WHEN the GAAR rule was launched it was one of the government’s first and biggest moves in its battle against tax avoidance, but since its introduction in 2013 the body tasked with enforcing the rule has been distinctly quiet despite claims that companies and their accountants are perpetrating tax avoidance… – Continue reading
PARIS: Singapore and France signed an amended Agreement for the Avoidance of Double Taxation (DTA) to lower withholding tax rates for dividends and new anti-abuse provisions. The most notable changes are the following: Withholding tax rate for dividends is reduced to 5 percent (from 10 percent previously) if the beneficial… – Continue reading
Over the past few years we have seen the introduction of various withholding taxes to the South African tax system. We set out below a high-level summary of the various withholding taxes that are levied in terms of the Income Tax Act 58 of 1962 (the “Act”), their rates and… – Continue reading
A fresh drive by the European Commission to ensure companies pay their tax where they make their profits could have far-reaching consequences for Irish corporate tax revenue. Some new pieces of legislation will be presented over the next few months, but one of the biggest could be the revival of… – Continue reading
The European Commission launched its work on its ambitious agenda to combat tax avoidance and aggressive tax planning. The College of Commissioners held a first orientation debate on possible key actions to ensure a fairer and more transparent approach to taxation in the EU.President Jean-Claude Juncker has made the fight… – Continue reading
The number of requests from foreign governments for tax information from the UK rose by 45 percent in 2013, according to international law firm Pinsent Masons. 2,466 requests were received by HM Revenue and Customs (HMRC) in the year to December 31, 2013, up from 1,701 recorded in 2012. James… – Continue reading
NUMBER OF THE WEEK: 3,415. The number of people who renounced their citizenship in 2014 according to IRS data. This is one of the five highest totals on record since the U.S. Congress passed the Foreign Account Tax Compliance Act in 2010. In the past five years, more than 10,000… – Continue reading
Those who are subject to the Foreign Account Tax Compliance Act (FATCA) – financial institutions – and those who have agreed with the US to help make it work – tax administrations – have a chance this week to get a feel for the mechanics of how information will be… – Continue reading
Probes since 2001 into offshore accounts include €4.6m from Irish HSBC customers The Revenue Commissioners has collected just more than €1 billion since 2001 from various special investigations of offshore bank accounts held by Irish residents. This includes the €4.6 million received to date from the holders of offshore accounts… – Continue reading
NEW YORK â?? A founder of famed New York City restaurant Le Périgord faces a potential three-year prison sentence that could take him away from the paragon of traditional French cuisine after he pleaded guilty to hiding income in offshore bank accounts. Georges Briguet, 77, admitted during a Brooklyn federal… – Continue reading
Sen. Bernard Sanders took aim at some of America’s biggest corporations Wednesday in his crusade to raise taxes on the wealthy, accusing the companies of “legalized tax fraud” for using off-shore banks to avoid U.S. taxes. Mr. Sanders, the ranking member on the Senate Banking Committee, released a report that… – Continue reading
Those who are subject to the Foreign Account Tax Compliance Act (FATCA) – financial institutions – and those who have agreed with the US to help make it work – tax administrations – have a chance this week to get a feel for the mechanics of how information will be… – Continue reading
BRUSSELS (AP) — The European Union has launched a drive to combat tax evasion following a series of probes into rules that allow multinationals to slash their bills in Luxembourg, Ireland and the Netherlands. The EU’s executive commission said Wednesday that it will propose new tax legislation next month, including… – Continue reading
CHINA China Releases GAAR Administrative Measures Courtesy of Mr Glen Wei, an attorney at law, certified tax adviser, and CPA based in China.China’s State Administration of Taxation (SAT) on December 12 issued Decree 32 (dated December 2) introducing administrative measures for applying the domestic general anti-avoidance rule to special tax… – Continue reading
This Tax Alert by EY summarizes a recent ruling of the Mumbai Income Tax Appellate Tribunal (Tribunal) in the case of Swiss Re-Insurance Company Ltd. (Taxpayer). The Tribunal ruled that the Taxpayer’s wholly-owned Indian subsidiary (ICo) engaged in carrying out risk assessment services, marketing insurance and providing administrative support for… – Continue reading
The abolition of unfair taxes was one of the foundational principles of Magna Carta, a document that King John assented to on June 15, 1215 at Runnymede, England. Taxation must be fair, and requires the consent of the people. There is no more unfair aspect of fiscal law than retroactive… – Continue reading
Police bosses have been accused of seeking to double tax residents through plans for communities to help fund community support officers. Norfolk Police and Crime Commissioner Stephen Bett yesterday defended his proposal that town and parish councils could contribute 50 per cent of the cost of a PCSO in their… – Continue reading
Every acquisition requires careful tax planning early on in the process, especially when dealing with cross border acquisitions. One important consideration when a foreign company plans to acquire a Canadian company is the impact of any tax treaties that currently exist between the two jurisdictions. Tax treaties effectively reduce tax… – Continue reading
Singapore and France signed a revised Agreement for the Avoidance of Double Taxation (DTA) on 15 January 2015, which is not yet in force. The new DTA provides for lower withholding tax rates for dividends and new anti-abuse provisions. The most notable changes are the following: 1. Withholding Tax Withholding… – Continue reading
Firms need clear rules, certainty to remain in compliance with tax law, says expert Heightened scrutiny of foreign companies’ tax practices is a sign of China’s effort to modernize its taxation system to keep up with the fast-changing international business environment, but there is another dimension that concerns the foreign… – Continue reading
PREMIER Rufus Ewing has called out United Kingdom Opposition Leader, Edward Miliband for published statements he recently made regarding the TCI being a tax haven. Miliband is reported in the UK press as stating that the UK overseas territories (OT) are not complying with UK directives on beneficial ownership of… – Continue reading
London Mayor Boris Johnson was born in New York City in 1964, and he has held dual British and American citizenship throughout his life. Recently, after months of grousing about having to pay a capital gains tax to the U.S. on the sale of his house in Greater London, Johnson… – Continue reading
UNTIL NOW, many British expatriates have been able to sell UK property without having to pay any capital gains tax in the UK. This changes from April when new rules come into effect. The concept of charging UK capital gains tax on the disposal of UK residential property owned by… – Continue reading
Some of the biggest listed Irish firms have subsidiaries in so-called ‘tax havens’, like the British Virgin Islands, Jersey or Luxembourg. They say it’s not to reduce their tax bills – so why are they there? The subsidiaries are registered in well-known offshore tax havens, such as the British Virgin… – Continue reading
The automobile industry is very important for the Indian economy, given its significant contribution to the national GDP, and the employment it generates directly and indirectly. After two years of sluggish growth, the fortunes of the industry seem to be changing. The latest forecast shows growth in almost all the… – Continue reading
NEW DELHI: The government plans to defer implementation of the General Anti Avoidance Rules (GAAR) until the time the tax administration is able to rebuild trust with companies on the controversial issue. “Given the low level of confidence in tax authorities, investors fear that the provisions may result in harassment…. – Continue reading
Budget should issue a) rules for announcements that were made in the budget in July 2014, (b) clarifications and guidance on matters that were at the centre of controversy during the past few years like equity infusion, valuations, etc. and (c) tax administrations, infrastructure and approach. The new government in… – Continue reading
The UK Treasury Committee has said that the draft legislation on the diverted profits tax (DPT) is unwieldy and stressed that the Government’s unilateral policy response should not destabilize international tax reform efforts. The Committee’s response to the plans are included in its new report on the Autumn Statement 2014,… – Continue reading
February 13 2015 Following the entry into force of the double tax agreement between Spain and Cyprus (for further details please see “New double taxation agreement between Cyprus and Spain enters into force”), the Spanish Ministry of Finance has announced that Cyprus has been formally removed from the Spanish tax… – Continue reading
If the Davis tax committee’s recommendations are followed, tax avoidance could be effectively reined in. Zeroing in on the super-wealthy and tax reluctant remains at the top of the global agenda as budgets across the world grow increasingly hungry for extra revenues. Now a draft report from the Davis tax… – Continue reading
Feb 12 (Reuters) – Brazilian Trade Minister Armando Monteiro said on Thursday he does not see much chance of agreeing on a tax treaty with the United States in the short term. In an interview during a visit to Washington, his first overseas trip as minister, Monteiro said double taxation,… – Continue reading
NEW DELHI: The much-feared general anti avoidance rules (GAAR) could be deferred by about two years so that business sentiment is allowed to improve in India but will need to be rolled out in some form or the other by 2017, in sync with the international framework on preventing treaty… – Continue reading
SINGAPORE: Singapore has signed agreements with France and Uruguay for avoidance of double taxation (DTA). In the agreement with France, the revised DTA offers improved terms for businesses, such as lower withholding tax rates for dividends and includes anti-abuse provisions. The signing took place in Singapore between Singapore Deputy Prime… – Continue reading
In a recent letter to the Committee on Foreign Relations, the American Institute of Certified Public Accountants (AICPA) requested that the US Senate urgently approve all pending bilateral double taxation agreements (DTAs) and protocols. The AICPA pointed out that the full Senate has not approved any DTA or protocol since… – Continue reading
New Delhi: Top officials from IT, BPO and e-commerce sectors have requested Finance Minister Arun Jaitley to address certain issues related to taxation in the Budget for fiscal year 2015-16, and provide incentives for setting up data centres in the country. They also suggested that the minister look at ways… – Continue reading
Private Sector Key KUWAIT CITY, Feb 11: The Parliament on Wednesday approved the development plan for fiscals 2015/2016 to 2019/2020 in its first and second readings with 33 votes in favor, four against and one abstention. It also approved the 20th report of the Finance and Economic Affairs Committee on… – Continue reading
Allowance of bilateral treaty for advanced pricing agreement should help mitigate issues around double taxation of income, feels brokerage house Morgan Stanley Moneycontrol Bureau Clarity around definition of export turnover and total turnover for computation of tax exemption in the Budget will help resolution of tax-related disputes, says brokerage house… – Continue reading
WASHINGTON DC — An international banking giant, HSBC, made huge profits by allegedly engaging in shady deals of over $270 million with some Zimbabwean citizens seven years ago, in the process, disadvantaging the poor southern African nation of the much-needed foreign currency, documents in Studio 7’s possession have revealed. BY… – Continue reading
“Well, Jon, the Government’s about to bring in a 1.5% corporate, or company, tax cut from the 1st of July. That’s something that obviously we support, because (the) corporate tax rate at 30% is not competitive with the rest of the region and we need to drive that down.” –… – Continue reading
Island’s History of Robust Regulation, Rule of Law, Global Tax Treaties and Lack of Bank Secrecy Laws Ought to be Recognised by UK Labour Party HAMILTON, Bermuda, Feb. 10, 2015 (GLOBE NEWSWIRE) — Bermuda’s well-documented financial services regulation, international partnership treaties, and lack of bank secrecy legislation ought to be… – Continue reading
Bermuda’s well-documented financial services regulation, international partnership treaties, and lack of bank secrecy legislation ought to be recognised by the UK Labour Party, the Bermuda Business Development Agency (BDA) said today. The BDA echoed the Bermuda Government’s weekend response to UK Opposition Leader Ed Miliband following a warning letter issued… – Continue reading
The International Chamber of Commerce (ICC) joined discussions today with G20 Finance Ministers and Central Bank Governors to set priorities for continued economic growth during the Turkish G20 presidency. As part of Turkey’s G20 platform for inclusiveness, implementation, and investment – the three I’s of the government’s G20 2015 presidency… – Continue reading
Call it the pass-through revolution. The U.S. has been losing about 60,000 conventional corporations a year, according to the Tax Foundation. It’s lost 1 million since 1986, the foundation said. Meanwhile, the number of pass-through entities has exploded. “More than 60 percent of U.S. business profits are now taxed under… – Continue reading
The mainland has stepped up its participation in the G20’s fight against international tax avoidance by passing a law cracking down on the indirect sale of assets outside the country to avoid paying taxes. The law would affect investment companies, analysts said, adding it would also have a significant impact… – Continue reading
On February 6, 2015, the Organisation for Economic Co-operation and Development (OECD) announced that it has reached agreement with the Group of Twenty (G-20) Finance Ministers on three key elements of its base erosion and profit shifting project. The three elements, which the OECD said will enable implementation of the… – Continue reading
Switzerland and Liechtenstein have concluded negotiations toward a new double tax agreement (DTA), which should enter into force from January 2017. Switzerland’s Federal Department of Finance (FDF) announced on February 5, 2015, that talks concluded on February 2. The FDF expects the deal to be signed this summer and, pending… – Continue reading
After several years of delays, the Foreign Account Tax Compliance Act (FATCA) finally took effect on July 1, 2014. Congress enacted FATCA as part of the Hiring Incentives to Restore Employment Act in 2010 to stop U.S. taxpayers from evading U.S. taxes through undisclosed offshore accounts and investments. FATCA requires… – Continue reading
NEW DELHI, FEBRUARY 9: The “door for dialogue” with India remains open despite the current “difficult environment” on the tax-related information sharing front, the Swiss Finance Ministry has said. In a just released annual report on International Financial and Tax Matters 2015, Switzerland has admitted that its relations with India… – Continue reading
The nation’s largest organization of accounting and tax professionals is urging the Senate to approve income tax treaties between the U.S. and various countries. In a February 3 letter to Senator Bob Corker (R-Tenn.), chairman of the Senate Committee on Foreign Relations and Senator Robert Menendez (D-N.J.), the committee’s ranking… – Continue reading
Guest Post by Andrew Blair-Stanek, Assistant Professor of Law at University of Maryland Carey School of Law Patent owners routinely tell the IRS, under penalties of perjury, that their patents have little value. Litigators representing defendants should take advantage of these remarkable admissions. IP has become the world’s leading tax… – Continue reading
