Category: Europe

Luxembourg: EC investigation of tax rulings, issued to US multinational

The European Commission today announced its decision to launch a “state aid” investigation into tax rulings granted by the tax authorities in Luxembourg to a company that is a member of a U.S.-based multinational taxpayer group. Background According to a February 2015 report, in 2008-2009, the group transferred its European… – Continue reading

Netherlands: CRS draft implementing decree

The Dutch Ministry of Finance published a draft decree for implementing the “common reporting standard” (CRS) and that includes the identification and reporting requirements contained in the CRS for reporting financial institutions. The CRS, developed by the OECD and largely based on FATCA, is a standard that governs the exchange… – Continue reading

Varga calls for joint EU crackdown on tax evasion

Hungary’s National Economy Minister Mihály Varga called on European Union members to assist in a joint crackdown on value added tax evasion, the minister said today at a conference in Prague, according to a report from the National Economy Ministry. Varga and Czech finance minister Andrej Babis, whose ministry organized… – Continue reading

Swiss bank to pay tax evasion penalty

Switzerland’s EFG Bank is to pay a penalty of $29m to the US Department of Justice to avoid prosecution for helping its American account holders evade taxes. The bank came forward as part of a voluntary programme launched in 2013, which allows Swiss banks to admit their potential role in… – Continue reading

Corporate tax revenues falling- OECD

Corporate tax revenues have been falling across OECD countries since the global economic crisis, putting greater pressure on individual taxpayers to ensure that governments meet financing requirements, according to new data from the OECD’s annual Revenue Statistics publication. Average revenues from corporate incomes and gains fell from 3.6% to 2.8%… – Continue reading

Closing offshore subsidiaries boosts corporation tax

Developments driven by Base Erosion and Profit Shifting (Beps) boost Irish tax The closing down by Irish multinationals of tax planning arrangements involving offshore or foreign subsidiaries is part of the reason for Ireland’s increased corporation tax receipts, according to an informed source. Under country-by-country reporting rules, Irish companies with… – Continue reading

Local and regional leaders want a crackdown on corporate tax avoidance and call for common EU rules

At the plenary of the European Committee of the Regions (CoR) local and regional leaders called for a fair and efficient corporate tax system in the European Union. The opinion drafted by Jean-Luc Vanraes (BE/ALDE), member of Uccle Municipal Council, criticises the complexity of corporate taxation systems, which disadvantages small… – Continue reading

Luxembourg says to appeal against EU tax ruling on Fiat

The Luxembourg government said on Friday that it would appeal against the European Commission’s decision ordering it to recover 20-30 million euros ($22-33 million) of back taxes from Fiat Chrysler. The Commission ruled in October that Fiat had benefited from illegal tax deals with the Luxembourg authorities, as well as… – Continue reading

Local and regional leaders want a crackdown on corporate tax avoidance and call for common EU rules

At the plenary of the European Committee of the Regions (CoR) local and regional leaders called for a fair and efficient corporate tax system in the European Union. The opinion drafted by Jean-Luc Vanraes (BE/ALDE), member of Uccle Municipal Council, criticises the complexity of corporate taxation systems, which disadvantages small… – Continue reading

Free Webinar: BEPS could produce a “wild west” tax approach to captives

Tax authorities around the world could take a “cowboy” attitude towards captive tax rights when following guidance from the Base Erosion and Profit Shifting (BEPS) papers, according to Dr Pierre Olivier Gehriger, partner and certified tax expert at Pestalozzi Attorneys at Law. Speaking on a Captive Review webinar hosted by… – Continue reading

Isle of Man signs tax co-operation agreement with Spain

As part of the Isle of Man Government’s continuing commitment to meet international standards in tax co-operation and transparency, a Tax Information Exchange Agreement (TIEA) has been signed with Spain. The agreement was signed by Mr José Manuel Gutiérrez Delgado, Financial Counsellor of the Embassy of Spain to the UK,… – Continue reading

Alan Grayson said he closed Cayman Islands hedge funds, but records list as active

Democratic U.S. Senate candidate Alan Grayson said more than two months ago that he had closed down the Cayman Islands-based hedge funds that helped prompt ethics complaints against the populist congressman from Orlando. Grayson declined to provide documentation to the Tampa Bay Times when asked for it in early October,… – Continue reading

Is the Royal Dutch Shell and BG Group Deal Near Completion?

Bidness Etc takes a look at how Shell-BG merger is right on track, after receiving approval from Australia’s Foreign Investment Review Board Royal Dutch Shell plc (ADR) (NYSE:RDS.A) is just one step away from closing a merger deal with BG Group plc. On Thursday, December 3, the Anglo-Dutch company received… – Continue reading

MEPs seek corporation tax transparency

Members of the European Parliament’s (MEPs) economic and monetary affairs committee (EMAC) have asked the European Commission (EC) to table measures that would include corporation tax transparency, reports Economia. Recommendations were voted on by the EMAC on Tuesday and seek to build on work carried out by the European Parliament’s… – Continue reading

Beneficial ownership issue left open ended after JMC

(CNS) UPDATED: The Cayman Islands and other overseas territories have agreed to hold beneficial ownership information in their jurisdictions via “central registers or similarly effective systems”, according to the communique released by the FCO following this week’s meeting in London with territory leaders and the UK government. The agreement on… – Continue reading

Bulgarian Offshore Companies Act amendment seeks to ease restrictions

A newly introduced amendment to the Bulgarian Offshore Companies Act (the “Act”) will bring significant changes to investment opportunities for offshore companies. If the Bulgarian Parliament adopts the amendment within the next month, the amended Act is expected to enter into force in the beginning of 2016. The proposed amendments… – Continue reading

Mystery surrounding sources of corporate tax bounty which has hit €6.3bn

Corporate taxes continued to flood into the exchequer’s coffers last month, compounding a mystery about their source and raising doubts about whether a future government can rely on the company receipts after the election. The Revenue Commissioners and the Department of Finance have moved in recent weeks to dampen down… – Continue reading

COP21: Climate change activists protest outside Paris bank over tax evasion

Dozens of climate change activists gathered outside of the headquarters of BNP Paribas in Paris on 3 December to protest against dirty climate dealings and tax evasion. The rally, organised by anti-globalisation group Attac, coincided with the UN Climate Change Conference taking place just north of Paris in Le Bourget,… – Continue reading

Guernsey: Guernsey Issues Regulations To Implement Common Reporting Standard

On 23 November 2015 Guernsey issued regulations to implement the Common Reporting Standard (“CRS”) under Guernsey’s domestic law. The regulations follow on from the commitment made on 29 October 2014 by Guernsey, along with the other Crown Dependencies and a number of other jurisdictions, to start exchanging information under the… – Continue reading

The Real Cost Of Global Tax Reform: An Unsustainable Increase In Accounting And Legal Fees

Leaders from the Group of 20 largest economies (G20) met in Turkey last month to put their final stamp of approval on a major overhaul of the international rules governing corporate taxes. The vote was the icing on a cake that the Organization for Economic Cooperation and Development (OECD) has… – Continue reading

Wilderness Safaris secretly stashing millions in tax havens?

A lengthy and yet complex investigation by The Botswana Gazette into financial affairs of the company in the shady tax haven of Bermuda blows the lid off the dealings amounting to P29 million with a mailbox sister company that has no office, employees or any legitimate business activities. Not only… – Continue reading

Premier: critics show ‘a lack of respect’

Michael Dunkley has hit back at calls for Bermuda to make its beneficial ownership information public, claiming that critics are “attempting to solve a problem that does not exist”. After three days of meetings in London, the British Overseas Territories agreed to put information on the people who ultimately own… – Continue reading

Change in UK Treatment of Dual-Resident Companies May Affect U.S. Tax Planning

On November 30, 2015, the UK tax authorities at HM Revenue and Customs (HMRC) reached an agreement with Jersey about the interpretation of the company residence tie-breaker provision of the Jersey-UK income tax treaty. After reviewing other income tax treaties that contain similar provisions, HMRC will now take the view… – Continue reading

Chris Blackhurst: Britain’s island tax havens need action

Amid all the diplomatic comings and goings on Syria and how to tackle Islamic State, an important but little-noticed high-level gathering has been taking place in London. The Overseas Territories were holding the fourth meeting of their Joint Ministerial Council at Lancaster House. Leaders from Anguilla, Bermuda, British Virgin Islands,… – Continue reading

Offshore Industry Tipped for Growth, Driven by Demand from Emerging Markets, According to OIL Offshore 2020 Report

HONG KONG, Dec. 2, 2015 /PRNewswire — Demand for asset protection, wealth planning and funds by high net worth individuals in Asian countries will drive continued growth in the offshore industry, according to OIL’s sixth “Offshore 2020” annual market research study. OIL, the leader in international incorporations and corporate services… – Continue reading

Automatic exchange of information obligation to identify and report the tax residence of the holders of financial accounts

Royal Decree 1021/2015, of November 13, establishing the obligation to identify the tax residence of persons who hold or control certain financial accounts and to provide information concerning them in the area of mutual assistance. On November 17 last the above-mentioned Royal Decree was published in the Official State Gazette…. – Continue reading

Bramwell’s Lunch Beat: ‘Cadillac Tax,’ Tax Extenders, BEPS Hearings

Lawmakers seek late deal to scale back ‘Cadillac tax’ Lawmakers are making a late push to repeal or scale back Obamacare’s “Cadillac tax” by the end of the year, eying inclusion of changes in a broader tax package, wrote Peter Sullivan of The Hill. But lawmakers in both parties say… – Continue reading

McDonald’s Investigated for European Tax Evasion

The U.S. multinational will likely be investigated for evading taxes with Luxembourg’s help, following a report by trade unions earlier this year. McDonald’s is under investigation by European Union regulators for illegal tax deals with Luxembourg, according to sources close to the inquiry. The multinational—joining a list of EU tax… – Continue reading

Consultation on changes to the deductibility of interest for companies

The Government has recently launched a consultation on amending the UK’s interest deductibility rules for companies. The consultation follows the OECD’s recommendations as part of the Base Erosion and Profit Shifting (BEPS) project. In line with those recommendations, it is proposed that a company’s net interest deductions be limited to… – Continue reading

Press release – Ending EU citizens’ bank secrecy in Liechtenstein

An EU deal with Liechtenstein, which will make it harder for EU citizens to hide cash from the tax man in bank accounts there, was endorsed by Parliament in a vote on Wednesday. Under the deal, the EU and Liechtenstein will automatically exchange information on the bank accounts of each… – Continue reading

GOVT TO PAY OUTSTANDING $300M TO PTA BANK

By SYLVESTER MWALE – THE Government has resolved to liquidate the outstanding US$300 million owed to Eastern and Southern African Trade and Development (PTA) Bank accumulated through petroleum importation. The arrears would be dismantled in four installments within a period of one year. Chief Government Spokesperson Chishimba Kambwili said in… – Continue reading

Senate vote lays groundwork to end banking secrecy

Swiss Senate has sealed the end of banking secrecy for foreign clients, following the House of Representatives in accepting the legal groundwork for the automatic exchange of information. The decision paves the way for a “decorous funeral for tax secrecy,” as senator Roberto Zanetti of the leftwing Social Democrats put… – Continue reading

FATCA List – December 1, 2015

The US Internal Revenue Service (IRS) reports no new registrations under Foreign Account Tax Compliance Act (FATCA) rules in November. The list stays at 177,147 institutions in 226 financial jurisdictions. The list details which overseas financial institutions have agreed to pass personal and financial information about accounts and investments controlled… – Continue reading

MEPs Task EC To Table Corporate Tax Measures

Members of the European Parliament have tasked the EU Commission to table measures to improve corporate tax transparency, coordination, and EU-wide policy convergence, in legislative recommendations passed by the Economic and Monetary Affairs Committee on December 1, 2015. The recommendations build on the work of EU Parliament’s Special Committee on… – Continue reading

GOP Pushes For International Reform In Wake Of Big Pharma Tax Flight To The UK

Republicans in both chambers of Congress said international tax reform is necessary to retain companies in the United States following pharmaceutical giant Pfizer’s announcement it is moving its headquarters overseas after its merger with Ireland-based Allergan, citing the country’s high corporate tax rates. During hearings in the House Ways and… – Continue reading

UK government amends view on DTA residence articles

UK tax authority HM Revenue and Customs (HMRC) has announced a change of view on the interpretation of the company residence articles in 16 double taxation agreements (DTAs), reports Tax News. The change was prompted by an agreement with Jersey on the interpretation of the company residence tie-breaker article in… – Continue reading

Malta: AEoI In Tax Matters – The CRS

AUTOMATIC EXCHANGE OF INFORMATION IN TAX MATTERS – THE COMMON REPORTING STANDARD Introduction The Common Reporting Standard (CRS) is a tool which facilitates the automatic exchange of information at a global level. The fight against tax evasion in cross border transactions has become a priority for Government around the globe…. – Continue reading

The foreign investment tax advisers should pay attention to

Taxes levied on foreign stock dividends can be recouped, but it makes most sense for high-net-worth clients with multimillion-dollar positions Advisers could be missing out on a way to maximize returns on their clients’ foreign investments. Americans investing in non-U.S. stocks could be earning less of a return than they’d… – Continue reading

Panton seeks Cayman’s removal from non-cooperative tax list

As the Joint Ministerial Council meeting continues in London this week Financial Services Minister Hon Wayne Panton says he intends to meet with European States in a bid to have Cayman removed from their lists of third-country, Non-cooperative Tax Jurisdictions. The minister, speaking at the last sitting of the Legislative… – Continue reading

Luxembourg finance minister attacks EU on business tax uncertainty

The European Commission’s use of state aid rules to challenge corporate tax agreements is causing uncertainly for businesses in Europe, Luxembourg finance minister Pierre Gramegna has said. Gramegna told the Financial Times this week that the situation “raises so many issues about predictability and certainty”. The Commission announced in October… – Continue reading

The foreign investment tax advisers should pay attention to

Taxes levied on foreign stock dividends can be recouped, but it makes most sense for high-net-worth clients with multimillion-dollar positions Advisers could be missing out on a way to maximize returns on their clients’ foreign investments. Americans investing in non-U.S. stocks could be earning less of a return than they’d… – Continue reading

Miscalculate tax on a holiday home or inheritance? You could soon be branded a criminal

Holiday home owners and others who inadvertantly break new tax rules could be ‘criminalised’ Holiday home owners who miscalculate tax owed, and those inheriting offshore money, face having their income wiped out entirely due to new penalties and punishments being introduced in the New Year. HM Revenue & Customs has… – Continue reading