Category: Europe

Cities and regions express their views on the sharing economy, the Trade in Services Agreement and a fair corporate tax system

On 29 September, the Commission for Economic Policy (ECON) of the EU Committee of the Regions (CoR) held an external meeting in Gelsenkirchen, Germany, at the invitation of Markus Töns (DE/PES), member of the North Rhine-Westphalia Regional Parliament. On the agenda was the adoption of the draft opinions on the… – Continue reading

‘Mistrust’ hampering continental trade

Pretoria – Trade between African countries remains low, despite efforts to harmonise taxation to allow for the free movement of goods and services. Tax experts this week warned mistrust between countries remains the greatest detractor to achieve harmony and increase intra-trade. Intra-Africa trade was only 11.3 percent of the continent’s… – Continue reading

Sunlight is the best way to disinfect corporate tax havens

Tax havens are by design secretive and opaque. The entire point of their existence is to conceal the wealth hidden within them. And a new book by Gabriel Zucman, The Hidden Wealth of Nations: The Scourge of Tax Havens, reveals, as never before, the extent of their role in the… – Continue reading

US$7.6tn hidden in tax havens – almost half annual US GDP

Gabriel Zucman, one of 3 French economists who in recent times have published extensive research on wealth and equality, in a book, ‘The Hidden Wealth of Nations: The Scourge of Tax Havens,’ published this month, estimates that 8% of the world’s financial wealth — some US$7.6tn — is hidden in… – Continue reading

OECD says Ireland to benefit post-BEPS

The OECD has said that its base erosion and profit shifting (BEPS) project will create policy challenges for Ireland, but the nation should emerge well placed to attract foreign direct investment, reports Tax News. The report states: “Given the strong presence of intellectual property-intensive information technology and pharmaceutical companies in… – Continue reading

“Delaware LLCs and UK Entity Classification: The Fallout From the Curious Case of George Anson”

Fundamental to any developed tax policy is knowing who the taxpayer is (or should be) with respect to any particular transaction. Although that can be relatively straightforward in purely domestic situations, a cross-border dimension can present different answers to this question in the jurisdictions involved and lead to issues over… – Continue reading

Big business avoids tax, yet wants to lower rate

One in five corporations with annual profits greater than $100 million paid no tax last year, the Australian Tax Office has revealed. Michael Cranston, one of the ATO’s deputy commissioners, revealed the figure to a Senate hearing into corporate tax avoidance. Corporations avoid paying tax by what is euphemistically called… – Continue reading

Netherlands seek Swiss help on Dutch accounts in Swiss banks

The Netherlands have requested information on a large number of Swiss bank accounts held by residents of its country in connection with a tax probe, Swiss authorities confirmed at the weekend, reports the Swiss Local. Swiss tax authorities received a request from their Dutch counterparts in July for access to… – Continue reading

Crunchtime for OECD global tax-avoidance push

Efforts to amend details of new rules on corporate profits raise questions, reports the Wall Street Journal. Nearly 50 governments are set to agree this fall to a new set of rules to clamp down on tax avoidance among multinational corporations. Their chance of success, however, is unclear. If the… – Continue reading

Barcelona’s Javier Mascherano charged with tax fraud in Spain

ESPN FC’s Fernando Palomo previews the upcoming UCL action, highlighting that Barcelona will have to learn to play without Messi. Also Mou faces his old Club, while Bayern may be playing at their best. Barcelona star Javier Mascherano was charged with two counts of defrauding the Spanish tax authorities of… – Continue reading

International Tax Reform May Still Be a Possibility; Treasury Focused on FATCA, PTPs

Tax Reform Still in Ryan’s Sights Despite Boehner’s Departure Last week, following the sudden announcement by House Speaker John Boehner (R-OH) that he would be stepping down from Congress at the end of October, House Ways and Means Committee Chairman Paul Ryan (R-WI) and various other Committee members quickly confirmed… – Continue reading

Shadow chancellor announces radical idea of making big businesses ‘pay their fair share of tax’

Jeremy Corbyn’s shadow chancellor has caused a stir with his idea that big businesses should pay their taxes. Speaking at the Labour Party conference in Brighton, John McDonnell named and shamed big companies over their tax arrangements. ‘Labour’s plan to balance the books will be aggressive,’ he said. ‘We will… – Continue reading

Swiss join IFC to promote EAC corporate transparency

NAIROBI, Kenya – The World Bank’s private arm, the International Finance Corporation (IFC) has jointly launched a business transparency initiative with the Swiss government, to promote corporate leadership in East Africa with the aim of helping firms attract foreign investments. The aim of the new initiative is to help firms… – Continue reading

Tax Havens Are Turning The U.S. Into An Unequal Aristocracy

French economist Gabriel Zucman, a protégé of Thomas Piketty, has a new book outlining how to avoid this. To Gabriel Zucman, protégé of rock star French economist Thomas Piketty, the United States is starting to look a lot like Europe in the late 1800s. “There’s been this great reversal where,… – Continue reading

US Justice Department Announces Two Banks Reach Resolutions Under Swiss Bank Program

The Department of Justice announced today that Migros Bank AG (Migros) and Graubündner Kantonalbank (Graubündner) have reached resolutions under the department’s Swiss Bank Program. These banks will collectively pay penalties totaling more than $18 million. “It is abundantly clear from the agreements reached to date that for decades, many foreign… – Continue reading

HMRC approach to double taxation relief and US companies mostly unchanged after Supreme Court decision

The UK’s tax treatment of US limited liability companies (LLCs) will remain mostly unchanged despite a recent Supreme Court decision in favour of the taxpayer, HM Revenue and Customs (HMRC) has confirmed.25 Sep 2015 HMRC said that the decision of the UK’s highest court in favour of George Anson, a… – Continue reading

The Rollout of FATCA Is Being Delayed to Help Foreign Banks. Tax Attorney Rob Wood Explains

The Foreign Account Tax Compliance Act, passed in 2010, is a tool devised to help the U.S. locate funds of U.S. citizens being held in foreign banks. (See this earlier FATCA report on LBN). The law requires foreign banks to report data about accounts owned by U.S. citizens to the… – Continue reading

Uber has revolutionised transport in Australia. But will taxpayers get anything in return?

ATO to force Uber drivers to pay GST Uber is to mount a legal challenge against the Australian Tax Office after a decision to force drivers to register and pay GST. Prime Minister Malcolm Turnbull has praised ride-sharing company Uber as part of the “agile” economy he envisages for Australia…. – Continue reading

Silver Wheaton faces potential C$353m CRA tax bill for offshore revenue

TORONTO (miningweekly.com) – The world’s largest precious metals streaming firm Silver Wheaton is set to challenge the Canadian Revenue Agency (CRA) over the agency’s decision to reassess the company’s 2005 to 2010 tax years and collect taxes on income earned by Silver Wheaton’s offshore subsidiaries. The TSX– and NYSE-listed company,… – Continue reading

Two more Swiss banks strike deals with U.S. over tax evasion

Two more Swiss banks will pay fines to the United States as part of settlements that mean they will not face criminal charges for helping Americans avoid taxes, U.S authorities said on Friday. Migros Bank AG will pay approximately $15 million and Graubündner Kantonalbank will pay $3.6 million, the U.S…. – Continue reading

US Signs Competent Authority Agreements With UK, Australia

The Internal Revenue Service has entered into landmark Competent Authority Agreements with authorities in Australia and the United Kingdom to support the implementation of the Foreign Account Tax Compliance Act (FATCA). The US has signed FATCA intergovernmental agreements with both of these nations. Each of these agreements provides that Competent… – Continue reading

The Common Reporting Standard: Automatic Information Exchange Goes Global

Automatic exchange of information for tax law enforcement purposes started first in Europe with the EU Savings Tax Directive, went international with the US Foreign Accounts Tax Compliance Act, and, from 2017, will go global with the recently-agreed Common Reporting Standard, the subject of this feature. Introduction To The Common… – Continue reading

Mauritius appoints minister for financial services

When Delta, a South Africa-based property investment fund, decided to switch the offshore domicile of its international operations from Bermuda to Mauritius a year ago, it gained unexpected benefits, reports the Financial Times. “We’ve been very pleased,” says Bronwyn Corbett, head of Delta, as she reflects on the success of… – Continue reading

Common Reporting Standard

On 20 October 2014 Ireland along with 50 other countries signed a multilateral competent authority agreement to automatically exchange certain information between tax authorities of signatory jurisdictions. The Common Reporting Standard (CRS) involves the collection of information in relation to financial accounts from financial institutions and the annual transmission of… – Continue reading

Treatment of companies managed outside Jersey

Tax residency of Jersey companies Jersey companies may (contrary to the default position) be treated as exclusively tax resident in jurisdictions other than Jersey pursuant to Article 123(1)(a) of the Income Tax (Jersey) Law 1961. The criteria for a Jersey incorporated company to be resident (for taxation purposes) in a… – Continue reading

More tax laws planned

Myanmar plans to introduce more laws and regulations to increase its tax income over the coming years, sources said. The Internal Revenue Department (IRD) currently sets polices under the Myanmar Tax Law and the Union Tax Law. Sources at the IRD said they will issue further notifications, if required, to… – Continue reading

Watch: Tax competition compensates disadvantaged EU small states – Alfred Sant

The Head of the Maltese Labour Delegation at the European Parliament, Alfred Sant, said that tax competition is needed by peripheral and island states unless there is compensatory mechanism to compensate them for the fact that they don’t have the endowments that other countries have. “Where competitive disadvantages exist, these… – Continue reading

Common Rules (Not Rates) Should Be The Answer To Tax Competition In The EU

Tax avoidance is a key problem for European countries, with the EU taking several steps to try and limit the ability of businesses to shift their profits to low-tax jurisdictions. Peter Dietsch writes on the nature of the problem and what can be done to tackle it. He argues that… – Continue reading

Andorra, Italy Sign Exchange Of Information Agreement

Andorra’s Ambassador to Spain, Jaume Gaytan, and the Ambassador of the Italian Republic in Andorra, Pietro Sebastiani, last week signed an agreement on the exchange of information on tax matters. Gaytan and Sebastiani noted that the tax information exchange agreement (TIEA) between the two territories builds upon existing strong bilateral… – Continue reading

Isle of Man signs Tax Information Exchange Agreement with the Cayman Islands

The Isle of Man has continued its programme of developing closer economic and taxation co-operation with other countries by concluding a Tax Information Exchange Agreement (TIEA) with the Cayman Islands. This is the Isle of Man‘s 33rd TIEA. The agreement was signed by Hon. G. Wayne Panton MLA, the Cayman… – Continue reading

Corporate taxation system has reached its limits, say ministers and MEPs

Tax competition as such cannot be avoided, but today’s system has reached its limits and led to unwanted side effects. Small firms should not have to bear the tax burden of multinationals that pay very little. Action is needed to harmonise corporate tax practices across Europe, so as to make… – Continue reading

The framework for investment between Malta and Russia is excellent – Minister Cardona in Moscow

The Minister for the Economy, Investment and Small Business, Dr Chris Cardona attended Malta Day 2015 in Moscow coinciding with the 51st anniversary from Malta’s independence, during which a Maltese-Russian Business Forum was held. Minister Cardona spoke about the good relations Malta has held with Russia, which go back many… – Continue reading

Austria: Successful Appeal Regarding Taxation Of Foreign Interest Income

On 26 February 2015, the Austrian Supreme Administrative Court decided in favor of an appeal filed by WOLF THEISS for a client who received tax exempt interest income from other countries. An Austrian taxpayer received interest from Greek, Brazilian and Argentinian government bonds between 2003 and 2007. According to the… – Continue reading

Austria: Mutual Agreement Procedures – New Decree

On 31 March 2015, the Austrian Ministry of Finance published a decree dealing with, inter alia, mutual agreement procedures under double tax treaties. Currently, Austria has concluded 85 double tax treaties, all of which contain provisions on mutual agreement procedures (MAPs). However, Austrian statutory law does not provide for procedural… – Continue reading

MEPs: Make EU Corporate Tax System ‘Fairer’

Action is needed to harmonize corporate tax practices across Europe, according to the European Parliament’s Special Committee on Tax Rulings. The committee said this was the key sentiment voiced during a meeting with finance ministers from Luxembourg, Italy, France, Spain, and Germany on September 22. According to the committee, while… – Continue reading

Chief Minister rejects Washington DC’s tax haven slur

Chief Minister Allan Bell has written to the District of Columbia Council to outline his concerns at the island’s inclusion in a blacklist of tax havens. Washington DC released the list of 39 ‘tax havens’ as part of its Budget Support Act, which was signed by the Mayor in August…. – Continue reading

Austria: Tax Treatment Of Liechtenstein Foundations

In a recent decision the Austrian Supreme Administrative Court ruled on the tax treatment of Liechtenstein foundations for the second time within one month. In the case at hand the competent tax authority attributed investment income generated by a Liechtenstein foundation to the Austrian resident widow of the founder. According… – Continue reading