Category: Activity

HMRC guidance on FATCA tax rules updated

HMRC has updated the reporting requirements under the US Foreign Account Tax Compliance Act (FATCA), which may mean that some organisations or taxpayers no longer need to submit a return by the 31 May deadline HMRC points out that two recent updates have changed the reporting criteria. Firstly, UK financial… – Continue reading

Guernsey: New International Tax Rules – Where Now For Hedge Funds?

Current international tax rules are based on principles that have not kept up with globalisation and the rise of the digital economy. Over the years the rules have been patched up but, almost two years ago, the Organisation for Economic Co-operation and Development (OECD), acknowledging that a substantial overhaul was… – Continue reading

FICCI statement

The Foreign Investors’ Chamber of Commerce & Industry (FICCI) has objected to a news item headlined “Tax theft by MNCs: Call to enforce transfer price rules” published in Sunday’s issue of The Financial Express. In a statement, the chamber said the shoulder “Tax theft by MNCs” and the reporter’s remarks… – Continue reading

Swiss banking to flourish after tax crackdown, says HSBC executive

Switzerland’s banks will benefit from the global crackdown on tax avoidance, the president of the country’s association of foreign banks and head of HSBC’s (HSBA.L) Swiss private banking arm said on Tuesday, reports Reuters. The Alpine nation famed for its banking secrecy is bowing to international pressure by committing to… – Continue reading

Putin fishing to pull oligarchs’ cash back to Russia

President Putin coined a new word in his state of the nation address at the end of 2012, when he called for new measures for the “deoffshorisation of our economy”, reports the International Business Times. This was to become a major addition, not just to the Russian vocabulary but to… – Continue reading

Indonesia to tighten corporate debt financing rules

May 13 Indonesia’s finance ministry plans to tighten a tax regulation to ensure firms’ have sufficient cash buffers against the amount of debt they take in a bid to better manage their foreign debt exposure and boost the government’s tax revenue. Finance Minister Bambang Brodjonegoro told a press conference on… – Continue reading

FIIs get another small dose of relief, fresh tax notices on hold

The announcement marks an attempt to defuse the raging controversy over MAT payouts, which has dented the outlook of foreign institutional investors toward the country’s stock and bond markets. The government on Monday announced it had stayed the issue of fresh notices to foreign institutional investors regarding the alleged non-payment… – Continue reading

Hong Kong: The Impact Of BEPS On Your Relationship With Customs Authorities

If you are moving or trading goods across borders, this topic should be of primary importance from both a Transfer Pricing and Customs perspective. There is potential for you to have Transfer Pricing and Customs exposures in your supply and value chains as a result of the OECD/G20 initiative on… – Continue reading

China Clarifies Tax Treatment of Indirect Asset Transfers

The Chinese government has been paying close attention recently to the effects of offshore entities having ownership or control of Chinese companies or assets. Following the release of the draft Foreign Investment Law in January 2015, the State Administration of Taxation (SAT) issued a Bulletin on the tax treatment of… – Continue reading

Vietnam: Contract Manufacturing And Tolling Agreements

I. VAT and Customs In many cases, the principal in the contract manufacturing relationship owns some or all of the raw materials, work-in-process and finished goods throughout the manufacturing process. The principal and many of the suppliers are typically outside of the manufacturing jurisdiction. 1. Generally Speaking, What Are The… – Continue reading

Chinese multinationals to be subject to stricter rules governing outbound transfer pricing payments

New rules applicable to payments made by Chinese companies to ‘related’ companies offshore will prevent them from artificially shifting profits to lower tax jurisdictions through “unreasonable” service and royalty payments, the State Administration of Taxation (SAT) has said. Circular 16, which came into force on 18 March, and its accompanying… – Continue reading

Switzerland: Total Return Swaps – Swiss Federal Supreme Court Sides With Federal Tax Authority (FTA) By Denying Reimbursement Of WHT

On 5 May 2015 the Federal Supreme Court rendered its long awaited decision on a withholding tax (WHT) reimbursement claim related to Total Return Swaps. The case was based on essentially the following facts: a Danish bank entered into swap contracts with clients in England, Germany, France and the US…. – Continue reading

KPMG Responds To Hockey’s Tax ‘Integrity’ Measures

Grant Wardell-Johnson, KPMG Tax Partner, has said that while it would have been better for Australia to await the outcome of the OECD’s base erosion and profit shifting Action Plan, the international tax measures proposed recently by Treasurer Joe Hockey “have the benefit of being highly targeted.” On May 11,… – Continue reading

Online tax laws holding SA companies back

South African companies are unable to compete with multinationals selling goods and services online in the country, partly as a result of tax laws. This is according to financial services group PwC, which argues that the country has not kept pace with the changing global economy. “Currently, multinationals in the… – Continue reading

Switzerland: Switzerland’s Practice Of Information Exchange Regarding Stolen Data

Introduction The Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) decided in mid-March 2015 that Switzerland should enter Phase 2 of the Peer Review. This decision represents a clear statement by the OECD that Switzerland’s legal and regulatory framework for information exchange complies with internationally… – Continue reading

UK: Finance Act 2015 – Avoidance Using Carried-Forward Losses

Tax analysis: Catherine Richardson, associate at Cadwalader, Wickersham & Taft LLP, examines the aspects of the Finance Act 2015 (FA 2015) which concern targeting avoidance using carried-forward losses. What is the target for the new rule countering tax avoidance involving carried-forward losses? Where losses for tax purposes arise within a… – Continue reading

MEPs’ Luxleaks probe risks falling apart

A special European Parliament committee to probe tax avoidance schemes is facing mounting obstacles to its work. The problems, which include access to documents, administrative delays, and internal disagreements risk undermining the MEP’s investigation into how government-backed tax rulings allow multinationals, in some cases, to pay less than 1 percent… – Continue reading

OECD nations gang up on internet retailers, tax dodgers

Australia to fine tech tax-dodgers 100% of their avoided tax, plus profits Australia’s treasurer* Joe Hockey has revealed that he and other money ministers from the Organisation for Economic Co-operation and Development (OECD) have shared plans to have online retailers charging the appropriate consumption tax on intangibles and goods bought… – Continue reading

Monsanto-Syngenta Could Be a Tax Inversion Under Current Rules

(Bloomberg) — Monsanto Co.’s potential acquisition of rival agricultural-chemical maker Syngenta AG could be structured as a tax inversion under current U.S. rules despite political resistance to such deals, according to an analysis by Bloomberg Intelligence. Switzerland’s Syngenta last week rejected St. Louis-based Monsanto’s $45 billion takeover offer. Monsanto, the… – Continue reading

Global news briefs from the Economist

Global business The European Union outlined its strategy to create a digital single market. The thrust of the proposals include establishing standard rules for buying goods online, pruning cross-border regulations on telecoms and reducing the tax burden on businesses. But the plan also calls for a “comprehensive assessment” of whether… – Continue reading

Fatca special report

Changing Requirements and Changing Methods As the first year of the US Foreign Account Tax Compliance Act (Fatca) being in effect is almost complete, the rules for reporting still appear to be in flux, as are the ways firms are responding to Fatca compliance and setting out methods to address… – Continue reading

Bancolombia Adds AxiomSL FATCA Solution to Reporting Platform

Ease of integration and flexibility of strategic reporting platform drive Colombia’s largest bank to expand partnership Tax reporting solution now deployed in five countries as a result of agreement AxiomSL, a leading provider of regulatory reporting and risk management solutions to the financial services industry, announced today that Bancolombia, Colombia’s… – Continue reading

Lexmark Considered Inversion Before Kofax Deal

Lexmark International Inc. considered moving its headquarters overseas to save money on taxes earlier this year, according to chief financial officer David Reeder. But the printing company decided to stay in its Lexington, Ky. home, after spending the bulk of its offshore cash to buy software developer Kofax Ltd.s

No shock and awe, just a sedate affair

AUSTRALIANS hoping to gorge on offerings intended to stimulate the economy in Tuesday’s Federal Budget have been warned to prepare for lukewarm but at least digestible fare. Though the electorate’s appetite has been whet by the sizzling entree of another Reserve Bank rate cut this week, economists expect the main… – Continue reading

Sebi cracks down on Rs 420-cr tax fraud, bars 178 entities

After finding them guilty of manipulation in the stock market for making illegal gains, Sebi has restrained the 178 entities, including Pine Animation, from accessing the securities market. In a fresh clampdown on misuse of stock market platform for suspected money laundering activity, Sebi today banned Pine Animation and 177… – Continue reading