Category: Denmark

Denmark must adopt EU controlled foreign company tax rules, Commission says

The EU Commission on July 25 decided to send a reasoned opinion to Denmark for its failure to communicate to Commission rules implementing controlled foreign company (CFC) rules required by the EU anti-tax avoidance directive (Council Directive (EU) 2016/1164 or ATAD). ... - Continue reading

Taxpayers given six months to challenge Denmark transfer pricing assessments based on insufficient documentation

A Danish tax administration decree, published 12 July in response to the Supreme Court’s decision in the Microsoft case, establishes a new practice for determining whether transfer pricing documentation must be available at the time the taxpayer is required to file its tax return. ... - Continue reading

Is this the end of the road for the EU’s digital services tax?

Ireland, Sweden, Denmark and Germany block digital services tax plan in Brussels. The spectre of a 3pc digital services tax (DST) levied by the EU against multinationals has been vanquished for now after Ireland, Sweden, Denmark and Germany joined forces in what is being heralded as a coup for diplomacy…. – Continue reading

PenSam to step up scrutiny of partners as €55bn tax scandal unfolds

The head of one of Denmark’s biggest pension funds has spoken out to condemn a wide-scale tax fraud uncovered by a media investigation. Danish national broadcaster DR, newspaper Politiken and other European media outlets in the last three months have published articles detailing a withholding tax scam – dubbed ‘Cum-Ex’… – Continue reading

France Boasts Second-Highest Taxes In the World

A new study shows that France taxes its population the second-most among developed countries. Which country claimed the first place spot? Denmark. As research from the OECD economic think tank attests, the combination of France’s income and property taxes, social security payments, and goods and services makes up 45.3% of… – Continue reading

New Japan-Denmark DTA To Waive Cross-Border Tax

The Japanese and Danish governments announced on October 11 that they had signed a new agreement for the avoidance of double taxation in Tokyo. The Japanese Ministry of Finance said: “This Convention wholly amends the existing Convention, which entered into force in 1968, by revising the taxation on business profits,… – Continue reading

Danish bank accused of Russia money laundering

Denmark’s top lender, Danske Bank, played an “organised” role in a Russian money-laundering scam, French prosecutors have said. The Tribunal de Grande Instance de Paris said the bank’s branch in Estonia helped to move €15 million of “money from organised fraud and tax evasion” in Russia into France and other… – Continue reading

Government sets tough course on international tax evasion

New centre established to focus efforts on gaining better foothold in tax havens A unanimous Parliament yesterday agreed to significantly step up Denmark’s efforts to combat international tax evasion. Among the new initiatives are the establishment of a new centre that will consolidate efforts against tax evasion, more transparency regarding… – Continue reading

Azerbaijan, Denmark ink convention on avoidance of double taxation

Azerbaijan and Denmark have signed the convention on avoidance of double taxation and prevention of tax evasion on income taxes. The document was signed by Azerbaijani Minister of Taxes Fazil Mammadov and his Danish counterpart Karsten Lauritzen. Mr. Mammadov said that the document will contribute to the development of trade… – Continue reading

Swedish Bank Merger Rules Aim to Limit Risk of Tax Imbalance

A plan by Nordea Bank AB to merge with subsidiaries in Denmark, Finland and Norway has prompted Sweden to revise its laws to minimize the risk of a tax imbalance when a foreign company’s shares and other financial instruments are merged with those of domestic company. Effective Jan. 1, the… – Continue reading

Ireland braced for new EU corporate tax plan

A new EU corporate tax proposal could fundamentally change how multinationals pay their tax bills in Ireland. It comes at a sensitive time for the State, following so closely after the commission ruled phone giant Apple tapped illegal tax breaks worth around €13bn. In proposals to be unveiled tomorrow, the… – Continue reading

Panama Papers: Denmark buys leaked data to use in tax evasion inquiries

Denmark pays up to £1m for documents from anonymous source and plans to investigate up to 600 Danes who may have evaded tax Denmark has become the first country in the world to apparently buy data from the Panama Papers leak, and now plans to investigate whether 500-600 Danes who… – Continue reading

UAE, Finland sign agreement on exchange of information for tax purposes

ABU DHABI: The United Arab Emirates and the Republic of Finland have signed an agreement on the exchange of information for tax purposes between the two countries. The agreement was signed by Younis Haji Al Khoori, Undersecretary of the Ministry of Finance, MoF, and Riitta Swan, Ambassador of Finland to… – Continue reading

Zambia signing its way out of tax revenues-ActionAid Zambia

A new report from ActionAid titled ‘Mistreated’ released this week has revealed that Zambia has 13 restrictive tax treaties that dramatically restrict the government’s power to tax global companies doing business on our soil and therefore unfairly limit our country’s potential to collect tax revenue. The report also found that… – Continue reading

Tanzania: Managing Tax Risks – Double Tax Treaties and Implications

Can tax treaty provisions override domestic law?In our last article we defined double taxation as an exposure to tax more than once on the same profit or income. We also highlighted the two types of double taxation i.e. economic double taxation and juridical double taxation and also noted that a… – Continue reading

31 nations sign agreement on exchange of country-by-country transfer pricing reports

In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting out the parameters for automatic exchange of country-by-country reports on large multinational corporations. The agreement — the Multilateral Competent Authority Agreement on… – Continue reading

S. Korea, Macau to sign tax information exchange agreement

Macau’s Financial Services Bureau (DSF) has confirmed to Business Daily that the local authority is to sign a Tax Information Exchange Agreement (TIEA) with South Korea, which would add to the existing 15 jurisdictions that have already signed this agreement with the territory. According to the Bureau, its South Korean… – Continue reading

Tanzania: Managing Tax Risks – Double Tax Treaties and Implications to Undertakings of Multinationals

The term double taxation refers to an exposure to tax more than once on the same profit or income. There are two types of double taxation i.e. economic double taxation and juridical double taxation. Economic double taxation is broad and occurs in a situation where an amount of income is… – Continue reading

2016 CHALLENGES FOR COMPANIES OPERATING IN JERSEY

Last year Jersey cemented its position as a leading centre for companies looking to list – as reflected in the rise in volume and value of Jersey companies listed on exchanges around the world. Here are some challenges that lie ahead in this jurisdiction over the next 12 months. In… – Continue reading

India: Swiss Apex Court Denies Treaty Benefits For Dividend On Securities Acquired For Hedging Derivative Contracts

Federal Supreme Court of Switzerland denies treaty benefits in case of dividend paid on shares acquired for hedging derivative contracts. Court stated that due to the fully hedged nature of ownership, there was economic nexus and interdependency between two independent transactions and therefore, the “intermediary” bank did not have beneficial… – Continue reading

Transfer pricing rules with wider ambit soon

Changes in I-T Act likely to curb tax evasion by multinational companies The government might change transfer pricing provisions in Budget 2016-17 to ensure companies with overseas presence and consolidated revenue of more than Rs 5,000 crore comply with extensive data reporting and documentation. Legislative changes in the Income Tax… – Continue reading

Brazil: Tax Treaty Series: The Bilateral Income Tax Treaty Between Brazil And Canada

This is the first of our series of posts on Brazilian tax treaties. In each post we will provide an overview of a specific tax treaty between Brazil and a particular foreign country, as well as comments on any Brazilian administrative or judicial precedents applying the treaty, and highlights on… – Continue reading

Column: MNEs must start test runs fast

Group companies, irrespective of the jurisdiction, will have to conform to common standards The Organization for Economic Cooperation and Development (OECD) recently released 15 action-plans to address the issue of “Base Erosion & Profit Shifting” or BEPS, which has led to misalignment between where taxes are paid and where value… – Continue reading

IP BOX: Italian and European Legal Framework

On 22 December 2014, the Italian Parliament approved the Budget for 2015.40 Among other measures, the Law introduces the possibility of an exemption from corporate income tax (IRES, generally levied at 27,5%) and local tax (IRAP, generally levied at 3,9%) on income derived from qualifying intangible assets (such as patents,… – Continue reading

France: French Tax Update – Amending Finance Bill For 2015 And Noteworthy Q4 Case Law

The present French Tax Update contains (i) an overview of the main provisions proposed by the draft amending finance bill for 2015 (loi de finances rectificative pour 2015, 2015 Draft Amending Finance Bill), (ii) an update of the parliamentary amendments adopted in respect of the draft finance bill for 2016… – Continue reading

Kenya and South Africa tax deal takes effect in January

The Kenya-South Africa double taxation agreement comes into force from January 1. An announcement in the November 19, South African government gazette says the agreement applies for taxes withheld at source. “A resident of Kenya will not be taxed on any South African business profits, unless it carries on business… – Continue reading

Denmark introduces a legislative proposal in order to implement BEPS Action Point 13

On 10 November 2015, the Danish Ministry of Taxation introduced a draft bill (bill no. L46) including an amendment to section 3B of the Danish Tax Control Act (skattekontrolloven). The purpose of the proposed amendment is to implement Action Point 13 of the BEPS Initiative (Guidance on Transfer Pricing Documentation… – Continue reading

India: Scope Of Exchange Of Information Widened Under India-Denmark DTAA

A Protocol to Double Taxation Avoidance Agreement between India and Denmark that has entered into force on February 1, 2015, has been notified by Notification No. 45/2015/F No. 503/02/1998-FDI-I, to expand the scope of Exchange of Information (EOI) clause under Article 26 by substituting the same with a new Article… – Continue reading

Spain among Europe’s worst offenders for tax evasion and money laundering

SPAIN is among Europe’s worst offenders for helping firms launder money and avoid paying tax. According to European Network report, 50 Shades of Tax Dodging, Spain is the fourth worst offender behind Luxembourg, Germany and Italy. The report accuses Spain of conducting the most aggressive tax treaty negotiations with developing… – Continue reading

Eurodad Identifies Surprising Haven Nations for Tax Evasion and Money Laundering

The European Network on Debt and Development (also known as “Eurodad”), a network of NGOs, has issued a recent report identifying European nations that have served as havens for tax evasion and money laundering. According to the report, Germany, Luxembourg, and Spain are among the most egregious offenders. By turning… – Continue reading

UK takes two-faced approach to tax, new report suggests

The UK government has a ‘Janus-faced’ approach to tax, a new report suggests: promising an increasingly intolerant approach to evasion and avoidance while being an aggressive participant in global tax competition and tolerating the UK tax havens which facilitate financial crime across the world. The report, Fifty Shades of Tax… – Continue reading

Two unexpected countries could be havens for money laundering and tax dodging

Eurodad’s country comparison table, showing how each of the studied countries fared in the evaluation of four tax-related categories. Germany, Luxembourg, and Spain are egregious offenders in “supporting an unjust global tax system,” according to a new report from the European Network on Debt and Development (Eurodad), a network of… – Continue reading

Kenya: ‘Kenya Losing Billions to Tax Havens’

The government has been accused of opening a loophole that allows super rich individuals and multinational companies to avoid taxes. The Tax Justice Network (TJN), a lobby group, has sued the government over agreements, which it says are robbing Kenya of the ability to raise revenues domestically, driving the country… – Continue reading

Corporate tax dodging still rampant in EU

A number of member states are failing to tackle corporate tax avoidance despite media revelations and EU and national-level moves to close loopholes. “It’s clear that in the EU it is business as usual for multinational corporations who want to dodge the rules to lower their tax bills”, said Tove… – Continue reading

NGOs slam EU’s ‘two-faced’ approach to tax

Tax systems within the European Union remain largely secretive and opaque despite leaders’ claims that measures are underway to fix loopholes, the European Network on Debt and Development (Eurodad) has said. The coalition of 46 NGOs from 20 European countries including Oxfam, Save the Children and ActionAid said that, while… – Continue reading

Australia out of step with global corporate tax rate trends

Australia’s corporate tax rate is higher than the global average, according to KPMG’s 2015 global tax rate survey, SmartCompany reports. While Australia’s corporate tax rate currently sits at 30 per cent, the global average sits at 23.68 per cent. The United States has the highest corporate tax rate at 40… – Continue reading

The Latest South African Tax Proposals are Far-reaching

There was a time when, from a tax perspective, South Africa’s “mini budget” used to be a non-event. The main emphasis was on the annual budget speech delivered in February each year when they announced tax policy proposals. However, over the past few years there has been an increasing tax… – Continue reading

Just how dirty is offshore money?

David Cameron threw the proverbial cat among the pigeons in July when, with a steely glare at the UK property industry, he warned that the UK must not become “a safe haven for corrupt money from around the world” and that “there is no place for dirty money in Britain”…. – Continue reading

BEPS: CURRENT STATUS OF IMPLEMENTATION IN VARIOUS COUNTRIES

Last week’s OECD release of the final package of measures for a coordinated international approach to the reform of the international tax system, under the OECD/G20 base erosion and profit shifting (BEPS) project, marks the end of the discussion and recommendation phase, and the start of the implementation and practical… – Continue reading

NBR to sign deal with Bhutan to avoid double taxation

Bangladesh is set to sign an agreement with Bhutan to avoid double taxation to boost investments, trade and facilitate information exchange between the two Saarc nations, the National Board of Revenue said in a statement. A team led by NBR Chairman Md Nojibur Rahman is now in Thimpu to take… – Continue reading

NORWAY: BUDGET 2016; MORE ABOUT PROPOSED TAX REFORM

The Norwegian conservative government on 7 October 2015 published both the proposed state budget for 2016 and a “white paper” containing proposals for tax reform. The proposed tax reform in the white paper is a follow-up action from a report on tax reform, presented by the Tax Commission in late… – Continue reading

Gaming the System: Underlying Problems of the U.S. Tax Code Must be Addressed

Last year at this time, news about “tax inversions” was grabbing headlines – cases where large U.S. multinationals would buy a foreign company in a tax-friendly jurisdiction, and then relocate its headquarters to reap the tax arbitrage benefits. The Obama administration responded to the rash of high-profile inversions with new… – Continue reading

Internal Revenue Service Begins Reciprocal Automatic Exchange of Tax Information Under FATCA IGAs

On October 2, 2015, the Internal Revenue Service announced that it had achieved a key milestone in implementation of the Foreign Account Tax Compliance Act (FATCA), a critical anti-tax evasion law passed by Congress in 2010 but not fully implemented until July 2014. The milestone announced by the IRS was… – Continue reading

It’s Here; The Automatic Exchange of Information Under FATCA Began September 30th

The IRS has announced that as of September 30, 2015 it will implement the automatic exchange of tax information as set forth in the Foreign Account Tax Compliance Act, (FATCA). The IRS Commissioner in announcing the implementation of the automatic exchange of information stated: “This information exchange is part of… – Continue reading