Category: Luxembourg

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

Election is the calm in the storm of maintaining a competitive corporate tax regime

When Tim Cook and his two senior Apple colleagues were questioned by a US Senate sub-committee back in May 2013, the headlines generated in the world’s business press were unsettling. Some lawmakers repeatedly characterised Ireland as a tax haven, saying behemoth Apple channelled billions of dollars of global revenues generated… – Continue reading

Special investigation: Why it’s not just planes that vanish in Bermuda

Journalist Steve Topple investigates Bermuda-based big business tax avoidance and its links with UK political parties – and even some charities LAST WEEK saw the news emerge that everyone’s favourite search engine, Google, only had to pay £97m in back-tax (not the “major success” of £130m as was first reported)… – Continue reading

EU Tax Proposal Expected To Target Multinational Corporations

Large multinational corporations such as Amazon.com, Apple, Google and Starbucks with operations in Europe have long been able to keep the tax rate they pay in one country secret, not only from neighboring nations but also from their competitors. Critics say this lack of transparency has allowed companies to unfairly… – Continue reading

Unions Blast Loopholes in New EU Tax Avoidance Proposals

A collective of unions has slammed the latest proposals by the European Commission to stamp out elaborate tax plans used by multinational companies to move vast profits around the EU in an effort to reduce their corporate tax bills in member states. The European Commission last week published a series… – Continue reading

French Tax Update – Recent Case Law and Other Noteworthy Publications

The present French Tax Update will focus on an overview of several noteworthy publications, including decisions issued during the past few months by the French Administrative Supreme Court (Conseil d’Etat) and French Constitutional Court (Conseil Constitutionnel), as well as the European Commission decision in respect of the Belgian Excess Profit… – 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

IRS 80- Swiss Banks 0

The formal IRS/Department of Justice (DOJ) Swiss Bank Program has concluded with 80 Swiss banks coming forward. The banks agreed to provide information about personnel, depositors and advisors who were participated in or assisted U.S. taxpayers in offshore tax evasion. In addition to disclosure and cooperation with investigations each of… – Continue reading

GLOBAL REGULATIONS HIT ALL JURISDICTIONS ALIKE: CAYMAN IS KEEPING ITS EDGE, BUT PRACTICAL IMPLEMENTATION A MAJOR CHALLENGE FOR MANAGERS

There is no doubt that Cayman Islands remain the favorite domicile for alternative investment funds globally. Cayman is a full service jurisdiction complying with all international standards, but it’s also business-friendly, with a lot of demand to have all relevant industry services located there: 184 banks, 149 trust companies, 108… – 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

Europe cracks down on tax dodgers

Directive follows a series of high-profile tax cases involving Google, Apple and others. Rampant corporate tax dodging and sweetheart deals that cheat governments and skew markets, have prompted the European Commission to unveil a new directive Thursday. The proposed legislation follows a quick succession of tax rulings, settlements and investigations… – 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

EU to clamp down on corporate tax avoidance schemes

Multinational companies are facing severe constraints on their ability to avoid taxes on their activities in Europe as regulators seek to close loopholes laid bare by the LuxLeaks scandal Pierre Moscovici, the EU’s tax policy chief, will set out plans next week to curb practices such as using debt interest… – Continue reading

The hidden wealth of nations

India’s biggest source of FDI is India itself, money departing on a short holiday to a tax haven and then routed back as FDI. Will the government muster up the political will to clamp down on the tax-allergic business elite? This could be a bumper year for the ever-lucrative tax… – Continue reading

Intl bodies to fight global tax evasion / Maximum of $240 bil. said to be dodged

The Yomiuri Shimbun Four international organizations will join forces to devise unified global tax rules aimed at preventing tax evasion by multinational companies. The four entities involved are the Organization for Economic Cooperation and Development, the United Nations, the International Monetary Fund and the World Bank. The OECD — whose… – Continue reading

Budget 2016 may introduce BEPS to make tax evasion difficult for MNCs

MUMBAI: In what could lead to an increase in domestic tax liabilities of many Indian conglomerates and multinationals, the government is set to introduce a framework for Base Erosion and Profit Shifting (BEPS), a global agreement to check tax avoidance by multinationals, in the upcoming Budget. Industry sources expect the… – Continue reading

European Parliament votes in favour of an EU fair tax label

The European Parliament has voted in favour of a “Fair Tax Payer” label across the EU to tackle tax avoidance. The proposal was passed on 16 December by 500 votes to 122, and drew cross-party support from members of the green, socialist, liberal, labour and conservative blocks. The plan came… – Continue reading

On tax avoidance

The only thing worse than paying taxes is the idea that other people avoid paying their fair share of them. On the subject of tax avoidance by other people, I can think of at least three principal feelings. As the kids say, I feel all the feelings. Outright tax fraud… – Continue reading

Expat eyes drift offshore

Offshore Financial Centres (OFCs) are jurisdictions, usually self-governing, which because of their low tax regimes, have specialized in providing commercial services to corporations and individuals, whether or not they are normally resident in that jurisdiction. The better-known offshore financial centres are small and sparsely populated countries or islands, and are… – Continue reading

Dutch say will lead EU fight against multinationals’ tax avoidance

The Netherlands will be at the forefront of efforts to combat multinationals’ tax avoidance, its finance minister has said. The comments come amid a dispute with the European Commission over his country’s tax treatment of Starbucks. The Commission, the EU’s executive arm, will propose a new set of binding rules… – Continue reading

EU cracks down on corporate tax avoidance in Belgium

The European Commission has ordered Belgium to recover €700 million from 35 large companies in back taxes in the EU executive’s biggest move yet to crack down on tax avoidance by multinationals. The Commission said Belgium’s “excess profit” tax system, whereby multinationals’ economies of scale can enable them to reduce… – Continue reading

Law Case Launched Against European Commission Over Tax Probe Cover-Up

Documentary Evidence European Union lawmakers sitting on the TAXE committee investigating corporate tax evasion in Europe say they have become frustrated at changes to their mandate and the unwillingness of the European Commission to hand over documents for their investigation. The matter is all the more personal as Commission President… – Continue reading

McDonald’s subject to EC competition complaint

McDonald’s faces another European regulatory headache after it was the subject of a competition complaint in Brussels. Three Italian consumer groups backed by a coalition of trade unions from across the continent, including the UK’s Bakers Food and Allied Workers Union, allege that the fast-food giant abuses its dominant market… – Continue reading

Ireland – the tax haven

‘We’re not a tax haven, we have never been involved in any kind of tax malpractice’ – Michael Noonan, Irish Minister for Finance 5th October 2015 ‘Nobody is using Ireland as a tax haven’ – Minister for Agriculture, Simon Conveney, The UN’s Philip Aston says, ‘When lists of tax havens… – Continue reading

Luxembourg – Croatian DTA to enter into force on January 13, 2016

On January 11, 2016 the Luxembourg tax authorities issued a newsletter announcing that on January 13, 2016 the Agreement between the Grand Duchy of Luxembourg and the Republic of Croatia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on… – Continue reading

Luxembourg’s Finances Stable, Says Fitch Ratings

The Organisation for Economic Co-operation and Development’s base erosion and profit shifting process will not have significant implications on Luxembourg-based companies, Fitch Ratings has said. The agency on January 8 re-affirmed Luxembourg’s AAA rating, with a stable outlook. According to Luxembourg for Finance, the territory’s financial services promotional agency, the… – Continue reading

Italian groups seek EU antitrust probe into McDonald’s

BRUSSELS – Three Italian consumer organizations have urged EU antitrust regulators to investigate McDonald’s (MCD.N) franchise system in Europe, a month after the opening of an EU inquiry into the U.S. fast food company’s tax deals with Luxembourg. Codacons, Movimento Difesa del Cittadino and Cittadinanzattiva filed their complaint with the… – Continue reading

Ireland: the Tax Haven that Dare Not Speak Its Name

‘We’re not a tax haven, we have never been involved in any kind of tax malpractice’ – Michael Noonan, Irish Minister for Finance 5th October 2015 If your top political figures need to constantly state that your country is not a tax haven, then the chances are it probably is… – Continue reading

Belgium’s $763 million tax loophole shut in EU payback order

AB InBev says it’s `disappointed’ and is assessing its options Vestager lashes out at `double non-taxation’ schemes BRUSSELS – The European Union ordered Belgium to recover about 700 million euros ($763 million) in illegal tax breaks given to at least 35 companies, including Anheuser-Busch InBev and BP, as regulators continued… – Continue reading

Thirty-eight percent of Australia’s large companies paid no tax in 2013-14

An Australian Taxation Office (ATO) report issued last month on “corporate tax transparency” showed that 1,539 of the country’s biggest firms had a combined turnover of $1.6 trillion but paid a total of only $39.9 billion in company tax—about 2.5 percent of the collective turnover. Five hundred and seventy-nine of… – Continue reading

Belgium’s $762 Million Tax Loophole Shut in EU Payback Order

The European Union ordered Belgium to recover about 700 million euros ($762 million) in illegal tax breaks given to at least 35 companies, including Anheuser-Busch InBev NVand BP Plc, as regulators continued a crackdown on overly generous tax schemes throughout the 28-nation bloc. The European Commission told Belgium to recoup… – 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

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

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

Bermuda On “Best Tax Havens In World” List

Bermuda has “long been a popular tax haven” according to a story by gobankingrates.com, which ranked the island as one of the “top 10 best tax havens in the world.” The story said “Bermuda has long been a popular tax haven, said Ravi Ramnarain, an independent certified public accountant. “Wealthy… – Continue reading

Luxembourg: Year-end provisions enacted, affecting corporate and individual taxpayers

The Luxembourg Parliament in December 2015 approved tax measures affecting both corporate and individual taxpayers. These provisions generally are effective beginning 2016, with a few measures applying retroactively as from 2015. Among the measures in the tax legislation are the following provisions: Transposition of amendments to the EU Parent-Subsidiary Directive… – Continue reading

New Luxembourg-Singapore agreement for the avoidance of double taxation which will stimulate trade and investment flows between both jurisdictions enters into force

On 28 December 2015, the revised Luxembourg-Singapore Agreement for the Avoidance of Double Taxation (the New Treaty) entered into force. The New Treaty (1) allows Luxembourg investment vehicles to invoke benefits under the New Treaty, (2) reduces the withholding tax rates for dividends, interest and royalties, (3) increases thresholds to… – Continue reading

Common Reporting Standard – Lining up for take-off

On Tuesday 15 December, Deloitte Luxembourg gathered around 150 business professionals from various sectors at Utopolis to this year’s last episode of the conference cycle covering the full spectrum of the Common Reporting Standards (CRS). While cinema technicians were preparing the premiere of the new Star Wars movie next door,… – 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

Antoine Deltour — The LuxLeaks Whistleblower

Luxembourg’s long-hidden role as a secret tax haven in the very heart of the European Union has been shattered by one man who happened to be in the right place at the right time to do what he thought was the right thing. Antoine Deltour brought to light how the… – 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

Report :Julius Baer Seeks Deal With US To Settle American Offshore Accounts Case

Swiss private banking group Julius Baer Group Ltd. (JBAXY.PK,JBARF.PK) may have to pay more than it anticipated to settle a case with the U.S. Justice Department over American offshore accounts, according to media report quoting people familiar with the matter. The report indicated that the U.S. prosecutors could ask Julius… – Continue reading

Netflix is latest multi-million-pound global company that does not pay UK corporation tax despite generating £200m of revenue in Britain

Netflix the online movie rental service did not pay any UK corporation tax last year, despite generating an income of £200million in Britain. The world’s biggest internet movie streaming service has five million subscribers in the UK alone and has proved a hit by offering U.S. shows like House of… – Continue reading

Battle of words over taxation

On December 8, there was a brief note in the media about the fact that Malta had managed to include a reference to flexibility into a European Council communiqué on taxation. You would be forgiven for overlooking it, assuming it was just a pedantic attempt to score political points. Think… – Continue reading

Luxembourg – Main New 2016 Tax Measures At A Glance

IP regime  To comply with the OECD’s BEPS reports and more specifically its action plan n° 5 regarding harmful tax practices, the Luxembourg intellectual property (“IP“) regime under article 50bis of the Luxembourg income tax law (“ITL“) will be repealed as from 1 July 2016. As such, the Luxembourg 80%… – Continue reading