisclosed assets and bank accounts abroad will get time up to December 31 to avoid a higher penalty and prosecution. The Finance Ministry has notified the compliance window under The Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015. Under… – Continue reading
The German government has announced plans to incorporate Action 13 (guidance on transfer pricing documentation and country¬by¬country (CbC) reporting) of the OECD’s BEPS project into local legislation. The wording of the new law is being drafted and may be published some time in autumn of this year. It is the… – Continue reading
The budget deal agreed to by state lawmakers this week quietly targeted Microsoft for a $57 million tax increase over the next two years, and the Redmond software giant is apparently willing to go along with it. They haven’t advertised it, but the budget deal agreed to by state lawmakers… – Continue reading
The Government has released exposure draft legislation to amend the anti-avoidance rules in Part IVA of the Income Tax Assessment Act 1936 (Cth) to prevent multinational entities using artificial or contrived arrangements to avoid a taxable presence in Australia. We will continue to monitor the progress of the exposure draft… – Continue reading
THE ROBERT Fico government is preparing an additional 30 measures by which it wants to combat tax avoidance and tax evasion in Slovakia. It wants, for example, to use cover companies to uncover criminal deeds, names of debtors should be published on the website of the Financial administration and excise… – Continue reading
OLDWICK, N.J.–(BUSINESS WIRE)–Proposed U.S. legislation aimed at preventing offshore tax avoidance by closing a tax loophole that allows offshore reinsurers to take advantage of an exception to the passive foreign investment company (PFIC) rules of the U.S. Tax Code will not lead to rating revisions over the near term, according… – Continue reading
A common mistake when analyzing the tax implications of a cross border transaction is to jump too quickly to the ramifications of a tax treaty without first having a clear handle on the tax implications under the Income Tax Act (Canada) (“ITA”). A related issue is that even though a… – Continue reading
“THE decision by a group of European Union (EU) Member States to blacklist Barbados as being non-cooperative and further claim that Barbados and 29 other countries, mostly small islands, do not meet its standards of transparency, exchange of information and fair tax competition, is hypocritical and on the face of… – Continue reading
Belize’s banking sector has caught up with the standards and regulations set by the US and European Union for accountability and transparency in our offshore sector. That’s what the new Director of the Financial Intelligence Unit had to say at press conference rarely called by the stat. Unless you’re a… – Continue reading
The “wall of Chinese capital” hitting property markets in Sydney and Melbourne will not ease up until the government introduces its anti-money laundering legislation, says an expert in ‘flight capital’. James Tee, an ethnic Chinese property developer whose business specialises in “capital expatriation” – that is, getting money out of… – Continue reading
The Unified Patent Court (UPC) Agreement will not be ratified in the UK this year, the Intellectual Property Office (IPO) has confirmed. In a statement sent to Out-Law.com, the IPO ruled out ratification of the Agreement this year but said that it intends to complete the “domestic preparations” for ratification… – Continue reading
GENEVA — The FIFA corruption scandal is prompting fresh moves to stem money laundering in Switzerland, but the nation long known as a haven for hiding money may be slow to change. The Swiss government announced new measures this month following the investigation of soccer’s governing body to tighten control… – Continue reading
NEW DELHI: Anecdotes about the first Income Tax searches in the T-20 IPL cricket tournament and a letter by former Finance Minister P Chidambaram seeking information about alleged illegal accounts by Indians in Switzerland find place in a new book on black money. The recently launched book “It’s Raining Black!… – Continue reading
The Cayman Islands is better positioned to police terrorism financing than the U.S., an American congressional subcommittee heard Wednesday. The comments came from New York County District Attorney Cyrus Vance, who was called before the U.S. House Task Force to Investigate Terrorism Finance. “On a near daily basis, we encounter… – Continue reading
Corporate entities are often deemed to be related in terms of excise law if (a) they are interconnected undertakings and / or (b) they have mutuality of interest in the business of each other. Excise and Customs law are the oldest surviving indirect tax legislations in India. Despite this, till… – Continue reading
The challenges faced by multinational enterprises (MNEs) in navigating the interface of transfer pricing and customs valuation rules is not a new phenomenon. However, due to a marked increase in recent years of the number of countries introducing or updating their transfer pricing legislation and scaling up their auditing and… – Continue reading
The biggest hurdle to stopping multinational tax evasion isn’t the companies themselves. It’s the governments behind them. As the OECD works swiftly on its plan to stop multinational tax evasion, the United States has already signalled it’s not happy with what’s being proposed. The US has always been clear on… – Continue reading
Tax Authority chief Moshe Asher: Banking secrecy is over. Another wave of arrests of Israelis with unreported overseas bank accounts and money is expected. In the coming day, Israelis who have not filled out forms sent to them by the Israel Tax Authority for declaring their assets will be summoned… – Continue reading
Tax Authority chief Moshe Asher: Banking secrecy is over. Another wave of arrests of Israelis with unreported overseas bank accounts and money is expected. In the coming day, Israelis who have not filled out forms sent to them by the Israel Tax Authority for declaring their assets will be summoned… – Continue reading
Executive summary On 8 June 2015, the Presidency of the EU Council (Latvia) sent a report (The Report) to the Permanent Representatives Committee and the European Council. The Report sets out the current state, as well as a number of open issues and questions, in regard to the 18 March… – Continue reading
Thailand’s Council of State is deliberating the country’s first law on transfer pricing. If passed the bill w ould allow Thailand Revenue Department (TRD) officials to enquire into profits from crossborder transactions of multinational companies. The final draft of the law w as approved by the Cabinet in May this… – Continue reading
In late May, Amazon announced it had started to pay tax on its sales in the UK rather than in Luxembourg. This came about after Amazon restructured its tax structure in Europe in response, at least in part, to the UK’s diverted profits tax (commonly known as the Google Tax)… – Continue reading
Conor Hynes and Ronan Connaughton of Deloitte Ireland explore the impending changes arising from BEPS Action 7 and the Skandia case and provide insight on the potential tax impact for the insurance industry. The Greek philosopher Heraclitus is attributed with the saying, “the only thing that is constant is change”…. – Continue reading
Before going after multinationals that channel profits through tax havens and low-tax nations, you must define what one is, business lobbies have told the Abbott government. Treasurer Joe Hockey announced in the May budget that the government would be strengthening anti-avoidance laws to go after 30 companies with over $1… – Continue reading
The UK tax system is about to experience one of its biggest ever upheavals. From April 2016, there could be two tax jurisdictions for income tax for the first time. We can’t definitively say what will happen yet, because the current Scotland Bill is still subject to negotiation – and… – Continue reading
Despite the inevitable move towards automatic exchange of tax information and Common Reporting Standards internationally, there continues to be a steady flow of litigation in the Courts of International Financial Centres such as Bermuda, the Cayman Islands, and Singapore relating to challenges to inter-governmental Tax Information Exchange Agreement (TIEA) requests…. – Continue reading
The Bahamas was yesterday “dumped on” through its inclusion on another so-called financial services ‘blacklist’, although an ex-Attorney General and others suggested the development should be taken “with a big grain of salt”, reports the Bahamas Tribune. John Delaney told Tribune Business that the European Union’s (EU) decision to ‘blacklist’… – Continue reading
David Gauke, financial secretary to the Treasury, told representatives from the European Parliament that Britain would reject plans to combat tax avoidance by multinationals According to the Guardian, German MEP Michael Theurer said, “He was very clear that the UK is insisting on tax competition”. The European Commission’s plan to… – Continue reading
Alberta’s new Finance Minister grudgingly admits it, and the province’s opposition proclaims it: The old Alberta Advantage is dead. The label long used by Progressive Conservative premiers to sell the Prairie province as a low-tax haven for individuals and corporations could be consigned to history when the NDP government passes… – Continue reading
Abstract Over the past 25 years, Cyprus has become the portal of choice for investment into and out of Russia and Central and Eastern Europe. The new Russian de-offshorization law, which took effect on 1 January 2015, will have significant implications for users of overseas structures. This article examines the… – Continue reading
Yesterday, on June 17, 2015, three state tax bills were favorably reported to the United States House of Representatives (House) by the House Judiciary Committee (House Judiciary) after considering each during a half-day markup. The bills that were advanced included: (1) the Mobile Workforce State Income Tax Simplification Act (Mobile… – Continue reading
On June 17, the House of Representatives Judiciary Committee approved the markup of three bills dealing with interstate tax rules in the United States on individual income tax, business activity taxes, and sales tax on digital goods. The Mobile Workforce State Income Tax Simplification Act is a bipartisan measure that… – Continue reading
Effective from January 1st next year, personal income tax in Hungary will be paid at a flat tax rate of 15%. Consequently, the standard withholding tax rate on all Hungarian securities (debt securities and equities) will also be reduced from the current 16% to 15%, says Clearstream Banking in a… – Continue reading
Effective from January 1st next year, personal income tax in Hungary will be paid at a flat tax rate of 15%. Consequently, the standard withholding tax rate on all Hungarian securities (debt securities and equities) will also be reduced from the current 16% to 15%, says Clearstream Banking in a… – Continue reading
The U.S. Model Income Tax Treaty (the U.S. Model Treaty) generally represents the United States’ opening position in treaty negotiations. As a result, when changes to the treaty are proposed, international tax practitioners should be aware of the potential impact those changes can have on their existing inbound U.S. structures…. – Continue reading
The Bahamian financial industry is concerned it will have to start reporting information for the US Foreign Account Tax Compliance Act (FATCA) without the necessary legislation being in place, Tribune Business can reveal, reports the Bahamas Tribune. Lawrence Lewis, a Deloitte & Touche (Bahamas) partner and accountant, confirmed to Tribune… – Continue reading
Tax avoidance can be defined as aggressive tax-planning strategies and structures by multinational companies that take advantage of the gaps or mismatches in tax rules to shift profits to low-tax locations. While many countries around the world have either general or specific anti-avoidance legislation to tackle this problem, the current… – Continue reading
