Category: Statutory

Preferential multinational tax agreements under fire – European Parliament

A European Parliamentary debate this afternoon discussed measures that would lead to the curtailing of tax evasion and avoidance. A debate was sparked last year when it was revealed that Luxembourg had struck preferential multi-billion dollar tax deals with some of the world’s largest multinational corporations. This debate has been… – Continue reading

Four further double taxation agreements with Iceland, Cyprus, Estonia and Uzbekistan in force

Bern, 11.24.2015 – Four additional double taxation agreements (DTAs) have entered into force between Switzerland and Cyprus, Iceland, Estonia and Uzbekistan. They contain provisions on mutual assistance in accordance with the internationally applicable standard. At the same time they promote the development of bilateral economic relations. With Cyprus, Switzerland has… – Continue reading

Switzerland signs an agreement on the exchange of information on tax matters with Brazil

Bern, 24.11.2015 – On 23 November 2015, Switzerland and Brazil signed in Brasilia an agreement on the exchange of information on tax matters (“Tax Information Exchange Agreement” TIEA). The Agreement with Brazil is the tenth TIEA signed by Switzerland. The agreement deepens the bilateral relations between Switzerland and Brazil. Switzerland… – Continue reading

Indian infrastructure firms seek to diversify debt with masala bonds

The global rupee bonds would be used to refinance costly loans or raise capital for new projects with little currency risk Mumbai/Singapore: Some of India’s most indebted infrastructure and steel groups are considering so-called masala bonds to diversify their funding options as local banks tighten lending, investment banking sources with… – Continue reading

The offshore financial industry shows resilience as demand stays robust

The offshore industry is poised for growth, as the industry insiders see the demand for offshore financial and corporate services likely to increase in the coming years, according to an industry survey conducted by OIL, a corporate service provider specializing in international incorporations. The industry has been battling negative perceptions… – Continue reading

The offshore financial industry shows resilience as demand stays robust

The offshore industry is poised for growth, as the industry insiders see the demand for offshore financial and corporate services likely to increase in the coming years, according to an industry survey conducted by OIL, a corporate service provider specializing in international incorporations. The industry has been battling negative perceptions… – Continue reading

The English version of the DTA as concluded between Malta and the Kingdom of The Netherlands in respect of Curaçao has been published

Earlier we already reported that Malta and Curaçao had signed a DTA. When we wrote our earlier article we had not yet been able to locate the text of the DTA. Now however, the English version of the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal… – Continue reading

Turkey launches golden visa residency scheme

Turkish Economy Minister Nihat Zeybekci says the country is set to follow in the footsteps of Spain, Portugal and Cyprus and launch its own Golden Visa scheme to grant citizenship to those foreigners who invest from €500,000-€1m in property, reports Property Showrooms. Leading Istanbul agent, Universal21, says the move could… – Continue reading

Taxation of dividends payable by a South African company to a Cypriot shareholder

SARS may now impose a dividends tax on dividends paid by a South African company to a Cypriot shareholder as provided for in the Protocol to the current agreement for the avoidance of double taxation between South Africa and Cyprus. In terms of the current agreement for the avoidance of… – Continue reading

DDM Holding AG: Swiss withholding tax applies in respect of interest payments to holders of the DDM Senior Secured Notes

Following a ruling by the Swiss Federal Tax Administration, payments of interest under the DDM Treasury SEK 300 million Senior Secured Notes with ISIN SE0005280831 (the “Notes”) are subject to Swiss withholding tax since the refinancing executed in June 2015. On 23 June 2015 certain amendments to the documentation in… – Continue reading

Better global rankings underline India’s potential

The World Bank has placed India twelve notches higher than last year in its Ease of Doing Business rankings for 2016. This comes close on the heels of the country’s sixteen place leap on the World Economic Forum’s Global Competitiveness index. These rankings underline the impact of the recent spate… – Continue reading

Why incorporate a startup in the British Virgin Islands?

As the founder of a startup company, one of the first questions you need to consider is “where should I incorporate my company?” Investors are drawn to the British Virgin Islands (BVI) for its flexible and modern corporate regime, tax neutrality, respected legal system, political stability and effective regulatory framework…. – Continue reading

Sinarmas Land eyes Reit to unlock value of Indonesian investments

SINGAPORE-listed Sinarmas Land is looking to unlock the value of its investment properties in Indonesia by spinning them into a real estate investment trust (Reit) but has not decided on whether to list in Singapore or Jakarta, with tax benefits on offer likely to be a key determinant. “The unlocking… – Continue reading

PwC Makes UK Autumn Statement Predictions

Professional services firm PwC has predicted that UK Chancellor George Osborne will introduce an “apprenticeship levy” and seek to lessen the impact of tax credit cuts when he delivers his Autumn Statement on November 25. In his Summer Budget, Osborne pledged that the Government would “introduce an apprenticeship levy on… – Continue reading

LUXEMBOURG: STATUS OF RATIFICATION OF PROTOCOL WITH FRANCE

A pending Protocol, that would amend the income tax treaty between Luxembourg and France, may not be effective until 2017. RATIFICATION PENDING The Luxembourg Parliament passed a bill to ratify the fourth Protocol to the income tax treaty (1958) between Luxembourg and France. However, it currently appears that the ratification… – Continue reading

New PE Language for BEPS Scales Back Earlier Drafts

Through tweaks to the Model Tax Convention, the OECD believes its work on profit shifting will stem elaborate structures, such as commissionaire arrangements, used by large multinationals to avoid the creation of a permanent establishment. The Organization for Economic Cooperation and Development, however, responded to concerns from taxpayers by narrowing… – Continue reading

Praise for Gibraltar government from Washington D.C.

DESPITE repeated allegations from the Spanish government that Gibraltar is a tax haven, news is regularly received that suggests this is far from the case, and that the government has been doing all that it can to ensure that it complies as fully as possible with international standards, whilst generating… – Continue reading

FATCA – correlation of the global economy with the US economy

Already from December 1, 2015 come into force provisions requiring all financial institutions calling their clients to make statements about their residence tax (FATCA – Foreign Account Tax Compliance Act). It is the first significant action since records to OPF. FATCA imposes on foreign institutions, including the Polish reporting obligations… – Continue reading

Tax of billions evaded, black money whitened every year

ISLAMABAD: In a major scam tax evasion of hundreds of billions of rupees and whitening of black money worth trillions of rupees take place every year with the government authorities facilitating the extremely undervalued sales and purchases of thousands of residential and commercial properties throughout the country every day. While… – Continue reading

Audits: Vanguard income taxes ‘deficient’ for 2010-14

Mutual-fund giant Vanguard Group underpaid taxes on its income in Texas for 2010-14, according to records of the Texas Comptroller of Public Accounts. State-sponsored audits found payment “deficiency” for all four years in Vanguard’s payments of the state’s corporate franchise tax, which charged companies 1 percent percent of a company’s… – Continue reading

Pakistan, Central Asia in talks to set up big, new economic zone

Nawaz Sharif has turned his full attention for close relations with Central Asian states since the five of them broke away from Russia 23 years ago. Fast track negotiations between Central Asian and Pakistani leaderships are slated to turn their countries into a big, new economic zone. Their desire and… – Continue reading

Insider blows the whistle on multi-million pound tax avoidance ‘factory’

Failed tax avoidance business Welbeck hired young actors to push schemes onto City big earners, and reaped millions in commissions that fuelled lifestyles of fast cars and exotic holidays, according to a whistleblower who worked at the firm. Welbeck Solutions sold pensions and financial products, but it specialised in tax… – Continue reading

Tax transparency: full list of exempt companies revealed as Senate battle looms

Private companies that were given a historical exemption from filing annual financial reports are run by a who’s who of corporate Australia, including Malcolm Turnbull Private companies associated with Australia’s business elite, including prime minister Malcolm Turnbull, are on a list of entities not required to publish tax information under… – Continue reading

Make note of new disclosure requirements

Towards compliance with tax information sharing laws put in place in recent times, all financial intermediaries are mandated to seek information from account holders. They are also obliged to share information of your account with relevant authorities. SEBI too has issued guidelines on identification of beneficial ownership and mandated all… – Continue reading

KPMG REPORT: INITIAL IMPRESSIONS OF NOTICE 2015-79 ON INVERSIONS

Notice 2015-79—released November 19, 2015, by the Treasury Department and IRS—announces their intention to issue regulations relating to inversion transactions and post-inversion restructuring transactions. Notice 2015-79 provides for rules that: Limit the ability of domestic companies to effect an inversion Limit the advantages of certain post-inversion restructuring transactions Clarify certain… – Continue reading

Ethiopia: Unmet Demands of the G20

The creation of the Group of Twenty (G20) was believed to serve as a remedy to the harsh realities of the world today. The initial formation of the Group of Seven G7 could do little to avert pertinent challenges both the developing and the developed nations face frequently. So a… – Continue reading

Osborne’s struggle to balance the books: Will the Chancellor target capital gains tax in the Autumn Statement?

The Chancellor could target capital gains tax for extra revenue when he delivers his Autumn Statement next week as gains from investors and landlords hit their highest on record in the past financial year, accountants suggest. George Osborne, who will unveil his spending plans for Britain next Wednesday, is under… – Continue reading

Welbeck Solutions: Whistleblower exposes secretive city firm at the heart of vast tax avoidance operation

Company used actresses including former Alan Partridge star to bombard financial sector workers with cold calls The grey Basinghall Street office building, in the heart of London’s City financial district, gives few clues about the frenzy of activity that was going on inside. But for years, this was the home… – Continue reading

More Banks Spill Tax Evasion Secrets To Avoid Criminal Charges, Account Holders Beware

Lately, the IRS is warning offshore account holders to disclose before it’s too late. Under FATCA, banks everywhere want to know if you are compliant with the IRS. And the cost of compliance for many people is growing. The IRS updated its list of foreign banks where accounts trigger a… – Continue reading

Investors heading abroad for growth

Wrap platforms are increasingly evolving to meet the needs of investors looking offshore for growth, with the addition of managed funds, ETFs and SMAs, Cameron Garrett writes. Traditionally, the investment portfolios of Australians have been heavily weighted towards investing in Australian equities. This is an interesting statistic, especially as the… – Continue reading

INDONESIA: AEOI GUIDANCE, PROCEDURES FOR EXCHANGE OF TAX INFORMATION

The Ministry of Finance issued a regulation with guidance concerning the procedures for the exchange of financial information with other jurisdictions and countries. The “automatic exchange of information” (AEOI) process will allow for the exchange of data to verify and confirm compliance with tax obligations, including information from financial institutions…. – Continue reading

Stricter norms likely for transfer pricing

MUMBAI: India’s forthcoming budget may draw from some of the recommendations, especially in the realm of transfer pricing, contained in the final package of ‘Base Erosion and Profit Shifting’ (BEPS) measures, rolled out in October. Certain anti-abuse measures, such as thin capitalization, which for tax purposes disallows interest payments beyond… – Continue reading

Main provisions of Patent Box regime

Introduction Tax exemptions Eligibility Trademarks Calculating tax benefits Eligible costs Introduction At the end of 2014, the government presented the 2015 budget, which introduced a ‘Patent Box’ tax regime in line with similar schemes adopted in other European countries. It applies to corporate income tax and regional tax on productive… – Continue reading

Govt to implement United States FATC Act of 2010

THE United States of America (USA) wants all companies of US origin, individuals and body corporates that are resident in Swaziland to report their financial information in their home country, the USA. This development is a result of Swaziland government announcing that it will implement the United States Foreign Account… – Continue reading

EU Asks Germany To Amend IHT Rules

The European Commission has asked the German Government to amend its inheritance tax (IHT) law after finding that current rules discriminate against those who are not resident in Germany for tax purposes in certain situations. Under German IHT law, a special maintenance allowance is granted to surviving spouses or registered… – Continue reading

India to make efforts to check Mauritius DTAA misuse: Official

NEW DELHI: Concerned over the misuse of double taxation treaty with Mauritius by certain entities, the government is working on measures to check such practices, a Finance Ministry official said today. The government is in the process of revising the Double Taxation Avoidance Agreement (DTAA) with Mauritius. Tax treaty amendments,… – Continue reading

Russia and Singapore sign a Protocol revising their existing DTA

On November 17, 2015 Russia and Singapore signed a Protocol revising the existing Agreement between the Government of the Russian Federation and the Government of the Republic of Singapore for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (Hereafter: the Protocol)…. – Continue reading

Finance Malta wants faster innovation

Malta recently ranked first for efficiency in transposing directives into national legislation – but the chairman of Finance Malta, Kenneth Farrugia, believes that the pace of innovation needs to accelerate. “We claim to be nimble, but we need to push it much more. Innovation needs to be much faster paced…. – Continue reading

Oil And Gas Contractors Face Tax Hikes And Job Losses

British oil and gas contractors are amid a huge financial upheaval as a combination of job cuts and tax changes threaten their well-paid lifestyle. Thousands of contractors in the oil and gas industry worldwide have lost their jobs as companies look to protect their cash by sacking staff. The oil… – Continue reading

The Tories Have Taken More Cash From This Donor Embroiled In Money-Laundering Probes

David Cameron’s party reported fresh donations of £217,500 from Lycamobile weeks after BuzzFeed News revealed the telecoms giant’s “deeply suspicious” business practices. The Tories have accepted a fresh donation of £217,500 from Lycamobile in defiance of calls on the party to sever its ties with the controversial telecoms group. The… – Continue reading

European Commission requests Germany to bring its inheritance tax rules on special maintenance allowances in line with EU law

On November 19, 2015 the European Commission published the key decisions of its November infringement package. One of the key decision mentioned is the Commission’s decision to request Germany to bring its inheritance tax rules on special maintenance allowances in line with EU law. According to a press release issued… – Continue reading

European Commission requests the Netherlands to amend the Limitation on Benefits clause in the Dutch-Japanese Tax Treaty for the Avoidance of Double Taxation

On November 19, 2015 the European Commission published the key decisions of its November infringement package. One of the key decision mentioned is the Commission’s decision to request the Netherlands to amend the Limitation on Benefits (LOB) clause in the Dutch-Japanese Tax Treaty for the Avoidance of Double Taxation, which… – Continue reading

Time for US to lead on international tax policy

In recent days, the new Speaker of the House Paul Ryan (R-Wis.) signaled a priority for international tax reform in 2016. And if the newest recommendations from the Organization of Economic Cooperation and Development (OECD) are any indication of what’s ahead on the global tax scene for American businesses, it… – Continue reading