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OECD Has Published Comments Regarding Taxation of Offshore Indirect Transfers

Published: 11/12/2017 | news

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#Offshore accounts #Offshore schemes #Offshores #Офшори

The Organization for Economic Cooperation and Development has published the comments that were received during the consultation on the draft of a new tool regarding the taxation of the so-called Offshore Indirect Transfers. We remind that the last ones constitute transactions for the sale of a legal entity located in one country and owning any immovable asset located in another country, by a non-resident of the country where the asset is located. The developed tool is part of the OECD program to assist developing countries in creating their own tax policies for Offshore Indirect Transfers. The Organization for Economic Cooperation and Development has justified its actions by the concern that such countries may have difficulties in administration of tax systems because of a lack of appropriate competencies and resources. Thus, the attempts to minimize the tax burden have become more frequent among the multinational corporations, and there is no single principle for considering these transactions. In addition, the issue is not regulated by the BEPS (Base Erosion and Profit Shifting), the action plan of the OECD on the counteract of the tax base erosion and profit shifting from...

Malta made changes in law regarding tax credits

Published: 04/09/2017 | news

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#Malta

Since the beginning of this year, Malta has issued a number of official notices, providing for the changes in the law regarding tax credits. Thus, the Official Notice No. 140 amended the Regulations on Tax Credits for Micro Enterprises and Private Entrepreneurs (Tax Credits for Micro Enterprises and the Self-Employed Regulations). In accordance with the revised provisions, the definition of "eligible costs" now includes family enterprises in the definition fixed by the Family Business Law. Yet, a clause was added to the Regulation, according to which since 2018, the family business can be granted a tax credit for an amount not exceeding 50,000 euros. The loan must be used during any 3-year...

DTA entered into force between Russia and Hong Kong

Published: 08/08/2016 | news

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#Double taxation #Exchange of tax information #Hong Kong #Russia

Comprehensive agreement for the avoidance of double taxation (CDTA) was signed in January of this year between Hong Kong and Russia, which came into force on 29 July 2016. According to the sources, this agreement shall remain in force for Hong Kong each year since its signing to double taxation, which took place on or after April 1, 2017. The CDTA is informed about what is required to support efforts to expand the tax obligations undertaken by the two countries in the framework of the «Belt and Road», which is a project of the Chinese government for the economic development aiming at the integration of trade and investment between the approximately 60 countries in Eurasia. In the absence of the CDTA program, of Hong Kong companies income, which conduct their entrepreneurial activities with the help of permanent missions in Russia and taxed in both places if their earnings was received in Hong Kong. On this basis, in the new agreement, double taxation is eliminated, and now any Russian tax paid by the companies on their earnings, will be allowed to tax payable in Hong Kong. Besides, in accordance with this agreement, the rate in Russia on income tax on royalties,...

EU signed tax agreement with IOTA

Published: 01/08/2016 | news

Tags:

#EU #Exchange of tax information

The Intra-European Organization of Tax Administrations (IOTA ) has signed tax agreement with European Commission to develop the solution of more effective way to common targets which this two brunches are working on and also one kind of them activity to prevent double tax avoidance. According to announce of IOTA 26 of July the main brunches of co-working in agreement frames include battle against swindle, information exchange, alternate support, support of tax departments to increase the level of maintenance by taxpayers. The agreement was signed between IOTA and the Taxation and Customs Union Directorate General (DG TAXUD) of the European Commission 7 of July. Edery said: «Commission has get a support IOTA from the day it start exist and attentively watching it progress. We have common target to support European states in development and modernization of tax administration. Based in Budapest, IOTA is a non-profit intergovernmental organization, created to promote using the best practice in tax administration direction and more effective co-working with 46 tax authorities’ members. Author: Olena Kutova senior lawyer of the Finance...

Italian-Swiss TIEA goes into force

Published: 27/07/2016 | news

Tags:

#Exchange of tax information #Italy #Switzerland

The Italiam Ministry of economy and finance claimed that protocol about tax information of double tax agreement between Italy and Switzerland wich was signed 23 of February, 2016 goes into force 13 of July, 2016. The agreement protocol comprises all kind of taxes, point out that country can't deny to represent asking information only because this information has in keeping on bank or any other financial constitution. Much less the country need to empty of all own inner legal proceedings before than protocol can ask information from other. Also need to indicate person or persons who are the object of asking request, period of time need to ask the information, descrabing of information need to and the reason of request if its known, the name and adress of suppose owner of information. This specifications was added for avoiding any want of judgment, general compromative information, and he also added that the second list of specifications don't using for placing obstacles on the way of effective agreements between these countries. This protocol also approves that this contributions will use retrospectively to the data that existed prior to or after the date of...

Parliament of Holland approves gambling tax

Published: 18/07/2016 | news

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#Holland

The lower house of Dutch parliament approved rule, which can regulate and provide online gambling taxation. Remote Gambling Bill has plan to open Dutch gambling market for foreign outer gambling companies which provide taxation about 29 percent of gamble gross revenue, the same way of taxation have had already gamble land-based operators. According to previous version of draft law, tax for online gambling fixed about 20 percent. The acting coalition included remark to legislation in the beginning of this year for agreement this tax. Nevertheless, the final version of this law approved by the law house 7 July contains measure of decreasing about 25 percent at the end of three years period. In this proposing for the first time was planned to go into force this rule in 2015, but now they were waiting for voting in the Senate. In case of approving by upper house, expect that the process of application submission a new license for gambling in the first half of the next year, and that this new regime will fully up in the middle of 2017 year. Author: Olena Kutova senior lawyer of the Finance Business Service company ...

General information about the global standard automatic exchange of information on accounts (AEOI & CRS)

Published: 06/06/2016 | news

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#Exchange of tax information #Offshores

What is the Global standard of automatic exchange of information about financial accounts (AEOI & CRS) (hereinafter - the "Global standard")? The global standard of automatic exchange of information on financial accounts (original title in English - Global Standard for Automatic Exchange of Financial Account Information in Tax Matters and Common Reporting Standard) is an international political initiative of the G20 member countries and countries participating in the Organization of Economic Cooperation and development (OECD / OECD), aimed at joint international fight against tax evasion and the illegal concealment of undeclared income in foreign financial institutions. How the requirements of Global standard implemented in real life? The OECD has developed and published the fundamentals and practical tools implementation of the Global standard, which were endorsed by the member countries of G20 at summit in September 2014. International obligations of countries participating in the global standard, in the vast majority are fixed in the form of accession to the Convention on mutual administrative assistance in the tax area on 25.01.1988 and by the signing and...

Japan-Panama, the tax information exchange

Published: 25/05/2016 | news

Tags:

#Exchange of tax information #Japan #Panama

Japan and Panama have agreed to conclude an agreement on the exchange of tax information. Negotiations for this agreement were launched after the Japan-Panama summit meeting which took place on April 20 this year between Prime Minister Shinzo Abe and President of Panama Juan Carlos Varela. The two leaders shared the view that Japan and Panama must immediately begin formal negotiations on an agreement on the exchange of tax information. Currently it is likely that Japan will become the first country to sign an agreement on the exchange of tax information with Panama after the leak "Panama Papers" earlier this year. The agreement will include the rules in accordance with the general standard of the automatic exchange of tax information between countries created by the Organization for Economic Cooperation and Development. Author: Sergey Panovmanaging partner Finance Business...

Canada has signed an agreement on international reporting

Published: 17/05/2016 | news

Tags:

#Canada #Exchange of tax information #Financial statements

Canada has signed a multilateral agreement on reporting between countries. The first exchange of information is expected to be held in June 2018. Budget Canada 2016 includes a proposal to require companies with annual revenues of the consolidated group of USD 750 million or more, to submit annual reports on their income and taxes paid and accrued on the number of employees, capital, retained earnings and tangible assets for each tax jurisdiction in which they do business. Canada has the opportunity to share the information contained in the reports with tax treaty partners which also comply with the necessary standards of accountability. According to the Agency Revenue Canada, this information will allow countries to improve their ability to check and detect aggressive international scheme of tax evasion, as well as contribute to making global operations affected companies more transparent and that they pay the relevant taxes in the country which is generated by their profit. Currently 32 jurisdictions have signed the agreement on the international exchange of information. Canada noted that the signing of the agreement is part of a four-point action plan to...

Exchange corporate tax return in Europe

Published: 28/04/2016 | news

Tags:

#EU #Exchange of tax information

The Committee on Economic and Monetary Affairs of the European Parliament voted in favor of the proposal for automatic exchange of country-by-country reports. MEPs approved a report on the proposal by 45 votes, with 11 abstentions. Dariusz Rosati, who prepared the report, said that the initiative is "an important step in the fight against harmful tax practices within the EU. This should increase transparency and reduce harmful tax competition." Under the proposal, multinational companies with total consolidated revenues of EUR 750 million or more will need to submit statements of EU countries. This rule will apply to all countries with which the company operates. The report stresses that the Commission should have full access to the information exchanged between the tax authorities of the countries to give the opportunity to assess whether they practice in accordance with the rules of state aid. This is especially important for small and medium-sized companies who work in one country only, as they "usually pay an effective tax rate which is much closer to the official rates than multinational firms." The Commission also added that "the domestic companies do not...

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