Category: Tax Laws

Cayman begins to see a rise in hybrid funds

UBS Fund Services has had one of its strongest years in terms of winning new clients according to Monette Windsor (pictured), who heads up the Cayman Islands business.   “We’ve invested heavily in our business development team this year and we’ve had to beef up our client onboarding team. We have 165… – Continue reading

Looking back at pensions, platforms and regulation in 2014

Bravura Solutions reflects on a year of reform and looks forward to 2015. The Chancellor’s Autumn Statement last week didn’t deliver anything as revolutionary as the reforms announced in his March budget, but there were a few early Christmas crackers around ISA rules. After a monumental year, let’s look at… – Continue reading

Ranking Facebook, Boris Johnson, Google On Taxes (Diplomatically Please)

Ambassadors are supposed to be diplomatic and suave. Yet even those of the diplomatic corp may occasionally get tongue-tied or utter ill-timed statements. Take U.S. Ambassador to Britain Matthew Barzun. He recently sounded not all that diplomatic about duty, compliance with law, and yes, even taxes. Lee Rigby was a… – Continue reading

Offshore tax probe seeks data from Panama firm

NEW YORK – The multiyear federal crackdown on wealthy Americans who duck taxes by hiding income and assets offshore is targeting a Panamanian legal services firm suspected of arranging anonymous banking services. A Manhattan federal judge on Friday approved special summonses for Sovereign Management & Legal. The approval also covered… – Continue reading

uncker turns tax debate away from Luxembourg and on to entire EU

Debate on multinational tax avoidance widens The surprise announcement by the European Commission that it is to extend its request for information on tax rulings to all European Union member states has the potential to significantly shift the terms of the debate on multinational tax avoidance. The timing of the… – Continue reading

Piketty Sticks to Wealth Tax Proposal, Sees Positive Signs

Thomas Piketty’s “Capital in the 21st Century” was a 2014 must-read for anyone interested in economics. But while his claim that income and wealth inequality has risen over recent decades to highs last seen before the start of the First World War was widely accepted, his policy prescriptions were not…. – Continue reading

Australia Decides to Keep Bitcoin Sales Tax, Risks Double Taxation

In a blow to Bitcoin’s international presence, Australia has confirmed it will keep its controversial sales tax policy for certain Bitcoin transactions. Following the Australian Tax Office (ATO) issuing the initial legislation earlier this year, considerable community opposition arose, with domestic exchange Coinjar even forced to relocate to the UK… – Continue reading

Billionaire Usmanov transfers key assets to Russian jurisdiction

“These measures were taken in line with the policy announced by President Vladimir Putin for the Russian economy’s de-offshorization,” USM Holdings owned by billionaire Alisher Usmanov said MOSCOW, December 19. /TASS/. USM Holdings owned by billionaire Alisher Usmanov is transferring key assets to Russian holding companies, USM said in a… – Continue reading

The Best Job in the World

This is going to be the plum job for any international tax practitioner: Competent Authority for the Republic of Ireland. It seems pretty clear that the Base Erosion and Profit Shifting (BEPS) project will meet its announced deadline of the end of 2015 to produce final reports on all of… – Continue reading

EU shines light on dirty money with central registers

The European Union has agreed rules to stamp out tax evasion and stop dirty money from criminal gangs or terrorism finance being channelled through anonymous companies. EU states and the European Parliament struck the agreement on Tuesday evening to update the bloc’s anti-money laundering rules, a statement from parliament’s economic… – Continue reading

Luxembourg accedes to EU antitrust demand to divulge tax data

(Reuters) – Luxembourg acceded on Thursday to the demand of the European Commission to release data to further EU antitrust regulators’ investigation into whether it allowed multinationals to pay excessively low taxes. The European Commission launched investigations this year into whether U.S. retailer Amazon (AMZN.O) and a unit of Italian… – Continue reading

Tax Inversions Wrap Up

There has been a recent surge in anti-tax inversion legislation discouraging companies attempting to shift corporate subsidiaries or headquarters to low-tax or tax-free countries. The issue was subjected to a great deal of publicity in April 2014 during the failed hostile takeover by Pfizer (NYSE:PFE) for AstraZeneca (NYSE:AZN) when Pfizer… – Continue reading

Anti-corruption rules fail to force clarity on property ownership, MPs say

Coalition plan for stripping ‘cloak of secrecy’ from shell firms that leaves housing loophole slated by politicians and other critics Business minister Matthew Hancock unveiled ‘the first UK anti-corruption plan bringing action across the government’. Photograph: Jack Taylor/Barcroft Media Government plans to rip “the cloak of secrecy” from corrupt officials… – Continue reading

Wolters Kluwer Financial Services Issues FATCA Guidance for Banks in Asia

Regional Adoption on Pace with Europe as Singapore Signs Agreement Experts at Wolters Kluwer Financial Services today issued guidance on the Foreign Account Tax Compliance Act in an effort to help support banks’ regulatory compliance efforts within the region. The commentary comes in reaction to the news last week that… – Continue reading

Income tax on Facebook, Twitter likely next year

India will start charging income tax on digital economy firms, such as Facebook, Twitter and Uber, soon after the OECD finalises a framework by April 2015 to tackle the widespread corporate practice of shifting of profits to low-tax countries, government officials said on Wednesday. Tax may be levied on overseas… – Continue reading

Indonesia Bans Some From Travel in Tax Evasion Drive

Jakarta. Indonesia has banned from foreign travel senior representatives of 147 firms and 21 individuals with outstanding tax bills amounting to $42.8 million as part of a crackdown on tax evasion, the finance ministry said on Wednesday. The tax office, which is under finance ministry, is also processing bans on… – Continue reading

Government proposes separate unit for disposal of transfer pricing case

NEW DELHI: India is proposing to set up a dedicated dispute-resolution unit for expeditious disposal of transfer pricing cases that have in the past few years evoked strong reaction from domestic and international investors, with some dubbing this ‘tax terrorism’. Through this measure, the new government hopes to send out… – Continue reading

Luxembourg budget 2015 – main tax measures at a glance

Advance Agreements The so-called tax rulings and advance pricing agreements will be formalised by the introduction of appropriate provisions in the Luxembourg tax laws. By this means, Luxembourg will be able to offer as from 1 January 2015 a unified system providing taxpayers with legal certainty and a consistent and egalitarian… – Continue reading

Australia: End of calendar year: Transfer pricing, changing duty rates and other customs considerations

2015 promises to be a big year from an Australian customs perspective. However, before turning to the events of 2015, the end of 2014 brings issues of changing duty rates, transfer pricing adjustments and developments in our existing free trade agreements that need to be considered. Below we set out… – Continue reading

Company Tax Deals Across EU Face Scrutiny as Probe Widens

The European Union’s probe of tax deals expanded as the competition regulator asked all EU countries to give it information about financial agreements with multinational corporations. The EU is seeking lists of every company granted a so-called tax ruling between 2010 and 2013, the European Commission said today in an… – Continue reading

US Business Attacks Proposed UK Diverted Profits Tax

The United States Council for International Business (USCIB) has warned that the United Kingdom’s proposal to impose a new tax on so-called “diverted profits” (DPT) would, if implemented, have a major impact on US-based multinational companies. The rules, contained in UK Government’s recent Autumn Statement, propose a 25 percent DPT… – Continue reading

Policy of inaction on multinational tax

Heading into the G20 in Brisbane last month, Treasurer Joe Hockey thundered that multinational companies who avoided paying tax were akin to “thieves” whose actions rendered it harder for governments to tackle poverty. Sadly however the government’s actions have failed to match its rhetoric. This week’s crafty back-down on Section… – Continue reading

German Estate Tax, Credit Raters, HFT Study: Compliance

The German government must revise rules that allow families to transfer companies from one generation to the next without paying estate tax after the country’s top court ruled the current exemption is unconstitutional. The inheritance law gives an unfair advantage to family-owned businesses over individuals passing on non-company assets, the… – Continue reading

Singapore, Indonesia on track to curb cross-border tax evasion

An agreement to help crack down on cross-border tax evasion is being worked on by Singapore and Indonesia. The two nations are working on implementing the framework for the automatic exchange of information (AEOI) on tax matters, as they look to keep improving trade and investment ties. The move was… – Continue reading

Worldwide exchange of tax information: OECD expands upon FATCA to add new requirements

While the Foreign Account Tax Compliance Act (FATCA) has focused worldwide attention on U.S. efforts to create a mandatory cross-border exchange of tax information, the enactment of FATCA was not an isolated occurrence. For more than a decade, the Organisation for Economic Co-operation and Development (OECD) has been trying to… – Continue reading

Australia – Transfer pricing recordkeeping, final guidance

December 17: The Australian Taxation Office (ATO) today finalised the transfer pricing ruling TR 2014/8, outlining the Commissioner’s views on the application of the recordkeeping provisions in Subdivision 284-E of Schedule 1 to the Taxation Administration Act 1953 (Subdivision 284-E). Taxpayers need to adequately address the requirements of Subdivision 284-E… – Continue reading

Netherlands – Tax regulation with Curaçao not effective before 2016

December 17:  The Dutch Ministry of Finance announced that a new regulation for the avoidance of double taxation between the Netherlands and Curaçao is expected to be effective beginning 1 January 2016. The Dutch government bill concerning this regulation is pending consideration by the Lower House. Once approved, the bill… – Continue reading

Shell Companies Face Disclosure in EU Anti-Tax-Dodge Deal

Companies will be forced to disclose their ultimate owners on national registers in European Union nations as the bloc seeks to clamp down on tax dodging, money laundering and terrorism financing. European Parliament legislators and representatives of 28 EU national governments struck a deal late yesterday to upgrade the bloc’s… – Continue reading

Japan, Qatar reach tax treaty agreement

TOKYO, Dec 17 (KUNA) — Japan and Qatar have reached a substantive agreement on a bilateral tax treaty that will help businesses and investors avoid double taxation involving the two countries, the Foreign Ministry announced Wednesday. The agreement aims to clarify the taxation on cross-border investment and economic activities between… – Continue reading

Financial Group Wants More Limits on Corporate Inversions

The FACT (Financial Accountability and Corporate Transparency) Coalition today submitted comments to the Treasury Department praising their previous actions to limit inversions while also calling for additional measures. The proposals come as a part of the open comment period for Notice 2014-52, Rules Regarding Inversions and Related Transactions, originally issued… – Continue reading

Government renegotiating tax treaties to curb flow of black money abroad, says Finance Ministry

To check illicit financial flows across borders, the government is renegotiating bilateral treaties with many countries to limit tax benefits to genuine investments and curb the routing of Indian money to safe havens, a senior Finance Ministry official said on Wednesday. While noting that the quantum of domestic black money… – Continue reading

ATO chief identified tax ‘abuse’ by multinationals before Joe Hockey backed away from reform pledge

The head of the Australian Tax Office, Chris Jordan, has described a tax lurk for multinational companies that is being retained by the Abbott government as having been “abused” by foreign corporations at a cost of “hundreds of millions of dollars” a year to the Commonwealth. As revealed by Fairfax… – Continue reading

UK clamps down on tax avoidance

(CNS Business): The British government has published draft legislation for a new Diverted Profits Tax (DPT), dubbed the “Google tax”, by which it intends to sidestep Britain’s existing tax treaties with low-tax jurisdictions by levying a charge that would fall outside the corporate tax system. The government hopes to raise… – Continue reading