The caretaker government may make the Netherlands a less attractive location for international business because of changes to the corporate tax system, the employers’ organisation VNO-NCW and tax advisers have warned, the Financieele Dagblad said on Monday. The employers and Dutch Order of Tax Advisors say the government is choosing… – Continue reading
The reach of Deferred Prosecution Agreements (“DPAs“) has been broadened to include the new offences of failing to prevent the facilitation of UK or foreign tax evasion – strengthening the DPA regime yet further as a weapon in the fight against corruption. From 30 September 2017, it will be an… – Continue reading
The government approved the agreement on Thursday to avoid double taxation between Estonia and Japan and handed over the power to the finance minister to sign the agreement on behalf of Estonia. The plan is to sign the agreement on August 30 in Tallinn, spokespeople for the government said. The… – Continue reading
Wealth managers have only days to send clients warning letters about disclosing overseas assets to the taxman, or risk a £3,000 fine. Wealth managers, advisers and fund managers have until 31 August to send an HM Revenue & Customs (HMRC) approved letter to clients about holding assets abroad which warns… – Continue reading
Top ‘compliant’ rating given to Ireland, Norway and Mauritius Ireland has received one of the highest international ratings on tax transparency from the OECD. The organisation’s Global Forum on Transparency and Exchange of Information is part of the implementation of the common reporting standards in the wake of the global… – Continue reading
Britain is the world’s second largest conduit for multinational companies avoiding tax on profits, according to new research. Although the British government has taken a leading stand in the fight to tackle corporate tax avoidance, data analysis by researchers at Amsterdam University in The Netherlands shows The City of London… – Continue reading
The Supreme Court has recently ruled in favour of HM Revenue and Customs in a long-running dispute with Rangers FC over the use of employee benefit trusts (EBT) as a means of avoiding tax. The case, which was initially decided in favour of the Glasgow-based football club in two employment… – Continue reading
Croatia and New Zealand have agreed that they should negotiate an agreement on the avoidance of double taxation. Croatia’s President, Kolinda Grabar-Kitarovic, said an agreement was discussed in a meeting with New Zealand’s Prime Minister, Bill English, while she was on a state visit to the country. A double tax… – Continue reading
Council leisure centres, universities and private schools would be forced into paying business rates under reforms suggested in a major review. Ken Barclay, the former RBS chief, accused local authorities of tax avoidance by delivering services such as gyms and cafes through arm’s length organisations (ALEOS) that attract charity relief…. – Continue reading
The United Kingdom’s Criminal Finances Act 2017 (the “Act”) creates two new corporate offences of failure to prevent facilitation of tax evasion (the “Corporate Offences”). These new Corporate Offences will be committed where a relevant body fails to prevent an associated person criminally facilitating the evasion of tax, whether the… – Continue reading
Thailand has lost income worth Bt4.311 billion due to tax evasion on luxury cars, according to an investigation of 259 luxury cars, Department of Special Investigation (DSI) deputy chief Korrawat Panprapakorn said on Friday. The DSI is forwarding information from Italy to the Customs Department to assess unpaid tax for… – Continue reading
The Geneva asset management firm Prime Partners has agreed to pay $5 million (CHF4.8 million) to the United States to settle charges for tax evasion and assisting US taxpayers in opening and maintaining undeclared foreign bank accounts from 2001 to 2010. A US Department of Justice (DOJ) statement external linkon… – Continue reading
The UK tax authority, HM Revenue and Customs (HMRC), has issued guidance for businesses on the preparation of country-by-country reports in the required format. The CbC report is one element of a new three-tiered standardized approach to transfer pricing documentation proposed under Action 13 of the OECD’s base erosion and… – Continue reading
INTRODUCTION HMRC have successfully challenged the offshore residence of Jersey companies holding UK real estate. In the case of Development Securities, the First Tier Tribunal held that Jersey companies set up to hold UK real estate were resident in the UK for tax purposes. This case serves as a timely… – Continue reading
The government’s plan to impose more levies on large companies will undermine their competitiveness amid a rising global trend of tax reductions and further distort the country’s taxation structure, analysts say. A draft tax code revision unveiled early this month proposes raising the corporate tax rate for businesses with taxable… – Continue reading
Every individual has a nil rate band of £325,000 after which any assets above this threshold become taxable at 40% unless they are passing to an exempt beneficiary such as a charity or spouse/civil partner. This threshold has been frozen until the end of the 2020/21 tax year. The government… – Continue reading
This article is the third of a series of articles that examines tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors in other offshore financial centres…. – Continue reading
Ireland has published guidelines for requesting Mutual Agreement Procedure (MAP) assistance. The guidelines, issued in early August, set out the legal basis for requesting MAP assistance as well as: the process through which taxpayers can request assistance from Ireland’s Competent Authority (the Revenue) the possible outcomes resulting from a request… – Continue reading
The UK tax authority, HM Revenue and Customs (HMRC), has warned taxpayers to avoid disguised remuneration schemes that attempt to recharacterize loan arrangements to avoid the 2019 loan charge on disguised remuneration. “HMRC is aware of schemes that claim to avoid the 2019 loan charge on disguised remuneration. These schemes… – Continue reading
The Irish Government is said to be nearing a deal with Apple that would protect the state from any losses that could arise while it holds in escrow the “state aid” money the EU has ordered the tech giant to pay back. Bloomberg reported that an individual familiar with the… – Continue reading
The UK tax man has raised almost an extra £30 billion in the past year from cracking down on avoidance. The boost came in a year that saw HM Revenue & Customs collect a record £574.9 billion in taxes from individuals and businesses. The tax take was £38.1 billion up… – Continue reading
Companies operating in Belgium sent more than €221 billion to countries local authorities regard as tax havens, according to Belgian daily Le Soir. Belgium’s gross domestic product was €466 billion last year. According to the country’s tax authorities, 853 Belgian companies funneled almost a half of the country’s economic output… – Continue reading
Brazilian football star Neymar is willing to pay a fine of £1.9 million to settle tax evasion allegations in his country, his lawyer said Friday. The 25-year-old wants to leave the fight with Brazilian authorities behind him as he prepares for a new professional life with Paris Saint-Germain after his… – Continue reading
I am a trustee of an offshore trust settled by a UK resident, non-UK domiciled settlor (with no UK origins) for the benefit of himself and his family. He previously opted to be taxed on the remittance basis. The trust holds only offshore investments. The settlor lent monies to the… – Continue reading
Luxembourg Finance Minister Pierre Gramegna has introduced legislation into parliament that would establish a new intellectual property tax regime in Luxembourg. The bill was submitted to the Chamber of Deputies on August 4, 2017, and is designed to be aligned with the “modified nexus” approach to special IP tax regimes… – Continue reading
Opposition to the widening of the automatic exchange of information (AEOI) is growing stronger, and now the populist Swiss Peoples Party (SVP) has called for a slowing of the process. In the consultative process several bodies, including the Union of Swiss Private Banks (Vereinigung Schweizerischer Privatbanken) have criticised the rapid… – Continue reading
HM Revenue & Customs’ new online Trusts Registration Service is now up and running, and beginning to get the attention of trust providers in a big way. Here, tax commentator Gerry Brown looks at the new regulations, and what they will mean for those in the trusts industry. The UK… – Continue reading
Amazon has refused to reveal how much it paid in total UK tax last year after it emerged it actually got a rebate of £1.3million. The online giant, which three years ago pledged to stop using a controversial tax avoidance scheme, admitted it had paid just £7million in corporation tax… – Continue reading
On August 3, 2017, the Irish Revenue published Revenue e-Brief No. 74/17, which contains guidance for taxpayers on complying with Ireland’s transfer pricing documentation requirements. The guidance notes that companies are legally required to maintain transfer pricing documentation. However, there is no requirement for documentation to be kept in a… – Continue reading
The New Zealand Government has announced the signature of two Orders of Council that will implement amendments to its tax treaty arrangements with India and San Marino. The third protocol to the double tax agreement (DTA) with India updates the information exchange provisions and inserts an article on assistance in… – Continue reading
The Swiss Federal Council has announced that an information exchange amendment to the double tax agreement with Belgium has entered into force. On August 7, the Council said the additional agreement to amend the DTA had entered into force on July 19. It contains an administrative assistance clause in accordance… – Continue reading
France is Airbnb’s second largest market and yet in 2016, the internet giant paid the country just €92,944 in taxes – equivalent to the amount paid by small and medium-sized enterprises (SMEs). Second only to the US as Airbnb’s biggest market and with Paris its top city for listings, during… – Continue reading
The notification follows hectic parleys between India and Switzerland for introduction of AEOI (Automatic Exchange of Information) under guidance of G20, OECD (Organisation for Economic Cooperation and Development) and other global organisations. Switzerland found India’s data security and confidentiality laws “adequate” for entering into an automatic exchange of information pact,… – Continue reading
APAs were recently implemented in the Croatian tax legislation. Our Transfer Pricing team briefly presents the main points of the Croatian legislation related to an APA. Transfer pricing legislation was introduced in Croatia by way of the Corporate Income Tax Act (CIT) on 1 January 2005. However, the Croatian tax… – Continue reading
Representatives of most multinational companies believe that there is a radical global change in both tax and tax control. Accordingly, the global tax model is undergoing a process of alignment with other principles, and the approach of the tax authorities during controls becomes stricter, a survey by Deloitte published in… – Continue reading
As part of the Irish Budgetary process, officials from the Finance Department have published a paper on the implications of Brexit for Ireland’s tax system. The paper was prepared for consideration by the Tax Strategy Group (TSG), an interdepartmental committee chaired by the Finance Department. The papers produced by the… – Continue reading
The UK will not engage in aggressive tax competition to attract business post-Brexit, Chancellor Philip Hammond has said. He added that the country’s economy will remain aligned with the European model after leaving the EU. “It is often said that London would consider launching into unfair competition in terms of… – Continue reading
ZURICH (Reuters) – Pushing forward European and international measures to prevent profit shifting and international tax fraud will be a top priority for Austria’s European Council presidency in the second half of 2018, Austrian Finance Minister Hans Joerg Schelling said on Saturday. “The cross-border fight against tax fraud and tax… – Continue reading
“Disproportionate” value disappears from economic system compared to GDP Malta ranks first among a number of EU countries in a list of what a new study calls 24 “sink offshore financial centres”, which it says are typically characterised as tax havens. The study, published this week in the academic journal… – Continue reading
Israel wants to develop friendly relations with Armenia, according to that country’s Regional Cooperation Minister, Tsakhi Hanegbi, who told Foreign Minister Edward Nalbandian on Wednesday as he kicked off an official visit to Armenia. He said that the purpose of his visit was to advance those ties. The two signed… – Continue reading
On 22 June 2017, the parliament of Kyrgyzstan approved the bill ratifying the tax treaty signed with Georgia on 13 October 2016. Currently, the ratification from Georgian side is still pending, and in order to become law and to be ratified, the bill still needs to be signed by the… – Continue reading
Computer scientists have worked to uncover the way the Netherlands, the UK, Ireland, Singapore and Switzerland, in particular, are used by multinationals to channel investments onto well-known offshore centres (OFCs). According to the research which was first reported by online journal Quartz, the five countries are used by multinationals to… – Continue reading
France intends to appeal against a recent court decision in favor of Google in a major tax avoidance case, but is open to settling the dispute outside of court, a government minister has said. In an interview with Les Echos, Minister of Action and Public Accounts, Gerald Darmanin, said that… – Continue reading
Business group Ibec has said that the Irish Government must “Brexit proof” its 2018 Budget, improve its foreign direct investment model, and implement a range of tax reforms to compete with the UK. Publishing the group’s pre-Budget submission, Ibec Director of Policy and Public Affairs, Fergal O’Brien said: “The Irish… – Continue reading
Italy is the most complex jurisdiction in Europe and comes in first place globally for ‘tax’ complexity, while Greece is most complex in the world for ‘compliance.’ Italy and Greece are among the five most complex jurisdictions in the world for Accounting and Tax compliance, according to TMF Group’s inaugural… – Continue reading
The OECD has praised Luxembourg’s tax regime for its predictability, although it sounded a warning about the volatility of tax revenues from the financial sector. In its latest assessment of the Luxembourg economy, the OECD said that Luxembourg’s strong economic performance was due partly to “business-friendly regulations, a predictable tax… – Continue reading
Tax avoidance by multinationals is better dealt with by an international treaty than harsher measures brought in by Australia and the United Kingdom, Revenue Minister Judith Collins says. In an interview with TV3’s The Nation, the minister said she had not ruled out the idea of diverted profit tax, which… – Continue reading
HM Revenue and Customs (HMRC) has released guidance on a change to value-added tax rules to tax services used outside the EU by UK consumers. The changes, which were introduced in the Spring Budget 2017, will affect suppliers of mobile telecommunication services, private consumers, and non-business users who consume telecommunication… – Continue reading
The Irish Parliament’s arts committee has recommended the introduction of a “foreign artists’ withholding tax (WHT) scheme.” The committee has released a report on the Government’s Culture 2025 initiative, which is intended to provide a framework for the development of Irish arts, culture, and heritage over the next eight years…. – Continue reading
THE BENEFITS OF NON-DOMICILE STATUS An individual who is resident but not domiciled in the UK does not pay tax on overseas income and gains, as long as they are kept outside the UK and are not used to provide benefits in the UK. This is called the remittance basis… – Continue reading
