Category: Europe

Banking / Corporation Tax / Legislation / Residency / Serbia / Tax Deductibility / Transfer pricing / Withholding Tax

Serbia to Abolish Full Blown Withholding Tax on Non-Resident Service-Providers and Simplify Conditions for Tax Deductibility of NPL Write-Offs for Serbian Banks

Posted On: December 4, 2017

The Serbian Ministry of Finance has published draft amendments to the Corporate Income Tax Act (CITA), which are expected to be formally approved by the Government within days. If approved by the Parliament, as expected, CITA amendments will take effect from 1 January 2018. The most important novelties concerns recognition… – Continue reading

Double Tax Treaty / Income Tax / Legislation / Permanent establishment / Residence / Royalties / United Kingdom / Withholding Tax

Proposed new UK royalty withholding tax will apply from April 2019

Posted On: December 4, 2017

A new royalty withholding tax will apply from April 2019 where a non-UK resident entity making sales in the UK pays a royalty to a connected party in a low tax jurisdiction, according to a consultation document which sets out further details of the proposal, which was first announced in… – Continue reading

Business / Italy / Milan / Tax Authority / Tax evasion investigations

ITALY FINANCIAL POLICE VISIT GUCCI’S OFFICES IN TAX PROBE – SOURCE

Posted On: December 3, 2017

The source said the Milan prosecutors suspected Gucci may have paid taxes on profits generated by sales in Italy in another country with a more favourable tax regime. MILAN – Italian tax police have visited the offices of fashion company Gucci for fiscal checks as part of an investigation by… – Continue reading

Base Erosion & Profit Shifting / Double Taxation / Mutual Agreement Procedure / OECD / Tax Dispute / Tax treaties / United Kingdom

OECD statistics show 20% increase in outstanding tax treaty disputes involving UK

Posted On: December 2, 2017

The number of outstanding tax treaty related disputes in the UK increased in 2016 by almost 20% from 262 at the beginning of the year to 314 at the end of the year, according to statistics released by the Organisation for Economic Cooperation and Development (OECD). The statistics show the… – Continue reading

Appleby / Bermuda / Britain / Business / Law Firm / Offshore / Tax Haven / Trust

Not for the weather, but the tax-climate!

Posted On: December 2, 2017

“The ceiling on taxation of capital gains reflects the national belief that speculation is a more worthwhile way to make a living than work.” – Calvin Trillin, Uncivil Liberties, 1982. Time was when both death and taxes were considered unavoidable. But in the light of the latest revelations contained in… – Continue reading

Bermuda / Business / Country-by-Country (CbyC) Reporting / Jurisdiction / Multinational Enterprises ("MNEs") / Tax Transparency / Transfer pricing / United Kingdom

Bermuda To Exchange MNE Tax Info With The UK

Posted On: December 1, 2017

Bermuda and the UK recently signed an agreement providing for the automatic exchange of country-by-country reports. Bermuda is the first UK Overseas Territory to sign a CbC Competent Authority Agreement with the UK, which enables the automatic reporting of corporate income on a country-by-country basis for UK-related transfer pricing enforcement… – Continue reading

Corporate Tax / OECD / Revenue / Switzerland / Tax Reform

OECD Reports On Swiss Tax Reform Efforts

Posted On: November 30, 2017

The OECD has said that Switzerland’s efforts to meet its international commitments to reform its corporate tax regime are welcome, but noted that there is some uncertainty around the proposed reform package. The OECD has published its latest Economic Survey of Switzerland. In its report, the OECD stated that there… – Continue reading

Budget / Capital Gains Tax / Commercial Property / Corporation Tax / HMRC / Inheritance Tax / Residential Property / United Kingdom

Be warned! HMRC flexes its muscles

Posted On: November 30, 2017

Island tax expert Greg Jones has issued a warning saying he believes the UK taxman has ‘bulked up’ and is starting to ‘flex his muscles.’ Mr Jones, a director of KPMG at its offices in Athol Street, Douglas, has analysed the UK Budget in this special report for Business News:… – Continue reading

Bahamas / Business / Corporate Tax / Income Tax / OECD

World Drives Bahamas To Introduce Income Tax

Posted On: November 28, 2017

A FORMER financial services minister yesterday said global regulatory initiatives appear designed to force the Bahamas to adopt a corporate/personal income tax alien to its culture. Ryan Pinder, who held this position in the Christie Cabinet from 2012 to late 2014, told Tribune Business that the likes of the European… – Continue reading

Business / Digital Services / Framework / Government Bodies / Multinational Enterprises ("MNEs") / Revenue / United Kingdom

UK To Continue Pushing For Effective MNE Tax Rules

Posted On: November 27, 2017

On November 22, the UK Government published for stakeholders’ comments a position paper setting out its views on the challenges posed by the digital economy for the corporate tax system and its preferred solutions. The paper, which was published alongside the 2017 Autumn Budget, states that “the Government believes in… – Continue reading

Blacklist update / EU / Serbia / Tax Haven / Turkey

Serbia “removed from EU’s draft tax haven blacklist”

Posted On: November 27, 2017

Serbia has for now avoided being included in EU’s blacklist of tax havens, Bloomberg reported on Monday. The agency said last week that the November 21 draft mentioned Turkey and Serbia as some of the countries that could be added to the list. But Serbia is now seen as “compliant… – Continue reading

Budget / Corporate Tax / Denmark / France / Income Tax / Individuals / Property Tax

France Boasts Second-Highest Taxes In the World

Posted On: November 25, 2017

A new study shows that France taxes its population the second-most among developed countries. Which country claimed the first place spot? Denmark. As research from the OECD economic think tank attests, the combination of France’s income and property taxes, social security payments, and goods and services makes up 45.3% of… – Continue reading

Cyprus / Double Tax Avoidance Treaty / Foreign Direct Investment (FDI) / India

Revised tax treaty to boost bilateral investment: Cyprus envoy

Posted On: November 25, 2017

Kolkata, Nov 25 (PTI) The revised tax treaty between Indian and Cyprus will promote bilateral investments, a diplomat said here today. The two countries signed the revised India-Cyprus Double Taxation Avoidance Agreement in November, 2016. “I believe with new taxation agreement, investment from both sides will increase,” High Commissioner of… – Continue reading

Budget / Capital Gains Tax / Corporation Tax / Interest / Investments / Property / Real Estate / Residential Property / United Kingdom

Autumn Budget 2017: Hidden Tax Blow to Real Estate Sector

Posted On: November 24, 2017

Summary: The Chancellor unexpectedly announced a U-turn to tax gains made by non-residents on UK commercial property with effect from April 2019. This will have a significant impact on overseas investors into UK real estate and creates additional uncertainty during an already volatile time as Brexit negotiations continue. Overseas investors… – Continue reading

Budget / Greece / OECD / Revenue / Tax competition

Greece tops OECD taxation hike chart

Posted On: November 24, 2017

Greece ranked first out of 35 OECD countries in tax hikes last year, according to a report by the Organization for Economic Cooperation and Development, and the budget for 2018 will lead to an even greater tax burden that will stifle growth, the Parliament’s Budget Office (PBO) warned on Thsurday…. – Continue reading

HMRC / Law Firm / Non Compliant / Offshore / Tax Evasion / United Kingdom

Budget 2017: Extended investigation time limit for offshore non-compliance

Posted On: November 24, 2017

The UK government is planning to extend the time limit to 12 years for HM Revenue & Customs (HMRC) to investigate all offshore tax non-compliance, according to documents released as part of the Budget. A Treasury document entitled ‘Tackling tax avoidance, evasion and non-compliance’ states that the government will consult… – Continue reading

Income Tax / Individuals / Luxembourg / Residence / Tax Authority

HOW DOES THE INCOME TAX SYSTEM WORK IN LUXEMBOURG?

Posted On: November 24, 2017

If you are going to work in Luxembourg, you will probably have some queries on the tax system of the country. Do you have to pay tax in the Grand-Duchy? Which income will be taxed? What are the different types of taxes and rates that apply? To find answers to… – Continue reading

Apple / Business / Digital Services / EU / European Commission / France / Google / OECD / Tax Reform

EU competition chief Margrethe Vestager threatens Tech giants with tax reform

Posted On: November 21, 2017

Europe’s fierce enforcer of competition rules is threatening tech giants with tough new rules on tax if politicians fail to come to an agreement on changes to the current system. Efforts to amend rules that would apply tax more fairly to firms which largely operate online such as Google, Amazon,… – Continue reading

Business / EU / Europe / Foreign Direct Investment (FDI) / Hungary / UN

Hungary pursues flexible tax line to attract manufacturing

Posted On: November 21, 2017

Hungary’s Investment Agency says highly competitive tax rates continue to attract automotive manufacturing to the country as the centrally-located countries of Central and Eastern Europe (CEE) jockey for access to labour. The Visegrad 4 countries; Hungary, Poland, Czech Republic and Poland, have been highly successful at drawing in hundreds of… – Continue reading

Business / Italy / Legislation / Multinational Enterprises ("MNEs") / Permanent establishment / Residence

The Italian “temporary web tax”

Posted On: November 21, 2017

The Italian government has introduced a “temporary web tax” which will be in force until the long-awaited OECD/EU strategy for the reshaping of traditional taxation systems based on the residence of companies (or on the location of permanent establishments) has been defined. Said reshaping is aimed at introducing taxation principles… – Continue reading

EU / Ireland / OECD / Offshore / Revenue / Tax Avoidance / Tax Evasion / Tax evasion investigations

Irish Revenue Launches New Tax Evasion Inquiry

Posted On: November 20, 2017

The Irish Revenue has announced that a new inquiry is underway to identify and pursue taxpayers engaged in offshore tax evasion and avoidance. Revenue said that the inquiry is being conducted in the context of increased and ongoing sharing of information between tax administrations, and of the changes to voluntary… – Continue reading

Automatic Exchange of Information / Banking / Government Bodies / India / Switzerland

Black money: Switzerland okays automatic sharing of bank details with India

Posted On: November 20, 2017

Switzerland has approved an automatic information exchange pact with India and a number of other countries on black money, a development that would enable authorities in India get instant access to details on Indians with Swiss accounts The Commission for Economic Affairs and Taxes of the Council of States –… – Continue reading

HMRC / Legislation / Non Compliant / Offshore Tax Evasion / United Kingdom

UK Offshore tax evaders face much higher penalties for non-compliance under new HM Revenue and Customs rules

Posted On: November 20, 2017

UK Offshore tax evaders face much higher penalties for non-compliance under new HM Revenue and Customs rules. The legislation requires those with undeclared offshore tax liabilities to disclose them to HMRC before the 30th of September next year. When the Right to Correct rules come into force, offenders can expect… – Continue reading

Compliant / Isle of Man / Jurisdiction / OECD / Tax Avoidance / Tax Information Exchange Agreements / Tax Transparency

Isle of Man complies with international standards

Posted On: November 19, 2017

The Isle of Man’s critics ignore the great progress it has made in keeping its business above board. Last week the island received a ringing endorsement from the OECD. We have retained the top ’compliant’ rating by the global body reviewing tax transparency – one of only six countries worldwide…. – Continue reading

Canada / HSBC / Investments / Jersey / London / Offshore / Pakistan / Panama / Real Estate / Shell / Switzerland / Trust

Jahangir Tareen’s ‘Trust Deed’ signed and executed in Switzerland

Posted On: November 17, 2017

ISLAMABAD/LONDON: The thirty-eight-page trust deed of Pakistan Tehreek-e-Insaaf (PTI) leader Jahangir Khan Tareen’s offshore trust was signed and formalised in Geneva, Switzerland, and facilitated by HSBC Guyerzeller Trust Company Geneva – raising questions about Swiss bank accounts. During the hearing before Pakistan’s Supreme Court, Tareen was asked no questions about… – Continue reading

Double Taxation Agreement / Kosovo / Legislation / OECD / Residence / Switzerland

Swiss Gov’t Agrees Double Tax Avoidance Deal With Kosovo

Posted On: November 16, 2017

The Swiss Federal Council has adopted a dispatch on the implementation of a new double tax agreement (DTA) with Kosovo. The agreement was signed in May. A previous DTA was in force until 2011. The DTA caps the maximum withholding tax rate for dividends being taxed at source at 15… – Continue reading

Germany / Tax Authority / Tax Evasion / Tax evasion investigations / Tax Fraud / Volkswagen

Investigators raid VW offices as tax fraud suspicion lingers

Posted On: November 15, 2017

Prosecutors and investigators from tax authorities have raided the offices of several senior officials from German carmaker Volkswagen. The move was part of an effort to scrutinize the firm in a tax evasion probe. Investigators on Tuesday night searched the offices of VW finance chief Frank Witter and human resources… – Continue reading

Court cases / Iceland / Individuals / Tax Evasion / Tax evasion investigations

Dozens of Tax Evasion Cases Dropped

Posted On: November 15, 2017

Around 60 cases against suspected tax evaders have been dropped by the district attorney’s office due to a break in case proceedings while waiting for a decision from the European Court of Human Rights. Kjarninn reported first. Many of the dropped cases are against individuals who appeared in the Panama… – Continue reading

Individuals / Jurisdiction / Legislation / Residence / Switzerland / Tax Reform

Special tax on provisionally-admitted migrants to end in 2018

Posted On: November 15, 2017

As of January 1, 2018, holders of an ‘F’ permit will no longer be subjected to a 10% special ‘compensatory’ tax on income designed to recuperate costs of their asylum procedures. However, the waiver of the 10% compensatory tax is valid only if the income earned is less than CHF15,000… – Continue reading

Apple / Corporate Tax / Intellectual Property / Ireland / Legislation / Offshore / Property / Tax Haven / USA

Senate’s Offshore Tax Ideas Could Be a ‘Goldmine’ for Some Companies

Posted On: November 14, 2017

Plan proposes 12.5% tax rate on intellectual-property income Bills ‘upend decades of U.S. tax policy’ on tight deadline U.S. companies that make billions of dollars from patents and other intellectual property held offshore would be eligible for a special 12.5 percent tax rate on those earnings under the Senate tax… – Continue reading

Bulgaria / Business / Country-by-Country (CbyC) Reporting / Jurisdiction / Legislation / Multinationals / Transfer pricing

Bulgaria Requires CbC Reports By Year End

Posted On: November 13, 2017

Bulgaria has said that multinationals covered by the country’s new transfer pricing country-by-country reporting regime should submit their first report by December 31, 2017. Through Order 3LIY-1410, Bulgaria’s National Revenue Agency has newly set out the rules concerning country-by-country documentation, including who the reporting obligations apply to and how to… – Continue reading

Automatic Exchange of Information / Bermuda / EU / Jurisdiction / OECD / Privacy / Regulatory / Tax Transparency / Trust

BDA & Industry Respond To Paradise Papers

Posted On: November 11, 2017

“Reportage about hacked data from global law firm Appleby has highlighted the substantial lack of media understanding of offshore investment structures and Bermuda’s long-time reputation for tax transparency and cooperation with international authorities,” the Bermuda Business Development Agency said. “Bermuda is committed to the exchange of relevant information to legitimate… – Continue reading

Business / EU / Jurisdiction / Legislation / Malta / OECD / Regulatory / Tax Haven

PANA report ‘confirms’ Malta ‘not a tax haven’

Posted On: November 10, 2017

FinanceMalta, the Institute of Financial Services Practitioners, the Chamber of Commerce, Enterprise and Industry and the Gozo Business Chamber have welcomed the PANA Committee’s confirmation that the Maltese tax system is in line with current international and EU standards. Furthermore,according to the Committee, Malta has transposed EU rules and respects… – Continue reading

Guernsey / Isle of Man / Jersey / Northern Ireland / Tax Arrangement / Tax Avoidance / Tax Evasion / Tax Reform / Tax Transparency / United Kingdom

Jersey, Guernsey and Isle of Man join commitment to tackle tax evasion

Posted On: November 10, 2017

The commitment comes amid ongoing controversy over the use of complex tax arrangements following the Paradise Papers leak. The islands of Jersey, Guernsey and the Isle of Man have signed up to a joint commitment with the British and Irish governments to tackle tax evasion and abusive tax avoidance. The… – Continue reading

Anti money laundering / Appleby / British Virgin Islands / Netherlands / Tax Haven / Yacht

Dutch-built super yachts are being re-sold to tax haven buyers

Posted On: November 10, 2017

Luxury yachts built in Dutch shipyards are being sold to suspect buyers around the world through tax havens, Trouw and the Financieele Dagblad reported on Friday. The dubious yacht transactions were revealed through an investigation being carried out into the Paradise Papers by the two Dutch newspapers . The documents… – Continue reading

EU / France / Jurisdiction / Tax Haven / Tax Laws / Tax Transparency

France’s Le Maire Calls For Tax Haven Sanctions

Posted On: November 9, 2017

French finance minister Bruno Le Maire has urged countries to approve tougher sanctions against jurisdictions that do not adhere to standards in tax transparency in the wake of the Paradise Papers leak. Le Maire told reporters ahead of a meeting of European Union finance ministers in Brussels that such sanctions… – Continue reading

Base Erosion & Profit Shifting / Common Consolidated Corporate Tax Base / Corporate Tax / EU / European Commission / Ireland / OECD / Revenue / Tax Avoidance / Tax Planning

CCCTB FAQ

Posted On: November 8, 2017

The European Union Common Consolidated Corporate Tax Base (CCCTB) has been talked about recently as a solution to the problem of an imperfect pan-EU corporate tax system, which allows large companies, particularly those with a digital presence, to detach profits from value-creation, and pay tax in low-tax jurisdictions. But what… – Continue reading

EU / Government Bodies / Legislation / Netherlands / Withholding Tax

Dutch government continues with dividend withholding tax proposal and announces conditional retroactive amendment to CIT fiscal unity regime

Posted On: November 8, 2017

In this Tax Alert we will briefly highlight two topical Dutch tax matters very relevant to internationally active companies: the current status of the legislative proposal regarding Dutch dividend withholding tax rules for holding cooperatives and BVs/NVs and the announcement of the Dutch Ministry of Finance that the Dutch fiscal… – Continue reading

Banking / Credit Suisse / Germany / Switzerland / Tax Evasion / Zurich

Swiss banks and tax evasion: spy verdict expected in German court

Posted On: November 8, 2017

Rarely has a spy case attracted so much attention in Germany as that of Daniel M. The bungling double agent passed on troves of bank data to German tax officials while allegedly gathering info on them for the Swiss. As far as the chronicles of the great espionage stories go,… – Continue reading

Bermuda / Business / Cayman Islands / Investments / Jurisdiction / Offshore / Offshore Financial Centres / Regulatory / Tax Haven / Tax Laws / United Kingdom

Cayman Islands defends integrity of its offshore financial sector

Posted On: November 8, 2017

GEORGE TOWN, Cayman Islands (CMC) — The Cayman Islands, noting that it has had to get used to “unfair and inaccurate” reporting about its global financial sector, is distancing itself from the so-called Paradise Papers, a set of confidential documents related to offshore investment. In addition, the island has also… – Continue reading

Apple / Appleby / Ireland / Jersey / Multinational Corporations / Offshore / Residency / USA

Apple defends moving offshore profits to the tax haven of Jersey

Posted On: November 7, 2017

The company known for the ‘double Irish’ scheme is moving its subsidiaries’ tax residency. A set of leaked documents from offshore law firm Appleby has revealed that Apple stashed $250 billion in Jersey, a tiny island off the coast of France known for being a tax haven. The tech titan… – Continue reading

Beneficial Ownership / Business / Corruption / Ghana / Indonesia / Ukraine

Ghana wins award for Company Ownership Transparency

Posted On: November 6, 2017

Ghana has won international recognition for its commitment to expanding the frontiers of transparency, including progress made towards lifting the veil off the actual beneficial owners of companies operating in the country. The recognition came in the form of an award from the Extractive Industries Transparency Initiative (EITI) International Board… – Continue reading

Appleby / Bermuda / Business / Jurisdiction / Law Firm / Offshore / Tax Evasion

Appleby Says Only Demonstrable Crime Is Of Data Theft

Posted On: November 6, 2017

Appleby, the offshore law firm, has spoken out against recent media coverage, which implies but does not allege that there is wrongdoing in the papers recently exposed that include information on its clients’ tax affairs – the so-called Paradise Papers. In its latest statement, the firm said: “Recent media coverage,… – Continue reading

Appleby / Canada / Cayman Islands / Facebook / Individuals / Investments / Liberia / Mauritius / Nike / Offshore Companies / Oil / Pakistan / Revenue / Russia / Trust / Yemen

Paradise Papers: ICIJ releases another database revealing offshore companies

Posted On: November 6, 2017

The International Consortium of Investigative Journalists (ICIJ) has released a database of around 13.4 million documents revealing over 25,000 companies owned by the world’s rich and influential individuals. The ICIJ coordinated the Panama Papers investigation into offshore companies. The latest files have disclosed the financial details of politicians, corporations, and… – Continue reading

British Virgin Islands / Jurisdiction / Russia / Tax Authority

Russian Federation: BVI Ready To Disclose Beneficiaries

Posted On: November 3, 2017

Goltsblat BLP advises that the Federal Tax Service (FTS) has approved BVI’s removal from the list of countries (jurisdictions) not exchanging information with the Russian Federation for tax purposes from 1 January 2018 (the relevant order is pending registration with the Ministry of Justice). A country’s removal from the FTS… – Continue reading

Bahamas / Base Erosion & Profit Shifting / Corporate Tax / Income Tax / OECD / Tax Avoidance

‘Low Level’ Corporation Tax Studied

Posted On: November 3, 2017

The Deputy Prime Minister yesterday revealed the Bahamas “may have to look at” implementing a low-rate corporate income tax, as global regulatory pressures force “hard decisions” upon it. K P Turnquest, while emphasising that such a move was a long way off, agreed that compliance with the OECD’s Base Erosion… – Continue reading

Budget / Business / Cayman Islands / Debt / Jurisdiction / Legislation / Revenue

Cayman Budget Targets Budget Surpluses

Posted On: November 2, 2017

The Cayman Islands’ Premier, Alden McLaughlin, recently delivered the territory’s first two-year budget, which was notable for the absence of new borrowing or revenue-raising measures. McLaughlin said his administration will continue to pay down debt and deliver operational budget surpluses to fund capital investment plans and provide for contingency against… – Continue reading

Barbados / Business / Caribbean / Czech Republic / Double Taxation / DTA / Italy

Double Taxation Agreement Between Barbados and Italy In Effect

Posted On: November 2, 2017

BRIDGETOWN, Barbados, Thursday November 2, 2017 – The Double Taxation Agreement (DTA) between the Government of Barbados and the Italian Republic has entered into force. The instruments of ratification for the Convention for the Avoidance of Double Taxation with Respect to Taxes on Income and the Prevention of Fiscal Evasion… – Continue reading

Base Erosion & Profit Shifting / Isle of Man / Jurisdiction / OECD / Tax Avoidance / Tax treaties

Treasury ratifies OECD’s tax avoidance treaty

Posted On: November 2, 2017

The Treasury says the Isle of Man has become one of the first countries to sign a new international treaty against tax avoidance. The Island joins Austria in agreeing to the OECD’s Multilateral Convention to Implement Tax Treasury Related Measures to Prevent Base Erosion and Profit Shifting. The agreement aims… – Continue reading

Digital Services / EU / OECD / Tax Equalisation / United Kingdom

CIOT Urges Restraint From Digital-Tax Policymakers

Posted On: October 31, 2017

The Chartered Institute of Taxation, the UK tax professionals representative body, has urged lawmakers globally to pause for thought on the direction being taken on the taxation of the digital economy. It is urging that any measures to improve the tax rules covering the digital economy must be developed and… – Continue reading

Category: Europe

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