Category: Activity

New FATCA / CRS guidance: clarifications to self-certification requirements

The Australian Taxation Office (ATO) has further updated its guidance material on the Australia-US FATCA Intergovernmental Agreement (IGA). This is especially important in relation to self-certification requirements. The ATO has followed the US interpretation that a FATCA self-certification must be obtained before a new individual account is opened. The OECD… – Continue reading

Isle of Man: Global Tax Investigations Conference – Isle of Man, September 2015

Following successful conferences in the Isle of Man in 2014 and in Gibraltar in March 2015, leading offshore law firm DQ Advocates and global law firm Latham & Watkins will be hosting their latest Global Tax Investigations Conference in the Isle of Man on 11 September 2015. The conference is… – Continue reading

Civil society groups in Kenya push for laws to criminalise tax evasion

NAIROBI: The civil society in Kenya wants Parliament to join them in the push to end tax evasion through enactment of laws that enhance compliance from international trade. This, they argue, will boost revenue collection by the State. They say tougher laws will criminalise tax avoidance and spell harsher penalties… – Continue reading

OECD releases three automatic information exchange reports

THE OECD has published three reports outlining the framework for the automatic exchange of financial information between governments as part of its efforts to curb tax avoidance and evasion. In October last year, the organisation announced the agreement to automatically share tax information on individuals by the year 2018, to… – Continue reading

Portugal – United States: FATCA Agreement Signed

On 6 August 2015, Portugal and the United States signed a Foreign Account Tax Compliance Act (FATCA) Agreement. FATCA seeks to obtain information on accounts held by U.S. taxpayers in other countries. It requires U.S. financial institutions to withhold a portion of certain payments made to Foreign Financial Institutions (FFIs)… – Continue reading

Businesses seek cross-border tax clarity, but would they really pay more?

Would businesses really be willing to pay more tax if they had more certainty on what is acceptable for cross-border tax planning? According to a recent Grant Thornton International Business Report, three quarters of business leaders would in fact be ready to pony up more taxes in exchange for greater… – Continue reading

Tax rate on intellectual property profits would be cut to approximately 10% and appreciated intellectual property could be repatriated free of current tax under bipartisan innovation box proposal

On July 29, 2015, Charles Boustany (R-LA) and Richard Neal (D-MA) released a bipartisan discussion draft of proposed Internal Revenue Code (the “Code”) amendments that would cut the United States income tax rate on corporate profits generated from patents and certain other intellectual property to approximately 10% (the “Tax Rate… – Continue reading

…but Larger Jurisdictions are Determined to Destroy Offshore Sector in Smaller Countries

While CIBC FirstCaribbean and Heritage Bank are working to formalize the sale of assets, another offshore institution operating from Belize is yet to secure a correspondent bank. As we’ve reported previously, Bank of America has severed ties with Atlantic International Bank Limited as part of an ongoing de-risking exercise. The… – Continue reading

Shell pumped $20 billion a year from motorists but paid no company tax

For the third year on the trot, Shell service stations generated billions of dollars and revenue but not a cent in company tax. In fact the owners of the sunny yellow servos reported tax benefits in all three years despite total sales which may be in excess of $60 billion…. – Continue reading

FinMin notifies rules on foreign account tax Act

India follows common approach for implementation of FATCA and CRS New Delhi, Aug 8: The Finance Ministry has come up with the rules for information reporting under the Foreign Account Tax Compliance Act (FATCA), spelling out the timelines and the entities have to comply with the new requirements. The new… – Continue reading

Tax Horror Defying Modi Causes AIG to Shun Cover for India Deals

Prime Minister Narendra Modi needs to offer much more than just his best intentions to clean up India’s whimsical tax regime to help convince insurers. Companies from Allianz SE to American International Group Inc. are avoiding offering tax-liability coverage in India’s cross-border mergers and acquisitions market because of a relatively… – Continue reading

OECD publishes a Common Reporting Standard (CRS) Implementation Handbook

On August 7, 2015 the OECD published a Common Reporting Standard Implementation Handbook (Hereafter: the Handbook). According to the introduction included in the Handbook, the purpose of the Handbook is to assist government officials in the implementation of the Standard for the Automatic Exchange of Financial Account Information in Tax… – Continue reading

Tax Court: Stock based Compensation Costs Need not be Included in International Cost-Sharing Arrangements

The Stunning Altera Case Employee stock options are an important part of compensation—both as income to the executives and as a deduction for the employer. But when stock options are used by multinational companies, the tax implications are complex and sometimes baffling. A new Tax Court case has just given… – Continue reading

TaxTalk Today- 7th August : PwC Australia

Australian Taxation Office New or updated materials on ATO website, including: Reminder: Taxable payments annual report due 28 August Remission of penalties: information about remission of penalties following a tax dispute In focus: Procurement hubs of Australian multinational enterprises: the ATO is reviewing arrangements involving offshore entities that are being used… – Continue reading

OECD likely to recommend fixed ratio cap on interest tax deductibility, says expert

The Organisation for Economic Co-Operation and Development (OECD) is likely to recommend that restrictions on interest deductibility should mainly involve a cap calculated as a percentage of EBITDA, an expert has said.07 Aug 2015 Corporate tax Tax International tax Energy Infrastructure However Heather Self of Pinsent Masons, the law firm… – Continue reading

Malta: Tax haven or frontier market?

In order to maintain a competitive edge, Malta offers wealthy individuals and corporations advantageous tax rates, using tax breaks to attract investment or hot money, which could originate from criminal activities Malta is this year expected to register the fastest growth rate in the EU, with property prices rising year… – Continue reading

Ghana: UK Partners With Ghana On Tax Transparency

The UK will help Ghana clamp down on tax avoidance and evasion by sharing expertise to improve their tax system. The UK will work with the Government of Ghana to tackle tax evasion so the country can raise revenues and build stronger public services, International Development Secretary Justine Greening and… – Continue reading

Cyprus: The New Double Taxation Agreement Between Cyprus And Georgia

On May 13, 2015, Cyprus and Georgia signed a new double taxation agreement (DTA). Unlike many former members of the USSR, Georgia did not adopt the 1982 Cyprus–USSR DTA when it became independent, and the new agreement is the first between the two countries. It will come into force once… – Continue reading

Ireland’s favourable tax base drives further pharmaceutical activity

Shire, the giant pharmaceutical company that relocated its head office from the UK to Ireland for tax reasons a number of years ago has surprised investors by launching a US$30bn hostile bid to acquire the American company, Baxalta, which is also involved in the manufacture of drugs to combat rare… – Continue reading

Double taxation pact reflects growing importance of Oman: Swiss envoy

Muscat – H E Christian Winter, Switzerland’s Ambassador to Oman has said that the recently signed Double Taxation Agreement (DTA) between his country and the sultanate reflects the broader ties Switzerland seeks with GCC. “The conclusion of the agreement takes into account the growing economic and political importance of the… – Continue reading

EY’s On the Beam: Issue 5

Since 2013, investment institutions have started to increase their investments in private healthcare institutions in mainland China. Though there hasn’t been a real local healthcare group, the modes of investment have become diversified, including the acquisition of healthcare institutions, the establishment of new healthcare institutions and the transformation of public… – Continue reading

ZETI HATCHET JOB SPLASHED ONLINE: Jho Low accused of ‘PROXY WAR’ to defend ROSMAH & himself

KUALA LUMPUR – As speculation intensifies that Malaysian Prime Minister Najib Razak is on the verge of sacking central bank governor Zeti Aziz, an expose on her family’s ‘dealings’ has been splashed online. Critics of the Prime Minister claim the article was sponsored by 1MDB figure Jho Low and his… – Continue reading

Business leaders renew appeal for clarity on ‘acceptable’ tax planning

LONDON–(BUSINESS WIRE)–Three quarters of business leaders would pay more taxes in exchange for greater clarity from authorities on what is acceptable, according to the Grant Thornton International Business Report (IBR), a global survey of 2,580 businesses in 35 economies. And while few expect a global agreement any time soon, the… – Continue reading

FATCA reporting deadline is August 15

Financial institutions and other reporting entities have been given a deadline date of August 15, 2015, as it relates to registration with the Barbados Revenue Authority (BRA), for sending key information required under the Foreign Account Tax Compliance Act (FATCA). Representing the Barbados Revenue Authority (BRA), Dava Leslie-Ward recently pointed… – Continue reading

74% of Businesses Are Asking for Greater Clarity from Authorities for Cross-Border Tax Planning

MONTRÉAL, Aug. 5, 2015 /CNW Telbec/ – Three quarters of business leaders would pay more taxes in exchange for greater clarity from authorities on what is acceptable for tax planning, according to the Grant Thornton International Business Report (IBR), a global survey of 2,580 businesses in 35 economies. And while… – Continue reading

CRA targeting mining-sector tax havens

Tax evasion by Canadian companies using offshore havens promises to become election issue Canadian corporations that use tax havens like Switzerland and the Cayman Islands to reduce the taxes they pay at home have good reason to worry. The Canada Revenue Agency (CRA) has been stepping up its scrutiny of… – Continue reading

Cayman Islands: Fiscal Transparency In The Cayman Islands

Introduction The Cayman Islands have an extremely open, accountable and transparent government and regulatory system. Despite the dated stereotype, the Cayman Islands have promoted transparency regulations and initiatives for many years.  In May 2000, the Cayman Islands made commitments to the Organisation for Economic Co-operation and Development (the “OECD“) to… – Continue reading

A light at the end of America’s fatca tunnel?

A “glimmer of hope” has emerged in the US for reform of the controversial Foreign Account Tax Compliance Act (Fatca), which has caused extensive financial headaches for millions of American foreign assignees and even prompted 7,000-plus expats to renounce their US citizenships. The post-crisis act, originally intended to expose details… – Continue reading

Foreign investors not liable to pay MAT, says AP Shah panel

The recommendations of Justice AP Shah-led three-member committee on minimum alternative tax (MAT) has come in for big relief to foreign investors. The 64-page report, exclusively accessed by dna, says a foreign investor is not liable to pay MAT prior to April 1, 2015. The report, however, is silent on… – Continue reading

Germany: Taxation of Foreign Investment in Germany

Germany has the largest economy in Europe. Along with the developed infrastructure, investors will also benefit from the advanced technology that will ease integration in many industrial sectors, and the highly specialized as well as educated workforce. In terms of the taxation of foreign investment, the taxation system in Germany… – Continue reading

SARS wants exchange of information treaties to include tax information

THE South African Revenue Service (SARS) wants to be able to share disclosed financial information with countries with which it has multilateral exchange of information agreements. The ability to automatically exchange information with revenue authorities and with SA’s treaty partners would allow SARS to expand its tax base and help… – Continue reading

EC Will Not Challenge Member States On Royalties Tax

Tax Commissioner Pierre Moscovici has said that European Commission law was not breached in the case of a French professional association taxing royalty payments earned by UK musicians in France. In a written question to the European Commission, Julie Girling, a UK Member of the European Parliament (MEP), alleged that… – Continue reading

Business execs divided on US tax reform prospects

Business executives are giving mixed predictions on when and if tax reform will finally happen in Washington, in a new survey, reports Accountancy Today. The latest Business Tax Reform Barometer survey from the Tax Council and Ernst & Young polled approximately 1,000 business executives, tax directors, government relations representatives and… – Continue reading

Cyprus: Opportunities For Offshore And Alternative Investment Funds

Introduction Following the implementation of the EU Alternative Investment Fund Managers (AIFM) Directive (2011/61/EC) and associated legislation, Cyprus now lays claim to being a growth jurisdiction within the European Union for the establishment and servicing of boutique and low cost alternative investment funds based locally or offshore. The choice of… – Continue reading

Microsoft’s Offshore Profit Pile Surges Past $100 Billion Mark

Microsoft Corp.’s stockpile of offshore profits rose to $108 billion, with a 17 percent increase over the past year as the company continues reaping profits in low-tax foreign jurisdictions. The company crossed the $100 billion mark, making it just the second U.S. corporation — after General Electric Co. — to… – Continue reading

Treasury proposes five major changes to the U.S. Model tax treaty

On May 20, 2015, the U.S. Treasury Department (“Treasury”) released five sets of proposed revisions to the U.S. Model Income Tax Convention (“Model Treaty”) for public comment. The Model Treaty was last updated in 2006. The purpose of the proposed revisions is to ensure that the United States maintains the… – Continue reading