Category: Investments

Mark Zuckerberg defends philanthropic venture against tax avoidance claims

Mark Zuckerberg has defended the structure of his new philanthropic organisation after critics suggested he was avoiding paying tax on the sale of his shares. Zuckerberg and his wife Priscilla Chan launched the organisation, the Chan Zuckerberg Initiative, this week to honour the birth of their daughter, Max. The couple… – Continue reading

Pfizer and Allergan chiefs say merger is good for America

Employees at Allergan have been told a proposed merger with Pfizer is about changing healthcare – not skirting tax law. Allergan’s global chief executive Brent Saunders has written directly to the company’s employees – including around 1,000 in Ireland, telling them the controversial deal is not just about tax savings…. – Continue reading

Italy Issues Patent Box Guidance

On December 1, the Italian Revenue Agency issued a guide delineating how companies can take advantage of Italy’s “patent box,” together with a circular containing the answers to questions arising out of the new regime’s operation. With effect from the present 2015 fiscal year, the patent box offers an optional… – Continue reading

France-Luxembourg tax treaty change cannot come into force until 2017

France and Luxembourg failed to ratify a protocol changing the France-Luxembourg double tax treaty by 30 November, which means that a change which will affect real estate structures cannot come into force until 1 January 2017, at the earliest, for companies whose fiscal year is based on a calendar year…. – Continue reading

A battle over billions in business tax incentives

Deep in the $1.1 trillion dollar spending bill that Congress has to pass by Dec. 11 to avoid a government shutdown are 50 annual “tax extenders” that would provide tens of billions of dollars in tax relief for the private sector. Advocates say these measures, which have been around for… – Continue reading

Government looks to rework DTAA tax provisions

Some of the DTAAs entered into by India with other countries allow taxation of capital gains on shares only in the country of which the taxpayer is a resident. The government on Friday told the Lok Sabha that it has started negotiations with some countries to amend provisions on capital… – Continue reading

Tax Revenue Loss due to Avoidance and Tax Planning by Companies

The Government of India is aware of the potential loss of revenue from tax avoidance, and has been taking all necessary measures for preventing it. As a part of these measures, India has actively participated n the Base Erosion and Profit Shifting (BEPS) project undertaken by the OECD and G-20… – Continue reading

China’s new transfer pricing guidelines and BEPS

The highly significant changes to transfer pricing guidance planned for under the SAT’s public discussion draft on ‘Special Tax Adjustments’ (yet to be finalised at the time of writing), and the impact of these changes in the light of evolving Chinese transfer pricing enforcement practice is the focus of this… – Continue reading

Bulgarian Offshore Companies Act amendment seeks to ease restrictions

A newly introduced amendment to the Bulgarian Offshore Companies Act (the “Act”) will bring significant changes to investment opportunities for offshore companies. If the Bulgarian Parliament adopts the amendment within the next month, the amended Act is expected to enter into force in the beginning of 2016. The proposed amendments… – Continue reading

Australia Legislates For Common Reporting Standard

The Australian Government has introduced legislation to implement the Organisation for Economic Cooperation and Development’s (OECD’s) Common Reporting Standard for the automatic exchange of financial account information. Treasurer Scott Morrison said: “The Standard will assist the tax office to crack down on taxpayers hiding funds and investments offshore in order… – Continue reading

Banks, MFs ask US NRIs to submit FATCA certificates

MUMBAI: Indian banks and mutual funds have in the past fortnight started warning NRIs who hold an American passport or are working in the US that their accounts could be frozen unless they get a tax-compliant certificate from US authorities, thanks to a treaty signed by New Delhi and Washington…. – Continue reading

OFFSHORE TAX EVASION BILL IN PARLIAMENT

Australians hiding funds and investments offshore to avoid paying tax have been put on notice. The federal government on Thursday introduced to parliament legislation to enable the tax office to crack down on taxpayers hiding funds overseas. It implements an OECD scheme allowing the sharing of information between foreign tax… – Continue reading

Offshore Industry Tipped for Growth, Driven by Demand from Emerging Markets, According to OIL Offshore 2020 Report

HONG KONG, Dec. 2, 2015 /PRNewswire — Demand for asset protection, wealth planning and funds by high net worth individuals in Asian countries will drive continued growth in the offshore industry, according to OIL’s sixth “Offshore 2020” annual market research study. OIL, the leader in international incorporations and corporate services… – Continue reading

FATCA List – December 1, 2015

The US Internal Revenue Service (IRS) reports no new registrations under Foreign Account Tax Compliance Act (FATCA) rules in November. The list stays at 177,147 institutions in 226 financial jurisdictions. The list details which overseas financial institutions have agreed to pass personal and financial information about accounts and investments controlled… – Continue reading

The foreign investment tax advisers should pay attention to

Taxes levied on foreign stock dividends can be recouped, but it makes most sense for high-net-worth clients with multimillion-dollar positions Advisers could be missing out on a way to maximize returns on their clients’ foreign investments. Americans investing in non-U.S. stocks could be earning less of a return than they’d… – Continue reading

Federal Tax Advisory: Economic Substance Doctrine Cases

Things are heating up in the economic substance doctrine area, which could lead to a U.S. Supreme Court review of the IRS’s aggressive arguments for the doctrine. Certiorari Petitions Salem Financial Inc. and Bank of New York Mellon Corporation have both petitioned for Supreme Court review of the Federal Circuit… – Continue reading

The foreign investment tax advisers should pay attention to

Taxes levied on foreign stock dividends can be recouped, but it makes most sense for high-net-worth clients with multimillion-dollar positions Advisers could be missing out on a way to maximize returns on their clients’ foreign investments. Americans investing in non-U.S. stocks could be earning less of a return than they’d… – Continue reading

Russian withholding tax reclaim process

In a previous article we have discussed that you might be entitled to reclaim withholding tax on your foreign investments in Russia (including ADRs, GDRs). For transactions where the ultimate beneficial owner is not declared prior to the payment of income, local Russian custodians apply 30% withholding tax on dividends1… – Continue reading

The Changing Face of Luxembourg Finance

“Luxembourg is famous for two things: its steel industry and its rose cultivation industry”. This quote from an Italian guidebook of the 1930s was uttered by Luxembourg’s Finance Minister Pierre Gramegna at the annual conference of the Luxembourg Directors’ Association on 17 June 2015[1]. The economic outlook of the tiny… – Continue reading

Cyprus link to ‘universally condemned’ Russia tax fraud case

Police last week raided the Nicosia offices of the law firm representing the Hermitage Fund, embroiled in the largest fraudulent tax rebate case in Russian history, the Cyprus Mail has learned. On Friday, two senior Russian interior ministry officials along with local police officers searched the Nicosia offices of a… – Continue reading

Pensions – Articles – Can infrastructure keep delivering for schemes in 2016?

Pension schemes should review their holdings in infrastructure heading into 2016, with the dual threat of incoming regulation and high prices potentially threatening returns, Kames Capital has said. Infrastructure has been an increasingly popular asset class for many schemes since bond yields tumbled in the wake of the financial crisis,… – Continue reading

Appleby: Private Equity Investment In Bermuda

The number of M&A transactions involving Private Equity [PE] investment in Bermuda in the first three quarters of this year has already eclipsed that seen in all of 2014, according to a report released today [Nov 30] by Appleby. “Bermuda was also the offshore jurisdiction to see the largest total… – Continue reading

Mauritius plans derivatives platform in bid for African business

Mauritius plans to launch a trading platform to hedge African currencies against the US dollar, part of a bid to expand its role as a financial hub for the continent, the financial services minister said. The Indian Ocean island is also in talks to boost ties with stock exchanges in… – Continue reading

Destination ‘filthy rich’: Where the wealthy go to get even richer

WELCOME to Switzerland. A mountainous country where nothing comes cheap but many of the world’s filthy rich come to grow their fortunes. The ongoing relationship between the wealthy and Switzerland looks set to only strengthen as the super rich get richer, according to a report released on Friday. That’s despite… – Continue reading

Sea-change in landscape of taxation

KUWAIT CITY, Nov 29: “The world of taxation has changed tremendously impacted by FATCA, transfer pricing, Base Erosion and Profit Sharing, and others which require dramatic changes in existing operating models and structures,” remarked Fouad Douglas, PwC Country Senior partner, at a tax seminar organised by the PwC in conjunction… – Continue reading

Iran, Hungary ink 8 coop. documents

TEHRAN, Nov. 30 (MNA) – Islamic Republic of Iran and Hungary signed eight cooperation documents for widening and deepening of relations. During his visit to Tehran, Hungary’s Prime Minister Viktor Orban, heading a group of 120 economic activists, businessmen and officials from the European country’s banks, and Iranian side signed… – Continue reading

CBDT defines ‘charitable purpose’ for benefits under I-T Act

NEW DELHI: With a view to weed out commercial activities under the garb of charity, the tax department has said any general public service that involves trade, commerce or business for a consideration will not be treated as Charity under the Income Tax act. Issuing ‘Explanatory Notes to the Provisions… – Continue reading

US should respond to OECD tax project with an ‘innovation box’

While the U.S. is plagued by inertia when it comes to tax policy, the rest of the world hasn’t been standing still. The biggest change of late has been the completion of the Organization for Economic Cooperation and Development’s (OECD) Base Erosion and Profit Shifting Project, or BEPS, a multiyear… – Continue reading

Well-timed call to modernise direct tax law

The law, at present, is replete with a complex web of cross-references, often causing confusion The clamour for simplifying tax legislations gets louder as a new government, in its interaction with businesses and the civil society, holds out a promise of a non-adversarial tax regime. The reform of indirect taxes… – Continue reading

East Africa: New Reporting Code for Mncs Could Save Africa $35b

East African countries expect to collect more revenue under a new code drawn, by the world’s richest economies to stop foreign multinationals from dodging taxes in host countries. The new code — Base Erosion and Profit Shifting (BEPS) — adopted by G20 at its meeting in Turkey two weeks ago,… – Continue reading

Apple, Amazon and Microsoft’s mega-million con: How titans of the new economy screw us all on taxes

Tech titans powering the economy shelter money through insane tax-avoidance havens. It’s wrong — and adding up Offshore tax havens enable not only individuals to dodge taxes—they also enable multinational corporations to do so. Often this tax avoidance is done within the letter of the law: multinational groups exploit the… – Continue reading

Pension Funds Reduce Offshore Investments In Kenya

Uncertainty over the US Federal Reserve’s rate hike decision caused lower returns for offshore investments by local pension schemes during the third quarter of the year, new data show. The Alexander Forbes Consulting Actuaries Schemes Survey for the period ending September 2015 covering 380 schemes indicates earnings by pension schemes… – Continue reading

CBDT signs 11 more unilateral advance pricing agreements

NEW DELHI, NOVEMBER 27: The Central Board of Direct Taxes (CBDT) has entered into 11 more unilateral advance pricing agreements (APAs). These APAs were signed with Indian subsidiaries of foreign companies operating in various segments of the economy like investment advisory services, engineering design services, marine products, contract Research & Development,… – Continue reading

Mauritius and Morocco Sign Double Taxation Avoidance Agreement

PRESS RELEASE Mauritius and Morocco signed on November 25 in Port Louis a Double Taxation Avoidance Agreement (DTAA) that will provide for greater tax certainty for businessmen of the two countries. The signatories were the Minister of Finance and Economic Development, Mr Vishnu Lutchmeenaraidoo, and the Ambassador of the Kingdom… – Continue reading

Government Tightens the Screws on Tax Evasion and Non-compliance

Individuals should focus on legitimising their assets while they can and start to look at how they can restructure their investments. Measures to tackle tax evasion continue to be a key focus for the government, with £800 million HMRC funding to be reinvested in additional work to tackle tax ‘evasion… – Continue reading

It’s not too late to invest offshore

‘Offshore exposure should be a part of any well-balanced investment portfolio, regardless of the rand’s value’ – Duane Gilbert. Fund managers are very much aware of the impact of the weaker rand on investments, but for consumers not dealing with asset management on a daily basis it is a huge… – Continue reading

Worldwide: Final BEPS Reports Issued By OECD

The OECD published 13 final reports along with an explanatory statement under its base erosion and profit shifting (BEPS) project on the 5th October 2015. This was endorsed three days later on the 8th October 2015 by the G20 Finance Ministers’ meeting in Peru’. The BEPS project outlines 15 action… – Continue reading

Shriram AMC gets Sebi nod for offshore fund management

Shriram Asset Management Company gets Sebi nod for offshore fund management Shriram Asset Management Company Ltd today said it has got market regulator Sebi’s approval to manage offshore funds. “The company has recently got the go-ahead from Securities and Exchange Board of India (Sebi) to undertake ‘offshore fund management’,” Shriram… – Continue reading

Charlotte Barbour: The drive to decentralise taxes

The House of Lords has recently criticised the speed of further devolution of powers to Scotland, but nevertheless the Scotland Bill is progressing through the UK parliament. Devolution more widely across the UK is a direction of travel in this Chancellor’s Autumn Statement. Among the announcements, George Osborne said that… – Continue reading

Positive offshore report ‘challenges’ perception

Following an independent report which ranked the British Virgin Islands (BVI) as the most important offshore jurisdiction for the sixth consecutive year, local stakeholders are singing the territory’s praises, with one going as far as to claim that the report has challenged the common perception that the BVI is being… – Continue reading

Common Reporting Standard effective in Ireland from 1 January 2016

Recent developments with regard to CRS (the OECD’s “Common Reporting Standard”) mean that Irish funds need to take steps now to update their application forms and subscription documents. As referred to in Matheson’s November Investment Funds Newsletter, the Irish Finance Bill 2015 contains further provisions putting in place the necessary… – Continue reading

Hong Kong: Offshore Industry Tipped For Growth, Driven By Demand From Emerging Markets, According To Leading Offshore Survey

Greater China, Southeast Asia Seen as Global Leaders in Use of Offshore Vehicles, Drawn by Efficiency & Legal Frameworks Key Highlights: OIL’s sixth annual survey shows: The offshore industry will be a leaner, more resilient and confident member of the global economy by 2020, driven by demand from increasing numbers… – Continue reading

Qatar-backed Volkswagen hit by tax evasion probe

German prosecutors have launched an investigation into suspected tax evasion in connection with cheating on emissions tests by Volkswagen, adding to the intense scrutiny of Europe’s biggest carmaker. The investigation focuses on five Volkswagen employees, a spokesman for the prosecutor’s office in the northern German city of Braunschweig, near Volkswagen’s… – Continue reading

Hong Kong: Crackdown On Caribbean Tax Havens A Surprise Boon For Hong Kong

Hong Kong is tipped to become the world’s largest offshore corporate services centre by 2020, helped ironically, by the industry’s own struggles against reform demands coming from western governments and pressure groups. On notice after high profile money laundering and tax avoidance scandals, traditional offshore havens like the British Virgin… – Continue reading