Category: Statutory

FPI holdings from Singapore, Mauritius surge 25% before DTAA implementation

Grandfathering is term for alteration of rules that apply to a certain investment technique Foreign portfolio investors (FPIs) based in Mauritius and Singapore had, it now appears, rushed to take advantage of the ‘grandfathering’ clause in the new Double Tax Avoidance Agreement signed between both the governments of the two… – Continue reading

IRS pilots new secure messaging program for correspondence examinations

The Internal Revenue Service is pilot testing a new program for conducting correspondence examinations of taxpayers using secure messaging technology that will also include their tax practitioners who have power of attorney. In an email to tax professionals Friday, the IRS said it plans to invite approximately 8,000 taxpayers who… – Continue reading

Tax collection from offshore gaming to double this year

REVENUE generated from taxing offshore gaming operations here is expected to double in 2017, or less than a year since the industry was regulated, with the Philippine Amusement Gaming Corporation’s (PAGCOR) online gaming arm noting high demand for licenses. PAGCOR’s recently established Philippine Offshore Gaming Operators (POGO) estimates that it… – Continue reading

Tax on offshore investments: time to come clean

The South African Revenue Service (SARS) launched the Special Voluntary Disclosure Programme (SVDP) in October 2016, providing taxpayers with the opportunity to make good on any tax and/or exchange control contraventions of which they may be guilty in relation to offshore investments. The nine-month window period opened on October 1,… – Continue reading

U.S. companies push hard for lower tax rate on offshore profits

Major U.S. multinationals are pushing the Trump administration to deepen the tax break it has already tentatively proposed on $2.6 trillion in corporate profits being held offshore, a key piece in Washington’s intricate tax reform puzzle. As President Donald Trump tries to deliver on his campaign promise to overhaul the… – Continue reading

India calls for global co-op to tackle illicit financial flows

India has called for enhanced international cooperation to address illicit cross- border financial flows, tax evasion and “hawala” transactions as it stressed that the world’s governance architecture for cooperation in taxation has not kept pace with globalisation. “Raising awareness on the important issue of International Cooperation on Tax matters is… – Continue reading

IMF Says African Countries Need To Tap New Revenue Streams

Sub-Saharan African countries should look to tap tax revenues outside natural resources, to finance stimulus measures that could reinvigorate their ailing economies, a new report from the International Monetary Fund says. The IMF’s Regional Economic Outlook for Sub-Saharan Africa report, released on May 9, notes that growth in the Sub-Saharan… – Continue reading

Regulatory Issues: Financial account information exchange for increased tax compliance

Malaysian individuals and entities that have bank accounts overseas will soon see their financial information being shared with other countries and tax authorities in an effort to boost global transparency and tax compliance. This requirement is part of the automatic exchange of financial account information set out by the Organisation… – Continue reading

Australian Budget Targets Housing, Tax Compliance

Australian Treasurer Scott Morrison’s 2017 Budget focused on measures to cool the housing market and crack down on tax avoidance. Morrison handed down the Budget on May 9. He said the the budget would return to a surplus in 2020-21 and remain in surplus over the medium term. The Budget… – Continue reading

Budget 2017: “Black economy”, multinationals in spotlight as government focuses on tax integrity

The federal government has pledged to create more fairness for businesses and “level the playing field” through a series of budget measures directed at tackling Australia’s so-called “black economy”. The government gave its “black economy taskforce” the job of investigating how individuals and businesses use cash payments in December 2016,… – Continue reading

Federal Budget 2017: Foreign home buyers hit by vacancy tax and restrictions

Foreign ownership of new developments will be restricted, there will be steeper charges applied to purchases, less favourable tax treatment and charges on those with empty properties, in a raft of measures in the federal budget aimed at taking the sting out of the housing market. One measure to be… – Continue reading

Draft rules released to prevent tax evasion via unquoted shares

NEW DELHI: India’s apex body for direct taxes has proposed new rules for bringing the value of unquoted shares on a par with the fair market value of underlying assets, seeking to prevent tax avoidance by firms that use the historical acquisition cost to set the price of unlisted stock…. – Continue reading

FBR initiates scrutiny of offshore transactions

KARACHI: The Federal Board of Revenue (FBR) has initiated audit of all those taxpayers who have made offshore transactions during the last six years, sources said on Tuesday. “All corporate and individual taxpayers, who have made offshore investments, have been selected for audit to check the tax concealment,” an official… – Continue reading

License barrier as of January 2018: Limited tax deductibility for cross license order royalty payments to foreign related parties

Germany will introduce “license barrier rules” as of January 2018. The new rules will limit the tax deductibility of license fees or royalty payments to foreign related parties that benefit from preferential regimes (“Patent Box”, “IP-Box”, “License Box”) which are incompatible with the “OECD nexus approach” (“unqualified preferential regimes”) (sec…. – Continue reading

Russia introduces draft law on country-by-country reporting requirements: implications for multinationals

A newly published federal draft law introduces Russia to a three-tiered approach to transfer pricing documentation and brings Russian regulations in this area in line with the OECD minimum standards under Action 13 of the Base Erosion and Profit Shifting (BEPS) Action Plan. The draft law, published by the Ministry… – Continue reading

Trump’s tax plan could have rich New Yorkers fleeing for Florida

President Trump has signed three executive orders to spark reviews of tax and financial regulations so taxes on businesses and individuals can be cut. The approach would be different from Trump’s earlier plan, which was criticized as an approach that would mostly benefit higher earners. Michael Zezas, a strategist at… – Continue reading

Tax predictability is key to driving investment

Deloitte survey highlights tax predictability as key to driving investment growth in Asia Pacific New Zealand well placed against backdrop of increased uncertainty in Asia Pacific’s tax landscape New Zealand’s tax policies are seen as relatively straight forward, consistent and predictable compared to other countries in the region, according to… – Continue reading

Trump Plans to Seek 10% Tax on Offshore Earnings, Official Says

President said to call for taxing pass-throughs at 15% Pass-throughs are currently taxed at higher individual rates President Donald Trump plans to propose a 10 percent tax on more than $2.6 trillion in earnings that U.S. companies have stockpiled offshore, said a White House official familiar with the president’s tax… – Continue reading

Survey: Citizens in G-20 countries favor gov’t cooperation over tax competition

The overwhelming majority of people in G-20 countries believe that cooperation between governments on tax policy is more important than competition to increase national tax revenue. According to a survey by the Association of Chartered Certified Accountants, the preference for cooperation over competition is strongest in Argentina, Australia, Brazil, France,… – Continue reading

Chevron: a game-changer for multinational tax avoiders

The Australian Tax Office had a superb win against Chevron in the Federal Court last week, but there is something everyone is missing, something that will turn the art of tax avoidance on its head; a game-changer for multinationals. Put simply, Chevron borrowed US$2.5 billion in the US at less… – Continue reading

Ontario Introduces the new Non-Resident Speculation Tax

Overview of the Tax As expected, the Government of Ontario has introduced a new non-resident speculation tax (“NRST”) that takes effect on April 21, 2017. The NRST is a 15% tax payable on the purchase of an interest in residential property located in the “Greater Golden Horseshoe” area (which includes… – Continue reading

US tax cuts could lead to financial instability: IMF

Report warns that Trump’s proposed corporate tax reforms could spark risk-taking WASHINGTON • The International Monetary Fund (IMF) warned yesterday that United States President Donald Trump’s proposed tax cuts and reduction of financial regulations could spark a new round of financial risk-taking of the type that preceded the last crisis… – Continue reading

General Election 2017: People on more than £70k ‘could pay more tax if Labour wins power’

People earning more than £70,000-a-year could be forced to pay more tax if Labour wins power, Shadow Chancellor John McDonnell hinted today. He stressed Labour wanted a “fair taxation system” which would see corporations and the rich “pay their way more”. Asked to define rich, Mr McDonnell said they would… – Continue reading

St Kitts-Nevis joins Antigua-Barbuda in rejecting Illinois tax haven label

BASSETERRE, St Kitts (WINN) — Efforts by one American state to officially label St Kitts and Nevis a foreign tax haven are being strongly objected to by the federation’s foreign affairs minister, Mark Brantley, thus joining Antigua and Barbuda in a similar protest. A proposed House Bill 3419 in the… – Continue reading

Draft Bulgarian tax law reflects EU legislation on mandatory automatic exchange of tax information

At the end of March 2017, the Ministry of Finance called for public discussion on a draft bill (the “Bill”) amending the Bulgarian Tax and Social Insurance Procedural Code (the “Code”). The Bill seeks to improve administrative cooperation in the Bulgarian tax sector. The first set of amendments relates to… – Continue reading

Understanding the taxation of international and expatriate assignments

(Second of two parts) In last week’s article, we discussed how or why taxpayers working on international assignments have to consider the impact of different tax jurisdictions on their individual tax obligations. We also explained how most companies implement a tax equalization (TEQ) arrangement for the employees so that they… – Continue reading

Noonan: Too Early To Anticipate Tax Performance For 2017

Irish Finance Minister Michael Noonan has said that despite a dip in tax revenues for the first quarter of 2017, “it remains too early to discern any firm trends.” Noonan made the comment during an appearance before parliament’s Budget Oversight Committee. He said that his Department has increased its GDP… – Continue reading

Tax amnesty plan premature, says Citi

MANILA, Philippines – Instead, the government should pursue the enactment of the proposed Comprehensive Tax Reform Program (CTRP) before pursuing a tax amnesty program, Citi economist Jun Trinidad said. He said fiscal priority remains the passage of the first component of the tax reform measure that includes income tax cut… – Continue reading

Australia Urged To Scrap GST On Digital Imports

An Australian taxpayer advocacy group has joined forces with a coalition of international taxpayer organizations and academics to condemn the Government’s plans to abolish the low-value goods and services tax threshold on imports. In separate submissions to the Senate inquiry into the proposes GST changes, the Australian Taxpayers Alliance and… – Continue reading

Cyprus: Abolition Of Profit Margins On Intra Group Loans – Upcoming Transfer Pricing Legislation – Transfer Pricing Studies Requirement

As a rule and according to Article 33 of the Cyprus Income Tax Law, which introduces the arm’s length principle (using wording similar to that of article 9 of the OECD Model Tax Convention), all transactions between companies, including loan agreements/transactions by Cyprus companies, must be undertaken at arm’s length… – Continue reading

Withholding tax on dividends – A bagful of uncertainties and complexities?

Muscat: One of the many changes that the Royal Decree 9 of 2017 (RD) has made in the Oman Income tax law is the introduction of withholding tax (WHT) on payment of ‘dividends on shares’ by Omani companies. This amendment requires Omani companies distributing dividends on shares to foreign persons… – Continue reading

Ukraine Sets Out Fiscal Plans In Talks With IMF

Ukraine has ruled out major tax reform, in consultations with the International Monetary Fund. The IMF noted that Ukraine has major substantial progress on improving its finances. The IMF said budget execution continues to be strong, over-performing relative to program targets. The 2016 budget deficit has been limited to 2.3… – Continue reading

Hong Kong signs agreements with Portugal and South Africa on automatic exchange of financial account information in tax matters

Hong Kong has signed agreements with Portugal and South Africa for conducting automatic exchange of financial account information in tax matters (AEOI), a Government spokesman said today (April 3). “We have been seeking to expand Hong Kong’s AEOI network with our tax treaty partners. The signing of agreements with Portugal… – Continue reading

Singapore, Ghana Sign New Double Tax Treaty

The DTA clarifies the taxing rights on all forms of income flows arising from cross-border business activities and seeks to ensure such income is not taxed twice. The agreement provides that withholding taxes on dividends, interest, and royalties will generally not exceed seven percent. Withholding taxes on service fees will… – Continue reading