Bill Dodwell comments: “Chancellor George Osborne will deliver the final Autumn Statement of this parliament. We expect that most of the announcements will concentrate on the outcomes from proposals launched at earlier Budgets, together with some technical changes. There will also be the first consultation on how the UK should… – Continue reading
Non-resident UK homeowners that have spent less than 90 days in their UK property in the previous tax year will be liable to pay capital gains tax (CGT) on any gains when they sell that property from next year, the UK government has confirmed.02 Dec 2014 Private wealth tax Tax… – Continue reading
What unites the dates February 12, 2013, July 19, 2013, and September 16, 2014? They are the key dates to this point in the OECD’s crusade against base erosion and profit shifting, which will be remembered either as a well-coordinated campaign against abusive tax avoidance by large multinational enterprises, or… – Continue reading
The refusal by the Mayor of London to pay his American taxes has been hailed as “noble” and “brave” by the CEO of independent financial advisor, deVere Group. The comments from Nigel Green, founder and chief executive of deVere Group, which operates in 100 countries and has $10 billion under… – Continue reading
Stock award is a popular method of rewarding talented and industrious employees. However, employees who render services across different jurisdictions may trigger a taxable presence in two or more jurisdictions. Such employees at times need to deal with the issue of double taxation on such benefits. A normal stock incentive… – Continue reading
The founder of a prominent wealth management firm says the Mayor of London, Boris Johnson, is noble and brave to refuse to pay his US tax bill under the Foreign Account Tax Compliance Act (Fatca). Johnson, who was born in New York, has a US passport as well as a… – Continue reading
High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Email ftsales.support@ft.com to buy additional rights. http://www.ft.com/cms/s/0/0092eb7c-788d-11e4-a33c-00144feabdc0.html#ixzz3KooWgw9y Multinational companies are braced for a tax crackdown after George Osborne vowed to use… – Continue reading
Recently approved incentives for companies to set up international headquarters and international trading centres in Thailand could have a positive effect on foreign investment, say foreign executives. “After Singapore, I think Thailand could be the next big attraction for [such offices] to open here,” said Stanley Kang, chairman of the… – Continue reading
Sol Campbell owns £25m house in London and Northumberland mansion He appeared on BBC2’s Daily Politics to explain mansion tax was unfair Ex-England footballer said proposed levy was a ‘tax on aspiration’ He said Labour should instead pursue companies who had avoided tax But MP Owen Smith said people had… – Continue reading
Love him or hate him, you have to say that Boris Johnson makes a very good point about FATCA. Having been hit with a US tax bill due to his unwanted dual citizenship, Johnson – who is as British as they come in all fairness – says he will not… – Continue reading
Martin Lock was formerly the top withholding-tax specialist at the Tax Office, a role that encompassed oversight of profit shifting by multinationals. He is one of many former officers who have voiced their concerns to Fairfax Media about the challenge of arresting the slide in tax receipts from multinational companies… – Continue reading
Should London’s Mayor Boris Johnson pay U.S. taxes and file FBARs? Born in New York, the iconic London mayor never gave up his U.S. citizenship. But rather than quietly paying U.S. taxes, Mr. Johnson in an NPR interview called it ‘outrageous’ to tax U.S. citizens on their global income. Mayor… – Continue reading
When is a Chinese company not Chinese? When it’s a complex web of offshore vehicles rooted in anonymous tax havens. That description includes some of the People’s Republic’s most successful and innovative companies. It will make the country’s apparent new push on tax evasion hard to enforce. Authorities have extracted… – Continue reading
The OECD has invited comments on a discussion draft on proposed changes to the OECD model tax convention to prevent tax treaty abuse. The OECD’s recent report on action 6 of the base erosion and profit shifting (BEPS) action plan recognised that further work would be needed on the precise… – Continue reading
Boris Johnson has a point about his U.S. tax bill, but he should still cough up. The London mayor objects to the fact that his dual UK and U.S. citizenship means he has been issued with an American tax bill, and he says he won’t pay. Though many U.S. expats… – Continue reading
The concept of base erosion and profit shifting (BEPS) has been debated at various international forums following discussions at the G20 Finance Ministers and Central Bank Governors meeting and the G20 Heads of State summit in Russia last year. The Organisation for Economic Co-operation and Development’s (OECD) BEPS Action Plan… – Continue reading
The concept of base erosion and profit shifting (“BEPS”) has been much discussed at various international forums including the G20 Finance Ministers and Central Bank Governors meeting in July 2013 in Moscow as well as the G20 Heads of State meeting in September 2013. From a South African perspective, the… – Continue reading
By closing the tax gap, South Africa can reap billions of rands to benefit the economy. A global crackdown on tax avoidance has begun and South Africa is forging ahead in a bid to tackle wealthy individuals and corporates who practise this tactic. The initiative is better poised to succeed… – Continue reading
November 21: The Organisation for Economic Cooperation and Development (OECD) today released a discussion draft [PDF 179 KB] concerning follow-up work as mandated under a report with respect to Action 6 (prevent treaty abuse) under the base erosion and profit shifting (BEPS) action plan. Background The OECD in September 2014… – Continue reading
November 21: The Organisation for Economic Cooperation and Development (OECD) today released a discussion draft [PDF 179 KB] concerning follow-up work as mandated under a report with respect to Action 6 (prevent treaty abuse) under the base erosion and profit shifting (BEPS) action plan. Background The OECD in September 2014… – Continue reading
Background In July 2013, the G20 Finance Ministers, including Australia, fully endorsed the base erosion and profit shifting (BEPS) Action Plan. As a result of the Action Plan, the Australian government encouraged a new commitment to focus resources on investigating international business structures to ensure companies pay tax in the… – Continue reading
Canada and Spain have signed a Protocol to their income tax convention which, when implemented, will reduce the withholding tax rates applicable on payments of dividends and interest. The Protocol was inked on November 18, 2014, by Canada’s Ambassador to Spain, Jon Allen, and Spain’s Finance Minister, Cristóbal Montoro. The… – Continue reading
In our previous post, we looked at the ways that global corporations minimise their tax burdens by routing income through offshore tax havens and transfer pricing. The ultimate beneficiaries of these shenanigans, of course, are actual people rather than legal entities. Many of these people also take advantage of offshore… – Continue reading
Nobody likes paying taxes. The rich, however, can reduce the burden more easily than others because capital is more mobile than labour. A clever new paper in the Journal of Economic Perspectives by Gabriel Zucman attempts to measure how much government revenue is lost because of the careful re-routing of… – Continue reading
A recent binding tax ruling recognised that the historical background of a multinational group is a key factor in considering whether a non-EU ultimate parent should trigger the anti-abuse rule which applies to exemption from dividend withholding tax. In a nutshell, the Spanish Non Resident Income Tax Law (NRIT), provides… – Continue reading
November 18: The Treasury Department and IRS today released for publication in the Federal Register final and temporary regulations (T.D. 9704) concerning the treatment of U.S. and foreign persons that fail to file gain recognition agreements (GRAs) or that fail to satisfy other reporting requirements associated with transfers of property… – Continue reading
A publication in the Economic Times has caused much debate in India since after blacklisting Cyprus for not sharing information on tax evaders, India is now looking to take away the favourable tax treatment available to investors from the European tax heaven under the bilateral tax treaty between the two… – Continue reading
Recent months saw various important developments that are relevant to Sino-European trade and investment. These include (i) changes to the EU Parent-Subsidiary Directive, (ii) the entry into force of the double tax treaty between Luxembourg and Taiwan, and (iii) proposed changes to China’s Foreign Investment Catalogue and the Governmental Verifications… – Continue reading
Hybrid entities have long been a tool for corporate tax planning. While tax authorities have fought the use of such hybrid mismatches for tax planning purposes, national efforts to prevent the use of hybrid mismatches have not proven to be very efficient, explain Michael Graf and Timothy Santoli, of Dentons… – Continue reading
The Federal Board of Revenue (FBR) has proposed that no exemption whatsoever from withholding tax under Eighth Schedule (Capital Gains Tax) of the Income Tax Ordinance 2001 is available to foreign institutional investors either on the basis of avoidance of double taxation treaties or for any other reason. Through an… – Continue reading
Proposals to extend capital gains and investment income tax exemptions under Portugal’s Non-Habitual Residents Tax Regime have not been passed, say government officials It seems that the Portuguese government has shelved plans, at least for 2015, to extend capital gains and investment income taxation exemptions. However, officials say they are… – Continue reading
KOCHI: Minister for Non-Resident Keralites Affairs (NORKA) K C Joseph has urged the Central Government to withdraw the service tax imposed on foreign remittances as it would impact the hard-earned savings of non-resident Keralites (NRKs). In a letter sent to Union Finance Minister Arun Jaitley, he said that the NRKs… – Continue reading
Sears Holdings and Pinnacle Entertainment have become the latest US companies to announce that they are considering establishing real estate investment trusts (REITs), to unlock tax advantages that have been considered by some companies as an alternative to a corporate inversion. REITS do not pay corporate tax as long as… – Continue reading
Spain negotiated the largest rate reductions in its tax treaties with developing countries, out of 15 EU nations scrutinised for their record on international tax-dodging in the wake of the Luxembourg Leaks scandal. Developing countries were missing out on billions of much needed-revenue as a result of the tax rate… – Continue reading
November 12: Danish companies subject to Danish corporate income tax generally must withhold tax at a rate of 27% on dividend distributions, but the rate of the withholding tax may be reduced to 15% when dividends are distributed to Danish domiciled investments funds that are known as “IMBs” (i.e., investment… – Continue reading
Subsidiary funds companies within Irish multinational, says spokesman RH did not feature in the leaked files, but accounts for one of its Luxembourg subsidiaries show it had multibillion-euro intra-group loans going in and out of the state. Photograph: Brenda Fitzsimons Ireland’s largest indigenous multinational, building materials group CRH, has a… – Continue reading
Delhi Tribunal holds that the mere fact that one of the steps in a transaction resulted in capital loss for the taxpayer would not make the series of transactions a sham. Karnataka High Court holds that shares bought at a premium, and sold at a lower value to individuals (ex-employees… – Continue reading
NEW DELHI: After reaching a significant breakthrough in information exchange on bank accounts with Switzerland, the Narendra Modi government has now turned the heat on European tax haven Cyprus as part of its fight against black money. The government wants to drop a provision in the tax treaty between the… – Continue reading
Being a non-UK resident can offer certain tax advantages however new regulation around capital gains tax proposed to take effect next year, may have implications for non-residents when they dispose of a residential property as Kirstie Carr of Mogers Drewett explains. Capital gains tax (CGT) is a tax which applies… – Continue reading
After the US bailed out the insurance conglomerate AIG in 2008, the company’s employees kept to business as usual—which included setting up complex tax structures to avoid taxes in Europe and Japan. In 2008, the company was on the brink of a bankruptcy that would have created huge losses throughout… – Continue reading
November 7: The KPMG member firm in Luxembourg has prepared a report that addresses the availability of withholding tax refunds for UTICS funds, including Luxembourg SICAVs, in Sweden. Swedish courts have confirmed that many types of investment funds are eligible for a full refund of Swedish withholding tax. Many funds… – Continue reading
The Australian tax office wants comments on a 2016 plan for buyers of some property worth more than AUS$2.5m sold by foreigners to withhold 10% for the tax office Overseas owners selling prime property in Australia may have 10% taken out as part of the deal, under tax proposals being… – Continue reading
An overhaul of the Grand Duchy’s corporate tax law and administration is required Occupying a damp 1,000 square miles where the French, German and Belgian borders meet, the Grand Duchy of Luxembourg is a far cry from the palm-fringed tropical island tax haven of popular imagination. In fact the country… – Continue reading
Vodafone sign in India. Photo: Ishan Khosla. Used under Creative Commons license. Vodafone recently won a rare – but potentially very significant – victory over Indian tax authorities. The Bombay High Court dismissed the government demand for the company to pay 30 billion rupees (about $490 million) for a share… – Continue reading
The taxation of a person is based on two principles: Source and Residence. A person for tax purposes includes an individual, trust, company, partnership and any form of business arrangement one chooses to take on. It should be noted that with globalisation, there is a constant mix of these two… – Continue reading
NEW YORK — Shifting the address of his Liberty Global Inc. from Colorado to London last year didn’t just put billionaire John C. Malone in a position to reduce his company’s tax bill. He also took precautions to avoid the capital-gains hit that the so-called inversion would trigger for him… – Continue reading
PARIS–(BUSINESS WIRE)–On September 2, 2014, under the aegis of the President of the Commercial Court of Paris, LVMH Moët Hennessy – Louis Vuitton (“LVMH”) and Hermès International (“Hermès”) entered into a settlement agreement (the “Settlement Agreement”) aimed at restoring a climate of positive relations between them. “Communiqué – Distribution exceptionnelle… – Continue reading
New York • Shifting the address of his Liberty Global Inc. from Colorado to London last year didn’t just put billionaire John C. Malone in a position to reduce his company’s tax bill. He also took precautions to avoid the capital-gains hit that the so-called inversion would trigger for him… – Continue reading
With FATCA having been officially implemented for the most part this past July 2014, withholding agents will want to be especially vigilant in their duties and obligations regarding the solicitation and receipt of the appropriate Form W-8 from foreign persons. They will also want to be up on the rules… – Continue reading
The OECD’s Action Plan on BEPS was published in July 2013 to reform the international tax system. The Action Plan identified 15 Actions to address BEPS. Seven of the 15 Action Plan items are now moving out of the station. I. Introduction On September 16, 2014 the OECD, together with… – Continue reading
