Category: Germany

Exclusive: EU aims to rule on Amazon’s Luxembourg tax deal by July – sources

BRUSSELS – EU state aid regulators aim to rule on Amazon’s (AMZN.O) tax deal with Luxembourg by July, two people familiar with the matter said on Thursday, and it may order the country’s tax authorities to recover about 400 million euros ($448 million) in back taxes. The European Commission’s decision… – Continue reading

Post-Panama: Why your AEOI frameworks must now be automated, auditable and adaptable

Hot off the heels of the Panamanian documents leak, 5 EU countries announced last month that they have agreed to exchange beneficial ownership information. France, Germany, Italy, Spain and the UK will now automatically exchange information on the ultimate beneficial owners of companies and trusts. These 5 EU countries are… – Continue reading

Banks to help create a national register of offshore firm owners

Greek banks and the state are in the process of creating a national register for offshore company owners, in compliance with a European Union directive to that effect. The register will be created on the Teiresias databank, known from its list of insolvent borrowers. Access will be granted to the… – Continue reading

EU threatens sanctions on money laundering, tax evasion havens

BERLIN – A European Union official threatened Thursday to sanction Panama and other nations if they don’t cooperate fully to fight money laundering and tax evasion, after a leak of data showed the small country remains a key destination for people wanting to hide money. The 11.5 million documents from… – Continue reading

US, Like Panama, Is ‘Playground for the World’s Dirty Money’

Panama and the U.S. have at least one thing in common: Neither has agreed to new international standards to make it harder for tax evaders and money launderers to hide their money. Over the past several years, amid increased scrutiny by journalists, regulators and law enforcers, the global tax-haven landscape… – Continue reading

Panama Papers Expose Celebs, Politicians, Billionaires With Offshore Tax Havens Despite FATCA

The Panama Papers–the biggest leak of financial data in history–has blown the lid off offshore tax havens, again. This time, those in the limelight include twelve current or former world leaders, many celebrities, and wealthy persons who are using offshore tax havens to hide their wealth. In scope, this is… – Continue reading

Where next for Corporation Tax?

The amount of tax multinational companies pay – and the amount they don’t pay – has become highly controversial, writes RTÉ’s Economics Correspondent Sean Whelan. This is mainly as a result of public outrage over legal tax avoidance schemes that big companies can use to shelter vast amounts of money… – Continue reading

London court slams UBS offshore tax schemes

Offshore schemes operated by Swiss bank UBS and Germany’s Deutsche Bank in a bid to avoid paying income tax on bankers’ bonuses are not exempt from tax, the Supreme Court in London ruled Wednesday. British tax authorities, who brought the court action, said the schemes set up by the Swiss… – Continue reading

EU sharpens focus on tax of multinationals

EU countries will exchange information on the tax affairs of multinational companies under new rules backed by EU finance ministers aimed at stopping big companies avoiding paying their fair share into government coffers. The rules, that should take effect later this year, are a response to growing concerns about corporate… – Continue reading

Talking Tax in Shanghai

In Shanghai, Wolfgang Schäuble is urging his fellow G20 countries to put new rules to tackle tax avoidance into law. Back home, business leaders worry that German companies could be left exposed by the new rules if they are introduced unilaterally or go too far. The finance ministers of the… – Continue reading

Important changes and developments in German double tax treaties

1. New double tax treaty between Germany and the Netherlands: tax authorities now bear burden of proof regarding tax- evading or tax-avoiding arrangements A new Double Tax Treaty (DTT) has been in place between Germany and the Netherlands since 01 January 2016. Art. 23 of the DTT introduces an important… – 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

BIR’s five-year plan outlines tax administration improvements

THE BUREAU of Internal Revenue (BIR) has released the details of its strategic plan reaching well into the next government, by which it intends to effect improvements in tax administration. BIR Commissioner Kim S. Jacinto-Henares on Feb. 15 issued Revenue Memorandum Order No. 6-2016 detailing the bureau’s Strategic Plan 2016-2020…. – Continue reading

EU finance ministers wary of anti-tax avoidance proposal

EU finance ministers will attempt to reach agreement by March on a directive requiring EU-wide country-by-country reporting for large multinationals and by July on a directive requiring EU states to adopt six anti-tax avoidance measures for corporations, Jeroen Dijsselbloem Dutch finance minister and president of the Eurogroup announced at an… – Continue reading

Taiwan, Italy sign pact to avoid double taxation

Taipei, Feb. 15 (CNA) The Ministry of Foreign Affairs said Monday that Taiwan and Italy have completed an agreement to avoid double taxation and tax evasion. The Ministry of Foreign Affairs said Monday that Taiwan and Italy have completed an agreement to avoid double taxation and tax evasion. The ministry… – Continue reading

Varner: Taxes and international trade

A while back in Germany, I was driving on the straight as an arrow B-1. That is Bundesstrasse, the equivalent of a U.S. highway, a notch below the Autobahn. Roads tend to curve around farmers’ fields, having been there first. The B-1 from Cologne on the Rhine toward Berlin was… – Continue reading

Canada: Insight – In Search Of Better Tax Outcomes

Taxing decisions With highly efficient labour markets, a solid institutional environment and a strong banking system, Canada has long been considered one of the most competitive nations in the world. In fact, in its most recent rankings in 2014, Bloomberg declared Canada the second best country in the world for… – Continue reading

The Tax Avoidance Battle: Nations vs. Multinationals

At least this is the goal – member states safeguarding their social models by preventing trans-border operating multinational companies from avoiding “their fair share” of the tax burden. According to the European Commission, small and medium-sized enterprises in the EU pay 30% higher tax burden than large multinational companies. With… – Continue reading

10 biggest multinational offenders evading taxes in the UK

The brands are known worldwide, and even though global companies like Google, Amazon, and Starbucks make billions — they pay little or no taxes at all in the UK and other markets where the firms make a majority of revenue and profits. Companies like Microsoft, Twitter, and Apple don’t set… – Continue reading

EU Seeks Broader Crackdown On Corporate Tax Loopholes

BRUSSELS (Alliance News) – The EU stepped up the fight against corporate tax avoidance Thursday, unveiling proposals including an EU-wide blacklist of international tax havens, as part of a wider clampdown on firms using loopholes to reduce their tax bills. The EU’s executive estimates that member states are deprived of… – 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

Irish tax advantages may be banned under new EU rules

Ireland will be forced to ban many of the tax advantages it offers multinationals under proposals to be published by the European Commission tomorrow. This is the first step in an effort to have all EU countries introduce similar tax rules to prevent companies in the 28 member states avoiding… – Continue reading

Google Strikes Deal With U.K. Tax Authority

DAVOS, Switzerland—Google said Friday that it has struck a deal with U.K. authorities that will settle a tax dispute and boost its corporate taxes in Britain, part of a broader effort by European governments to wring more out of big firms in the tech sector. As part of the settlement,… – Continue reading

European Commission plans threaten change to Irish tax system

Ireland’s insistence that it is not a tax haven and that in fact other EU countries have tax regimes that facilitate tax dodging by multinationals will be borne out by a study to be released next week. But while this will be good news to Finance Minister Michael Noonan a… – Continue reading

Anger at plans to curb UK’s business-friendly tax regime

Plans to restrict the generous tax treatment of interest costs — a key aspect of Britain’s business-friendly taxation regime — are unnecessary and potentially damaging, companies have told the Treasury. Professional bodies and business groups are voicing fears about the restrictions that are set to be introduced as part of… – Continue reading

Property groups say Beps will cost UK sector £660m

UK property companies are seeking changes to the proposed implementation of a global agreement to fight tax avoidance that is set to add £660m to their annual tax bill. Private equity and infrastructure companies are also among those groups facing additional payments under OECD rules on base erosion and profit… – 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

A hidden network of hidden wealth

If taxed on the nearly $100 billion dollars they keep offshore, the largest U.S. financial institutions could cover the U.S.’s entire poverty-focused foreign assistance budget for 2014. Tax havens are a scourge. They allow individuals and institutions to cloak their financial activity in secrecy to escape and undermine other jurisdictions’… – Continue reading

Luxembourg Tax Alert 2016-02

January 2016 You will find below a summary of some of the most important tax developments that have happened since the release of our last newsletter, at OECD, EU or country level, in the area of tax transparency and the fight against tax avoidance. EU – Tax transparency and anti-BEPS… – Continue reading

New Australia/Germany Double Tax Treaty shows Australia’s policy response to BEPS

On 13 November 2015 the Treasurer and Minister of Finance jointly announced that a new double tax treaty had been negotiated with Germany, replacing the 1972 agreement. The new treaty has not yet been formally adopted as part of Australian law, as a change to the International Tax Agreements Act… – Continue reading

The Rules: Patent Box changes will create increased red tape for UK businesses

Changes to patent box rukes will mean that businesses must now track and trace all of their research and development (R&D) expenditure AFTER the recent government consultation on the UK’s Patent Box scheme, businesses will find it a challenge to comply with the proposed new rules. The changes will mean… – Continue reading

European Union: Implementing The Revised Parent Subsidiary Directive Across The EU

A striking example of the EU’s efforts to accelerate the implementation of anti-base erosion and profit shifting (BEPS) measures is the amended Parent Subsidiary Directive (PSD). Originally designed to prevent economic double taxation of profits distributed within an EU corporate, the PSD is now also being deployed to counter undesired… – Continue reading

Dispelling offshore myths

Although the British Virgin Islands is often seen as an offshore tax haven, a closer look shows such opinions may be overstated There is a stereotypical image of the so-called ‘tax haven’ for ‘shady people to put their money’. While it is true that BVI Finance enjoys warm, sunny weather… – Continue reading

How Microsoft moves profits offshore to cut tax bill

SEATTLE — When someone in Seattle buys a copy of Office at a Microsoft Store, that cash doesn’t take the short route to the company’s area headquarters. Instead, after accounting for state taxes, the profit goes to a Microsoft sales subsidiary in Nevada. From there, much of that money begins… – Continue reading

Philippines, Germany Update Tax Treaty

Germany and Philippines have completed the necessary domestic ratification procedures to bring their new double tax agreement into force. The two nations exchanged instruments of ratification on December 20 to replace their existing treaty, which was concluded in 1983. Negotiations on the upgraded treaty were concluded on July 20, 2012,… – Continue reading

Exclusive: Seven big investment banks in UK paid just $30 million tax in 2014

LONDON (Reuters) – Seven of the biggest investment banks operating in London paid little or no tax in Britain last year, despite reporting billions of dollars in profits, a Reuters analysis of corporate filings shows. In recent months, the seven investment and corporate banks operating in London reported figures showing… – Continue reading

BEHIND THE HEADLINES: Tax haven hypocrisy

A BALANCING ACT in London, folly and redemption in America’s District of Columbia and sheer hypocrisy in Brussels. And in every case, Barbados and many of its Caribbean neighbours were placed in the negative international spotlight at a time when some of the world’s major financial centres are casting about… – Continue reading

Arab League intent on increasing investments in Brazil

The organization’s new ambassador in the Brazilian capital Brasília claims trade and mutual investment between Arab countries and Brazil can be worked on. São Paulo – Newly appointed to represent the Middle East and North Africa countries in Brazil, the ambassador of the League of Arab States in the national… – Continue reading

Germany: New legislation on the automatic exchange of financial account information

The Bundesrat (upper house of the German parliament) approved the Law on the Automatic Exchange of Financial Account Information (Finanzkonten-Informationsaustauschgesetz) on 18 December 2015. Financial institutions face new reporting obligations and duties of care under this law. The new legislation requires financial institutions to provide the German Federal Central Tax… – Continue reading

Multinational moves could prompt major losses in corporate tax

Action on tax avoidance could see €600m go from the pharma sector, says report International moves on multinational tax could threaten Ireland, with a potential annual loss of corporate tax revenue of €600 million or more from the pharma sector alone, according to a new report from Chartered Accountants Ireland…. – 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

BEPS also applies to medium-sized businesses

Stricter Tax and documentation requirements for foreign transactions “Amazon, Facebook, Google and Starbucks pay little taxes …” or “Luxembourg attracts international corporations” – headlines like these have 62 states and the OECD called into action. The result was “base erosion and profit shifting” BEPS shortly. Even the German SME sector… – Continue reading

Senate approves tax treaties with Turkey, Italy & Germany

The Senate concurred, after hearing, the ratification of tax treaties between the Philippines and the governments of Italy, Germany and Turkey that will prevent double taxation. Sen. Juan Edgardo “Sonny” Angara said the approval on third and final reading of Senate resolutions 1540, 1541, 1542 on the double taxation avoidance… – Continue reading

How Microsoft moves profits offshore to cut its tax bill

Cash doesn’t flow directly from buyers’ pockets to Microsoft’s headquarters in Redmond, Wash. Instead, the company operates through three regional sales units, centered in Ireland, Singapore and Puerto Rico. These groups control the rights to profit from Microsoft products around the world. By conducting sales from places with small populations… – Continue reading