Category: Sweden
Sweden’s tax agency rejects Puma’s transfer pricing position, concludes risk borne elsewhere
The Swedish tax agency has adjusted the taxable income for the PUMA Group’s Swedish distributor, Puma Nordic AB, concluding that, for transfer pricing purposes, the Swedish distributor could not control the main risks in the Puma Group and therefore should not have carried the local market risks. The adjustment, made… – Continue reading
Swedbank hires EY to conduct forensics into money laundering
Swedbank, one of the largest banks in Sweden, has hired professionals services firm EY to investigate the bank’s possible involvement in large scale money laundering. According to media reports in Sweden, over the period of nearly ten years the bank facilitated approximately $5.8 billion worth of suspicious transactions. The transactions… – Continue reading
Is this the end of the road for the EU’s digital services tax?
Ireland, Sweden, Denmark and Germany block digital services tax plan in Brussels. The spectre of a 3pc digital services tax (DST) levied by the EU against multinationals has been vanquished for now after Ireland, Sweden, Denmark and Germany joined forces in what is being heralded as a coup for diplomacy…. – Continue reading
Sweden takes measures to tackle tax evasion, financial crimes
STOCKHOLM, Sept. 4 (Xinhua) — The Swedish government has proposed three new measurements to tackle aggressive tax planning, evasion and financial crimes, the Government Offices of Sweden said Tuesday. The proposals include increased international automatic information exchange, new possibilities for the Swedish Tax Agency to prevent financial crimes and tighter… – Continue reading
Seychelles Needs To Redouble BEPS Efforts: UN Expert
The Seychelles has been told to deploy more resources to implement recommendations from the OECD on base erosion and profit shifting. Ingela Willfors, a United Nations tax expert from the Swedish Ministry of Finance, held discussions on implementation with the Seychelles’ Minister of Finance, Trade, and Economic Planning and in… – Continue reading
Sweden Clarifies CbC Reporting Threshold Rules
The Swedish tax authority (Skatteverket), has published guidance on companies’ country-by-country reporting obligations with respect to short and extended tax years, and company divestments and restructurings. Under Sweden’s Tax Procedures Act, a group is not obligated to submit a CbC report if, according to its consolidated accounts, it has a… – Continue reading
Swedish retirees are flocking to Portugal to avoid taxes – but they could soon end up like their Danish and Finnish peers
In recent years, Portugal has become a popular low-tax haven for Swedish retirees. Since 2009, almost 2300 Swedes, most of them senior citizens, have swapped dark winters for the Mediterranean sun, and moved to Portugal either part- or full-time. Doing so, they have been able to avoid paying taxes to… – Continue reading
Sweden Considers New Reporting Obligation for Tax Advisers
A parliamentary commission will consider the introduction of a new legal obligation for tax advisers to disclose information about advice on tax mitigation to the Swedish Tax Agency, Skatteverket. Under the proposed rules, tax attorneys would be required to provide details of which clients have received advice on tax reduction… – Continue reading
BEPS from an IP perspective, Part 2
Part 2: Transfer Pricing documentation requirements From 1 April 2017, BEPS action 13 guidelines on transfer pricing (TP) documentation will be effective in Sweden. Action 13 is an effort to make MNEs global financial situation more transparent. It is a three-tiered based approach including a master file, local files and… – Continue reading
OECD Recommends Swedish Property Tax Reform
The OECD has recommended that Sweden rebalance its property tax system. In its latest Economic Survey for the country, the OECD said that Sweden’s favorable tax treatment of owner-occupied housing is regressive, benefiting relatively high-income households most and contributing to the high demand for housing. It said it also encourages… – Continue reading
German, Swedish Banks Back Tougher Beneficial Owner Rules
German banks support stricter beneficial ownership rules for companies and trusts, while the leading Scandinavian bank backed an offshore corporate economic substance test to help comply with EU laws against money laundering and tax evasion. Testifying before the European Parliament’s Panama Papers investigative committee, the Association of German Banks told… – Continue reading
Swedish Bank Merger Rules Aim to Limit Risk of Tax Imbalance
A plan by Nordea Bank AB to merge with subsidiaries in Denmark, Finland and Norway has prompted Sweden to revise its laws to minimize the risk of a tax imbalance when a foreign company’s shares and other financial instruments are merged with those of domestic company. Effective Jan. 1, the… – Continue reading
Finland allowed to tax pensioners in Portugal
Following pressure from the Finnish government and public opinion in the Scandinavian country, Helsinki has announced a deal which will allow it to come after expat pensioners, who are residing in Portugal, for income tax payments from which they were previously exempt. Other EU states have also expressed their aversion… – Continue reading
Armenia eliminates double taxation of property and income with Serbia and Slovakia
The Armenian Parliament has ratified today two agreements to avoid double taxation and prevent tax evasion with respect to taxes on property and income with Serbia and Slovakia. According to Deputy Minister of Finance Armen Hayrapetyan, the document on the mutual avoidance of double taxation on property and income with… – Continue reading
Ireland braced for new EU corporate tax plan
A new EU corporate tax proposal could fundamentally change how multinationals pay their tax bills in Ireland. It comes at a sensitive time for the State, following so closely after the commission ruled phone giant Apple tapped illegal tax breaks worth around €13bn. In proposals to be unveiled tomorrow, the… – Continue reading
Nordea blocks 68 accounts in Panama Papers investigation
Nordea has blocked 68 accounts for further analysis after finding suspicious signs in an internal investigation of the bank’s handling of the Panama Papers leaks. The bank announced some of the findings of the probe into whether it adhered to internal rules and external regulations regarding offshore structures at the… – Continue reading
After Mauritius, now government wants to amend Dutch tax treaty; asks Netherlands to resume talks
India has asked the Netherlands to resume negotiations on amending their bilateral tax treaty as the government extends its efforts to plug loopholes in such accords to curb misuse. The Dutch tax treaty , which allows exemption from capital gains and a lower rate of tax on dividends, has led… – Continue reading
Beyond FATCA, Costa Rica Adopts “GATCA” Tax Reporting Measures
The unpopular Foreign Account Tax Compliance Act (FATCA) of the United States has set off a rash of similar legislation around the world, and Costa Rica has been eager to adopt these international asset reporting treaties, which many taxpayers consider overreaching and in violation of financial privacy. The Costa Rica… – Continue reading
Sweden Issues Tax Avoidance Action Plan
Sweden will appoint an inquiry to study whether tax advisers should be required to inform the Swedish Tax Agency about tax planning schemes as part of an action plan to combat tax avoidance, which also urges companies to maintain their own tax policies at board level. According to the Government,… – Continue reading
David Cameron’s finances touched a nerve – tax openness is the answer
Nearly half of people say the Prime Minister’s handling of his finances was ‘morally repugnant’, according to our opinion poll, and they support public tax returns for all As the fallout from the fallout from the Panama Papers leak begins to settle, the Prime Minister is left contemplating the damage… – Continue reading
The rich people who pay no tax
Only the little people pay taxes. For a small, select cohort of rich Australians, the famous quote of New York property billionaire Leona Helmsley rings not as an outrage but as an inspiration. In the most recent documents released by the Australian Tax Office, there were 55 people who had… – Continue reading
Zambia signing its way out of tax revenues-ActionAid Zambia
A new report from ActionAid titled ‘Mistreated’ released this week has revealed that Zambia has 13 restrictive tax treaties that dramatically restrict the government’s power to tax global companies doing business on our soil and therefore unfairly limit our country’s potential to collect tax revenue. The report also found that… – Continue reading
Getting to the crux of Ncell buyout deal
CAN NEPAL IMPOSE CAPITAL GAINS TAX ON NCELL BUYOUT DEAL? This question has been making rounds ever since TeliaSonera, the largest shareholder in Nepali telecom operator, Ncell, announced its decision to sell 60.4 per cent of its stake in the telecom company to Malaysian giant, Axiata, for $1.03 billion. Divergent… – Continue reading
Ikea avoiding tax liability, report claims
EU countries may have lost out on more than €1 billion in tax revenues between 2009 and 2014 due to aggressive tax strategies by furniture giantIkea, a new report has claimed. The report, commissioned by the Green/EFA group in the European Parliament into the tax affairs of the private company,… – Continue reading
Azerbaijan, Sweden eliminate double taxation
A Convention between the Government of the Republic of Azerbaijan and the Government of the Kingdom of Sweden for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income was signed on Wednesday. The Convention was signed by Azerbaijani Foreign Minister Elmar Mammadyarov… – Continue reading
Armenia and Sweden free businesses of double taxation
Armenian foreign minister Edward Nalbandian and his Sweden opposite number Margot Wallström have signed today in Yerevan an agreement on the mutual avoidance of double taxation of income and property and prevention of tax evasion. Speaking to reporters after the signing ceremony, Nalbandian said the two countries are boosting a… – 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
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
S. Korea, Macau to sign tax information exchange agreement
Macau’s Financial Services Bureau (DSF) has confirmed to Business Daily that the local authority is to sign a Tax Information Exchange Agreement (TIEA) with South Korea, which would add to the existing 15 jurisdictions that have already signed this agreement with the territory. According to the Bureau, its South Korean… – Continue reading
Tanzania: Managing Tax Risks – Double Tax Treaties and Implications to Undertakings of Multinationals
The term double taxation refers to an exposure to tax more than once on the same profit or income. There are two types of double taxation i.e. economic double taxation and juridical double taxation. Economic double taxation is broad and occurs in a situation where an amount of income is… – Continue reading
BOTSWANA, African tax haven?
About Botswana Botswana, a former British colony in Southern Africa, is one of the most prominent countries in Africa. The country has a strong economy,uses one of the most advanced banking systems in the continent, and maintains a stable tradition of representative democracy. After becoming independent in 1966, Botswana developed… – Continue reading
Multinational moves could prompt major losses in corporate tax
Action on tax avoidance could see €600m go from the pharma sector, says report International moves on multinational tax could threaten Ireland, with a potential annual loss of corporate tax revenue of €600 million or more from the pharma sector alone, according to a new report from Chartered Accountants Ireland…. – Continue reading
IP BOX: Italian and European Legal Framework
On 22 December 2014, the Italian Parliament approved the Budget for 2015.40 Among other measures, the Law introduces the possibility of an exemption from corporate income tax (IRES, generally levied at 27,5%) and local tax (IRAP, generally levied at 3,9%) on income derived from qualifying intangible assets (such as patents,… – Continue reading
IKEA’s Founder Paid Tax for the First Time in 42 Years
In 2015, after returning from a 40 years-long Swiss tax exile, IKEA’s founder and the 11th richest person in the world, Ingvar Kamprad, paid Swedish tax for the first time. In 2014, Kamprad declared income of €1.9 million in Sweden. As a result, he was subject to Swedish personal income… – Continue reading
Sweden: “Hybrid rule” implications for dividend income, withholding tax
Changes to the tax law in Sweden reflect additions of anti-avoidance provisions to the EU Parent/Subsidiary Directive and are intended to bring Swedish tax law into compliance with the directive. The new anti-avoidance provisions will be effective 1 January 2016—which is also the timeframe for EU implementation of the directive’s… – Continue reading
Destination ‘filthy rich’: Where the wealthy go to get even richer
WELCOME to Switzerland. A mountainous country where nothing comes cheap but many of the world’s filthy rich come to grow their fortunes. The ongoing relationship between the wealthy and Switzerland looks set to only strengthen as the super rich get richer, according to a report released on Friday. That’s despite… – Continue reading
Kenya and South Africa tax deal takes effect in January
The Kenya-South Africa double taxation agreement comes into force from January 1. An announcement in the November 19, South African government gazette says the agreement applies for taxes withheld at source. “A resident of Kenya will not be taxed on any South African business profits, unless it carries on business… – Continue reading
DDM Holding AG: Swiss withholding tax applies in respect of interest payments to holders of the DDM Senior Secured Notes
Following a ruling by the Swiss Federal Tax Administration, payments of interest under the DDM Treasury SEK 300 million Senior Secured Notes with ISIN SE0005280831 (the “Notes”) are subject to Swiss withholding tax since the refinancing executed in June 2015. On 23 June 2015 certain amendments to the documentation in… – Continue reading
Yle programme: Finnish corporations cold-shoulder EU anti-tax planning efforts
Finnish companies continue to take advantage of legal tax planning to shelter their profits from taxation. According to Yle’s Ajankohtainen kakkonen current affairs programme, state-owned firms are among those that have been dragging their feet on reporting income from their foreign subsidiaries. The European Union is making an effort to… – Continue reading
UAE concludes its visits to Scandinavian countries by signing an agreement on exchange of information for tax purposes with Sweden
The UAE delegation, which was headed by HE Obaid Humaid Al Tayer, Minister of State for Financial Affairs, has concluded its official visits to the Scandinavian countries. These visits aimed at strengthening the country’s network of agreements on exchange of information for tax purposes, reviewing the financial practices adopted by… – Continue reading
Kenya: ‘Kenya Losing Billions to Tax Havens’
The government has been accused of opening a loophole that allows super rich individuals and multinational companies to avoid taxes. The Tax Justice Network (TJN), a lobby group, has sued the government over agreements, which it says are robbing Kenya of the ability to raise revenues domestically, driving the country… – Continue reading
Tax panel compels companies to testify
HSBC, Google, Facebook are among firms that will now appear after threat from MEPs on access to Parliament. Several multinational companies have now dropped their opposition to appearing before a special European Parliament panel investigating allegations of tax avoidance in Europe. HSBC said Tuesday it would participate in a hearing… – Continue reading
The Latest South African Tax Proposals are Far-reaching
There was a time when, from a tax perspective, South Africa’s “mini budget” used to be a non-event. The main emphasis was on the annual budget speech delivered in February each year when they announced tax policy proposals. However, over the past few years there has been an increasing tax… – Continue reading
Just how dirty is offshore money?
David Cameron threw the proverbial cat among the pigeons in July when, with a steely glare at the UK property industry, he warned that the UK must not become “a safe haven for corrupt money from around the world” and that “there is no place for dirty money in Britain”…. – Continue reading
Unpacking the Budget
“If we do not achieve growth, revenue will not increase. If revenue does not increase, expenditure cannot be expanded.” It is with this statement that the Minister of Finance set the tone of the Medium Term Budget Policy Statement (MTBPS) which he presented on Wednesday against a fiscal backdrop of… – Continue reading