Category: Luxembourg

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, 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

Worldwide: Global FATCA: Let’s Do It Again

Fifty-three jurisdictions have agreed to automatic exchange of tax information beginning in 2017, under the OECD’s Common Reporting Standard. Over 40 others have committed to exchange information by 2018. Another wave of global tax information is about to take place, and financial institutions everywhere are in a race to prepare… – Continue reading

Luxembourg: CRS implementing legislation moves forward

The Luxembourg Parliament unanimously passed legislation that would transpose into domestic law an EU directive concerning the automatic exchange of information in the field of taxation (a directive known as “DAC 2”). The DAC 2 provides that EU Member States are to require financial institutions to implement reporting and due… – Continue reading

EC Extends Investigation Into Apple Tax Deal

The European Commission has extended its investigation into a tax ruling provided by the Irish Government to Apple. The Commission has asked the Irish authorities for additional information on the case. Irish media reports that the Government does not anticipate a decision until 2016. In late November, Finance Minister Michael… – 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

EP votes in favour of stopping corporate tax avoidance; Malta could lose competitive edge

A vote taken in the European Parliament could effectively rob Malta of its ability to attract multinational companies and their millions of Euros in taxation revenue. A vast majority of MEPs, spanning across all political groups showed their support for a resolution, prepared in Parliament’s Economic and Monetary Affairs Committee…. – Continue reading


Journal: The EU’s ongoing investigation into Luxembourg’s tax agreements with multinational corporations is threatening to leave a black mark on the Grand Duchy at the end of its six-month European presidency. Luxembourg’s finance ministry could face legal action from the European Commission, as the EU authority continues its probe into… – 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

Ireland regains its swagger in the tax arena

Something unusual is happening with the Irish corporation tax in 2015 — so unusual that Ireland’s top tax man felt obliged to write to the parliament to explain what is going on. But the explanation left a lot to be desired. According to government data, Ireland received 57.7 percent more… – Continue reading

EU probe of Apple’s Irish tax deal extended to 2016

A European Union investigation into whether Apple’s bespoke tax arrangement with the Irish government amounts to illegal state aid has been delayed again, as officials in Brussels continue to gather more information. “We do not expect any decision until after the new year,” a spokesperson for the European Commission told… – Continue reading

Company which owns Queen’s jeweller Mappin & Webb ‘has paid no corporation tax for five years despite £66million profits’

The company that owns the Queen‘s jeweller Mappin & Webb has paid no corporation tax for five years – despite profits of £66million. The allegations made against Mappin & Webb owners Aurum Holdings came as the conduct of firms holding royal warrants was scrutinised amid revelations about their tax arrangements…. – Continue reading

MEPs to Commission: make member states share tax information and protect whistle-blowers

Tax evasion costs the EU €1 trillion a year in lost tax revenue, according to the European Commission. The Lux leaks scandal showed that EU countries sometimes court multinationals with advantageous tax schemes. These practices were investigated by the Parliament’s special committee on tax rulings. MEPs adopted its report last… – Continue reading

‘The best has yet to come in financial services sector’

Outgoing Deloitte Malta chairman and senior partner Andrew Manduca speaks to Anthony Manduca about the future of the financial services sector in Malta, his 36 years in the profession and the need for more accountants. Andrew Manduca is very confident about the future of Malta as a leading international financial… – 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

TAXE: Have We Taken the Right Path To Ensure Fairer and More Efficient Taxation in the European Union?

After the LuxLeaks affair in November 2014, the European Parliament established a special committee “on tax rulings and other measures similar in nature or effect” (TAXE) in February 2015. The committee’s report was adopted in a plenary session of the European Parliament on 25 November 2015. The Conference of Presidents… – Continue reading

Royal warrant companies accused of using tax havens and moving their manufacturing out of Britain

Companies like Mappin & Webb have not paid any corporation tax for the past five years, according to the Sunday Times Several companies which hold the much-coveted royal warrant have come under scrutiny after being accused of benefiting from tax havens and moving their manufacturing out of Britain. The warrants… – Continue reading

The Changing Landscape for IP Regimes Around the World

Patent Boxes, Innovation Boxes, Intangible Property Boxes, Knowledge Development Boxes (IP Regimes) – countries may use different names, but all of these regimes are designed to allow a preferential rate of tax to be applied to income generated from intangible property (IP). There are a number of these regimes in… – Continue reading

Worldwide: A Guide To The Top 20 Offshore Fund Locations

There are a variety of benefits to moving offshore, yet few would argue the assertion that tax neutrality is paramount among them. As anyone familiar with the phrase “tax haven” would surely recognize, many countries offer strongly favorable tax terms as an incentive to draw new business. Written by CT… – Continue reading

Beps impact on Ireland? So far, so good

Global corporation tax reform proving good for country As things stand, it would appear that matters are going Ireland’s way insofar as global corporation tax reform is concerned. The country-by-country reporting rules that have been proposed under the OECD’s Beps programme, and that commentators had been focused on in relation… – Continue reading

Removing the obligation to declare payments made by companies to individuals established in Cyprus, Luxembourg and Seychelles.

On October 30, 2015, the Global Forum on Transparency and Exchange of Information for Tax Purposes decided that Cyprus, Luxembourg and Seychelles have actually and substantially implemented the international standard on transparency and exchange of tax information. Therefore, companies no longer have the obligation to declare payments made to persons… – Continue reading

EU adopts new transparency rules

The EU Council has adopted a new transparency directive aimed at preventing corporate tax avoidance The directive, which was proposed by the European Commission (EC), is aimed at improving transparency on tax rulings given by member states to companies about how their taxes are calculated. Under the new directive, member… – Continue reading

Noonan explains Ireland’s stance on CCCTB, code of conduct

Michael Noonan, Ireland’s Finance Minister, underlined Ireland’s position on key international tax issues that were scheduled for discussion at a meeting of the EU’s Economic and Financial Affairs Council (ECOFIN), reports Tax News. Noonan was addressing the Joint Committee on Finance, Public Expenditure, and Reform on December 1, 2015, in… – Continue reading

Call for UK clampdown on territories

An influential UK newspaper has called for Britain to force its Overseas Territories to create a public register of owners of companies. Chris Blackhurst, the group content director of a four-newspaper stable, writing in the London Evening Standard, said: “Only then, once we have put our own house in order,… – Continue reading