Category: Switzerland

US firm Johnson Controls to cut tax bill with $16bn Tyco takeover

Car battery and heating equipment maker accused of ‘stranding honest taxpayers’ Johnson Controls, a US maker of car batteries and heating and ventilation equipment, has agreed to buy Irish-based peer Tyco International in a $16.5 billion (€15.23 billion) deal that will lower its tax bill. By redomiciling to Tyco’s headquarters… – Continue reading

TAX DEPT INKS SEVEN NEW TRANSFER PRICING PACTS

The new advanced pricing agreements cover sectors like investment advisory, IT enabled services and manufacturing In the current fiscal year, which is the third year of APA programme, 30 agreements have been signed so far. As part of efforts to reduce tax disputes related to international transactions carried out by… – Continue reading

Google Strikes Deal With U.K. Tax Authority

DAVOS, Switzerland—Google said Friday that it has struck a deal with U.K. authorities that will settle a tax dispute and boost its corporate taxes in Britain, part of a broader effort by European governments to wring more out of big firms in the tech sector. As part of the settlement,… – Continue reading

Ireland’s new growth a model for other nations, Enda Kenny tells Davos forum

Ireland’s emergence from economic meltdown provides a model for other nations, the Taoiseach has told the World Economic Forum. Enda Kenny also defended his country’s tax arrangements with multinational companies, telling the audience past claims that it was a tax haven for big businesses were without foundation. Mr Kenny took… – Continue reading

Investor group buys Barclays’ offshore trust business

Barclays (BARC.L) has sold its offshore trust business to an independent investor group but will keep a 20 percent stake in the new company, renamed as ZEDRA, for at least three years. The sale marks another step in the British bank’s efforts to simplify its wealth and investment management activities…. – Continue reading

On tax avoidance

The only thing worse than paying taxes is the idea that other people avoid paying their fair share of them. On the subject of tax avoidance by other people, I can think of at least three principal feelings. As the kids say, I feel all the feelings. Outright tax fraud… – Continue reading

Expat eyes drift offshore

Offshore Financial Centres (OFCs) are jurisdictions, usually self-governing, which because of their low tax regimes, have specialized in providing commercial services to corporations and individuals, whether or not they are normally resident in that jurisdiction. The better-known offshore financial centres are small and sparsely populated countries or islands, and are… – Continue reading

Negative interest rates make it expensive to hold large cash reserves, writes Izabella Kaminska

I know Switzerland is renowned as a tax haven but this is surely a step too far? To be fair, they are not actually cutting tax levels. They are just discouraging early payment of taxes. Why would anyone pay the tax authorities early if they didn’t have to? The canton… – Continue reading

Brazil’s Rousseff signs amnesty to undeclared offshore assets

BRASILIA, Jan 14 (Reuters) – Brazilian President Dilma Rousseff on Thursday signed a bill that gives amnesty to holders of undeclared offshore assets in exchange for a fine, part of efforts to cut a swelling budget gap and revive investment in the recession-hit economy. The law offers amnesty from prosecution… – Continue reading

2016 CHALLENGES FOR COMPANIES OPERATING IN JERSEY

Last year Jersey cemented its position as a leading centre for companies looking to list – as reflected in the rise in volume and value of Jersey companies listed on exchanges around the world. Here are some challenges that lie ahead in this jurisdiction over the next 12 months. In… – Continue reading

Swiss canton tells taxpayers to delay settling bills

Taxpayers in parts of Switzerland this year face an unusual request from fiscal authorities: please delay settling your bill until as late as possible, reports the Financial Times. Zug, the small but affluent canton outside Zürich, has announced it is ending discounts for early payment of tax bills. The reason?… – Continue reading

India: Swiss Apex Court Denies Treaty Benefits For Dividend On Securities Acquired For Hedging Derivative Contracts

Federal Supreme Court of Switzerland denies treaty benefits in case of dividend paid on shares acquired for hedging derivative contracts. Court stated that due to the fully hedged nature of ownership, there was economic nexus and interdependency between two independent transactions and therefore, the “intermediary” bank did not have beneficial… – Continue reading

Taxmen mishandled Swiss treaty talks in 2014

ISLAMABAD: Pakistan’s hopes to seek information from Switzerland about the presumed $200 billion stashed in Swiss banks have apparently been ruined by tax authorities who mishandled delicate negotiations for amending a convention on avoidance of double taxation. A Pakistani delegation that visited Switzerland in August 2014 to renegotiate the 2005 treaty… – Continue reading

Luxembourg Tax Alert 2016-02

January 2016 You will find below a summary of some of the most important tax developments that have happened since the release of our last newsletter, at OECD, EU or country level, in the area of tax transparency and the fight against tax avoidance. EU – Tax transparency and anti-BEPS… – Continue reading

US Justice Department Announces Resolution Under Swiss Bank Program With Union Bancaire Privée, UBP SA

The Department of Justice announced today that Union Bancaire Privée, UBP SA (UBP), reached a resolution under the department’s Swiss Bank Program. UBP will pay a penalty of more than $187 million. “Today’s agreement marks the final resolution with UBP, which acknowledges its role in conspiring with U.S. taxpayers to… – Continue reading

UBP to pay $187 million to avoid U.S. charges of aiding tax evasion

UBP is the latest bank to reach a resolution under the Swiss Bank Program, launched in 2013, that allows Swiss banks to resolve potential criminal liabilities in the United States. UBP between 2008 and 2013 helped U.S. clients to open and maintain undeclared accounts in Switzerland and conceal assets and… – Continue reading

European Union: Implementing The Revised Parent Subsidiary Directive Across The EU

A striking example of the EU’s efforts to accelerate the implementation of anti-base erosion and profit shifting (BEPS) measures is the amended Parent Subsidiary Directive (PSD). Originally designed to prevent economic double taxation of profits distributed within an EU corporate, the PSD is now also being deployed to counter undesired… – Continue reading

United States: Is Julius Baer Group AG The Next Swiss Bank To Resolve Its Tax Problems With The U.S.? If So, What Does It Mean To Those Who Had A JB Account?

Shortly before New Year’s, on Wednesday, December 30, 2015, the media reported that Julius Baer Group AG (“JB”) expected to pay about $547 million to settle the U.S. investigation into how the bank (and its bankers) assisted U.S. taxpayers in evading tax. This investigation began more than 4 years ago,… – Continue reading

Switzerland: Tax News: Corporate Tax Reform III Approved By Swiss Council Of States

On 14 December 2015, the Swiss Council of States discussed the legislative draft of the Corporate Tax Reform III and in principle approved the reform package. In deviation from the revised draft legislation issued by the Swiss Federal Council on 5 June 2015, the Council of States voted against the… – Continue reading

Corruption in Ukraine: US threatens to cut off aid

United States Vice President Joe Biden has never been one to hold his tongue. He certainly didn’t in his recent trip to Kiev. In a speech before Ukraine’s Parliament, Biden told legislators that corruption was eating Ukraine “like a cancer,” and warned Ukrainian President Petro Poroshenko that Ukraine had “one… – Continue reading

Exclusive: More banks pay no UK tax, Labour wants tougher approach

Two more investment banks have reported paying zero tax in Britain in 2014, prompting the opposition Labour party to urge the government to reverse a tax change it made for banks last year. Citigroup and Credit Suisse disclosed in the past fortnight that their main UK subsidiaries paid no corporate… – Continue reading

Bermuda On “Best Tax Havens In World” List

Bermuda has “long been a popular tax haven” according to a story by gobankingrates.com, which ranked the island as one of the “top 10 best tax havens in the world.” The story said “Bermuda has long been a popular tax haven, said Ravi Ramnarain, an independent certified public accountant. “Wealthy… – Continue reading

Swiss bank Julius Baer to settle US tax probe for $547 mn

One of the leading Swiss banks Julius Baer Group AG is set to reach a deal with US authorities over a tax probe by paying $547 million early next year. Julius Baer, Switzerland’s third-largest wealth manager after UBS and Credit Suisse has been under criminal investigation since 2011 by the… – Continue reading

Global dragnet puts pressure on tax evaders as year-end deadlines loom

Tax cheats are facing a series of year-end deadlines to come clean, as an international dragnet affecting both wealthy Canadians with offshore accounts and Americans in Canada who have failed to file U.S. tax returns keeps tightening. Lawyers say some Canadians with Swiss bank accounts have received letters demanding written… – Continue reading

Swiss, Italy agree deal on taxing cross-border commuters

ZURICH: Negotiators from Switzerland and neighbour Italy reached agreement on Tuesday on how to tax cross-border commuters, wrapping up months of talks that aimed to help Italy crack down on undeclared foreign wealth. The accord, which must be approved by both national governments and parliaments, would see workers paying up… – Continue reading

Offshore bank gets up to $840k in payroll rebate

It’s probably not the best time in the province to announce a payroll rebate to a major offshore bank promising to create 50 jobs in Halifax. Nova Scotia Business Inc. on Tuesday announced a rebate worth a potential $840,000 over six years to the Bank of N.T. Butterfield and Son… – Continue reading

Exclusive: Seven big investment banks in UK paid just $30 million tax in 2014

LONDON (Reuters) – Seven of the biggest investment banks operating in London paid little or no tax in Britain last year, despite reporting billions of dollars in profits, a Reuters analysis of corporate filings shows. In recent months, the seven investment and corporate banks operating in London reported figures showing… – Continue reading

Hervé Falciani — The SwissLeaks Whistleblower

Most people with undisclosed Swiss bank accounts have, by definition, something to hide. Secrets, however, sometimes don’t remain secret, especially when they involve someone else’s money. While disclosing the names and financial details of Swiss bank account holders has recently come into vogue, a whistleblower may have just as murky… – Continue reading

BEHIND THE HEADLINES: Tax haven hypocrisy

A BALANCING ACT in London, folly and redemption in America’s District of Columbia and sheer hypocrisy in Brussels. And in every case, Barbados and many of its Caribbean neighbours were placed in the negative international spotlight at a time when some of the world’s major financial centres are casting about… – Continue reading

India to sign agreements with S’pore, UAE and Hong Kong for info on illegal bank a/c: CBDT

NEW DELHI: India is close to signing collaborative jurisdictional agreements with three countries – Singapore, the United Arab Emirates and Hong Kong – for dealing with challenges related to the siphoning of black money, said the Central Board of Direct Taxation (CBDT). A spokesperson of the CBDT told ANI in… – Continue reading

Swiss Banker to Royalty to Pay $45.4 Million to End U.S. Tax Probe

Edmond de Rothschild (Suisse) SA agreed to pay $45.4 million to avoid prosecution for helping U.S. clients evade taxes, admitting it aided them in moving cash and using sham offshore entities to hide money from the Internal Revenue Service. Rothschild is the 68th Swiss bank to reach an accord with… – Continue reading

US Justice Department Announces Joint Resolution With Two Banks Under Swiss Bank

The Department of Justice announced today that Edmond de Rothschild (Suisse) SA and Edmond de Rothschild (Lugano) SA (collectively EdR Switzerland) reached a joint resolution under the department’s Swiss Bank Program. EdR Switzerland will pay a penalty of more than $45 million. The Swiss Bank Program, which was announced on… – Continue reading

Swiss bank hid assets for Jews, then tax evaders

Dreyfus Sons & Co. has operated for two centuries as a private Swiss bank, catering to Jewish clients who wanted to hide assets from the Nazis during the 1930s and World War II. More recently, it helped U.S. clients hide assets from the Internal Revenue Service by concealing their true… – Continue reading

Switzerland: Towards the end of the tax gifts to foreign companies

For the Socialist Senator Roberto Zanetti, the reform is an open-heart surgery, which must be done with great accuracy. Under pressure from the EU, G20 and the OECD, also Switzerland is obliged to give up his special tax regimes for holding companies and management companies. After years of negotiations with… – 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

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

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

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

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

Capacity market: Fossil fuel companies controlled by tax haven entities receive millions in subsidies

Fossil fuel companies and nuclear power producers, some of which have been involved in shaping government energy policy, will receive over £834 million* in state subsidies for the winter of 2019-2020, the government has announced. The big winners of the capacity market auction, which is managed by National Grid and… – Continue reading