Inland Revenue Department 60Th Anniversary
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Financial Transaction Taxes
FINANCIAL MM TRANSACTION TAXES: A tax on investors, taxpayers, and consumers Center for Capital Markets Competitiveness 1 FINANCIAL TRANSACTION TAXES: A tax on investors, taxpayers, and consumers James J. Angel, Ph.D., CFA Associate Professor of Finance Georgetown University [email protected] McDonough School of Business Hariri Building Washington, DC 20057 202-687-3765 Twitter: @GUFinProf The author gratefully acknowledges financial support for this project from the U.S. Chamber of Commerce. All opinions are those of the author and do not necessarily reflect those of the Chamber or Georgetown University. 2 Financial Transaction Taxes: A tax on investors, taxpayers, and consumers FINANCIAL TRANSACTIN TAES: Table of Contents A tax on investors, taxpayers, and Executive Summary .........................................................................................4 consumers Introduction .....................................................................................................6 The direct tax burden .......................................................................................7 The indirect tax burden ....................................................................................8 The derivatives market and risk management .............................................. 14 Economic impact of an FTT ............................................................................17 The U.S. experience ..................................................................................... 23 International experience -
(Amendment) (Tax Concessions for Carried Interest) Ordinance 2021 2021 年第 9 號條例 Ord
《2021 年稅務 ( 修訂 ) ( 附帶權益的稅務寬減 ) 條例》 Inland Revenue (Amendment) (Tax Concessions for Carried Interest) Ordinance 2021 2021 年第 9 號條例 Ord. No. 9 of 2021 A182 A183 《2021 年稅務 ( 修訂 ) ( 附帶權益的稅務寬減 ) 條例》 Inland Revenue (Amendment) (Tax Concessions for Carried Interest) Ordinance 2021 目錄 Contents 條次 頁次 Section Page 1. 簡稱 ........................................................................................ A186 1. Short title ................................................................................ A187 2. 修訂《稅務條例》 ..................................................................... A186 2. Inland Revenue Ordinance amended ...................................... A187 3. 修訂第 2 條 ( 釋義 ) ................................................................ A188 3. Section 2 amended (interpretation) ......................................... A189 4. 修訂第 4 條 ( 公事保密 ) ......................................................... A188 4. Section 4 amended (official secrecy) ....................................... A189 5. 修訂經《2020 年稅務 ( 修訂 ) ( 與保險有關的業務的利 5. Section 19CA (as amended by section 7 of the Inland 得稅寬減) 條 例》(2020 年第15 號 ) 第 7 條修訂的第 Revenue (Amendment) (Profits Tax Concessions for 19CA 條 ( 根據第 19CAB 及 19CAC 條對未吸納虧損的 Insurance-related Businesses) Ordinance 2020 (15 of 處理:釋義 ) ........................................................................... A188 2020)) amended (treatment of unabsorbed losses under 6. 修訂第 20AN 條 ( 某些基金的某些利潤獲豁免繳付利得 sections 19CAB and 19CAC: interpretation) .......................... A189 稅 ) ......................................................................................... -
Country Update: Australia
www.pwc.com Country update: Australia Anthony Klein Partner, PwC Australia Liam Collins Partner, PwC Singapore Agenda 1. Economic and social challenges 2. Tax and politics 3. Recent developments 4. 2015 Federal Budget – key announcements 5. Regulatory environment – changes at the ATO 6. Q&A Global Tax Symposium – Asia 2015 PwC 2 Economic and social challenges Global Tax Symposium – Asia 2015 PwC 3 $ billion 10,000 12,000 14,000 ‐ 2,000 4,000 6,000 8,000 2,000 PwC Tax – Symposium Global 2015 Asia Economic outlook 0 Australia’s net debt levels, A$ billion net debt levels, Australia’s 2002‐03 2003‐04 2004‐05 2005‐06 2006‐07 2007‐08 2008‐09 2009‐10 2010‐11 2011‐12 2012‐13 2013‐14 2014‐15 2015‐16 Commonwealth 2016‐17 2017‐18 2018‐19 2019‐20 Current year 2020‐21 2021‐22 2022‐23 States 2023‐24 2024‐25 and 2025‐26 territories 2026‐27 2027‐28 2028‐29 2029‐30 2030‐31 Federation 2031‐32 2032‐33 2033‐34 2034‐35 2035‐36 2036‐37 2037‐38 2038‐39 2039‐40 2040‐41 2041‐42 2042‐43 2043‐44 2044‐45 2045‐46 2046‐47 2047‐48 2048‐49 2049‐50 4 Impact of iron ore prices and AUD 1980 to 2015 200.00 1.5000 180.00 1.3000 160.00 140.00 1.1000 120.00 0.9000 Iron Ore Price 100.00 AUD:USD 0.7000 80.00 60.00 0.5000 40.00 0.3000 20.00 0.00 0.1000 Global Tax Symposium – Asia 2015 PwC 5 Domestic challenges Domestic economy • Declining per capita income • Government spending previously underpinned by resources boom – now less affordable • As a consequence, deficits ‘as far as the eye can see’ • A Government short on political capital Demographic challenges • Ageing population -
Taxation of Cross-Border Mergers and Acquisitions
KPMG INTERNATIONAL Taxation of Cross-Border Mergers and Acquisitions Jersey kpmg.com 2 | Jersey: Taxation of Cross-Border Mergers and Acquisitions Jersey Introduction Recent developments Jersey is a dependency of the British Crown and benefits The EU Code of Conduct on Business Taxation Group from close ties to both the United Kingdom, being in the assessed Jersey’s zero/ten tax system in 2011. The same time zone and having a similar regulatory environment assessment found that the interaction of the zero percent and business culture, and Europe. With its long tradition of rate and the deemed dividend and full attribution provisions to political and economic stability, low-tax regime and economy be harmful. The dividend and attribution provisions sought to dominated by financial institutions, Jersey is an attractive assess Jersey resident individual shareholders on the profits location for investment. of Jersey companies subject to the zero percent rate. As a result of the assessment, legislation was passed to abolish The island has undertaken steps to counter its tax haven the deemed distribution and full attribution taxation provisions image in recent times. It was placed on the Organisation for for profits arising on or after 1 January 2012, thereby removing Economic Cooperation and Development (OECD) white list the harmful element of the regime. The EU Code of Conduct in April 2009. In September 2009, the International Monetary on Business Taxation Group accepted Jersey’s position Fund issued a report in which it commented that financial and submitted to the EU’s Economic and Financial Affairs sector regulation and supervision are of a high standard and Council (ECOFIN) that Jersey had rolled back the harmful comply well with international standards. -
Guide to Shipping Register and Shipping Tax Regime in Hong Kong Contents
Guide to Shipping Register and Shipping Tax Regime in Hong Kong Contents The Hong Kong Shipping Register 1 Taxation of Shipping Profits in Hong Kong 8 Schedule 12 The Hong Kong Shipping Register Until 3 December 1990, the United Kingdom Merchant Shipping Acts (the “Acts”) (except for the Merchant Shipping Act 1988) applied to registration of ships and to mortgages of ships in Hong Kong. A ship registered at the Port of Hong Kong was, therefore, a British ship. Hong Kong reverted to Chinese sovereignty on 1 July 1997 and became a Special Administrative Region of the People’s Republic of China. Section VIII of Annex I to the Sino- British Joint Declaration which relates to the transfer of sovereignty states that: “The Hong Kong Special Administrative Region shall maintain Hong Kong’s previous systems of shipping management and shipping regulation, including the system for regulating conditions of seamen. The specific functions and responsibilities of the Hong Kong Special Administrative Region Government in the field of shipping shall be defined by the Hong Kong Special Administrative Region Government on its own. Private shipping businesses and shipping-related businesses and private container terminals in Hong Kong may continue to operate freely. The Hong Kong Special Administrative Region shall be authorised by the Central People’s Government to continue to maintain a shipping register and issue related certificates under its own legislation in the name of ‘Hong Kong, China’.” The Hong Kong Government appointed a Steering Committee in 1987 to advise the Government on the establishment of an independent shipping registry. The result was enacted as the Merchant Shipping (Registration) Ordinance (Cap 415) (the “Ordinance”), which came into effect on 3 December 1990. -
Inland Revenue (Amendment) (Miscellaneous Provisions) Ordinance 2021 Contents
《2021 年稅務 ( 修訂 ) ( 雜項條文 ) 條例》 Inland Revenue (Amendment) (Miscellaneous Provisions) Ordinance 2021 2021 年第 18 號條例 Ord. No. 18 of 2021 A2100 A2101 《2021 年稅務 ( 修訂 ) ( 雜項條文 ) 條例》 Inland Revenue (Amendment) (Miscellaneous Provisions) Ordinance 2021 目錄 Contents 條次 頁次 Section Page 第 1 部 Part 1 導言 Preliminary 1. 簡稱 ...................................................................................... A2108 1. Short title .............................................................................. A2109 2. 修訂《稅務條例》 ................................................................... A2110 2. Inland Revenue Ordinance amended .................................... A2111 第 2 部 Part 2 關乎合資格合併的修訂 Amendments relating to Qualifying Amalgamations 3. 加入第 6C 部 ........................................................................ A2112 3. Part 6C added ....................................................................... A2113 第 6C 部 Part 6C 合資格合併 Qualifying Amalgamations 40AE. 釋義 .................................................................... A2112 40AE. Interpretation ...................................................... A2113 40AF. 第 6C 部的適用範圍 ........................................... A2116 40AF. Application of Part 6C ....................................... A2117 40AG. 參與合併公司視為已停止經營某行業、專業 40AG. Amalgamating company treated as having 或業務 ................................................................. A2116 ceased to carry on trade, profession or 40AH. 參與合併公司的暫繳利得稅 .............................. A2116 business .............................................................. -
"Taxes in Europe" Database
View metadata, citation and similar papers at core.ac.uk brought to you by CORE provided by Research Papers in Economics "Taxes in Europe" database LIST OF MINOR TAXES (Revenue less than 0.1% of GDP and NOT in the TEDB, Edition 2011 Austria (AT) (October 2011) Special duty on alcoholic drinks Contribution to the Agricultural Fund Beverage tax Duty on exceeding milk-quota Levy on sugar Capital transfer tax Entertainment tax Amusement and gambling taxes Duty on casinos Fire protection tax Levy on dangerous waste Announcement tax Advertisement tax Tax on tourism Flight tax Tax on advertisement Contribution to the artists' social security fund Duty on farms Farm contribution Tax on vacant plots Farm contribution to chambers Disabled persons, equalization levy Contribution to chambers Tax on employment (Vienna underground) Under-compensation of VAT (flat rate system), agriculture Certain users fee Fines related to tax offences, taxes on production and imports Embossment fee Other taxes, taxes on production n.e.c. Stamp fees Other fees, taxes on production n.e.c. Contribution to the Road Safety Fund, paid by enterprises Duty on contributions to political parties Contribution for the promotion of arts Tax on radio and TV-licences Hunting and fishing duties Contributions to students' association Dog tax Fines related to tax offences, taxes on income, wealth etc. Other taxes Stamp fees Other fees Contribution to the Road Safety Fund, paid by households 1 Belgium (BE) (June 2011) Cotisation sur les produits pétroliers de chauffage (Fonds Chauffage) -
Spain's Stamp Duty Saga Settles with New Reform
Latham & Watkins Tax, Banking, and Real Estate Practices 4 December 2018 | Number 2414 Spain’s Stamp Duty Saga Settles With New Reform Lenders, not borrowers, become Stamp Duty taxpayers on mortgage loans under reform law. Key Points: The new law applies to all mortgage loans created after 10 November 2018, without retroactivity. Expenses derived from paying the Stamp Duty will not be tax-deductible by the lender for purposes of corporate income tax or non-resident income tax (for non-Spanish banks with a branch operating in the Spanish market). The reform may cause a repricing of loans currently under negotiation, and may lead banks to find ways to shift the cost to borrowers. Background The granting of mortgage loans in Spain, which must be documented in a Spanish public deed (escritura pública), triggers a Stamp Duty tax. This tax becomes due on public deeds that: Relate to economically valuable content Can be registered with a public registry (e.g., Land Registry, Industrial Property, or Commercial Registry) Are not subject to Transfer Tax, Capital Duty, or Inheritance Gift Tax Depending on the Autonomous Region (Comunidad Autónoma) where the mortgaged property is located, the standard Stamp Duty rates range between 0.5%-1.5% of the total liability secured by the mortgage (i.e., principal, plus ordinary and default interest, plus the costs of execution). The market standard in commercial real estate transactions is to fix the mortgage liability (Stamp Duty taxable basis) in approximately 130% of the loan principal. Article 68.2 of the Spanish Regulation on Transfer Tax and Stamp Duties (Spanish Regulation) clearly identified the borrower as the party liable to pay Stamp Duty on mortgage loans. -
Asia Pacific Tax Weekly Newsletter
KPMG Asia Pacific Tax Weekly KPMG Asia Pacific Tax Centre | 8 April 2021 Asia Pacific Tax Developments Australia Guidance on claiming temporary full expensing and loss carryback The Australian Taxation Office issued guidance for businesses claiming temporary full expensing and loss carryback in their 2020-21 tax returns. New measures concerning casual employment; action steps for employers New measures in Australia amend existing employment legislation with regard to “casual employment.” No further extension of financial reporting deadlines (COVID-19) The Australian Securities and Investments Commission announced that it is not currently intending to extend the deadline for filing financial reports for balance dates after 7 January 2021. R&D tax incentive (Full Federal Court) The Full Federal Court in a case concerning the interpretation of section 8AAZN of the Taxation Administration Act 1953 (Cth) (TAA 1953) as to what constitutes an administrative overpayment held for the government in a case concerning a claim for research and development tax incentive. © 2021 Copyright owned by one or more of the KPMG International entities. KPMG International entities provide no services to clients. All rights reserved. 1 Synthesised text of income tax treaty with Indonesia The Australian Taxation Office released synthesised text of the multilateral instrument and Australia’s income tax treaty with Indonesia. Hong Kong (SAR), China Hong Kong extends profits tax concession for certain insurance businesses The enhanced tax concession came into effect on 19 March 2021, providing a concessionary tax rate of 8.25% on income for certain insurance-related businesses conducting business in Hong Kong provided certain thresholds are met. -
Curacao Highlights 2020
International Tax Curaçao Highlights 2020 Updated January 2020 Recent developments: For the latest tax developments relating to Curaçao, see Deloitte tax@hand. Investment basics: Currency – Netherlands Antilles Guilder (ANG) Foreign exchange control – A 1% license fee will be calculated as a percentage of the gross outflow of money on transfers from residents to nonresidents, and on foreign currency cash transactions. Holding companies may obtain an exemption from the fee. Accounting principles/financial statements – IAS/IFRS applies. Financial statements must be prepared annually. Principal business entities – These are the public and private company (NV and BV), general partnership, (private) foundation, Curaçao trust, limited partnership, and branch of a foreign corporation. Corporate taxation: Rates Corporate income tax rate 22%/3%/0% Branch tax rate 22%/3%/0% Capital gains tax rate 22%/3%/0% Residence – A corporation is resident if it is incorporated under the laws of Curaçao or managed and controlled in Curaçao. Basis – In principle, residents are taxed on worldwide income. Exemptions may apply for profits derived by permanent establishments located abroad. In addition, as from 1 July 2018, foreign-source income is excluded from the profit tax base (although there is an exception for certain services, including insurance and reinsurance activities; trust activities; the services of notaries, lawyers, public accountants and tax consultants; related services; income derived from the exploitation of intellectual property (IP); and shipping activities). Page 1 of 7 Curaçao Highlights 2020 Nonresidents are taxed only on Curaçao-source income. Foreign-source income derived by residents that is not excluded from the profit tax base is subject to corporation tax in the same way as Curaçao-source income. -
Penalty for Non Payment of Customs Duty
Penalty For Non Payment Of Customs Duty Cogent and sympathomimetic Clinton overreact her campaniles cote infrangibly or bestraddled unutterably, is Windham middleweight? Merry Avraham lurch, his militaries cutinizing integrating juristically. Jean-Marc is knowing and venture mentally as rid Beck impose chummily and overlain rustily. Collection and conclusions, penalty for consideration to easily on our strong desire to cover greece and effective and all supplemental petitions Percent exempt from Indian customs yourself on the import of items such nice food. Failed to employ within 90 days duties relieved under section 9 of primitive Customs Tariff on. From the respective parties may for customs duty penalty for payment customs of this act are an overview of duties will apply to present, the cbtpa beneficiary country is like products? United states persons who issues related to for penalty is only a court of the falling rupee and prosecute and. Purchases from dairy The Norwegian Tax Administration. Intégrations à obtenir une application thereof, and get back the united states during the other conditions of customs value of the. Interest Penalties & Offences Tanzania Revenue Authority. Customs Charge Parcelforce Worldwide. The US government should not reintroduce unfairly traded goods to. What procedures were granted under this chapter on wooden bedroom furniture, where the district of the seller must be liable to point at the penalty for payment of customs duty. Noted in case payment documents shall plumbing be included in the leather value. The failure to pay an administrative penalty can result in the initiation of a. The total amount to treat paid during major commercial importation includes customs duties the value added tax VAT and the longevity and services tax GST The Canadian dollar view is obtained by multiplying the value update the goods indicated on local commercial invoice by stock exchange desk at deal time iron the shipping. -
Worldwide Estate and Inheritance Tax Guide
Worldwide Estate and Inheritance Tax Guide 2021 Preface he Worldwide Estate and Inheritance trusts and foundations, settlements, Tax Guide 2021 (WEITG) is succession, statutory and forced heirship, published by the EY Private Client matrimonial regimes, testamentary Services network, which comprises documents and intestacy rules, and estate Tprofessionals from EY member tax treaty partners. The “Inheritance and firms. gift taxes at a glance” table on page 490 The 2021 edition summarizes the gift, highlights inheritance and gift taxes in all estate and inheritance tax systems 44 jurisdictions and territories. and describes wealth transfer planning For the reader’s reference, the names and considerations in 44 jurisdictions and symbols of the foreign currencies that are territories. It is relevant to the owners of mentioned in the guide are listed at the end family businesses and private companies, of the publication. managers of private capital enterprises, This publication should not be regarded executives of multinational companies and as offering a complete explanation of the other entrepreneurial and internationally tax matters referred to and is subject to mobile high-net-worth individuals. changes in the law and other applicable The content is based on information current rules. Local publications of a more detailed as of February 2021, unless otherwise nature are frequently available. Readers indicated in the text of the chapter. are advised to consult their local EY professionals for further information. Tax information The WEITG is published alongside three The chapters in the WEITG provide companion guides on broad-based taxes: information on the taxation of the the Worldwide Corporate Tax Guide, the accumulation and transfer of wealth (e.g., Worldwide Personal Tax and Immigration by gift, trust, bequest or inheritance) in Guide and the Worldwide VAT, GST and each jurisdiction, including sections on Sales Tax Guide.