Category: Legislation

Budget 2015: Address tax issues, push data centre infra are Infy, Wipros’ request to Arun Jaitley

NEW DELHI: Top officials from IT, BPO and eCommerce sectors today requested Finance Minister Arun Jaitley to address certain issues related to taxation in the Budget 2015-16, and provide incentives for setting up data centres in the country. They also suggested that the minister look at ways to help in… – Continue reading

Indian economy gathers pace as the government tries to ‘walk the talk’ on key reforms

With foreign investment, energy security and strategic partnerships at the top of his agenda, the Indian Prime Minister Narendra Modi criss-crossed eight countries, including the US, Australia, Japan and Nepal, meeting more than 40 international leaders in the first six months of his tenure. Mr Modi is riding high on… – Continue reading

How an Obscure Tax Loophole Brought Down Obama’s Treasury Nominee

(Bloomberg) -– So how did the previously obscure term tax inversions become part of Washington parlance, fodder for the next presidential campaign and the issue that helped derail a U.S. Treasury nominee? Thank, or blame, depending on your perspective, cutting-edge tax lawyers, populist Democrats, a banana seller, a drugmaker, a… – Continue reading

Finance ‘open-minded’ on knowledge box taxes

The Department of Finance is understood to be “open-minded” over what rate should be applied to its proposed ‘knowledge box’ tax regime for patents and intellectual property assets developed here. The department yesterday formally launched its planned consultation process for the programme, which was announced in October’s Budget. There has… – Continue reading

National Taxpayer Advocate Slams IRS Offshore Programs & FBAR Penalties, Demands Change

The National Taxpayer Advocate Nina Olson is a strong and vocal advocate for taxpayer rights. Her annual report to Congress castigates the IRS for its unfair application of offshore account penalties, and its disparate treatment of innocent Americans caught in reporting snafus. Some of the report asks the IRS to… – Continue reading

Government launches public consultation on Knowledge Development Box

The Government has unveiled a three-month public consultation on the proposed Knowledge Development Box, with submissions invited from businesses and the wider public. The proposed scheme, also known as a patent box, was announced in the Budget and is due to come into force next year. It will provide for… – Continue reading

Changes to Ireland’s general anti-avoidance regime

Substantial changes have been made to Ireland’s general anti-avoidance regime (GAAR) in an effort to simplify the procedures Revenue must follow to successfully withdraw a tax advantage from a taxpayer on the basis that the transaction constituted a tax avoidance transaction.  The changes will apply to transactions entered into on… – Continue reading

Ireland: ‘Knowledge box’ patent tax rate expected to be 5%

Ireland: The Department of Finance will publish a consultation document Wednesday on the proposed ‘knowledge box’ patent tax regime that will be enacted in replacement of the Double Dutch tax avoidance scheme. Late last year Department officials hinted that a 5% rate was under discussion to match the Dutch rate…. – Continue reading

Ireland: Changes To Irish Corporate Residence Rules

On October 14 2014, Ireland’s Minister for Finance (the Minister) announced changes to Ireland’s corporate residence rules. Following much speculation, the Minister confirmed that Ireland would change its rules to restrict the ability of Irish incorporated companies to be treated as non-Irish resident. Under existing Irish law, an Irish incorporated… – Continue reading

Changes to Singapore Transfer Pricing Guidelines

On 6th January 2015, the Inland Revenue Authority of Singapore (“IRAS”) released revised transfer pricing guidelines, providing a better defined view of how the IRAS will handle transfer pricing matters. These guidelines call for taxpayers to prepare and maintain contemporary transfer pricing documentation. In addition, they specify thresholds for related… – Continue reading

Property tax will have adverse effect on the market – Chamber of Commerce

The Chamber of Commerce believes the new regime will have an adverse effect on the recently recovering property market The Malta Chamber of Commerce, Enterprise and Industry has expressed its strong disagreement with the new Property Tax announced by Government in the Budget for 2015. The new regime, it says,… – Continue reading

Senator Whitehouse hopes compromise will close tax loopholes used by large corporations + Poll

PROVIDENCE — With tax reform one issue that congressional Republicans and Democrats might agree on this year, U.S. Sen. Sheldon Whitehouse announced Monday his plans to introduce three bills aimed at making the super rich pay more through a “fairer” tax system and closing loopholes that allow some corporations to… – Continue reading

China’s Fiscal Roadmap: Tax Like America

Jurisdictionally speaking, the Internal Revenue Code attempts to cast a broad net. The United States taxes its citizens’ income on a worldwide basis, regardless of residency. As every American expat knows all too well, this means overseas earnings must be reported to the IRS as taxable income. It matters not… – Continue reading

Security and ‘Juncker Plan’ at heart of debate with Council president Tusk

“The European Strategic Investment Plan is not the silver bullet. But if anyone has ideas to overcome the economic crisis with one stroke, stand up please,” said European Council President Donald Tusk in the debate on the results of the December European Council, which also covered tax avoidance and —… – Continue reading

Seen&Heard: Department considering whether to give banking inquiry notes from night of bank guarantee

Official’s notes include minutes from two meetings held on September 29th, 2008, in Government Buildings Bank guarantee notes The Department of Finance is considering whether to give the Oireachtas banking inquiry two notes from the night of the bank guarantee written by a Department official. They include minutes from two… – Continue reading

Switzerland’s Financial Centre Reforms Are A Work In Progress

Switzerland’s Financial Centre Reforms Are A Work In Progress by Andreas Keiser, swissinfo.ch In the last few months Switzerland has made progress in making its financial centre internationally compliant. Key areas are the automatic exchange of information, enhanced administrative assistance with other countries, and the reduction of foreign untaxed assets…. – Continue reading

Recent progress in the OECD’s BEPS project

Within the framework of the BEPS (Base Erosion and Profit Shifting) action plan, adopted in July 2013, on last September 16, the OECD published its first recommendations in the form of reports on 7 of the 15 points of the action plan: Address the tax challenges of the digital economy… – Continue reading

Legitimate versus illegitimate tax planning – Delhi High Court dissects Vodafone

Globally, the sphere of taxation has witnessed a constant tussle between its primary players – while governments continually strive to maximise revenue and widen the tax base through successive amendments to tax laws and streamlining tax administration, taxpayers seek to arrange their affairs in a manner so that the incidence… – Continue reading

Lawmakers Re-introduce Bill to Curb Offshore Tax Havens

A pair of Democratic lawmakers in the House and Senate have re-introduced legislation aimed at preventing the abuse of offshore tax havens by multinational companies. Rep. Lloyd Doggett, D-Texas, a senior member of the tax-writing House Ways and Means Committee, and Sen. Sheldon Whitehouse, D-R.I., a member of the Senate… – Continue reading

HK, Singapore Home To Asia’s Highest Property Taxes

In its recent Asia-Pacific Residential Review, global property consultancy Knight Frank has said that Hong Kong and Singapore have the highest tax burdens on foreign property investors. It notes Singapore and Hong Kong have imposed taxes on foreign property buyers, such as additional duties, as a “macro-prudential tool … to… – Continue reading

American Business Problems with Hong Kong Bank Accounts? Singapore as an Answer

CDE Op-Ed CommentaryGiven the recent problems American trading companies are having in establishing bank accounts in Hong Kong, viable alternatives need to be found. These issues, which are directly related to the American IRS carrying out extensive investigations in Hong Kong concerning breaches of the new FATCA regulations, have made… – Continue reading

Solar Sukuk Marks Australia’s Debut Choosing Labuan Haven

(Bloomberg) — Australia is set to become the newest entrant to the Islamic debt market this year as a solar-power joint venture seeks to sell a debut sukuk in Malaysia’s offshore tax haven of Labuan. SGI-Mitabu, run by The Solar Guys International and Mitabu Australia Pty, has revived a plan… – Continue reading

The OECD’s BEPS Action Plan poses immediate challenges for oil and gas companies

Already on the radar of governments and regulatory bodies around the world, recent developments with respect to the Organization for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) Action Plan are raising further the profile of oil and gas companies globally with both tax authorities and the… – Continue reading

Overseas Chinese to get taxed

Chinese nationals and companies operating overseas, who hold their fortunes outside of China, will soon be required to pay taxes on their worldwide earnings come Feb 1. Part of Beijing’s New Year resolution to crack down on tax avoidance and evasion, the general anti-avoidance rule (GAAR) and new penalties will… – Continue reading

Canada Launches Anti-Evasion Electronic Funds Transfer Initiative

New Electronic Funds Transfer (EFT) rules have entered into force in Canada, requiring certain financial intermediaries to report incoming and outgoing transfers of CAD10,000 (USD8,446) or more to the Canada Revenue Agency. On January 7, 2015, Revenue Minister Kerry-Lynne D. Findlay announced the launch of the CRA’s EFT initiative. Effective… – Continue reading

Billions of rands leave SA under the radar

South Africa has lost out on billions in tax revenue in the past decade as large corporations, wealthy individuals and criminal syndicates slipped nearly R1-trillion out of the country. A Washington DC research and advocacy group, Global Financial Integrity, believes South Africa suffered “illicit financial flows” totalling more than $122-billion… – Continue reading

What’s in store for the business world in 2015?

Business editor Duncan Foulkes quizzes three prominent Isle of Man businessmen on their thoughts ——————– Chris Eaton, Chief Executive Officer, The ILS Group There is no one major issue or initiative that faces the CSP and TSP sectors in 2015. Rather, they face more of a continued barrage of supra… – Continue reading

UK Parliamentary Hearing Held On BEPS Response

British Members of Parliament (MPs) have questioned the Government’s unilateral decision to push for the introduction of a Diverted Profits Tax (DPT) ahead of the completion of the Organisation for Economic Cooperation and Development’s (OECD’s) work on base erosion and profit shifting (BEPS). In a debate held in Parliament on… – Continue reading

Arab League slams Israel for withholding Palestinian tax revenues

CAIRO, Jan 9 (KUNA) — The Arab League on Friday lambasted Israel for retaining the Palestinian tax revenues, terming the move as “theft and collective punishment” of the Palestinian people. In a press statement today, Assistant Secretary-General for Palestine and Occupied Arab Territories Affairs Mohammad Subeih stressed the necessity of… – Continue reading

Draft bill would allow Northern Ireland to set its own corporation tax rate from 2017, says UK government

The Northern Ireland assembly would be given the power to set its own corporation tax rate from April 2017 if draft legislation published by the UK government is passed.09 Jan 2015 Corporate tax Tax UK Europe The Corporation Tax (Northern Ireland) Bill forms part of last month’s Stormont House Agreement… – Continue reading

Real estate investment trusts may get taxation relief

CBDT to make provisions for MAT and reduce tax liability on Reits Jayshree P Upadhyay  |  New Delhi  January 9, 2015 Last Updated at 00:50 IST Real estate investment trusts (Reits), notified last year, have so far found few takers due to taxation-related issues. To address this, the Central Board… – Continue reading

Financial Institutions failing to register may face penalties

The Model 1B Intergovernmental Agreement signed between the Cayman Islands and the United States, sees those entities considered Financial Institutions (FI) that fall under FATCA, and have not registered with the IRS (to obtain a Global Intermediary Identification Number (GIIN), prior to 22 December 2014) now facing possible penalties (withholding)… – Continue reading

Voluntary disclosure in Israel- it’s time to become compliant

January 8 2015 As of 2003, Israeli tax residents are subject to tax in Israel on their worldwide income, including passive income (i.e., interest, dividends and capital gains) generated in their offshore bank accounts. Although more than a decade has passed, many Israeli residents have still not reported on income… – Continue reading

China Wants US Style Citizen Taxation to Cut Overseas Avoidance

As Chinese individuals and companies head overseas in greater numbers, the country’s tax authorities are starting to follow. The Beijing billionaires who set up cryptically named companies in the British Virgin Islands to hold their fortunes are in the cross hairs. So are the Guangdong salesmen living and working in… – Continue reading

The Anti-Inversion Rules of Notice 2014-52: A Trap for the Unwary ‘Blocker’

From Premier International Tax Library With the publication in September of Notice 2014-52, the IRS has made it extremely difficult for any foreign corporation that is not primarily engaged in an active business to acquire a U.S. business in exchange for its stock without risking being transformed into a U.S…. – Continue reading

US Internal Revenue Staff In Israel For Tax Evasion Talks

A delegation from the US Internal Revenue Service (IRS) visited Israel last week to meet representatives of the Israel Tax Authority. Sources inform “Globes” that the purpose of the meeting was to implement the agreement for the exchange of information between Israel and the US concerning the accounts of US… – Continue reading

CRA HAS NEW TOOLS TO FIGHT TAX EVASION

CRA has launched the Electronic Funds Transfer (EFT) initiative, introduced in the 2013 Budget as one of several new measures to crack down on international tax evasion and aggressive tax avoidance. Read: Top 10 tax changes of 2014 Effective January 1, 2015, certain financial intermediaries, including banks, have to report… – Continue reading

Singapore updates corporate tax guidelines to better align with West

SINGAPORE (Reuters) – Singapore is updating guidelines on an accounting practice mired in controversy for helping multinational companies minimize their tax bills, as the city-state moves more in line with a crackdown by Western governments on aggressive tax avoidance. International taxation has come under scrutiny since a quirk of “transfer… – Continue reading