Category: Luxembourg

Bramwell’s Lunch Beat: ‘Cadillac Tax,’ Tax Extenders, BEPS Hearings

Lawmakers seek late deal to scale back ‘Cadillac tax’ Lawmakers are making a late push to repeal or scale back Obamacare’s “Cadillac tax” by the end of the year, eying inclusion of changes in a broader tax package, wrote Peter Sullivan of The Hill. But lawmakers in both parties say… – Continue reading

McDonald’s Investigated for European Tax Evasion

The U.S. multinational will likely be investigated for evading taxes with Luxembourg’s help, following a report by trade unions earlier this year. McDonald’s is under investigation by European Union regulators for illegal tax deals with Luxembourg, according to sources close to the inquiry. The multinational—joining a list of EU tax… – Continue reading

Luxembourg finance minister attacks EU on business tax uncertainty

The European Commission’s use of state aid rules to challenge corporate tax agreements is causing uncertainly for businesses in Europe, Luxembourg finance minister Pierre Gramegna has said. Gramegna told the Financial Times this week that the situation “raises so many issues about predictability and certainty”. The Commission announced in October… – Continue reading

European Union: European Council Approves Transparency Rules For Tax Rulings

Following a directive proposal put forward by the European Commission as part of a package of measures in March, the European Council reached political agreement on a directive amending the text of 2011/16/EU directive on administrative cooperation in the field of taxation. EU member states will be required to automatically… – Continue reading

The Changing Face of Luxembourg Finance

“Luxembourg is famous for two things: its steel industry and its rose cultivation industry”. This quote from an Italian guidebook of the 1930s was uttered by Luxembourg’s Finance Minister Pierre Gramegna at the annual conference of the Luxembourg Directors’ Association on 17 June 2015[1]. The economic outlook of the tiny… – Continue reading

Tax Policy Emerges As New Source of Friction As Europe Seeks Additional Revenue From US Multinationals

The 28 nations of the European Union lose up to $1 trillion per year in revenue thanks to multinational corporations that use a spider’s web of completely legal constructs to lower their taxes. Now, Europe’s law enforcers and lawmakers want to wipe away these intricate tax-avoidance systems. If they have… – Continue reading

EU committee to vote on plans to curb tax avoidance

EU committee to vote on plans to curb tax avoidance EU countries should be compelled to inform other member states in advance of plans to introduce tax initiatives that could affect their own or another country’s effective tax rate, according to a report to be considered by the European Parliament’s… – Continue reading

Doesn’t Look Like Much Has Really Changed At Deutsche Bank

Barely a week goes by without Deutsche Bank featuring in the news for some reason, usually a bad one. This time, it’s tax avoidance. The FT reports that Deutsche Bank “has been devising complex tax avoidance strategies for some of its largest corporate clients”. Not that this is illegal, of… – Continue reading

Apple, Amazon and Microsoft’s mega-million con: How titans of the new economy screw us all on taxes

Tech titans powering the economy shelter money through insane tax-avoidance havens. It’s wrong — and adding up Offshore tax havens enable not only individuals to dodge taxes—they also enable multinational corporations to do so. Often this tax avoidance is done within the letter of the law: multinational groups exploit the… – Continue reading

Clampdown on tax evasion

As Common Reporting Standard (CRS) comes into operation. OHANNESBURG – South Africans with undeclared offshore funds may only have a few months to get their affairs in order or risk facing significant penalties and even criminal prosecution as revenue authorities start the automatic exchange of information. The Common Reporting Standard… – Continue reading

MEPs back corporate tax reforms

The European Parliament has overwhelmingly approved a suite of corporate tax reforms that will ensure multinational companies pay taxes where profits are made and increase transparency. A total of 508 MEPs voted in favour of the adoption of recommendations put forward by the Special Committee on Tax Rulings last month…. – Continue reading

Hong Kong: Offshore Industry Tipped For Growth, Driven By Demand From Emerging Markets, According To Leading Offshore Survey

Greater China, Southeast Asia Seen as Global Leaders in Use of Offshore Vehicles, Drawn by Efficiency & Legal Frameworks Key Highlights: OIL’s sixth annual survey shows: The offshore industry will be a leaner, more resilient and confident member of the global economy by 2020, driven by demand from increasing numbers… – Continue reading

The Amendment to the France-Luxembourg tax treaty will still not be applicable in 2016!

The new provisions of the 4th Amendment to the France/Luxembourg double tax treaty on profits deriving from sale of real estate assets signed on September 5, 2014 will not be applicable in 2016. Currently, the right to tax the capital gains realized by a Luxembourg company upon the transfer of… – Continue reading

Julius Baer’s Meier Says Future for Advice Is Local

Veteran banker says India purchase reflects client demand for onshore private banking advice. Julius Baer’s Asia Pacific head Thomas Meier is preparing to leave Asia after 20 years, but he isn’t leaving Asia behind. The veteran banker, who also worked at Credit Suisse and Deutsche Bank, will continue to oversee… – Continue reading

Interview: how the tax rulings committee came up with plans for a fairer system

Multinationals should pay their taxes where they make their profits, according to one of the recommendations by the tax rulings committee, which were adopted by MEPs on 25 November. Report authors Elisa Ferreira (S&D, Portugal) and Michael Theurer (ALDE, Germany) told us it had been difficult for the committee to… – Continue reading


The Italian Supreme Court overturned decisions of lower courts to conclude that two renowned Italian fashion designers were not guilty of tax evasion. The designers, however, could still be subject to civil penalties of about €343.3 million. BACKGROUND The designers had set up Luxembourg companies, to which they had transferred… – Continue reading

Preferential multinational tax agreements under fire – European Parliament

A European Parliamentary debate this afternoon discussed measures that would lead to the curtailing of tax evasion and avoidance. A debate was sparked last year when it was revealed that Luxembourg had struck preferential multi-billion dollar tax deals with some of the world’s largest multinational corporations. This debate has been… – Continue reading

The offshore financial industry shows resilience as demand stays robust

The offshore industry is poised for growth, as the industry insiders see the demand for offshore financial and corporate services likely to increase in the coming years, according to an industry survey conducted by OIL, a corporate service provider specializing in international incorporations. The industry has been battling negative perceptions… – Continue reading

The offshore financial industry shows resilience as demand stays robust

The offshore industry is poised for growth, as the industry insiders see the demand for offshore financial and corporate services likely to increase in the coming years, according to an industry survey conducted by OIL, a corporate service provider specializing in international incorporations. The industry has been battling negative perceptions… – Continue reading

DDM Holding AG: Swiss withholding tax applies in respect of interest payments to holders of the DDM Senior Secured Notes

Following a ruling by the Swiss Federal Tax Administration, payments of interest under the DDM Treasury SEK 300 million Senior Secured Notes with ISIN SE0005280831 (the “Notes”) are subject to Swiss withholding tax since the refinancing executed in June 2015. On 23 June 2015 certain amendments to the documentation in… – Continue reading


A pending Protocol, that would amend the income tax treaty between Luxembourg and France, may not be effective until 2017. RATIFICATION PENDING The Luxembourg Parliament passed a bill to ratify the fourth Protocol to the income tax treaty (1958) between Luxembourg and France. However, it currently appears that the ratification… – Continue reading

More Banks Spill Tax Evasion Secrets To Avoid Criminal Charges, Account Holders Beware

Lately, the IRS is warning offshore account holders to disclose before it’s too late. Under FATCA, banks everywhere want to know if you are compliant with the IRS. And the cost of compliance for many people is growing. The IRS updated its list of foreign banks where accounts trigger a… – Continue reading

Clock Ticking for U.S. Holdouts as BNP Joins Swiss Tax Pact

The clock is ticking for American tax dodgers around the world after BNP Paribas SA’s Swiss unit and two other banks joined a U.S. program to avoid prosecution, revealing the exact methods of Swiss bankers’ legendary discretion. BNP agreed to pay $59.8 million in a program that has brought in… – Continue reading

Malta and Caraçao agree tax treaty

The governments of Malta and the Caribbean island of Caraçao have signed a treaty, which both sides say will prevent tax evasion and the double taxation of companies operating in both jurisdictions. In line with internationally agreed standards, Malta’s finance minister Edward Scicluna and his counterpart from Caraçuo Jose Jardim… – Continue reading

Crackdown on Caribbean tax havens a surprise boon for Hong Kong

Hong Kong is tipped to become the world’s largest offshore corporate services centre by 2020, helped ironically, by the industry’s own struggles against reform demands coming from western governments and pressure groups. On notice after high profile money laundering and tax avoidance scandals, traditional offshore havens like the British Virgin… – Continue reading

Yle programme: Finnish corporations cold-shoulder EU anti-tax planning efforts

Finnish companies continue to take advantage of legal tax planning to shelter their profits from taxation. According to Yle’s Ajankohtainen kakkonen current affairs programme, state-owned firms are among those that have been dragging their feet on reporting income from their foreign subsidiaries. The European Union is making an effort to… – Continue reading

Top tax havens for the rich

Offshore tax havens came under fire after the global financial crisis in 2008. Front and center among the countries calling for transparency was the U.S., which made a stand against Switzerland in particular, by demanding release of the names of ultra-rich account holders. So it might surprise you to learn… – Continue reading

Global Tax Network Will Impact Every Investor

Global tax is set to face the biggest shake up ever that will affect every saver and investor with accounts in any of the world’s major financial centres. Financial firms and governments are readying to start the Common Reporting Standard (CRS) from January 1, 2016. CRS is a souped up… – Continue reading

Taxes: Google quizzed by EU

Brussels – Google and Facebook were among US companies facing questions on Monday from European Union lawmakers about their tax-reducing techniques, a month after regional antitrust regulators raised the stakes by ordering Starbucks and a Fiat Chrysler Automobiles NV unit to repay millions of euros in back taxes. The queries… – Continue reading

EU Savings Directive repealed

On November 10th 2015, the European Council announced that the EU Savings Directive 2003/48/EC (EUSD) has been repealed in order to eliminate the overlap with other legislation developed in the aspect of preventing measures of tax evasion. Brief Background The 2003 EUSD, which originally came into effect on 1 July… – Continue reading

Luxembourg rated as “Largely Compliant” by the OECD Global Forum

On 30 October 2015, the Global Forum on Transparency and Exchange of Information for Tax Purposes published a supplementary peer review report for Luxembourg. Luxembourg, which was rated “Non-Compliant” in November 2013, has since implemented a number of recommendations made by the Global Forum, leading to an upgrade of its… – Continue reading

Taxing issue: multinationals respond to EP proposals to make them pay their fair share

€1 trillion a year: that’s how much tax evasion and tax avoidance is costing European tax payers every year, according to the European Commission. Parliament set up a special committee to investigate these practices in the wake of the Luxleaks scandals and came up with plans to ensure multinationals pay… – Continue reading

Switzerland & Luxembourg among DTA approvals sent for US Senate vote

Eight tax treaties and protocols were passed forward for a ratification vote by the full US Senate at a business hearing of the Committee on Foreign Relations on November 10, reports Tax News. The Committee approved the new US double taxation agreements (DTAs) with Chile and Hungary, and protocols to… – Continue reading

Ireland Braced For European Commission Ruling On Apple Tax

DUBLIN (Alliance News) – After the European Commission ruling that multinationals received unfair tax benefits in the Netherlands and Luxembourg, Ireland is braced for an EC ruling on whether its taxation treatment of technology company Apple constituted state aid. “I don’t know what the outcome will be, but this is… – Continue reading

Financial prosecutors ask PM for more staff

Early last week, Greece’s financial prosecutors sent a long letter to Prime Minister Alexis Tsipras, urging him to appoint more inspectors and expert staff to boost their efforts to raise much-needed revenue from tax evasion, Kathimerini understands. The 26-page letter, the second to be sent to Tsipras this year, was… – 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

Two states ordered to recover unpaid corporation tax

Luxembourg and Netherlands must recoup unpaid tax from Fiat and Starbucks of €20m-€30 each The European Commission has ordered Luxembourg and the Netherlands to recover unpaid tax from Fiat and Starbucks in the region of €20 million to €30 million each. On October 21st, competition commissioner Margrethe Vestager condemned tax… – Continue reading

France backs country-by-country corporate tax reporting from 2016

French lawmakers sought to tackle corporate tax avoidance on Thursday, voting to require big French companies to report tax information on their foreign activities on a country-by-country basis from 2016. The French government wants to get an early start on implementing an OECD recommendation for country-by-country reporting that aims to… – Continue reading

A Wale(s) of a Tax Strategy

Companies such as Apple, Starbucks, and Amazon are well known for legally using international law to their advantage when it comes to tax. Now a small Welsh town is mimicking their tactics. Independent traders in Crickhowell are moving their businesses “offshore” to avoid paying tax. The local businesses – including… – Continue reading

Canada to join G20 effort to limit ‘profit shifting’ by multinationals

Canada is expected to join other G20 countries to sign off on an international deal in Turkey aimed at cracking down on “profit shifting” by large multinational companies seeking to reduce their tax bills. The changes, which are also aimed at exposing the corrupt use of tax havens to launder… – Continue reading


The Senate Foreign Relations Committee has approved, for a second time, the following income tax treaties and Protocols. 12 November 2015 Switzerland: A Protocol to amend the income tax treaty with Switzerland—the Protocol was signed in 2009. Luxembourg: A Protocol to amend the income tax treaty with Luxembourg—the Protocol was… – Continue reading


A bill submitted to the Luxembourg Parliament in November 2015 would transpose, into Luxembourg domestic law, an EU directive amending a 2011 directive for administrative cooperation and concerning the exchange of information on request. The directive (2011/16/EU) as amended, is referred to as “DAC 2” (the updated “directive on administrative… – Continue reading


Tax: Luxembourg among countries helping US firms cut their tax bills by more than a quarter, campaigners say. The abuse of holding company structures in the Grand Duchy, and fiscal regimes in several other countries, allows American firms to avoid paying billions of dollars in corporate profit taxes, two NGOs… – Continue reading

US Senate Foreign Relations Committee approves eight long-pending tax treaties, Rand Paul not present for the vote

In a surprising development, the US Senate Committee on Foreign Relations on November 10 approved without amendment eight pending US tax treaties and protocols. Proposed income tax treaties with Chile, Hungary, and Poland; proposed tax protocols with Japan, Luxembourg, Spain, and Switzerland; and a proposed protocol amending the multilateral mutual… – Continue reading

BEPS and real estate investment funds: What are sponsors to do?

The final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) project were issued on 5 October (the “Reports”) after a two-year consultation period during which 62 countries and many other stakeholders (such as the World Bank, the IMF, and many trade associations) participated. These Reports, split into 15… – Continue reading

US Justice Department Announces Two Banks Reach Resolutions Under Swiss Bank

The Department of Justice announced today that Banque Internationale à Luxembourg (Suisse) SA (BIL Switzerland) and Zuger Kantonalbank (ZGKB) have reached resolutions under the department’s Swiss Bank Program. These banks will collectively pay penalties totaling more than $13 million and continue to cooperate with the department. “The agreements reached today… – Continue reading