Category: Luxembourg

As tax havens disappear, global revenue wars begin

We are entering a new world of tax revenue wars, and no one can say who will emerge as the victor. All we know is that there will be tension over the next five years as governments seek to implement the global plan to end to tax havens from Luxembourg… – Continue reading

Starbucks, Fiat Decisions Seen in First Wave of EU Tax Cases

Starbucks Corp. and a Fiat Chrysler Automobiles NV unit are set to be first in the firing line as European Union regulators issue a series of rulings over tax breaks for global companies, including Apple Inc. The EU may issue decisions against Starbucks and Fiat as soon as next week… – Continue reading

Commerzbank agrees with prosecutors on fine for tax evasion -report

Oct 14 Germany’s Commerzbank has agreed with Cologne prosecutors to pay 17 million euros ($19.49 million) of fines for tax evasion, Sueddeutsche Zeitung reported on Wednesday, without citing the source of the information. Germany’s second biggest bank by market value is the country’s third lender after Hypovereinsbank and HSH Nordbank… – Continue reading

Ireland, accused of giving tax breaks to multinationals, plans an even lower rate

Ireland, whose corporate tax rate of 12.5 percent is already one of the lowest in the developed world, said it would cut that rate in half for a new tax category — one covering revenue pegged to companies’ patents and other intellectual property. The Irish government, long criticized by other… – Continue reading

Geneva Bank Jobs Fall to Lowest Since Crisis Amid Regulatory Woe

Banking jobs in Geneva slipped to the lowest level since the 2008 financial crisis amid regulatory pressures, tax scrutiny and consolidation in the Swiss finance industry, according to lobby group Geneva Financial Center. Employees at banks in the city fell 3 percent to 18,855 in the 12 months through August,… – Continue reading

Report: AstraZeneca funnels billions into Dutch tax-avoidance scheme

AstraZeneca ($AZN) is not the first company to employ questionable tax-planning strategies, and it certainly won’t be the last. But the U.K.-based drugmaker is the latest poster child for tax avoidance. As The Guardian reports, AstraZeneca funneled billions of dollars into the Netherlands to get out of paying corporate taxes… – Continue reading

Ireland wins as UBS shifts fund from Cayman Islands

Swiss fund manager will use new Irish Icav structure to move product from the Caribbean domicile UBS has shifted a fund of hedge funds onshore to Ireland from the Cayman Islands, delivering another blow to the reputation of the Caribbean tax haven as the domicile of choice for international hedge… – Continue reading

Leumi to Reclaim Bonuses From Executives After U.S. Tax Fine

An independent panel appointed by Bank Leumi Le-Israel Ltd. recommended that a former chairman and chief executive officer both return bonuses after the lender agreed to pay a fine to U.S. authorities in a tax probe. An insurer for the former bank officials will pay an additional $92 million. Leumi,… – Continue reading

G20 economies to tackle corporate tax avoidance

G20 finance ministers have endorsed a package of measures to tackle corporate tax avoidance, but questions remain about whether certain countries will follow through on the plans or leave loopholes multinationals can exploit. The ministers agreed to back proposals drawn up by the OECD, which aim to shake up rules… – Continue reading

India: No MAT for FIIs/FPIs For Period Pprior To April 2015

The CBDT has clarified that MAT provisions will not be applicable to those FIIs /FPIs which do not have a permanent establishment in India, for the period prior to 1 April 2015. An amendment to the IT Act will be made in the winter session of Parliament and directions have… – Continue reading

DBS China picked to test yuan payment system

DBS Bank’s Chinese unit has been chosen to be among the first group of banks to test a new international payment system that promises faster transactions for businesses using the yuan. The Cross-border International Payment System (CIPS), launched yesterday, is seen as a big step towards making the yuan a… – Continue reading

OECD report not the last word on Ireland’s FDI corporation tax regime

The global war on corporate tax avoidance doesn’t look like being so gruesome after all. The OECD reckons that governments are losing out on at least €213bn per year from aggressive tax planning by multinationals, reports the Irish Independent. A new book by a Berkeley University economics professor estimates that… – Continue reading

Colorado corporations dodge U.S. taxes through offshore accounts, according to new report

It’s no conspiracy theory that mega-corporations benefit from dodging taxes and that there are a bevy of legal loopholes accountants use to ensure businesses lose as little money as possible to the government. Few of these loopholes sound as nefarious as shuffling money into offshore accounts in the Cayman Islands… – Continue reading

UK: The Use Of UK Holding Companies In International Group Structures

The location of a holding company is a significant consideration in any international corporate structure. Choice of jurisdiction for a group holding company (‘Holdco’) is relevant both from the point of view of tax optimisation (maximising withholding tax free dividend, interest and royalty flow up through the group and minimising… – Continue reading

72% of Fortune 500 Used Foreign Tax Havens

Nearly three-quarters of Fortune 500 companies booked their profits to tax havens last year, with just 30 companies accounting for 62 percent of earnings stashed offshore, according to a new report. The report, “Offshore Shell Games,” released Tuesday by the U.S. PIRG Education Fund and Citizens for Tax Justice, found… – Continue reading

OECD: countries commit to minimum standards on international tax dispute resolution

Countries should commit to minimum standards on the resolution of international tax disputes, the Organisation for Economic Co-operation and Development (OECD) said in a report published as part of its base erosion and profit shifting (BEPS) project.06 Oct 2015 The standards would include a commitment to “seek to resolve” cases… – Continue reading

Top Wall Street Banks Stash Billions Of Dollars In Nearly 400 Offshore Tax Havens

Six of the nation’s largest banks — Bank of America, Citigroup, JPMorgan Chase, Wells Fargo, Morgan Stanley and Goldman Sachs — utilize a combined 395 known tax havens to avoid potential tax bills in the billions, according to a new analysis. In total, the big six banks kept $126 billion… – Continue reading

EU ministers agree measures to curb multinationals’ tax avoidance

LUXEMBOURG: European Union finance ministers agreed on Tuesday to automatically exchange information on deals struck with multinational companies from 2017 in a bid to reduce tax avoidance, officials said. “We have a political deal on this issue,” Luxembourg’s finance minister Pierre Gramegna told his EU counterparts in a public session… – Continue reading

Big U.S. firms hold $2.1 trillion overseas to avoid taxes: study

The 500 largest American companies hold more than $2.1 trillion in accumulated profits offshore to avoid U.S. taxes and would collectively owe an estimated $620 billion in U.S. taxes if they repatriated the funds, according to a study released on Tuesday. The study, by two left-leaning non-profit groups, found that… – Continue reading

Ireland tweaks tax regime to divert avoidance criticism

The Irish government is set to make further changes to the country’s corporate tax regime as it seeks to align itself with a global initiative to clamp down on corporate tax avoidance, reports the Financial Times. The change being considered will oblige companies that have global headquarters in Ireland to… – 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

Some of Plymouth’s most well-known landmarks are owned by offshore companies

SOME of Plymouth best-known landmarks are owned by secretive offshore companies based in tax havens, it has been revealed. Swathes of land all over the city belongs to faceless firms based in places like Luxembourg and the Cayman Islands, The Herald can reveal. They include everything from historic former military… – Continue reading

Global Tech Firms Brace for Tax Rules Which Could Create New Disputes

PARIS–Global tech firms such as Amazon.com Inc. are already preparing for new tax rules that could force them to pay corporate taxes in more countries where they operate, but are also girding for what some say will be more fights with–and between–national tax authorities. The Organization for Economic Cooperation and… – Continue reading

A Tax Revolution in the Making in EU

Europe’s stiff-neckedness is difficult to cure. To come to an agreement for supranational treatment of a certain issue there needs to be a large cataclysm or at least a large scandal. In the case of taxation policy the problem begins to gain urgent and most importantly European status after the… – Continue reading

OECD Beps: Biggest corporate tax reform plan since 1920s

On Monday (5 Oct) the Paris-based Organisation for Economic Cooperation and Development (OECD) will present its final Base Erosion and Profit Shifting (Beps) project corporate tax reform proposals and on Tuesday the Ecofin council of EU finance ministers, is expected to agree on the exchange of tax rulings between member… – Continue reading

Osborne to net billions as huge global crackdown on multinational tax avoidance begins

The world’s richest nations will launch a huge crackdown on multinational tax avoidance on Monday as part of the biggest shake-up of international tax rules for decades. The move could lead to a multi- billion pound gain for Chancellor George Osborne and higher tax bills for a raft of blue-chip… – Continue reading

US Treasury Department adds India to its FATCA list

MUMBAI: The US Treasury Department has issued a list of 34 countries which includes India with whom it would share information under FATCA (foreign account tax compliance act) regulations. The pact aims to cover automatic sharing of information on bank accounts and other instruments like mutual funds, insurance and equities… – Continue reading

Corporate tax regime to face renewed scrutiny

EU member states to reveal information on tax rulings offered to companies Ireland’s corporate tax regime is to come under renewed scrutiny next week as EU finance ministers sign off on a proposal obliging member states to reveal information on tax rulings offered to companies. EU finance ministers meeting in… – Continue reading

The rise of Europe’s unlikeliest tax haven

Two hundred miles off the coast of Morocco, the Canary Islands remainamong Spains farthest-flung territories, appearing as a few specks of volcanic rock against the endless Atlantic blue. Tourists roast on its beaches, and everything moves at a snails pace. That includes, unfortunately, the economy, which suffers from high unemploymentand… – Continue reading

Luxembourg completes FATCA implementation by enacting Luxembourg–U.S. intergovernmental agreement

The Luxembourg “FATCA Law”1 became effective on 1 August 2015. Among other provisions, the FATCA Law implemented the Model 1 Luxembourg–U.S. intergovernmental agreement of 28 March 2014 (IGA). On the day prior to the law taking effect, the Administration des Contributions Directes (Office of Income Tax) issued two circulars on… – Continue reading

Jersey: The Offshore Dragon: The Increasing Popularity Of IFCs In The PRC

Using companies incorporated in international financial centres (IFCs) in structuring financial transactions, capital raisings and corporate structures has long been popular in Asia, particularly Hong Kong (itself an IFC). Following the energetic expansion of the PRC economy and assisted in part by the relaxation of PRC regulations in relation to… – Continue reading

Revealed: St Austell property owners registered in offshore tax havens

Tens of millions of pounds worth of property in St Austell is owned by companies based in offshore tax havens. They include large parts of Fore Street in the town centre; the beaches at Carlyon Bay, and dozens of individual buildings throughout St Austell and the clay country. NHS Kernow’s… – Continue reading

EU’s Juncker releases secret ‘Luxleaks’ tax advice

Secret Luxembourg document discussed risks of special tax deals, but Jean-Claude Juncker says he cannot remember discussing it with its author The president of the European Commission faces fresh questions about his role in designing Luxembourg’s controversial system of “sweetheart” tax deals after he released an 18-year old document that… – Continue reading

Bill n° 6847 – amendment to the participation exemption regime in Luxembourg

On 5 August 2015, the Luxembourg government presented a bill implementing Council Directives 2014/86/UE and 2015/121/UE amending Council Directive 2011/96/UE of 30 November 2011 on the common taxation applicable in the case of parent companies and subsidiaries of different Member States (the Parent-Subsidiary Directive). In accordance with Directive 2014/86/UE, the… – Continue reading

Spotlight on tax havens reveals inequality link

With a slim new book that has the feel of Piketty’s bestselling Capital in the 21st Century, Zucman, a 28-year-old University of California-Berkeley economist, is taking his own swing at global capitalism. His target: tax havens that he says hide $7.6-trillion — about 8% of the world’s net financial wealth…. – Continue reading

Luxembourg bill of law introduces EU anti-hybrid and anti-abuse rules and horizontal fiscal unity

In light of the global Base Erosion and Profit Shifting (BEPS) initiative and the European developments against tax evasion and aggressive tax planning, two European Directives were adopted in July 2014 and January 20151 by the European Council, amending the Parent-Subsidiary Directive (2011/96/EU). These two Directives, in a nutshell, aim… – Continue reading

Sunlight is the best way to disinfect corporate tax havens

Tax havens are by design secretive and opaque. The entire point of their existence is to conceal the wealth hidden within them. And a new book by Gabriel Zucman, The Hidden Wealth of Nations: The Scourge of Tax Havens, reveals, as never before, the extent of their role in the… – Continue reading

US$7.6tn hidden in tax havens – almost half annual US GDP

Gabriel Zucman, one of 3 French economists who in recent times have published extensive research on wealth and equality, in a book, ‘The Hidden Wealth of Nations: The Scourge of Tax Havens,’ published this month, estimates that 8% of the world’s financial wealth — some US$7.6tn — is hidden in… – Continue reading

Shadow chancellor announces radical idea of making big businesses ‘pay their fair share of tax’

Jeremy Corbyn’s shadow chancellor has caused a stir with his idea that big businesses should pay their taxes. Speaking at the Labour Party conference in Brighton, John McDonnell named and shamed big companies over their tax arrangements. ‘Labour’s plan to balance the books will be aggressive,’ he said. ‘We will… – Continue reading

Common Rules (Not Rates) Should Be The Answer To Tax Competition In The EU

Tax avoidance is a key problem for European countries, with the EU taking several steps to try and limit the ability of businesses to shift their profits to low-tax jurisdictions. Peter Dietsch writes on the nature of the problem and what can be done to tackle it. He argues that… – Continue reading

Corporate taxation system has reached its limits, say ministers and MEPs

Tax competition as such cannot be avoided, but today’s system has reached its limits and led to unwanted side effects. Small firms should not have to bear the tax burden of multinationals that pay very little. Action is needed to harmonise corporate tax practices across Europe, so as to make… – Continue reading

MEPs: Make EU Corporate Tax System ‘Fairer’

Action is needed to harmonize corporate tax practices across Europe, according to the European Parliament’s Special Committee on Tax Rulings. The committee said this was the key sentiment voiced during a meeting with finance ministers from Luxembourg, Italy, France, Spain, and Germany on September 22. According to the committee, while… – Continue reading

Valeant’s latest tax-cutting tactic, courtesy of Luxembourg

Valeant is famous for wringing cost savings out of its buyouts, and its tax-advantaged Canadian domicile helps on that front. Now, it’s leveraging another address to pare down Salix’s tax bill by more than $560 million. But how? According to documents seen by The Wall Street Journal, the strategy used… – Continue reading

Eurozone heavyweights resume tax offensive on multinational companies

Finance ministers of euro zone’s major economies renewed on Tuesday their commitment to curb multinational corporations’ tax avoidance and called for more consistent rules to reduce “harmful” tax competition. Multinational companies have long been in the sights of European Union authorities because of the way they can legally reduce their… – Continue reading

‘30% of foreign investors from tax havens’

About 30 percent of foreign investors in Korea are from overseas tax havens, a lawmaker said Tuesday. Citing data from the Financial Services Commission and the Korea Customs Service, Rep. Park Kwang-on of the main opposition New Politics Alliance for Democracy (NPAD) said that the number of corporate or individual… – Continue reading