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Recent News

US Treasury limits the foreign tax credits

Published:   20.09.2016 |

The US Treasury and the Internal Revenue Service (IRS) issued a notice 2016-52, which declares its intention not to allow the US multinational, which has been the subject of foreign-initiated adjustment of the tax the use of foreign tax credits with no corresponding income repatriation. The notice was issued subsequent retroactive studies by the European Commission (EC), against US tax practices of transnational corporations, state aid, since a claim against Apple in the amount of up to EUR13 billion (USD14.5 billion), plus interest. Treasury Secretary Jack Lew has recently pointed out that the EC 'actions also threaten to undermine the corporate tax base of the United States. US companies can claim foreign tax credits to the account of the United States tax for any tax-related payments to the Member States." IRS will negate any attempt to divide the affected company additional taxes payable of related income, and thereby reduce their US tax bills. Separation of probable foreign taxes from the corresponding revenues will now be prevented, as a rule, putting the right to request loans is income not included in the taxable income of the United States. New rules in the...

Ireland follows the existing tax regulations

Published:   19.09.2016 | news

The Irish Government has proposed that the tax authorities carried out a full review of tax decisions every five years. In a statement to the Dáil Éireann, the lower house of Parliament on 7 September 2016, Finance Minister Michael Noonan said that the tax authorities will amend the relevant guidance and regulations that will ensure that tax regulations are to remain in force for five years without a full review. Noonan added that the income will be published in its annual report the number of inmates each year, so as to fully ensure the confidentiality of the taxpayer. The announcement was made shortly after the conclusion of the European Commission have been made that the two tax rulings issued by Apple Ireland significantly and artificially lowered the taxes paid by Apple in Ireland since 1991. Irish Parliament endorsed the government's motion to appeal against the Commission's decision - 14 of September. In a statement, Noonan said that "a reaction to the decision of the Commission has, at times, an outdated and unfair caricature the position of Irish tax. It is a caricature that is contrary to the evidence in recent years. The facts show our constructive engagement of the...

Wales has delegated land tax deal

Published:   16.09.2016 |

Wales Government introduced legislation to replace the UK stamp duty land tax (SDLT), together with the land transaction tax (LTT), from April 2018. LTT will be payable on the purchase or lease of the building or land in Wales at a certain price. It will broadly mirror the UK SDLT, to ensure consistency and stability for businesses and home buyers. Nevertheless, some changes will be made taking into account the Welsh circumstances and priorities. LTT mode will include a comprehensive general rule against tax evasion (Gaar) and targeted generally against tax evasion (Taar), which will be applied to all reliefs. This would eliminate the existing two British relief relating to the demutualization of insurance companies and building societies, as well as change other reliefs in order to make them more relevant to Welsh circumstances. A small part of new residential leases will be exempted from tax in accordance with the LTT, as well as rules relating to the lease, will be simplified. The government will announce LTT strip prices closer to the date of implementation in April 2018. The Minister of Finance Mark Drakeford said: "This is a tax that affects many of us, replacing the...

UK tax changes for non-residents

Published:   15.09.2016 | Без категории

The UK government may lose significant tax revenue, if his proposed new rules for nonresidents prompt too many rich people to leave the country, warns the international law firm Pinsent. According to Pinsent, British residents contributed GBP6.57bn (USD8.67bn) income tax in 2014-15, respectively. He explained that this figure is an average of GBP56,589 for the year, compared with an average of GBP5,152 per person in the general population. Expert tax investigation Fiona Fernie said: "Non-residents made a very valuable contribution to the UK economy and any significant outcome could have serious long-term consequences of this policy." Under the current rules, non-residents pay tax on income and profit outside the UK only if they transferred funds in the UK using tax base. Non-residents must pay an additional fee for money transfer Charge (RBC), or pay the full amount of tax in the UK to be covered by the resident. This measure would be effective for most purposes of income tax and GCT after 6 April 2017. "The presence of non-resident status gives the UK real competitive advantage when it comes to attracting the rich and talented people. Uninstall or change it now, especially...

Panama takes further action on tax transparency

Published:   14.09.2016 |

Cabinet of Panama On September 6, 2016, approved the legislation providing for the corresponding nation latest international tax transparency initiatives. The legislation would improve fiscal transparency in both the private and public sector, and ensure that the information provided by financial institutions area. In addition, the legislation will allow the Ministry of Economy and Finance, in order to better gather the information necessary to share with other countries and make him improve the supervision of financial statements. The bill will be considered by the National Assembly before the end of the year. September 8, 2016, the World Bank Board of Executive Directors approved a USD300m loan to support Panama's efforts to improve financial management and maintaining international standards of tax transparency. Author: Sergey Panovmanaging partner Finance Business...

The law of Scotland on the tax reform of the Council

Published:   13.09.2016 | Без категории

The Scottish Government has introduced tax legislation Council reform groups and rates from April 2017. The legislation will implement the proposals announced by the SNP government in March. Properties that fall under high tax board strips (E, F, G and H) would pay more as a result of these bands coefficient increases in relation to the middle band (D) properties. The government estimates that this will lead to annual average increase of about GBP100 (USD132) for Zone E properties, GBP200 for F, GBP335 for band G and GBP517 range for range H. The circuit board of reducing the tax would apply to families with low income, having children, and the government will introduce an exemption for families with low income living in conditions with high added value. Frozen council tax, which has been in place since 2007, will be removed from April 2017. Local authorities will be able to increase the tax up to a maximum of three per cent per year. The government expects to raise an additional reforms GBP100m a year in income or GBP500m, during the term of the current parliament. This money will be invested in the school education system in Scotland. Finance Minister Derek Mackay said...

Irish parliament withdraws its lawsuit against Apple

Published:   12.09.2016 |

Irish Parliament approved the Government's request to appeal against the decision of the European Commission that the tax rules, given Apple's constitute illegal state aid. The decision was adopted by 93 votes to 36. He stated that Parliament "supports the government's decision to appeal the decision of the European Commission that Ireland gives Apple an illegal state aid." Finance Minister Michael Noonan described the decision by the Commission and the Government of treatment as "a landmark moment for Irish tax policy and our place in Europe." Noonan said that with a call "necessary to protect the integrity of our tax system, to provide certainty for business, as well as to challenge an infringement of EU state aid rules in the public parts of the competence of the tax." He added that "it is simply not true that Ireland provides a favorable tax regime in Ireland," and warned that "it is very bad for our reputation, which has been questioned." The Commission last month concluded that the two tax regulations issued by the Apple Ireland significantly and artificially lowered the taxes paid by Apple in Ireland in order to restore "unpaid taxes" from Apple over the years...

Australia investigates tax Panama documents

Published:   09.09.2016 |

In response to the analysis of documents Panama appear serious financial crime task force Australia (SFCT) held a "week of action" against persons suspected of tax evasion. SFCT made 15 unannounced visits to the states of Victoria and Queensland, and executed three search warrants. SFCT was launched in July 2015 and is headed by Australian Federal Police and a representative of the tax office, the Australian Commission on Crime Australian transaction reports, Securities and Investment Commission of Australia. Minister revenues O'Dvayer Kelly said: "Our government built a profile on the basis of more than 1000 Australians found in the leak, and review the information provided to us by other tax jurisdictions, we found taxpayers and advisers related to tax evasion, illegal drugs and corruption." She said at a press conference: "Some of these Australian taxpayers include dignitaries also include professional intermediaries, which include people who work as accountants and lawyers. The information shown significant tax avoidance arrangements that promoters have to their customers. Some of them are very complex and have several levels of offshore companies, fake shareholders, and...

The law protects Ireland’s tax base

Published:   08.09.2016 |

The Irish government will make changes to the tax regime of special purpose companies established for assets to close a loophole so-called "predatory companies." Finance Minister Michael Noonan has published an amendment to section 110 of the Law of 1997 on tax consolidation governing the taxation of such companies. He explained that "issues have been raised recently about the possible use of aggressive tax practices by some sections of the 110 companies to avoid paying tax on Irish real estate transactions." He said that the amendment was intended to address the abuse of Article 110 and to ensure the provision fenced for bona fide purposes. Section 110 was introduced to improve the supply of Ireland as a place to conduct financial services. According to section 110, a company must be a tax resident in Ireland and do business holding or management of "qualifying assets" that should be at least EUR10m (USD11.3m). In addition to holding or management of "qualifying assets," the company can not conduct any other activity. Gain or income under section 110 of the company subject to corporate tax at 25%. This is the norm for passive income, but taxable income is calculated using...

New Zealand tax system progresses

Published:   07.09.2016 |

The top ten income in New Zealand is projected to pay 37.2% income tax in 2016/17, compared with 35.5% in the 2007/08 year. The New Zealand government has published data showing that the tax system is more progressive. "These latest data confirm that the income tax system and support of New Zealand much income redistribution needy households, said Acting Finance Minister Steven Joyce. "Many families with low incomes pay a larger share of income tax than in 2008, and households with low incomes pay less - 30% of households with the lowest incomes are projected to pay only 5.4% of income tax, compared with 6.3% in 2007/08 p ". "The Government has increased support to low-income households to help New Zealanders go through difficult times. So at any given time, a large number of households effectively do not pay income tax," said Joyce. According to the Treasury in 2016/17, 42% of households will pay less tax than they receive from social security benefits it work for family tax credits and if we compare, the 2007/08 figure was - 39%. Author: Olena Kutova senior lawyer of the Finance Business Service company ...