After several rounds of negotiations, on 28 March 2014, a new Double Taxation Treaty (“new DTT”) was signed between the governments of the PRC and Germany to replace the old DTT which was signed by both governments on 10 June 1985. The new DTT incorporates new elements of a typical… – Continue reading
Here come the tax acronyms; FATCA, AEOI, specified US persons & the potential for a tax residence licence in your wallet alongside your driver’s licence Posted in Personal Finance April 15, 2014 – 07:22am, By Gareth Vaughan First we get FATCA then we’ll get AEOI. Apologies for the acronyms. FATCA… – Continue reading
HMRC ‘Must Change Approach’ To Successfully Tackle Tax Evasion April 14th, 2014 Legal Expert Reacts To Offshore Evasion Strategy Document HM Revenue and Customs (HMRC) needs a change in approach rather than more powers if it is to improve its efforts to tackle tax evasion, according to a legal expert… – Continue reading
More than three people a day have disclosed offshore income or assets in the fortnight since the Australian Taxation Office announced an amnesty, The Australian Financial Review reports. According to the newspaper, tax commissioner Chris Jordan said early results were promising, with 16 disclosures and 33 expressions of interest about possible disclosures… – Continue reading
Mauritian conglomerate Ireland Blyth IBLP.MZ says uncertainty over new tax rules by key trading partner India has affected its business by putting off investors using the Mauritius financial center to invest in India. Nicolas Maigrot, chief executive of the group which has a wide range of interests in financial services,… – Continue reading
The Liechtenstein Disclosure Facility (LDF) is a tax disclosure facility for UK taxpayers. It is open to those with unpaid UK tax liabilities who had assets outside the UK (whether or not in Liechtenstein) as at 1 September 2009. It can be used to regularise their tax affairs on preferential… – Continue reading
Article 27 of the new double taxation agreement between Spain and Cyprus provides that the agreement will enter into force three months after the exchange of official notifications between the governments concerned that all ratification procedures have been completed. We understand that notifications were exchanged in March, which means that… – Continue reading
India had received in $8.17 bn during April- January 2012-13 Foreign Direct Investment inflows from Mauritius have almost halved during April-January period of last fiscal to $4.11 billion on fears of impact of GAAR and possible re-negotiation of the tax avoidance treaty. India had received in $8.17 billion during April-… – Continue reading
Introduction Article 10 of the Russia-Cyprus double tax agreement grants taxing rights over dividends to the state of residence of the company paying the dividends (in addition to the state of residence of the recipient). The tax that may be imposed in the state in which the dividends originate is… – Continue reading
The Government of the Kingdom of Denmark and the Government of the Republic of Ghana have signed the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains In relation to the Danish Minister for Trade and Development… – Continue reading
1. The traditional attitude to tax avoidance is encapsulated in the judgment of Lord Tomlin in the English case of IRC v Duke of Westminster (1936): “Every man is entitled if he can to arrange his affairs so that the tax attaching under the appropriate Acts is less than it… – Continue reading
A joint effort by India and the US to amicably decide on their respective shares of taxes from IT and ITeS companies operating in both countries is threatening to unravel, owing to a big, seemingly unresolvable gap between the transfer pricing (TP) margins individually determined by them. While New Delhi… – Continue reading
The OECD has been prolific in its publication of discussion documents since the start of the year. OECD discussion draft documents have been released in respect of: Action 13: Transfer pricing documentation and country by country reporting – 30 January 2014 The BEPS Action Plan issued on 19 July 2013… – Continue reading
They have big money and experienced staff, and operate with effortless sophistication. These are some of the features of multinational companies that use complex instruments to avoid paying taxes especially in developing countries. Mindful of this, Uganda Revenue Authority is keeping on guard. The tax body has joined a global… – Continue reading
On Tuesday, the House Ways and Means Committee holds a hearing to discuss making permanent several of multinationals’ favorite tax code provisions, including the Apple loophole. Thus the House, like the Senate, is in the early stages of enacting these expired provisions yet again. That’s how Congress traditionally gives multinationals their offshore tax loopholes: propose… – Continue reading
Given the proximity of Canada to the U.S., it is not surprising that many Canadians own real estate south of the border. Some, especially those who are retired snowbirds, also spend a good part of the year in the U.S. It is important to understand what the tax implications are… – Continue reading
Commission proposal to clamp down on companies cheating tax by opening subsidiary companies in different member states supported by vast majority of MEPs. On Wednesday Labour MEPs were part of a very small minority of 32 MEPs who voted against a resolution backing the Commission’s proposal to tighten the Parent-Subsidiary… – Continue reading
The revenue the UK Government will see in its coffers as a result of the Liechtenstein Disclosure Facility amnesty scheme “is likely to fall significantly short of its £3bn target”, a UK law firm has predicted. With just two years left to run, the number of new LDF registrations each… – Continue reading
Luxembourg and the US have signed an intergovernmental agreement (IGA) to implement the Foreign Account Tax Compliance Act (FATCA). Luxembourg and the US negotiated a Model 1 IGA, requiring the Luxembourg Tax Administration and the US Internal Revenue Service (IRS) to exchange information automatically on accounts held by US citizens… – Continue reading
Offshore companies can not acquire and have ownership of agricultural land in Bulgaria, according to the latest amendments to the Agricultural Land Ownership and Use Act. The changes to the Agriculture Land Act were passed on second reading, Thursday, Bulgarian BTV reports. The restriction applies to joint-stock companies that have issued bearer shares, as well…. – Continue reading
The National Treasury and the SA Revenue Service are discussing entering into an inter-governmental agreement (IGA) with the United States on a foreign tax compliant act, Sars said on Thursday. “The wording of a draft IGA has now been agreed upon and will be signed at governmental level as soon… – Continue reading
The United States Department of the Treasury and the Internal Revenue Service (IRS) have announced that foreign jurisdictions that have reached agreement on the terms of intergovernmental agreements (IGAs) under the Foreign Account Tax Compliance Act (FATCA) can be treated as having such agreements in effect until the end of… – Continue reading
April 2 — The Treasury Department and the Internal Revenue Service announced that countries that have reached intergovernmental agreements (IGAs) in substance under the Foreign Account Tax Compliance Act before July 1 will be treated as having signed agreements through Dec. 31, 2014, winning praise from practitioners. The government also said… – Continue reading
Canadians who spend their winters in the warmer climates of the United States may be attracting some unwanted attention starting this year. A new tax treaty between Canada and the United States has spawned a cozy relationship between the Canada Revenue Agency and the U.S. Internal Revenue Service. The two… – Continue reading
Baku, Fineko/abc.az. The U.S. is waiting for Azerbaijan’s response on the agreement on the exchange of tax information on the FATCA rules. The U.S. Embassy reports that the US has engaged the Azerbaijani government on this issue. “Now we’re waiting for their response. The US government is negotiating similar arrangements… – Continue reading
On 27 March 2014, the Commissioner of Taxation announced an initiative to allow eligible taxpayers to come forward and voluntarily disclose unreported foreign income and assets. He urged taxpayers with offshore assets to declare their interests ahead of a global crackdown on people using international tax havens. The initiative covers… – Continue reading
Canada is clamping down on off-shore tax shelters used by private-equity funds, in a move that may curb investment in the oil and gas industry by KKR & Co. and Blackstone Group LP. (BX) The government has given private-equity firms and other interested parties until April 11 to respond to proposals tucked… – Continue reading
Corporate Tax Reform: The Organisation for Economic Co-operation and Development (OECD) held a briefing and webcast at its Paris headquarters Wednesday on its Base Erosion and Profit Shifting (BEPS) project and Pascal Saint-Amans, the director of the OECD’s tax centre confirmed that “Double Irish Dutch” sandwich tax schemes, which involve… – Continue reading
ActionAid Ghana (AAG) said Illicit Financial Flows (IFFs) was depriving Africa of billions of dollars each year, more than is received in overseas development aid or foreign direct investment combined. It said IFFs were commonly associated with criminal activity like drug dealing, smuggling or human trafficking, adding that the United… – Continue reading
Expats should put their financial affairs in order while they have the chance as governments around the world prepare a global tax net aimed at wiping out avoidance. The operation is headed by the Organisation of Economic Co-Operation and Development (OECD) and closely follows the lines of the controversial US… – Continue reading
On Friday the Conservative government tabled legislation to implement key elements of this year’s Budget. But it contains more than tax credits. Buried within is a revised version of draft legislation implementing the Intergovernmental Agreement (IGA) with the U.S. on FATCA. A Department of Finance press release makes no mention of this… – Continue reading
ZAMBIA, which has signed 22 double taxation treaties (DTT) with various nations has been urged to develop its own model that suits particular circumstances to maximise benefits. Double taxation is levying of taxes on the same income (or capital) of the same tax payer in the same period. According to… – Continue reading
Luxembourg’s Prime Minister Xavier Bettel said the conclusions adopted at the recent European Council meeting on the revised Savings Tax Directive have enabled “a green light from the Grand Duchy of Luxembourg.” He expressed his satisfaction that all 28 European Union (EU) member states reached an agreement at the latest… – Continue reading
The US and Luxembourg governments have signed an agreement to improve international tax compliance and to implement the Foreign Account Tax Compliance Act (FATCA). On 27 February 2014, the Luxembourg and US negotiating teams agreed on the substance of the Model 1 Agreement. ALFI – the Association of the Luxembourg… – Continue reading
A call to tax technology companies such as Apple and Google in the countries where they have substantial activities has re-ignited concerns companies may be taxed twice and stop business altogether. The Organisation for Economic Co-operation and Development, which is working on a global plan to prevent companies from avoiding paying… – Continue reading
The European Council this week adopted a directive strengthening EU rules on the exchange of information on savings incomes, aimed at enabling the member states to better clamp down on tax fraud and tax evasion. The EU Directive requires the member states to exchange information automatically so as to enable… – Continue reading
It would be surprising if Union finance minister P. Chidambaram’s threat to his Swiss counterpart — to declare Switzerland an uncooperative nation for not sharing information on the 562 Indians who allegedly stashed their black money in Swiss banks — is actually carried out. The threat has trade implications. These… – Continue reading
The Anti-Tax Evasion Act and the Finance Act 2014 have introduced an annual transfer pricing documentation filing obligation and new disclosure requirements for large companies. Since 2010, French companies that have an annual turnover or gross asset value exceeding €400 million, are related to a French or foreign entity exceeding one of… – Continue reading
In the early hours of Thursday Morning, Australia announced a tax amnesty on any tax resident with offshore assets not declared to the Australian Taxation Office Geraint Davies, Managing Director of Montfort International sees this move as significant from many perspectives. “We have seen the breaking news of a complete… – Continue reading
BASSETERRE, St. Kitts, March 26th 2014 (CUOPM) – The Member Governments of the Eastern Caribbean Currency Union (ECCU) have commenced discussions with the United States of America (US) towards executing an Inter-Governmental Agreement (IGA) for the implementation of the provisions of the US Foreign Account Tax Compliance Act (FATCA). The… – Continue reading
The Tax Office is allowing Australians with money parked in offshore accounts to avoid harsh penalties by coming forward, in an amnesty program worth up to half a billion dollars. ATO Commissioner Chris Jordan will announce the program today, which will reduce the penalties for taxpayers who hand over information… – Continue reading
WASHINGTON (Reuters) – Caterpillar Inc’s offshore tax strategies will come under scrutiny on Tuesday at a U.S. Senate hearing expected to examine dealings by the world’s largest mining and construction equipment maker in Switzerland, Bermuda and Luxembourg. With many multinationals being criticized for tax avoidance, veteran tax sleuth Senator Carl Levin… – Continue reading
The Luxembourg and US governments have today signed an agreement to improve international tax compliance and implement the so-called Model 1 Intergovernmental Agreement (IGA) of the US Foreign Account Tax Compliance Act (FATCA). As a result of this agreement, the Luxembourg Tax Administration has set up two working groups including… – Continue reading
The long arm of the American tax man has officially reached its way to Hong Kong. The question is, will it extend to the rest of China? Hong Kong, a special administrative region of China, signed an agreement with the U.S. on Tuesday to share tax information about Americans who… – Continue reading
Hong Kong and the United States Tuesday signed an agreement on exchange of tax information. Hong Kong’s Secretary for Financial Services and the Treasury,K C Chan, on behalf of the Hong Kong Special Administrative Region( HKSAR) government, signed the agreement with the US consul general to Hong Kong and Macao,… – Continue reading
Ghana and Denmark have signed a Double Taxation Agreement, moving the bilateral cooperation between the two countries to another level. A Double Taxation Agreement regulates the tax treatment of income or capital gains in situations where the same taxpayer is subject to tax in two states with respect to the… – Continue reading
OECD plan to make practice of shifting locations ineffective New rules aimed at preventing the type of aggressive tax avoidance schemes run by some of the largest multinational employers here will begin to be introduced in September, according to a draft report seen by The Irish Times . Structures that artificially shift… – Continue reading
RIYADH, March 24 (KUNA) — Saudi Arabia and Hungary have signed an agreement for double taxation avoidance and prevention of fiscal evasion with respect to taxes on income and capital, and its related protocol. The deal was signed by Saudi Minister of Finance Dr. Ibrahim bin Abdulaziz Al-Assaf and Hungarian… – Continue reading
LONDON — They are the most expensive and luxurious flats in the whole of London. Their ultramodern bay windows offer an unobstructed view onto Hyde Park. An underground corridor connects them to the Mandarin Oriental, the palace where Michelin-starred chef Heston Blumenthal has one of his prized restaurants. In total, the… – Continue reading
The European Union has formally adopted the Savings Tax Directive after six years of negotiations. The directive is intended to bolster the power of the EU to crackdown on tax evasion. The measure was adopted shortly after Luxembourg and Austria abandoned their opposition to the plan. EU tax commissioner Algirdas Semeta, commenting… – Continue reading
