Category: Europe

What is America’s real objective with FATCA?

Many US citizens resident in Jamaica are unaware of the tax compliance requirements of FATCA. Notwithstanding, this article is not about providing full information or professional advice about FATCA. That information can be obtained in a variety of ways. This article is about informing those who do not yet know… – Continue reading

Ministry of Finance issues guidelines for Financial Institutions with US and UK Clients

Providenciales, 08 Dec 2015 – Since December of 2014, the Turks and Caicos signed an Intergovernmental agreement or IGA so that the laws of the US FATCA or Foreign Accounts Tax Compliance Act and the UK equivalent could have force in these islands. Last month, the Ministry of Finance issued… – Continue reading

During the exchange of information, against the tax amnesty

Banking secrecy no longer protects foreign clients: Council of States approved the transition to the automatic exchange of information. At the same time, he rejected the idea of a tax amnesty. Rejection of the tax amnesty was the main surprise of the discussion of the Government’s project to move to… – Continue reading

Israel and Niue become the 91st and 92nd jurisdiction to sign OECD’s Convention on Tax Assistance Among Countries

In Paris on the occasion of the COP21, the Honourable Billy Graham Talagi, Minister for Ministry of Natural Resources of Niue signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters in the presence of Deputy Secretary General Rintaro Tamaki. Previously, Israel signed the Multilateral Convention on Mutual Administrative… – Continue reading

Cross-border tax rulings – Transparency rules adopted

On 8 December 2015, the Council adopted a directive aimed at improving transparency on tax rulings given by member states to companies in specific cases about how taxation will be dealt with. The directive is one of a number of initiatives aimed at preventing corporate tax avoidance. It will require… – Continue reading

Bermuda Welcomes Compromise On BO Registers

Following persistent demands from the United Kingdom that its Offshore Territories include beneficial ownership information on public central registers, it was agreed at the Overseas Territories Joint Ministerial Council (JMC) that “similarly effective systems” are a permissible alternative. A joint statement after the JMC meeting said: “We agreed to hold… – Continue reading

Beps impact on Ireland? So far, so good

Global corporation tax reform proving good for country As things stand, it would appear that matters are going Ireland’s way insofar as global corporation tax reform is concerned. The country-by-country reporting rules that have been proposed under the OECD’s Beps programme, and that commentators had been focused on in relation… – Continue reading

Illicit money flow from developing world surged to $1.1 tn in 2013, says GFI

WASHINGTON Illicit financial flows or black money from developing and emerging economies surged to US$1.1 trillion or a staggering 4 percent of the developing world’s GDP in 2013, according to a study released Wednesday by Global Financial Integrity (GFI), a Washington, DC-based research and advisory organization. The cumulative illicit outflows… – Continue reading

Removing the obligation to declare payments made by companies to individuals established in Cyprus, Luxembourg and Seychelles.

On October 30, 2015, the Global Forum on Transparency and Exchange of Information for Tax Purposes decided that Cyprus, Luxembourg and Seychelles have actually and substantially implemented the international standard on transparency and exchange of tax information. Therefore, companies no longer have the obligation to declare payments made to persons… – Continue reading

EU adopts new transparency rules

The EU Council has adopted a new transparency directive aimed at preventing corporate tax avoidance The directive, which was proposed by the European Commission (EC), is aimed at improving transparency on tax rulings given by member states to companies about how their taxes are calculated. Under the new directive, member… – Continue reading

US Justice Department Announces Aargauische Kantonalbank Reaches Resolution Under Swiss Bank Program

The Department of Justice announced today that Aargauische Kantonalbank (AKB) reached a resolution under the department’s Swiss Bank Program. The Swiss Bank Program, which was announced on Aug. 29, 2013, provides a path for Swiss banks to resolve potential criminal liabilities in the United States. Swiss banks eligible to enter… – Continue reading

Fighting tax evasion: EU and the Republic of San Marino sign new tax transparency agreement

The new agreement marks the end of bank secrecy between San Marino and the EU. As of 2017, San Marino and EU Member States will automatically exchange information on the financial accounts of one another’s residents. Pierre Moscovici, Commissioner for Economic and Financial Affairs, Taxation and Customs, said: “This agreement… – Continue reading

Corporate taxation proposals: Malta ‘breaks silence on reservations’

Finance Minister Edward Scicluna pushes for ‘flexibility’ during today’s meeting of EU finance ministers in Brussels Malta has come out strongly against applying “rigid rules”, urging the European Commission to adopt a more flexible approach as it drafts legislation on taxation. Corporate tax was high on the agenda of EU… – Continue reading

Finance meeting to be dominated by corporate tax

Ministers due to adopt conclusions on future of EU’s code of conduct on business taxation Corporate tax will top today’s meeting of EU finance ministers in Brussels, as ministers discuss the latest state of play regarding the common consolidated corporate tax base (CCCTB) and cross-border tax rulings. In particular, finance… – Continue reading

Dividend tax raid: what can expats do?

With a new tax on company dividends coming into force from April 2016, a financial planner explains how Britons overseas will be affected, and what steps they should take Investors who receive more than £5,000 from company dividends held outside tax-efficient plans such as Isas will pay more tax from… – Continue reading

IRS continues focus on corporate inversions

The Internal Revenue Service (IRS) continues its focus on perceived abuses in corporate inversion transactions. On November 19, the IRS released Notice 2015-79, which places new limitations on the ability of a U.S. multinational corporation to reduce its U.S. tax burden by inverting its corporate structure. U.S.-based multinationals are subject… – Continue reading

Why are Tax Inversion” Relocations Accelerating?

Tax inversions — the process of U.S. firms, merging with or buying foreign companies to shift their taxpaying headquarters abroad — have deprived the U.S. Treasury of ever-increasing billions of dollars. Although President Barack Obama promised to take punitive action against companies deliberately engaging in mergers and/or acquisitions for tax… – Continue reading

Government to Review Requiring Taxpayers to Report Tax Consulting

The government will look into compelling taxpayers to report to authorities if they receive consulting to reduce their tax obligations. The Ministry of Strategy and Finance said Sunday that it will review the measure as a follow-up to the Base Erosion and Profit Shifting program approved at last month’s Group… – Continue reading

Malta: The Tax Challenges Of The Digital Economy – Article 2

Main principles of direct taxation – Domestic Tax Rules In our second 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

Cyprus: Tax Incentives For Expatriate And High Net Worth Individuals Relocating To Cyprus (In Russian)

INTRODUCTION In the context of changes in the international system of taxation of the company in the choice of jurisdiction for the implementation of operational activities closely fit to the question of economic feasibility, to protect their interests. The strategic location of Cyprus, the presence of the country’s full membership… – Continue reading

HMRC changes view on the company residence tie-breakers in certain double tax agreements

HMRC has reached an agreement with Jersey concerning the interpretation of the company residence tie-breaker in the Jersey-UK 1952 double tax agreement. This change also affects the interpretation of 15 other double tax agreements (DTAs) which have identical or very similarly worded company residence tie-breakers. The issue concerns dual residents… – Continue reading

Top UK cricketers caught up in film scheme losses

Several former England cricket captains have been caught up investing in disputed film schemes that have also seen many high-profile footballers lose millions. The Sunday Times reported over the weekend that it had seen documents showing that Michael Vaughan, Andrew Flintoff and Marcus Trescothick were among the cricketers who had… – Continue reading

Canadians with Swiss bank accounts have until December 31, 2015 to file a voluntary disclosure

The United States came down hard on Swiss banks after receiving, from various whistleblowers, Swiss bank data evidencing U.S. citizens had hidden fortunes in Swiss accounts. Swiss banks were fined billions for assisting U.S. citizens in evading taxes and now want to avoid repetition of this scenario when the exchange… – Continue reading

Tata Steel to refinance $1.5bn offshore debt

Tata Steel’s Singapore arm T S Global Holdings Pte raised $1.5 billion debt to settle outstanding loans, the company said in a statement. Tata Steel group executive director-finance and corporate Kaushik Chatterjee said, “Tata Steel actively reviews all its financing options and seeks to continuously optimise its debt based on… – Continue reading

Yanukovych-era digital TV monopoly fined for abuses

A digital TV monopoly left over from the era of ex-President Viktor Yanukovych has caught the eye of anti-trust authorities and lawmakers. The Antimonopoly Committee of Ukraine on Dec. 4 fined Zeonbud, the nation’s monopoly digital TV provider, Hr 44 million (less than $2 million) for abusing its position on… – Continue reading

What CFOs Need to Know About BEPS

The Base Erosion and Profit Shifting (BEPS) project is an initiative being pursued by the Organization of Economic Cooperation and Development (OECD) to curtail perceived exploitation of international tax rules and loopholes by multinational enterprises (MNEs). The OECD’s BEPS project was initiated in 2013 at the request of the Group… – Continue reading

Bermuda accuses critics of ‘a lack of respect’ over transparency

Campaigners attack offshore centre for support of tax dodging, corruption and terrorist financing, reports the Financial Times. Bermuda has hit back against its critics, claiming that the financial centre is the victim of an “irresistible urge to stereotype” the British overseas territories. Bob Richards, finance minister, mounted a trenchant defence… – Continue reading

Noonan explains Ireland’s stance on CCCTB, code of conduct

Michael Noonan, Ireland’s Finance Minister, underlined Ireland’s position on key international tax issues that were scheduled for discussion at a meeting of the EU’s Economic and Financial Affairs Council (ECOFIN), reports Tax News. Noonan was addressing the Joint Committee on Finance, Public Expenditure, and Reform on December 1, 2015, in… – Continue reading

Call for UK clampdown on territories

An influential UK newspaper has called for Britain to force its Overseas Territories to create a public register of owners of companies. Chris Blackhurst, the group content director of a four-newspaper stable, writing in the London Evening Standard, said: “Only then, once we have put our own house in order,… – Continue reading

Clinton offers new ‘exit tax’ on U.S.-foreign company mergers

WASHINGTON — Hillary Clinton on Wednesday will unveil a proposal for a new “exit tax” aimed at cracking down on corporate inversions, a practice that permits U.S. companies to merge with corporations overseas to lower their tax bill. The new tax would be part of a broader effort to target… – Continue reading

The minister who dismantled Swiss banking secrecy

As the curtain falls on Eveline Widmer-Schlumpf’s career in government, one of the most abiding legacies she leaves behind is the collapse of Swiss banking secrecy under her watch as Finance Minister. Her predecessor, Hans-Rudolf Merz, told the world in 2008 that it would “break its teeth on Swiss banking… – Continue reading

Terrorist threat will force countries to tear up EU budget laws

Pierre Gramegna says “challenging and long lasting” impact of the terrorist and refugee crises means countries have “no choice” but to ramp up spending Terrorist attacks are the biggest threat facing the European Union and countries have “no choice” but to tear up budget rules and ramp-up spending in order… – Continue reading

More than 50 banks which helped American clients dodge tax in Swiss bank accounts receive immunity from criminal prosecution in US

More than 50 banks which helped American clients dodge tax in Swiss bank accounts have received immunity from criminal prosecution in the US. The firms, which include UK giant Standard Chartered, Germany’s biggest lender Deutsche Bank, and France’s BNP Paribas, have reached plea bargains with the US Department of Justice…. – Continue reading

Cadbury owner paid no UK corporation tax last year

Mondelez was able to pay no UK corporation tax as a result of a Channel Islands-based bond, despite Cadbury making £96.5m profit in 2014 Mondelez, which owns Cadbury, is facing controversy over its tax arrangements after it was reported that it had not paid UK corporation tax last year. An… – Continue reading

Private sector opposes retroactive tax measure

THE Private Sector Organisation of Jamaica (PSOJ) is not happy with amendments to the Income Tax Act that will see the implementation of a transfer pricing regime retroactive to April 1 this year. The PSOJ, in a letter to Tax Administration Jamaica (TAJ) Commissioner General Ainsley Powell in September, had… – Continue reading

Google, Apple and Starbucks would face ‘laughable’ fines for tax dodging under new rules

£300 penalties would be dwarfed by millions in potential profits for firms that take advantage of tax-avoidance schemes Huge multinational companies that dodge millions of pounds in tax in the UK and around the world face “laughable” fines of £300 under new rules proposed by HM Revenue and Customs. The… – Continue reading

Pfizer and Allergan chiefs say merger is good for America

Employees at Allergan have been told a proposed merger with Pfizer is about changing healthcare – not skirting tax law. Allergan’s global chief executive Brent Saunders has written directly to the company’s employees – including around 1,000 in Ireland, telling them the controversial deal is not just about tax savings…. – Continue reading

Luxembourg plots to steal London’s financial crown

The tiny nation wants to become “the European location of choice” for global financial services firms, and is already the biggest centre for fund management in the EU, reports the Telegraph. Luxembourg’s finance sector has set out plans to become Europe’s leading financial centre in the next five years, plotting… – Continue reading

Sunshine Islands Feel Heat Over Tax Avoidance

The British government is about to get tough with so-called tax havens that are dragging their feet on revealing the secret ownership of thousands of offshore companies. One of the main thrusts of Britain’s drive to clean up the murky world of tax avoidance has been to put pressure on… – Continue reading

Italy Issues Patent Box Guidance

On December 1, the Italian Revenue Agency issued a guide delineating how companies can take advantage of Italy’s “patent box,” together with a circular containing the answers to questions arising out of the new regime’s operation. With effect from the present 2015 fiscal year, the patent box offers an optional… – Continue reading

France-Luxembourg tax treaty change cannot come into force until 2017

France and Luxembourg failed to ratify a protocol changing the France-Luxembourg double tax treaty by 30 November, which means that a change which will affect real estate structures cannot come into force until 1 January 2017, at the earliest, for companies whose fiscal year is based on a calendar year…. – Continue reading

UK: Diverted profits tax guidanc

HM Revenue & Customs (HMRC) updated its diverted profits tax guidance to clarify the tax authority’s interpretation of the legislation and proposed administrative practice. Highlights Some highlights from the revised guidance include: Both the “insufficient economic substance condition” and the “design test” in section 86 FA 2015 (avoidance of UK… – Continue reading

Italy: Decree removes Hong Kong from certain “black lists”

Italy has removed Hong Kong from two of three “black lists.” A ministerial decree in November 2015 removed Hong Kong from the black lists that apply with respect to: The Italian controlled foreign corporation (CFC) rules and the full taxation of inbound dividends Costs that arise in transactions between Italian… – Continue reading