The OECD has dealt another serious blow in the fight against international tax evasion and avoidance. The Paris-based organisation has defined the common rules that require financial intermediaries, lawyers, tax advisors and banks to inform tax authorities of any schemes they put in place for their clients to prevent the identification of the beneficial owners […]
Bad Debt Write-offs – Timing is Everything… A recent TRA decision should be a reminder to us all, that a bad debt deduction may only be claimed in the income year that it is physically written off – section DB 31(1)(a)(i). The basic facts in this case, was that the taxpayer was a barrister and […]
GST Registration Effective Dates… Recently released ED0206 is a draft Standard Practice Statement (“SPS”) describing how IR will approach GST registration applications, particularly those applying for voluntary registration and with a retrospective effective date. The SPS first sets out that required registrations (supplies exceeding registration threshold) will usually have an effective date which coincides with […]
It is said that there are more Lebanese outside Lebanon then there are in Lebanon, so it comes as no surprise that Lebanon has more than 30 tax treaties, especially when the country’s diaspora is highly engaged in holding assets, investing in their homeland and sending savings back to family members. Lebanon has always been […]
Farm Related QWBA’s… IR has recently released two draft Questions We’ve Been Asked (“QWBA”), dealing with issues in the farming sector. PUB00237 looks at the question of the income tax treatment of allowances paid and benefits provided to farm workers. However, it is worthwhile noting that the majority of the commentary can be applied to […]
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PE Additional Guidance Doc released… The OECD has just released a report entitled “Additional Guidance on the Attribution of Profits to Permanent Establishments (“PE”)”, which is a follow-on to the 2015 final BEPS package report on “Preventing the Artificial Avoidance of Permanent Establishment Status”. The guidance document sets out high-level general principles, which countries agree […]
HoldCo’s Beware… IR has released its latest Revenue Alert – RA 18/01, expressing the Commissioner’s concerns regarding dividend stripping arrangements being used in restructures, which predominantly involve a holding company being inserted into the taxpayers structure, with the original shareholders deriving an effective transfer of value, even though their economic interest in the original (target) […]
IR Global, the world’s largest exclusive network of advisory firms is delighted to introduce Dirk Lehmann of Wagemann + Partner PartG mbB. Dirk has joined IR as our exclusive Tax (Accountants) Member in Germany. “Wagemann + Partner PartG mbB (limited liable partnership) is a tax advisory, audit and CPA firm experienced in providing advice in […]
Win some, lose some… Last May I commented on a High Court case involving CFC’s resident in China, whom had received tax sparing concessions, naturally reducing the level of taxes paid on their income. At the time, NZ had not introduced the active/passive attribution rules and consequently the income of the CFC’s had been attributed […]
Tuesday 13 March 2018 Settling in to the new cycle of Spring Statements and Autumn Budgets, Philip Hammond delivered his very quick spring statement (in fact on of the shortest updates ever!). Before the announcement there was a promise of no tax changes. The flip side to tax is of course spending, so […]
Ring-Fencing on the Horizon… If you thought the increase of the bright-line period from two to five years was a political overkill, just wait, there’s more. Also in action at the recent NZ International Fiscal Association conference in Queenstown, was the new Revenue Minister, Stuart Nash. Top of his speech agenda, was the second bullet […]