Ireland Transfer Pricing Feedback Statement Explained
The Irish Government recently published a Transfer Pricing Rules Feedback Statement which is explained in this article. ... - Continue reading
Category: Tax Laws
United States: Senators Introduce Bill To Require Reporting Of Beneficial Ownership Information
A bipartisan group of senators introduced a bill which would impose federal beneficial ownership reporting requirements for legal entities established under state law, intended to assist law enforcement in fighting money laundering and terrorist financing ("AML/CFT"). ... - Continue reading
Nigeria: Key Considerations On Employment And Remuneration Of Expatriates In Nigeria
The natural resources and the economic opportunities in Nigeria continue to attract foreign direct investments (FDI) by investors across the world. ... - Continue reading
Citizenship, residency and tax liability
Is it true that if I become Italian I have to pay taxes in Italy? “I am a U.S. citizen and I plan to move my residency to Italy. I will continue working remotely for my U.S.-based company and will continue paying my taxes in the U.S. What should I… – Continue reading
Argentina issues burdensome draft transfer pricing guidance for public comment
Argentina’s tax authority on October 2 launched a public consultation on proposed guidance that includes significant and burdensome changes to the transfer pricing requirements that local taxpayers must comply with. ... - Continue reading
Accidental Americans’ sue France over FATCA disclosure rules
A group representing French-American taxpayers has filed a complaint against France with the European Commission over its compliance with the US Foreign Account Tax Compliance Act (FATCA), in a bid to avoid being blacklisted by French banks starting in January. France is a signatory to an agreement to give the… – Continue reading
EU to remove UAE and Switzerland from tax blacklist
The United Arab Emirates and Switzerland are set to be removed from a European Union blacklist of countries deemed to be tax havens, according to a Reuters report citing an official document. Switzerland has delivered on its commitments, the document said, acknowledging that a tax reform passed last year –… – Continue reading
BIR warns delinquent POGOs anew
The Bureau of Internal Revenue (BIR) said that service providers for Philippine offshore gaming operators (POGO) must cooperate and comply with the tax authorities to avoid revenue losses once they become subject for closure. BIR Commissioner Caesar R. Dulay said that POGO service providers should be prepared to incur millions… – Continue reading
NRIs or RNORs are generally not liable to pay tax in India on foreign income
If you wish to retain the NRI status to avoid clubbing of US salary with Indian income for tax purposes, it would be advisable for you to restrict your stay in India to less than 60 days during FY20 ... - Continue reading
Worldwide: Financial Institutions And Personal Data
Combating Tax EvasionIn recent years, there have been several high-profile prosecutions for the crime of tax evasion (for example the actor, Wesley Snipes, and the footballer, Lionel Messi). Governments around the world have been making a concerted effort in an attempt to tackle this problem. Their objective is for their respective tax administrations to work together so that taxpayers pay the correct amount of tax in the correct jurisdiction. ... - Continue reading
LCCI help sought on tax issues
LAHORE: Lahore traders having failed to convince the Federal Board of Revenue on taxation measures have sought the assistance of the Lahore Chamber of Commerce and Industry (LCCI) to plead their case, a statement said on Saturday. LCCI President Irfan Iqbal Sheikh, Senior Vice President Ali Hussam Asghar and Vice… – Continue reading
Bermuda: Chambers Private Wealth 2019: Bermuda (2019)
1. Tax1.1 Tax regimes In Bermuda there is no income or profits tax, withholding tax, capital gains tax, capital transfer tax or inheritance tax. There is no exit or similar such tax based on a resident's wealth when ceasing to be resident and there are no other consequences of leaving the jurisdiction. Customs duties and stamp duty are major government revenue earners, with stamp duties charged at different rates and in different manners on a variety of legal documents, excluding wills. ... - Continue reading
Cyprus: Convention Between The Republic Of Cyprus And The Netherlands For The Avoidance Of Double Taxation
Last week saw Cyprus add The Netherlands to the long list of countries with which it has signed double taxation agreements. ... - Continue reading
Paraguay introduces transfer pricing rules
Paraguay, on September 13, enacted special regulations providing for the transfer pricing analysis of intercompany transactions. ... - Continue reading
UK: Ways For UK Businesses And Foreign Investors To Mitigate Uncertainty Around Brexit
The UK remains in the international spotlight in 2019 as the first member of the European Union to signal its intention to exit irrevocably from the Union. ... - Continue reading
Draft “toolkit” aims to help developing countries with transfer pricing documentation
The Platform for Collaboration on Tax – a joint initiative of the International Monetary Fund, OECD, United Nations, and World Bank Group – on September 27 released a draft “toolkit” aimed at helping developing nations design transfer pricing documentation rules. ... - Continue reading
Imminent Changes To US Immigration Program
There has been a lot of recent media attention surrounding the EB-5 Investment Visa Program, and for good reason. South African residents are not able to emigrate for exchange control purposes (sometimes referred to as a financial emigration) unless they have a lawful right of abode in the country to… – Continue reading
Turkey: new tax audit wave focuses on non-resident digital companies
Turkey’s government has initiated a new wave of tax audits scrutinizing the taxation of non-resident taxpayers engaged in the digital economy. ... - Continue reading
East Africa bloc mulls regional tax treaty framework to boost integration
NAIROBI, Oct. 1 (Xinhua) — The East Africa Community (EAC) bloc plans to develop a regional tax treaty framework to boost regional integration, an official said on Tuesday. Doris Akol, commissioner general, Uganda Revenue Authority told Xinhua in Nairobi that once the treaty is in place the trading bloc will… – Continue reading
Switzerland moves to end bearer shares
The Swiss government will begin to phase out bearer shares on 1 November in a bid to curb tax avoidance by bearer shareholders. Under the new rules companies no longer issue bearer shares—equity in a company that is owned by whoever holds a physical stock certificate—unless they are a listed… – Continue reading
Africa needs disruptive tax policy to tax digital businesses
Panelists of the 7th Pan African Conference on tax and Illicit financial flows, stress that Africa needs disruptive tax policies that respond to the positively disruptive digital businesses such as uber. ... - Continue reading
Ireland must prepare for international tax turbulence
It looks like the world’s leading economies are determined to claim a bigger slice of the global corporate tax pie which will lead to tricky times ahead for Ireland, according to PwC tax policy leader Peter Reilly ... - Continue reading
Uganda: Don’t Make Up Losses To Avoid Tax
Conflicting interests arise for many businesses where decisions have to be made to determine how they consistently achieve profitability, while on the other hand minimise payment of tax. The temptation to minimise profits or even make a loss then becomes a tax risk management strategy. ... - Continue reading
Jersey: Capital Markets: Listing Jersey Holding Companies
With £184 billion market capitalisation held by Jersey listed companies on global exchanges as of 30 June 2019, this briefing explores why Jersey vehicles remain such a popular choice for taking international businesses to market. ... - Continue reading
EU ready to act alone on digital tax if no global deal in 2020
Ramping up pressure on multinationals accused of paying too little. ... - Continue reading
Ukraine: Ukraine Ratifies Protocol Amending Double Taxation Treaty Between Ukraine And Switzerland
On 18 September 2019, the Parliament of Ukraine ratified a protocol (the Protocol) of amendments to the double tax treaty between Ukraine and Switzerland (the DTT) which had been signed by the states on 24 January 2019. ... - Continue reading
Dutch government asks banks to give American expats more time to deal with FATCA
The Dutch government is urging banks to be accommodating towards American nationals who risk having their bank accounts closed because of US fiscal regulations as it calls on EU member states to campaign together for changes to American tax laws which are affecting thousands who have American nationality but no… – Continue reading
Despite big corporate tax cut gains, ITC’s stock has not fired up enough
- News flow on the potential sale of an 8% govt stake in ITC held by SUUTI has weighed on sentiments, say analysts
- Sure, the tax cut gives ITC room to delay price hikes and that may prove helpful
Important tax changes for home owners from next April
QUESTION: I’m in the process of selling our family home and down sizing to a smaller property. I have just completed the purchase of our new home and we intend to move in soon. Our current home has been on the market for six months but we haven’t been able… – Continue reading
US/UK tax series: US citizens moving to the UK
If you are a US citizen who is becoming UK resident you will continue to be subject to US tax and reporting obligations but will also become subject to UK tax. ... - Continue reading
BIR padlocks main office, 2 branches of tax-dodging POGO service provider
The Bureau of Internal Revenue (BIR) padlocked simultaneously Wednesday the main office and two branches of one of the biggest Philippine Offshore Gaming Operator (POGO) service providers in the country for alleged failure to register and pay the corresponding deficiency taxes amounting to P2 billion. Shuttered were the headquarter of… – Continue reading
Portugal: Portuguese Tax Law – New Provisions To Meet The EU Anti-Tax Avoidance Directive (ATAD)
On 3 May 2019, Portugal introduced amendments to Portuguese Taw Law, in accordance with the European Union (EU) Anti-Tax Avoidance Directive (ATAD). ... - Continue reading
Australian tax office advises on transfer pricing for offshore drilling
The Australian Taxation Office (ATO) on September 27 set out its approach to analyzing transfer pricing issues associated with the use in Australian waters of non-resident owned mobile offshore drilling units such as drill-ships, drilling rigs (including but not limited to submersibles, semi-submersible and jack-up rigs), pipe-laying vessels, and heavy-lift vessels. ... - Continue reading
Indian court rules Hitachi Singapore’s liaison office is a permanent establishment
In a landmark ruling, the Delhi bench of the Income Tax Appellate Tribunal has concluded that a liaison office could be treated as a permanent establishment of a foreign entity in India. ... - Continue reading
Hong Kong signs tax treaty with Estonia
The Hong Kong government today announced that Hong Kong and Estonia have signed a comprehensive tax treaty. ... - Continue reading
CITIRA set to replace outdated tax scheme
Finally, the outdated and “dysfunctional” tax regime based on gross income earned is now about to end with the expected enactment into law of the new Corporate Income Tax and Incentives Rationalization Act (CITIRA), which the House recently passed with a vote of 170 versus eight against and six abstentions. … – Continue reading
Armenia, Malta sign double tax treaty
YEREVAN, SEPTEMBER 25, ARMENPRESS. Armenian Foreign Minister Zohrab Mnatsakanyan on September 24 met with Malta’s Minister for Foreign Affairs and Trade Promotion Carmelo Abela on the sidelines of the 74th session of the UN General Assembly in New York, the Armenian ministry told Armenpress. The officials praised the current dynamic… – Continue reading
Denmark tax bill clarifies timing rules for transfer pricing documentation
Denmark’s Ministry of Taxation on 12 September published a draft bill proposing a number of changes to Denmark’s international tax provisions including a requirement to submit transfer pricing documentation together with the corporate income tax return. ... - Continue reading
EU court backs use of arm’s length principle to assess Starbucks, Fiat APAs for state aid violation
The EU General Court today released long-awaited rulings in the Fiat and Starbucks tax state aid cases, concluding in both decisions that it is appropriate for the European Commission to assess whether an advance pricing agreement (APA) confers a selective advantage to a taxpayer for state aid purposes by referring to the arm’s length principle. ... - Continue reading
Taxation of the digital economy, future of debt, and other OECD updates during the IFA Congress 2019 in London
The IFA Congress 2019, held 8-12 September in London, brought together leading international tax and transfer pricing experts from around the world. ... - Continue reading
Mexico 2020 tax reform: big changes proposed for foreign companies doing business in Mexico
On September 8, the executive branch of the Mexican government introduced Mexico 2020 tax reform, proposing far-reaching changes to the Mexican income tax, value-added tax, and Federal Tax Code. ... - Continue reading
Wealth managers not ready for rise in HNWI demand for offshore investments: GlobalData
Wealth managers will have to review their offshore service propositions in lieu of an expected rise in high net worth (HNW) demand, according to GlobalData, a data and analytics company. GlobalData’s 2019 Global Wealth Managers Survey noted that 50.2% of industry participants expect HNW demand for offshore investments to rise… – Continue reading
Netherlands: The Netherlands: Tax Plan 2020
On September 17, 2019, the Dutch government released the Budget 2020 containing its Tax Plan 2020 with certain amendments to Dutch tax law. ... - Continue reading
BSP study dismisses risks of POGOs pullout
Initial results of a study conducted by the Bangko Sentral ng Pilipinas show that an immediate pullout by Philippine offshore gaming operators from the country will not have an impact on the financial stability, Governor Benjamin Diokno said Tuesday. Diokno asked the BSP’s Financial Stability team and the Anti-Money Laundering… – Continue reading
India fires bazooka to lift economy, slashing corporate tax rates and enacting other tax relief
In a development that surprised businesses and the stock market, India’s Finance Minister on Friday announced a significant reduction in the corporate tax rates. ... - Continue reading
VAT on online purchase must if not paid by cos during sourcing: NBR
Value-added tax on online purchase of goods and services will be applicable if the e-commerce company concerned collects those from the original suppliers and manufacturers without paying VAT, according to the National Board of Revenue. ‘There will be no VAT on online purchase of any goods and services if the… – Continue reading
Dutch tax office demands £902m in back taxes from British American Tobacco
The Dutch tax authorities have issued British American Tobacco with a €1bn bill for back taxes after a tax evasion investigation, website De Onderzoeksredactie has reported. ... - Continue reading
Foreign investors inject $143.6 million in t-bills since July
KARACHI: Foreign portfolio investors invested $143.633 million in treasury bills from July onwards as the present government started betting on overseas funds into debt securities to finance budget deficit and refinance maturities. The State Bank of Pakistan’s (SBP) latest data showed that outflow from portfolio investors amounted to $5.808 million… – Continue reading
Russia may stop automatic tax data exchange with Britain, dependencies: media
MOSCOW, Sept. 20 (Xinhua) — The Russian Federal Tax Service (FTS) may stop the automatic exchange of financial information with Britain and its dependencies — the Isle of Man, Guernsey and Jersey, TASS news agency reported Friday, quoting an FTS draft order. According to the news report, the draft order… – Continue reading
