On December 15, 2017, the CRA released the final version of Information Circular IC 00-1R6 – Voluntary Disclosures Program (“VDP”) for income tax, after receiving and considering community input on the June 2017 draft version. This article summarizes the important differences between the draft and the final ICs and discusses… – Continue reading
The Executive Chairman, Federal Inland Revenue Service (FIRS), Mr. Babatunde Fowler has said federal government tax defaulters have until March 2018 to declare assets and income via the Voluntary Assets and Income declaration Scheme (VAIDS) or face the consequence. Fowler speaking at the media workshop programme in Lagos, recently, said… – Continue reading
Australian tax rules relating to cryptoassets remain in their infancy, comprising largely of antiquated rules for fiat currency transactions, with impractical attempts at guidance from revenue authorities. This practical guide summarises the Australian tax issues for some typical cryptoasset transactions. In this innovative sector, no two transactions are the same…. – Continue reading
The Lagos State Internal Revenue Service ( LIRS ) on Thursday shut 11 hotels, restaurants and event centres over alleged failures to remit their taxes under the Hotel Occupancy and Restaurant Consumption Laws of Lagos State 2009. Mr Seyi Alade, Director, Legal Services of the LIRS, said this after a… – Continue reading
The International Centre for Tax and Development has released a working paper on how to best support developing countries in the area of taxation. The paper says that developing countries would particularly benefit from support in the implementation of two areas that were covered by the OECD’s base erosion and… – Continue reading
Summary: The Chancellor unexpectedly announced a U-turn to tax gains made by non-residents on UK commercial property with effect from April 2019. This will have a significant impact on overseas investors into UK real estate and creates additional uncertainty during an already volatile time as Brexit negotiations continue. Overseas investors… – Continue reading
In the aftermath of Satoshi Nakamoto’s groundbreaking paper in 2009, money began travelling via a new financial route – virtual currencies. The first Bitcoin exchange was established on February 6, 2010 where Bitcoin traded for the first time for 0.3 cents. Last June, the American Institute of Certified Public Accountants… – 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 Senate Finance Committee released its tax reform plan on November 9, presenting a draft bill with marked differences to that agreed by the House Ways and Means Committee on the same day. The proposal was drafted by Finance Committee Republicans under the leadership of Senate Finance Committee Chairman Orrin… – Continue reading
HYDERABAD: Income Tax sleuths on Wednesday conducted simultaneous searches in Hyderabad and Vijayawada on three top businessmen cum-realtors, who were allegedly evading tax, particularly in real estate transactions and unearthed documents pertaining to unaccounted investments running into hundreds of crores of rupees. These are the first big raids after shell… – Continue reading
French deputies have adopted at first reading the 2018 Finance Bill, which includes several of the Government’s key tax measures. The bill, adopted by the National Assembly on October 24, will reduce compulsory levies by EUR10.3bn (USD12.1bn) by the end of 2018. The bill includes the abolition of the wealth… – Continue reading
Removal of withholding tax on G-Sec income effectively frees foreign investors paying any taxes New tax law proposes to remove 10% withholding tax on G-Secs but makes such income liable for income tax up to 24% This likely to result in sizeable leakage of tax revenue to govt. as G-Secs… – Continue reading
Tax inversions by US multinationals attempting to shift profits into lower tax jurisdictions could cost the US up to $12bn (£7.4bn) in lost corporate tax revenues by 2027, according to figures released by the US Congressional Budget Office There were 11 major corporate inversions from 2014-2015, although two significant inversions… – Continue reading
In our last publication, we discussed the signing of the Ghana-Morocco Double Tax Agreement (“DTA”) and the provisions of the DTA in relation to the taxation of permanent establishments and business income. In the concluding part of the article, we will discuss the taxation of investment, employment and service incomes… – Continue reading
The OECD has taken issue with the Estonian Government’s plans to reduce the rate of tax on distributed dividends for established companies, warning that the measure could complicate the tax system and discriminate against small firms. Under recently enacted legislation, tax on distributed dividends will be reduced from 20 percent… – 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
Some double tax treaties are being amended by a multilateral instrument Establishing how a particular treaty is affected can be a complicated process The UK intends to publish amended DTTs and this will help, but the MLI has added an additional layer of complexity 18 Sep 2017 Speed Read LEGAL… – Continue reading
The governments of Japan and Russia signed a new convention on the elimination of double taxation on September 7. The convention replaces the 1986 agreement between Japan and the former Soviet Union. It lowers withholding tax rates on cross-border income from trade and investment – in most cases to zero… – Continue reading
The Panamanian Government with the aim of improving the competitiveness of the international services industry in Panama and, at the same time, comply with international standards for the effective exchange of information, initiated in 2009 a decisive agenda for the selection of countries with whom tax agreements were going to… – Continue reading
The UK tax authority, HM Revenue and Customs (HMRC), has warned taxpayers to avoid disguised remuneration schemes that attempt to recharacterize loan arrangements to avoid the 2019 loan charge on disguised remuneration. “HMRC is aware of schemes that claim to avoid the 2019 loan charge on disguised remuneration. These schemes… – Continue reading
I am a trustee of an offshore trust settled by a UK resident, non-UK domiciled settlor (with no UK origins) for the benefit of himself and his family. He previously opted to be taxed on the remittance basis. The trust holds only offshore investments. The settlor lent monies to the… – Continue reading
Contrary to calls from businesses from the regulation’s withdrawal, the Institute on Taxation and Economic Policy has called on the US Treasury to fully implement and strengthen its final Section 385 anti-earnings stripping debt-equity regulations, designed to reduce the benefits of corporate tax inversions. The final regulations, released in October… – Continue reading
The Swiss Federal Council has announced that an information exchange amendment to the double tax agreement with Belgium has entered into force. On August 7, the Council said the additional agreement to amend the DTA had entered into force on July 19. It contains an administrative assistance clause in accordance… – Continue reading
BEIRUT: The Association of Banks in Lebanon and other private sector leaders are weighing the few options open to them as recently approved new tax measures, poised to be implemented soon, threaten to have a detrimental effect on their businesses and the overall economy. The few available options include trying… – Continue reading
The change converts tax-deductible interest payments employed by the schemes into taxable stock dividends. The U.S. government on Friday gave companies an extra year to comply with an Obama-era regulation meant to crack down on corporations that try to minimize their U.S. tax bills by shifting profits abroad to countries… – 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
Obama-administration regulation drew criticism as overbroad Trump ordered review of tax rules that may pose undue burdens A federal rule aimed at limiting corporate “earnings stripping’’ for tax-avoidance purposes may pose an undue burden on taxpayers and may be changed or rescinded, according to a U.S. Internal Revenue Service notice…. – Continue reading
Mauritius has signed the Multilateral Convention to Implement Tax Treaty Related Measures to prevent Base Erosion and Profit Shifting (MLI). Once ratified, the MLI will affect as many as 23 tax treaties entered into by this island nation, which has been an important jurisdiction for routing investments into India. Interestingly,… – Continue reading
Ghana signed another Double Tax Agreement (DTA) with the Czech Republic on 11 April, 2017. Ghana already has DTAs in force with Denmark, the United Kingdom, Belgium, Italy, South Africa, Switzerland, Netherlands, France and Germany. DTAs with Mauritius, Singapore and the Czech Republic are in the process of being ratified… – Continue reading
A. Introduction In February 2017 Cyprus Tax Department has announced that the current practice regarding profit margins between related Company loans will be abolished by the 30th June 2017. The announcement indicates that the minimum acceptable margins will apply up to 30th June 2017, and as from 1st July 2017… – Continue reading
India has, for long, been always regarded as the one of the most aggressive transfer pricing jurisdictions. To mend this image and reduce litigation, the government introduced various measures like Advance Pricing Agreements (APA), the safe harbour regime, risk-based selection of transfer pricing audit cases etc. While most of these… – Continue reading
Chevron has decided to take its tax battles to the High Court of Australia after it was reported that the supermajor is in the crosshairs of the Australian Tax Office (ATO) for a disputed AU$1 billion outstanding tax bill. This comes after the Federal Court ruled in favor of the… – Continue reading
Apartment construction is booming as the wealthy rush to invest in rental housing as a way to reduce inheritance tax and banks hand out easy mortgages, but concerns are mounting that excessive supply paired with a shrinking population could soon lead to the bursting of the bubble. New starts on… – Continue reading
Norway’s Ministry of Finance has released a consultation on a proposal to further strengthen the nation’s restrictions on interest deductions within groups. The regime, introduced in 2014, is intended to prevent groups from establishing subsidiaries in lower tax territories from which to lend capital to companies in a higher tax… – Continue reading
European Union presidency holder Malta has launched a new attempt to salvage pending EU legislation designed to eliminate withholding taxes for cross-border interest and royalty payments in the EU single market. One of the key hurdles the Interest and Royalties Directive has faced in the Council of Economic and Financial… – Continue reading
Only a few days left for this financial year to end and tax filing deadline is striking the calendar. Indian Government has already taken many initiatives to simplify the tax filing process by introducing new ITR forms, online filing facility etc. Yet many taxpayers tend to make silly mistakes while… – Continue reading
(Second of two parts) In last week’s article, we discussed the revised procedure to avail of tax treaty benefits for dividend, interest, and royalty payments under Revenue Memorandum Order (RMO) No. 8-2017. Under the amended rules, a tax treaty relief application (TTRA) is no longer required and withholding agents can… – 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
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
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
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
Filing of your income tax return (ITR) is mandatory under the Income Tax Act, 1961 under certain circumstances. For instance, if someone’s income exceeds the maximum amount not chargeable to tax, one is required to file income tax return. Similarly, filing ITR is mandatory for ordinary residents having overseas assets… – 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
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
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
A new bill introduced this week by Rep. Mark Pocan (D-WI), the Tax Fairness and Transparency Act, would rip out the offshore corporate tax avoidance system by its roots. This legislation combines into a single, comprehensive bill elements of three pieces of legislation that Rep. Pocan has proposed in previous… – Continue reading
HMRC is to renew and extend the scope of the double taxation treaty passport (DTTP) scheme, which will now be available to all UK borrowers who are required to withhold income tax at the basic rate on certain loan interest payments to overseas lenders from 6 April 2017 The DTTP… – Continue reading
Chile is leading a regional push across Latin America to clamp down on tax avoidance and profit-shifting by multinational and local firms, with the country’s tax authority making companies with interests and assets one of its priorities for inspections this year. Outlining its tax enforcement plan for 2017 on March… – Continue reading
Venture capitalists, investors left unfazed Both President Trump and Capitol Hill Democrats head into negotiations over tax reform vowing to put the squeeze on hedge fund managers by closing the carried interest tax loophole — a point of agreement that held out promise for becoming a foundation for a once-in-a-generation… – Continue reading
The New Zealand Law Society says that following discussions with Inland Revenue and the New Zealand Bankers’ Association it has now reached an understanding with Inland Revenue about application of FATCA to lawyers’ trusts accounts. FATCA is the United States’ Foreign Account Tax Compliance Act. Its objective is to reduce… – Continue reading
