Key Points: A key requirement for the anti-avoidance rules to apply will be that a principal purpose of the scheme is to avoid a taxable presence in Australia. Treasurer Joe Hockey has today confirmed that Australia is going to bolster its income tax anti-avoidance rules to counter large multinationals (global… – Continue reading
Grant Wardell-Johnson, KPMG Tax Partner, has said that while it would have been better for Australia to await the outcome of the OECD’s base erosion and profit shifting Action Plan, the international tax measures proposed recently by Treasurer Joe Hockey “have the benefit of being highly targeted.” On May 11,… – Continue reading
Tax analysis: Catherine Richardson, associate at Cadwalader, Wickersham & Taft LLP, examines the aspects of the Finance Act 2015 (FA 2015) which concern targeting avoidance using carried-forward losses. What is the target for the new rule countering tax avoidance involving carried-forward losses? Where losses for tax purposes arise within a… – Continue reading
There are two pressing concerns facing us in 2015. First, the increased crackdown on multinational corporations reportedly using offshore tax hubs to avoid taxes will make summer 2015 the make or break season for the global economy. On the one hand, the argument is made that firms such as Apple,… – Continue reading
Australia to fine tech tax-dodgers 100% of their avoided tax, plus profits Australia’s treasurer* Joe Hockey has revealed that he and other money ministers from the Organisation for Economic Co-operation and Development (OECD) have shared plans to have online retailers charging the appropriate consumption tax on intangibles and goods bought… – Continue reading
The Australian government announced a world-leading crackdown on Monday on alleged tax avoidance by 30 multinational companies that will likely force them to restructure their businesses before next year, reports Reuters. “These companies are diverting profits earned in Australia away from Australia to no-tax or low-tax jurisdictions,” Treasurer Joe Hockey… – Continue reading
You’re just over a month to prepare for the provision of the first Russian banks reporting FATCA. In the future, Russia will reach the full exchange of information with the United States, who also contribute to the development of the domestic economy. By June 29, the Russian banks will be… – Continue reading
Chile’s Senate on May 5, 2015, approved a bill that strengthens the Internal Revenue Service (SII). The bill was passed with 30 votes in favor and none against, with one abstention. It will now be sent to the Chamber of Deputies for consideration, following changes made by the Senate. The… – Continue reading
Corporations that have reclassified themselves as “foreign-owned” received approximately $1 billion in federal contracts over the last five years. These companies profit from American tax dollars despite avoiding U.S. taxes themselves. That could soon change. Two members of Congress have reintroduced legislation that would block these companies from winning lucrative… – Continue reading
Top-level executives turned out for information sessions in Toronto and Calgary this week to hear a BDA-hosted delegation spell out the benefits of establishing captive insurance companies and e-commerce entities in Bermuda. The BDA said, “A 20-strong delegation from the Island delivered a compelling Bermuda message to well-attended sessions in… – Continue reading
Exchange Traded Funds (ETFs) have gained huge popularity in recent times with Irish investors; however, there has been much complexity and uncertainty in relation to their tax treatment. The concept of an ETF is not specifically provided for in Irish tax legislation. It depends on the legal form and characteristics… – Continue reading
A draft law empowering shareholders to vote on directors’ remuneration, so as to ensure proper transparency and tie their pay more closely to their performance, was backed by Legal Affairs Committee MEPs on Thursday. Some large companies should also be required to disclose, country by country, information on tax rulings,… – Continue reading
Nedbank Private Wealth is an international private bank headquartered in the Isle of Man, a self-governing British Crown dependency. The bank has been growing its presence in the Middle East since January 2011 through a representative office established in Dubai and licensed by the UAE Central Bank. “Our presence in… – Continue reading
The Foreign Account Tax Compliance Act is meeting with some success in prompting foreign banks to disclose the holdings of U.S. taxpayers to the Internal Revenue Service, according to a former IRS official. FATCA was included as part of the HIRE Act of 2010 and requires foreign financial institutions to… – Continue reading
For the fourth consecutive year, PKF Malta will be participating in Canada’s premier Captive Insurance event for risk managers. Captives & Corporate Insurance Strategies Summit will take place in Sheraton Center Toronto, located in the heart of this vibrant city, on 27th-28th May2015. In this year’s event, George Mangion, Senior… – Continue reading
Jason Porter explores the tax regimes in Portugal, France, Malta and Cyprus – four of the most advantageous territories for UK ex-pat retirees People aged 55 and over are now entitled to their pension in the form of a lump sum, to be taxed at marginal rates applying in the… – Continue reading
In the 2015 Budget Speech presented to the National Assembly on 25 February 2015 the Minister of Finance announced that amendments will be proposed to change the rules for the digital economy in line with the latest guidance issued by the Organisation for Economic Co-operation and Development (“OECD”) in its… – Continue reading
BRUSSELS–The European Union won’t meet a self-imposed June deadline for deciding whether four multinational companies including Apple Inc. and Amazon.com Inc. benefited from illegal tax sweeteners, the bloc’s antitrust chief Margrethe Vestager said Tuesday. “We won’t meet the deadline we set ourselves [of] the end of the second quarter,” Ms…. – Continue reading
The Standing Committee’s recommendation comes after the finance minister announced in the Budget that DTC would not be pursued as most provisions of the code have been incorporated in the existing Act. Even as finance minister Arun Jaitley scrapped the proposed direct taxes code (DTC) in Budget 2015-16, the standing… – Continue reading
Passing between tax administrations Polish and US information on accounts and income tax residents predicts signed by the president Bronislaw Komorowski law on ratification of the agreement with the USA on the use of so-called FATCA Act. As reported by the presidential office, in terms of the Act of 20… – Continue reading
Mauritius and Singapore are both examples of countries with Double Taxation Avoidance Agreements (DTAAs) with India, meaning dividends from corporations that are paid out to shareholders are not taxed further, having already been taxed at the corporate level. This legislation has meant that such countries have been used to “round-trip”… – Continue reading
On 21 April 2015, the Danish Parliament adopted a bill, which sets out to deal with certain potential abuses recently encountered by the tax authorities as well as the Danish enactment of the general international anti-abuse initiatives currently considered at EU and OECD level. The new Danish GAAR will take… – Continue reading
During 2014, Barbados again produced strong evidence of the underlying strength of its financial system. All of the financial stability indicators and stress tests performed for the financial system strongly indicate that the system remains stable with the capacity to withstand a wide variety of severe economic shocks. It is… – Continue reading
The game of cat and mouse between tax authorities and citizens has been played for a very long time. People have been dodging taxes for centuries. But the more nuanced and sophisticated game of avoiding tax is a more recent phenomenon. Indeed, when it comes to tax avoidance the game… – Continue reading
An independent group of tax professionals should report annually to parliament on whether new legislation complies with the rule of law, the Law Society’s tax committee recommended this week. Publishing a position paper on tax and the rule of law, committee chair Gary Richards said that ‘legislative hyperactivity has become… – Continue reading
Hong Kong’s Secretary for Financial Services and the Treasury, K C Chan confirmed that the Government and regulators remain fully committed to combating money laundering and tax evasion, following the latest reports of foreign banks being used to open offshore accounts. In response to a question in the Legislative Council,… – Continue reading
COMPANIES that engaged in tax avoidance practices such as the abuse of transfer pricing should be expropriated without compensation, Economic Freedom Fighters (EFF) MP Floyd Shivambu proposed in Parliament on Wednesday. This was one of a raft of “aggressive” measures that he believed the government should adopt to deal with… – Continue reading
As discussed in our previous briefing, Labour calls time on the remittance basis, Ed Miliband has announced a policy of abolishing what he called the “non-dom tax regime”, to be implemented in the event of a Labour victory in the coming election. Many individuals who are UK resident but non-UK… – Continue reading
There is a great need to protect traditional knowledge in order to curb the exploitation of holders of indigenous knowledge, particularly the elderly. It has been observed that the elderly have indigenous knowledge but their wisdom is being stolen from them and used for commercial purposes while they languish in… – Continue reading
Hong Kong (HKSAR) – Following is a question by the Hon Frederick Fung and a written reply by the Secretary for Financial Services and the Treasury, Professor K C Chan, in the Legislative Council today (April 29): Question: It has been reported that an investigation conducted jointly by an international… – Continue reading
The Companies (Amendment) Act 2014 (the “Amendment Act”) which will introduce wide-ranging changes to the Companies Act, will be implemented in two phases. Two-phase implementation: 1 July 2015 and Q1 2016 About 40% of the changes in the Amendment Act will take place in the first phase on 1 July… – Continue reading
If Illinois small business owners were to collectively offset state and federal revenues lost annually due to corporations using offshore tax havens, they would each have to pay $4,570 in additional taxes a year. That what-if scenario is laid out in a recent report from the Illinois Public Interest Research… – Continue reading
As compared to past federal Budgets, Budget 2015 contained fewer (and arguably less controversial) international tax measures. Nevertheless, Budget 2015 did announce the Government’s intention to address taxpayer concerns relating to (i) the withholding obligations borne by non-resident employers that have non-resident employees that work in Canada, and (ii) the… – Continue reading
Premier Michael Dunkley spoke at a recent Transcontinental Trusts Conference forum here on the island, the first time that the conference’s flagship event has been held outside of Europe in 30 years. In his remarks, Premier Dunkley said, “As this is the leading trust event for private client professionals, our… – Continue reading
The Greek government will table a new draft bill to Parliament that will allow Greek citizens to voluntarily reveal deposits held in Switzerland in exchange for a smaller tax payment, Finance Minister Yanis Varoufakis said on Tuesday. Speaking to reporters after a meeting with Swiss State Secretary for International Financial… – Continue reading
A bill that could allow the state to collect taxes on corporate profits in offshore tax havens to fund Colorado schools survived a narrow party-lane vote in the state House of Representatives on Tuesday. The Democrats’ bill, which passed the House 33-31, faces a tough road as it moves from… – Continue reading
Vermont Sen. Bernie Sanders introduced a corporate tax bill earlier this month. Unsurprisingly, it cuts in a different direction than most tax proposals floating around Washington these days. The bill (S.922) is titled the Corporate Tax Dodging Prevention Act of 2015. A companion bill was introduced in the House by… – Continue reading
When Burger King’s owners first announced last summer’s mega-deal to gobble up Tim Hortons, the fast-food firm’s executives downplayed a key reason why they were acquiring the Canadian coffee chain and relocating corporate HQ to Canada: to cut its taxes. “Tax wasn’t really the driver of this,” Daniel Schwartz, the… – Continue reading
Americans have overcome oligarchy before — and there’s no reason we can’t do it again. Rising inequality seems to pose an insurmountable political problem. If the underlying causes are technological change and globalization, the forces appear to be unstoppable. Alternatively, if the causes are primarily political and involve the power… – Continue reading
THE REVENUE Commissioner’s large cases division is investigating almost 100 schemes it suspects were designed by companies and wealthy individuals to avoid paying capital gains tax. The taxman is enquiring into 89 cases which used sophisticated financial instruments known as contracts for difference to generate artificial losses. The schemes avoided… – Continue reading
The world’s high and ultrahigh net worth families are run much like businesses these days, with family governance in place as well as fund structures in favourable tax jurisdictions that allow for consolidated reporting across diversified assets. That is the way the world is moving, with global tax authorities grouping… – Continue reading
NUMBER OF THE WEEK: 6.5 percent The tax rate at which companies could voluntarily repatriate their foreign earnings under the Invest in Transportation Act of 2015 ( S. 981). Senators Barbara Boxer (D-CA) and Rand Paul (R-KY) introduced the bipartisan proposal, offering ways to save the Highway Trust Fund. Funding… – Continue reading
Company accounts provide insight into Parlesse Investments A Larry Goodman company based in Luxembourg made a profit of €52.6 million in 2013 and paid just 0.4 per cent tax, according to accounts in the tiny EU member state. The company, Parlesse Investments Sarl, began operations in 2010 and had accumulated… – Continue reading
Multinationals play such a large role in many nations’ budgets that effective control is crucial. Business Tax-base erosion cripples Africa 24 Apr 2015 00:00 Lisa Steyn Multinationals play such a large role in many nations’ budgets that effective control is crucial. Finance Minister Nhlanhla Nene says practices such as incorrect… – Continue reading
Britons overseas are now subject to CGT when selling UK properties, but this straightforward advice could help minimise the impact Expats who have kept a house or flat in Britain need to act now to avoid being stung by a hefty capital gains tax (CGT) bill in the future. Since… – Continue reading
Hong Kong (HKSAR) – The Government today (April 24) launched a consultation exercise to gauge views on proposals to apply, with adaptations for Hong Kong, the prevailing international standards on the automatic exchange of financial account information in tax matters (AEOI). On the basis of the Organisation for Economic Cooperation… – Continue reading
PANAMA CITY (AP) — – Panama took a major step in an effort to clean up its reputation as Latin America’s premier hub for money laundering. The nation’s legislature late Wednesday unanimously approved a proposed law that will toughen supervision of more than a dozen non-financial sectors where illicit proceeds… – Continue reading
Tax evasion overseas has been further targeted by authorities as HM Revenue and Customs (HMRC) implements tougher penalties for those who hide assets and income abroad. The maximum penalty for offshore evasion of income and capital gains tax has doubled to 200 per cent of the tax due, but can… – Continue reading
Panama took a major step in an effort to clean up its reputation as Latin America’s premier hub for money laundering, reports the AP. The nation’s legislature late Wednesday unanimously approved a proposed law that will toughen supervision of more than a dozen non-financial sectors where illicit proceeds from the… – Continue reading
On Oct. 14, 1960, President John F. Kennedy made an impassioned plea to University of Michigan students, exhorting them to move abroad and assist nations struggling under the weight of underdeveloped economies. Kennedy was convinced American talent is a unique, effective export commodity. That speech laid the foundation for the… – Continue reading
