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The changed tax rules for Swiss banks

Published: 04.10.2016 |

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#Banks #Switzerland

Switzerland has amended the "too large to fail" legislation to reduce the tax burden in some banks. The Swiss Federal Council requested the Federal Department of Finance to prepare a draft consultation document on changes to the position of participations in the deductions TBTF legislation. He noted that the proposed reform would "not allow the tax load of the leading holdings of systemically important banks from raising together with the conditional issuance of convertible securities (CoCos), written off bonds and bail bonds." The Federal Council has proposed that the interest payments on cocos, decommissioned bail bonds and bonds, were not taken into account when calculating the deduction. In accordance with current regulations, the deduction is reduced, because the interest in cocos, written off bonds and bail bonds, regarded as financing costs. The Federal Council said: "The deduction - a system associated with the current legislation, ie all interest on debt capital lead to a reduction in the gross income of all corporations and cooperatives This can lead to a higher tax burden.". The Federal Council said that some banks are required by supervisory law circulate such...

In Japan double tax go into force

Published: 03.10.2016 |

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#Double taxation #Japan

Protocol double tax agreement tax between Japan and India came into force on 29 September. The Protocol updates the provisions on the exchange of tax information existing contract. It also amends the list of state financial institutions or central banks eligible for exemption from income tax at source of interest payments presentation in Article 11. The revised pact is active in Japan since 1 January 2017, and in India from April 1, 2017. The new double tax agreement with Germany Japan also entered into force on 28 September. The new contract provides for more favorable conditions for companies engaged in trade or investment between the two territories. Agreement again provides tax exemption at source for interest and royalties. Income from dividends will be removed if the company which receives income has a 25 percent share in dividends at least 18 months. Dividend income might otherwise qualify for a reduced rate of five per cent if the company which receives the dividends are held at least five percent of the company paying the dividends for at least six months. Otherwise, it will apply the rate of 15 percent. For updated provisions on the exchange of tax information, which...

Australia introduces the latest round of reforms of higher

Published: 30.09.2016 |

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#Australia #Reforms

The Australian Government has published draft legislation for the implementation of the second tranche of the proposed reforms to the taxation of pension contributions. As part of the reforms, the government will: Implement AUD1.6 million balance transfers peaks to a limited number of people could be held in a tax-free retirement phase; Lowering the preferential contributions AUD25,000 a year; Lowering the income threshold at which individuals are required to pay an additional 15 percent tax contribution from AUD300,000 to AUD250,000; Allow individuals with remnants of at least AUD500,000 "carry on" Do not use the top of the privileged "space" for up to five years; Make sure that the transition to retirement income stream has access for the purpose for which they were designed, not to tax minimization; and: To abolish the anti money-losing situation. In a joint statement, Treasurer Scott Morrison and Minister of Revenue Kelly O'Dwyer said: "The reforms will make the system fairer, more flexible and more stable majority of Australians - 96 percent of people with pension - or will be completely switched off or will not be affected by these changes.". Consultation on the proposals...

The European Parliament began inquiries in Panama

Published: 29.09.2016 |

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#EU #Panama

The European Parliament began its investigation following the hearing Panamanian documents. Committee of the European Parliament to investigate money laundering, tax evasion (Panama) held its first full meeting on 27 September. It consists of 70 members, including the chairman and four deputies. It will investigate the allegations of wrongdoing and improper administration in the application of European legislation on money laundering, tax evasion and tax avoidance by the European Commission or Member States. Its creation was due to a leakage of 11.5 million documents relating to Panamanian law firm Mossack Fonseca. Data relating to the ownership of bank accounts and offshore companies in 21 jurisdictions, and cover a period of almost 40 years, until the end of 2015. Parliament said that the journalist Frederic Obermayer suggested that Panama's documents represent only the tip of the iceberg, and argued that EU banks are actively helping their clients evade taxes. Parliament added that the Swiss journalist Oliver Zilmen described the use of the system, including intermediaries, such as, for example, Swiss lawyers who actually run companies, Russian money and banks in Cyprus and...

Kenny Ireland seeks to 12.5 percent CIT rate

Published: 28.09.2016 |

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#Ireland #Taxation

Irish Prime Minister Enda Kenny confirmed its commitment to the 12.5 per cent rate of corporate tax "from the visual point of tax certainty." In his speech to the American Chamber of Commerce of Ireland (AmCham Ireland), Kenny noted that the rate will not change, and acknowledged that "this is an important element to consider with US investors to come here in Ireland." Bob Savage, president of the American Chamber of Commerce of Ireland, welcomes the statement by Kenny. According to him, the Chamber "deeply appreciates the unequivocal declaration of the Prime Minister that his government will firmly defend our reputation as a blood pro-Corporate Business of the country, which is determined by justice and the determination processing." In his pre-budget problem, of AmCham Ireland Ireland stressed the need "to evolve a corporate tax regime in response to the post-OPP landscape, to remain competitive." Comments Kenny later duplicated Finance Minister Michael Noonan. "We could almost put it on the flag right now, because everyone knows at the international level, that the figure is 12.5 per cent. In fact, when entrepreneurs are thinking about Ireland, they automatically think of 12.5...

Switzerland amends for keeping tax resolution

Published: 27.09.2016 | news

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#Switzerland #Taxation

Swiss Federal Council proposed an amendment to the tax deduction management, maintenance is easier finance group. The Council noted that the group created in Switzerland often carry out targeted measures to finance overseas, thus avoiding any deductions that would be related to funding issues, conducted by a group of companies established in Switzerland. The Council added that the Swiss economy as "pass some of the value added in this sector." The proposed amendment to the Retention Tax Resolution can affect groups in which the Swiss group companies (guarantor) provides a guarantee for bonds of foreign companies and groups (the issuer), belonging to the same group. According to the amendment, interest payments within the group made Swiss guarantee will no longer be subjected to withholding taxes. In December 2014, the Federal Council proposed move to a paid agent of the system under which the debtor will transfer all worth paying agent (usually a bank). Implementation of the proposals but has been suspended pending the results of the referendum on popular initiative. Federal Council announced that its 2014 proposal would solve the issue of improving the financing of the group,...

US Senate Progresses pension reforms

Published: 26.09.2016 |

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#Funds #USA

Senate Finance Committee unanimously approved a bipartisan bill layout - improved savings and retirement Act 2016 - to make some changes in the pension provisions of the tax legislation. For example, in accordance with the present law, a person who has reached the age of 70.5, before the end of the year can not make contributions to a traditional individual retirement account (IRA). The law will revoke this ban. Ron Wyden (D - OR), Ranking Member of the Committee, said that the renewal provisions of the retirement age "is essential, especially because so many Americans are living longer, if they can afford to save for retirement, they must get permission to do that" . The second proposal is to change the calculation of the dollar limit amount on a non-refundable tax credit, currently provided for beginners small entrepreneur's cost adopted new qualified pension plan, a simple IRA plan (or SEP), provided that the cover of the plan, at least one is not of the strongest workers' compensation. Calculation of the three-year loan, currently less than USD500 per year, or 50 percent of qualified start-up costs. Under the proposed changes, a fixed amount of dollars for the fiscal year...

BHP defends its position in the Australian tax dispute

Published: 23.09.2016 | Без категории

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#Australia #Taxation

The company BHP Billiton said its tax dispute with the Australian tax authorities (ATO) is a matter of assessment and does not entail tax evasion. BHP Billiton Annual Report for 2016 shows that at present it has a transfer pricing dispute with the ATO for the amount of tax payable as a result of sales of Australian products in our marketing business since 2003. According to the report, the dispute relates to the price at which products were sold to an Australian. The report notes that BHP Billiton has made a partial payment for these corrected estimates of 50 percent of the basic tax. She added that the assessment of the dispute is essential for calculating the amount of responsibility for the now defunct useful resources rental tax (MRRT). The company has received refined assessment MRRT total. The report said that BHP Billiton disagree with the position of ATO and object of the corrected estimates. The Company intends to continue to defend its position and will initiate legal action if necessary. Author: Olena Kutova senior lawyer of the Finance Business Service company ...

Netherlands announces tax plan

Published: 22.09.2016 | Без категории

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#Netherlands #Tax planning

The Dutch government has announced measures to simplify aspects of the tax regime and the tax administration. The majority of people will get tax cuts, certain tax procedures will be simplified, and the Dutch tax will be changed to the mode of dividend under the new tax plan, announced by the Ministry of Finance of 20 September, small and medium-sized businesses. Proposed dividend tax changes aimed at leveling the tax treatment of dividends to the holding of cooperatives, which are frequently used in international structures of the holding company, along with private companies (BVS) and public companies (PNV). Under existing rules, holding cooperatives, as a rule, are not subject to tax on dividends in the Netherlands, in contrast to the terminal and NVs. The government intends to eliminate this difference, but at the same time to release the distribution of dividend tax in cases where shareholders holding cooperative, the NV or BV, residing in a jurisdiction with a tax treaty with the Netherlands, subject to a minimum of five per cent threshold of holding. These changes are expected to be introduced from 1 January 2018. With regard to income tax, the ministry said that "the...

Japan – EU accelerate free trade agreement

Published: 21.09.2016 |

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#EU #Japan

Japanese and European trade and industry association addressed a joint letter to the leaders of the European Union and Japan, urging them to "make all efforts to speed up" the current negotiations on a free trade agreement. 16 September letter from the Japan Business Federation, Japan Business Council in Europe and the European Business Council in Japan seeking to enter negotiations this year. EU and Japan at the recent G7 summit pledged to arrange a free trade agreement "as early as possible in 2016". Currently, the EU and Japan are negotiating a free trade for more than three years, the letter stated: "While the 16 rounds of talks and negotiations were entered into the stage of maturity, a successful conclusion is not yet visible. ... We believe that the EU Japan and familiar with the views of each other, and both sides must now be crucial to the outstanding issues. " "If in fact, the association called on leaders to do everything possible to ensure that the free trade agreement will lead to commercially meaningful market access, removal of tariff and non-tariff measures, and include an ambitious chapter on procurement." The differences that remain between the two sides...

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