NEW DELHI The Indian Income Tax Department will accept applications for Mutual Agreement Procedure (MAP) in transfer pricing disputes, as well as for bilateral Advance Pricing Agreements (APAs), even for entities resident in countries with which India has double taxation avoidance agreements (DTAA), minus the provision to claim corresponding tax… – Continue reading
The Internal Revenue Service released guidance Wednesday to give tax relief to residents of Puerto Rico and the U.S. Virgin Islands who have evacuated the islands or were unable to return because of Hurricanes Irma or Maria. The relief extends the typical 14-day absence period to 117 days (starting Sept…. – Continue reading
International pension plans involve complex questions of structuring and compliance International Pension Plans (IPPs) are pension plans sponsored and funded by an employer, for employees assigned to work outside their home country, who are expected to receive IPP benefits while they are resident in their home country, or in another… – Continue reading
Popular investment schemes offering generous tax breaks for wealthier investors are likely to face new restrictions. The Treasury is mulling a crackdown on Enterprise Investment Schemes, likely to be announced in the next Budget on November 22. The scheme allows people to invest in start-ups, either directly or through funds,… – Continue reading
Hong Kong (HKSAR) – The Secretary for Financial Services and the Treasury, Mr James Lau, on behalf of the Government of the Hong Kong Special Administrative Region, signed in Hong Kong today (August 24) a comprehensive agreement for the avoidance of double taxation (CDTA) with Saudi Arabia, which signifies the… – 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
Expats can claim pension tax relief as long as they are still resident in the UK. Residence is a matter of fact rather than choice and depends on the result of the statutory residence test. Expats who are not resident in the UK cannot claim pension tax relief How do… – Continue reading
‘Misleading media reports’ Ingenious Film has hit out at “misleading” press reports on its ongoing tax court case and criticised HM Revenue & Customs (HMRC) for painting its partnerships “as nothing more than tax avoidance vehicles”. The film production partnership firm has been in an ongoing court dispute with HM… – Continue reading
Malaysia uses both progressive and flat rates for personal income tax, depending on an individual’s duration and type of work in the country. As expatriates may fall into either tax category depending on their work, it is important to understand Malaysia’s basic tax structure. The Income Tax Act of 1967… – Continue reading
(Second of two parts) In last week’s article, we discussed the revised procedure to avail of tax treaty benefits for dividend, interest, and royalty payments under Revenue Memorandum Order (RMO) No. 8-2017. Under the amended rules, a tax treaty relief application (TTRA) is no longer required and withholding agents can… – Continue reading
Governments should look to remove tax policies that distort business decisions, to unlock higher economic growth, a new paper from the International Monetary Fund says. “Upgrading the design of their tax systems can help countries chip away at resource misallocation by ensuring that firms’ decisions are made for business and… – Continue reading
The Philippines is currently a signatory to 41 tax treaties that address double taxation situations. MANILA, Philippines – According to Philippine law, nonresidents with income sources in the Philippines are required to file taxes. For these individuals who reside in a different country but receive income from the Philippines, double… – Continue reading
The Offshore Compliance Advisory Committee issued a report in December 2016 to the Canada Revenue Agency about the Voluntary Disclosures Program (VDP or tax amnesty). If a taxpayer submits a successful income tax or GST/HST voluntary disclosure program application then generally criminal income tax prosecution and civil tax penalties under… – Continue reading
The 2017 Italian Budget Law introduces a tax relief for individuals transferring their tax residence to Italy, in accordance with similar regimes adopted by other countries such as the United Kingdom, Switzerland and Portugal. The relief is part of a package of measures intended to facilitate investment in Italy and… – Continue reading
Investors in a financing scheme aimed at helping the UK film industry are being asked to repay “multiple millions of pounds” following a court ruling. HMRC is pursuing investors in the Eclipse scheme, including celebrities, financiers and sports stars, for up to 20 times their original investment. Courts ruled that… – Continue reading
The season hasn’t started off that well for Wayne Rooney – and now it’s got even worse. The England and Manchester United captain is now facing a £3.5million tax bill after authorities challenged a tax avoidance scheme that he was involved with. Rooney has already come under fire this season… – Continue reading
Accounts show each of the firm’s 682 workers took home average of £242,000 each in 2015 Facebook lavished £165million on its UK staff last year, while handing the taxpayer just £4million. Accounts show each of the firm’s 682 workers took home average of £242,000 each in 2015. The bumper payout… – Continue reading
Wales is to replace stamp duty with a land transaction tax as it moves towards devolved tax collection. The new tax on land transactions will be introduced from April 2018 alongside measures to tackle devolved tax avoidance, the Welsh government said. Land transaction tax is paid on the purchase or… – Continue reading
The Union Cabinet on Wednesday gave its nod for signing of revised double taxation avoidance agreement (DTAA) with Cyprus, a popular tax haven. It is also learnt to have approved the removal of island nation as a non-cooperative jurisdiction for income-tax purpose. Cyprus was the only country to have been… – Continue reading
The Australian Taxation Office (ATO) has issued a series of taxpayer alerts that caution large companies against using contrived arrangements to avoid their tax obligations. The first alert concerns arrangements where Australian consolidated groups use offshore permanent establishments that have entered into intra-group transactions. Deputy Commissioner Jeremy Hirschhorn explained: “Through… – Continue reading
British multinational companies face new withholding taxes that may cost hundreds of billions of euros a year if U.K. voters decide to leave the European Union, international tax specialists say. A so-called Brexit “would have a major impact” on British corporations that have subsidiaries in the EU, said Daniel Gutmann,… – Continue reading
A CLAMPDOWN on tax planning, a transformation of its services for taxpayers and delivering a professional, efficient and engaged organisation are the three key objectives for HMRC in its updated single departmental plan. The government department has outlined its main visions and objectives for the period between 2015 and 2020,… – Continue reading
The EU’s Economic and Financial Affairs Council (ECOFIN) has been unable to reach agreement on the European Commission’s proposed anti tax avoidance directive. The issue has therefore been postponed until the next ECOFIN meeting in June. The European Commission announced its proposed anti-tax avoidance directive (ATAD) in January. The proposed… – Continue reading
Tax Commissioner Ryan Rauschenberger said North Dakota residents may qualify for property tax relief, even if they rent their primary residence. Qualifying individuals may be eligible for a partial refund of their rent. “Senior citizens and disabled individuals may qualify for a refund on a portion of the rent they… – Continue reading
On October 5, 2015, the Organization for Economic Cooperation and Development (OECD) issued final tax policy recommendations stemming from its Base Erosion and Profit Shifting (BEPS) project. The reports, endorsed by the G20 Finance Ministers on October 8 and by the G20 leaders at their November 15-16 summit, consist primarily… – Continue reading
In the wake of the Panama Papers leak debates about the morality of taxation are back in vogue. Unlike tax evasion, tax avoidance is, by definition, legal. This is not the same thing as saying it’s acceptable. No one wants to live in a society where everything questionable is banned… – Continue reading
The first Budget tabled by Canada’s new Liberal Government provides for a major crackdown on tax evasion and avoidance, and streamlines the domestic tax credits system. The Budget was delivered by Finance Minister Bill Morneau on March 22, 2016. He told Parliament: “Today, we begin to restore hope for the… – Continue reading
THE digital economy has increased opportunities for digital commerce companies to reap substantial sales from a country without establishing a taxable presence in that country. Existing permanent-establishment (PE) rules in both domestic laws and tax treaties require some type of physical presence before a PE is established in another country…. – Continue reading
The amount of tax multinational companies pay – and the amount they don’t pay – has become highly controversial, writes RTÉ’s Economics Correspondent Sean Whelan. This is mainly as a result of public outrage over legal tax avoidance schemes that big companies can use to shelter vast amounts of money… – Continue reading
In this final instalment considering the draft clauses from the Finance Bill 2016 most relevant to financial planners, I am going to turn my attention to the ever-popular subject of tax avoidance and evasion. Every Budget and Finance Bill has plenty to say on this subject. As in the previous… – Continue reading
Can tax treaty provisions override domestic law?In our last article we defined double taxation as an exposure to tax more than once on the same profit or income. We also highlighted the two types of double taxation i.e. economic double taxation and juridical double taxation and also noted that a… – Continue reading
Car battery and heating equipment maker accused of ‘stranding honest taxpayers’ Johnson Controls, a US maker of car batteries and heating and ventilation equipment, has agreed to buy Irish-based peer Tyco International in a $16.5 billion (€15.23 billion) deal that will lower its tax bill. By redomiciling to Tyco’s headquarters… – Continue reading
