Category: Europe

Senegal signs multilateral agreements to fight tax avoidance and evasion

Senegal on February 4 signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, becoming the 93rd jurisdiction to sign the document, and the Multilateral Competent Authority Agreement for the automatic exchange of Country-by-Country reports, becoming the 32nd signatory to that agreement, the OECD has announced. The Multilateral Convention… – Continue reading

Bank Julius Baer Hit With $547M Criminal Tax Evasion Penalty, Two Bankers Plead Guilty

Bank Julius Baer of Switzerland will pay a $547 million penalty as two bankers individually plead guilty. The bank itself is charged with helping U.S. taxpayers hide billions in offshore accounts and cheating the IRS. The Bank’s deferred prosecution agreement admits that it knowingly assisted U.S. taxpayer-clients in evading taxes…. – Continue reading

The Tax Avoidance Battle: Nations vs. Multinationals

At least this is the goal – member states safeguarding their social models by preventing trans-border operating multinational companies from avoiding “their fair share” of the tax burden. According to the European Commission, small and medium-sized enterprises in the EU pay 30% higher tax burden than large multinational companies. With… – Continue reading

Beazley moves its tax base back to Britain from Ireland

Insurance firm has been domiciled in Ireland since 2009 The insurance group Beazley has said it will move its headquarters back to London more than six years after shifting to Dublin for tax reasons. The FTSE 250 firm will ask shareholders to vote on the move back to the UK… – Continue reading

Kenya: Treasury Defends Controversial Mauritius Tax Agreement

Treasury is still fighting to keep a tax agreement out of parliament after a lobby group sued them over a pact it signed with Mauritius back in 2012. The double taxation avoidance agreement allows firms registered in the two countries to pay taxes in only one country. It also allows… – Continue reading

Cayman’s offshore banking sector shrinking

A major sector of the banking industry in the Caymans could be wiped out by tough regulations designed to fight money-laundering. The number of Class B banks registered with the islands’ regulator has fallen by 14 to 184 over the last year alone. Class B banks generally offer depository services… – Continue reading

Unions Blast Loopholes in New EU Tax Avoidance Proposals

A collective of unions has slammed the latest proposals by the European Commission to stamp out elaborate tax plans used by multinational companies to move vast profits around the EU in an effort to reduce their corporate tax bills in member states. The European Commission last week published a series… – Continue reading

McDonald’s halves its tax bill, back pays $78m

McDonald’s Australia was able to more than halve its tax bill last year after routing payments via the low-tax nation of Singapore. Each year McDonald’s reduces its profit, and thus its local tax bill, by paying McDonald’s Asia Pacific based in Singapore, and registered in Delaware, a “service fee” amounting… – Continue reading

French Tax Update – Recent Case Law and Other Noteworthy Publications

The present French Tax Update will focus on an overview of several noteworthy publications, including decisions issued during the past few months by the French Administrative Supreme Court (Conseil d’Etat) and French Constitutional Court (Conseil Constitutionnel), as well as the European Commission decision in respect of the Belgian Excess Profit… – Continue reading

10 biggest multinational offenders evading taxes in the UK

The brands are known worldwide, and even though global companies like Google, Amazon, and Starbucks make billions — they pay little or no taxes at all in the UK and other markets where the firms make a majority of revenue and profits. Companies like Microsoft, Twitter, and Apple don’t set… – Continue reading

Google overtakes Apple as world’s most valuable listed company

Revenue spike sees tech firm’s parent company, Alphabet, valued at $568bn – surpassing Apple’s valuation of $535bn Google has become the world’s most valuable listed company after announcing that its global revenues rose 13% to $75bn (£52bn) last year, and the group’s tax rate fell to just 17%. The group… – Continue reading

Higher SDLT rates for second homes

During last year’s Autumn Statement the Chancellor announced that SDLT rates would increase in relation to the purchase of additional residential properties. As with the 2014 Autumn Statement changes to SDLT rates for residential property, it was something of a surprise move. Transactions falling within the new ‘additional dwelling’ regime… – Continue reading

All You Need to Know About Estonia’s E-Residency Program

Estonia has become the first country in the world to offer a transnational digital identity. It’s attracted the attention of entrepreneurs and digital nomads worldwide, but there’s still a huge amount of confusion about the benefits of the E-Residency Program and what e-residency actually means. Let’s take a look. What… – Continue reading

OECD BEPS deal of little significance to mining right now

JOHANNESBURG – A data sharing agreement signed by 31 countries – including South Africa – in a bid to enhance transparency by multinational enterprises, is unlikely to have an immediate impact on mining companies. Through the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reporting, signed by members of… – Continue reading

British Virgin Islands: Arbitration Agreements And Insolvency Proceedings

The British Virgin Islands (BVI) Court tightens up on creditors raising spurious disputes and relying on arbitration clauses to avoid insolvency. There has been a recent trend in the BVI whereby debtor companies have sought to identify what appear to be spurious disputes and then rely upon arbitration clauses in… – Continue reading

Scicluna insists Malta won’t budge from ‘red line’ over tax sovereignty

Finance minister will commission an impact assessment on on how a proposed package by the European Commission to clamp down on aggressive tax planning will impact Malta’s economy Malta will resist any attempt by the European Commission to reduce sovereignty over its own fiscal affairs, finance minister Edward Scicluna pledged…. – Continue reading

Brussels’ Corporate Tax Plan Falls Short of Reforms Needed

European Commission’s tax avoidance plan announced last week includes positives, like country-by-country reporting, but doesn’t go far enough to turn the tide against corporate tax dodging; Such reporting should be made public The European Commission last week announced proposals for new laws to tackle tax avoidance and evasion in the… – Continue reading

IRS 80- Swiss Banks 0

The formal IRS/Department of Justice (DOJ) Swiss Bank Program has concluded with 80 Swiss banks coming forward. The banks agreed to provide information about personnel, depositors and advisors who were participated in or assisted U.S. taxpayers in offshore tax evasion. In addition to disclosure and cooperation with investigations each of… – Continue reading

Brazil: PRORELIT, CSLL Within International Treaties And Tax Planning Statements: Conversion Of Provisional Measure No. 685/2015 Into Law No. 13,202/2015

On December 8, 2015, law No. 13,202 was published, as a result of the conversion of Provisional Measure No. 685/2015 into law. In addition to providing for the Program for Reduction of Tax Litigation (PRORELIT, for its acronym in Portuguese), said law addressed issues such as the scope of double… – Continue reading

Tax Injustice Is Systemic

COMMUNIST trade union leader Ken Gill famously referred to taxation as “the price we pay for civilisation.” If so last week gave further evidence of just how uncivilised a country Britain has become after decades of neoliberalism. Google’s deal with HMRC has rightly prompted outrage and consternation at the sheer… – Continue reading

Mauritius to begin automatic tax info exchange from Sept 2018

Mauritius will start automatic exchange of tax information with other nations only from September 2018, as it has postponed by a year implementation of global common reporting standard on tax matters. The delay could impact Indian authorities’ efforts to gather more tax-related information from Mauritius, which is allegedly being used… – Continue reading

New EU rules to curb tax avoidance among giant multinational firms, following Google’s £130m “sweetheart” tax deal with HMRC

The European Commission proposed a set of new rules to curb tax avoidance by large companies. This follows Google’s £130m “sweetheart” tax deal with UK’s HM Revenue and Customs to allegedly avoid paying its fair share of corporate tax that spreads across ten years. Euronews reported that one of the… – Continue reading

Government ‘lobbying to protect Google’s £30bn tax haven in Bermuda’

European officials have been urged by the British government to remove Bermuda – a tax haven used by Google – from an official blacklist, according to reports. The behind-the-scenes lobbying by UK Treasury ministers involved a memo circulated among Tory MEPs in Brussels describing the sanctions against tax havens as… – Continue reading

Barney Jones: Meet the whistleblower who helped expose Google’s tax avoidance

The whistleblower who helped to reveal how Google was avoiding paying tax in the UK said that Britain needed to create better incentives to encourage more people to come forward and reveal how multinationals are avoiding paying tax to the exchequer. Like millions of others this weekend, Barney Jones is… – Continue reading

Business taxation may need radical change – think tank

Radical changes to business taxation may be necessary to reduce large multinationals’ ability to avoid levies, a respected economic think tank has indicated. In the wake of the row over Google’s deal with HM Revenue and Customs, the Institute for Fiscal Studies (IFS) suggested a shake-up of the corporation tax… – Continue reading

EU targets reinsurance arrangements

The EU’s anti-base erosion and profit shifting (BEPS) proposals could have consequences for captives in Europe, as politicians pinpoint reinsurance arrangements as a means of unfair tax avoidance. The European Commission introduced a range of anti-tax avoidance proposals on 28 January, following the release of the Organisation for Economic Co-operation… – Continue reading

Secret accounts overseas urged to be reported

Those who have been hiding their income or wealth overseas had better think again, as Korea will soon be exchanging financial information with multiple countries, including tax havens. They are advised to voluntarily report it to the government before the end of March to be given a grace period, said… – Continue reading

The Italian Patent Box and Its (Non-) Compliance with OECD Recommendations

The Italian Patent Box regime largely complies with the OECD recommendations to prevent base erosion and profit shifting. Its non-compliant features offer a brief window of opportunity for companies able to take swift advantage of its wide range of qualifying intangible assets. Many countries have implemented specific IP regimes through… – Continue reading

Internet shaming and tax law enforcement

Finance Minister Bambang Brodjonegoro officially announced the aggregate tax revenue for 2015, amounting to Rp 1 quadrillion (US$72.46 billion). This record breaking number, however, was far below the target, by more than Rp 230 trillion. Still, the minister claimed the results were a decent achievement. This is true, especially because… – Continue reading

Mandatory disclosure of tax bills closer as Australia joins OECD push

Australia is one of 31 countries to sign an agreement in Paris to confidentially share tax information on multinational companies in a bid to stamp out tax avoidance. The deal comes as Apple has taken advantage of accounting rules in its local business that could allow it to pay virtually… – Continue reading

Swiss-US tax evasion saga: where are we now?

swissinfo.ch charts the evolution of the long-running tax dodging dispute between Switzerland and the United States and looks at how far there is still to go before the final curtain can be drawn on the affair. The United States wound up its “Category 2” tax evasion programme on Wednesday, netting… – Continue reading

Fair Taxation: Commission presents new measures against corporate tax avoidance

Today’s proposals aim for a coordinated EU wide response to corporate tax avoidance, following global standards developed by the OECD last autumn. New rules are needed to align the tax laws in all 28 EU countries in order to fight aggressive tax practices by large companies efficiently and effectively. The… – Continue reading

Why tax technology is critical in 2016

2015 has officially come to an end. Amidst the ending celebrations, packing away of decorations, and last spoonful of dessert, many of us are putting together our work plans and resolutions for 2016. And looking back at last years’ list, there remains one capitalised, un-crossed-off item: BEPS Perhaps your organisation… – Continue reading

Tanzania: Managing Tax Risks – Double Tax Treaties and Implications

Can tax treaty provisions override domestic law?In our last article we defined double taxation as an exposure to tax more than once on the same profit or income. We also highlighted the two types of double taxation i.e. economic double taxation and juridical double taxation and also noted that a… – Continue reading

GLOBAL REGULATIONS HIT ALL JURISDICTIONS ALIKE: CAYMAN IS KEEPING ITS EDGE, BUT PRACTICAL IMPLEMENTATION A MAJOR CHALLENGE FOR MANAGERS

There is no doubt that Cayman Islands remain the favorite domicile for alternative investment funds globally. Cayman is a full service jurisdiction complying with all international standards, but it’s also business-friendly, with a lot of demand to have all relevant industry services located there: 184 banks, 149 trust companies, 108… – Continue reading

Seoul preparing to levy ‘Google tax’

x The government plans to exchange financial information on multinational firms doing business here with members of the OECD and G20 countries in order to make them pay appropriate taxes to countries where profits are generated, officials said Thursday. The Ministry of Strategy and Finance said that it will follow… – Continue reading

100 transfer pricing disputes with US resolved, says CBDT

NEW DELHI: The Central Board of Direct Taxes (CBDT) today said it has resolved as many as 100 transfer pricing disputes with the US, which will lead to an environment of “tax certainty and encourage MNCs” to do business in India. The resolution of such issues, CBDT said further, follows… – Continue reading

EU Seeks Broader Crackdown On Corporate Tax Loopholes

BRUSSELS (Alliance News) – The EU stepped up the fight against corporate tax avoidance Thursday, unveiling proposals including an EU-wide blacklist of international tax havens, as part of a wider clampdown on firms using loopholes to reduce their tax bills. The EU’s executive estimates that member states are deprived of… – Continue reading

Start Corporate Tax Reform by Stopping Tax-Dodging Merger

If Republican leaders in Congress really want to fix our broken corporate tax system, as they’ve recently claimed, they should start by blocking what would be the biggest offshore tax dodge in American history. By stopping drug giant Pfizer from changing its legal address to Ireland — and thereby avoiding… – Continue reading

India, Armenia sign protocol to amend tax pact

India and Armenia on Wednesday signed a protocol to amend the existing Double Taxation Avoidance Convention between the two countries. “The Protocol amends the Article on Exchange of Information for tax purposes to bring it in line with the updated provisions in the OECD Model,” said a Finance Ministry release…. – Continue reading

The tax cut we have to have

Australia must not be blown off course from getting a company tax rate closer to 20 per cent. Corporate tax transparency figures released in December by the Australian Taxation Office should not slow momentum. For the first time, the ATO reported the tax affairs of companies with total incomes of… – Continue reading

31 nations sign agreement on exchange of country-by-country transfer pricing reports

In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting out the parameters for automatic exchange of country-by-country reports on large multinational corporations. The agreement — the Multilateral Competent Authority Agreement on… – Continue reading

Africa: EU Anti-Tax Avoidance Package Will Fail to End the Era of Tax Havens, Warns Oxfam

Despite EU intentions to crack down on tax avoidance, the European Commission’s Anti-Tax Avoidance Package does not do what it says on the tin, warns Oxfam, and developing countries will feel the EU’s failure most. The package comes a week after the international NGO revealed that just 62 people own… – Continue reading