On 14 January 2013, HM Revenue & Customs (HMRC) published new section INTM120085 of the International Manual on company residence, providing clarification on non-standard treaty tie-breaker rules. According to certain double taxation agreements, e.g. Canada - United Kingdom Income Tax Treaty (1978), Netherlands - United Kingdom Income Tax Treaty (2008) and United Kingdom - United […]

On 8 November 2012, the Ministry of Finance issued a letter No. 03-01-18/8-162 clarifying the tax treatment applicable to assets (works, services, or property rights) received free of charge in transactions between independent parties. The Ministry of Finance clarified that assets received free of charge from an independent entity should be reported by the beneficiary […]

It has been reported that the China Securities Regulatory Commission (CSRC) and the State Administration of Taxation (SAT) have agreed on expanding the taxation of qualified foreign institutional investors (QFII) recently. Currently, QFIIs are subject to enterprise income tax at a rate of 10% on dividends, profits and interest and are exempt from capital gains […]

On 8 January 2013, HM Revenue & Customs (HMRC) announced that it will offer to individuals, companies and partnerships that have entered into specific tax avoidance schemes, the opportunity to finalize their tax position and settle their tax liabilities by agreement without recourse to litigation. The schemes covered include UK Generally Accepted Accounting Practice (GAAP) […]

The US Department of Justice (DOJ) and the US Internal Revenue Service (IRS) have announced that a Swiss private bank (Wegelin & Co.) entered a guilty plea before a US District Court for conspiring with US taxpayers and others to hide more than USD 1.2 billion in secret Swiss accounts and to evade US taxes […]