Common Reporting Standard

Common Reporting Standard, Compliance, Europe, Germany, Italy, Law enforcement, MNE Profits, Tax transparency, United Kingdom

(Temple Tax Chambers; King’s College London)/ /1 Comment

Tax authorities have relied on informers for investigative leads perhaps since taxes were first imposed. In the 21st Century high profile cases of theft of taxpayer information by employees of service providers including banks and professional firms have provided data not only of interest to tax authorities but also as a driver of international tax…

Administrative cooperation, Administrative obligations, Common Reporting Standard, Exchange of Information, FATCA, Germany, India, International Tax Law, Law enforcement, Mandatory disclosure, Personal income tax, Residence, Tax Treaties, United Kingdom, United States

(Temple Tax Chambers; King’s College London)/ /1 Comment

HMRC v Embiricos [2020] UKUT 370 (TC) reflects a common issue that arises in connection with tax investigations or audits of internationally mobile individuals. Mr Embiricos  filed his tax returns on the basis that he was resident, but not domiciled in the UK. On that basis, he was entitled to the remittance basis of taxation….

Common Reporting Standard, Exchange of Information, FATCA, Financial institutions, Tax Avoidance, Tax Policy, Trusts and Estates, United States

(DCIT, Foreign Tax and Tax Research Division, Government of India)/ /1 Comment

In the 1980s, a new dimension to profit shifting was introduced in the United States through the establishment of Onshore Offshore Banks. New legislation (called the International Banking Facility (IBF)) allowed banks in the US to maintain two separate sets of accounts. One set capturing all transactions with residents of USA which would be subject…