In May 2012, Cyprus introduced a package of incentives and tax exemptions relating to investment in intellectual property rights, commonly known as an “IP box.” Intellectual property projects are particularly susceptible to cross-border planning by reason of the mobility of intellectual property rights, which do not consist of physical assets… – Continue reading
Tax avoidance has always been a matter of great commotion, both for the HM Revenue & Customs, and also for the general public who want to make sure that everybody pays what is due so that fairness is ensured. So when cases such as this hit the news, it is… – Continue reading
In response to the economic downturn and the growing need for tax revenues, the Italian Tax Authorities (ITA), like authorities in many other jurisdictions, have more aggressively targeted multinationals and their tax planning strategies in recent years, resulting in more domestic and international tax controversies. Transfer pricing (TP) issues account… – Continue reading
Ethiopia has signed double taxation avoidance agreement with Poland on July 13, 2015, Ethiopian News Agency reported (ENA). The agreement was signed between Ethiopian Minister of Finance and Economic Development, Sofian Ahmed and Poland Minister of Finance, Mateusz Szczurek as the side event of the Third International Conference on Financing… – Continue reading
Sofia. Bulgarian government approved the agreement between Bulgaria and Romania on the double taxation avoidance and prevention of tax concealing, inked in April 2015, the press office of the Bulgarian Council of Ministers announced. The document is filed for ratification by the parliament. The current agreement between the countries was… – Continue reading
Over the past few months, several foreign portfolio investors registered in India have received notices from the Indian tax authorities demanding payment of Minimum Alternate Tax in respect of transactions which took place over the course of prior assessment years. The Indian Government has indicated that it could raise several… – Continue reading
MUMBAI: The government may soon clarify tax rules making it easier for fund managers operating large India-dedicated funds to set up an office in the country, four months after finance minister Arun Jaitley announced in the budget about the government’s intentions to do so. The finance ministry and the central… – Continue reading
Republican presidential candidate Rand Paul sued the Treasury Department and Internal Revenue Service over rules on how Americans abroad are taxed and what foreign banks must disclose about U.S. customers. The Foreign Account Tax Compliance Act is supposed to make it harder to hide assets overseas, yet its regulations are… – Continue reading
Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely questioned whether this tax is compliant with the provisions of the EU treaties and the double tax treaties signed by France. French subsidiaries whose parent… – Continue reading
In a recent case involving Next Brand Ltd, the First-Tier Tribunal ruled in favor of HM Revenue & Customs (HMRC), finding that double tax relief was not available for dividends that in effect represented loan repayments. Background Prior to the introduction of the dividend exemption, when a UK parent company… – Continue reading
Investors need to scrutinise the impact of new tax measures on the banking sector after the Budget created clear winners and losers, managers have claimed, the FT Advisor reports. Last week Chancellor George Osborne revealed in his first Conservative Budget that the annual levy UK banks must pay – based… – Continue reading
The Supreme Court has overturned a lower court’s ruling that the government’s comprehensive real estate taxation system is being run correctly, saying real estate owners have been double-taxed on some of their holdings. In a lawsuit filed by 25 Korean companies, including KT and the Korea Electric Power Corporation, against… – Continue reading
Mauritius’ former finance minister claims that his country has given up the right to tax capital gains. This has raised questions regarding the scope of the renegotiation of the India-Mauritius Double Tax Avoidance Treaty (DTAA) Former finance minister of Mauritius says renegotiated tax treaty with India will have devastating effect… – Continue reading
The Government’s submission to the “Re:think” tax white paper process under way in Australia highlights the lack of mutual recognition of imputation credits as the most significant barrier to a seamless transtasman market and calls for visionary political leadership. Prime Minister John Key displays the very leadership he’s calling for,… – Continue reading
The long-awaited formation of the Asean Economic Community (AEC) is just over five months away. Drawn by the promise of a freer flow of goods, services, investment, capital and skilled labour, many businesses need to study how to prevent or reduce the effects of double taxation. Double taxation results from… – Continue reading
A draft amendment to the Income Tax Ordinance and the Prohibition on Money Laundering Law regarding Israel joining international tax information-sharing agreements. The Israel Tax Authority (ITA) has just circulated a draft amendment to the Income Tax Ordinance and the Prohibition on Money Laundering Law regarding Israel joining international tax… – Continue reading
Special Business News article by Rob Rotherham, KPMG tax division senior manager, on the effects of the UK Budget. With effect from April 1, 2015, the UK Government introduced a new tax: the Diverted Profits Tax. (DPT). The DPT is aimed at countering the use of aggressive tax planning techniques… – Continue reading
Muscat: His Majesty Sultan Qaboos Bin Said today issued two Royal Decrees as follows: Royal Decree No. 30/2015 establishes Oman Governance and Sustainability Centre and promulgates its bylaw. Article (1) states that a centre to be named “Oman Governance and Sustainability Centre” shall be set up and affiliated to the… – Continue reading
On 07th July 2015, the United States and Vietnam signed an income tax treaty with Vietnam, the first ever between the two countries. The Double Taxation Agreement applies to personal income tax and enterprise income tax in the case of Vietnam. What is a permanent establishment? Under the Double Taxation… – Continue reading
Ukraine and Cyprus have agreed to review bilateral agreements on taxation to prevent the withdrawal of capital to offshore zones, Finance Minister Natalie Jaresko wrote on Facebook. “After very lengthy negotiations, we’ve finally taken an important step in the fight against capital withdrawal to offshore zones: we have with the… – Continue reading
The benefits of switching to Bangkok Qualifying Recognised Overseas Pension Schemes (QROPS) are often overlooked by expats who believe the low cost of living in Thailand is already making their money stretch further. Bangkok offers a great life for expats with even modest financial resources with a tropical climate and… – Continue reading
Portugal is an increasingly desirable destination, thanks to its tax-friendly stance. Portugal may not be top of everyone’s list in terms of tax-friendliness, particularly given the recent backdrop of the recession and bail-out, but it does have a history of running successful tax-friendly programmes, for example the Madeira and Azores… – Continue reading
OECD guidance needs to be clear otherwise the process could favour the bigger nations In Paris last week, as Angela Merkel and Francois Hollande discussed events in Greece, the international tax system was being discussed in an underground meeting room at OECD headquarters. For almost two days tax authority delegates… – Continue reading
Over the past few months, several foreign portfolio investors registered in India have received notices from the Indian tax authorities demanding payment of Minimum Alternate Tax in respect of transactions which took place over the course of prior assessment years. The Indian Government has indicated that it could raise several… – Continue reading
The Supreme Court ruled on Sunday that the country’s tax authority may have imposed double taxation on real estate holders, a decision that could make the National Tax Service (NTS) responsible for handing back massive refunds to domestic businesses. On Sunday, the Supreme Court sent back to the Seoul High… – Continue reading
Uzbekistan’s President Islam Karimov has signed a protocol to make amendments to Uzbek-Belgian convention on avoidance of double taxation and prevention of tax evasion on income and capital. Uzbek president’s decree “On approving the international agreement” published in the local media July 13, approves the amendments to the convention of… – Continue reading
On 10 July 2015, Liechtenstein and Switzerland signed a new Income and Capital Tax Treaty. Once in force and effective, the new treaty will replace the old one of 1995. The new treaty will come into force after the two countries exchange ratification instruments. The provisions of the new treaty… – Continue reading
Experts have warned of the impact of UK Chancellor George Osborne’s decision to abolish permanent non-dom status and tighten non-dom inheritance tax (IHT) rules. The Government will abolish permanent non-dom tax status, meaning that anyone resident in the UK for more than 15 of the past 20 years will have… – Continue reading
The continuing speculation over Greece’s possible exit from the Eurozone and the weakening effect this might have on the shared currency in the short-term, may once again be prompting some folks to consider setting up non-resident bank accounts in non-eurozone countries. Offshore banking has a bit of a dodgy image… – Continue reading
One of the most immediate and obvious consequences of globalisation is the impact of domestic tax policies in other countries on the economy of Tanzania. This has necessitated the continuous evaluation of the tax regime in Tanzania and brought about crucial fiscal and economic reforms in the country. Hence, the… – Continue reading
A “tax allowance”. That’s what the Government calls the new £5,000 tax-free band of dividend income announced in the Budget. In other words, it’s a favour they are doing us – offering a tax perk, akin to the breaks on Isas or the tax-free personal allowance. By introducing a dividend… – Continue reading
As many of our readers know, the Canadian Income Tax Act (the “Act”) provides for an unlimited exemption from the imposition of Canadian income tax on the gains resulting from a disposition of a “principal residence”. Access to the principal residence exemption can be valuable, especially in cities (e.g. Vancouver,… – Continue reading
Finance Ministry has informed that the negotiations on the double taxation avoidance agreement (DTAA) between India and Mauritius are in advanced stage and the pact would be revised soon. Revenue Secretary Shaktikanta Das has said that “DTAA treaty (with Mauritius) is in very advanced stage of negotiation. It is progressing… – Continue reading
Poor countries need to get better at raising tax, and multinational firms need to get better at paying it SOMALIA is not only one of the world’s poorest and least developed countries, it is also one of the most dangerous for tax collectors. By one reckoning a fifth of tax… – Continue reading
The government’s grip over information is tightening not only in respect of transactions undertaken within the country but also overseas In a liberal economic and low tax rate environment, people are expected to go straight. Tax fraud and tax evasion deprive governments of revenues needed to restore growth and at… – Continue reading
Swiss Poised To Support Greek Tax Amnesty by Matthew Allen, swissinfo.ch Struggling to pay off more than €300 billion (CHF313 billion) in debts, Greece is banking on Switzerland to help it recover a treasure trove of undeclared assets that tax cheats have stashed in alpine vaults. But anti-tax haven campaigners… – Continue reading
MUMBAI: Mauritius, which serves as the gateway to Dalal Street for most foreigners, will be back in news soon. India and the tax haven are believed to be close to finalising a revised tax treaty that would lower tax on interest income of overseas investors betting on Indian debt papers…. – Continue reading
Italy has ratified the inter-governmental agreement top facilitate compliance with the United States Foreign Account Tax Compliance Act. FATCA, enacted by the US Congress in 2010, is intended to ensure that the US obtains information on accounts held abroad at foreign financial institutions (FFIs) by US persons. Failure by an… – Continue reading
Remuneration paid for employment services performed in Canada (even for short-term assignments) by non-resident employees is subject to Canadian income tax withholding, remittance and reporting requirements under subsection 153(1) and regulation 102 (Reg. 102) of the Income Tax Act (Canada) (Act). On April 21, 2015, Finance Minister Joe Oliver tabled… – Continue reading
Treaty developments Following last month’s report that the Mauritius/South Africa double tax treaty had been ratified in Mauritius, the treaty has now come into force on 28 May 2015. The new Hong Kong/South Africa double tax treaty, which was signed last year, has been ratified in Hong Kong on 3… – Continue reading
New Zealand, Samoa sign double tax agreement WELLINGTON, July 8 (Xinhua) — New Zealand and the Pacific island nation of Samoa have signed a double tax agreement that should help boost trade and investment, New Zealand Prime Minister John Key said Wednesday. Key, who is in Samoa for a rugby… – Continue reading
MULTAN: Pakistan Tehreek-i-Insaf (PTI) national organiser Shah Mehmood Qureshi on Tuesday lambasted the imposition of a 0.6 per cent withholding tax on bank transactions. Qureshi was speaking to journalists at the press club. He demanded that the tax to be immediately withdrawn and said the PTI stood with traders on… – Continue reading
On 17 June 2015, the Income Tax Treaty between Malta and Moldova entered into force and will come into effect on 1 January 2016. The Treaty was signed on 10 April 2014. In accordance with the treaty, the following withholding taxes will apply: Dividends: where the dividends are paid by… – Continue reading
Where Qualified Dividend Treatment Is Important, Serious Consideration Should Be Given to Ensuring the Company Is Eligible for Treaty Benefits Before Taking It Public. Dividends generally are taxed at ordinary income rates (up to 39.6 percent for individuals). Qualified dividends derived by individuals, however, are taxed at the preferential rate… – Continue reading
Agreement with Mauritius to be renegotiated. National Treasury says the abuse of double tax agreements by multinational companies is the main reason why the agreement with Mauritius has been renegotiated. National Treasury head of tax and financial sector policy Ismail Momoniat says companies have often used dual tax residence structures… – Continue reading
Finance Act 2015 has expanded the scope of the agreements meant for avoidance of double taxation and prevention of fiscal evasion to be executed by the federal government. Explaining the Finance Act 2015, Former FBR Member Habib Fakharuddin said that the federal government may enter into an agreement, bilateral or… – Continue reading
BARBADOS is targeting the South American country of Colombia for more international business. A delegation from the island will be spending the next week or so in that country as this island looks to broaden the more than $900 million in domestic contributions by the international Business and Financial Services… – Continue reading
The present French Tax Update will focus on an overview of several noteworthy French tax court decisions issued during the past few months. BUYBACK AND CANCELLATION OF OWN SHARES The tax treatment of buybacks, from the shareholders’ point of view, has now been simplified through a change of legislation, i.e.,… – Continue reading
With a new government at India’s center and positive macroeconomic fundamentals working in its favor, the private equity industry is expected to invest more actively into India over the short to medium term. In the past year, inflation has steadily tapered, the fiscal deficit has been reduced, domestic demand has… – Continue reading
The UK Government’s goal is to make the UK the best place in the world to locate an international business; it has one of the most open economies globally, a highly skilled workforce, access to capital markets, a first-class infrastructure, and a highly competitive corporate tax system. UK tax policy… – Continue reading
