http://www.scmp.com/business/banking-finance/article/1819470/hk-financial-sector-seeks-exemption-new-tax-reporting-rule The financial industry is seeking exemption from a tax law on sharing of foreigners' account information, which would add to their reporting requirements. Secretary for Financial Services and the Treasury Chan Ka-keung said the proposed law, which is under a three-month consultation until the end of this month, would affect about 2,900 firms, including banks, brokers, insurers and fund houses. The government wants to table the proposal in the Legislative Council next year. If passed, the law would allow the government to automatically exchange from 2018 non-residents' financial information with other countries to prevent tax avoidance. The exchange of information will be on an annual basis instead of on request.
The Convention on Mutual Administrative Assistance in Tax Matters ("the Convention") was developed jointly by the OECD and the Council of Europe in 1988 and amended by Protocol in 2010. The Convention is the most comprehensive multilateral instrument available for all forms of tax co-operation to tackle tax evasion and avoidance, a top priority for all countries. The Convention was amended to respond to the call of the G20 at its 2009 London Summit to align it to the international standard on exchange of information on request and to open it to all countries, in particular to ensure that developing countries could benefit from the new more transparent environment. The amended Convention was opened for signature on 1 June 2011. Since 2009, the G20 has consistently encouraged countries to sign the Convention including most recently at the meeting of the G20 Finance Ministers and Central Bank Governors Meeting in February 2016 where the communique stated "We reiterate our call for all countries to join the Multilateral Convention on Mutual Administrative Assistance in Tax Matters [...]" 109 jurisdictions currently participate in the Convention, including 15 jurisdictions covered by territorial extension. This represents a wide range of countries including all G20 countries, all BRIICS, all OECD countries, major financial centres and an increasing number of developing countries.http://www.oecd.org/ctp/exchange-of-tax-information/convention-on-mutual-administrative-assistance-in-tax-matters.htm
- hkej 25apr17 article by tsang ka wai of oxfam
Its purpose is to combat tax evasion. The idea was based on the U.S. Foreign Account Tax Compliance Act (FATCA) implementation agreements and its legal basis is the Convention on Mutual Administrative Assistance in Tax Matters. 97 countries had signed an agreement to implement it, with more countries intending to sign later. First reporting occurred in 2017, with many of the rest starting in 2018.
- http://hk.hkcd.com/pdf/201809/0905/HA11905CZGG.pdf china implement in sep18
London summit
- http://www.theguardian.com/world/2016/may/04/cameron-to-propose-global-anti-corruption-agency-at-summit
- http://www.theguardian.com/world/2016/may/09/tax-havens-have-no-economic-justification-say-top-economists
boosting tax revenue
- economist 2mar19 "hitting the jackpot" some countries are using receipt lotteries to boost tax revenues
Assets offshore
- http://orientaldaily.on.cc/cnt/china_world/20160510/00180_012.html 國際調查記者同盟（ICIJ）早前公布「巴拿馬文件」，揭露全球多名富商政要在離岸避稅天堂設有公司或戶口。英國組織「稅務公正網絡」（Tax Justice Network）日前公布研究，估計逾十二萬億美元（約九十三萬六千億港元）資產，從中國、俄羅斯及其他發展中國家和地區抽取至離岸，佔全球金融資產總值百分之十至十五。該項研究由美國哥倫比亞大學教授亨利（James S. Henry）領導，以國際貨幣基金組織（IMF）及聯合國的數據為基礎，歷時十八個月完成。報告指，至二○一四年末，中國公民合共有一萬二千億美元（約九萬四千億港元）資產藏於離岸，報告亦將香港及澳門列為離岸「稅務天堂」。俄羅斯則有一萬三千億美元（約十萬一千億港元）流至離岸。
robots
- http://www.economist.com/news/finance-and-economics/21717374-bill-gatess-proposal-revealing-about-challenge-automation-poses-why-taxing
Panama papers
- full list of people involvedhttps://projects.icij.org/panama-papers/power-players/index.html
- http://www.vox.com/2016/4/3/11356326/panama-papers Here are a few of the highlights that the team found, with links to the full stories where you can read the details:
Vladimir Putin's inner circle appears to control about $2 billion worth of offshore assets.
The Prime Minister of Iceland secretly owned the debt of failed Icelandic banks while he was involved in political negotiations over their fate.
The family of Pakistan's prime minister owns millions of dollars worth of real estate via offshore accounts.
Ukrainian President Petro Poroshenko pledged to sell his Ukrainian business interests during his campaign, but appears instead to have transferred them to an offshore company he controls.
The International Consortium of Investigative Journalists has a full profile ofpolitical figures and their relatives named in the Panama Papers for your reading pleasure. But though political corruption is fun and newsy, the document dump also features a leaked memorandum from a Mossack Fonseca partner revealing the more boring truth that "Ninety-five per cent of our work coincidentally consists in selling vehicles to avoid taxes." How much money is there in offshore tax havens? A big part of the idea, of course, is to make it hard for anyone to know for sure. But Gabriel Zucman, an economics professor at UC Berkley, has made the most detailed study of the question for his book The Hidden Wealth of Nations and estimates that it totals at least $7.6 trillion. That's upwards of 8 percent of all the world's financial wealth, and it's growing fast. Zucman estimates that offshore wealth has surged about 25 percent over the past five years. Much of that reflects "new money" from China and other developing nations whose citizens to an extent have legitimate fears about political stability and the rule of law. But some of it is simple avarice. The name of Ian Cameron, the late father of British Prime Minister David Cameron, shows up in the Panama Papers, for example. Mossack Fonseca helped him set up his investment company Blairmore Holdings (named after his family's ancestral country estate) in the British Virgin Islands where, marketing material assured investors, the company "will not be subject to United Kingdom corporation tax or income tax on its profits."
- http://www.theguardian.com/global/2016/apr/04/panama-papers-release-sparks-war-of-words-in-australia-over-tax-avoidance Of the 800 individual taxpayers identified by the ATO, an analysis of the files by Guardian Australia and the ABC reveals that Mossack Fonseca acts for 77 Australian clients.
- http://hk.apple.nextmedia.com/news/art/20160405/19558024 「巴拿馬文件」顯示，2012年新地高層貪污案曾令雙方關係一度緊張。新地在原執董陳鉅源（圖）被捕後，要求莫薩克．馮賽卡關閉陳有份擔任董事20年的離岸公司Yorkshire Limited，但律師行的法律部門這時得知陳鉅源被捕、他可能有違英屬處女島對公司董事的規定，要求新地提供更多關於陳的資料作盡職審查，以備香港當局未來查問，律師行內部甚至有聲音建議向英屬處女島當局舉報新地。起初新地拒絕，莫薩克．馮賽卡的本港分公司也反對逼得新地太緊，擔心生意會流失。雙方糾纏了3個月後，新地最終提供所需資料關閉Yorkshire Limited。不過，事件未完結，莫薩克．馮賽卡在2014年再發現陳鉅源持有另一間離岸空殼公司Moricrown，這間公司另一股東是本港富商李嘉誠旗下長實一間子公司。不久，陳罪成被判入獄6年。
- https://www.icij.org/investigations/panama-papers/second-panama-papers-leak-findings-from-around-the-world/
- pakistan
Oecd
- Base erosion and profit shifting (BEPS) refers to tax avoidance strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations. Under the inclusive framework, over 100 countries and jurisdictions are collaborating to implement the BEPS measures and tackle BEPS.http://www.oecd.org/tax/beps/
measures to combat evasion
- economist 2mar19 "hitting the jackpot" some countries are using receipt lotteries to boost tax revenues
usa
- fatca
- blackstone
EU
- https://www.ft.com/content/4680a384-c2fb-11e7-a1d2-6786f39ef675 European officials have told 53 countries and territories that they risk being blacklisted as tax havens after the UK earlier delayed warnings to a dozen jurisdictions with ties to Britain. Brussels advised 41 countries 10 days ago that they would be blacklisted unless they promised to change their tax rules, according to people close to the talks. But British concerns caused the EU to hold back similar warnings for 12 more jurisdictions including Bermuda, the Isle of Man and Cayman Islands — what one official called the “usual suspects”. London changed its stance late last week, two days before the “Paradise Papers” leak put the issue of global tax legislation back in the spotlight. The European Council, made up of EU member states, started analysing non-EU countries last year to decide if they should be designated as tax havens, sending inquiry letters to 92 jurisdictions in February after initial screening. The council has set criteria for countries to avoid being labelled as tax havens. Its definition of fair tax rules says jurisdictions should not offer preferential tax measures or arrangements that enable companies to move profits to avoid tax. Countries should also meet transparency standards and implement anti profit-shifting guidelines set by the Organisation for Economic Co-operation and Development. Countries that fail to meet the council’s criteria can avoid being blacklisted if they provide a political commitment and a specific plan to comply. Representatives from all 28 EU member states will need to approve the final list, which is expected to be published on 5 December.
- 歐盟本周二將澳門、南韓、阿聯酋及巴拿馬等十七個非歐盟國家及地區，列入避稅天堂黑名單，另將四十七地列入監察「灰名單」，當中香港、台灣、瑞士、土耳其、百慕達及開曼群島等均上榜，歐盟稱將觀察有關國家及地區有否遵守承諾，改變稅務規定。文件顯示，香港和台灣承諾在二○一八年前，簽署協議推行自動交換訊息制度，以提高稅務透明度；歐盟又指香港和台灣現存的稅務制度有害，兩地承諾會在二○一八年前修正或廢除相關情況。歐盟官員表示，摩洛哥與維德角承諾進行稅改後，已移至灰名單。灰名單將定期更新。中國外交部發言人耿爽周三回應指，歐盟有關決定與澳門實際情況不符；至於香港特區的情況則需要作進一步了解。香港特區政府回應指，將會繼續與歐盟聯繫，有信心可符合國際稅務新標準。http://orientaldaily.on.cc/cnt/news/20171207/00176_033.html
- https://www.icij.org/investigations/paradise-papers/eu-removes-panama-seven-others-tax-haven-black-list/ The European Union has removed eight jurisdictions, including Panama, from its tax haven blacklist that was adopted last month. Only nine countries now remain on the list. The eight countries removed are Barbados, Grenada, Macao, Mongolia, Panama, South Korea, Tunisia and the United Arab Emirates.
- https://www.reuters.com/article/us-china-beltandroad-piraeus-exclusive/eu-suspects-tax-fraud-at-chinas-new-gateway-to-europe-idUSKBN1HR2LT European Union and Italian authorities are investigating suspected wide-scale tax fraud by Chinese criminal gangs importing goods via Greece’s largest port of Piraeus, a trade gateway between China and Europe, officials said.“The VAT is completely evaded, with enormous damage to the national tax authorities and to the community,” Fabio Botto, of the Italian Central Anti-fraud Office’s special investigative unit, said in an interview. He said the suspected scam at Piraeus, part of China’s vast Belt and Road infrastructure project, had cost Italy tens of millions of euros in unpaid value-added taxes (VAT), though the total could be far higher as the investigation was not over. The European Anti-Fraud Office (OLAF) confirmed it was working with Italy on the investigation but declined to give details, citing confidentiality.
- economist 6oct18 "one foot in the algarve" loopholes allow some pensioners in EU to retire tax free
sweden
- The head of Sweden’s largest business lobby resigned Wednesday after comments he made amid Paradise Papers revelations about his offshore holdings. Leif Östling, chairman of the Confederation of Swedish Enterprise and the former head of the truckmaker Scania, and his wife owned a Maltese company called Hertsoe Ltd. that held about $3.6 million worth of stock via subsidiaries in Luxembourg, ICIJ partner SVT (Swedish public television) reported two weeks ago.https://www.icij.org/investigations/paradise-papers/swedish-business-chairman-leif-ostling-resigns-amid-paradise-papers-link/
Switzerland
- https://www.ft.com/content/890a4262-c795-11e6-8f29-9445cac8966f Switzerland wants to update a tax deal with the US next year to allow the automatic, two-way exchange of information about bank accounts between the two countries, a senior official in Bern has said. The move shows the scale of the rethink on bank secrecy in Switzerland, once famous for helping tax evasion.
africa
- https://www.icij.org/blog/2018/07/behind-the-scenes-of-the-largest-ever-west-african-journalism-collaboration/ The offshore industry is a perfect example for tackling these sorts of issues, and its impact in our region is obvious. Among the series of #WestAfricaLeaks stories, we were able to reveal the political elites’ secretive bank accounts, including a longtime friend of Liberian ex-president Ellen Johnson-Sirleaf, a Malian presidential candidate and the mayor of the Ivory Coast’s richest city, as well as identify powerful international companies like the Canadian SNC-Lavalin, who used offshore companies to avoid taxes in Senegal.
tunisia
- ft 3jan17 report on tunisia pushes to remove from tax haven blacklist
mauritius
- https://www.icij.org/investigations/mauritius-leaks/treasure-island-leak-reveals-how-mauritius-siphons-tax-from-poor-nations-to-benefit-elites/ Mauritius Leaks, a new investigation by the International Consortium of Investigative Journalists and 54 journalists from 18 countries, provides an inside look at how the former French colony has transformed itself into a thriving financial center, at least partly at the expense of its African neighbors and other less-developed countries. In Uganda, more than 40% of the population lives on less than $2 a day. Based on a cache of 200,000 confidential records from the Mauritius office of the Bermuda-based offshore law firm Conyers Dill & Pearman, the investigation reveals how a sophisticated financial system based on the island is designed to divert tax revenue from poor nations back to the coffers of Western corporations and African oligarchs, with Mauritius getting a share. The files date from the early 1990s to 2017. The island, which sells itself as a “gateway” for corporations to the developing world, has two main selling points: bargain-basement tax rates and, crucially, a battery of “tax treaties” with 46 mostly poorer countries. Pushed by Western financial institutions in the 1990s, the treaties have proved a boon for Western corporations, their legal and financial advisers, and Mauritius itself — and a disaster for most of the countries that are its treaty partners. “What Mauritius is providing is not a gateway but a getaway car for unscrupulous corporations dodging their tax obligations,” said Alvin Mosioma, executive director of the nonprofit Tax Justice Network Africa. The leaked records – including emails, contracts, meeting notes and audio recordings – provide a glimpse inside a busy offshore law firm working with global accounting and advisory firms for some of the world’s largest corporations and some very wealthy individuals. They’ve all found their way to an island built on helping the rich avoid paying taxes to nations as far-flung as the United States, Thailand, and Oman.
- https://www.icij.org/investigations/mauritius-leaks/it-takes-a-village-to-create-a-tax-dodge/
India
- http://www.ft.com/cms/s/0/c78e52d4-1760-11e6-b8d5-4c1fcdbe169f.html india has closed a loophole that has long allowed domestic and foreign investors to escape taxes on short-term investments by routing them through the tiny island nation of Mauritius. New Delhi has amended a 33-year-old tax treaty with Mauritius that had exempted the island’s investors from capital gains tax on short-term investments in India. That exemption encouraged many foreign funds and companies to route investments into India through Mauritius, frustrating New Delhi as it sought to increase its tax revenues. The government said the changes would also prevent “round-tripping”, a phenomenon by which Indian individuals and companies avoid tax by sending funds abroad and then bringing them back on to home soil via Mauritius-based companies. Much of the investment into India via Mauritius over the last 15 years is believed to have been by Indian residents. India’s finance ministry said the amendment of the treaty would “help curb tax evasion and tax avoidance” and “double non-taxation”.
marshall islands
- [ablj sep-oct19 jonathan silver maple's group]recent amendments to business corporations act reqiure all marshall islands corporations, excluding publicly traded companies, to keep and maintain a record of their ultimate beneficial owners. A beneficial owner is defined as a natural person who exercises control over a company directly or indirectly, and will generally be deemed to hold more than 25% of the interests of the company.
australia
- https://www.ft.com/content/8864c808-4d65-11e8-97e4-13afc22d86d4 Bupa is under investigation by Australian tax authorities over the healthcare provider’s approach to structuring its debt, fuelling calls from campaigners for greater transparency around how companies that receive large government subsidies structure their businesses. The UK-based company disclosed that it was under investigation by the Australian Tax Office in filings submitted locally in 2016 and in 2017, according to a report released this week. One of the filings stated that the tax authority was scrutinising Bupa’s approach to “thin capitalisation” — the practice of using loans between different corporate entities within the same group to artificially reduce a company’s tax burden. The Australian arm of the Tax Justice Network, a group that lobbies against corporate tax avoidance, said in its report that Bupa and other large healthcare providers that receive significant subsidies from the Australian government had deployed “aggressive tax avoidance strategies”.
- [packers lunch] euro pacific banking group was an investment bank set up in the cook islands, apparently with the noble intention of ensuring nobody ever paid any tax ever again. Guy jalland, a former lawyer who worked for rene rivkin before joining euro pacific, wrote to his brother-in-law, james mackenzie, who ran euro pacific's trustee business in HK
- 澳洲北塔斯馬尼亞蜂農比倫波特，與妻子芬妮多年來一直以「違反上帝意願」為由拒絕交稅，稱信徒擁有的東西皆屬於上帝，稅務法應服膺《聖經》的司法管轄。法院周三裁定，該對夫婦須支付約二百三十二萬澳元（約一千二百七十八萬港元）的稅款，他們的部分財產被地方政府沒收。https://orientaldaily.on.cc/cnt/china_world/20190720/00180_024.html
nepal
- https://www.icij.org/blog/2019/03/nepaleaks-on-the-trail-of-money-flowing-from-nepal-to-tax-havens-then-back-to-nepal/
China
- http://www.scmp.com/news/china/policies-politics/article/1943616/china-airs-plan-help-close-multibillion-dollar China is mulling plans to tighten tax reporting requirements on multinationals operating in the country to help close a massive global loophole. If the plan goes ahead, multinationals would have to file extensive reports on internal pricing and costs between overseas branches and headquarters, sources said. The plan is China’s contribution to a global effort to stamp out the common practice of multinationals altering the price put on labour, services or intangible asset transfers within global operations to allow firms to divert profits to low-tax countries. The Organisation for Economic Cooperation and Development estimated that these kinds of profit-shifting practices amounted to about US$100 billion-US$240 billion in lost tax revenue each year, equivalent to up to 10 per cent of global corporate income tax revenue. A source at a law firm told the South China Morning Postthat the State Administration of Taxation issued a consultation draft on the proposal at the end of last year, specifying that multinationals would have to disclose affiliated businesses and how intangible assets, labour and other internal cost transfers were made. “[Internal transfer pricing] is a grey area to utilise loopholes in tax rules between different countries, but now the governments [of those countries] are acting to close the hole,” the source said.
- https://www.scmp.com/news/china/science/article/3043437/china-prepares-unleash-artificial-intelligence-catch-tax-cheats Chinese scientists have been working on a system to use
artificial intelligence that would make it almost impossible to cheat on taxes, according to researchers involved in the project. Over the last three years, about 300,000 government tax inspectors have been helping to train an AI system that draws on big data to detect behaviour that may be hard for human inspectors to spot.Now the machine can flag more than 95 per cent of offences, including some new ploys unfamiliar to most human tax collectors, researchers involved in the project said.However, given the number of companies that rely on informal deals with local tax authorities to lessen their burden, the system’s introduction may be delayed until the economic climate is more favourable.
- http://paper.takungpao.com/resfile/PDF/20160630/PDF/b2_screen.pdf 5月11日，第十屆稅收徵管論壇（FTA）大會在中國北京 順利召開。38個FTA成員經濟體、6個受邀非成員經濟體和7 個國際組織以及9家企業近200名中外代表的參與，共同為國 際稅收合作譜寫新的華章。這是一次落實全球稅改、彰顯國際 稅收合作的盛會。2016年是落實稅基侵 蝕和利潤轉移（BEPS）項目成果的開局 之年，也是全面實施G20稅改成果的重 要一年。在此背景下，此次FTA大會達 成多項共識、簽署多項合作，是國際稅 收合作發展的重要里程碑。也勾畫國際 合作路線圖。- 內地嚴查偷稅漏稅盯上外國商人，四名土耳其商人近日到福建廈門參加國際石材展覽會，上周六清晨突被中國海關緝私部門以逃稅為由，在其下榻酒店被拘捕，並查扣若干文件及物品。 https://orientaldaily.on.cc/cnt/china_world/20190313/00178_009.html
hk
- 稅務局質疑牛奶公司集團透過旗下兩間公司之間的安排避稅，要該兩間公司就五個課稅年度，繳交三億四千萬元的利得稅，或一億八千萬元的商標利潤稅。牛奶公司已提出上訴，聆訊將於明年三月進行，不過，稅局堅持要牛奶公司買齊上述兩項稅種合共逾五億元儲稅券，以換取上訴期間暫緩繳稅，惟牛奶公司認為即使其公司敗訴，最多亦只須繳付三億四千萬元稅款，因此提出司法覆核。高院昨裁定稅局犯了法律錯誤，撤銷稅局的決定，發還稅局重新考慮退回多買一億八千萬元的儲稅券給牛奶公司。http://orientaldaily.on.cc/cnt/china_world/20181009/00180_022.html
Assets offshore
- http://orientaldaily.on.cc/cnt/china_world/20160510/00180_012.html 國際調查記者同盟（ICIJ）早前公布「巴拿馬文件」，揭露全球多名富商政要在離岸避稅天堂設有公司或戶口。英國組織「稅務公正網絡」（Tax Justice Network）日前公布研究，估計逾十二萬億美元（約九十三萬六千億港元）資產，從中國、俄羅斯及其他發展中國家和地區抽取至離岸，佔全球金融資產總值百分之十至十五。該項研究由美國哥倫比亞大學教授亨利（James S. Henry）領導，以國際貨幣基金組織（IMF）及聯合國的數據為基礎，歷時十八個月完成。報告指，至二○一四年末，中國公民合共有一萬二千億美元（約九萬四千億港元）資產藏於離岸，報告亦將香港及澳門列為離岸「稅務天堂」。俄羅斯則有一萬三千億美元（約十萬一千億港元）流至離岸。
robots
- http://www.economist.com/news/finance-and-economics/21717374-bill-gatess-proposal-revealing-about-challenge-automation-poses-why-taxing
Panama papers
- full list of people involvedhttps://projects.icij.org/panama-papers/power-players/index.html
- http://www.vox.com/2016/4/3/11356326/panama-papers Here are a few of the highlights that the team found, with links to the full stories where you can read the details:
Vladimir Putin's inner circle appears to control about $2 billion worth of offshore assets.
The Prime Minister of Iceland secretly owned the debt of failed Icelandic banks while he was involved in political negotiations over their fate.
The family of Pakistan's prime minister owns millions of dollars worth of real estate via offshore accounts.
Ukrainian President Petro Poroshenko pledged to sell his Ukrainian business interests during his campaign, but appears instead to have transferred them to an offshore company he controls.
The International Consortium of Investigative Journalists has a full profile ofpolitical figures and their relatives named in the Panama Papers for your reading pleasure. But though political corruption is fun and newsy, the document dump also features a leaked memorandum from a Mossack Fonseca partner revealing the more boring truth that "Ninety-five per cent of our work coincidentally consists in selling vehicles to avoid taxes." How much money is there in offshore tax havens? A big part of the idea, of course, is to make it hard for anyone to know for sure. But Gabriel Zucman, an economics professor at UC Berkley, has made the most detailed study of the question for his book The Hidden Wealth of Nations and estimates that it totals at least $7.6 trillion. That's upwards of 8 percent of all the world's financial wealth, and it's growing fast. Zucman estimates that offshore wealth has surged about 25 percent over the past five years. Much of that reflects "new money" from China and other developing nations whose citizens to an extent have legitimate fears about political stability and the rule of law. But some of it is simple avarice. The name of Ian Cameron, the late father of British Prime Minister David Cameron, shows up in the Panama Papers, for example. Mossack Fonseca helped him set up his investment company Blairmore Holdings (named after his family's ancestral country estate) in the British Virgin Islands where, marketing material assured investors, the company "will not be subject to United Kingdom corporation tax or income tax on its profits."
- http://www.theguardian.com/global/2016/apr/04/panama-papers-release-sparks-war-of-words-in-australia-over-tax-avoidance Of the 800 individual taxpayers identified by the ATO, an analysis of the files by Guardian Australia and the ABC reveals that Mossack Fonseca acts for 77 Australian clients.
- http://hk.apple.nextmedia.com/news/art/20160405/19558024 「巴拿馬文件」顯示，2012年新地高層貪污案曾令雙方關係一度緊張。新地在原執董陳鉅源（圖）被捕後，要求莫薩克．馮賽卡關閉陳有份擔任董事20年的離岸公司Yorkshire Limited，但律師行的法律部門這時得知陳鉅源被捕、他可能有違英屬處女島對公司董事的規定，要求新地提供更多關於陳的資料作盡職審查，以備香港當局未來查問，律師行內部甚至有聲音建議向英屬處女島當局舉報新地。起初新地拒絕，莫薩克．馮賽卡的本港分公司也反對逼得新地太緊，擔心生意會流失。雙方糾纏了3個月後，新地最終提供所需資料關閉Yorkshire Limited。不過，事件未完結，莫薩克．馮賽卡在2014年再發現陳鉅源持有另一間離岸空殼公司Moricrown，這間公司另一股東是本港富商李嘉誠旗下長實一間子公司。不久，陳罪成被判入獄6年。
- https://www.icij.org/investigations/panama-papers/second-panama-papers-leak-findings-from-around-the-world/
- pakistan
- Former Pakistan Prime Minister Nawaz Sharif has been sentenced to 10 years in prison and fined $10.6 million on corruption charges linked to 2016 Panama Papers revelations about his family’s properties overseas. The National Accountability Bureau, Pakistan’s anti-graft court, also has convicted Sharif’s daughter Maryam to a seven-year prison term and his son-in-law Muhammad Safdar to one year imprisonment.https://www.icij.org/investigations/panama-papers/former-pakistan-pm-sharif-sentenced-to-10-years-over-panama-papers/
- http://www.scmp.com/news/china/policies-politics/article/1940984/son-law-ex-senior-chinese-leader-jia-qinglin-named The son-in-law of one of China’s former top leaders, Jia Qinglin, has been revealed as owning a company in an offshore tax haven, according to documents in the latest batch of the Panama Papers obtained by the South China Morning Post.
- http://hk.apple.nextmedia.com/news/art/20160511/19606813國際調查記者聯盟昨公佈最新巴拿馬文件資料，涉及3.3萬名中國人，而不少大陸高級官員的名字拼音亦出現在文件中，包括財政部長樓繼偉（圖）及全國政協副主席王正偉，其中一間疑與樓相關的持股公司，註冊地址是北京東長安街2號，與大陸商務部掛牌地址一樣。據已披露的巴拿馬文件內容，與大陸有關的離岸公司有4,188間，其中疑涉不少中共官員，包括與樓繼偉（Lou Jiwei）拼音一樣的人。資料庫內的Lou Jiwei與一名叫Zhang Jianfeng的人同為一間英屬處女島註冊公司Crown Aquarius Ltd的受益人，該公司由另一間名為Crown International Trading Ltd的公司持有，這間公司註冊地址竟在北京東長安街2號，亦即大陸商務部地址，而這地址同時被註冊過千間離岸公司。
另外，疑似王正偉的名字拼音Wang Zhengwei亦榜上有名，他同時持有兩間於非洲國家塞舌爾（Seychelles）註冊的離岸公司，兩間分別名為World Quality Trans Co., Ltd及Golden Circle Co., Ltd，他本人的註冊地址在英國屬地澤西島（Jersey）。疑似其他中共官員的名字拼音亦出在文件中，包括國務委員楊晶（Yang Jing）的名字出現6次、同為國務委員的王勇（Wang Yong）出現11次等。而台灣這次涉及的公司涉2,906間，藝人吳奇隆則持有4間在英屬處女島的公司有關。 - http://orientaldaily.on.cc/cnt/china_world/20160511/00178_031.html「巴拿馬文件」牽涉中國大陸約三萬三千人、四千多家離岸公司，當中有不少人的名字拼音與高官相似，包括財政部長樓繼偉、全國政協副主席王正偉、四川省長尹力、安徽省委書記王學軍及廣西壯族自治區政府主席陳武等。台灣近兩萬台灣民眾及約二千九百間離岸公司牽涉其中。
- http://www.scmp.com/news/hong-kong/law-crime/article/1934948/panamanian-law-firms-man-hong-kong On the face of it, Zhang Xiaodong appeared to be a professional artist when he opened his photo exhibition,Obsessed in Havana, at a university in Xian last month. Only his overly formal business suit might have offered a clue about his status as the businessman in charge of the pivotal Hong Kong operation of Mossack Fonseca, a Panamanian law firm that was to become the centre of an international tax-avoidance scandal implicating political leaders, wealthy businessmen and celebrities around the world. Zhang – who is better known by his adopted Cantonese name, Austin Cheung – has for two decades been a core member of the company’s business in Hong Kong and on the mainland. The firm is accused of helping relatives of past and present Chinese leaders set up offshore companies in an alleged bid to avoid paying taxes. About a third of the Panama firm’s business was conducted on the mainland, with the bulk passing through the Hong Kong office, according to the BBC, which is part of the consortium of investigative journalists examining the Panama Papers.
- http://www.scmp.com/news/hong-kong/article/1939404/two-more-hong-kong-universities-admit-they-also-have-offshore
- http://hk.apple.nextmedia.com/news/art/20160511/19606810巴拿馬文件令本港政商界人士的離岸公司曝光，其中全國政協委員、中華總商會永遠榮譽會長蔡冠深就被發現與一名新加坡商人合組船公司，該商人曾因與涉運送大殺傷力武器的伊朗航運（IRISL）合作，違反制裁令而被美國起訴；資料更顯示蔡的公司是其中一間伊朗航運的「分身公司」在緬甸的合作夥伴。
記者︰林偉聰資料顯示蔡是一系列3間離岸公司的股東，分別是Conteast Lines Vietnam Ltd、Conteast Lines Myanmar Ltd及Conteast Lines Agencies Limited，與蔡共同持股尚有新加坡商人Cheong Kheng Guan和Richard Tao，均為1996年成立。Cheong的船務生意早在5年前已廣受傳媒關注，他名下的兩間船公司Sinose Maritime及Leading Maritime，在2011年被美國紐約法院起訴，指其與被制裁的伊朗航運合組新公司，協助該公司避過美國銀行監察，運轉約3.3億港元資金。 - http://hk.apple.nextmedia.com/news/art/20160511/19606816國際調查記者聯盟（ICIJ）昨凌晨起讓公眾於網站搜查內容，再發現本港多名富豪亦持有離岸公司，其中早前被披露透過股權重組避稅的華置前主席劉鑾雄（大劉）外，其胞弟、即利福主席劉鑾鴻（細劉）亦持有多間離岸公司，其中3更是由大劉私人助理游敏儀作為中介人。最新公開的巴拿馬文件網絡資料庫資料，細劉名下共有6個紀錄，其中兩個紀錄持有的兩間離岸公司已解散；餘下4個紀錄其中一個是一間離岸投資公司「Unicorn Investments Limited」的受益人，而大劉及華置執行董事兼公司秘書均為該公司的受權人士。另3個紀錄，則分別持有3間離岸公司，以及於部份離岸公司出任董事。由細劉持有的3間離岸公司為「Goodasia Ocean Limited」、「Shine Top Limited」及「Sam Air Group Limited」；3間公司均是由大劉私人助理游敏儀作中介人。利福發言人接受查詢時表示，有關公司均與上市公司無關。近年活躍殼股買賣的曹貴子，其胞兄曹貴宜及曹貴子手下蕭錦秋，與「玩具大王」蔡志明女兒蔡加怡共擔任兩間離岸公司董事，包括一間「Joy Surplus International Limited」，註冊地點為英附屬維京群島（BVI），另一間「Wealth Treasure Group Limited」，同樣在BVI註冊。事實上，自蔡志明2005年入股康健國際後，已安排女兒蔡加怡出任主席，兩家關係變得非常密切。上述兩間公司的股份，均由一間「Charm Advance Limited」持有。當中「Charm Advance Limited」及BVI公司「Town Health（BVI） Limited」則共同持有BVI公司「Fair Jade Group Limited」，以上公司均透過BVI方式互相控股，並間接持有康健國際股份，股權錯綜複雜。此外，原來由藝人榮升老闆的周星馳亦是巴拿馬律師行Mossack Fonseca& Co.的客戶。他在1997年成立「Fortunemaker Investments Corporation」的離岸公司，註冊地為紐埃（Niue）。他的胞姊周文姬，同樣有離岸公司「Winner Holdings Ltd.」，資料顯示其關連公司，「Loyal Port Limited」忠港有限公司，股東為朱詠珊，兩間公司在2009年不再聘請Mossack Fonsecaz。由細劉持有的3間離岸公司為「Goodasia Ocean Limited」、「Shine Top Limited」及「Sam Air Group Limited」；3間公司均是由大劉私人助理游敏儀作中介人。利福發言人接受查詢時表示，有關公司均與上市公司無關。近年活躍殼股買賣的曹貴子，其胞兄曹貴宜及曹貴子手下蕭錦秋，與「玩具大王」蔡志明女兒蔡加怡共擔任兩間離岸公司董事，包括一間「Joy Surplus International Limited」，註冊地點為英附屬維京群島（BVI），另一間「Wealth Treasure Group Limited」，同樣在BVI註冊。事實上，自蔡志明2005年入股康健國際後，已安排女兒蔡加怡出任主席，兩家關係變得非常密切。上述兩間公司的股份，均由一間「Charm Advance Limited」持有。當中「Charm Advance Limited」及BVI公司「Town Health（BVI） Limited」則共同持有BVI公司「Fair Jade Group Limited」，以上公司均透過BVI方式互相控股，並間接持有康健國際股份，股權錯綜複雜。此外，原來由藝人榮升老闆的周星馳亦是巴拿馬律師行Mossack Fonseca& Co.的客戶。他在1997年成立「Fortunemaker Investments Corporation」的離岸公司，註冊地為紐埃（Niue）。他的胞姊周文姬，同樣有離岸公司「Winner Holdings Ltd.」，資料顯示其關連公司，「Loyal Port Limited」忠港有限公司，股東為朱詠珊，兩間公司在2009年不再聘請Mossack Fonsecaz。
paradise papers
- https://www.icij.org/investigations/paradise-papers/explore-politicians-paradise-papers/
- usa
- uk
- mauritius
- 中國藝人趙薇的丈夫、富商黃有龍亦被「天堂文件」揭發跟「大馬賭王」林國泰有秘密關係。參與調查的《香港01》報道指，黃有龍早在2011年已跟林國泰合作投資蒙古業務，涉資8,000萬美元（6.24億港元），顯示二人合作關係比外界所知至少早了三年。報道指，「天堂文件」中有數份林國泰控制的雲頂香港公司從未曝光的董事局會議文件，當中披露雲頂香港在2011年6月及7月向黃有龍的蒙古採礦公司「Mizu LLC」借出約310萬美元（約2,418萬港元），由黃有龍作個人擔保。Mizu曾去信雲頂香港表示會盡快還款，但最終逾期未還，至當年年底本金、利息連逾期賠償共達1,000萬美元（約7,800萬港元）。文件未顯示款項有沒有還清。文件又揭林國泰家族控制的離岸公司Xendrill Limited，2011年8月向黃有龍借出2,000萬美元（約1.56億港元），並作價5,000萬美元（3.9億港元）收購黃有龍控股的蒙古公司「Etugen EY LLC」45%股份，成為該公司大股東。兩人關係要到他們在2014年注資上市公司藍鼎國際時才曝光。https://hk.news.appledaily.com/international/daily/article/20171107/20206536
- non profit making entity
- 由今年開始，一些離岸國家例如英屬處女島（BVI）及開曼群島（Cayman Islands）都立了新稅法，對相關離岸公司需要有經濟實質（Economic substance）要求。從稅務方面來看，假設一間離岸公司在香港是有營業場所，並持有香港商業登記證，即使是海外成立的公司也有香港稅務居民身份，需要繳交香港利得稅，若公司總部設於美國，全球的生意都需要向美國繳稅。https://orientaldaily.on.cc/cnt/finance/20190415/00275_001.html
- Offshore company register- https://www.icij.org/investigations/paradise-papers/explore-politicians-paradise-papers/
- Yukio Hatoyama was Japan’s prime minister from 2009 to 2010. He resigned after only nine months in power after a term mired in fundraising irregularities and his inability to follow through on a campaign pledge to relocate U.S. troops from Okinawa. In March 2013 Hatoyama was appointed honorary chairman and senior consultant of Hoifu Energy Group Ltd., an oil and gas exploration and production company incorporated in Bermuda in 2000. According to a company report, his role was to use his “amicable relationship” with the energy industry in the United States, Japan, China and Africa as the directors planned to expand Hoifu’s oil and gas business. The directors of the company, which is listed on the Hong Kong stock exchange, include Hui Chi Ming, one of China’s wealthiest oil tycoons with business interests in Madagascar, and international investor Neil Bush, the brother of former U.S. President George W. Bush.https://offshoreleaks.icij.org/stories/yukio-hatoyama
- Two years after the Panama Papers rocked the offshore financial system, a fresh document leak from the law firm Mossack Fonseca reveals new offshore details about an array of global elites, including soccer superstar Lionel Messi, the Argentine president’s family and a former senior Kuwaiti official convicted of looting his country’s social security system. The documents also show Mossack Fonseca scrambling to contain the falloutfrom the leak and identify its own clients. The 1.2 million documents date from a few months before April 2016, when the International Consortium of Investigative Journalists and more than 100 media partners published the initial Panama Papers stories, and continue through December 2017. The documents were leaked to Munich-based Süddeutsche Zeitung, which shared them with ICIJ.Emails between Mossack Fonseca’s head office in Panama and its Uruguay branch in September and October 2016 show employees discussing a plan to backdate documents to conceal the fact that the firm did not know that a company it had set up in the Bahamas, Fleg Trading Co., was controlled by the family of Argentine president Mauricio Macri.Macri and other family members were directors of Fleg Trading, the original Panama Papers investigation revealed. His father was the owner. Anti-money-laundering laws required Mossack Fonseca to know such information.In March 2017, Mossack Fonseca discovered that a company it had registered in the British Virgin Islands was owned by Mohamed Nizam bin Abdul Razak, the brother of Malaysia’s former prime minister, Najib Razak. The company, Everbright Universal Holdings Ltd., owned property in the United States, according to the files.The new files also reveal a company registered by Mossack Fonseca was owned by Fahad al-Rajaan, the former head of the agency that oversees Kuwait’s social security system. Al-Rajaan was convicted in absentia in 2016 of embezzling up to $390 million. He has denied the accusations and called them politically-motivated, according to reports. The files show he owned Tawny Real Estates Ltd., which in turn owned a Macau apartment and a Swiss bank account. Al-Rajaan was arrested in Britain in April 2017, but Mossack Fonseca was still the registered agent as of November 2017, despite learning of the allegations against him in March 2016. Also named in the new files: Vitaly Malkin, a Russian oligarch who resigned a seat in Russia’s senate in 2013 after reports that he had undeclared assets overseas. Malkin appears as the owner of two British Virgin Islands companies, Audrey Holdings Group Ltd. and Top Matrix Holdings Ltd. Audrey Holdings Group held Swiss bank accounts worth $200 million, according to Malkin’s source of wealth filecompiled by Mossack Fonseca. Malkin did not respond to a letter delivered to his Luxembourg address.In July 2017, Mossack Fonseca learned that Panama shell companies it had set up were controlled by heirs of iconic French jeweler Pierre Cartier. The companies owned a Canadian forest and Swiss bank accounts, according to the new documents. Members of the Cartier family did not respond to requests for comment. The heirs’ financial adviser declined to answer questions from ICIJ media partner Le Monde.Reporters also discovered that Dariga Nazarbayeva, the daughter of Kazakhstan president Nursultan Nazarbayev, was the sole shareholder of a British Virgin Islands company, information not previously reported. Dariga Nazarbayeva, a former deputy prime minister, is a senator who heads the Kazakh Senate’s Committee of International Relations. Her political rise is viewed by some Central Asian politics watchers as an indication she may one day replace her father. In October 2007, Nazarbayev became a shareholder of Asterry Holdings Ltd., which held a stake in sugar factories in Kazakhstan, via a chain of other companies, according to ICIJ media partner OCCRP. Nazarbayeva did not respond to requests for comment. Another company set up and managed by Mossack Fonseca was owned through a trust by Israel Perry, the new papers show. Perry, who died in 2015, was an Israeli attorney convicted of defrauding other Israelis, most of whom were Holocaust survivors. The firm only learned of Perry’s ownership of the company, called Mallett Ford Inc., through a lawsuit brought against it, according to the documents.https://www.icij.org/investigations/panama-papers/new-panama-papers-leak-includes-offshore-links-lionel-messi-cartier-argentine-leader/
- 被指為「親華派」的日本前首相鳩山友紀夫，周三受聘成為北京師範大學新興市場研究院的特聘教授，並發表演講。他表示，在「一帶一路」倡議下，中日兩國能夠合作的領域有很多，又強調和平比經濟發展更重要。http://orientaldaily.on.cc/cnt/china_world/20180317/00178_002.html
- usa
- https://www.ft.com/content/64403078-7346-11e8-aa31-31da4279a601 US secretary of commerce Wilbur Ross sold shares he owned in a New York-listed shipping company just days before the publication of an article that revealed the company’s ties to Vladimir Putin’s inner circle. Documents released by the US Office of Government Ethics on Monday show Mr Ross took a “short” position worth between $100,001 and $250,000 in Navigator Holdings on October 31. The move came just days before the November 5 publication of a New York Times article linking Mr Ross and Navigator to Gennady Timchenko, a Russian oligarch and judo partner of Mr Putin who is the subject of US sanctions.
- uk
- 英國牛津大學及劍橋大學兩家頂級學府，也被揭有千萬美元計的秘密離岸投資，當中包括石油勘探及深海鑽油項目。文件指，兩間大學均透過一家美國特拉華州基金公司，在開曼群島投資，涉嫌以此避稅。英國《衞報》報道指，以這種形式投資對沖基金，意味大學可以避開、甚至乎不用繳交美國稅項，大學更可獲派免稅股息。文件顯示，牛津大學在二○○六年向英國屬地根西島一家私募股權公司，投資了三百四十萬美元。這筆投資分為兩部分，一部分為大學本身的資金，另一部分由大學旗下的學院而來。至於劍橋大學，也在同樣的計劃中投資了一百七十萬美元。http://orientaldaily.on.cc/cnt/china_world/20171110/00180_005.html
- The head of Sweden’s largest business lobby resigned Wednesday after comments he made amid Paradise Papers revelations about his offshore holdings. Leif Östling, chairman of the Confederation of Swedish Enterprise and the former head of the truckmaker Scania, and his wife owned a Maltese company called Hertsoe Ltd. that held about $3.6 million worth of stock via subsidiaries in Luxembourg, ICIJ partner SVT (Swedish public television) reported two weeks ago.https://www.icij.org/investigations/paradise-papers/swedish-business-chairman-leif-ostling-resigns-amid-paradise-papers-link/
- Mauritian authorities have frozen 91 bank accounts linked to investor Jean-Claude Bastos, a key figure from the Paradise Papers with close connections to Angola’s former leaders. The Mauritius Supreme Court froze accounts in four judgements issued this month as part of probes involving Bastos and part of a $3 billion Angolan sovereign wealth fund investment, according to Mauritian newspaper L’Express. Mauritius’ offshore regulator also suspended the licenses of seven investment companies linked to Bastos’ Zurich-based management company, Quantum Global.https://www.icij.org/investigations/paradise-papers/angolan-tycoons-frozen-funds-highlight-kpmgs-role-in-offshore-secrecy/
- mauritius
- The companies behind the New Dawn Satellite channeled millions of dollars in payments from African companies and governments through offshore companies in Mauritius, one of the continent’s premier tax havens. In so doing, the companies achieved a Mauritian double-whammy, using one kind of offshore company to avoid local taxes and another to pay as little as possible on bills paid from overseas using treaties signed between Mauritius and its African neighbors. https://www.icij.org/investigations/paradise-papers/africas-satellite-avoided-millions-using-african-tax-scheme/
- https://www.icij.org/investigations/mauritius-leaks/five-companies-that-went-thousands-of-miles-to-use-mauritius/
- 根據最新的「天堂文件」指出，台灣的台塑集團始創人王永慶家族海外資產達二千五百六十億（新台幣‧下同，逾六百九十億港元），是在台灣資產的三點四倍。有台媒暗指，這凸顯台灣稅法的落後與不足。http://orientaldaily.on.cc/cnt/china_world/20180425/00178_009.html
- 中國藝人趙薇的丈夫、富商黃有龍亦被「天堂文件」揭發跟「大馬賭王」林國泰有秘密關係。參與調查的《香港01》報道指，黃有龍早在2011年已跟林國泰合作投資蒙古業務，涉資8,000萬美元（6.24億港元），顯示二人合作關係比外界所知至少早了三年。報道指，「天堂文件」中有數份林國泰控制的雲頂香港公司從未曝光的董事局會議文件，當中披露雲頂香港在2011年6月及7月向黃有龍的蒙古採礦公司「Mizu LLC」借出約310萬美元（約2,418萬港元），由黃有龍作個人擔保。Mizu曾去信雲頂香港表示會盡快還款，但最終逾期未還，至當年年底本金、利息連逾期賠償共達1,000萬美元（約7,800萬港元）。文件未顯示款項有沒有還清。文件又揭林國泰家族控制的離岸公司Xendrill Limited，2011年8月向黃有龍借出2,000萬美元（約1.56億港元），並作價5,000萬美元（3.9億港元）收購黃有龍控股的蒙古公司「Etugen EY LLC」45%股份，成為該公司大股東。兩人關係要到他們在2014年注資上市公司藍鼎國際時才曝光。https://hk.news.appledaily.com/international/daily/article/20171107/20206536
- non profit making entity
- at least since 2009, the museum’s endowment fund has quietly invested millions in the oil and gas industry through an undisclosed stake in a private equity fund, reveals a report by NBC News, which joined the International Consortium of Investigative Journalists in a new Paradise Papers investigation examining the offshore investments of nonprofit organizations. The museum invested $5 million in a fund run by Denham Capital, a private equity firm that invests in oil and gas, mining and power plants. That fund has pumped money into fracking for shale oil in Ohio and Pennsylvania and made an unsuccessful bid to invest in coal in Mongolia. The museum is one of several prominent environmental nonprofits and foundations, including the World Wildlife Fund, whose investments in fossil fuels were uncovered by NBC and other partners in a collaboration with ICIJ in a new look at the Paradise Papers, a leaked trove of 13.4 million documents, obtained by the German newspaper Süddeutsche Zeitung and shared with ICIJ. The files revealed how endowments, foundations and other nonprofits use offshore companies and undisclosed investments to obscure where their tax-exempt dollars are flowing. The investigation showed nonprofits repeatedly making investments that contradict their missions and lobbying in state legislatures to increase the secrecy surrounding their investments. NBC’s findings are part of a collaboration, dubbed Alma Mater, organized by ICIJ to examine the offshore investments of U.S. tax-exempt charitable organizations. Originally designed to investigate more than 100 universities whose endowments appeared in the Paradise Papers, the project expanded to include nonprofit museums, foundations and advocacy groups. It includes reporters in California, Montana, New York and Tennessee, working for outlets ranging from national television networks to city newspapers to an independent university publication. Among the most striking findings were the investments by environmental groups in the fossil fuel industry. Not only the American Museum of Natural History, but also World Wildlife Fund, which states publicly that “we must urgently reduce carbon pollution,” invested in the Denham Capital fund, NBC News found.
- 由今年開始，一些離岸國家例如英屬處女島（BVI）及開曼群島（Cayman Islands）都立了新稅法，對相關離岸公司需要有經濟實質（Economic substance）要求。從稅務方面來看，假設一間離岸公司在香港是有營業場所，並持有香港商業登記證，即使是海外成立的公司也有香港稅務居民身份，需要繳交香港利得稅，若公司總部設於美國，全球的生意都需要向美國繳稅。https://orientaldaily.on.cc/cnt/finance/20190415/00275_001.html
- http://www.theguardian.com/world/2016/apr/22/australia-to-follow-uk-in-creating-public-register-of-shell-companies
Oecd
- Base erosion and profit shifting (BEPS) refers to tax avoidance strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations. Under the inclusive framework, over 100 countries and jurisdictions are collaborating to implement the BEPS measures and tackle BEPS.http://www.oecd.org/tax/beps/
- Article on cepa investment agreement and beps singtao 28jan18 a12
measures to combat evasion
- economist 2mar19 "hitting the jackpot" some countries are using receipt lotteries to boost tax revenues
- fatca
- economist 5cot19 "fatca chance?" america's notorious tax compliance law faces another challenge
- blackstone
- https://www.icij.org/investigations/paradise-papers/blackstone-group-uses-fairly-aggressive-tactics-slash-tax-bill/ the private equity giant routed its ownership of two large U.K. commercial rental properties through a string of subsidiaries in two well-known tax havens: Luxembourg and the island of Jersey, a U.K. dependency off the coast of France.
- The southern part of the Las Vegas Valley was referred to as Paradise Valley as early as 1910, owing to a high water table that made the land particularly fertile for farming.[4][5] County commissioners established a Paradise school district in 1914.In 1950, mayor Ernie Cragin of Las Vegas sought to annex the Las Vegas Strip, which was unincorporated territory, in order to expand the city's tax base to fund his ambitious building agenda and pay down the city's rising debt.[7] A group of casino executives, led by Gus Greenbaum of the Flamingo, lobbied the county commissioners for town status, which would prevent the city from annexing the land without the commission's approval.[7] The commission voted to create the unincorporated town of Paradise on December 8, 1950.[8][9] The town encompassed a strip one mile wide and four miles long, from the southern city limits of Las Vegas to just south of the Flamingo.[9] The town board initially consisted of five casino managers, chaired by Greenbaum.A month after its establishment, the town was expanded to include the residential areas of Paradise Valley, giving it a total area of 54 square miles (140 km2).[10] Months later, however, it was reported that county officials had determined that the town had not been properly established, because the petition for the town's formation had an insufficient number of signatures and because it had violated a state law forbidding formation of a town spanning multiple school districts.[11] On August 20, 1951, county commissioners accepted petitions to create two new towns covering the area of the putative town.[12] Town "A" of Paradise included the areas that lay within a Las Vegas school district, extending from the city limits to a point one mile south, while Town "B" included the areas within the Paradise school district.In 1953, Town A was renamed as Winchester, and Town B became known simply as Paradise.In 1975, Nevada enacted a law that would have incorporated Paradise (along with Sunrise Manor and Winchester) into the City of Las Vegas.[14] Before it could take effect, however, the bill was struck down as unconstitutional by the Nevada Supreme Court.
jamaica
- economist 23feb19 "reclaiming the booty" hundreds of billions of dollars a year are lost to corporate tax avoidance. some countries are seeking help to deal with the problem
EU
- https://www.ft.com/content/4680a384-c2fb-11e7-a1d2-6786f39ef675 European officials have told 53 countries and territories that they risk being blacklisted as tax havens after the UK earlier delayed warnings to a dozen jurisdictions with ties to Britain. Brussels advised 41 countries 10 days ago that they would be blacklisted unless they promised to change their tax rules, according to people close to the talks. But British concerns caused the EU to hold back similar warnings for 12 more jurisdictions including Bermuda, the Isle of Man and Cayman Islands — what one official called the “usual suspects”. London changed its stance late last week, two days before the “Paradise Papers” leak put the issue of global tax legislation back in the spotlight. The European Council, made up of EU member states, started analysing non-EU countries last year to decide if they should be designated as tax havens, sending inquiry letters to 92 jurisdictions in February after initial screening. The council has set criteria for countries to avoid being labelled as tax havens. Its definition of fair tax rules says jurisdictions should not offer preferential tax measures or arrangements that enable companies to move profits to avoid tax. Countries should also meet transparency standards and implement anti profit-shifting guidelines set by the Organisation for Economic Co-operation and Development. Countries that fail to meet the council’s criteria can avoid being blacklisted if they provide a political commitment and a specific plan to comply. Representatives from all 28 EU member states will need to approve the final list, which is expected to be published on 5 December.
- 歐盟本周二將澳門、南韓、阿聯酋及巴拿馬等十七個非歐盟國家及地區，列入避稅天堂黑名單，另將四十七地列入監察「灰名單」，當中香港、台灣、瑞士、土耳其、百慕達及開曼群島等均上榜，歐盟稱將觀察有關國家及地區有否遵守承諾，改變稅務規定。文件顯示，香港和台灣承諾在二○一八年前，簽署協議推行自動交換訊息制度，以提高稅務透明度；歐盟又指香港和台灣現存的稅務制度有害，兩地承諾會在二○一八年前修正或廢除相關情況。歐盟官員表示，摩洛哥與維德角承諾進行稅改後，已移至灰名單。灰名單將定期更新。中國外交部發言人耿爽周三回應指，歐盟有關決定與澳門實際情況不符；至於香港特區的情況則需要作進一步了解。香港特區政府回應指，將會繼續與歐盟聯繫，有信心可符合國際稅務新標準。http://orientaldaily.on.cc/cnt/news/20171207/00176_033.html
- https://www.icij.org/investigations/paradise-papers/eu-removes-panama-seven-others-tax-haven-black-list/ The European Union has removed eight jurisdictions, including Panama, from its tax haven blacklist that was adopted last month. Only nine countries now remain on the list. The eight countries removed are Barbados, Grenada, Macao, Mongolia, Panama, South Korea, Tunisia and the United Arab Emirates.
- https://www.reuters.com/article/us-china-beltandroad-piraeus-exclusive/eu-suspects-tax-fraud-at-chinas-new-gateway-to-europe-idUSKBN1HR2LT European Union and Italian authorities are investigating suspected wide-scale tax fraud by Chinese criminal gangs importing goods via Greece’s largest port of Piraeus, a trade gateway between China and Europe, officials said.“The VAT is completely evaded, with enormous damage to the national tax authorities and to the community,” Fabio Botto, of the Italian Central Anti-fraud Office’s special investigative unit, said in an interview. He said the suspected scam at Piraeus, part of China’s vast Belt and Road infrastructure project, had cost Italy tens of millions of euros in unpaid value-added taxes (VAT), though the total could be far higher as the investigation was not over. The European Anti-Fraud Office (OLAF) confirmed it was working with Italy on the investigation but declined to give details, citing confidentiality.
- economist 6oct18 "one foot in the algarve" loopholes allow some pensioners in EU to retire tax free
- European Union finance ministers are set to add the British overseas territory of Bermuda and the Dutch Caribbean island of Aruba to the bloc’s blacklist of tax havens on Tuesday, according to EU documents and officials. The United Arab Emirates are also on the draft new list, but Italy and Estonia are opposing the listing of the emirates, a document seen by Reuters shows. The largest review of the list since its adoption in Dec. 2017 is expected to see the number of listed jurisdictions triple from the current five. The Caribbean island of Barbados and the Arab Sultanate of Oman are also on the expanded draft list, EU documents show. Other jurisdictions in the Caribbean and the Pacific Ocean are set to complete the updated list. https://www.reuters.com/article/us-eu-tax-blacklist/eu-to-add-bermuda-to-tax-haven-list-italy-blocks-uae-listing-idUSKBN1QS1AA
russia
- ft 30jul19 "taxman's digital dream" russian tech record and tax real-time transactions
UK
- https://www.ft.com/content/991ab660-c31a-11e7-a1d2-6786f39ef675 Britain’s failure to force offshore financial centres to introduce public registers of company ownership was heavily criticised by its opposition politicians in the wake of the “Paradise Papers” leak. David Cameron, the former British prime minister, promised to push for public registers in the British Overseas Territories, such as the Cayman Islands and Bermuda, in 2014, in an effort to “rip away the cloak of secrecy”. But the pledge was never enacted after reluctance from the offshore centres. On Monday, politicians from the Labour, Scottish National and Liberal Democrat parties all called for the government to press ahead again with the plan.
-https://www.ft.com/content/8cc0e314-4d47-11e8-97e4-13afc22d86d4 British overseas territories, including the Cayman Islands and Bermuda, will be forced to lift the veil of secrecy over the ownership of companies based there after the UK approved radical new measures to tackle money-laundering and corruption. The Caribbean territories have responded angrily to the measures, which will force them to make public the owners of all their registered companies by the end of 2020, in a significant victory for financial transparency campaigners. Robert Briant, acting chairman of BVI Finance, which represents the British Virgin Islands’ financial industry, said the UK had “shot itself in the foot”. The move would bring into question “the viability” of the BVI’s financial sector, he added. The measures were first proposed by David Cameron, the former prime minister, five years ago amid an international wave of political anger over tax avoidance by big companies and wealthy individuals. But the Conservative government only accepted the transparency measure after a group of its own MPs teamed up with the Labour opposition to amend the anti-money laundering bill being debated in parliament this week.
france
- 法國傳媒周五引述警方消息，財政部正調查紅酒出產地波爾多區內十間酒莊，懷疑涉及逃稅及偽造文件。報道指，涉事酒莊均屬於中國大連一間企業，而該企業在當地至少收購了二十四間酒莊。法國展開調查的原因，是中國於二○一四年的國家審計署報告披露，該企業涉挪用政府巨額補貼收購酒莊。http://orientaldaily.on.cc/cnt/china_world/20180630/00180_020.html
russia
- ft 30jul19 "taxman's digital dream" russian tech record and tax real-time transactions
UK
- https://www.ft.com/content/991ab660-c31a-11e7-a1d2-6786f39ef675 Britain’s failure to force offshore financial centres to introduce public registers of company ownership was heavily criticised by its opposition politicians in the wake of the “Paradise Papers” leak. David Cameron, the former British prime minister, promised to push for public registers in the British Overseas Territories, such as the Cayman Islands and Bermuda, in 2014, in an effort to “rip away the cloak of secrecy”. But the pledge was never enacted after reluctance from the offshore centres. On Monday, politicians from the Labour, Scottish National and Liberal Democrat parties all called for the government to press ahead again with the plan.
-https://www.ft.com/content/8cc0e314-4d47-11e8-97e4-13afc22d86d4 British overseas territories, including the Cayman Islands and Bermuda, will be forced to lift the veil of secrecy over the ownership of companies based there after the UK approved radical new measures to tackle money-laundering and corruption. The Caribbean territories have responded angrily to the measures, which will force them to make public the owners of all their registered companies by the end of 2020, in a significant victory for financial transparency campaigners. Robert Briant, acting chairman of BVI Finance, which represents the British Virgin Islands’ financial industry, said the UK had “shot itself in the foot”. The move would bring into question “the viability” of the BVI’s financial sector, he added. The measures were first proposed by David Cameron, the former prime minister, five years ago amid an international wave of political anger over tax avoidance by big companies and wealthy individuals. But the Conservative government only accepted the transparency measure after a group of its own MPs teamed up with the Labour opposition to amend the anti-money laundering bill being debated in parliament this week.
france
- 法國傳媒周五引述警方消息，財政部正調查紅酒出產地波爾多區內十間酒莊，懷疑涉及逃稅及偽造文件。報道指，涉事酒莊均屬於中國大連一間企業，而該企業在當地至少收購了二十四間酒莊。法國展開調查的原因，是中國於二○一四年的國家審計署報告披露，該企業涉挪用政府巨額補貼收購酒莊。http://orientaldaily.on.cc/cnt/china_world/20180630/00180_020.html
- economist "lactose intolerance" a gamble in france could cost UBS dear
germany
- A second former partner at Freshfields Bruckhaus Deringer LLP was charged in a German Cum-Ex probe over advisory work on the controversial trading strategy for bankrupt investment boutique Maple Bank. Frankfurt prosecutors confirmed they indicted another lawyer in the same case without disclosing any names. The man is ex-Freshfields partner Tobias T., two people familiar with the case said. Under German media law, the 46-year-old lawyer can’t be fully identified.https://www.bloomberg.com/news/articles/2020-06-24/second-ex-freshfields-partner-charged-in-german-cum-ex-probegermany
- In a round of questions before the Bundestag, German finance minister Olaf Scholz said he believed Freshfields Bruckhaus Deringer should no longer receive government mandates due to the firm’s involvement in the cum-ex tax scandal. https://www.law.com/international-edition/2020/09/10/cum-ex-scandal-freshfields-advisory-role-to-german-government-in-doubt/
sweden
- The head of Sweden’s largest business lobby resigned Wednesday after comments he made amid Paradise Papers revelations about his offshore holdings. Leif Östling, chairman of the Confederation of Swedish Enterprise and the former head of the truckmaker Scania, and his wife owned a Maltese company called Hertsoe Ltd. that held about $3.6 million worth of stock via subsidiaries in Luxembourg, ICIJ partner SVT (Swedish public television) reported two weeks ago.https://www.icij.org/investigations/paradise-papers/swedish-business-chairman-leif-ostling-resigns-amid-paradise-papers-link/
Switzerland
- https://www.ft.com/content/890a4262-c795-11e6-8f29-9445cac8966f Switzerland wants to update a tax deal with the US next year to allow the automatic, two-way exchange of information about bank accounts between the two countries, a senior official in Bern has said. The move shows the scale of the rethink on bank secrecy in Switzerland, once famous for helping tax evasion.
africa
- https://www.icij.org/blog/2018/07/behind-the-scenes-of-the-largest-ever-west-african-journalism-collaboration/ The offshore industry is a perfect example for tackling these sorts of issues, and its impact in our region is obvious. Among the series of #WestAfricaLeaks stories, we were able to reveal the political elites’ secretive bank accounts, including a longtime friend of Liberian ex-president Ellen Johnson-Sirleaf, a Malian presidential candidate and the mayor of the Ivory Coast’s richest city, as well as identify powerful international companies like the Canadian SNC-Lavalin, who used offshore companies to avoid taxes in Senegal.
tunisia
- ft 3jan17 report on tunisia pushes to remove from tax haven blacklist
mauritius
- https://www.icij.org/investigations/mauritius-leaks/treasure-island-leak-reveals-how-mauritius-siphons-tax-from-poor-nations-to-benefit-elites/ Mauritius Leaks, a new investigation by the International Consortium of Investigative Journalists and 54 journalists from 18 countries, provides an inside look at how the former French colony has transformed itself into a thriving financial center, at least partly at the expense of its African neighbors and other less-developed countries. In Uganda, more than 40% of the population lives on less than $2 a day. Based on a cache of 200,000 confidential records from the Mauritius office of the Bermuda-based offshore law firm Conyers Dill & Pearman, the investigation reveals how a sophisticated financial system based on the island is designed to divert tax revenue from poor nations back to the coffers of Western corporations and African oligarchs, with Mauritius getting a share. The files date from the early 1990s to 2017. The island, which sells itself as a “gateway” for corporations to the developing world, has two main selling points: bargain-basement tax rates and, crucially, a battery of “tax treaties” with 46 mostly poorer countries. Pushed by Western financial institutions in the 1990s, the treaties have proved a boon for Western corporations, their legal and financial advisers, and Mauritius itself — and a disaster for most of the countries that are its treaty partners. “What Mauritius is providing is not a gateway but a getaway car for unscrupulous corporations dodging their tax obligations,” said Alvin Mosioma, executive director of the nonprofit Tax Justice Network Africa. The leaked records – including emails, contracts, meeting notes and audio recordings – provide a glimpse inside a busy offshore law firm working with global accounting and advisory firms for some of the world’s largest corporations and some very wealthy individuals. They’ve all found their way to an island built on helping the rich avoid paying taxes to nations as far-flung as the United States, Thailand, and Oman.
- https://www.icij.org/investigations/mauritius-leaks/it-takes-a-village-to-create-a-tax-dodge/
India
- http://www.ft.com/cms/s/0/c78e52d4-1760-11e6-b8d5-4c1fcdbe169f.html india has closed a loophole that has long allowed domestic and foreign investors to escape taxes on short-term investments by routing them through the tiny island nation of Mauritius. New Delhi has amended a 33-year-old tax treaty with Mauritius that had exempted the island’s investors from capital gains tax on short-term investments in India. That exemption encouraged many foreign funds and companies to route investments into India through Mauritius, frustrating New Delhi as it sought to increase its tax revenues. The government said the changes would also prevent “round-tripping”, a phenomenon by which Indian individuals and companies avoid tax by sending funds abroad and then bringing them back on to home soil via Mauritius-based companies. Much of the investment into India via Mauritius over the last 15 years is believed to have been by Indian residents. India’s finance ministry said the amendment of the treaty would “help curb tax evasion and tax avoidance” and “double non-taxation”.
marshall islands
- [ablj sep-oct19 jonathan silver maple's group]recent amendments to business corporations act reqiure all marshall islands corporations, excluding publicly traded companies, to keep and maintain a record of their ultimate beneficial owners. A beneficial owner is defined as a natural person who exercises control over a company directly or indirectly, and will generally be deemed to hold more than 25% of the interests of the company.
australia
- https://www.ft.com/content/8864c808-4d65-11e8-97e4-13afc22d86d4 Bupa is under investigation by Australian tax authorities over the healthcare provider’s approach to structuring its debt, fuelling calls from campaigners for greater transparency around how companies that receive large government subsidies structure their businesses. The UK-based company disclosed that it was under investigation by the Australian Tax Office in filings submitted locally in 2016 and in 2017, according to a report released this week. One of the filings stated that the tax authority was scrutinising Bupa’s approach to “thin capitalisation” — the practice of using loans between different corporate entities within the same group to artificially reduce a company’s tax burden. The Australian arm of the Tax Justice Network, a group that lobbies against corporate tax avoidance, said in its report that Bupa and other large healthcare providers that receive significant subsidies from the Australian government had deployed “aggressive tax avoidance strategies”.
- [packers lunch] euro pacific banking group was an investment bank set up in the cook islands, apparently with the noble intention of ensuring nobody ever paid any tax ever again. Guy jalland, a former lawyer who worked for rene rivkin before joining euro pacific, wrote to his brother-in-law, james mackenzie, who ran euro pacific's trustee business in HK
- 澳洲北塔斯馬尼亞蜂農比倫波特，與妻子芬妮多年來一直以「違反上帝意願」為由拒絕交稅，稱信徒擁有的東西皆屬於上帝，稅務法應服膺《聖經》的司法管轄。法院周三裁定，該對夫婦須支付約二百三十二萬澳元（約一千二百七十八萬港元）的稅款，他們的部分財產被地方政府沒收。https://orientaldaily.on.cc/cnt/china_world/20190720/00180_024.html
nepal
- https://www.icij.org/blog/2019/03/nepaleaks-on-the-trail-of-money-flowing-from-nepal-to-tax-havens-then-back-to-nepal/
China
- http://www.scmp.com/news/china/policies-politics/article/1943616/china-airs-plan-help-close-multibillion-dollar China is mulling plans to tighten tax reporting requirements on multinationals operating in the country to help close a massive global loophole. If the plan goes ahead, multinationals would have to file extensive reports on internal pricing and costs between overseas branches and headquarters, sources said. The plan is China’s contribution to a global effort to stamp out the common practice of multinationals altering the price put on labour, services or intangible asset transfers within global operations to allow firms to divert profits to low-tax countries. The Organisation for Economic Cooperation and Development estimated that these kinds of profit-shifting practices amounted to about US$100 billion-US$240 billion in lost tax revenue each year, equivalent to up to 10 per cent of global corporate income tax revenue. A source at a law firm told the South China Morning Postthat the State Administration of Taxation issued a consultation draft on the proposal at the end of last year, specifying that multinationals would have to disclose affiliated businesses and how intangible assets, labour and other internal cost transfers were made. “[Internal transfer pricing] is a grey area to utilise loopholes in tax rules between different countries, but now the governments [of those countries] are acting to close the hole,” the source said.
- https://www.scmp.com/news/china/science/article/3043437/china-prepares-unleash-artificial-intelligence-catch-tax-cheats Chinese scientists have been working on a system to use
artificial intelligence that would make it almost impossible to cheat on taxes, according to researchers involved in the project. Over the last three years, about 300,000 government tax inspectors have been helping to train an AI system that draws on big data to detect behaviour that may be hard for human inspectors to spot.Now the machine can flag more than 95 per cent of offences, including some new ploys unfamiliar to most human tax collectors, researchers involved in the project said.However, given the number of companies that rely on informal deals with local tax authorities to lessen their burden, the system’s introduction may be delayed until the economic climate is more favourable.
- http://paper.takungpao.com/resfile/PDF/20160630/PDF/b2_screen.pdf 5月11日，第十屆稅收徵管論壇（FTA）大會在中國北京 順利召開。38個FTA成員經濟體、6個受邀非成員經濟體和7 個國際組織以及9家企業近200名中外代表的參與，共同為國 際稅收合作譜寫新的華章。這是一次落實全球稅改、彰顯國際 稅收合作的盛會。2016年是落實稅基侵 蝕和利潤轉移（BEPS）項目成果的開局 之年，也是全面實施G20稅改成果的重 要一年。在此背景下，此次FTA大會達 成多項共識、簽署多項合作，是國際稅 收合作發展的重要里程碑。也勾畫國際 合作路線圖。
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- 稅務局質疑牛奶公司集團透過旗下兩間公司之間的安排避稅，要該兩間公司就五個課稅年度，繳交三億四千萬元的利得稅，或一億八千萬元的商標利潤稅。牛奶公司已提出上訴，聆訊將於明年三月進行，不過，稅局堅持要牛奶公司買齊上述兩項稅種合共逾五億元儲稅券，以換取上訴期間暫緩繳稅，惟牛奶公司認為即使其公司敗訴，最多亦只須繳付三億四千萬元稅款，因此提出司法覆核。高院昨裁定稅局犯了法律錯誤，撤銷稅局的決定，發還稅局重新考慮退回多買一億八千萬元的儲稅券給牛奶公司。http://orientaldaily.on.cc/cnt/china_world/20181009/00180_022.html
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