Category: Statutory

Irish PM defends country’s corporation tax arrangements

Irish Prime Minister Enda Kenny has defended his country’s low rate of corporation tax, currently set at 6.25 per cent, and Dublin’s arrangements with global corporations which house subsidiaries in the country, reports Digital Look. Over the last decade, major corporations such as Google and Dell have created corporate subsidiaries… – Continue reading

The Ministry of Finance proposed to soften the terms of the Amnesty

Moscow. November 10. The Finance Ministry has prepared proposals aimed to strengthen Amnesty of capital, which is now actually fails, reports the newspaper “Kommersant”. The law on the voluntary Declaration by individuals of assets and accounts, is known as the law on the legalization or Amnesty of capital, earned from… – Continue reading

Still Broken: major new report on global corporate tax cheating

“In 2013 the OECD, supported by the G20, promised to bring an end to international corporate tax avoidance which costs countries around the world billions in tax revenues each year. However, with the recently announced actions against corporate tax dodging, G20 and OECD countries have failed to live up to… – Continue reading

Paradigm shift in tax landscape through BEPS must also engender tax certainty

A paradigm shift in the way business is conducted is taking place as new base erosion of profit shifting (BEPS) rules are aligned with tax systems, but more tax certainty and rules that suit specific African circumstances are needed, a Deloitte OECD Transfer Pricing Guidelines seminar heard on Wednesday, 04… – Continue reading

United States: Steps Foreign Persons Can Take To Avoid Unnecessary U.S. Estate Tax

A recent CNBC report suggests that several billion dollars of estate tax due from the estates of foreign decedents on investments in U.S. stock and real estate goes uncollected by the IRS every year. The report noted a large discrepancy between the amount of foreign investment in these assets and… – Continue reading

Crickhowell: Welsh town moves ‘offshore’ to avoid tax on local business

The Powys tax rebellion, led by traders including the town’s salmon smokery, local coffee shop, book shop, optician and bakery, could spread nationwide When independent traders in a small Welsh town discovered the loopholes used by multinational giants to avoid paying UK tax, they didn’t just get mad. Now local… – Continue reading

Why Australia’s landmark tax ruling against Chevron is a first battle in a global war on profit shifting

At a very high level, it’s a simple concept: a multinational borrows money from a related company overseas, and then uses the interest bill and the repayment methods to reduce tax exposure in Australia. If the loans – and the interest rates – are big enough, the tax savings can… – Continue reading

Bermuda: Day Of The Deed

Article by Patrick W Martin and Ashley Fife With a net worth of USD77.1 billion, Mexican telecoms businessman Carlos Slim Helú was ranked the second richest person in the world in a 2015 survey.1 At the end of 2014, 16 of Mexico’s citizens were on Forbes’ billionaires list.2 As for… – Continue reading

Implementation problems in connection with the FATCA Agreement

The BMF has application letter sent to the chief financial authorities of the countries associated with the between the Federal Republic of Germany and the United States of America concluded by 31.5.2013 FATCA Agreement. Background Background of extensive, comprehensive 71 pages, application letter from the Federal Ministry of Finance on… – Continue reading

Tax breaks must end, says economist

Economist and policy consultant, Avernash Persaud is urging government to remove concessions for foreign investors, a similar advice proffered by the International Monetary Fund (IMF). Persaud said government should instead focus its attention on infrastructure development. Persaud, who has assisted in policy development in countries like Singapore, said investors will… – Continue reading

Billionaire Dart Reinvents Himself as Cayman Islands Land Baron

Two decades after Ken Dart renounced his U.S. citizenship and took his tax attorney with him to the Caribbean, the billionaire bond investor and local kingpin is reinventing himself as the Cayman Islands’ biggest real estate owner. In a rare glimpse into Dart’s holdings, Mark VanDevelde, chief executive of the… – Continue reading

Former Manchester United and Arsenal stars ‘face ruin’ after failed investments reaching £100m

The company at the centre of the revelations denied any wrongdoing Some of the best-known names in British football face losing millions of pounds after being allegedly advised to invest in “risky” projects that have subsequently failed or were hit with tax bills. Rio Ferdinand and Andy Cole, both former… – Continue reading

Transfer pricing drains us of tax blood

Transfer pricing by multinationals has cost South Africa an estimated R250 billion over three years and, with it, lost tax revenue. This is according to Sunia Manik, group executive for the large business centre at the SA Revenue Service (Sars), adding that it was being done through “service payments” made… – Continue reading

The ‘end’ of tax evasion

The UK is one of several countries to introduce voluntary disclosure schemes. More people are coming forward to regularise their affairs as they realise there is nowhere left to hide in this new world of tax transparency. Tax authorities and financial institutions are gearing up for the new automatic exchange… – Continue reading

Full faith in India on tax treaty revision: Mauritius

NEW DELHI: Dismissing apprehensions of Mauritius being used to route black money as “misconception”, its Prime Minister Anerood Jugnauth has termed the issue as an aberration in the “very special” ties with India and hoped that revision of their tax treaty won’t harm its interests. Stating that Prime Minister Narendra… – Continue reading

Canada: ACB Adjustments For Foreign Affiliate Shares Held Through Partnerships

Recent CRA comments at the May 2014 IFA international tax seminar1 and a subsequently released CRA technical interpretation2 highlight anomalies in the application of subsections 92(4) and (5) of the Income Tax Act (Canada) (the “Act“).3 These provisions address the situation where shares of a foreign affiliate are held by… – Continue reading

“Cronies and cheating the taxpayer”: MP targets RBS bank tax avoiders in share sell off

Call to halt bank sale in favour of reform rejected by UK Government UK MINISTERS decided to “wash their hands” of a tax evasion scandal in a subsidiary of the government-owned Royal Bank of Scotland, according to damning testimony given by a former treasury official who is now a Labour… – Continue reading

Bleak growth exposes malaise of revenue shortfalls

First it was the scourge of public sector corruption, until now the mortifying spectacle of South Africa’s post-apartheid transition. Now, with the ground shifting beneath the world’s sclerotic economy – and the past few years have produced more tremors than ever in the 21 years of democracy – it’s a… – Continue reading

Schroder Real Estate taps into hunger for offshore investment

Plans to list its European REIT on the JSE. Feeding South Africans’ seeming insatiable desire for rand-hedge stocks, Schroder Real Estate is planning to launch a European Real Estate Investment Trust (REIT), which will have a primary listing on the London Stock Exchange with a secondary listing on the Johannesburg… – Continue reading

Marco Rubio’s Billionaire Backer Likes to Sue Poor Countries and Put Profits in Tax Havens

Paul Singer has a good track record as a money manager. In 1995, he bought $20 million worth of Peruvian debt at a discounted price of $11.4 million, then forced Peru’s government, through lawsuits, to eventually pay nearly five times his initial investment — some $58 million. In 2002 and… – Continue reading

Victims of conman Peter Foster hunt missing millions

Exclusive More than 100 victims of notorious conman Peter Foster have moved to freeze funds held in offshore tax havens after more than $10 million was siphoned from his online gambling company Sports Trading Club. Fairfax Media can reveal Foster and at least eight associates have been served with freezing… – Continue reading

Changes to the BVI Anti-Money Laundering Regime

The BVI has announced amendments to its Anti-Money Laundering (AML) regime in order to ensure continued compliance with developing international standards on transparency and AML regimes. Amendments to the legislation have recently been published (Code of Practice and Regulations) and the proposed changes are to take effect on 1 January… – Continue reading

BEPS and funds

On 5 October 2015 the OECD published the final package of recommendations to reform the international tax system – the “BEPS” Project. Base Erosion and Profit Shifting (BEPS) refers to tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations… – Continue reading

Canada: Income And Other Taxes

In Canada, taxes are levied at the federal, provincial and municipal levels of government. At the federal level, the government generates most of its revenue by way of income taxes and excise taxes imposed on the distribution and consumption of goods and services in Canada. The provinces and territories also… – Continue reading

Knowledge Development Box – to encourage more innovation

Since Minister Noonan announced in October 2014 that Ireland would introduce a “best-in-class” Knowledge Development Box (“KDB” ), there has been a lot of speculation about ‘how low would he go’. Budget 2016 announced that the rate of tax which will apply for income qualifying under the new KDB will… – Continue reading

‘SA is bleeding billions’

JOHANNESBURG – South African has lost R250 billion in the form of service payments over a three-year period, highlighting the significant risk base erosion and profit shifting (BEPS) is posing to the country’s tax base, a South African Revenue Service (Sars) official has said. Almost R80 billion of this were… – Continue reading

AUSTRALIA: ARE INVESTMENT ENTITIES EXCLUDED FROM “GROUP” FOR COUNTRY-BY-COUNTRY REPORTING?

A question being considered in Australia—concerning country-by-country (CbyC) reporting—is whether an investment entity is to be excluded from the “group” for CbyC reporting purposes. A preliminary position being advanced is when an entity is not required to prepare consolidated financial statements for financial reporting purposes, then it would be excluded… – Continue reading

UAE signs agreement on exchange of information for tax purposes with Norway

The visit aimed to explore ways of developing and promoting the technical partnership as well as exchanging experience on financial and economic affairs between the two parties. The UAE delegation started off with a visit to the Capital of Norway Oslo, during which the Ministry of Finance (MoF), signed an… – Continue reading

UK takes two-faced approach to tax, new report suggests

The UK government has a ‘Janus-faced’ approach to tax, a new report suggests: promising an increasingly intolerant approach to evasion and avoidance while being an aggressive participant in global tax competition and tolerating the UK tax havens which facilitate financial crime across the world. The report, Fifty Shades of Tax… – Continue reading

‘Patently False’: Bahamas Not Violating Tax Rules

A former finance minister yesterday slammed as “patently false” suggestions by a prominent tax advocacy group that the Bahamas is “disregarding the rules” and flouting global information exchange and transparency standards. James Smith, also an ex-Central Bank governor, hit out at the Tax Justice Network after its 2015 Financial Secrecy… – Continue reading

Cyprus – Switzerland: Tax Treaty Enters Into Force

TThe Income and Capital Tax Treaty between Cyprus and Switzerland entered into force on 15 October 2015. The provisions of the treaty will become effective on 1 January 2016. The treaty was signed on 25 July 2014. In accordance with the treaty, the following withholding taxes will apply: Dividends: 0%… – Continue reading

Canada: Canadian Challenge To FATCA

On August 4 and 5, 2015, the FC heard oral arguments in a lawsuit—commenced on August 11, 2014 by two Canada-US citizens—that challenges the law implementing the Canada- US intergovernmental agreement (IGA) relating to FATCA (Virginia Hillis et al. v. The Attorney General of Canada et al., court file no…. – Continue reading

No revisions in main provisions of DTAA with India: Mauritius PM

Prime Minister of Mauritius, Anerood Jugnauth, on Tuesday said there will be no revisions to the main provisions of its Double Tax Avoidance Agreement (DTAA) with India as both countries are happy with the existing provisions of the tax treaty. “This treaty between our two countries has been there for… – Continue reading

EY tax partner warns that foreigners keen to do business here are paying for new property rules requiring you to open a NZ bank account to get an IRD number

Frustrations are mounting, as foreigners keen to do business in New Zealand are getting tangled in red tape aimed at regulating overseas property speculators. EY tax partner, Aaron Quintal, warns the new laws requiring “offshore persons” to have a New Zealand bank account to get an IRD number, are causing… – Continue reading

Why Billions of Dollars in Estate Taxes Go Uncollected

They say the only certain things in life are death and taxes, but a large number of non-U.S. citizens may have found a way to avoid at least one of those. Under U.S. tax law, the estates of foreign holders of U.S. assets, such as stocks, real estate and valuables,… – Continue reading

NPS useful only if NRI settles in India after retirement

Non-resident Indians (NRIs) have one more investment option to choose from. The Reserve Bank of India (RBI) has allowed NRIs to invest in the National Pension System (NPS), under Foreign Exchange Management Act. NPS will allow NRIs to invest in a mix of equities and debt and save for their… – Continue reading

Irish-based Shire buys rival for €5.3bn

Pharmaceutical giant Shire, which is headquartered in Ireland for tax purposes, has agreed to buy US rare disease specialist Dyax Corp for about $5.9bn (€5.35bn), and potentially up to $6.5bn, while still pursuing a five- times larger unsolicited bid for biopharma firm Baxalta Inc. The Dyax deal, the latest in… – Continue reading

US Justice Department Announces Banque Bonhôte & Cie SA Reaches Resolution Under Swiss Bank Program

The Department of Justice announced today that Banque Bonhôte & Cie SA (Banque Bonhôte) has reached a resolution under the department’s Swiss Bank Program. The Swiss Bank Program, which was announced on Aug. 29, 2013, provides a path for Swiss banks to resolve potential criminal liabilities in the United States…. – Continue reading

Kenya: ‘Kenya Losing Billions to Tax Havens’

The government has been accused of opening a loophole that allows super rich individuals and multinational companies to avoid taxes. The Tax Justice Network (TJN), a lobby group, has sued the government over agreements, which it says are robbing Kenya of the ability to raise revenues domestically, driving the country… – Continue reading