Category: Legislation

US Senate Presents A Different Take On Tax Reform

The Senate Finance Committee released its tax reform plan on November 9, presenting a draft bill with marked differences to that agreed by the House Ways and Means Committee on the same day. The proposal was drafted by Finance Committee Republicans under the leadership of Senate Finance Committee Chairman Orrin… – Continue reading

Ghana leveraging technology to enhance tax collection: VP

ACCRA, Nov. 10 (Xinhua) — Ghana’s Vice-President Mahamudu Bawumia said on Friday Ghana was leveraging technology to broaden the tax base and enhance tax collection. He believes that Ghana has reached a stage in its development where it must adopt appropriate, current and improved technology to make tax administration convenient… – Continue reading

Dutch government continues with dividend withholding tax proposal and announces conditional retroactive amendment to CIT fiscal unity regime

In this Tax Alert we will briefly highlight two topical Dutch tax matters very relevant to internationally active companies: the current status of the legislative proposal regarding Dutch dividend withholding tax rules for holding cooperatives and BVs/NVs and the announcement of the Dutch Ministry of Finance that the Dutch fiscal… – Continue reading

IMF praises Philippines for placing casinos under AML act

The International Monetary Fund (IMF) has commended the Philippines for legal changes that brought the nation’s casinos within the scope of the country’s Anti-Money Laundering Act. “[The IMF] welcomes the recent amendment… to include casinos” under the act, the IMF executive board said in a press release issued on Monday,… – Continue reading

Republicans Reveal US Tax Reform Law

On October 2 the US Government released the Tax Cuts and Jobs Act, setting out in legislation its plans for comprehensive reform of the US tax code. For businesses, the bill will bring about a landmark shift to a territorial corporate tax system, replacing the current worldwide tax basis regime… – Continue reading

Russian Federation: BVI Ready To Disclose Beneficiaries

Goltsblat BLP advises that the Federal Tax Service (FTS) has approved BVI’s removal from the list of countries (jurisdictions) not exchanging information with the Russian Federation for tax purposes from 1 January 2018 (the relevant order is pending registration with the Ministry of Justice). A country’s removal from the FTS… – Continue reading

Cayman Budget Targets Budget Surpluses

The Cayman Islands’ Premier, Alden McLaughlin, recently delivered the territory’s first two-year budget, which was notable for the absence of new borrowing or revenue-raising measures. McLaughlin said his administration will continue to pay down debt and deliver operational budget surpluses to fund capital investment plans and provide for contingency against… – Continue reading

“FATCA on steroids”: T&T misses 2017 deadline to become tax compliant

T&T faces possible sanctions after the Global Forum recognised this country as the only jurisdiction not considered to have made sufficient progress towards satisfactory implementation of the agreed tax transparency standards. Speaking at a media conference on Friday afternoon, Attorney General Faris Al Rawi said this has negative implications for… – Continue reading

Turkey: Turkey Updates Rules On Double Taxation Prevention Treaties For Independent Professional Services

Turkey has clarified rules for taxing income derived from independent professional services (and similar activities) carried out within Turkey, by residents of countries which have double taxation prevention agreements with Turkey. The number of days a company’s employees spent in Turkey will now become the only basis for calculating the… – Continue reading

French Lawmakers Adopt 2018 Finance Bill

French deputies have adopted at first reading the 2018 Finance Bill, which includes several of the Government’s key tax measures. The bill, adopted by the National Assembly on October 24, will reduce compulsory levies by EUR10.3bn (USD12.1bn) by the end of 2018. The bill includes the abolition of the wealth… – Continue reading

Morrison Pushing For Australian Company Tax Cuts

Cutting Australia’s company tax rate is “now an urgent matter,” according to Treasurer Scott Morrison. In a speech to CEDA, Morrison said that with the UK, France, and the US each seeking to lower their corporate tax rate, Australian businesses risk “becoming stranded on an uncompetitive tax island if we… – Continue reading

OECD’s Gurria Calls For Collective Action On Digital Taxation

OECD Secretary-General Angel Gurria has called for a collective effort on the design of temporary, short-term measures to tackle the international tax challenges of the digital economy. Speaking at the Group of Twenty (G-20) Finance Ministers and Central Bank Governors meeting held in Washington on October 13, Gurria said: “There… – Continue reading

Mainland China briefing: Implementation of CRS

On 1 July 2017, the “Administrative Measures on Due Diligence of Non-resident Financial Account Information in Tax Matters” (the Measures) came into effect. The Measures were jointly promulgated in May 2017 by the State Administration of Taxation (SAT), the Ministry of Finance, the People‘s Bank of China, the China Banking… – Continue reading

Revenue receives just 11 tax scheme alerts in six years

Exemptions make the mandatory disclosure regime a joke, says MEP Matt Carthy The Revenue Commissioners have received just 11 reports of potentially abusive tax-avoidance schemes since Ireland made it mandatory in early 2011 for transactions giving “aggressive” tax advantages to be disclosed to authorities. The disclosure by Minister for Finance… – Continue reading

CbCR obligations for Italian entity members of US groups

Concerns have arisen over a temporary misalignment between the US country-by-country reporting regime and Italian legislation. Antonella Della Rovere and Federico Vincenti of Valente Associati GEB Partners explain. An agreement for the automatic exchange of country-by-country reports (CbCR) between Italy and the US (Agreement) came into effect on September 27… – Continue reading

Philippine Government `On a Roll’ Against Tax Evaders: Dominguez

(Bloomberg) — The Philippine government plans to target additional companies in its crackdown on tax evasion, said Finance Secretary Carlos Dominguez “We are on a roll, and this is part of the president’s program to make our country more law abiding,” Dominguez told Bloomberg Television’s Kathleen Hays in an interview… – Continue reading

Singapore Legislates For Income Tax Change

Singaporean lawmakers approved the Income Tax (Amendment) Bill 2017 on October 2, 2017, which provides for numerous changes to income tax policy. Discussing the bill in parliament, Indranee Rajah, Senior Minister of State for Finance, confirmed that the existing corporate income tax rebate for 2017 will be enhanced by raising… – Continue reading

EU Approves Rules to Fix 900 Cross-Border Double-Tax Disputes

European Union finance ministers gave formal approval to legislation designed to dramatically reduce the 900-plus unresolved company cross-border double taxation disputes. The Oct. 10 approval for the EU Double Taxation Dispute Resolution Directivecomes amid skepticism from tax professionals that it has the resources to be effective. It includes mandatory binding… – Continue reading

Ireland Seeks Comment on International Tax Strategy Plans

The Irish government is inviting businesses and practitioners to provide feedback on its plans to update its international tax strategy, including how Ireland should incorporate the OECD’s transfer pricing guidelines into national law and implement the European Union’s anti-tax avoidance rules. The consultation, which runs until the end of January… – Continue reading

EU Countries Seek Legislative End-Around on Digital Tech Tax

EU nations led by France and Italy reinforced the need for an “equalization tax” or turnover tax on large internet companies such as Facebook Inc. and Amazon.com Inc., and suggested they would use special legislative procedures to impose one in the event all 28 EU-member countries don’t back the levy…. – Continue reading

New Corporate Criminal Offences of Failure to Prevent Facilitation of Tax Evasion

Quick Guide Part Three of The Criminal Finances Act 2017 (CFA 2017) introduces two new corporate criminal offences: The failure to prevent facilitation of UK tax evasion offences The failure to prevent facilitation of foreign tax evasion offences Both “failure to prevent” offences can be committed by a body corporate… – Continue reading

Armenia insists on signing double taxation agreement with USA

YEREVAN, September 25. /ARKA/. Until 2022 Armenia will conclude agreements on the exclusion of double taxation with 8 more countries and will pursue an agreement also with the United States to abolish double taxation, Armenian finance minister Vardan Aramyan said at a press conference on Monday. So far Armenia has… – Continue reading

Partnership tax rules overhaul by 2018

Changes to partnership taxation are to go ahead with draft legislation now published, effectively clarifying the tax treatment for partnerships to ensure that the principle of taxing the beneficiary of partnership profit applies and to prevent a double reporting burden on investment partnership This measure makes changes to the income… – Continue reading

U.S. not going to abolish double taxation with Armenia: envoy

PanARMENIAN.Net – The United States is not going to abolish double taxation with Armenia, U.S. ambassador to Armenia Richard M. Mills told reporters on Wednesday, September 13, Sputnik Armenia reports. According to Mills, the double taxation issue was raised by the Armenian government, and the United States has repeatedly noted… – Continue reading

OECD releases guidance to ensure BEPS country-by-country reports are used appropriately.

Canada has implemented the country-by-country reporting requirement for large multinational enterprises (MNEs) contained in the 2015 Final Report on Action 13 of the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan.  Canada’s legislation is found in s. 233.8 of the Income Tax Act (Canada), and is supported by the… – Continue reading

Panama probe: First prosecutions are taken to court for off-shore tax evasion

While at the beginning of the year (The Indian Express, March 16, 2017) the number of requests sent by India stood at 283 cases, it has now crossed 300. And while the number of replies received from among these 13 jurisdictions stood at 165, that figure has now crossed 240…. – Continue reading

Non-dom taxpayers account for £9.3bn of UK tax receipts

Non-domiciled taxpayers contributed £9.3 billion to the UK economy in 2014/15 through a combination of income tax, capital gains tax and National Insurance contributions (NICs), according to newly-published figures. The number of non-doms paying tax in the UK marginally increased in 2014/15, to 121,300, up from 119,800 the previous year…. – Continue reading

Court Rules In Favor Of Taxpayer In Canadian TP Audit Case

The Federal Court of Canada has ruled that the Canadian Revenue Agency may not conduct further in-person interviews with representatives from a multinational corporation concerning its transfer pricing affairs, having already discussed earlier tax years. Cameco Corporation declined to produce approximately 25 personnel for oral interviews in relation to an… – Continue reading

Australia: Proposed changes to CGT main residence exemption for foreign residents

The Treasurer has recently released exposure draft legislation (Treasury Laws Amendment (Housing Tax Integrity) Bill 2017) in relation to removal of the CGT main residence exemption for foreign residents. The changes are part of the Commonwealth Government’s ‘housing affordability’ reforms announced in the 2017-18 Budget. This will affect both Australian… – Continue reading

African tax authorities consider how to boost revenue

African nations will have more resources at their disposal to meet the Sustainable Development Goals if their national revenue authorities can boost tax collection. The United Nations Economic Commission for Africa estimates that the continent loses more than $50 billion through illicit financial outflows per year, much of this linked… – Continue reading

UK: The UK Company: A Tax-Efficient Business Vehicle For International Investors

This article is the third of a series of articles that examines tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors in other offshore financial centres…. – Continue reading

Labor tries to force hundreds of Australian companies to publish secret tax data

Bill would require private companies with more than $100m in turnover to publicly release tax information Six hundred of Australia’s biggest private companies could finally be forced to publish their high-level tax information, under a new push by Labor to repair a notorious piece of legislation. Labor will introduce a… – Continue reading

Ireland Explains Transfer Pricing Documentation Rules

On August 3, 2017, the Irish Revenue published Revenue e-Brief No. 74/17, which contains guidance for taxpayers on complying with Ireland’s transfer pricing documentation requirements. The guidance notes that companies are legally required to maintain transfer pricing documentation. However, there is no requirement for documentation to be kept in a… – Continue reading

Tech-based tax services gain pace to ensure businesses comply with global digital transparency standards

Global consultancy EY among firms now offering advanced services that redefine how companies face new developments in tax, audit and compliance Rigid new global initiatives to increase transparency of business data are giving rise to more advanced professional tax services, which employ innovative tools that include cloud computing, financial technology… – Continue reading