Tax reform is widely expected under the Trump administration by the corporate tax executives polled by BDO USA in a new survey. BDO’s 2017 Tax Outlook Survey polled 100 tax executives at public companies across the U.S., and found that 100 percent of the surveyed tax executives believe tax reform… – Continue reading
A significant cut to the dividend tax allowance announced in the UK Budget will not deter people from incorporating their own business to take advantage of lower corporation tax rates, the Chartered Institute of Taxation (CIOT) has said. The Government will reduce the tax-free dividend allowance, which affects owner managers… – Continue reading
The new scanners by Kenya Revenue Authority at entry points has helped curb a multi-million-shilling tax evasion racket. The crooks had used all ways to beat the authority’s system to import luxury cars declared as toys or bicycles; scrap batteries that turned out to be Kenyan tea for export and… – Continue reading
Luxembourg should seek to widen the tax base while ensuring that its corporate tax regime continues to meet international best standards, says the International Monetary Fund. It said that the country could improve its reputation by “promptly transposing” the EU’s Anti-Tax Avoidance Directive into national law and continuing to implement… – Continue reading
From 6 April 2017, non-dom owners of UK property will be liable to inheritance tax (IHT) at 40% on any UK residential property they own. This has always been the case where a non-dom (broadly an individual who is resident in the UK but who has their permanent home abroad)… – Continue reading
Romania approved legislation to join the OECD’s base erosion and profit shifting Inclusive Framework on March 2. As an Associate member under the Inclusive Framework, Romania will work on an equal footing with other associates and G-20 and OECD countries in the development of further BEPS standards and the peer… – Continue reading
WASHINGTON — In the current deregulatory environment, investment advisers might expect a reprieve from new federal compliance rules. But one exception is the proposal for an anti-money-laundering regulation, which experts believe is likely to become the law of the land, bringing with it a significant new compliance responsibility. A year… – Continue reading
The United States Court of Federal Claims has turned down a claim from an Irish citizen that more than USD5m in US tax withheld on gambling winnings should be refunded under the US-Ireland double tax avoidance treaty. The claim was filed by the plaintiff, John P McManus, after USD5.22m in… – Continue reading
These three CGT exclusions have remained unchanged for five years. Over the last few years government has collected a significant amount of tax revenue by not fully adjusting the personal income tax tables for inflationary increases in earnings, thereby increasing the effective tax rate of individuals. A middle-class individual earning… – Continue reading
The Hong Kong Government has put forward a proposal to amend its tax laws to establish a dedicated tax regime for aircraft owners/lessors based in Hong Kong and leasing to offshore (including PRC) lessees/airlines (see Timeline / References below) (“Proposed Regime”). Assuming there are no surprises or drafting issues in… – Continue reading
On October 1, 2016, the Indiana Office of Fiscal and Management Analysis of the Indiana Legislative Services Agency released a Combined-Reporting Study and a Transfer Pricing Study. These studies, which address corporate income tax issues, were required by legislation passed in 2016. The Combined-Reporting Study discusses the reduction of state… – Continue reading
South Korea’s tax authorities have been investigating the local importer of Toyota and luxury Lexus vehicles over suspected tax evasions since late 2016, industry sources said Friday. In November, the Seoul office of the National Tax Service (NTS) launched a tax audit into Toyota Korea over suspicions that it paid… – Continue reading
The Swiss Federal Department of Finance has said that it is forging ahead with work on a new corporate tax proposal, named “tax proposal 17” (TP17). A steering committee held its first meeting on March 2. It is led by Federal Councillor Ueli Maurer and comprises members from the government… – Continue reading
Countries that end up on the European Union’s list of tax havens could subject companies operating within their borders to tax sanctions—such as withholding taxes and denied deductions for royalty payments—damaging the businesses’ ability to offset losses in the jurisdictions. Following a March 1 meeting, politicians identified a range of… – Continue reading
Federal agents raided three Caterpillar buildings near its Illinois headquarters on Thursday, company and law enforcement officials said, in an escalation of an inquiry into the heavy equipment manufacturer’s offshore tax practices. Caterpillar has been dogged by accusations that it slashed its domestic tax bill by shifting corporate profits from… – Continue reading
On 30 December 2016 the Commercial Court of Voronezh Oblast delivered a judgement in case No. А14-10190/2014 (the “Decision”) under the claim of Ilyushin Finance Co. Open Joint Stock Company (the “Company”). The case is an example of a broad interpretation of the list of documents confirming entitlement to a… – Continue reading
Muscat: A portal for entities subjected to taxation was launched on Wednesday by the ministry of finance. The ministry, represented by the Secretariat General for Taxation launched the portal www.taxoman.gov.om. The portal has legislations, taxation charts and agreements on avoidance of double taxation as well as developments in the field… – Continue reading
The new Residence Nil Rate Band will allow people to pass on property to their descendants tax free. But some people need to take action now or risk missing out. In April, a major change to inheritance tax (IHT) law comes into effect with the launch of the Residence Nil… – Continue reading
The European Parliament’s Monetary Affairs and Civil Liberties committees’ overwhelming support for access by EU citizens to information concerning the beneficial owners of companies without having to demonstrate a ‘legitimate interest’ and trusts would have to meet the same requirements. MEPs agreed the on their position on EU Anti-Money Laundering… – Continue reading
THE ORGANISATION for Economic Cooperation and Development (OECD) initiated the base erosion and profit shifting (BEPS) project in 2013 to address perceived gaps in international tax rules causing a loss of revenues for governments of about US$100 billion to $240 billion (Bt3.5 trillion to Bt8.4 trillion) annually. The OECD’s BEPS… – 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
The importance of taxation to a nation’s economic wealth and development cannot be overemphasised. However, the achievement of this goal is often undermined by tax evasion and deliberate attempts by multinationals to shift profits from one jurisdiction to another, amongst others. Over the years, Nigeria has attempted to use taxation… – Continue reading
The Netherlands is slowly but surely steering away from facilitating the use of its corporate income tax system by companies that are set up merely to obtain tax benefits. These companies, which often do not actually carry out activities in the Netherlands, have contributed to the perception among policy makers… – Continue reading
On 22 December 2016 the Luxembourg Parliament passed article 56bis of the Luxembourg Income Tax Law (LITL). This provision gives taxpayers and tax authorities more guidance on how to apply the arm’s-length principle. The new article can be seen as a transposition of OECD BEPS reports (actions 8-9-10) released in… – Continue reading
New Oxfam report indicates Government measures to tackle tax avoidance are failing Multinationals are continuing to route billions of euro in profit to and through Ireland to avoid tax, according to a new report by Oxfam Ireland. The study, which suggests that Government measures aimed at tackling tax avoidance are… – Continue reading
Transfer pricing—the price charged for intercompany transactions between entities in different tax jurisdictions—can be used to shift funds within a multinational corporation (MNC), and serves as an effective means to manage a firm’s finances. Transfer pricing—the price charged for intercompany transactions between entities in different tax jurisdictions—can be used to… – Continue reading
U.S. multinational companies with more than $850 million in annual consolidated gross income now have draft instructions for filing IRS reports on their global tax and profits. The Internal Revenue Service added instructions to the draft Form 8975 and accompanying draft Schedule A it released in December 2016, companies that… – Continue reading
Muscat: Dodging taxes can lead to a jail term of up to three years and a maximum fine of OMR50,000 under tax law amendments published by the Ministry of Finance, as government begins its crack down on evaders. Out of the 300,000 companies registered by the Oman Chamber of Commerce… – Continue reading
A bombshell hidden in the detail of the 2017 Budget review relates to the taxation of offshore trusts. It refers to the 2015 Budget review in which it was announced that measures would be introduced to the tax treatment of foreign companies held by interposed trusts. No specific countermeasures were… – Continue reading
Brazil’s federal revenue service is continuing to adapt the country’s tax rules to OECD recommendations, as shown in recent guidance on how companies should seek help from the government on international tax questions. Normative Instruction 1689, issued Feb. 21, spells out the requirements for companies to request a consultation on… – Continue reading
President of Panama Juan Carlos Varela signed into law today the implementation of the Convention on Mutual Administrative Assistance in Tax Matters (MAC), which allows for sharing tax information multilaterally on request with the 107 jurisdictions that are part of the convention and provides a common legal basis for cooperation… – Continue reading
Finance Minister, Sri Mulyani, says that Indonesia continues to make preparations for implementing exchange of information in financial services and taxation sectors like alignment of the rules in the Law on the General Rules and Procedures of Taxation (KUP). “We will try various ways to incorporate various articles for KUP… – Continue reading
Apple, which was recently slapped with a $14 bn tax bill for its activities in Ireland has now filed a 14-point appeal against the ruling. The EC had filed a case accusing Ireland of giving “state aid” to Apple. The European Commission (EC) charged Apple on various grounds, including tax… – Continue reading
The National Assembly of the Republic of Srpska (RS) adopted amendments to the Profit Tax Law on 28 December 2016. The main changes have become effective as of 1 January 2017 and will be briefly presented in this article. With the amendments, the Law clarifies the definition of “taxable person”… – Continue reading
The CRA has the power to make a transfer pricing adjustment to any amount for a taxation year under s. 247(2) in respect of a non-arm’s length cross-border transaction. A taxpayer is also liable to a 10% penalty under s. 247(3), which penalty is determined with reference to the taxpayer’s… – Continue reading
We are all familiar with the use of offshore intellectual property holding companies to capitalize on international tax gradients. These companies are designed to take advantage of strategic local tax rules to reduce tax burdens on royalty streams generated from licensing. Because of these favorable tax treatments, countries like Luxembourg… – Continue reading
Finance Minister Edward Scicluna presented amendments to rules against tax avoidance practices within the ECOFIN Council today, amounting to a compromise solution which was accepted. The solution provides rules regarding corporate hybrid mismatches and third countries. The Council agreed its position on rules aimed at closing down ‘hybrid mismatches’ with… – Continue reading
The Government is considering making companies include detail of who their supervisor is under the Anti-Money Laundering and Countering Financing of Terrorism Act (AML/CFT Act) as it strives to clean up the Financial Service Providers Register (FSPR). This suggestion is included in a consultation paper on a Financial Services Legislation… – Continue reading
Irish Finance Minister Michael Noonan has criticized the EU’s proposals for a common consolidated corporate tax base (CCCTB) and public country-by-country (CbC) reporting as “against the BEPS consensus.” In a speech to an event on corporation tax, Noonan said that the consensus over the OECD’s BEPS proposals must hold and… – Continue reading
The Australian Government has introduced legislation to extend the goods and services tax (GST) to low value imports from July 1, 2017. The legislation, introduced on February 16, requires overseas vendors, electronic distribution platforms, and goods forwarders with an Australian turnover of AUD75,000 (USD57,528) or more to register for, collect,… – Continue reading
MPs propose tweaks to the Union Revenue Bill. The solution to widespread tax evasion on land purchases is the creation of a fairer, more even taxation system. This was the prevailing opinion of MPs assembled in Nay Pyi Taw last week to deliberate the Union Revenue Bill prescribing three tax… – Continue reading
It seems that our tax system is quite the topic of conversation. It has even been called “not European”, “not social” and “a harmful tax practice”. Indeed. The idea that there is some moral code that can be called ‘European’ is as absurd a notion as any I have ever… – Continue reading
Thousands of properties in Cyprus that have not been declared to the Tax Department have been discovered during a revaluation exercise by the Department of Lands and Surveys according to the island’s Interior Minister. The general assessment of immovable property valuations formed part of the Memorandum of Understanding between Cyprus… – Continue reading
As part of the global transparency push, the G20 has committed to implement rules requiring the disclosure of beneficial ownership of legal entities (in addition to automatic exchange of financial account information and the BEPS related transparency measures). On 13 February 2017, Treasury released a consultation paper dealing with part… – Continue reading
In the public vote held on February 12, 2017, Swiss voters rejected the Corporate Tax Reform III Law Proposal (CTR III). Nevertheless, this issue is not yet resolved and remains on the table! A «CTR III 2.0» is expected in a timely manner. Information about the newest developments, but also… – Continue reading
On February 16, 2017, the Presidium of the Supreme Court of the Russian Federation approved the Review of Court Practice in the Consideration of Cases Involving the Application of Certain Provisions of Section V.1 and Article 269 of the Tax Code of the Russian Federation (the “Review”). There is no… – Continue reading
SEOUL, Feb. 16 (Yonhap) — The Cayman Islands became the largest investor as a tax haven country in the South Korean market last year, data showed Thursday, amid suspicions that some of the money could be owned by South Koreans disguised as foreign investors in an attempt to avoid taxes…. – Continue reading
The EU has signalled plans to ramp up its work to tackle harmful tax practices internationally, with the Council working group that oversees implementation of the EU’s code of conduct on business taxation finalising a list of jurisdictions that are considered non-cooperative in tax matters to be published shortly. The… – 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
The OECD has recommended that Sweden rebalance its property tax system. In its latest Economic Survey for the country, the OECD said that Sweden’s favorable tax treatment of owner-occupied housing is regressive, benefiting relatively high-income households most and contributing to the high demand for housing. It said it also encourages… – Continue reading
