Cyprus: Substance – From Corporate Tax Perspective And Other Factors
Substance is vital when it comes to the tax residency of companies and their management and control aspect. ... - Continue reading
Category: Tax Avoidance
Japan to tighten rules on wealthy residents with overseas assets
The government is set to tighten rules on disclosure by Japan’s wealthier residents about their overseas assets in a bid to prevent tax avoidance, sources close to the matter said Sunday. ... - Continue reading
US IRS tells banks not to close accounts just because of missing tax ID number: FATCA
The US Internal Revenue Service has eased the rules of FATCA compliance by telling banks overseas that they are not required to close the accounts of their accidental Americans clients who have not provided their tax identification number by January 2020. FATCA was passed in 2010 and forces banks wanting… – Continue reading
Australians owe record levels of tax: commissioner
Australians are avoiding their tax responsibilities in record numbers. The Australian Taxation Office (ATO) announced at a Senates Estimates hearing that the debt owed by Australians to the tax man has recently hit 45 billion Australian dollars (31 billion U.S. dollars), a record figure, according to the Australian Broadcasting Corporation… – Continue reading
HMRC targets tax avoidance enablers
HMRC is clamping down on the promoters and enablers of tax avoidance scheme as prison sentence lengths for tax evasion rose by 1% on average last year. Penny Ciniewicz, HMRC’s director general of customer compliance, said “We have more than 100 current investigations into promoters [and enablers] and we’re keeping… – Continue reading
BEPS MLI to enter to force for Mauritius
Mauritius on October 18 deposited its instrument of ratification or acceptance of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting ... - Continue reading
‘Who is buying Seattle?’: New report issues warnings on Seattle’s luxury housing boom
Seattle’s luxury housing boom will worsen inequality and affordability in the city, according to a new report, which calls for officials to require more transparency on who is actually buying luxury real estate in the area. The report — “Who is Buying Seattle? The Perils of the Luxury Real Estate… – Continue reading
European Union: UAE Removed From EU Tax Haven Blacklist Along With Switzerland
The United Arab Emirates and Switzerland removed from European Union's list of non-cooperative jurisdictions for tax purposes on October 10. ... - Continue reading
Disclosure of cross-border arrangements
HMRC has recently been consulting on how the UK will implement new EU disclosure rules contained in the latest Directive on Administrative Cooperation (DAC6). ... - Continue reading
Nigeria: Unprecedented Global Drive For Tax Transparency – The Nigerian Perspective
In the last few years, the international tax space has experienced an unprecedented drive to achieve increased transparency in the tax practices of Multinational Enterprises (MNEs) and individuals in order to curb tax avoidance and evasion. ... - Continue reading
Utah man failed to submit proper tax returns, avoided paying taxes for 12 years
A man from Pleasant Grove, Utah, was convicted of multiple counts of tax evasion for failing to submit proper tax returns and avoiding paying his taxes for 12 years. Robin Kartchner, 69, has been convicted of 15 counts of tax evasion, according to a Tuesday press release from the Utah… – Continue reading
Ireland Budget 2020 released
On 8 October, the Irish government announced its Budget 2020 measures. Brexit and climate change are core themes of new revenue measures and expenditure commitments. Brexit remains the foremost immediate concern for the Irish economy, whereas tackling climate change requires long-term commitments to tax and spending policies. ... - 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
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
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
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
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
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
Declaration must for Pakistanis having foreign assets, income
KARACHI: The Federal Board of Revenue (FBR) will tighten noose around offshore illicit money and assets as Pakistanis having undeclared assets abroad are required to file statement by September 30, 2019. “The FBR will launch proceedings against persons having offshore assets on the basis of available data,” an official at… – Continue reading
Panel to hear taxpayer before invoking GAAR under new set of rules
New rules mandate officials to refer a suspected case of tax avoidance to a panel of senior officials ... - Continue reading
IRS offers tax break to some American expats
The Internal Revenue Service (IRS) has outlined new procedures for some “accidental Americans,”, giving them the chance to comply with their US tax and filing obligations and in turn qualify for relief from back taxes, penalties and interest. The changes would allow people with less than $2m in net worth… – Continue reading
Tax avoidance drives nearly 40% of global FDI: IMF
Nearly 40% of worldwide foreign direct investment (FDI), amounting to $15trn, “passes through empty corporate shells” with “no real business activities”, a study by the IMF and the University of Copenhagen reveals. According to the report, ten economies including Luxembourg, the Netherlands, Hong Kong, BVI, Switzerland, Singapore, Ireland, the Cayman… – Continue reading
Canada: Canada Ratifies The Multilateral Instrument
On June 7, 2017, Canada along with numerous other jurisdictions signed the Organisation for Economic Co-operation and Development’s (“OECD”) Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “MLI” or “multilateral instrument”). The multilateral instrument is the culmination of work undertaken as part of the OECD/G20 BEPS Project to equip governments with domestic and international instruments to address tax avoidance. ... - Continue reading
HMRC collects record £191bn in income tax
The taxman is raking in record amounts in income tax as the latest figures reveal Britons paid an extra £11bn in 2018/19. Income tax receipts have soared to a record £191bn, according to figures published, a 6% increase from the previous year. Britons are paying almost 30% more income tax… – Continue reading
Canada, Switzerland ratify instrument to tackle tax avoidance
Canada and Switzerland on August 8 deposited with the OECD their instruments of ratification for the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS MLI). The BEPS MLI, negotiated by over 100 countries and jurisdictions, updates the existing network of tax treaties and… – Continue reading
Luxembourg: bill submitted to implement anti-tax avoidance provisions
With effect from 1 January 2019, the Anti-Tax Avoidance Directive (ATAD) I intra-EU hybrid mismatches rules were introduced into Luxembourg’s domestic law. ... - Continue reading
Cayman Islands publishes FAQ’s on economic substance for tax purposes
The Cayman Islands has published a set of frequently asked questions detailing a law requiring that companies with geographically mobile activities have economic substance for tax purposes. ... - Continue reading
Luxembourg: Luxembourg Starts The Implementation Of ATAD 2
On 8 August, the draft law (the "draft law") implementing the EU Directive 2017/952 of 29 May 2017 ("ATAD 2") amending Directive (EU) 2016/1164 laying down rules against tax avoidance practices that directly affect the functioning of the internal market (the so-called Anti-Tax-Avoidance-Directive, "ATAD") was presented to Parliament. ... - Continue reading
Luxembourg: Luxembourg Government Submits Bill To Parliament Implementing The EU Anti-Tax Avoidance Directive 2 Into Domestic Law
Luxembourg corporate income taxpayers, including Luxembourg permanent establishments of foreign entities, will be subject to the Draft Law as from 1 January 2020. In addition, provisions targeting reverse hybrid mismatches will be applicable to Luxembourg transparent partnerships that would be treated as opaque by their nonresident owners as from 1 January 2022. ... - Continue reading
FATCA could push French banks to close up to 40,000 account
Banks in France have warned that they could be forced to close up to 40,000 accounts belonging to US citizens because of ongoing difficulties with the Foreign Account Tax Compliance Act (FATCA). ... - Continue reading
Three different routes to save tax on long-term capital gains
There are provisions under different sections of the Income-tax Act that can help you save on LTCG tax ... - Continue reading
Namibia joins international taxation initiative
This was revealed by the Organisation for Economic Cooperation and Development (OECD) last Friday in an announcement made on its website. ... - Continue reading
Tax from non-doms falls by £2bn as wealthy flee the UK
The number of wealthy residents who pay no UK tax on their offshore accounts has fallen to its lowest level ever, Treasury figures reveal. Last year, there were 78,300 non-domiciled taxpayers, or “non-doms”, in the UK compared with 98,500 in 2016-17. And the £9.5bn they paid to the taxman in… – Continue reading
Uber looks to the Netherlands to reduce its tax bill by $6,1bn
Uber is moving its intellectual property arm from Bermuda to the Netherlands to save $6.1bn from its tax bid, Bloomberg reported on Friday. ... - Continue reading
European Union: EU Directive On Administrative Cooperation (DAC6)
The European Union has added further impetus to its objective of enhancing transparency against harmful tax practices with the amendment to Directive 2011/16/EU, commonly referred to as DAC6. ... - Continue reading
New Zealand-Swiss tax agreement tightens net on avoidance
WELLINGTON, Aug. 8 (Xinhua) — Opportunities to dodge tax are shrinking with the completion of a new tax agreement between New Zealand and Switzerland, New Zealand’s Revenue Minister Stuart Nash said on Thursday. Nash and Swiss Ambassador to New Zealand David Vogelsanger signed documents to update the Double Tax Agreement… – Continue reading
Mauritius leaks latest reminder of how much we lose to tax havens
Mauritius leaks latest reminder of how much we lose to tax havensA report by Canadians for Tax Fairness Bay Street and Tax Havens revealed how over 90% of Canada’s largest corporations have subsidiaries in tax havens. Ottawa (06 Aug. 2019) — Last month Canadians for Tax Fairness reported that, while… – Continue reading
Income tax department refutes harassment allegations
Industry leaders Kiran Mazumdar-Shaw and Mohandas Pai have made allegations of harassment by income tax dept officials ... - Continue reading
HMRC win £450m tax avoidance scheme as football stars and celebrities lose out
The scheme had received investments from the likes of Ant and Dec, David Beckham and Celtic duo Neil Lennon and Peter Lawwell. ... - Continue reading
Multilateral tax treaty to enter into force for Norway
The OECD today announced that Norway has deposited its instrument ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). ... - Continue reading
Deal firmly with those who game the system: Sitharaman to taxmen
Finance Minister Nirmala Sitharaman on Wednesday asked taxmen to firmly deal with those who try to evade taxes and game the system but act as facilitators to those who want to pay taxes honestly. ... - Continue reading
Journalists publish details of 200+ companies using offshore law firm, conclude Mauritius promotes tax avoidance
Data on more than 200 companies that engaged the Mauritius office of Conyers Dill & Pearman were published on the internet today by the International Consortium of Investigative Journalists (ICIJ) as a result of leak of confidential information. ... - Continue reading
European Union: Dutch Implementation Proposal On EU Anti-Hybrid Measures
On July 2, 2019, the Dutch government published the legislative proposal implementing the EU Anti-Tax Avoidance Directive II (ATAD II) that was adopted on May 29, 2017. The ATAD II mandates EU Member States to implement rules that target hybrid mismatches by January 1, 2020 (specific sections by January 1, 2022). ... - Continue reading
Taxability of annuity paid by Australian account depends on residential status
On July 12 the Netherlands government published a legislative proposal implementing the EU mandatory disclosure directive. This follows an internet consultation on a draft legislative proposal which ran from December 19, 2018 — February 1, 2019. ... - Continue reading
UK Finance Bill 2019-20: what international businesses need to know
Draft legislation and explanatory notes to the UK Finance Bill 2019-20 were published on 11 July. Much of the legislation was anticipated with some further clarifications provided. ... - Continue reading
Gibraltar and UK Open Negotiations to Enter into a Double Tax Agreement
The Government of Gibraltar has said it is delighted to welcome Robert Jenrick, Exchequer Secretary to Her Majesty’s Treasury, to Gibraltar to announce that HMGoG and Her Majesty’s Government have opened negotiations to enter into a Double Tax Agreement. It is anticipated that with hard work on both sides a… – Continue reading
Transfer (mis)pricing
TRANSFER pricing — the pricing of commodities traded between or within multinational enterprises — is a legal practice and a key feature of cross-border and intra-firm transactions. The United Nations prefers to use the broader phrase ‘trade pricing’ in addressing this practice and defines it as a ‘normal incident of… – Continue reading
Netherlands announces tax policy agenda for 2019
The Dutch government on May 29 announced its priorities and timelines in the area tax policy, including how the Netherlands intends to deal with tax evasion and tax avoidance and improve the Dutch investment climate. ... - Continue reading
