The Italian Supreme Court, in a decision released 10 July, has addressed whether a sub-holding company was beneficial owner of interest payments for withholding tax purposes, applying the European Court of Justice’s holdings in the well-known Danish cases. ... - Continue reading
Bermuda is a self-governing overseas territory of the United Kingdom. It has a population of over 60,000 people on a land mass of just 21 square miles. The island group is located in the Atlantic Ocean, approximately 760 miles due east of Cape Hatteras, North Carolina. Surrounded by coral reefs and the Gulf Stream, Bermuda remains a popular destination for tourists but its infrastructure, flexible and innovative corporate structures and strong regulatory environment have made it a leading offshore jurisdiction for company incorporations, including for a number of companies listed on the main New York and Hong Kong stock exchanges ... - Continue reading
The recurring inability of government to achieve its projected non-oil revenues over the years points to the need for urgent structural reforms, a report by Guaranty Trust Bank Plc (GTBank) has stated. The bank stated this in its 2020 macroeconomic and banking sector outlook, obtained yesterday. It stressed the need… – Continue reading
The U.S. government ended fiscal year 2019 with the largest budget deficit in seven years as gains in tax receipts were offset by higher spending and growing debt service payments, the Treasury Department said on Friday. It is the first time since the early 1980s that the budget gap has… – Continue reading
The US IRS on October 11 released IRS guidance addressing the expiration of debt-equity documentation temporary regulations under code Section 385. ... - Continue reading
A gold trader has been acquitted by the Court of Tax Appeals in the P110-million tax evasion case for the failure of the Bureau of Internal Revenue (BIR) to prove his guilt beyond reasonable doubt.n a 56-page decision, the CTA’s Second Decision said the BIR was not able to present… – Continue reading
ISLAMABAD: The Economic Coordination Committee (ECC) of the cabinet on Wednesday approved a new tax regime for non-resident companies to attract investment into the local debt market, while it also directed officials to check wheat price hike in Karachi and other parts of the country. The ECC approved the tax… – Continue reading
The Australian Tax Office on 28 August, released its awaited draft guidance contained in Practical Compliance Guideline 2019/D3, on applying the arm’s length debt test contained in Division 820 of the Income Tax Assessment Act 1997, Australia’s thin capitalization statutory provisions. ... - Continue reading
Tax authority of Australia takes measures on tax issues ... - Continue reading
The Bureau of Internal Revenue filed Thursday separate criminal cases against 15 business taxpayers in Metro Manila for alleged refusal to pay tax debts totaling to more than P493 million. This brought to 482 the number of tax evasion charges lodged by the bureau under its Run-After-Tax-Evaders (RATE) program under… – Continue reading
BERLIN, May 9 (Xinhua) — According to current tax estimates, the German federal, state and local governments will have 124.3 billion euros (139.5 billion U.S. dollars) less to spend by 2023 than previously predicted, the Federal Ministry of Finance announced on Thursday. According to the German finance ministry, expectations about… – Continue reading
JAKARTA, NNC – The issue of state debt comes into spotlight of many parties. Although the swelling of debt is not only happening in Joko Widodo-Jusuf Kalla (Jokowi-JK) government alone, Finance Minister Sri Mulyani Indrawati again explains why the government as if hooked to loan. Sri Mulyani said if asked… – Continue reading
The Australian Tax Office has updated and added to its list of the guidance on international tax matters it intends to release this year. This month, the ATO intends to release a guide on corporate residency – central management and control in Australia [reference code 3838], to provide the ATO’s… – Continue reading
WARSAW (Reuters) – Poland will continue fighting tax evasion, allowing the government to keep public debt in check and finance its public spending agenda, Prime Minister-designate Mateusz Morawiecki said on Friday. He also told the Catholic Trwam television that value added tax revenue would most likely increase by 30 billion… – Continue reading
The Ministry of Economy and Finance (MEF) recently decided to shrink the tax burden for local microfinance institutions (MFIs) by lowering withholding tax on interest from loans acquired from abroad from 14 to 10 percent, a move that the government claims will keep the massive sector sustainable. This is the… – Continue reading
The Cayman Islands’ Premier, Alden McLaughlin, recently delivered the territory’s first two-year budget, which was notable for the absence of new borrowing or revenue-raising measures. McLaughlin said his administration will continue to pay down debt and deliver operational budget surpluses to fund capital investment plans and provide for contingency against… – Continue reading
LONDON — Brazil has provided investors with some of the best returns in the world this year but investment funds based in Ireland have been forced to adopt new strategies to get their money’s worth. Brazil blacklisted Ireland as a tax haven in September 2016 because of its low corporate… – Continue reading
(Bloomberg) — The Philippine government plans to target additional companies in its crackdown on tax evasion, said Finance Secretary Carlos Dominguez “We are on a roll, and this is part of the president’s program to make our country more law abiding,” Dominguez told Bloomberg Television’s Kathleen Hays in an interview… – Continue reading
…as tax dispute escalates Vodafone Ghana has filed a motion at the High Court of Justice, Commercial Division in Accra, against the Ghana Revenue Authority (GRA) disputing tax assessments of GH¢160 million, according to the Writ obtained by ghanabusinessnews.com. The GRA has asked Vodafone to pay 30 per cent of… – Continue reading
The Australian Tax Office is preparing to take several companies to court over abuse of thin capitalisation rules and will start a wave of audits of large multinationals with complex cross-border loans, as it continues to take a hardline approach in the wake of its win against Chevron. The ATO… – Continue reading
Amendments to Cook Islands tax laws are expected to be made next month. The changes would allow government to write-off some tax debts and forgive companies or individuals any undeclared income. Describing the changes as a tax amnesty the Finance minister Mark Browne said the government had made a commitment… – Continue reading
The European Court of Justice (ECJ) has ruled in favor of Austria in its dispute with Germany relating to the taxation of interest from profit-participation certificates received by an Austrian bank from a German bank. The case involved the interpretation and application of Article 11 of the 2000 double tax… – Continue reading
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
Tax residency certificate is required from the resident country tax authorities to claim applicable relief under the DTAA What is the purpose of a tax residency certificate? —Srivats Typically, source of income lies where the services are performed, or where the asset, from which the income arises, is located. Residential… – Continue reading
Banks are urged to stop lending to zombie companies and shell companies in CBRC guidelines highlighting 10 types of specific risk China’s banking regulator has urged commercial lenders to be more vigilant when dishing out loans after a spate of heavily indebted companies found themselves in hot water in the… – Continue reading
You might have thought you have enough on your plate getting to grips with anti-money laundering rules closely followed by FATCA – but it’s not over yet! Next off the block is the Automatic Exchange of Financial Account Information in Tax Matters (AEOI). The AEOI, which we first provided an… – Continue reading
[HONG KONG] More Chinese companies are looking to raise debt offshore after Beijing approved a new funding structure last month that makes it easier and cheaper to tap foreign lenders. China’s foreign exchange regulator in January let domestic companies bring home cash raised through offshore bonds secured by onshore guarantees,… – Continue reading
Italy must reform its banking system if it is to continue on a “weak” path to recovery, according to the Organisation for Economic Co-operation and Development (OECD). The country should be prepared to force holders of Italian bank debt to lose money rather than using public funds to bail them… – Continue reading
Following Moody’s Investors Service affirmation of Indonesia’s sovereign credit rating at Baa3 with a stable outlook in January 2016, there has been renewed interest in the international bond market for Indonesian credits. This bulletin seeks to summarise the regulatory changes in Indonesia over the last 24 months as well as… – Continue reading
Among other things, Union Budget 2017 will be remembered for two firsts – the introduction of secondary adjustment and thin capitalisation rules. Both are transfer pricing provisions which will have a far-reaching impact on corporates. Secondary Adjustment Since the concept of secondary adjustment is introduced for the first time in… – Continue reading
The OECD recently released a public discussion draft entitled the “BEPS Action 6 Discussion Draft on non-CIV examples” to clarify when investors like private equity funds, real estate funds and hedge funds should be entitled to tax treaty benefits. The release of the 2017 Discussion Draft is timely, given that… – Continue reading
KARACHI: Finance minister Ishaq Dar on Friday said that tax evaders will find no place to park their ill-gotten money, as Pakistan will begin automatic-exchange of information from next year. “As per international agreement with OECD (Organisation of Economic Cooperation and Development), Pakistan will start automatic exchange of information regarding… – Continue reading
Given the recent developments in the Indian economy, the upcoming Union Budget will certainly be critical and important in determining the future outlook of the economy. The financial services industry has been one of the key drivers of growth due to its strong cause and effect relationship with the economy…. – Continue reading
South Africa’s Ministry of Finance has published the 2016 Taxation Laws Amendment Bill (TLAB), which has received parliamentary approval and gives effect to the tax changes announced in the Budget in February this year, together with legislation confirming the final details of the Special Voluntary Disclosure Program (SVDP). With changes… – Continue reading
Ecuador signed an agreement with Italy to define the tax obligations of the citizens of the two countries, in order to avoid double taxation on income taxes and equity and prevent tax evasion, the Ecuadorian Foreign Ministry said. “This protocol modifies the agreement signed in Ecuador and Italy in 1984… – Continue reading
Small businesses in the U.S. have to shoulder, on average, an extra $5,128 in taxes to make up for the revenue lost due to the abuse of offshore tax havens by multinational corporations, according to a new report by U.S. Public Interest Research Group Education Fund. As a new administration… – Continue reading
Giants Real Madrid and Barcelona are among five La Liga clubs from whom the Spanish taxman is looking to recover €52 million (RM244 million), online newspaper El Confidencial claimed yesterday. Alongside Atletico Madrid, Sevilla and Valencia, the big two are accused of having avoided tax by paying player’s agents directly…. – Continue reading
While Trump wants to close loopholes, many of them stem from public policy concerns — not “special interests.” After a dramatic upset victory in one of the most bitterly contested presidential races in recent history, Donald Trump now has some serious work to do. His corporate tax policies—which are vital… – Continue reading
Vietnam’s Ministry of Finance released a draft circular on October 11th which, if passed, is set to become the largest change to transfer pricing (TP) regulation since the implementation of Circular 66/2010/TT-BTC in 2010 – which the draft updates. Touching on conditionality of TP exemption and thresholds for defining related… – Continue reading
Many kinds of U.S. multinational companies, including S-corporations, REITS, and financial services companies apparently dodged a bullet last month when the U.S. Treasury Dept. issued its final, substantially revised rules aimed at curtailing “earnings stripping.” The revised regulation represents an attempt by Treasury to help “narrow the rule and avoid… – Continue reading
After five years of negotiations, the European Commission has finally announced its plans to overhaul the way in which companies are taxed in the Single Market. The revised Common Consolidated Corporate Tax Base (CCCTB) is aimed at making it easier and cheaper to do business in the Single Market and… – Continue reading
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
In the wake of the recent disclosure of leaked Bahamas tax haven data, United Nations human rights experts today urged governments to work together on liquidating offshore tax avoidance and establishing tougher financial regulations. In a news release, Juan Pablo Bohoslavsky, the UN Independent Expert on foreign debt and human… – Continue reading
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
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
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
The Australian government shouldn’t rely on leaks like that of the Panama Papers to pick up on tax evasion, it should consider stronger action. The federal government showed some leadership earlier this year by announcing the establishment of a public register of beneficial ownership of companies, with the aim of… – Continue reading
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
The Vanuatu Government says it’s considering introducing an income tax to broaden its revenue base to help pay for vital public services. A government spokesperson John Sala says a government analysis has indicated a 17 percent income tax rate could apply to those earning more than 750 thousand vatu or… – Continue reading
Today, we see more enthusiasm for tax reform in Indonesia. Although opposed by some civil society groups, President Joko “Jokowi” Widodo’s administration continues to push its fiscal framework reform — which includes a tax amnesty and more incentives for taxpayers. Last year, the Finance Ministry issued a new tax holiday… – Continue reading
