Category: Statutory

Ukraine and Luxembourg sign a Protocol modifying their double tax treaty

On 30 September 2016 Ukraine signed a protocol (the “Protocol”) modifying the not-yet-in-force Convention between the Government of Ukraine and the Government of the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital (the “Convention”)…. – Continue reading

There is one way to put a stop to BHP’s tax avoidance

One of the most common ways multinationals take advantage of current laws to reduce their tax bill is through what’s known as transfer pricing. Former Treasurer Wayne Swan last week accused mining giant BHP of “aggressive transfer pricing,” denying the Australian government A$5.7 billion in tax revenue. For most companies,… – Continue reading

IRS, Mexico Reach Tax Deal For Contract Manufacturers

U.S. companies operating contract manufacturers in Mexico can avoid double taxation between the United States and Mexico under a deal struck between their respective tax authorities and unveiled Friday by the IRS. So-called maquiladoras can avoid double taxation through a unilateral advance pricing agreement signed with the Servicio de Administración… – Continue reading

100 Financial Centres Start Swapping Tax Data

Expats who have money or assets outside Britain can expect to start receiving letters from the UK tax man soon. Hundreds of thousands of letters are being drafted for expats who have returned to the country after spells abroad and for expats considered UK taxpayers who have had overseas assignments…. – Continue reading

FinMin to issue rules for norms under BEPS

Applicable to transfer pricing for MNCs whose consolidated annual revenue is over Rs 5,000 crore The finance ministry will issue rules and guidance to address some concerns and ambiguity over mandatory reporting norms with respect to transfer pricing for multinational companies whose consolidated annual revenue is over Rs 5,000 crore…. – Continue reading

Georgia-Kyrgyzstan sign agreement on double taxation

Georgia and Kyrgyzstan are increasing economic cooperation by signing an agreement on avoidance of double taxation. The deal was signed today in Georgia’s capital Tbilisi and will prevent people or businesses working between the two countries from evading income and capital taxes. Double taxation is the levying of tax by… – Continue reading

BHP Billiton has evaded taxes for more than a decade, says Wayne Swan

Former Labor treasurer Wayne Swan has accused one of Australia’s biggest companies of evading taxes for more than a decade, and for lying to the former Labor government during the height of the mining tax debate. Swan used parliamentary privilege on Wednesday to claim BHP Billiton had been “gaming the… – Continue reading

Singapore Issues Guidance On CbC Reporting

The Inland Revenue Authority of Singapore (IRAS) has published detailed guidance on the implementation of a new country-by-country (CbC) reporting requirement in the territory. The guidance, released on October 10, sets out which entities are obliged to report and how to complete and submit a CbC report to IRAS. For… – Continue reading

Tax haven: The devil is always in the detail

In July 2016 the then Indonesian finance minister Bambang Brodjonegoro, in conjunction with the launch of the widely publicized tax amnesty program (TAP) for undeclared offshore assets, also laid out less publicized plans for a new tax haven on the islands of Bintan and Rempang (Proposed Tax Haven). A key… – Continue reading

Foreigners’ databank soon to track tax evasion

Foreigners will come under a coordinated databank just after arrival so they could be traced until checkout and tax evasion by any of them prevented, officials said. They said a databank having networking with relevant nodal points would be developed under the National Board of Revenue (NBR). The NBR recently… – Continue reading

Facebook pays just £4million in tax while lavishing British staff with £165MILLION

Accounts show each of the firm’s 682 workers took home average of £242,000 each in 2015 Facebook lavished £165million on its UK staff last year, while handing the taxpayer just £4million. Accounts show each of the firm’s 682 workers took home average of £242,000 each in 2015. The bumper payout… – Continue reading

Singapore wants to delay revision of tax treaty with India

Singapore is seeking more time to revise the two-decade old tax treaty with India, saying its investors need more time to shift to source-based taxation. India has, however, rejected any deferment in the revision of the treaty that will help prevent Singapore, which is the top source of FDI into… – Continue reading

Hong Kong Committed To Compliant International Tax Regime

During a recent speech, the Secretary for Financial Services and the Treasury, K C Chan, reiterated Hong Kong’s commitment to meeting the international standards on tax transparency, and to implementing the Organisation for Economic Co-operation and Development’s (OECD’s) base erosion and profits shifting (BEPS) package. In his speech on October… – Continue reading

EY Survey Reveals Increasing Tax Audit Presence Driven by BEPS

EY announced today the results of a new tax survey at its 35th Annual International Tax Conference, “Unlocking the future.” The survey revealed that, more than ever, companies are experiencing an increasing number of audits and more aggressive enforcement from tax authorities around the world. According to the survey, nearly… – Continue reading

Vietnam plans new transfer pricing rules to curb tax fraud

Various agencies are expected to work together to draft a decree and keep the practice in check. In a move that signals Vietnam’s apparent stronger stance against tax evasion, the Ministry of Finance has sought to work with other ministries and agencies to draft a new decree on transfer pricing… – Continue reading

Ethiopia introduces new transfer pricing directive

Ethiopia recently adopted new transfer pricing rules in the form of Directive 43/2015 (“the Directive”) issued by the Ministry of Finance and Economic Development. The Directive provides detailed guidance as to the application of Article 29 of the Income Tax Proclamation (ITP) 286/2002, which requires taxpayers to ensure transactions between… – Continue reading


In 2015, more than 73 percent of Fortune 500 companies maintained subsidiaries in offshore tax havens, according to “Offshore Shell Games,” released today by the U.S. PIRG Education Fund, Citizens for Tax Justice and the Institute on Taxation and Economic Policy. Collectively, multinationals reported booking $2.5 trillion offshore, with just… – Continue reading

Indonesia is finally cracking down on tax avoidance

The Indonesian government recently launched tax hunt on Google Indonesia. If Google were indeed guilty of tax avoidance, it would have to pay a huge price for its actions. But Google is not alone in avoiding paying tax to Indonesian government. Indonesians and Indonesian companies are squirrelling their wealths in… – Continue reading

Taxation on corporate debt rules out for consultation

Revised rules affecting the way corporate debt and derivative contracts are taxed have now been drafted and are out for a brief consultation, in a bid to avoid double taxation and curb potential abuse HMRC has issued draft legislation for consultation following amendments to the Change of Accounting Practice Regulations… – Continue reading

Here’s the latest on the non-dom reform

What will happen to clean capital, tainted trusts and enveloped assets under the new tax regime? John Goodchild reports. The UK government has at last disclosed further details of the tax changes for UK resident non-domiciled individuals first announced in July 2015. The government remains determined to implement all the… – Continue reading

VP Kalla Reminds Tax Dodgers That They Can’t Escape Automatic Exchange of Information

Jakarta. Tax dodgers and taxpayers who have underreported their wealth in the past and who now seek to rectify the situation should join the tax amnesty program as they will not be able to hide once a system for the automatic exchange of financial information between states comes into effect… – Continue reading

US gives Trinidad new deadline for approving FATCA legislation

The United States is recommending that Trinidad and Tobago pass the Foreign Account Tax Compliance ACT (FATCA) by February next year, providing a five-month breathing space for the country. US Ambassador John Estrada in a brief statement issued from Washington said he wanted to provide an update on FATCA after… – Continue reading

Tax havens are under attack

Ireland, accused of being a tax haven for multinationals such as Apple to pay nearly zero tax on the bulk of its profits earned outside the United States, finds itself with a new adversary in the global fight against unfair tax practices — Brazil. As of October 1, Brazil will… – Continue reading

UK aid programme “failing to tackle tax avoidance and evasion”

A report by the Independent Commission for Aid Impact (ICAI) has criticised the Department for International Development’s (DfiD) approach to tackling tax avoidance and its alleged failure to achieve value for money on HMRC collaboration DfiD has failed in its efforts to fully include developing countries so that they benefit… – Continue reading

Zimbabwe scraps double taxation with China to boost cooperation

The Zimbabwean government enacted a law last week to remove double taxation for individuals and firms doing business between Zimbabwe and China to boost economic cooperation between the two nations. Under the Statutory Instrument, investors in any of the two states would only be taxed in their country of operation… – Continue reading

Canadians in Panama Papers shouldn’t expect a tax deal, CRA says

More than 2,000 files under review, 85 taxpayers under audit National Revenue Minister Diane Lebouthillier said in a statement Monday that a few thousand files are now being pursued by the tax agency after it sifted through the Panama Papers. Canadians implicated in the Panama Papers shouldn’t expect any leniency… – Continue reading

Base erosion and profit shifting protocol: Small firms may get relief

The threshold could be R5,400 crore of annual consolidated group revenue for the purpose of country-by-country reporting Not more than 120 India-headquartered firms — along with their global associates — are likely to be impacted by the base erosion and profit shifting (BEPS) protocol once it is implemented, as the… – Continue reading

Democrats Introduce Corporate Tax Transparency Bill in Congress

House Democrats have introduced legislation that would require multinational corporations to disclose more information about the taxes they pay in other countries. The bill, known as the Corporate Transparency and Accountability Act, aims to shine more light on corporate tax avoidance strategies, requiring the disclosure of country-by-country and pre-tax profit… – Continue reading

Bahamas files: New leak exposes offshore ‘tax haven’ dealings of politicians, companies

Five months after the Panama Papers exposed the offshore dealings of government leaders and influential people, a new leak of 1.3 million files has revealed the names of individuals associated with companies registered in the Bahamas, a notorious tax haven. The files – received by the German newspaper Süddeutsche Zeitung… – Continue reading

Ecuador Fights for Global Rules to Clamp Down on Tax Evasion

Ecuador’s foreign minister, leading economists and campaigners call for a new U.N. body to root out tax evaders and crack down on offshore havens. Ecuador ramped up its fight against tax dodging Wednesday as the South American country proposed a plan on the sidelines of the U.N. General Assembly in… – Continue reading

Indonesia launches tax hunt on Google

The government has stepped up efforts to collect what it says are millions of dollars of outstanding tax liabilities from Singapore-based Google Asia Pacific Pte. Ltd., which has allegedly booked hefty revenue from Indonesian advertisers without paying proper taxes. The message to the tech giant is clear: we want a… – Continue reading

Private sector groups urge passage of FATCA legislation

Seven private sector organisations Tuesday called on the Trinidad and Tobago government and opposition to put aside their differences and ensure the country meets the September 30 deadline for the Foreign Account Tax Compliance Act (FATCA). They also warned that failure to do so could result in ”serious negative consequences”… – Continue reading

KPMG wants better tax systems

Auditing and tax advisory firm KPMG is calling for establishment of the T&T Revenue Authority (TTRA) so there can be a structured way of collecting taxes. “The current main tax authority does not appear to have structured means, if any, of treating with businesses that conceal transaction to avoid tax… – Continue reading

U.K. Considers Tough Regs on ‘Tax Avoidance Enablers’

Tax evasion is a serious crime that can result in hefty fines and even prison time for the taxpayer if convicted. In an effort to curb the incidence of tax evasion in the U.K., Treasury officials are considering new regulations that would penalize accountants, financial advisors and other promoters and… – Continue reading

China Introduces Sweeping New Transfer Pricing Rules

China’s State Administration of Taxation (SAT) issued the Announcement on the Administration of Related-party Transactions and Contemporaneous Documentation (SAT Announcement [2016] No. 42), which introduces a three-tiered documentation framework that will replace its current transfer pricing documentation rules. The June 29 announcement followed the publication of the opinion-seeking draft by… – Continue reading

Pakistan can access 15 years data of offshore accounts

The Federal Board of Revenue (FBR) will now be able to obtain the data of offshore bank accounts of Pakistani nationals for the last 15 years under the international tax treaty that it signed with the Organization for Economic Cooperation and Development (OECD), officials said on Saturday. “The signatories of… – Continue reading

Singapore and the UK sign agreement to exchange financial account information

Singapore’s tax authority has signed another agreement to fight tax evasion. The Inland Revenue Authority of Singapore (IRAS) and the British tax authority, Her Majesty’s Revenue and Customs (HMRC) have agreed to share financial account information. In a statement from IRAS today (September 16), it said that the agreement is… – Continue reading

Wales to switch to Land Transaction Tax

Wales is to replace stamp duty with a land transaction tax as it moves towards devolved tax collection. The new tax on land transactions will be introduced from April 2018 alongside measures to tackle devolved tax avoidance, the Welsh government said. Land transaction tax is paid on the purchase or… – Continue reading

Mauritius seeks India’s help, post tax treaty revision

Mauritius, the island nation that accounts for the second-largest FDI, has sought a line of credit and more investments from India as it gets ready for implementation of the revised tax treaty from April 2017. Mauritian Minister of Finance and Economic Development Pravind Kumar Jugnauth yesterday met Finance Minister Arun Jaitley… – Continue reading

Australia in talks with Israel for tax treaty, says Treasurer Scott Morrison

The Turnbull government will introduce a tax treaty between Australia and Israel to improve business relations between the two countries. The treaty is linked to the government’s plan to boost innovation in Australia as well as its push to further trade between the two countries as Israel’s technology sector booms…. – Continue reading

ATO warns accounting firms on tax avoidance

Back in July, ABC’s The Business and Michael West featured an extraordinary raft of allegations from a 32-year veteran industry insider turned whistleblower, George Rozvany, who claimed that multinational tax avoidance was “out of control” and cost the Budget up to $50 billion dollars a year in lost revenue. Rozvany… – Continue reading

Apple May Face Double Tax on Profits If France Adds to Tab

Apple Inc. may face double taxation on some of its profits if the European Commission’s Aug. 30 ruling inspires France to slap its own tax adjustment on the company, practitioners said. Apple could even face “triple taxation” if it repatriates profits from the European Union to the U.S., Laurent Leclercq,… – Continue reading

India to get tax, banking related info from Seychelles

NEW DELHI: Aiming to curb tax evasion and avoidance, India has operationalised the Tax Information Exchange Agreement (TIEA) with Seychelles, one of the major sources of foreign investment into the country. The agreement will enable the authorities of both nations to provide assistance through exchange of tax and banking information,… – Continue reading

U.S. Citizens Retiring Abroad: “Tax Trigger” Situations and Related Disclosure Forms

The following is a bolded checklist of important situations that may “trigger” a tax review by a skilled United States tax professional. Many of these situations also require a simultaneous review by a foreign tax professional. It is generally best practice for these tax professionals to work together to minimize… – Continue reading

Pakistan’s taxation crisis

Whether they indulged in legal tax avoidance or evaded taxes under the counter, leaked documents of a Panamanian firm revealed quite a lot in April about a number of Pakistani politicians and businessmen. Tax evasion has of late become synonymous with Pakistan because of its failure to overcome its taxation… – Continue reading

Tax Havens Impact Canadians Too

Tax havens have become increasingly formidable players in the global economy. With increased globalization and financialization of the global economy, tax havens have become important players in the world economy. According to a report by Tax Justice Network, $21 to $32 trillion is stashed offshore. According to the World Bank, the GDP… – Continue reading

New Report Finds Corporate Offshore Tax Avoidance ‎a Growing Problem

According to a new report, secretive offshore tax avoidance practices are on the rise among multinational businesses. The report, released from the Financial Accountability and Corporate Transparency Coalition (FACT), finds that these practices put investors at risk because they are caught off guard when governments act to collect the lost… – Continue reading