Senior tax executives are preparing for changes in the tax landscape as a result of the Organization for Economic Co-operation and Development’s base erosion and profit shifting project. A new survey by Ernst & Young, presented Thursday at its 34th Annual International Tax Conference, found 88 percent of tax directors… – Continue reading
The location of a holding company is a significant consideration in any international corporate structure. Choice of jurisdiction for a group holding company (‘Holdco’) is relevant both from the point of view of tax optimisation (maximising withholding tax free dividend, interest and royalty flow up through the group and minimising… – Continue reading
On 6 October 2015, the Council of the European Union reached agreement on a proposal for a Council Directive (‘the New Directive’) amending Directive 2011/16/EU (Directive on administrative cooperation between Member States) and requiring automatic exchange of information on ‘advance tax rulings’ (‘Tax Rulings’) and ‘advance pricing arrangements’ (‘APAs’) between… – Continue reading
The UK Government’s consultation paper on non-domicile status is “thin on the ground” when it comes to detail and, if introduced as proposed, will fail to treat some ‘non-doms’ fairly, according to tax experts. “It feels like this new legislation is being rushed through,” said Dean Mullaly, managing director of… – Continue reading
EU finance ministers today agreed to introduce provisions for the automatic exchange of information on cross-border tax rulings—the latest development concerning the European Commission’s initiative to address tax avoidance and harmful tax competition. Detailed provisions to be included in a directive are expected to be finalized before the end of… – Continue reading
At the third India Germany Inter-Governmental Consultations (IGC) held in New Delhi, Indian Prime Minister Narendra Modi and German Federal Chancellor Angela Merkel renewed their determination to expand bilateral trade and investment In a joint statement issued by both leaders after IGC, both sides noted the potential of open markets… – Continue reading
Six of the nation’s largest banks — Bank of America, Citigroup, JPMorgan Chase, Wells Fargo, Morgan Stanley and Goldman Sachs — utilize a combined 395 known tax havens to avoid potential tax bills in the billions, according to a new analysis. In total, the big six banks kept $126 billion… – Continue reading
LUXEMBOURG: European Union finance ministers agreed on Tuesday to automatically exchange information on deals struck with multinational companies from 2017 in a bid to reduce tax avoidance, officials said. “We have a political deal on this issue,” Luxembourg’s finance minister Pierre Gramegna told his EU counterparts in a public session… – Continue reading
The Irish government is set to make further changes to the country’s corporate tax regime as it seeks to align itself with a global initiative to clamp down on corporate tax avoidance, reports the Financial Times. The change being considered will oblige companies that have global headquarters in Ireland to… – Continue reading
PARIS–Global tech firms such as Amazon.com Inc. are already preparing for new tax rules that could force them to pay corporate taxes in more countries where they operate, but are also girding for what some say will be more fights with–and between–national tax authorities. The Organization for Economic Cooperation and… – Continue reading
Europe’s stiff-neckedness is difficult to cure. To come to an agreement for supranational treatment of a certain issue there needs to be a large cataclysm or at least a large scandal. In the case of taxation policy the problem begins to gain urgent and most importantly European status after the… – Continue reading
It is estimated that only around 1% of the world’s population have two or more passports, making dual citizenship an exclusive privilege JOHANNESBURG – “No man is an island” is the theme of this year’s upcoming Investment Agenda, being held in Johannesburg on the 20th of October. Leading investors, asset… – Continue reading
Tax evasion is a massive global industry. Of every hundred dollars people put in bank accounts and investments, eight are socked away in tax havens such as Switzerland and Singapore, according to work by the UC-Berkeley economist Gabriel Zucman. While only the very wealthy can afford to play this international… – Continue reading
The OECD’s measures to reform international corporate tax systems will cause Ireland fewer problems than forecast, but for eurozone countries it will be just the beginning of greater and more detailed change. Following two years of constant meetings between tax experts from its 34 country members, the Paris-based body releases… – Continue reading
On Monday (5 Oct) the Paris-based Organisation for Economic Cooperation and Development (OECD) will present its final Base Erosion and Profit Shifting (Beps) project corporate tax reform proposals and on Tuesday the Ecofin council of EU finance ministers, is expected to agree on the exchange of tax rulings between member… – Continue reading
Once again, Commonwealth Caribbean countries are under attack as “tax havens”, even though they are nothing of the sort. This time it is not only the usual countries which have been listed. Trinidad and Tobago has been included, and we can bet that Jamaica and Guyana will be added unless… – Continue reading
EU member states to reveal information on tax rulings offered to companies Ireland’s corporate tax regime is to come under renewed scrutiny next week as EU finance ministers sign off on a proposal obliging member states to reveal information on tax rulings offered to companies. EU finance ministers meeting in… – Continue reading
Two hundred miles off the coast of Morocco, the Canary Islands remainamong Spains farthest-flung territories, appearing as a few specks of volcanic rock against the endless Atlantic blue. Tourists roast on its beaches, and everything moves at a snails pace. That includes, unfortunately, the economy, which suffers from high unemploymentand… – Continue reading
Under pressure to find resources for his promises of sweeping tax cuts, Italian Prime Minister Matteo Renzi is hoping to raise billions of euros by forcing multinational Internet firms to pay taxes on profits generated in Italy. Treasury Undersecretary Enrico Zanetti said a so-called “Google Tax” could yield up to… – Continue reading
A new report by global consulting outfit, Price¬waterhouseCoopers (PwC), released on Monday has indicated that expanding com¬pliance burden, more audits and the potential for increased and double taxation remain key hurdles facing companies due to the rapidly evolving global tax landscape. The report’s findings showed that the demand for greater… – Continue reading
Secret Luxembourg document discussed risks of special tax deals, but Jean-Claude Juncker says he cannot remember discussing it with its author The president of the European Commission faces fresh questions about his role in designing Luxembourg’s controversial system of “sweetheart” tax deals after he released an 18-year old document that… – Continue reading
In light of the global Base Erosion and Profit Shifting (BEPS) initiative and the European developments against tax evasion and aggressive tax planning, two European Directives were adopted in July 2014 and January 20151 by the European Council, amending the Parent-Subsidiary Directive (2011/96/EU). These two Directives, in a nutshell, aim… – Continue reading
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
The European Commission will propose a draft law next year to stop tax regimes that favour raising corporate debt over equity as it tries to reduce the amount of company loans on banks’ books and to cut companies’ leverage, officials said on Monday, reports Reuters. In most European countries, companies… – Continue reading
The Embassy of the Republic of Latvia has begun operations in Seoul, the capital of the Republic of Korea. The Embassy will be promoting political and economic dialogue between Latvia and Korea especially in support of Latvian businesses and cooperation with potential Korean investors, thereby facilitating access to third country… – Continue reading
The increasingly international nature of business will lead to complications and disruptions that may plague the future of audit, according to PwC. A recently-released PwC report, Global Tax Transparency and Risk Management – part of the ‘Tax Function of the Future’ series – notes that the number and size of… – Continue reading
Prime Minister Narendra Modi has assured Cyprus President Nicos Anastasiades that he would look into the double taxation agreement to see how he could expedite it and said that Nicosia has always stood by New Delhi on all issues of ‘mutual concern’. “The Cyprus President said that the nation had… – Continue reading
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
The government in the tiny Swiss canton of Zug has been forced to admit the previously unthinkable: its famously low tax rates, which have attracted a host of companies and celebrities, may have to rise. Facing a series of financial blows — including the effects of a strong Swiss franc… – Continue reading
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
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
Hungary’s Minister of State for the Utilization of EU Funds, Balázs Rákossy, has called for a more coordinated EU effort in the fight against tax evasion. Speaking at the 13th G28 taxation forum, Rákossy noted that the recent EU report on the VAT gap revealed that EU states lost theoretical… – Continue reading
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 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
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
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
Finance ministers of euro zone’s major economies renewed on Tuesday their commitment to curb multinational corporations’ tax avoidance and called for more consistent rules to reduce “harmful” tax competition. Multinational companies have long been in the sights of European Union authorities because of the way they can legally reduce their… – Continue reading
A report from Italy’s Minister of the Economy and Finance says the annual Italian “tax gap” – the revenue lost due to tax breaks, avoidance, and evasion – totalled EUR91.3bn, or 6.6 percent of the country’s gross domestic product, during the period 2007-2013. This represents a fall from the EUR93.5bn… – Continue reading
Companies would save €1bn per year in administrative costs if the European Union adopts a common approach to corporate taxation, EU Economic and Tax Commissioner Pierre Moscovici has claimed. The former French finance minister has posted an article to his online blog calling for a mandatory EU common consolidated corporate… – Continue reading
Labour MEP warns that EU tax harmonisation against the interests of Malta and other European islands and peripheral regions Labour MEP and former Prime Minister Alfred Sant told the European Parliament that EU tax harmonisation goes against the interests of Malta and other peripheral regions and islands with limited endowments… – Continue reading
The Swiss Bankers Association (SBA) has waded into the ongoing anti-tax evasion political debate by urging lawmakers not to burden banks with too many regulations, reports Swiss Info. The SBA said on Thursday that it supported the introduction of automatic tax data sharing with other countries. However, the lobby group… – Continue reading
European Commission president Jean-Claude Juncker has denied involvement in sweetheart deals that allowed hundreds of multinationals to slash their tax bills by locating to Luxembourg, despite being prime minister of the country for almost 20 years, reports the Financial Times. Facing questions from a committee of EU lawmakers set up… – Continue reading
Speed read On 15 September 2015 the Dutch government published its Tax Plan 2016. In this e-alert we discuss the legislative proposals in the Tax Plan which are of interest for companies. 1 INTRODUCTION Today, the Dutch Ministry of Finance published its Tax Plan 2016. In fact, the government sent… – Continue reading
Galway Bay FM Newsroom – Supermac’s boss Pat McDonagh has spoken out against McDonald’s alleged tax avoidance schemes which could have reportedly cost the EU almost 4 billion euro. It follows a meeting of the European Parliaments TAXE Committee today to investigate the 3.7 billion euro tax avoidance. It’s alleged… – Continue reading
HMRC has today published new draft guidance notes to cover the automatic exchange of financial account information under the International Tax Compliance Regulations 2015 (SI 2015 No. 878) (the Regulations), which were made in the spring. The main document is a new draft HMRC guidance manual covering the Regulations. The… – Continue reading
More than 90 jurisdictions, including all 34 member countries of the Organisation for Economic Co-operation and Development (“OECD”) and the G20 members, have committed to implement the Common Reporting Standard for automatic exchange of tax information (“CRS”). Building on the model created by FATCA, the CRS creates a global standard… – Continue reading
Read the full newsletter. The OECD’s recent recommendations1 with respect to transfer pricing documentation and country-by-country reporting may have the most significant impact on multinational enterprises (“MNEs”) of all of the OECD’s BEPS proposals. The adoption of these recommendations, without consensus on effective dispute resolution, is likely to alter the… – Continue reading
Some Italian parliament members published a proposal for a new law that may dramatically change the scenario for e-commerce and web operators doing business in Italy. The proposal (called by some commentators as “Digital” or “Web Tax”) is substantially a combination of domestic rules affecting the taxation of the digital… – Continue reading
On September 15, the Dutch government released its Budget 2016, containing the Tax Plan 2016 which includes certain amendments to Dutch tax law. The government will discuss the plans the coming weeks in parliament. Further to these discussions, some elements of the Tax Plan 2016 may change. Most proposals will… – Continue reading
EU committee set up to investigate aggressive tax planning concludes its report in weeks Lobbyists representing internet company Facebook could be banned from entering the European Parliament following a request by the parliament’s special committee on tax to revoke access to multinationals who refused to cooperate with the committee’s inquiries…. – Continue reading
