Podcast: Cum-Ex Dividend Trade Investigations
The Knesset Finance Committee approved a draft bill for second and third readings to ease the conditions for tax relief during corporate restructuring. The bill was first published in the initial draft bill within the tax...more
Welcome to the third Regulatory & Risk Advisory Review instalment of 2024. In this edition we cover the latest Cayman Islands regulatory updates including the Beneficial Ownership Transparency Act and The Perpetuities...more
The Organisation for Economic Co-operation and Development (OECD) has urged participating tax authorities around the globe to take further steps to ensure compliance with the Common Reporting Standard (CRS). As a result...more
The British Virgin Islands (the BVI), along with most other major offshore jurisdictions, has introduced “economic substance” requirements for entities carrying on certain specified activities. This economic substance regime...more
It has now been over a year since the updated Enforcement Guidelines: Economic Substance (the “Guidelines”) were issued on 31 March 2023, outlining the enforcement powers and processes of the Cayman Islands Tax Information...more
En Concepto 100202208-0603 del 27 de marzo de 2024, luego de que nuestro equipo solicitara la reconsideración de su doctrina, la Dirección de Impuestos y Aduanas Nacionales (DIAN) de Colombia acepta que no es necesario emitir...more
As described in more detail in our recent client bulletin, BVI companies are now required to prepare and file with their registered agent an “annual return” containing a basic balance sheet and income statement. This annual...more
On February 5, 2024, the French Supreme Tax Court (Conseil d’État) voided French tax authority guidelines from May 2023 that provided that shares acquired upon the exercise of founder stock options, or Bons de Souscription de...more
In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more
The Department of Justice (DOJ), IRS Criminal Investigations (CI) and international tax authorities continue to prosecute tax abuses related to digital asset transactions. In imposing a multiyear prison sentence in a recent...more
Earlier this year, the English Court refused to sanction two Part 26A restructuring plans ("RPs") which sought to bind HMRC, the UK tax authority, into restructurings via "cross-class cram down". (See "Restructuring Plans...more
Welcome to the second edition of our Horizon Scan, where we focus on some of the principal recent and expected developments and changes that we expect to be of interest to those in the non-listed funds sector. We have grouped...more
Welcome to the latest edition of our Quarterly Corporate Update covering recent developments in the British Virgin Islands. The first quarter of 2023 saw a raft of amendments to existing BVI legislation being introduced...more
The Economic Substance (Companies and Limited Partnerships) Act, as amended (the "ESA"), requires BVI legal entities which engage in relevant activities to maintain economic substance in the BVI. Our 'Overview of the British...more
The following BVI legislative supplements to the Mutual Legal Assistance (Tax Matters) Act (“MLA Act”) and the International Tax Authority Act (“ITA Act”) were gazetted on 13 June 2022: The Mutual Legal Assistance (Tax...more
Key Takeaways - ..The Joint Chiefs of Global Tax Enforcement (J5) issued its first intelligence bulletin providing guidance to banks, law enforcement partners and private investigators regarding indicators of potential...more
In May 2021, President Biden’s administration released a $6 trillion budget proposal for the coming fiscal year (Budget), including $3.6 trillion of tax increases over 10 years and generous tax credits to incentivize clean...more
Following the introduction of the Economic Substance (Companies and Limited Partnerships) Act 2018 ( ES Act) and the passing of the deadline for the first filings thereunder to be made by BVI entities, the BVI International...more
Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation - An Experience Unlike Any Other - Find yourself on the cutting-edge of international tax law, with...more
With effect from 30 June 2021 the International Tax Co-operation (Economic Substance) (Amendment) of Schedule Regulations, 2021 serve to expand the application of the International Tax Cooperation (Economic Substance) Act...more
Foreign Financial Institutions (FFIs) have multiple FATCA reporting compliance responsibilities and face the possibility of penalties for not complying. ...more
What is DAC6? DAC6 is a new regime under which intermediaries and/or taxpayers must report to an EU tax authority information about cross-border arrangements with a view to the information being exchanged with other tax...more
The Supreme Administrative Court has confirmed that the Director of the National Fiscal Information Bureau will now be required to assess the correctness of the statistical classification when issuing a tax ruling. This...more
Across the world, tax authorities are becoming more aggressive and have sharpened their focus on corporates and multinationals. As a result, tax audits, investigations and disputes have increased significantly, both at the...more
The month of July has seen several significant developments regarding implementation of the Foreign Account Tax Compliance Act (FATCA), which has been fully effective since July 1, 2014. First, the IRS Office of Chief...more