Category: Fees

European Union: European M+A News, Spring 2015

EUROPEAN M&A DOS AND DON’TS FOR NON-EUROPEAN BUYERS Inbound M&A in Europe by non-European buyers increased in 2014 by 68.6% compared to 2013, representing over a third of USD 901.4 billion total European M&A.1 For non-European buyers the basic framework of transactions may be similar, but there are a number… – Continue reading

Firm run by David Cameron’s election guru Lynton Crosby lost £1 million in two years, as pressure mounts on unanswered tax questions

A British company run by the Conservative’s election guru Lynton Crosby lost more than £1 million in two years, public records show. Accounts filed by Crosby Textor Ltd reveal that the firm, owned by Mr Crosby and his business partner Mark Textor made losses of £511,000 in 2014 and £510,000… – Continue reading

Australia must break the shackles of intellectual property in FTAs

Last week some of Australia’s biggest and richest companies voluntarily fronted up to a senate inquiry on corporate tax avoidance. Bigwigs from big brands, including Apple, Google, Microsoft, Rio Tinto, BHP Billiton and Fortescue Metals, squirmed under the spotlight as they were grilled about how they (legally) shift profits offshore… – Continue reading

Treasurers should provide transaction documentation according to BEPS

Corporate treasury departments will have to start complying with International tax rules and provide documentation for transactions according to recent reports. G20 leaders attempted to reform the international tax system in July 2012 by setting up the Base Erosion and Profit Shifting (BEPS) project. This task was given to the… – Continue reading

Cameron advisor back in Labour’s crosshairs over Malta companies

Claims of using Malta to reduce tax liability ‘malicious and libellous’ – Lynton Crosby British Prime Minister David Cameron’s electoral guru, Australian Lynton Crosby, has rejected a Labour attack on his personal tax affairs as a “made up negative story”. On Thursday the British Labour Party called on Mr Crosby… – Continue reading

Wall Street Fees, Swiss Banks, Clydesdale Fined: Compliance

(Bloomberg) — Wall Street banks and other financial firms should pay new fees to bankroll their own government oversight, according to a member of the top U.S. derivatives regulator. Sharon Y. Bowen, a Democrat on the Commodity Futures Trading Commission, said Congress should let the agency set fees on banks… – Continue reading

Tax Directors Expect Their Companies to Expand

Tax directors at many organizations anticipate their companies will grow by entering into new domestic and international markets in the years ahead, according to a new survey by BDO USA. In a sign of an improving economy, 50 percent of the 100 tax directors at $1billion-plus public companies surveyed by… – Continue reading

European Union: European Competition Law Newsletter – April 2015

EU’s Highest Court Rules on Information Exchange On 19 March 2015, the European Court of Justice (ECJ) handed down a significant judgment on the application of EU competition law to information exchange between competitors. The case was an appeal from the European Commission’s 2008 decision to fine banana importers Dole,… – Continue reading

Swiss banks suddenly preach transparency in U.S. tax evasion endgame

Swiss banks, for decades the bastions of secrecy, are preaching the virtue of transparency to their U.S. clients as they try to head off billions of dollars in potential fines for helping Americans evade taxes. Faced with the threat of penalties that could bankrupt some of them, almost 100 of… – Continue reading

Tax Directors Anticipate Domestic and Cross-Border Growth Over The Next Three Years, According To The Inaugural BDO Tax Outlook Survey

– Rising Cost of Compliance Within The Tax And Financial Regulatory Environment Creates Opportunities For Increased Efficiency – CHICAGO–(BUSINESS WIRE)–As the economy continues to accelerate, many organizations plan to grow by entering into new markets in the years ahead, reveals the first ever BDO USA, LLP Tax Outlook Survey. Fifty… – Continue reading

Canada: Private Client Tax, Third Edition – Chapter: Canada

1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins Canada is a federal state, with legislative powers divided between the federal and provincial governments. The federal government has legislative jurisdiction over issues concerning Canada as a whole, including foreign affairs, international trade, banking, telecommunications,… – Continue reading

Social networking sites to become work places

The Revenue Office will take steps to tax social networking sites and implement other regulations related to e-commerce. After the implementation of this regulation, all such virtual sites will be deemed as “work places” and the advertisers of social networking sites will also be deemed as “electronic tax payers.” Moreover,… – Continue reading

PICKING UP THE TAB 2015: SMALL BUSINESSES PAY THE PRICE FOR OFFSHORE TAX HAVENS

Every year, corporations and wealthy individuals use complicated gimmicks to shift U.S. earnings to subsidiaries in offshore tax havens – countries with minimal or no taxes – in order to reduce their federal and state income tax liabilities by billions of dollars. While tax haven abusers benefit from America’s markets,… – Continue reading

Swiss Banks Strong-Arm Clients in U.S. Tax-Evasion Endgame

Swiss banks, for decades the bastions of secrecy, are preaching the virtue of transparency to their U.S. clients as they try to head off billions of dollars in potential fines for helping Americans evade taxes. Faced with the threat of penalties that could bankrupt some of them, almost 100 of… – Continue reading

Legal flash – Shanghai office – March 2015 – Announcement of the State Administration of Taxes concerning enterprise income tax on fees resident enterprises pay to overseas related parties

In recent years, the State Administration of Taxes (“SAT”) has paid closer attention to fees resident enterprises pay their overseas related parties, concerned that multinational groups have shifted profits away from China through aggressive tax planning and by paying unreasonable service fees and royalties overseas. Following PRC’s active participation in… – Continue reading

Worldwide: Protecting Yourself From International Tax Investigations

Who Will Be Next? How To Respond To A Tax Investigation The international political community continues to make the most threatening noises about those who they believe do not pay enough tax. Long gone it seems are the days where it was accepted that a person could properly organise his… – Continue reading

China’s pre-emptive strike on OECD profit-shifting initiative

China has introduced measures to deny income tax deductions for certain service fees and royalties paid by Chinese companies to their overseas affiliates. They appear to stem from China’s initiatives to implement rules it sees as related to the OECD’s Base Erosion and Profit Shifting project (BEPS) They will likely… – Continue reading

Auditors are not forensic investigators – Booker

Changes are in the pipeline which will have a dramatic impact on the way that auditing firms handle public-interest entities (PIEs) as from December 2016 – but Deloitte CEO Malcolm Booker is very wary about how this could work in practice. According to the legislation, auditors would have to enter… – Continue reading

QROPS for US Residents – FATCA & IRS Compliant

For British pension holders in the US, transferring into a Qualifying Recognised Overseas Pension Scheme (QROPS) is now commonplace. These pension solutions are widely accessible to all US residents or nationals who have accrued pensions from their time working in the UK, and are an invaluable aspect of financial planning… – Continue reading

Seychelles Sets Out Transfer Pricing Regime

The Seychelles Revenue Commission has issued, for comment, Public Ruling 2015-3, which explains the authority’s rules and procedures to enforce the arm’s length principle in respect of related-party transactions under Section 54 of the Business Tax Act, 2009. The Ruling states that in applying the arm’s length principle, the Commissioner… – Continue reading

European Competition Law Newsletter – April 2015

EU’s Highest Court Rules on Information Exchange On 19 March 2015, the European Court of Justice (ECJ) handed down a significant judgment on the application of EU competition law to information exchange between competitors. The case was an appeal from the European Commission’s 2008 decision to fine banana importers Dole,… – Continue reading

United States: Uncle Sam Wants You (To Pay Tax): Income Tax Pitfalls For Americans Living Abroad

I. Introduction In an effort to crack down on individuals obtaining U.S. citizenship illegally, the U.S. Department of Justice recently raided several “maternity tourism” operations in Southern California.1 These companies cater to wealthy foreigners seeking to give the gift of U.S. citizenship to their children. Since at least 1868, the… – Continue reading

UK tax rules on disguised investment management fees: final legislation published

The UK’s Finance Bill was published on 24 March 2015. It was subsequently enacted on 26 March 2015 without further amendment and became the Finance Act 2015. The “disguised investment management fee” provisions contained in this Act, summarised below, will be effective from 6 April 2015. These rules apply to… – Continue reading

HMRC triumphs in £260m tax avoidance court battles

HM Revenue & Customs (HMRC) has secured over £260 million after triumphing against three tax avoidance schemes in tribunal battles. The Upper Tribunal dismissed an appeal brought by the investors of a scheme promoted by NT Advisors. This was HMRC’s ninth win against schemes promoted by NT Advisors. According to… – Continue reading

Rory McIlroy moves business interests to Dublin rather than tax haven

Irish economy set to receive financial boost by world number one golfer’s decision to pay tax on earnings. World number one Rory McIlroy is moving his vast business interests to Ireland’s capital city Dublin, according to a report in the Irish Independent. The newspaper says that McIlroy’s decision will boost… – Continue reading

Ghana and Netherlands sign agreement to fight tax evasion

Ghana and the Netherlands have signed a Memorandum of Understanding (MoU) for the Automatic Exchange of Information to help in efforts to fight tax evasion. The agreement would allow the tax authorities of the two countries to automatically provide each other with information about income from immovable property earned by… – Continue reading

Tax refund advances appeal to more cash-strapped Americans

WASHINGTON (AP) — Cash-strapped Americans anxious for tax refunds are increasingly turning to payment advances, prepaid cards or other costly services when getting tax preparation help, according to new federal data raising concerns among regulators about whether consumers are fully informed about the fees. Regulators are looking to increase oversight… – Continue reading

Will There Be An Increase In State Transfer Pricing Audits?

Transactions between related entities are common and engaged in for both business and tax purposes. Management fees, factoring fees, loans, and other intercompany transactions can be beneficial from a tax planning standpoint, provided the transactions are properly structured and supported by adequate documentation, which often includes a transfer pricing study…. – Continue reading

EAC told to weigh pros, cons of single income tax rates

East African member states have been advised to make critical assessment of single income tax rates. A law expert, Anatoly Nahayo said recently in Dar es Salaam after launching his book titled “East African Community Tax Harmonisation.” He said the move will ease allocation of capital shares within EAC member… – Continue reading

Swiss Leaks: Malta Investment Registration Scheme attracts 1,469 applications with €455m

An investment registration scheme launched by the government last year attracted a total of 1,469 valid registrations covering an aggregate of €455.8 million worth of eligible assets, The Finance Ministry told The Malta Independent. Of the total amount registered, €69.8 million or 15% of the total was repatriated following registration…. – Continue reading

Worldwide: Asia Tax Bulletin – January 2015

CHINA China Releases GAAR Administrative Measures Courtesy of Mr Glen Wei, an attorney at law, certified tax adviser, and CPA based in China.China’s State Administration of Taxation (SAT) on December 12 issued Decree 32 (dated December 2) introducing administrative measures for applying the domestic general anti-avoidance rule to special tax… – Continue reading

Payment of Annual Fees (€350) in relation to Voluntary Liquidations (Winding up’s) and Compulsory Liquidations

The Bankruptcies and Liquidations Section announces that, with accordance to the Companies (Amendment) (No. 2) Act 2011, it will not receive the documents for Voluntary Liquidation, unless they are accompanied by a proof of payment of the Annual Fee of the amount of €350 – for all the pending years,… – Continue reading

PAYMENT OF THE ANNUAL FEE

The Department of Registrar of Companies and Official Receiver announces that as from 2nd April 2014 the payment of the annual fee of three hundred and fifty euros (€350) for the years 2011 and 2014 will be done only through the Department’s website www.mcit.gov.cy/drcor and through JCCsmart. NO payment of the annual… – Continue reading