The Regulation of the Law Regulating Transfer Pricing was published last month and is based on the principle of free competition (arm’s length) where transactions between related parties should be carried out at market prices, i.e. those used in comparable transactions between independent parties in similar conditions. The regulation determines… – Continue reading
MTN has consistently prided itself as the foremost telephone company that is getting Nigerians talking the most. Now the South African company is about to set tongues wagging across networks with revelations that it has routinely been shipping billions of naira overseas to avoid paying its fair share of tax… – Continue reading
The Anti-money Laundering (AML) Bill has remained stuck in the Senate Standing Committee on Finance since February this year. The opposition, which has the majority in the upper house, is not letting it go through because of its misplaced fears that it would be misused by the Federal Board of… – Continue reading
Since the initiation of the U.S.Internal Revenue Service’s (IRS) Offshore Voluntary Disclosure Program (OVDP) which originally began in 2009 and the Streamlined Filing Compliance Procedures first offered on September 1, 2012, the IRS recently reported that more than 54,000 taxpayers have come forward and the result is more than $8… – Continue reading
India has told the International Court of Justice that it will soon appoint an arbitrator to resolve the Rs 10,247-crore tax dispute with British oil explorer Cairn Energy Plc. Cairn on March 10 sought arbitration under the India-UK Bilateral Investment Protection Agreement against the tax demand raised on a 2006… – Continue reading
The Organisation for Economic Cooperation and Development (OECD) has been leading the charge to improve transparency in tax administration and curb tax avoidance by multinational companies. Endorsed by the G20 nations, including India, OECD recently came out with a package of measures and a road map to tackle base erosion… – Continue reading
OECD Secretary General Angel Gurria, “Base Erosion and profit Shift (BEPS) to Combat Action Plan” s stated would be the most radical reforms in international taxation system, “BEPS Action Plan, Turkey will be one of the biggest acts in and heritage in the G20 presidency” he said. Gurria, recently in… – Continue reading
The European Commission looks highly likely to make a finding against Ireland in relation to its tax arrangements with Apple, following two similar findings during the week involving Starbucks and Fiat. It is perplexing that the EC doesn’t just come out and make the announcement. The delay is leading to… – Continue reading
Bermuda is battling hard to make its voice heard in Washington’s corridors of power as the controversy around hedge fund reinsurers rumbles on. The Association of Bermuda Insurers and Reinsurers (ABIR) had a team of company tax directors in the US capital city to brief congressional staff on its position… – Continue reading
The African Union Advisory Board on Corruption (AUABC) recently requested major multinationals operating in Africa to be more open about the taxes and royalties they pay governments to improve transparency and accountability. Although a reasonable request, this is a tall order when you consider that often it is the governments… – Continue reading
NEWARK, Del. — It may not summon up a sense of international intrigue like Geneva or Luxembourg, but this small city, just off the Interstate and down the road from Wilmington, can now boast that it has joined those more glamorous locales as a tax haven for art collectors. Fritz… – Continue reading
Rwanda has commissioned an audit into recent merger and acquisition deals involving foreign firms in its latest effort to clamp down on tax avoidance among multinational corporations. This comes amid growing concern that multinational companies move profits from the countries where they are generated and, in so doing, reduce national… – Continue reading
DOZENS of Winchester properties worth more than £100 million are owned by firms based in offshore tax havens. High street shops, restaurants, care homes, a health clinic and even a single parking space are owned by companies benefitting from low tax regimes overseas. Burma Road student village, sold by the… – Continue reading
Since the revelations on government surveillance and data capture by Edward Snowden, journalists have rightfully raised concerns about governments’ insatiable appetite for data collection and the resulting encroachment on citizens’ civil liberties. In the EU an individual’s right to privacy is regarded as a human right in accordance with Art…. – Continue reading
The Cayman Islands Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations, 2015 (the “CRS Regulations”) were issued on 16 October 2015. Cayman Islands Government Industry Advisory – CRS Regulations Are in Effect The CRS Regulations, which are the first part of two in the roll-out of the Cayman… – Continue reading
THE House of Representatives on Tuesday postponed its vote on the Income Tax (Amendment) (No 2) Act, 2015, which includes provisions for the introduction of transfer pricing rules in Jamaica. Minister of Finance and Planning Dr Peter Phillips agreed to postpone taking a vote on the Bill, also referred to… – Continue reading
According to recent estimates, Chinese investors represented the largest group of foreign investors in U.S. real estate in the second quarter of 2015 with $1.9 billion in acquisitions. In the last 12 months, Chinese investors acquired $5.9 billion in commercial U.S. real estate, and Asia was second overall to Europe… – Continue reading
The Indian government’s initial unsuccessful efforts to unearth billions of dollars of undeclared foreign assets – some believed to be hidden in Swiss banks – highlight the complexity of vehicles used to move money illicitly. Earlier in the year, a new law on black money came into effect. It included… – Continue reading
The key corporate tax measures in the Finance Bill show clear signs of the international scrutiny now surrounding multinational tax. The main new measure, the knowledge development box offering a lower tax rate on profits earned as a result of research and development, has been strictly drawn up to comply… – Continue reading
Leading family offices in Latin America and the Caribbean are going through a transitional period, says Steven Cantor, managing partner of Cantor & Webb, a Miami-based law firm, reports the Financial Times. “As the world moves to tax transparency, with a crackdown on undisclosed tax savings in Swiss bank accounts,… – Continue reading
Taiwan and Mainland China signed the “Cross-straits Agreements for the Avoidance of Double Taxation on Income and Solidifying Cooperation with respect to Taxes” (hereinafter referred to as “Cross-straits ITA”) on 25 August 2015. After the draft Article 25-2 of the “Act Governing Relations between the People of the Taiwan Area… – Continue reading
While stocks such as Hindustan Unilever (HUL) and Maruti Suzuki have outperformed the markets by a wide margin in the last couple of years, the stocks have sustained the performance even over longer periods. Despite the hue and cry over royalty payments by Indian subsidiaries of multinational companies, these companies… – Continue reading
The New York billionaire is aiming his financial might at members of Congress who aren’t willing to cut deals on corporate tax policy. Sure, Carl Icahn might make money—lots of money—on his $6 billion stake in Apple Inc. if a political campaign he announced Wednesday to cut taxes on companies’… – Continue reading
David Cameron threw the proverbial cat among the pigeons in July when, with a steely glare at the UK property industry, he warned that the UK must not become “a safe haven for corrupt money from around the world” and that “there is no place for dirty money in Britain”…. – Continue reading
On October 22, the United Kingdom’s tax and customs authority announced a public consultation for its proposed modification to its existing patent box regime. The patent box regime is intended to provide incentives for companies that develop patents in the UK and to ensure new and existing patents are further… – Continue reading
Jakarta. The Indonesian government revealed its fifth stimulus package on Thursday in a bid to prop up the economy by, among others, scrapping double taxation imposed on companies called real estate investment trusts to improve property investment. The package was announced by Cabinet Secretary Pramono Anung, Coordinating Minister for Maritime… – Continue reading
Multinational oil giant Chevron has been hit with a tax bill of about $300 million after losing a landmark profit-shifting case that could have global implications for the way tax is assessed. The Australian Tax Office’s case in the Federal Court case has been closely watched by the tax and… – Continue reading
The company that is not a taxi company, which has drivers that are not taxi drivers, who carry people around that are not clients, Uber, is not only killing the taxi business, it is also avoiding paying taxes. The company uses a trick known as “the double-Dutch.” It is perfectly… – Continue reading
MUMBAI: Technologies that are developed in India but their patents registered in tax havens may come under the domestic tax net from the next financial year, when the country is expected to adopt a new world standard aimed at preventing abuse of double taxation avoidance agreements. Many multinational and local… – Continue reading
Introduction The Internal Revenue Service (IRS) recently replaced Revenue Procedure 2006-54 for requesting assistance under the mutual agreement procedure (MAP) article of US tax treaties, and Revenue Procedure 2006-9 for requesting advance pricing agreements (APAs). New Revenue Procedures 2015-40 and 2015-41 largely track draft procedures issued in 2013 (Notices 2013-78… – Continue reading
Oil and gas giant Chevron faces a massive tax bill after losing a long-running battle with the tax office over allegations the company used internal lending to reduce its Australian taxes. The Federal Court this morning ruled against Chevron in a landmark legal case that had argued the US multinational… – Continue reading
Major US investor Carl C. Icahn and the Chief Executive Officer of TechNet, Linda Moore, have both recently written letters to leading lawmakers pointing out that the passage of international tax reform by Congress has become a matter of extreme urgency. In his letter, Icahn announced that “the time has… – Continue reading
Cross-border transactions have always been a challenge to tax authorities India’s transfer pricing rules and the rising number of litigation over transfer pricing assessments have been a concern for the global business for some time. According to estimates by some experts, India has the highest number of transfer pricing litigations…. – Continue reading
On 21 October, the European Commission (“EC”) adopted its first decisions in its investigation into Member States’ tax rulings. The investigation, which began in June 2013, has also targeted tax rulings given to Apple and Amazon as well as Belgium’s so-called “excess profits regime”. Although the investigation is conducted under… – Continue reading
Expats living in the United States enjoy greater financial comfort than U.S. expats living abroad, according to a recent HSBC survey. Financial findings from the report, “Expat Explorer: Balancing Life Abroad,” revealed key differences between expats living in the U.S. and U.S. citizens living abroad. According to the report, expats… – Continue reading
Chevron lost an appeal in Australian federal court that will see the US supermajor pay more than US$232 million (A$322 million) in back taxes, in addition to fines, after losing a case with the Australian Tax Office (ATO). The Aussie federal court ruled against Chevron, stating the company wrongly shifted… – Continue reading
The Dutch Secretary for Finance, Eric Wiebes, has reported to the House of Representatives on the impact of the OECD’s base erosion and profit shifting project on Dutch tax rules. His letter, published on the Dutch Government website on October 19 in English, splits measures into those that concern domestic… – Continue reading
The entire multi-billion euro aircraft leasing industry here paid Irish corporation tax of only €23m last year, reports the Irish Independent. That is according to figures provided by the Minister for Finance, Michael Noonan, who confirmed that the €23m paid in corporation tax last year was down from the €29m… – Continue reading
Prime Minister of St. Kitts and Nevis, Dr. the Hon. Timothy Harris, was the featured speaker at the Financial Services Regulatory Commission – St. Kitts Branch’s (FSRC) 2nd annual Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) seminar at the St. Kitts Marriott Resort on Wednesday, October 21, reports SKN Vibes…. – Continue reading
Foreign tax credit available to taxpayers even on a portion of exempt income. Exempt income (under section 10A) is chargeable to tax under section 4 and 5 of the ITA although no tax may actually be payable. Actual payment of the tax is not necessary for claiming foreign tax credits…. – Continue reading
Global assets under management are expected to climb to around $102 trillion by 2020 according to a new report from PwC. The report – Asset Management 2020 and beyond: Transforming your business for a new global tax world – notes that the boom in AUM is due to be caused… – Continue reading
Pascal Saint-Amans sups water from a plastic cup, coughing and spluttering. There’s a weariness about him. He’s battling a cold, and is feeling “bloody sick”. The state of his health isn’t terribly surprising given his recent punishing travel schedule. New York last week preceded by Peru, where G20 finance ministers… – Continue reading
Ayar Law Group speaks about Amnesty Programs expiring as foreign banks comply with FATCA. Oct. 22, 2015 / PRZen / DELHI, India — The unofficial period of grace to reveal foreign bank accounts to the IRS is ending for U.S. taxpayers. Those who don’t comply with the law may soon… – Continue reading
its tax bulletins, the legislation will apply to transactions even between unconnected parties if the non-Jamaican party is in a tax haven. In addition, it will take into account the use of captive insurance companies, that is, insurance companies established by a parent group or groups with the specific objective… – Continue reading
From 1 October 2015, all parties to transactions which include a transfer of land or an interest in land have to complete a “tax statement” as part of the registration process. We summarise how the new rules apply to trusts. New requirements in brief The tax statement is a one… – Continue reading
Multinational companies (MNCs) in India which have been evading tax on profits created due to a function carried out in the country by shifting contractual risk to some other location may soon find it difficult to escape the domestic tax net. Experts closely working with the government on how to… – Continue reading
Mauritius beats Singapore as the world’s top route for foreign investment to India and is a hub for thousands of firms managing half a trillion dollars in assets. But there are only a sprinkling of office blocks in Ebene Cybercity, the heart of the tiny Indian Ocean island’s financial services… – Continue reading
“If we do not achieve growth, revenue will not increase. If revenue does not increase, expenditure cannot be expanded.” It is with this statement that the Minister of Finance set the tone of the Medium Term Budget Policy Statement (MTBPS) which he presented on Wednesday against a fiscal backdrop of… – Continue reading
By Martina Neuwirth and Thomas Kattnig [This blog article published on July 9, 2015 is translated from the German on the Internet, http://blog.arbeit-wirtschaft.at.] June 23 was the international day of public services. Did you know that? Provision of these services – water, hospitals, schools, culture, energy, streets, public transportation and… – Continue reading
Congress needs to lower the corporate tax rate from its current 35% to discourage U.S. insurers from moving offshore, according to the head of Travelers Cos. Inc. “Reducing this rate would end a self-defeating policy that distorts corporate behavior, weakens domestic companies and ultimately harms the U.S. economy,” wrote Travelers… – Continue reading
