I am a trustee of an offshore trust settled by a UK resident, non-UK domiciled settlor (with no UK origins) for the benefit of himself and his family. He previously opted to be taxed on the remittance basis. The trust holds only offshore investments. The settlor lent monies to the… – Continue reading
The statutory federal corporate tax rate in the United States is 35%, and it has been since 1993. Any company that pays that rate should probably be looking for a new chief financial officer. When state taxes are slotted in, the average combined tax rate is 39.1%, according to a… – Continue reading
Luxembourg Finance Minister Pierre Gramegna has introduced legislation into parliament that would establish a new intellectual property tax regime in Luxembourg. The bill was submitted to the Chamber of Deputies on August 4, 2017, and is designed to be aligned with the “modified nexus” approach to special IP tax regimes… – Continue reading
The Government of Hong Kong has said that it will introduce legislation into the Legislative Council by the end of this year to implement the minimum standards proposed by the OECD as part of its base erosion and profit shifting project. The BEPS framework, proposed by the OECD at the… – Continue reading
Whilst the peer-to-peer (P2P) economy has posed many challenges to traditional tax collections systems, the sector’s technological foundation also holds the keys to solving these problems, according to a new report by the International Monetary Fund (IMF). The IMF working paper, published on August 8, explores the implications for the… – Continue reading
HM Revenue & Customs’ new online Trusts Registration Service is now up and running, and beginning to get the attention of trust providers in a big way. Here, tax commentator Gerry Brown looks at the new regulations, and what they will mean for those in the trusts industry. The UK… – Continue reading
Italy has granted non-domiciled status to a taxpayer for the first time, after introducing a new non-dom regime at the start of the year. Withers LLP represented the taxpayer, a high net worth individual who was formerly registered as a non-dom in the UK, and who has decided to move… – Continue reading
Amazon has refused to reveal how much it paid in total UK tax last year after it emerged it actually got a rebate of £1.3million. The online giant, which three years ago pledged to stop using a controversial tax avoidance scheme, admitted it had paid just £7million in corporation tax… – Continue reading
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
Contrary to calls from businesses from the regulation’s withdrawal, the Institute on Taxation and Economic Policy has called on the US Treasury to fully implement and strengthen its final Section 385 anti-earnings stripping debt-equity regulations, designed to reduce the benefits of corporate tax inversions. The final regulations, released in October… – Continue reading
The New Zealand Government has announced the signature of two Orders of Council that will implement amendments to its tax treaty arrangements with India and San Marino. The third protocol to the double tax agreement (DTA) with India updates the information exchange provisions and inserts an article on assistance in… – Continue reading
Brazil’s Inland Revenue has announced that assets worth BRL4.6bn (USD1.46bn) have been declared by Brazilian taxpayers through its amnesty for undeclared overseas holdings. It said that the income tax and fines linked to these assets totalled BRL1.6bn. The figures cover the period between March 3 and July 31, 2017, when… – Continue reading
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
The Philippines is set to sign a double taxation agreement (DTA) with Brunei while eyeing to start negotiations with three other Asean countries as part of its commitments under the regional integration framework. Internal Revenue Assistant Commissioner Marissa O. Cabreros told the Inquirer yesterday that the Philippines’ DTA with Brunei… – Continue reading
Paying employees in gold bullions to avoid tax will not be permitted under the first use of the general anti-abuse rule (GAAR). The GAAR advisory panel stated that the use of gold as payments for employees is “abnormal and contrived” and “not a reasonable course of action”. “We can see… – Continue reading
Israel’s $41 million tax demand from the Coca-Cola Co. on royalties from its Israeli licensee could mark the start of a wave of claims against U.S. and other multinationals with similar business operations in the country. That could lead to a conflict with U.S. and other authorities about which country… – Continue reading
The Swiss Federal Council has announced that an information exchange amendment to the double tax agreement with Belgium has entered into force. On August 7, the Council said the additional agreement to amend the DTA had entered into force on July 19. It contains an administrative assistance clause in accordance… – Continue reading
France is Airbnb’s second largest market and yet in 2016, the internet giant paid the country just €92,944 in taxes – equivalent to the amount paid by small and medium-sized enterprises (SMEs). Second only to the US as Airbnb’s biggest market and with Paris its top city for listings, during… – Continue reading
In an effort to create a ‘level playing field’, Asian economies are committing to new standards of transparency At the risk of losing some foreign investors, Asian jurisdictions are stepping up efforts to combat corporate tax avoidance to meet new global transparency standards. More than a dozen Asia-Pacific jurisdictions have… – Continue reading
Stock analysts in South Korea played down the possible impact of the government’s decision Wednesday to impose taxes on foreign investors holding over 5 percent of a company, but warned of widening volatility prompted by foreign investors’ sell-offs over the past couple of weeks. Starting January 2018, a broader scope… – Continue reading
The notification follows hectic parleys between India and Switzerland for introduction of AEOI (Automatic Exchange of Information) under guidance of G20, OECD (Organisation for Economic Cooperation and Development) and other global organisations. Switzerland found India’s data security and confidentiality laws “adequate” for entering into an automatic exchange of information pact,… – Continue reading
An ATO ruling is being interpreted as allowing ‘bucket companies’ linked to trusts to be eligible for lower tax rate The federal government’s company-tax reforms are making the use of family trusts even more attractive as a tax minimising strategy, experts have warned. The Coalition’s company tax rate cut from… – Continue reading
The current plan for US tax reform would disproportionately benefit the wealthy, the International Monetary Fund has said, recommending more support for low-income taxpayers and higher indirect taxes. On the need for tax reform, the IMF said in its Article IV consultation for the United States that “the US personal… – Continue reading
Taxpayers have been reminded of the looming deadline for the Special Voluntary Disclosure Programme (SVDP) on 31 August 2017. SVDP is a window period for individuals and companies to regularise undisclosed or unauthorised foreign assets and associated income. It came into effect on 1 October 2016. Taxpayers are urged to… – Continue reading
Nigeria’s federal government on Wednesday signed an agreement with Singapore that would help companies operating in the two countries avoid double taxation in their different bases. The agreement clearly spells out taxing rights of the two countries in respect of different incomes derived from each country. It will specifically assist… – Continue reading
The International Revenue Service’s Criminal Investigation unit is readying two new programs focusing on data investigations and international tax enforcement. The data initiative will tie together the information uncovered by the IRS’s field offices around the country with headquarters in Washington, D.C. “We are standing up a nationally coordinated data… – Continue reading
APAs were recently implemented in the Croatian tax legislation. Our Transfer Pricing team briefly presents the main points of the Croatian legislation related to an APA. Transfer pricing legislation was introduced in Croatia by way of the Corporate Income Tax Act (CIT) on 1 January 2005. However, the Croatian tax… – Continue reading
The Act currently provides for income taxable as ‘capital gains’ to be computed after taking into account the full value of consideration received or accrued on transfer of a capital asset “A person doesn’t know how much he has to be thankful for until he has to pay taxes on… – Continue reading
The Costa Rican government is very interested in forming part of the Organization for Economic Co-operation and Development (OECD http://www.oecd.org/ ). The OECD is formed by 35 nations to promote policies that will improve the economic and social well-being of people around the world. Last Thursday, economist Bert Brys, explained… – Continue reading
As part of the Irish Budgetary process, officials from the Finance Department have published a paper on the implications of Brexit for Ireland’s tax system. The paper was prepared for consideration by the Tax Strategy Group (TSG), an interdepartmental committee chaired by the Finance Department. The papers produced by the… – Continue reading
The UK will not engage in aggressive tax competition to attract business post-Brexit, Chancellor Philip Hammond has said. He added that the country’s economy will remain aligned with the European model after leaving the EU. “It is often said that London would consider launching into unfair competition in terms of… – Continue reading
Indians who are on deputation overseas or have settled overseas — whether by way of acquiring a permanent residency such as a green card in the US, or acquiring citizenship of a foreign country — need to be aware of their tax obligations in India. A recent move seeking details… – Continue reading
HÀ NỘI — A number of enterprises have taken advantage of technology used for tax collection to avoid paying taxes. The Law on Value Added Tax (VAT) regulates that unprocessed, or preliminarily processed, agricultural, forestry and aquatic products imported from foreign countries are not subject to VAT. However, if these… – Continue reading
The Common Reporting Standard (CRS) allows for the automatic exchange of information between tax authorities. Local taxpayers who may have stashed their assets in cash and property offshore have a month to disclose their earnings and ownership details to the South African Revenue Services (Sars). The deadline for the Special… – Continue reading
BEIRUT: The Association of Banks in Lebanon and other private sector leaders are weighing the few options open to them as recently approved new tax measures, poised to be implemented soon, threaten to have a detrimental effect on their businesses and the overall economy. The few available options include trying… – Continue reading
The algorithm will match residents’ spending patterns, as evidenced from their social media postings, with their declared income. Bloomberg reported that the Indian government will be rolling out a new data analytics platform, called Project Insight, to catch tax evaders. In addition to traditional taxation data, such as IT returns,… – Continue reading
US Ambassador Allan Mustard and Turkmenistan’s Minister of Finance Gochmyrat Myradov signed an Intergovernmental Agreement (IGA) to implement the provisions of the Foreign Account Tax Compliance Act (FATCA), said the US Embassy in Ashgabat. The agreement underscores growing international cooperation to curb offshore tax evasion and marks a step forward… – Continue reading
ZURICH (Reuters) – Pushing forward European and international measures to prevent profit shifting and international tax fraud will be a top priority for Austria’s European Council presidency in the second half of 2018, Austrian Finance Minister Hans Joerg Schelling said on Saturday. “The cross-border fight against tax fraud and tax… – Continue reading
“Disproportionate” value disappears from economic system compared to GDP Malta ranks first among a number of EU countries in a list of what a new study calls 24 “sink offshore financial centres”, which it says are typically characterised as tax havens. The study, published this week in the academic journal… – Continue reading
The change converts tax-deductible interest payments employed by the schemes into taxable stock dividends. The U.S. government on Friday gave companies an extra year to comply with an Obama-era regulation meant to crack down on corporations that try to minimize their U.S. tax bills by shifting profits abroad to countries… – Continue reading
Cambodia signed a double taxation agreement (DTA) with Brunei aimed at preventing dual taxation and fiscal evasion, the Ministry of Economy and Finance said yesterday in a press release. This is the third DTA agreement that Cambodia has signed after Singapore and China, while the government is currently developing framework… – Continue reading
LUSAKA, July 28 (Xinhua) — Zambia’s revenue agency warned on Friday that it will freeze all bank accounts holders without Tax Payer Identification Number (TPIN) by the end of this year. The Zambia Revenue Authority (ZRA) said having a TPIN was a pre-requisite to all procedures of tax registration and… – Continue reading
Israel wants to develop friendly relations with Armenia, according to that country’s Regional Cooperation Minister, Tsakhi Hanegbi, who told Foreign Minister Edward Nalbandian on Wednesday as he kicked off an official visit to Armenia. He said that the purpose of his visit was to advance those ties. The two signed… – Continue reading
On 22 June 2017, the parliament of Kyrgyzstan approved the bill ratifying the tax treaty signed with Georgia on 13 October 2016. Currently, the ratification from Georgian side is still pending, and in order to become law and to be ratified, the bill still needs to be signed by the… – Continue reading
Federal income tax reform is by far the biggest concern of corporate tax executives, a new survey from Bloomberg BNA reveals. Survey of Corporate Tax Departments 2017 spotlights several key tax issues, and “corporate tax professionals are facing a wealth of challenges as they look to prepare their businesses for… – Continue reading
New law to fulfill requirements under OCED’s AEOI framework Move could unlock billions of dollars of assets kept abroad Indonesia moved a step closer to hunting down tens of billions of dollars it believes its citizens have hidden abroad after political parties agreed to seek a parliamentary approval for a… – Continue reading
The number of wealthy Russians declaring foreign assets has spiked in recent months, the RBC news outlet reported, citing research conducted by real estate broker Tranio and British company Adam Smith Conferences. The number of Russians with assets worth at least $1 million who revealed foreign bank accounts has increased… – Continue reading
The Department of Finance (DOF) on Wednesday asked the Senate to support the proposal relaxing the country’s bank secrecy law as it would allow the Bureau of Internal Revenue (BIR) to conduct the proper audit in tax fraud cases. Absolute bank secrecy is one of the “major” issues that need… – Continue reading
France intends to appeal against a recent court decision in favor of Google in a major tax avoidance case, but is open to settling the dispute outside of court, a government minister has said. In an interview with Les Echos, Minister of Action and Public Accounts, Gerald Darmanin, said that… – Continue reading
Business group Ibec has said that the Irish Government must “Brexit proof” its 2018 Budget, improve its foreign direct investment model, and implement a range of tax reforms to compete with the UK. Publishing the group’s pre-Budget submission, Ibec Director of Policy and Public Affairs, Fergal O’Brien said: “The Irish… – Continue reading
