Category: Europe

The UK’s Registry of Beneficial Ownership

According to Baroness Neville-Rolfe, Parliamentary Under Secretary of State at the Department for Business, Innovation and Skills, the United Kingdom “is at the forefront of a dramatic increase in transparency about company ownership” in developed countries. However, it is the UK which is going to provide the testing ground for… – Continue reading

Voluntary Disclosure: capital, relations spring (Italy Today, December 15, 2015)

Broader terms for the presentation of the report and the documentation related to the demands of voluntary disclosure. According to its statement in ItaliaOggi, assessments are under way between the tax authorities and the Ministry of Economy to allow more time for the completion of the procedures of the instances… – Continue reading

Australia shuts down investment schemes run by fund linked to 1MDB

The Australian Federal Court has ordered five investment schemes managed by Avestra Asset Management to shut down, The Australian reported today, following the fund’s link to the 1Malaysia Development Berhad (1MDB) controversy. It was reported that the judge made the decision after going through a report from liquidators, who unearthed… – Continue reading

European Commission adopts new rules to help EU tax authorities exchange information

On December 15, 2015 the European Commission issued a media release announcing that on that same date it adopted new rules to make it easier for EU Member States’ tax authorities to exchange financial information so that they can ensure full tax transparency and cooperation. According to the media release… – Continue reading

Russian Nuke Exec Gets Jail for Bribe Scheme

(CN) – A Russian nuclear energy official living in Maryland has been sentenced to four years in federal prison on money laundering charges, the Justice Department announced Tuesday. Vadim Mikerin, 56, of Chevy Chase. Md. was also ordered to forfeit more than $2.1 million, after he pleaded guilty to charges… – Continue reading

HMRC To Proceed With ‘Facilitating Evasion’ Offense

The UK Government has confirmed that it will legislate for a new criminal offense for corporations that fail to take adequate steps to prevent the facilitation of tax evasion. Tax authority HM Revenue and Customs (HMRC) has published responses to four consultations on anti-evasion measures announced at the March 2015… – Continue reading

Blacklisted HK: The Italian Case

More good news for Hong Kong before the end of 2015: Italy decided to remove Hong Kong from its national blacklist on November 30, 2015. Italy ratified a comprehensive agreement for the avoidance of double taxation (CDTA) signed with Hong Kong on June 18, 2015. Facilitating an early removal of… – Continue reading

Swiss banks pay $130M to avoid US tax evasion charges

Three Swiss banks, including a unit of France’s Crédit Agricole SA, will pay a total of more than $130 million to the U.S. Justice Department to avoid possible prosecution for helping Americans evade taxes, the department said on Tuesday. The Zurich-based unit of Crédit Agricole will pay $99.2 million, the… – Continue reading

Nokian Tyres received EUR 87 million additional payable tax in Finland regarding years 2007-2010

the company will make a complaint against the decision Nokian Tyres plc (HEX:NRE1V) has received a renewed reassessment decision from the Tax Administration, according to which the Company is obliged to pay EUR 87 million additional taxes with punitive tax increases and interests concerning tax years 2007-2010. Payment must be… – Continue reading

Vatican Praised for Efforts to Combat Money-Laundering

European evaluators urged Vatican prosecutors on Tuesday to move ahead and bring charges in some of the 25 money-laundering investigations they have opened over the past few years as part of beefed-up measures to prevent illicit activity at the Vatican’s scandal-marred bank. The Council of Europe’s Moneyval committee issued the… – Continue reading

Malta: The Tax Challenges Of The Digital Economy – Article 3

Main principles of Direct Taxation – Double Tax Treaties In our third article in a series of articles on the tax challenges of the digital economy, we shall be providing you hereunder with a brief overview of the principles of direct taxation, with a focus primarily on the taxation of… – Continue reading

Transfer pricing findings from the court house

Dear clients and cooperation partners, This newsflash will tell you about findings reflected in court judgements with regard to application of resale price method, and in particular – contradictions in calculation of arm’s length profit level. Recent transfer pricing judgements in Latvia lead to increased controversy in application of resale… – Continue reading

Poroshenko hopes revamped agreement on taxation would benefit for Ukraine and Cyprus

Ukrainian President Petro Poroshenko hopes that the signing of the revamped intergovernmental agreement to avoid double taxation would facilitate the development of economic relations between Ukraine and Cyprus. “Following the negotiations, the parties signed 4 documents, inter alia, those allowing the avoidance of double taxation. The head of state expressed… – Continue reading

The Gavel: Secret Gov’t – Administration Ignoring Recommendations For Access To Information Amendments

Phillip Paulwell’s response to a question from opposition member Gregory Mair about when a bill to amend the Access to Information Act (ATI) will be taken to Parliament is, at the very least, unsatisfactory and should not be accepted. Paulwell, the leader of government business in the House of Representatives,… – Continue reading

BEPS also applies to medium-sized businesses

Stricter Tax and documentation requirements for foreign transactions “Amazon, Facebook, Google and Starbucks pay little taxes …” or “Luxembourg attracts international corporations” – headlines like these have 62 states and the OECD called into action. The result was “base erosion and profit shifting” BEPS shortly. Even the German SME sector… – Continue reading

Ireland regains its swagger in the tax arena

Something unusual is happening with the Irish corporation tax in 2015 — so unusual that Ireland’s top tax man felt obliged to write to the parliament to explain what is going on. But the explanation left a lot to be desired. According to government data, Ireland received 57.7 percent more… – Continue reading

Judge drops charges against Messi relating to tax fraud in charity games

It’s been proved that the Argentina international did not receive money for the matches A Barcelona judge has archived the case against Lionel Messi regarding a claim he committed tax fraud in relation to six charity matches he participated in in 2012 and 2013, concluding that the Argentine international did… – Continue reading

No going back – the perils and pitfalls of the UK’s APN and PPN

What is abundantly clear to anyone who has a passing interest in the manner in which tax disputes are dealt with in the UK is that the legislation in Finance Act 2014, concerning accelerated and partner payment notices (the APN legislation), marks a significant shift in the rules of engagement… – Continue reading

EU probe of Apple’s Irish tax deal extended to 2016

A European Union investigation into whether Apple’s bespoke tax arrangement with the Irish government amounts to illegal state aid has been delayed again, as officials in Brussels continue to gather more information. “We do not expect any decision until after the new year,” a spokesperson for the European Commission told… – Continue reading

Common Reporting Standard Enters Into Effect for Investment Funds in Early Adopter Jurisdictions

Many jurisdictions have agreed to implement the Organisation for Economic Co-operation and Development’s multilateral system of automatic exchange of information called the “Common Reporting Standard” (CRS).  In furtherance of its objectives, the CRS imposes a variety of diligence and reporting requirements on “financial institutions,” which includes many master funds, offshore… – Continue reading

Netherlands: European Commission Puts Netherlands On Notice Regarding Its Tax Treaty With Japan

The European Commission asked the Netherlands on 19 November to amend the limitation on benefits (LOB) provision in the existing Dutch-Japanese tax treaty. The LOB provision may be detrimental to Dutch companies held by residents of certain EU/EEA countries when they receive interest, royalties and dividends from Japan. They may… – Continue reading

Cyprus: Double Tax Treaty Between Cyprus And Swiss Confederation

On 15th October 2015, the Double Tax Treaty between the Republic of Cyprus and Swiss Confederation had entered into force (the “Treaty“). The said Treaty is based on the OECD Model Convention on the Avoidance of Double Taxation on Income and on Capital. Under the Treaty, there is no withholding… – Continue reading

Coca-Cola Fights $9.4 Billion Transfer Pricing Adjustment

Dec. 14 — The Coca-Cola Co. filed a petition in U.S. Tax Court challenging a proposed $9.4 billion income adjustment related to the company’s transfer pricing for tax years 2007-09 (Coca-Cola Co. v. Commissioner, T.C., petition filed, 12/14/15). If the adjustment is sustained, the company could face a tax bill… – Continue reading

UK enforcement agencies to visit Cayman

(CNS): The UK is expected to send law enforcement officials to Cayman in the New Year to enhance the current cooperation regime between this jurisdiction and the authorities in Britain regarding financial crime and money laundering. Financial Services Minister Wayne Panton said that experts are coming at Cayman’s invitation to… – Continue reading

___uk to modify patent box in line with oecd recommendations__

Its approach includes a new “nexus principle”, as agreed by the multinational Organisation for Economic Cooperation and Development (OECD). This is designed to ensure that the benefits of the UK tax regime are only available where the research and development (R&D) expenditure required to develop that innovation also took place… – Continue reading

Hundreds more evaders caught by the taxman: Number of fraudsters prosecuted for fiddling the system up 58% in a year

Hundreds more people who fiddled their tax have been prosecuted in the past year, it was revealed today. HM Revenue & Customs (HMRC) has said its assault on tax evasion has produced a 58 per cent rise in convictions with criminals getting a total of 400 years in jail. HMRC… – Continue reading

Tax info sharing kicks in 2017

Come 2017, tax information on all foreign nationals holding bank accounts or other financial holdings in Cayman will be automatically shared with tax authorities in their home countries when the Mutual Administrative Assistance in Tax Matters convention kicks in. Maples, in a Cayman Islands Automatic Exchange of Information update statement… – Continue reading

Meg Hillier: Meet the Public Accounts Committee chairwoman taking over from Margaret Hodge

Meg Hillier has a tough act to follow. This parliament’s Public Accounts Committee chairwoman had a ringside seat watching her predecessor, Margaret Hodge, tear into tax avoiders and the tax man. “It is very exciting – you see all the guts of Whitehall spilled out in front of you,” she… – Continue reading

HMRC turns to aggressive tactics to target accountants

HMRC has been accused of targeting accountants with “aggressive” letters, without any evidence A City law firm, RPC, claims that the Revenue is writing to traditional high street accountants, implying they are helping clients avoid tax, without offering evidence in support. According to RPC, the letters imply that if accountants… – Continue reading

Ryanair pilot supplier reported to be at centre of tax evasion probe

British police and German investigators searched Brookfield Aviation International headquarters The Times of London reports this morning that a company that supplies Ryanair with pilots is at the centre of an international investigation for tax evasion. It is understood both British police and German investigators have searched the headquarters of… – Continue reading

Senate approves tax treaties with Turkey, Italy & Germany

The Senate concurred, after hearing, the ratification of tax treaties between the Philippines and the governments of Italy, Germany and Turkey that will prevent double taxation. Sen. Juan Edgardo “Sonny” Angara said the approval on third and final reading of Senate resolutions 1540, 1541, 1542 on the double taxation avoidance… – Continue reading

Company which owns Queen’s jeweller Mappin & Webb ‘has paid no corporation tax for five years despite £66million profits’

The company that owns the Queen‘s jeweller Mappin & Webb has paid no corporation tax for five years – despite profits of £66million. The allegations made against Mappin & Webb owners Aurum Holdings came as the conduct of firms holding royal warrants was scrutinised amid revelations about their tax arrangements…. – Continue reading

MEPs to Commission: make member states share tax information and protect whistle-blowers

Tax evasion costs the EU €1 trillion a year in lost tax revenue, according to the European Commission. The Lux leaks scandal showed that EU countries sometimes court multinationals with advantageous tax schemes. These practices were investigated by the Parliament’s special committee on tax rulings. MEPs adopted its report last… – Continue reading

Canada: Canadian Tax Amnesty – Time May Be Running Out For Canadians With Swiss Bank Accounts To File A Voluntary Disclosure With CRA

Swiss Banks Sending Letters to Canadian Account Holders For resident Canadian taxpayers that hold Swiss bank accounts which have not been reported to the Canada Revenue Agency (“CRA”), the window to come clean with Revenue Canada by filing a Voluntary Disclosure, and thereby avoid financial penalties and the possibility of… – Continue reading

A special relationship

Each year the elected leaders of Britain’s overseas territories (OTs) gather from around the world to meet with British Ministers in London. Their objective is to discuss the continuing partnership with the UK, to establish priorities and to try to resolve differences. For the most part the issues covered at… – Continue reading

Outcry over royal warrant handed to foreign-owned firms ‘who legally avoid paying tax’

The Queen’s jeweller has not paid corporation tax in five years, it is claimed, despite reported profits of £66million Demands are growing for a review of the royal warrant system after firms supplying the monarchy were criticised for moving profits overseas. The crest is a mark of British craftsmanship and… – Continue reading

‘The best has yet to come in financial services sector’

Outgoing Deloitte Malta chairman and senior partner Andrew Manduca speaks to Anthony Manduca about the future of the financial services sector in Malta, his 36 years in the profession and the need for more accountants. Andrew Manduca is very confident about the future of Malta as a leading international financial… – Continue reading

How Microsoft moves profits offshore to cut its tax bill

Cash doesn’t flow directly from buyers’ pockets to Microsoft’s headquarters in Redmond, Wash. Instead, the company operates through three regional sales units, centered in Ireland, Singapore and Puerto Rico. These groups control the rights to profit from Microsoft products around the world. By conducting sales from places with small populations… – Continue reading

Globalisation and regulation driving industry growth

The asset servicing industry is likely to see a growth spurt driven by globalisation and regulatory change, according to an Ernst & Young (EY) report, reports the Asset Servicing Times. The report outlined six key drivers of growth: asset growth and breadth; globalisation; regulation; new products; platform extension and consolidation;… – Continue reading

Isle of Man to be removed from Spain’s ‘tax haven blacklist’

The Isle of Man has signed a tax information exchange agreement with Spain, reports the Isle of Man Today. It’s part of what the Manx government calls its ‘continuing commitment to meet international standards in tax co-operation and transparency’. The agreement was signed by Mr José Manuel Gutiérrez Delgado, Financial… – Continue reading

TAXE: Have We Taken the Right Path To Ensure Fairer and More Efficient Taxation in the European Union?

After the LuxLeaks affair in November 2014, the European Parliament established a special committee “on tax rulings and other measures similar in nature or effect” (TAXE) in February 2015. The committee’s report was adopted in a plenary session of the European Parliament on 25 November 2015. The Conference of Presidents… – Continue reading