Presidency sent to Congress ratification of treaties with Jersey, Guernsey, the Cayman Islands and Uruguay; text follows the G20 guidelines The Presidency referred for evaluation of Congress four agreements for the exchange of tax information (TIEA, which stands for the English term “Tax Information Exchange Agreement”) entered into with Uruguay,… – Continue reading
Britain has done more to tackle secretive company ownership practices which facilitate corruption than other leading economies, while the United States and China are falling short of their promises, a leading anti-corruption group said. Britain has made good progress on making beneficial ownership information accessible, having legislated for a central… – Continue reading
The Common Reporting Standard (“CRS”) will impose new investor due diligence and reporting obligations on funds and other financial institutions based in “early adopter” participating jurisdictions, with effect from January 1, 2016. According to the OECD, all major financial centres have now signed up to the standard. Financial institutions should… – Continue reading
Clare Maurice, Arabella Murphy and Sophie Mazzier, Maurice Turnor Gardner LLP For better or worse, the concept of “fairness” is here to stay in relation to taxation, whether domestic or international. Politicians of all persuasions like to insist that their respective policies will ensure that everyone pays his or her… – Continue reading
Finland’s Minister for Foreign Trade and development, Lenita Toivakka, has admitted being involved in a scheme to reduce tax liabilities on a multi-million euro shopping centre development in Mikkeli. She insisted that the arrangement was legal as well as commonplace for international property investors. Finland’s Minister for Foreign Trade and… – Continue reading
In this edition we also include the leading trustees, private bankers and accountants serving the private client industry. RBC Wealth Management leads our research in trust and advisory services with an impressive 18 names recommended. Alan Binnington specialises in establishing and administering trust and fiduciary structures for high net worth… – Continue reading
The New Zealand foreign trust regime – its use in international wealth planning The New Zealand “foreign trust” regime came into being over 25 years ago. It arose from a domestic initiative to make the use of offshore trusts for tax minimisation more difficult for New Zealand residents, by imposing… – Continue reading
To increase the scope of income tax laws, GCC countries are pursuing tax determinations with significantly broader interpretations of activities or actions that constitute doing business in-country. New concepts like Virtual Service Permanent Establishment and dependent agents are being used in Saudi Arabia and Kuwait to determine taxable presence or… – Continue reading
Exclusive PM underlines fairness test for GST ‘The fact of the matter is that any changes to the tax system will be fair’ says Prime Minister Malcolm Turnbull in question time on Monday. Australia’s peak union body is preparing for a major political fight with the Turnbull government over tax… – Continue reading
Luanda — A substantially Intergovernmental Agreement under the Foreign Account Tax Compliance Act (FATCA) was signed Monday in Luanda between the Ministry of Finance and the government of the United States of America, represented by its ambassador to Angola. According to the Internal Revenue Service (IRS), the US tax authority,… – Continue reading
United States taxpayers using foreign accounts in the United Arab Emirates may see more rigorous enforcement of the Foreign Account Tax Compliance Act, or FATCA, in the UAE, as obligations for UAE financial institutions have been ramped up under a new intergovernmental FATCA Agreement between the U.S. and the UAE,… – Continue reading
On November 10, 2015 the European Commission published a brochure titled “Did you know… Facts and figures about the European Union and the G20 – 2015 Turkey G20 Antalya, 15>16 November 2015”. According to the European Commission, the brochure sets out the European Commission’s aims for the G20 summit. The… – Continue reading
Key Points: The rejection of the Commissioner’s position on the relevance of credit rating agencies and the relevance of implicit support will give rise to uncertainty going forward, as it is unclear how an arm’s length interest rate can be practically determined. The Federal Court’s recent decision in Chevron Australia… – Continue reading
A Chris Christie administration would likely make shareholders at some major U.S. companies very happy. The two-term New Jersey Governor has called for an array of pro-growth, business-friendly reforms as he bids for the Republican nomination. Christie is in favor of lowering corporate taxes so companies earn more profits, raising… – Continue reading
Moscow. November 10. The Finance Ministry has prepared proposals aimed to strengthen Amnesty of capital, which is now actually fails, reports the newspaper “Kommersant”. The law on the voluntary Declaration by individuals of assets and accounts, is known as the law on the legalization or Amnesty of capital, earned from… – Continue reading
“In 2013 the OECD, supported by the G20, promised to bring an end to international corporate tax avoidance which costs countries around the world billions in tax revenues each year. However, with the recently announced actions against corporate tax dodging, G20 and OECD countries have failed to live up to… – Continue reading
The European Union’s top antitrust official lauded rulings ordering two companies to repay tens of millions of euros in back taxes as she considers similar decisions involving Apple Inc. and Amazon.com Inc. European Union competition chief Margrethe Vestager told lawmakers Monday that the rulings last month against Starbucks Corp. and… – Continue reading
Headline: G20 among biggest losers in large-scale tax abuse – but poor countries relatively hardest hit G20 countries are the biggest losers when US multinationals avoid paying taxes where they do business. This is the main finding of a new report on the global tax system, ‘Still Broken,’ released by… – Continue reading
NEW DELHI: The forthcoming G20 summit will not be only about the global economy. Host Turkey has said the world’s top 20 nations will have to debate the world’s biggest political and security crisis of the day, Syria, and the mass migration of refugees. According to local media reports, the… – Continue reading
France wants an agreement on a financial transactions tax (FTT) struck on Monday after a meeting of euro zone finance ministers, Finance Minister Michel Sapin said, reports Reuters. “We have done most of the technical work. I think the time has come to make a decision,” Sapin told reporters. “We… – Continue reading
The Council of European Union has revoked Directive 2003/48/EC, which has allowed tax administrations better access to information on private savers since 2005. By revoking the directive, which is part of a tax transparency package presented by the Commission in March this year, the Council says it strengthens measures to… – Continue reading
A paradigm shift in the way business is conducted is taking place as new base erosion of profit shifting (BEPS) rules are aligned with tax systems, but more tax certainty and rules that suit specific African circumstances are needed, a Deloitte OECD Transfer Pricing Guidelines seminar heard on Wednesday, 04… – Continue reading
While proponents of the base erosion and profit shifting project claim it will facilitate appropriate taxing of global corporate profits, enforcement remains the elephant in the room, writes FX-MM’s Paul Golden. In October, the OECD presented the final package of measures for reform of international tax rules, stating that annual… – Continue reading
In February we wrote about a discussion draft of Action 6 of the Action Plan on Base Erosion (BEPS Action Plan) developed by the Organisation for Economic Co-Operation and Development (OECD) at the request of the G20. In October, the OECD published its final report on Action 6 of the… – Continue reading
A recent CNBC report suggests that several billion dollars of estate tax due from the estates of foreign decedents on investments in U.S. stock and real estate goes uncollected by the IRS every year. The report noted a large discrepancy between the amount of foreign investment in these assets and… – Continue reading
The Powys tax rebellion, led by traders including the town’s salmon smokery, local coffee shop, book shop, optician and bakery, could spread nationwide When independent traders in a small Welsh town discovered the loopholes used by multinational giants to avoid paying UK tax, they didn’t just get mad. Now local… – Continue reading
Dorothy Coleman, the NAM’s Vice President, Tax and Domestic Policy, today joined U.S. Senator Rob Portman (R-OH) and a panel of experts, including representatives from the Organization for Economic Co-Operation and Development (OECD), to discuss key international tax issues, including the Base Erosion and Profit Shifting (BEPS) project recommendations recently… – Continue reading
U.S. companies moved $500 billion to $700 billion in profits to countries with low or no corporate tax rates in 2012 alone, according to new research published by tax reform campaigners Tuesday. Tax avoidance on such a large scale means the U.S. accounts for about 71% of profits worldwide that… – Continue reading
The Taxation Laws Amendment Bill and Tax Administration Laws Amendment Bill were tabled in Parliament on 27 October 2015. The Acts introduce the legislative amendments for the 2015 year based on the Budget Speech delivered in February 2015. Following from our previous article on legal professional privilege, we note that… – Continue reading
United States corporations avoid an estimated $US1.45 billion ($2.06b) of tax in Australia each year by shifting their profits to low or no tax countries, research shows. A joint report by advocacy and union groups Tax Justice Network, Oxfam, Global Alliance for Tax Justice and Public Services International says in… – Continue reading
More than 1,600 new financial institutions have signed up to the US Foreign Account Tax Compliance Act (FATCA) List. The list now covers 177,147 institutions in 226 financial jurisdictions – up 1,604 from the last list published on October 1. The US Internal Revenue Service (IRS) keeps the list to… – Continue reading
At a very high level, it’s a simple concept: a multinational borrows money from a related company overseas, and then uses the interest bill and the repayment methods to reduce tax exposure in Australia. If the loans – and the interest rates – are big enough, the tax savings can… – Continue reading
A planned crackdown on multinational tax dodgers could be in limbo after Labor backed changes to force large companies to submit yearly financial statements. The opposition and the Greens joined forces on Tuesday to back amendments by independent senator Nick Xenophon that would force the bill back to the House… – Continue reading
Kenya’s tax authority has launched a campaign to encourage people to report evasion and to crack down on staff misconduct, it said on Tuesday, after media allegations of corruption. The Kenya Revenue Authority (KRA) said it will vet staff for misconduct and step up efforts to prevent abuses when calculating… – Continue reading
NITI Aayog vice-chairman Arvind Panagariya, who is a sherpa for the G20 Leaders’ Summit to be held at Antalya in Turkey on November 15 and 16, says the member countries recognise that India will continue to grow at high rate that will contribute to the global growth. He tells Indivjal… – Continue reading
The widow of Texas billionaire Charles Wyly told a judge the IRS wrongly accused her of a “sinister” tax-avoidance plot to bolster the agency’s $1.2 billion claim in her bankruptcy case. Caroline “Dee” Wyly, who is in her early 80s, asked the U.S. Bankruptcy Court in Dallas to toss out… – Continue reading
Ireland is expecting European Union regulators to issue a decision on the country’s tax deal with Apple before the end of the year. The Irish finance minister said the move could force the iPhone maker to pay substantial back taxes. The European Commission has already ordered Dutch authorities to recover… – Continue reading
Article by Patrick W Martin and Ashley Fife With a net worth of USD77.1 billion, Mexican telecoms businessman Carlos Slim Helú was ranked the second richest person in the world in a 2015 survey.1 At the end of 2014, 16 of Mexico’s citizens were on Forbes’ billionaires list.2 As for… – Continue reading
A Senate inquiry committee has endorsed government measures to crack down on multinational tax avoidance. A Senate committee has recommended the government review proposed multinational tax avoidance measures within three years to ensure they stop companies siphoning profits offshore. An inquiry into a government bill to crack down on companies… – Continue reading
Broad and retroactive legislation are two reasons the rule of law is under attack The rule of law – essentially, the idea that nobody is above the law – has come under threat in recent years, and could lower the UK’s desirability to do business with, according to a report… – Continue reading
HM Revenue & Customs (HMRC) has launched a new crackdown on tax avoidance with 10 tips on how to stay on the right side of the law. The warning follows recent revelations of 1,500 investors, including celebrities and sports stars, who are being pursued for £200 million for staking cash… – Continue reading
Governments have taken an important step towards ensuring that consumption taxes on cross-border transactions are effectively paid in the jurisdiction where products are consumed, while minimizing the risks that uncoordinated tax rules distort international trade. The decision by representatives of more than 100 countries and jurisdictions to endorse the new… – Continue reading
Measures to control corporate tax avoidance to be presented at Antalya summit The final package of measures proposed by the OECD as part of its base erosion and profit shifting (Beps) project will be presented to G20 leaders in Turkey this weekend. The new Beps rules are designed to improve… – Continue reading
Ghana’s financial secrecy – the tendency to facilitate tax evasion, money laundering and illicit financial transfers – has been rated at a fairly high 67 per cent. The Tax Justice Network, an organisation concerned with tax havens and tax evasion, ranked Ghana 48th out of 92 territories, in its 2015… – Continue reading
The dramatic expansion of international trade and development of new business strategies due to globalisation, converted the world into a large global market. In connection with that, companies have been using complex networks of subsidiaries and branches (e.g. permanent establishments) in order to continue most of their operations. The Multinational… – Continue reading
Although Finance Minister Nhlanhla Nene played it very close to his chest regarding the specifics of tax reforms we can expect in the February 2016 Budget, we’ve compiled a snapshot of the possible tax reforms announced in his 2015 Medium Term Budget Policy Statement. Corporate income tax There are great… – Continue reading
NZ welcomes Cook Islands measures to tackle tax avoidance Minister of Revenue Todd McClay has welcomed a decision by the Cook Islands government to implement the ‘Automatic Exchange of Financial Account Information in Tax Matters Agreement’ (AEOI) and says the Cooks Islands and New Zealand will play their part to… – Continue reading
The Financial Crimes Enforcement Network (FinCEN) is again flexing its regulatory muscles by increasing the breadth and scope of the types of entities regulated by the Bank Secrecy Act (BSA). Among other things, the BSA requires certain types of financial institutions to implement anti-money laundering (AML) programs and file suspicious… – Continue reading
The Belgian Federal Parliament recently adopted a new controlled foreign corporation provision, known as the “Cayman tax”, that allows Belgian tax authorities to look through low-taxed offshore structures to directly tax their Belgian resident founders and third-party beneficiaries on the structure’s income. Belgium’s introduction of the Cayman tax is in… – Continue reading
Over the weekend, German news magazine, Der Spiegel, reported that over many years EU member states such as Luxembourg and the Netherlands have sabotaged attempts to counter profit shifting to low tax jurisdictions via ‘patent boxes’ under the political leadership of current President of the European Commission, Jean Claude Juncker,… – Continue reading
