THE COMMON REPORTING STANDARD ("CRS") UPDATE FOR OCORIAN CLIENTS
|
|
- Veronica Whitehead
- 5 years ago
- Views:
Transcription
1 JERSEY BRIEFING November 2015 THE COMMON REPORTING STANDARD ("CRS") UPDATE FOR OCORIAN CLIENTS At present 93 countries will implement CRS over a two year period commencing 1 January The CRS initiative follows on the heels of US FATCA and, for Crown Dependencies, such as Jersey and Guernsey, UK FATCA. Although UK FATCA will be in force for exchanging information in 2016 for the Crown Dependencies it is anticipated that it will subsequently fall away and that UK FATCA regime will become part of CRS. It is unclear at present over what period and how UK FATCA reporting will be transitioned to CRS reporting. WHAT IS CRS? CRS is the result of the drive by the G20 nations to develop a global standard for the automatic exchange of financial account information following the approach taken to implement US FATCA. A Financial Institution in participating jurisdictions (see list below) will be required to report certain financial information on relevant clients to its local tax authority which will, in turn, exchange this information with any jurisdictions where the relevant client is known to be tax resident. WHO IT AFFECTS? At present 93 countries (see list below) will implement CRS over a two year period commencing 1 January 2016, in order to comply with the automatic exchange of information required by the Competent Authority Agreements (CAAs). Apart from Singapore, all Ocorian jurisdictions have signed up to be early adopters of CRS and are, therefore, expected to start to gather relevant information from 1 January 2016, and report in Singapore is expected to adopt CRS with effect from 1 January 2017, and report in LIST OF COUNTRIES SIGNED AND COMMITTED: 2017 Signed Anguilla Argentina Belgium Bermuda British Virgin Islands Cayman Islands Colombia Croatia Curacao Cyprus Czech Republic Denmark Estonia Faroe Islands Finland France Germany Gibraltar Greece Guernsey Hungary Iceland Ireland Isle of Man Italy Jersey Korea Latvia Liechtenstein Lithuania Luxembourg Malta Mauritius Mexico Montserrat Netherlands Norway Poland Portugal Romania San Marino Slovak Republic Slovenia South Africa Spain Sweden Turks & Caicos Islands United Kingdom
2 JERSEY BRIEFING 2 Committed Barbados Bulgaria Chile Dominica Greenland India Niue Seychelles Trinidad & Tobago Uruguay 2018 Signed Albania Aruba Austria Committed Andorra Antigua & Barbuda Australia The Bahamas Belize Brazil Brunei Darussalam Canada China Costa Rica Grenada Hong Kong (China) Indonesia Israel Japan Marshall Islands Macau (China) Malaysia Monaco New Zealand Qatar Russia Saint Kitts and Nevis Saint Lucia Saint Vincent and the Grenadines Samoa Saudi Arabia Singapore Sint Maarten Switzerland Turkey United Arab Emirates TIMELINE CHART Date Comment Year ending 31 Dec 2014 June/July 2015 Sept 2015 Year Ending 31 Dec 2015 Q to Q By 30 June 2016 End Sept 2016 First reporting period for US and UK FATCA purposes. Local jurisdiction reporting of Accounts for US Account Holders under US FATCA. Exchange of information between local jurisdictions and US IRS re US Account Holders. Second reporting period for US and UK FATCA purposes. Account balances as at 31 December 2015 reportable and trust distributions to relevant beneficiaries during the calendar year to 31 December 2015 reportable for US and UK FATCA purposes. Verification exercise undertaken by Ocorian and subsidiaries and affiliates for UK account holders for UK FATCA reporting purposes. Likely circulation of detailed information on CRS implication in Early Adopter countries including all jurisdictions in which Ocorian and its subsidiaries operate (other than Singapore). Likely commencement of verification exercise to be undertaken by Ocorian and its subsidiaries and affiliates in all jurisdictions other than Singapore in respect of account holders who are clients and/or relevant trust beneficiaries in relevant early adopter jurisdictions. First reporting of relevant information for UK account holders under UK FATCA regime to Jersey Comptroller of Income Tax (information to be reported for both 2014 and 2015 reportable periods including account balances and distributions made to relevant trust beneficiaries and/or account holders during both periods.) Second reporting date under US FATCA for US Account Holders. Exchange of information with relevant tax authorities in UK and US under UK and US FATCA
3 JERSEY BRIEFING 3 Year End 2016 Likely to be end of first reporting period in respect of CRS in the case of early adopter jurisdictions including account balances as at 31 December 2016, and relevant trust distributions made during the preceding 12 months. End of third reporting period for US FATCA. End of third reporting period for UK FATCA (on the assumption that UK FATCA has not by then been superseded by CRS). A large number of entities administered by Ocorian and its subsidiaries and affiliates fell into the classification of Active or Passive NFFEs. 30 June 2017 Expected date for exchange of information between early adopter jurisdictions under CRS. WHAT ARE OCORIAN AND ITS SUBSIDIARIES AND AFFILIATES DOING? When US FATCA was introduced, Ocorian attempted to anticipate the CRS requirements and therefore implemented processes that could be followed when implementing CRS. It had always been anticipated that CRS would follow the definitions and framework of US FATCA reporting and this has, largely, proved to be the case. The OECD has now issued an implementation guide to jurisdictions and most recently the UK HMRC has released its draft CRS guidance. To date there has been no further guidance released by competent authorities in the other jurisdictions in which Ocorian operates (Jersey, Guernsey, Ireland, Mauritius or Singapore) and in respect of each of those jurisdictions, Ocorian is monitoring and waiting for the local guidance notes from each jurisdiction. It will also be a requirement that each jurisdiction signs up to a CAA based on the model CAA provided by the OECD in order to implement the exchange of information. These agreements are based on the FATCA model 1 inter-governmental agreement but as with such inter-governmental agreements CAAs will need to be adopted under domestic legislation before coming into force. No jurisdictions have yet passed the relevant legislation to adopt CAAs. Jurisdictions have the flexibility, when adopting CAAs to sign either: a multi-lateral agreement meaning a number of jurisdictions can jointly agree to exchange information; a bi-lateral agreement meaning that jurisdictions negotiate and agree an exchange of information just between those two jurisdictions; or a non-reciprocal agreement meaning one jurisdiction will receive information from another jurisdiction but will not be obliged to report information in return. Until local guidance notes are introduced on a jurisdiction by jurisdiction basis and relevant CAAs are given force of law in each jurisdiction by subordinate legislation, it is impossible to be certain how CRS will be implemented and what form the reporting by Financial Institutions ("FI" using FATCA terminology) may take. What can, however, be said with a degree of certainty is as follows: CLASSIFICATION CRS definitions and terminology largely follow that under US FATCA meaning that CAAs are likely to use the same terminology such as FI being a reporting entity and Active and Passive NFFEs (non-reporting foreign financial entities). In practice under US FATCA classifications, a large number of entities administered by Ocorian and its subsidiaries and affiliates fell into the classification of Active or Passive NFFEs (or Sponsored Financial Institutions) and thus did not need to register and report in their own name. However, where the entities were trusts or investment funds, Ocorian or one of its subsidiaries or affiliates was usually the reporting FI on a sponsored/sponsoring entity basis. We fully expect the same classifications to apply once CRS has been implemented and thus, as all entities administered by Ocorian and its subsidiaries and affiliates have already had to be classified for the purpose of US FATCA, we believe that this exercise for CRS will largely have already been done, assuming the same classifications apply as mentioned above. There will, of course, have to be a review undertaken of all existing classifications to check for any variations for CRS purposes. VERIFICATION Under US FATCA, Ocorian and its subsidiaries and affiliates have to verify the identity of and obtain up to date passports, proof of a residential address and US tax payer identification numbers (TINs) for all those clients, including beneficiaries of trusts,
4 JERSEY BRIEFING 4 Ocorian and its subsidiaries and affiliates are actively working on an impact assessment of which this early notification to clients and relevant trust beneficiaries forms part. having US connections ("Indicia" being the terminology used under US FATCA). Ocorian in Jersey has now started this verification exercise in respect of clients including beneficiaries of trusts who have UK connections (UK tax residence) and who will thus be reportable under UK FATCA in For this purpose we will be writing to all clients and any trust beneficiaries who have received distributions within the past 24 months (since 1 January 2014) and who we believe to be UK tax resident in order to obtain up to date information for verification purposes including, where appropriate, their UK tax reference numbers. This information will be needed in connection with UK FATCA reporting which is anticipated to take place in June/July Further verification of all clients and trust beneficiaries will be required going forward, probably commencing in first quarter 2016, so as to have information, including relevant tax payer identification number for clients and trust beneficiaries in all jurisdictions which have signed up to or committed to implement CRS reporting in either 2017 or 2018 (see lists above). REPORTING For early adopter countries which have signed and/or committed to implement CRS reporting in 2017 (which means that such reporting will apply in respect of FI account balances as at 31 December 2016, and in respect of relevant trust distributions made during 2016) it is expected that reporting of information to local tax authorities in such early adopter jurisdictions will take place in June/July 2017, and exchange of information take place in September For those countries which have committed (but not yet signed) to adopt CRS in 2018, relevant dates are expected to be one year further on although there is no certainty at this stage as to whether these dates will apply in respect of "second wave" jurisdictions. KEY DIFFERENCES BETWEEN CRS AND US FATCA Reportable Persons who are the relevant Account Holders in respect of FIs are defined with reference to their tax residency rather than their citizenship and tax residency. One consequence of this is that there may be multiple reporting in the event that the reportable person is tax resident in more than one country. There is no de minimis threshold for preexisting individual account holders under CRS although there is a de minimis threshold of US$250,000 applying to existing entity accounts. There is no provision for a specific compliance and monitoring regime overseen by a Responsible Officer within each FI although it is likely that the US FATCA standard will be adopted in practice for monitoring and compliance. No withholding tax - CRS does not include provision for withholding tax to apply to institutions which do not have the relevant information in order to ascertain the tax residency of the reportable person in respect of an account held by such an FI. It is, however, anticipated that domestic legislation may impose some penalty or withholding tax requirement on FIs who do not hold the relevant information for reporting purposes. COSTS It is inevitable that although significant costs have already been incurred in undertaking classification for US FATCA purposes, there will be significant additional costs for all entities administered by Ocorian and its subsidiaries and affiliates to ensure that the existing classifications are appropriate under CRS and that verification and reporting in accordance with anticipated CRS standards (once adopted under local legislation) is capable of being met. Ocorian and its subsidiaries and affiliates are actively working on an impact assessment of which this early notification to clients and relevant trust beneficiaries forms part. We will be writing in individual cases to clients and relevant trust beneficiaries in respect of UK FATCA and in respect of other early adopter jurisdictions where CRS reporting is expected to commence in 2017 in the first quarter of CONTINUED ON FOLLOWING PAGE
5 JERSEY BRIEFING 5 KEY CONTACTS JERSEY BRADLEY VAUTIER Head of Tax Compliance and Reporting T +44 (0) E bradley.vautier@ PAUL LEARY Chief Operating Officer T +44 (0) E paul.leary@ MICHAEL RICHARDSON Partner T +44 (0) E michael.richardson@ DISCLAIMER AND REGULATORY The content of this document (including any opinion expressed) is intended for general information purposes only and it does not constitute and should not be interpreted as an offer, an invitation to contract or legal or any other form of professional advice and nor should it be used or relied upon as such. Unless expressly stated otherwise, information is not intended to be comprehensive and is only current at the time of initial publication or, if this document is dated, as at that date and Ocorian gives no warranty as to the adequacy, accuracy or completeness of any information. Should you require legal or other professional advice, it is recommended that you contact a suitablyqualified lawyer or other relevant professional. Neither Ocorian Limited nor any of its subsidiaries or affiliates from time to time accepts any liability or responsibility whatsoever for any loss that may arise from the use by any person of this document or its content. Ocorian Limited is regulated by the Jersey Financial Services Commission. Ocorian Fund Services (Jersey) Limited is regulated by the Jersey Financial Services Commission. Ocorian (Luxembourg) S.à r.l is authorised to conduct business by the Ministère des Classes moyennes. Ocorian (UK) Limited is authorised and regulated by the Financial Conduct Authority of the United Kingdom. Ocorian (Mauritius) Limited is regulated by the Financial Services Commission Mauritius. Singapore Trust Company Pte Ltd is regulated by the Monetary Authority of Singapore. Ocorian (Guernsey) Limited (registered Guernsey 45342) is licensed and registered by the Guernsey Financial Services Commission under the Regulation of Fiduciaries, Administration Business and Company Directors, etc. (Bailiwick of Guernsey) Law Ocorian (Ireland) Limited is an authorised trust or company service provider in accordance with Section 89(6) of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 of Ireland NewCo.
When will CbC reports need to be filled?
Who will be subject to CbCR? Country by Country Reporting (CbCR) applies to multinational companies (MNCs) with a combined revenue of euros 750 million or more When will CbC reports need to be filled?
More informationAUTOMATIC EXCHANGE OF INFORMATION (AEOI)
AUTOMATIC EXCHANGE OF INFORMATION (AEOI) As the world becomes increasingly globalised, money can be transferred from one jurisdiction to another with ease. While this may help to facilitate trade and boost
More informationUPDATE. COMMON REPORTING STANDARD IN THE CAYMAN ISLANDS. What is CRS? Participating Jurisdictions
www.kensington-trust.com UPDATE COMMON REPORTING STANDARD IN THE CAYMAN ISLANDS The Cayman Islands Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations, 2015
More informationSTANDARD FOR AUTOMATIC EXCHANGE OF FINANCIAL ACCOUNT INFORMATION. Philip Kerfs, OECD
STANDARD FOR AUTOMATIC EXCHANGE OF FINANCIAL ACCOUNT INFORMATION Philip Kerfs, OECD Overview Background, context and timeline The Standard: basic approach and key features Next steps: implementing the
More informationOECD Common Reporting Standard Getting into the Detail STEP / GAT
OECD Common Reporting Standard Getting into the Detail STEP / GAT Jo Huxtable Martin Popplewell 11 February 2016 Agenda Introduction CRS and the wider regulatory environment CRS latest developments and
More informationTAXATION (IMPLEMENTATION) (CONVENTION ON MUTUAL ADMINISTRATIVE ASSISTANCE IN TAX MATTERS) (AMENDMENT OF REGULATIONS No. 3) (JERSEY) ORDER 2017
Taxation (Implementation) (Convention on Mutual Regulations No. 3) (Jersey) Order 2017 Article 1 TAXATION (IMPLEMENTATION) (CONVENTION ON MUTUAL ADMINISTRATIVE ASSISTANCE IN TAX MATTERS) (AMENDMENT OF
More informationTAXATION (IMPLEMENTATION) (INTERNATIONAL TAX COMPLIANCE) (COMMON REPORTING STANDARD) (JERSEY) REGULATIONS 2015
Arrangement TAXATION (IMPLEMENTATION) (INTERNATIONAL TAX COMPLIANCE) (COMMON REPORTING STANDARD) (JERSEY) REGULATIONS 2015 Arrangement Regulation 1 Interpretation... 3 2 Meaning of relevant date and relevant
More informationWebinar: Common Reporting Standard. Game Plan for Compliance December 10, 2015
Webinar: Common Reporting Standard Game Plan for Compliance December 10, 2015 Presenters Moderator: Sara Pereda Director DMS Offshore Investment Services Roman Ipfling Director DMS International Tax Compliance
More informationArgentina Tax amnesty: the day after
Argentina Tax amnesty: the day after Walter C. Keiniger December 2016 YES to amnesty: exchange of Information DTTs (Art. 26 OECD Model) Provisions or agreements signed by Argentina Bilateral Agreements
More informationSAINT CHRISTOPHER AND NEVIS STATUTORY RULES AND ORDERS. No. 32 of 2016
1 SAINT CHRISTOPHER AND NEVIS STATUTORY RULES AND ORDERS No. 32 of 2016 Common Reporting Standard (Automatic Exchange of Financial Account Information) Regulations The Minister, in exercise of the powers
More informationTAX TRANSPARENCY THE NEW GLOBAL REPORTING STANDARD
TAX TRANSPARENCY THE NEW GLOBAL REPORTING STANDARD 2 TAX TRANSPARENCY THE NEW GLOBAL REPORTING STANDARD A COMMON REPORTING STANDARD ACROSS THE WORLD The goalposts in international tax reporting are moving
More informationIntercontinental Trust Ltd COMMON REPORTING STANDARD
Intercontinental Trust Ltd COMMON REPORTING STANDARD 1 Conspectus The OECD, working in collaboration with G20 and in close co-operation with the EU, has developed a global standard for automatic exchange
More informationCOSTAS TSIELEPIS & CO LTD
COSTAS TSIELEPIS & CO LTD TAX UPDATE Authored By: ALEXIS TSIELEPIS, Director, Head of Taxation VOLUME 5, ISSUE 2 knowledge Facts, information and skills acquired through experience or education; the theoretical
More informationA guide to FACTA and the new Common Reporting Standard. For advisers use only.
A guide to FACTA and the new Common Reporting Standard For advisers use only. Contents 01 Introduction 01 Background 02 How are we complying with FACTA in the UK? 02 How are we complying with FACTA in
More informationTax certification for Entities FATCA and CRS
Schroder Investment Management Australia Limited Level 20, Angel Place 123 Pitt Street Sydney, NSW 2000 www.schroders.com.au AFSL 226473 ABN 22 000 443 274 Tax certification for Entities FATCA and CRS
More information- Act Nr. XXXVII of 2013 on certain regulation connected with the international administrative cooperation on tax and other public burdens.
Dear Customer, The Hungarian Parliament introduced the Common Reporting Standards, CRS on the automatic financial data exchange with the effect of 01.01.2016. The aim of the regulation is to hinder the
More informationFACT SHEET. Automatic exchange of information (AEOI)
FACT SHEET Automatic exchange of information (AEOI) In a joint statement, a number of countries, including all major financial centres and Liechtenstein, have announced that they will introduce the new
More informationRSM AND HFMWEEK CRS/FATCA SURVEY HOW DO FUNDS INTEND TO ADDRESS CRS AND FATCA COMPLIANCE CHALLENGES?
RSM AND HFMWEEK CRS/FATCA SURVEY HOW DO FUNDS INTEND TO ADDRESS CRS AND FATCA COMPLIANCE CHALLENGES? During the third quarter of 2016, RSM and Hedge Fund Management Week (HFMWeek) surveyed chief operating
More informationOrganisation de Coopération et de Développement Économiques Organisation for Economic Co-operation and Development
Unclassified English/French Unclassified Organisation de Coopération et de Développement Économiques Organisation for Economic Co-operation and Development 25-Sep-2009 English/French COUNCIL Council DECISION
More informationGlobal Forum on Transparency and Exchange of Information for Tax Purposes. Statement of Outcomes
Global Forum on Transparency and Exchange of Information for Tax Purposes Statement of Outcomes 1. On 25-26 October 2011, over 250 delegates from 84 jurisdictions and 9 international organisations and
More informationMEXICO - INTERNATIONAL TAX UPDATE -
TTN Conference May 2017 MEXICO - INTERNATIONAL TAX UPDATE - Arturo G. Brook Main Taxes Income Tax Value Added Tax Others Agenda DTTs and TIEAs FATCA (IGA) and CRS Choice of Vehicles Income Tax - General
More informationConvention on Mutual Administrative Assistance in Tax Matters as amended by the 2010 Protocol
European Treaty Series - No. 127 Convention on Mutual Administrative Assistance in Tax Matters as amended by the 2010 Protocol Strasbourg, 1.VI.2011 Annex B Competent authorities (*) States From A to F
More informationFATCA: THE NEXT PHASE Thursday 05 March 2015
FATCA: THE NEXT PHASE Thursday 05 March 2015 Martin Popplewell & Paul Woodman (Deloitte) Lorraine Wheeler (First Names Group) - Chair STEP Jersey is sponsored by: STEP Jersey FATCA The Next Phase Martin
More informationCayman Islands - FATCA and CRS Top tips & pitfalls to avoid in 2018
Cayman Islands - FATCA and CRS Top tips & pitfalls to avoid in 018 In this article we share our tips for reporting success for a Cayman Investment Entity Financial Institution (FI) and common pitfalls
More informationTax Game Changers Yair Zorea, Tax Partner, PwC Israel Yitzhak Zahavy, Tax Supervisor, PwC Israel November 2015
www.pwc.com/il Tax Game Changers Yair Zorea, Tax Partner, Yitzhak Zahavy, Tax Supervisor, November 2015 Agenda FATCA Common Reporting Standard IRS Audit Trends A look under the hood 2 FATCA 3 Foreign Account
More informationFATCA FAQS FATCA AND THE MOVEMENT TO HARMONISE INTERNATIONAL TAX COMPLIANCE AND TRANSPARENCY
FATCA FAQS FATCA AND THE MOVEMENT TO HARMONISE INTERNATIONAL TAX COMPLIANCE AND TRANSPARENCY The last decade has seen an extraordinary number of tax information exchange agreements (TIEAs), which the Organisation
More informationTHE COMMON REPORTING STANDARD ("CRS") - SECOND UPDATE (JUNE 2016) FOR OCORIAN CLIENTS
JERSEY BRIEFING June 2016 THE COMMON REPORTING STANDARD ("CRS") - SECOND UPDATE (JUNE 2016) FOR OCORIAN CLIENTS Ocorian previously issued a briefing in October 2015 ("first update") to all its clients
More informationTRANS WORLD COMPLIANCE, INC. CARIBBEAN ASSOCIATION OF BANKS, INC. & BARBADOS INTERNATIONAL BUSINESS ASSOC. Presents: FATCA compliance update
TRANS WORLD COMPLIANCE, INC. IN PARTNERSHIP WITH CARIBBEAN ASSOCIATION OF BANKS, INC. & BARBADOS INTERNATIONAL BUSINESS ASSOC. Presents: FATCA compliance update AGENDA Current FATCA status / update FATCA
More informationThe Development of Tax Transparency in
The Development of Tax Transparency in OECD Countries Hoang Ha Nguyen Thi and Till Nikolka 1 Over the course of globalisation, governments have been confronted with the growing international dimension
More information55/2005 and 78/2005 Convention on automatic exchange of information
INCOME TAX TREATIES AND AGREEMENTS ON THE TAXATION OF INCOME FROM SAV- INGS (IN FORCE, SIGNED, INITIALLED OR IN NEGOTIATING PROCESS, SITUATION ON 25th April 2018) Country Year of conclusion Number in the
More informationTax trends and issues for financial services. Michael Velten, Southeast Asia Financial Services Industry Tax Leader
Tax trends and issues for financial services Michael Velten, Southeast Asia Financial Services Industry Tax Leader Agenda Overview: Tax as a risk BEPS: A changing tax landscape CRS: Status in the region
More informationSCHEDULE OF REVIEWS (DECEMBER 2017)
2016-2020 SCHEDULE OF REVIEWS (DECEMBER 2017) 2016-2021 SCHEDULE OF EOIR REVIEWS 1. At its meeting in Jakarta on 21-22 November 2013, the Global Forum agreed that a new round of peer reviews for the Exchange
More informationCRS Form for Tax Residency Self Certification For Individuals, Joint Accounts (CRS I)
For Individuals, Joint Accounts (CRS I) Please read these instructions carefully before completing the form Chapter XIIA of Income Tax Rules, 2002 and Regulations based on the OECD Common Reporting Standard
More informationJapan s DTA Strategy and its Implications to Developing Countries. April 9 th, 2015 Kentaro Ogata
Japan s DTA Strategy and its Implications to Developing Countries April 9 th, 2015 Kentaro Ogata Table of Contents Role of DTA DTA strategy: basics JP and DC perspectives New initiatives Growing focus
More informationFATCA. Its Implications for the Financial Services Industry in Belize (A Banking Perspective) February 19, 2015 Aldo J. Salazar
FATCA Its Implications for the Financial Services Industry in Belize (A Banking Perspective) February 19, 2015 Aldo J. Salazar Introduction The Foreign Account Tax Compliance Act (FATCA) was signed into
More informationCOMPANY DETAILS FORM
FOR USE IN MAURITIUS COMPANY DETAILS FORM IMPORTANT: ALL SECTIONS MUST BE COMPLETED Name of proposed new entity: (if known) Name of applicant company: Company type: (please tick one box) Quoted on a stock
More informationIRS Reporting Rules. Reference Guide. serving the people who serve the world
IRS Reporting Rules Reference Guide serving the people who serve the world The United States has and continues to maintain a policy of not taxing the deposit interest earned by United States (US) nonresidents
More informationRev. Proc Implementation of Nonresident Alien Deposit Interest Regulations
Rev. Proc. 2012-24 Implementation of Nonresident Alien Deposit Interest Regulations SECTION 1. PURPOSE Sections 1.6049-4(b)(5) and 1.6049-8 of the Income Tax Regulations, as revised by TD 9584, require
More informationPARTNERSHIP DETAILS FORM
FOR USE IN SINGAPORE PARTNERSHIP DETAILS FORM IMPORTANT: ALL SECTIONS MUST BE COMPLETED Name of proposed new entity (if known) Name of applicant partnership Form of applicant partnership Partnership Limited
More informationTRUST AND SETTLEMENT DETAILS FORM
FOR USE IN CAYMAN, DUBLIN AND JERSEY TRUST AND SETTLEMENT DETAILS FORM IMPORTANT: ALL SECTIONS MUST BE COMPLETED Name of proposed new entity: (if known) Name of trust: Date trust established: Proper law
More informationThe Global Forum on Transparency and Exchange of Information for Tax Purposes
ANNEXES 1 The Global Forum on Transparency and Exchange of formation for Tax Purposes INFORMATION BRIEF November 2013 For more information please contact: Monica Bhatia, Head of the Global Forum Secretariat
More informationTotal Imports by Volume (Gallons per Country)
2/6/2019 Imports by Volume (Gallons per Country) YTD YTD Country 11/2017 11/2018 % Change 2017 2018 % Change MEXICO 48,959,909 54,285,392 10.9 % 657,851,150 716,916,480 9.0 % NETHERLANDS 11,903,919 10,024,814
More informationTotal Imports by Volume (Gallons per Country)
3/6/2019 Imports by Volume (Gallons per Country) YTD YTD Country 12/2017 12/2018 % Change 2017 2018 % Change MEXICO 54,169,734 56,505,154 4.3 % 712,020,884 773,421,634 8.6 % NETHERLANDS 11,037,475 8,403,018
More informationTotal Imports by Volume (Gallons per Country)
12/6/2018 Imports by Volume (Gallons per Country) YTD YTD Country 10/2017 10/2018 % Change 2017 2018 % Change MEXICO 56,462,606 60,951,402 8.0 % 608,891,240 662,631,088 8.8 % NETHERLANDS 11,381,432 10,220,226
More informationINTERNATIONAL CONVENTION ON STANDARDS OF TRAINING, CERTIFICATION AND WATCHKEEPING FOR SEAFARERS (STCW), 1978, AS AMENDED
E 4 ALBERT EMBANKMENT LONDON SE1 7SR Telephone: +44 (0)20 7735 711 Fax: +44 (0)20 7587 3210 1 January 2019 INTERNATIONAL CONVENTION ON STANDARDS OF TRAINING, CERTIFICATION AND WATCHKEEPING FOR SEAFARERS
More informationTotal Imports by Volume (Gallons per Country)
10/5/2017 Imports by Volume (Gallons per Country) YTD YTD Country 08/2016 08/2017 % Change 2016 2017 % Change MEXICO 51,349,849 67,180,788 30.8 % 475,806,632 503,129,061 5.7 % NETHERLANDS 12,756,776 12,954,789
More informationGENERAL ANTI AVOIDANCE RULE RECENT CASE LAW IN ARGENTINA
GENERAL ANTI AVOIDANCE RULE RECENT CASE LAW IN ARGENTINA Leandro M. Passarella Passarella Abogados TTN Conferences Latin America 2014 Buenos Aires November 17, 2014 Background Past structures Case Law
More informationCOMPANY DETAILS FORM
FOR USE IN JERSEY COMPANY DETAILS FORM IMPORTANT: ALL SECTIONS MUST BE COMPLETED Name of proposed new entity: (if known) Name of applicant company: Company type: (please tick one box) Quoted on a stock
More informationGlobal Forum on Transparency and Exchange of Information for Tax Purposes
Global Forum on Transparency and Exchange of Information for Tax Purposes Automatic Exchange of Information Implementation Report 2017 AEOI Implementation Report 2017 1 2 Table of contents Executive summary...
More informationTotal Imports by Volume (Gallons per Country)
1/5/2018 Imports by Volume (Gallons per Country) YTD YTD Country 11/2016 11/2017 % Change 2016 2017 % Change MEXICO 50,994,409 48,959,909 (4.0)% 631,442,105 657,851,150 4.2 % NETHERLANDS 9,378,351 11,903,919
More informationFATCA: Developments & perspectives
FATCA: Developments & perspectives Automatic Exchange of Information 22 May 2014 FATCA evolves into CRS a multilateral automatic exchange of information 2010 The Foreign Account Tax Compliance Act (FATCA)
More informationINTERNATIONAL CONVENTION ON STANDARDS OF TRAINING, CERTIFICATION AND WATCHKEEPING FOR SEAFARERS (STCW), 1978, AS AMENDED
E 4 ALBERT EMBANKMENT LONDON SE 7SR Telephone: +44 (0)20 7735 76 Fax: +44 (0)20 7587 320 MSC./Circ.64/Rev.5 7 June 205 INTERNATIONAL CONVENTION ON STANDARDS OF TRAINING, CERTIFICATION AND WATCHKEEPING
More informationTotal Imports by Volume (Gallons per Country)
11/2/2018 Imports by Volume (Gallons per Country) YTD YTD Country 09/2017 09/2018 % Change 2017 2018 % Change MEXICO 49,299,573 57,635,840 16.9 % 552,428,635 601,679,687 8.9 % NETHERLANDS 11,656,759 13,024,144
More informationTotal Imports by Volume (Gallons per Country)
10/5/2018 Imports by Volume (Gallons per Country) YTD YTD Country 08/2017 08/2018 % Change 2017 2018 % Change MEXICO 67,180,788 71,483,563 6.4 % 503,129,061 544,043,847 8.1 % NETHERLANDS 12,954,789 12,582,508
More informationFACT SHEET. Automatic exchange of information (AEOI)
FACT SHEET Automatic exchange of information (AEOI) In a joint statement, a number of countries, including all major financial centres and Liechtenstein, have announced that they will introduce the new
More informationUpdate on the Work of the Global Forum and Outline of Future Directions
Update on the Work of the Global Forum and Outline of Future Directions 4 th IMF-Japan High Level Tax Conference Tokyo, Japan Dónal Godfrey, Global Forum Secretariat Global Forum on Transparency and Exchange
More informationTotal Imports by Volume (Gallons per Country)
7/6/2018 Imports by Volume (Gallons per Country) YTD YTD Country 05/2017 05/2018 % Change 2017 2018 % Change MEXICO 71,166,360 74,896,922 5.2 % 302,626,505 328,397,135 8.5 % NETHERLANDS 12,039,171 13,341,929
More informationTotal Imports by Volume (Gallons per Country)
2/6/2018 Imports by Volume (Gallons per Country) YTD YTD Country 12/2016 12/2017 % Change 2016 2017 % Change MEXICO 50,839,282 54,169,734 6.6 % 682,281,387 712,020,884 4.4 % NETHERLANDS 10,630,799 11,037,475
More informationTotal Imports by Volume (Gallons per Country)
5/4/2016 Imports by Volume (Gallons per Country) YTD YTD Country 03/2015 03/2016 % Change 2015 2016 % Change MEXICO 53,821,885 60,813,992 13.0 % 143,313,133 167,568,280 16.9 % NETHERLANDS 11,031,990 12,362,256
More informationTHE MULTILATERAL CONVENTION ON MUTUAL ADMINISTRATIVE ASSISTANCE IN TAX MATTERS AND THE PATH TO THE OECD-STANDARD ON AUTOMATIC EXCHANGE OF INFORMATION
THE MULTILATERAL CONVENTION ON MUTUAL ADMINISTRATIVE ASSISTANCE IN TAX MATTERS AND THE PATH TO THE OECD-STANDARD ON AUTOMATIC EXCHANGE OF INFORMATION Dr. Achim Pross Head of International Cooperation and
More informationCB CROSS BORDER YOUR GOAL. OUR MISSION.
CB CROSS BORDER YOUR GOAL. OUR MISSION. Your Chosen Counsel Because We care We are an international private wealth advisory We specialize in providing offshore solutions crossborderworldwide.com What we
More informationTotal Imports by Volume (Gallons per Country)
3/7/2018 Imports by Volume (Gallons per Country) YTD YTD Country 01/2017 01/2018 % Change 2017 2018 % Change MEXICO 54,235,419 58,937,856 8.7 % 54,235,419 58,937,856 8.7 % NETHERLANDS 12,265,935 10,356,183
More informationTotal Imports by Volume (Gallons per Country)
6/6/2018 Imports by Volume (Gallons per Country) YTD YTD Country 04/2017 04/2018 % Change 2017 2018 % Change MEXICO 60,968,190 71,994,646 18.1 % 231,460,145 253,500,213 9.5 % NETHERLANDS 13,307,731 10,001,693
More informationFATCA Update May 2014
www.pwc.com The Basics Foreign Account Tax Compliance Act Purpose of Prevent and detect offshore tax evasion by US citizens Increased information reporting Enforced by withholding tax Effective begins
More informationConvention on Mutual Administrative Assistance in Tax Matters
Convention on Mutual Administrative Assistance in Tax Matters Strasbourg, 25.I.1988 Annex B Competent authorities (*) European Treaty Series - No. 127 States From A to F Albania Argentina Australia Austria
More informationTotal Imports by Volume (Gallons per Country)
4/5/2018 Imports by Volume (Gallons per Country) YTD YTD Country 02/2017 02/2018 % Change 2017 2018 % Change MEXICO 53,961,589 55,268,981 2.4 % 108,197,008 114,206,836 5.6 % NETHERLANDS 12,804,152 11,235,029
More informationGUERNSEY. Sections 75C and 75CC of the Income Tax (Guernsey) Law, 1975
GUERNSEY Sections 75C and 75CC of the Income Tax (Guernsey) Law, 1975 75C. Notices under section 75A and 75B: requests for information. 75CC. Implementation of approved international agreements by regulation.
More informationa closer look GLOBAL TAX WEEKLY ISSUE 249 AUGUST 17, 2017
GLOBAL TAX WEEKLY a closer look ISSUE 249 AUGUST 17, 2017 SUBJECTS TRANSFER PRICING INTELLECTUAL PROPERTY VAT, GST AND SALES TAX CORPORATE TAXATION INDIVIDUAL TAXATION REAL ESTATE AND PROPERTY TAXES INTERNATIONAL
More informationInternational Journal TM
International Journal TM Reproduced with permission from Tax Management International Journal, Vol. 47, No. 12, 12/07/2018. Copyright 2018 by The Bureau of National Affairs, Inc. (800-372-1033) http://www.bna.com
More informationCurrent Status of U.S. Tax Treaties and International Tax Agreements
Tax Management International Journal TM Reproduced with permission from Tax Management International Journal, Vol. 47, No. 12, p. 788, 12/08/2017. Copyright 2017 by The Bureau of National Affairs, Inc.
More informationForeign Account Tax Compliance Act (FATCA)
Foreign Account Tax Compliance Act (FATCA) Andrea Garcia Castelao November 18, 2013 Foreign Account Tax Compliance Act (FATCA) 0 2013 Deloitte Tax LLP FATCA Update Final FATCA regulations were released
More informationCommon Reporting Standard
www.pwc.com Common Reporting Standard Singapore September 2016 1. Setting the scene 2 Asset management in the spotlight FATCA 3 CRS is the next wave of increasing global standards on Tax Information Reporting
More informationInformation Leaflet No. 5
Information Leaflet No. 5 REGISTRATION OF EXTERNAL COMPANIES INFORMATION LEAFLET NO. 5 / May 2017 1. INTRODUCTION An external (foreign) limited company registered abroad may establish a branch in the State.
More informationAttorneys at Law. 11th Annual International Estate Planning Institute New York City, 12 & 13 March 2015
FATCA Implementation Attorneys at Law 11th Annual International Estate Planning Institute New York City, 12 & 13 March 2015 Presenters: Anthony Cetta: Citi Trust Wealth Planner, Citigroup (New York, NY)
More informationSession 4, Stream 6. Global regulation of lending. John Paul Zammit. 07 & 08 October 2015
Session 4, Stream 6 Global regulation of lending John Paul Zammit 07 & 08 October 2015 This document sets out a high level summary only of the information received from local counsel for the purposes of
More informationTax Management International Journal
Tax Management International Journal Reproduced with permission from Tax Management International Journal, 43 TMIJ 540, 09/12/2014. Copyright 2014 by The Bureau of National Affairs, Inc. (800-372- 1033)
More informationInformation Leaflet No. 5
Information Leaflet No. 5 REGISTRATION OF EXTERNAL COMPANIES INFORMATION LEAFLET NO. 5 / FEBRUARY 2018 ii 1. INTRODUCTION An external (foreign) limited company registered abroad may establish a branch
More informationThe outcomes of the meeting which were agreed by participants 1, as well as the next steps in the process, are set out below 2.
Summary of Outcomes of the Meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes Held in Mexico on 1-2 September 2009 178 delegates from over 70 jurisdictions and international
More informationCOMMONWEALTH OF DOMINICA
COMMONWEALTH OF DOMINICA CITIZENSHIP BY INVESTMENT Simply Perfect CITIZENSHIP BENEFITS UNITED ST ATES MEXICO ATEMALA THE BAHAMAS CUBA DOMINICAN REPUBLIC PUERTO RICO SAINT KITTS and NEVIS GU EL SALVADOR
More informationBelize FedEx International Priority. FedEx International Economy 3
SERVICES AND RATES FedEx International Solutions for your business Whether you are shipping documents to meet a deadline, saving money on a regular shipment or moving freight, FedEx offers a suite of transportation
More informationBelize FedEx International Priority. FedEx International Economy 3
SERVICES AND RATES FedEx International Solutions for your business Whether you are shipping documents to meet a deadline, saving money on a regular shipment or moving freight, FedEx offers a suite of transportation
More informationNon-XIS Return for 2016: Business not processed through Xchanging or via the Lloyd s Direct Reporting process
market bulletin Ref: Y5045 Title Non-XIS Return for 2016: Business not processed through Xchanging or via the Lloyd s Direct Reporting process Purpose To arrange the collection of all premiums and claims
More informationProgress Towards Tax Transparency
COMMITTED TO YOU April 2015 Progress Towards Tax Transparency OECD Developments The Swiss Strategy Latest Steps Impact - What s Next Union Bancaire Privée, UBP SA Rue du Rhône 96-98 CP 1320 1211 Geneva
More informationSt. Martin 2013 SERVICES AND RATES
SERVICES AND RATES FedEx International Solutions for your business Whether you are shipping documents to meet a deadline, saving money on a regular shipment or moving freight, FedEx offers a suite of transportation
More informationForeign Account Tax Compliance Act (FATCA)
Foreign Account Tax Compliance Act (FATCA) Impact Assessment on the Financial Services (Banking and Insurance) sectors and businesses in Trinidad and Tobago Presentation by the Bankers Association of Trinidad
More informationFedEx International Priority. FedEx International Economy 3
SERVICES AND RATES FedEx International Solutions for your business Whether you are shipping documents to meet a deadline, saving money on a regular shipment or moving freight, FedEx offers a suite of transportation
More informationBRICS V Legal Forum Conference 2018
Professor Michael Honiball Tel: 011 535 8136 E-mail: mhoniball@werksmans.com BRICS V Legal Forum Conference 2018 Streamlining the Tax Treaty Mutual Agreement Procedure (MAP) between BRICS Member States
More informationWho is in scope of the AEoI?
Who is in scope of the AEoI? Transparent treatment of foundations, trusts and domiciliary companies under the Automatic Exchange of Information (AEoI) by Jürg Birri und Philipp Zünd January 2018 kpmg.ch
More informationArgentina Bahamas Barbados Bermuda Bolivia Brazil British Virgin Islands Canada Cayman Islands Chile
Americas Argentina (Banking and finance; Capital markets: Debt; Capital markets: Equity; M&A; Project Bahamas (Financial and corporate) Barbados (Financial and corporate) Bermuda (Financial and corporate)
More informationDouble Tax Treaties. Necessity of Declaration on Tax Beneficial Ownership In case of capital gains tax. DTA Country Withholding Tax Rates (%)
Double Tax Treaties DTA Country Withholding Tax Rates (%) Albania 0 0 5/10 1 No No No Armenia 5/10 9 0 5/10 1 Yes 2 No Yes Australia 10 0 15 No No No Austria 0 0 10 No No No Azerbaijan 8 0 8 Yes No Yes
More informationThe Foreign Account Tax Compliance Act (FATCA) AUTOMATIC EXCHANGE OF INFORMATION. Questions and Answers WHAT IS AUTOMATIC EXCHANGE OF INFORMATION
The Foreign ccount Tax Compliance ct (FTC) and COMMON REPORTING STNDRDS (CRS) UTOMTIC EXCHNGE OF INFORMTION uestions and nswers This document provides you with an overview of the FTC and the CRS agreements
More informationMINISTERIAL REGULATION dated February 7, 2014 for the modification of the Regulation on registration and registration reference (AB 1991 no.
[Emblem] 2014 no. 15 LEGAL PROCLAMATION BULLETIN OF ARUBA MINISTERIAL REGULATION dated February 7, 2014 for the modification of the Regulation on registration and registration reference (AB 1991 no. GT
More informationFOREIGN ACTIVITY REPORT
FOREIGN ACTIVITY REPORT SECOND QUARTER 2012 TABLE OF CONTENTS Table of Contents... i All Securities Transactions... 2 Highlights... 2 U.S. Transactions in Foreign Securities... 2 Foreign Transactions in
More informationSection 872. Gross Income. Rev. Rul
Section 872. Gross Income (Also sections 883, 894.) 26 CFR 1.872 2: Exclusions from gross income of nonresident alien individuals. (Also 26 CFR 1.883 1.) This revenue ruling updates the list of countries
More informationRegistration of Foreign Limited Partnerships in the Cayman Islands
Registration of Foreign Limited Partnerships in the Cayman Islands Preface This publication has been prepared for the assistance of those who are considering registration of a foreign limited partnership
More informationTRENDS AND MARKERS Signatories to the United Nations Convention against Transnational Organised Crime
A F R I C A WA T C H TRENDS AND MARKERS Signatories to the United Nations Convention against Transnational Organised Crime Afghanistan Albania Algeria Andorra Angola Antigua and Barbuda Argentina Armenia
More informationCountries with Double Taxation Agreements with the UK rates of withholding tax for the year ended 5 April 2012
Countries with Double Taxation Agreements with the UK rates of withholding tax for the year ended 5 April 2012 This table shows the maximum rates of tax those countries with a Double Taxation Agreement
More informationReporting practices for domestic and total debt securities
Last updated: 27 November 2017 Reporting practices for domestic and total debt securities While the BIS debt securities statistics are in principle harmonised with the recommendations in the Handbook on
More informationSave up to 74% on U.S. postage.
BRITISH COLUMBIA RATE CARD 2019 Effective January 27 2019 Save up to 74% on U.S. postage. Postage from $2.66 USD Delivery within 4 business days Tracking included Chit Chats Insurance from $0.35 Canada
More informationPENTA CLO 2 B.V. (the "Issuer")
THIS NOTICE CONTAINS IMPORTANT INFORMATION OF INTEREST TO THE REGISTERED AND BENEFICIAL OWNERS OF THE NOTES (AS DEFINED BELOW). IF APPLICABLE, ALL DEPOSITARIES, CUSTODIANS AND OTHER INTERMEDIARIES RECEIVING
More information