(CNS Business): The use of Cayman Islands funds as a wealth management tool for high net worth Latin American families was debated last week at the STEP LatAm Conference in Brazil, where kidnapping is a constant worry for the wealthy and demand for outbound investments is fuelled by privacy and… – Continue reading
JAKARTA, Oct 28 (Reuters) – Indonesian conglomerate Lippo Group plans to shift two real estate investment trusts (REITs) with 35 trillion rupiah ($2.6 billion) in assets from Singapore to Indonesia next year in order to benefit from new tax breaks offered by Jakarta. Lippo’s move could be followed by at… – Continue reading
Herve Falciani, the Frenchman wanted on charges of industrial espionage in Switzerland, has opted to skip his trial at the country’s top court and instead plead his case before a jury of journalists at a French hotel, less than a mile from the Swiss border. The Frenchman was the star… – Continue reading
Come November 1, mutual fund investors will have to provide details and declaration pertaining to Foreign Account Tax Compliance Act (FATCA) and common reporting standards (CRS) for all new accounts opened, failing which fund houses are likely to reject their applications. While some fund houses have already started this process… – Continue reading
Action 13 of the final package of reports issued by the Organisation for Economic Cooperation and Development (OECD) under the base erosion and profit shifting (BEPS) project focuses on a company group’s global value chain and transfer pricing policy, and introduces a standardized three-tiered approach to transfer pricing documentation—core documentation… – Continue reading
The European Commission recently published new rulings, the OECD published its base erosion and profit shifting (BEPS) final reports, and many countries are reviewing and reinforcing their transfer pricing rules—and France is no exception. Tax professionals in France have observed certain recent trends with regards to transfer pricing. The current… – Continue reading
Following the recent Irish budget statement (the “Budget”), the Finance Bill 2015 (the “Bill”) has been published and it implements the changes announced by the Irish Minister for Finance (the “Minister”). The Bill includes additional detail on: the new knowledge development box (“KDB”); and Ireland’s implementation of country by country… – Continue reading
On October 27, 2015 the U.S. Treasury Department and Internal Revenue Service published final regulations concerning the treatment of “mixed-use” projects financed with tax-exempt bonds. These new regulations have significant and immediate importance for tax planning and tax compliance of tax-exempt bond issuers and borrowers. A copy of the new… – Continue reading
When considering which foreign assets are reportable under FATCA, one of the most commonly misunderstood and overlooked is the contribution to foreign pensions. Whether you are a U.S. citizen who worked abroad or a foreign national resident in the U.S., you may very well have some type of foreign pension…. – Continue reading
Global tax experts KPMG expect taxpayers throughout the world will need to pay more tax in the years ahead as governments repay debt and fund increases in social welfare. In its annual global tax rates survey released on Tuesday it says Australia’s tax mix is out of step with global… – Continue reading
French online gambling is overseen by the Regulatory Authority for Online Gaming (ARJEL), the ruling organization responsible for imposing a series of strict and sometimes puzzling regulations that often limit the market’s full potential. ARJEL President Charles Coppolani attempted to clear some of the confusion earlier this month at the… – Continue reading
LONDON (Alliance News) – The Renewables Infrastructure Group Ltd on Tuesday said it is planning to raise further funding from its equity placing programme. The company, which invests in renewable energy infrastructure projects, said the fundraising will likely take the form of placing of shares and will be closed in… – Continue reading
The Australian Taxation Office (ATO) recently engaged in the first automatic sharing of financial account information with the tax authority (IRS) in the United States. The details of more than 30,000 Australian financial accounts of individuals with a connection to the United States were provided to the IRS under the… – Continue reading
A decision by the Federal Court of Australia has key implications for transfer pricing of intercompany financing transactions, as well as implication for other broader intercompany arrangements. The case concerns the transfer pricing implications of an intercompany loan agreement between an Australian taxpayer and its U.S. subsidiary (CFC) and whether… – Continue reading
The Financial Stability and Development Council (FSDC), headed by Finance Minister Arun Jaitley, will meet on November 5 to take stock of the economic situation. Fiscal situation, external sector environment, financial sector reforms, rising non-performing assets and regulatory issues are likely to figure in the meeting, sources said. FSDC is… – Continue reading
The Internal Revenue Service is encouraging all non-compliant U.S. citizens, including those among the 1 million Americans who are resident in Canada, to take advantage of its voluntary disclosure programs initiated in 2009 and 2012. The move comes just a few weeks after Canadian courts refused to issue injunctions prohibiting… – Continue reading
The Bank of Butterfield has agreed to buy the multibillion dollar private banking trust and investment arm of rivals HSBC Bermuda. The move means Butterfield will acquire the Bermuda Trust Company Ltd as well as the trust and investment business of HSBC. At the end of last year, HSBC’s trust… – Continue reading
On October 22, 2015, the UK launched a consultation on the design of the country’s new “patent box” regime. The UK is developing a new patent box regime that would comply with the recommendations of the OECD on harmful tax practices. It was agreed at international level that, from July… – Continue reading
Ireland has announced a new 6.25 per cent corporate tax rate for intellectual property research Ireland’s 12.5 per cent corporate tax rate is already one of the lowest in Europe, Economia reports. Now, companies investing in research and development (R&D) will be able to avail of the even lower rate… – Continue reading
BRUSSELS, Oct 27 (KUNA) — The European Parliament adopted a resolution Tuesday by 593 votes to 37 on a deal with Switzerland to make it harder for EU citizens to hide cash from the taxman in Swiss bank accounts. Under the deal, the EU and Switzerland will automatically exchange information… – Continue reading
The global climate for international tax is rapidly changing. The OECD, the EU and tax authorities around the world have focused attention on tax planning implemented by leading multinational companies. The OECD believes that tax planning and related structures lead to an annual revenue loss of US$100-240 billion. Since 2013,… – Continue reading
Brazil has reduced from 20 percent to 17 percent the maximum income tax rate required to designate a location that meets the other requirements as a low-tax jurisdiction for transfer pricing and other tax purposes. The change was made via Ordinance 488/2014 of the Ministry of Finance, published in the… – Continue reading
The Ministry of Finance yesterday held a press conference to explain causes on state budget balance that the public currently raise concerns about. Deputy Minister Do Hoang Anh Tuan said that the ministry would focus on collecting tax debts, fighting against transfer pricing and inspecting businesses over their financial obligations,… – Continue reading
Government action against tax avoidance has made the headlines on numerous occasions over the past few years, with significant developments in litigation, legislation and early tax collection, via a combination of follower notices and accelerated payment notices. Add to this the expansion of the disclosure of tax avoidance schemes, hallmarks… – Continue reading
The new non-resident capital gains tax came into force in Guernsey on 6 April 2015. The rules intend to capture disposals of residential property in the United Kingdom by all non-residents. These notes provide a summary of who and which property is affected, and describe how a new UK tax… – Continue reading
On the heels of extensive preparation for the implementation of FACTA in St. Kitts and Nevis, banks and other financial institutions are now starring down the barrel of additional financial accounts information reporting on a wider scale. The Organization for Economic Co-operation and Development (OECD) has proposed a global version… – Continue reading
On October 5 the OECD published recommended measures that purport to tackle BEPS – Base Erosion Profit Shifting. Exporters around the world need to take note of the latest recommendations of the OECD. Any business that uses overseas agents or warehouses should take note. A company resident in country A… – Continue reading
For many years, policymakers have criticized the strategies that American corporations use to reduce their taxes by shifting income and capital offshore. The impetus behind these strategies is the U.S. corporate income-tax rate — at 35 percent, the highest of any industrialized nation, easily surpassing countries such as the U.K…. – Continue reading
India will apply a 5 percent withholding tax to offshore rupee bonds for foreign investors, in line with the rate applied to domestic debt, Manoj Joshi, joint secretary at the finance ministry, told reporters on Tuesday. The clarification comes amid some confusion about whether the withholding tax also applied to… – Continue reading
Parliament adopted its stance on a deal with Switzerland to make it harder for EU citizens to hide cash from the tax man in Swiss bank accounts, in a vote on Tuesday. Under the deal, the EU and Switzerland will automatically exchange information on the bank accounts of each other’s… – Continue reading
MUMBAI: The government is set to ease a few pre-set conditions for offshore fund managers to allow private equity investors to shift base to India without attracting a tax on capital gains by relaxing safe harbour rules, people familiar with the matter said. The government is likely to allow a… – Continue reading
Profit-shifting has not paid off for petroleum multinational Chevron, slugged with a tax bill for $322 million thanks to a Supreme Court decision on Friday. Chevron has been under close scrutiny this year, particularly since a senate inquiry into tax-avoidance in April which also put mining giants BHP, Rio Tinto,… – Continue reading
THE NUMBER of Slovak companies with ownership registered in a tax haven decreased in the first half of 2015 by 112, to a total of 4,250. The biggest outflows were recorded in Monaco and the British island of Jersey. The declining trend of companies selecting a tax haven for their… – Continue reading
Citing the need to boost job growth locally and around the United States, Rep. Jerry McNerney, D-Stockton, has introduced legislation that would close tax loopholes that encourage companies to send jobs overseas and that would make companies reveal their outsourcing. The idea behind the legislative package is to provide greater… – Continue reading
Credit Suisse Group AG, the Swiss Bank that unveiled a major shift in strategy last week to focus on wealth management over investment banking, plans to make acquisitions and invest about $400 million in Switzerland in the next few years, Chief Executive Officer Tidjane Thiam and Chairman Urs Rohner said… – Continue reading
The offshore yuan market faced a rocky patch following Beijing’s shock devaluation in August, but the push to internationalise the currency has lost little momentum, according to The Strait Times. Similarly, Singapore’s role in the growth of the yuan is likely to continue unabated. The general manager of ICBC Singapore,… – Continue reading
Lawmakers at the European Parliament are set to vote on a controversial series of proposals to harmonize the corporate tax system in Europe in a move that will put them on a collision course with some member states which favor sovereignty over taxation. The EU lawmakers on the TAXE committee… – Continue reading
The French Ministry of Finance has issued guidance on the procedure for taxpayers to follow to reclaim wrongly charged social security contributions. The guidance has been issued following a European Court of Justice ruling in February in Ministre de l’Économie et des Finances v. Gérard de Ruyter. The case concerned… – Continue reading
There was a time when, from a tax perspective, South Africa’s “mini budget” used to be a non-event. The main emphasis was on the annual budget speech delivered in February each year when they announced tax policy proposals. However, over the past few years there has been an increasing tax… – Continue reading
Taxation of Profits of Controlled Foreign Companies (CFC): Double Taxation Conventions must prevail over domestic rules The Superior Court of Justice (STJ) has recently decided a case involving the applicability of Brazilian CFC rules in cases in which the controlled company is located in a country with which Brazil has… – Continue reading
More than three quarters of UK companies feel their approach to tax planning conflicts with HMRC’s expectations, a new survey has found, as corporates struggle to strike a balance between the needs of investors and tax authorities Law firm Allen & Overy found that 78% UK corporates believe their approach… – Continue reading
The government has launched a consultation on tax avoidance policies related to interest deductions that could have significant consequences for real estate. The proposals were released by the the Organisation for Economic Co-operation and Development (OECD) as part of a series of recommendations earlier this month designed to prevent companies… – Continue reading
You must have received an email or a letter from your mutual fund (MF), if you have been investing in MFs, asking for some details. If you haven’t yet received such communication, you might receive a letter or email shortly. Your fund house wants to know if you pay taxes… – Continue reading
A company controlled by Mayor of Belgrade Sinisa Mali and his family obtained more than 10 hectares of agricultural land worth anywhere from €123,000 to € 250,000 (US$140,000 to US$290,000) for free from a privatized state company. Problem is, the land wasn’t the company’s to give, but was still owned… – Continue reading
The European Commission and the World Bank urged Romania on Monday to push ahead in its anti-corruption crackdown by recovering stolen assets following court convictions. Corruption in Romania has deterred foreign investors, while tax evasion and bribery put a further strain on the public finances. Anti-corruption prosecutors have launched investigations… – Continue reading
The European Commission (“Commission”) ruled on 21 October that tax advantages granted by Luxembourg to Fiat and by the Netherlands to Starbucks by means of advance tax rulings were unlawful under the EU State aid rules. The two Member States will be required to recover the aid, in each case… – Continue reading
Provisional Measure No. 692/2015 increases the income tax rate on capital gains earned by individuals and certain companies1 from 15% to 15%-30%. As from January 1st, 2016, when the new rules will become applicable, capital gains earned on the sale or disposition of any assets or rights located in Brazil… – Continue reading
The Bank of Japan need not boost its massive monetary stimulus this week as the labor market remains tight, a key economic adviser to Prime Minister Shinzo Abe said on Monday. Koichi Hamada, an emeritus professor of economics at Yale University, also told Reuters that the central bank does not… – Continue reading
Coca-Cola might owe an additional $3.3 billion in federal income taxes following an audit, says the Internal Revenue Service (IRS). Following a five year audit of the company, the IRS concluded that the company’s strategy of lowering its taxable income through transfer pricing, underestimates the amount the company should’ve been… – Continue reading
• There can be no straight jacket formula to determine what is meant by “provision of service,” which may include where services are i) provided; ii) rendered; or iii) utilized. • The expression ‘provision of services’ is much wider than ‘provision of rendering of services,’ and covers the services even… – Continue reading
