Category: Tax treaties

Uganda: How MTN Uganda’s Offshore Stash Sent URA On the Hunt

MTN Uganda has been accused of failing to provide evidence to justify shifting huge amounts of cash out of Uganda to a briefcase company located in Mauritius, potentially lowering its tax bill in Uganda – the subject of which remains an ongoing dispute with Uganda Revenue Authority, it has emerged…. – Continue reading

Singapore backs international plan to curb tax avoidance

Singapore has given the thumbs up to an international plan that aims to clamp down on tax avoidance by multinational firms, reports the Straits Times. The Republic says if the plan is soundly implemented, it will help foster free and fair economic competition. Singapore agrees with the main principle of… – Continue reading

Tax Execs Expect Major Tax Changes from OECD BEPS Project

Senior tax executives are preparing for changes in the tax landscape as a result of the Organization for Economic Co-operation and Development’s base erosion and profit shifting project. A new survey by Ernst & Young, presented Thursday at its 34th Annual International Tax Conference, found 88 percent of tax directors… – Continue reading

Call for care on tax changes

New Zealand needs to be careful not to get out of step with the rest of the world in implementing tax changes on multinational companies seeking to minimise their tax obligations, Deloitte Dunedin tax partner Peter Truman says. The Government this week released a report on Base Erosion and Profit… – Continue reading

KPMG Tax Director: Tax betting and gaming activities

Government should look to the example set by Barbados and start charging Value Added Tax (VAT) on betting and gaming activities in Trinidad and Tobago. This was the advice coming from Tax Director of KPMG’s TT operations, Nicole Joseph, during a post-budget forum hosted by the American Chamber of Commerce… – Continue reading

Canada: International Tax Reform 2015-BEPS Final Reports

On October 5, 2015, the OECD released its final reports relating to the OECD/G20 base erosion and profit shifting (BEPS) project (the Final Reports). The BEPS project began in 2013 and has received unprecedented attention from governments and the private sector. The Final Reports outline the OECD’s recommendations and the… – Continue reading

Central Board of Direct Taxes feels black money recovery difficult

A senior officials say they have no legal jurisdiction over the accounts maintained in foreign countries and governments there can cooperate only in case of established criminal conspiracy While the government has threatened rigorous action against black money hoarders after tepid response to its one-time compliance window, it may have… – Continue reading

US companies holding $2.1 trillion offshore profits

There’s enough cash sitting in offshore bank accounts to wipe out the federal deficit — if only it was subject to U.S. taxes. That’s because U.S. companies are saving some $620 billion by parking profits outside the country, according to the latest accounting from Citizens for Tax Justice and U.S…. – Continue reading

Cabinet approves double taxation avoidance protocol between India & Israel

The Union Cabinet chaired by the Prime Minister Narendra Modi, has approved the protocol amending the convention and the protocol between India and Israel, for avoidance of double taxation and for prevention of fiscal evasion with respect to taxes on income and on capital. The protocol provides for internationally accepted… – Continue reading

Singapore’s tax jurisdiction largely in line with OECD’s tax proposals: Experts

The proposals are aimed at preventing aggressive tax planning by multinationals. However, experts warn that the risk of double taxation may increase. SINGAPORE: Tax experts have said that Singapore’s tax jurisdiction is broadly in line with new tax proposals announced on Monday (Oct 5) by the Organisation for Economic Co-operation… – Continue reading

Cabinet okays amendments to tax avoidance pacts with Israel, Vietnam

NEW DELHI, OCTOBER 7: The Union Cabinet on Wednesday gave its nod for the introduction of a ‘limitation of benefit’ clause in the double taxation avoidance convention (DTAC) with Israel. The ‘LOB’ Article is an anti-abuse provision aimed at preventing misuse of the convention. The protocol that received the Cabinet’s… – Continue reading

UK: The Use Of UK Holding Companies In International Group Structures

The location of a holding company is a significant consideration in any international corporate structure. Choice of jurisdiction for a group holding company (‘Holdco’) is relevant both from the point of view of tax optimisation (maximising withholding tax free dividend, interest and royalty flow up through the group and minimising… – Continue reading

Russian Federation: Russian 2015 Tax Revolution

For many years international tax planning for Russian inbound and outbound investments, and wealth planning for Russian resident individuals, was rather straightforward. That was primarily due to relatively simple domestic tax rules and a degree of inexperience amongst the Russian tax and other interested authorities in relation to international tax… – Continue reading

CORRECT: NZ’s biggest companies may face ‘enormous compliance burden’ from OECD tax dragnet

Oct. 6 (BusinessDesk) – Fonterra Cooperative Group is likely to be among some 20 New Zealand companies left dealing with increased red tape to comply with wide-ranging reforms to corporate tax rules proposed by the Organisation for Economic Cooperation and Development and expected to be endorsed by the world’s 20… – Continue reading

BEPS plan puts companies in the firing line, say experts

The OECD-G20 plan to stop multinational tax avoidance could put companies in the middle of border disputes between revenue authorities, tax experts have warned. But civil society groups say the plan has not gone far enough and could make it easier for some multinationals to dodge tax. Treasurer Scott Morrison… – Continue reading

OECD: countries commit to minimum standards on international tax dispute resolution

Countries should commit to minimum standards on the resolution of international tax disputes, the Organisation for Economic Co-operation and Development (OECD) said in a report published as part of its base erosion and profit shifting (BEPS) project.06 Oct 2015 The standards would include a commitment to “seek to resolve” cases… – Continue reading

Turkey: Council Of Ministers Approves Agreement Between Turkey And Kosovo To Prevent Tax Evasion And Double Taxation

The Council of Ministers has approved an agreement between the Republic of Turkey and Republic of Kosovo (“State” or collectively “States”) to prevent tax evasion and double income taxation for residents of the two countries (“Agreement”). On 19 August 2015, the Council of Ministers approved the Agreement and its annexed… – Continue reading

Mythbusters: the UK/Spain tax treaty

Writing exclusively for SuperyachtNews.com, Patrick Maflin, of Marine Accounts, advises crewmembers on how best to avoid falling foul of the UK/ SPAIN Double Taxation Agreement… The Seafarers Earnings Deduction (SED) is arguably the taxation scheme of choice for most Seafarers nowadays working on foreign going yachts. It is open to… – Continue reading

Singapore: Singapore Tax Treaties: The End Of Limitation Of Relief?

What is limitation of relief? Here is an actual illustration: A client in Singapore has loans to a Spanish SOCIMI, a real estate investment company equivalent to a REIT. Spain requires tax to be deducted at source when interest becomes payable even if in fact the interest is not actually… – Continue reading

OECD poised to release new tax dodge rules

Senior EY partners Andy Archer and David Snell look at some looming changes to international tax rules. In what will be the biggest change to the international tax rule book since it was put in place before World War 2, the OECD will tomorrow (4 am Tuesday 6 October) release… – Continue reading

Plans to overhaul global tax system to be published

A plan for overhauling the global system for the taxation of multinationals, to be published on Monday in Paris, will contain major challenges and opportunities for Ireland’s vital foreign direct investment (FDI) sector, according to tax experts, reports the Irish Times. The culmination of two years’ work, the report by… – Continue reading

Why landmark OECD tax reform is doomed before it starts

The OECD’s final package of proposals for reforming the international system for taxing companies brings to an end the two-year BEPS project led by the OECD and other G20 countries which also included participation by representatives of developing countries, business, academia and NGOs. Developing the BEPS, or Base Erosion and… – Continue reading

India discussing revision of tax treaty with Mauritius: Hasmukh Adhia

NEW DELHI: The Centre is in talks with Mauritius with regard to the long-pending revision of the bilateral tax treaty, Revenue Secretary Hasmukh Adhia said today. “We are in discussion with them. Some negotiations have already taken place and they wanted to reopen certain issues. we are in discussion with… – Continue reading

Global Tech Firms Brace for Tax Rules Which Could Create New Disputes

PARIS–Global tech firms such as Amazon.com Inc. are already preparing for new tax rules that could force them to pay corporate taxes in more countries where they operate, but are also girding for what some say will be more fights with–and between–national tax authorities. The Organization for Economic Cooperation and… – Continue reading

Colombia and Panama fail to meet deadline in tax evasion dispute

Colombia and Panama have given each other another 60 days to come to agreement on how to combat Colombian tax evasion through Panamanian banks. The two countries failed to meet the negotiation deadline set for the exchange of tax information after one year, extending a further 60 days, in a… – Continue reading

OECD Beps: Biggest corporate tax reform plan since 1920s

On Monday (5 Oct) the Paris-based Organisation for Economic Cooperation and Development (OECD) will present its final Base Erosion and Profit Shifting (Beps) project corporate tax reform proposals and on Tuesday the Ecofin council of EU finance ministers, is expected to agree on the exchange of tax rulings between member… – Continue reading

Taxation of undistributed profits of foreign companies controlled by Indian MNCs’, an evident outcome?

By: Jayesh Sanghvi, Partner & National Leader – International Tax Services, EY India Multinational groups can create non-resident affiliates in low tax jurisdictions to which income is shifted, wholly or partly for tax reasons rather than for non-tax business reasons. Such overseas profits are not subjected to tax in the… – Continue reading

Cyprus: Double Tax Agreement Round-Up

The new Protocol to the Cyprus – Ukraine double taxation agreement The Cyprus Ministry of Finance has announced that agreement has been reached with Ukraine on a Protocol that will amend the existing DTA between the two countries. The existing DTA was signed in 2012 and entered into force on… – Continue reading

India signs 16 advance pricing agreements with MNCs

The income tax department has signed 16 advance pricing agreements (APAs) with multinational companies (MNCs) so far, exempting their transactions with local units from rigorous tax audits. The income tax department has signed 16 advance pricing agreements (APAs) with multinational companies (MNCs) so far, exempting their transactions with local units… – Continue reading

Orders on tax information exchange agreements with Nordic jurisdictions and protocol on avoidance of double taxation arrangement with the Mainland gazetted

Hong Kong (HKSAR) – Six orders for implementing the tax information exchange agreements (TIEAs) with six Nordic jurisdictions (i.e. Denmark, the Faroes, Greenland, Iceland, Norway and Sweden), and an order for implementing the Fourth Protocol to the Comprehensive Arrangement for the Avoidance of Double Taxation with the Mainland (the Arrangement)… – Continue reading

IRS Begins Exchanging Tax Info with Other Countries under FATCA

The Internal Revenue Service said Friday it has met a key milestone relating to the Foreign Account Tax Compliance Act, or FATCA, having begun exchanging tax information with certain foreign governments in time to meet a Sept. 30, 2015 deadline. The automatic exchange of account information with tax authorities abroad… – Continue reading

Jersey: The Offshore Dragon: The Increasing Popularity Of IFCs In The PRC

Using companies incorporated in international financial centres (IFCs) in structuring financial transactions, capital raisings and corporate structures has long been popular in Asia, particularly Hong Kong (itself an IFC). Following the energetic expansion of the PRC economy and assisted in part by the relaxation of PRC regulations in relation to… – Continue reading

Hong Kong likely to be removed from European Commission tax blacklist

European Commission list identifies the city as one of 30 non-cooperative tax jurisdictions, reports the South China Morning Post. The European Commission is likely to remove Hong Kong from its list of top 30 tax havens, according to a source familiar with the situation. The source, who cannot be identified,… – Continue reading

Boston University professor tapped as S. Korean arbitrator in Hanocal case

SEOUL/SEJONG, Oct. 1 (Yonhap) — A professor of international business law at Boston University has been tapped to represent South Korea in a tax dispute case involving a Netherlands-based company, the government said Thursday. Hanocal Holding B.V., a Dutch paper company belonging to the International Petroleum Investment Company (IPIC) of… – Continue reading

New tax landscape imposes burdens on corporate entities –PwC report

A new report by global consulting outfit, Price¬waterhouseCoopers (PwC), released on Monday has indicated that expanding com¬pliance burden, more audits and the potential for increased and double taxation remain key hurdles facing companies due to the rapidly evolving global tax landscape. The report’s findings showed that the demand for greater… – Continue reading

BEPS recommendation: Lower thresholds for permanent establishments may impact MNEs going global

At the request of the G20, OECD published its Action Plan on addressing ‘base erosion and profit shifting’ (BEPS) in July 2013, wherein it identified 15 actions on BEPS for future work, intending to carry out fundamental changes to the international tax standards. Amongst other, Action 7 deals with ‘preventing… – Continue reading

Steps to avert treaty abuse makes treaty access more taxing!

Tax treaties serve to reduce or eliminate double taxation which, if unrelieved, would be a significant barrier to cross-border trade and investment. At the same time, there was need felt to protect against granting of treaty benefits in inappropriate circumstances. In this background, the work of the OECD and G20… – Continue reading

‘Mistrust’ hampering continental trade

Pretoria – Trade between African countries remains low, despite efforts to harmonise taxation to allow for the free movement of goods and services. Tax experts this week warned mistrust between countries remains the greatest detractor to achieve harmony and increase intra-trade. Intra-Africa trade was only 11.3 percent of the continent’s… – Continue reading

OECD says Ireland to benefit post-BEPS

The OECD has said that its base erosion and profit shifting (BEPS) project will create policy challenges for Ireland, but the nation should emerge well placed to attract foreign direct investment, reports Tax News. The report states: “Given the strong presence of intellectual property-intensive information technology and pharmaceutical companies in… – Continue reading

SC to hear Castleton Investment case against MAT levy tomorrow

The court agrees to an early hearing in the case, scheduling it for 30 September New Delhi: The Supreme Court on Tuesday agreed to an early hearing in the case of Castleton Investment Ltd scheduling it for 30 September. Castleton Investment, a Mauritius-based foreign company, is contesting a case against… – Continue reading

China Pushes Ahead with Localisation of BEPS Actions

China’s State Administration of Taxation (SAT) has been busy during recent months pushing ahead with its own plans to update/revise a series of domestic tax laws and regulations as well as Sino-foreign tax treaties. The most prominent of these changes is a proposed update of Circular Guoshuifa 2009 No.2 (Circular… – Continue reading