Officials from the Treasury and HM Revenue and Customs (HMRC) have been meeting with representatives of the PPP/ PFI industry to discuss the implications for infrastructure projects of possible restrictions to interest relief.24 Oct 2014 Corporate tax Tax Projects Construction Advisory & Disputes Infrastructure UK Europe In a report on… – Continue reading
By the wide margin of a 250-76 vote on October 16, the Chamber of Deputies of the Italian Parliament passed a decree law to introduce a voluntary disclosure program for undeclared assets and funds held abroad or in Italy. Under the new program, such taxpayers would be allowed to declare… – Continue reading
Move intended to make Ireland more attractive to firms wanting to bring key decision makers The Government is to relax the rules governing a special tax incentive scheme to attract foreign executives into Ireland after just 31 individuals availed of the scheme last year. The move, contained in the Finance… – Continue reading
Wednesday, October 22, 2014 – The BVI Advantage was the theme of a feature presentation at the recent China Offshore Summit. The summit was held from October 15-16 in Shanghai, China. Global Head of BVI Practice at Maples and Calder, Mr. Michael Gagie presented on behalf of the BVI International… – Continue reading
The Gibraltar Betting & Gaming Association (GBGA) is continuing its challenge against changes to the United Kingdom’s regulatory and licensing changes for gambling-service providers by asking for a judicial review of a recent High Court decision which went against the GBGA’s interests, specifically challenging whether the new 15% “UK point… – Continue reading
The European Union Court of Justice (CJEU), Europe’s highest court in matters of EU law, ruled against the Italian government in a dispute related to the Italian taxation on gambling. According to the CJEU, Italy’s tax legislation operates in conflict with Article 52 and Article 56 of the Treaty on… – Continue reading
“The issue of substance and taxation is, and always will be, a core column of the Irish taxation system,” Michael Noonan, Ireland’s Finance Minister, said at his Department’s Tax Policy Conference on October 21, 2014, underscoring that Ireland’s strategy is to play fair but play to win. Beginning by discussing… – Continue reading
The European Union and Singapore have announced the completion of negotiations towards a free trade agreement (FTA), after concluding talks on the investment protection portion of the pact. Negotiations on an FTA between the EU and Singapore began in March 2010 and a text including all but the investment portion… – Continue reading
Countries that work together like Ireland and the US “need to be cognisant” of the impact their tax policies have on each other, new US Ambassador to Ireland Kevin O’Malley said in a speech yesterday. He said cross-border mergers can make the Irish and American economies stronger, but that “these… – Continue reading
23/10/14 – After a comprehensive review in October 2012, the OECD Working Group on Bribery asked France, through a series of concrete recommendations, to intensify its actions to fight the bribery of foreign public officials and undertake important reforms. In October 2014, the Working Group welcomed several significant reforms, including:… – Continue reading
Around $180 million in undeclared offshore income has now been recovered as part of the amnesty, the ATO said. A further $1 billion in assets has also been recovered. Photo: Louie Douvis The Tax Office is keeping a close eye on foreign banks as part of its push to stop… – Continue reading
Irish Finance Bill 2014: Last Sunday The New York Times in an editorial following the decision in Budget 2015 to eliminate the Double Irish tax dodge from 2021, said “Ireland, which for years used policies like the Double Irish to attract multinational businesses, appears uninterested in true reform. It will… – Continue reading
LUXEMBOURG — On the first floor of a rust-colored building near the main railway station, Marius Kohl spent years engineering this country’s most valuable export: tax relief. As head of a federal agency called Societes 6, Mr. Kohl approved thousands of tax arrangements for multinational corporations, sometimes helping them save… – Continue reading
THE OECD has signalled support for the Government’s plan to introduce a so-called “Knowledge Development Box”, but warned that the devil would be in the detail. Pascal Saint-Amans, the director of the Centre for Tax Policy and Administration at the Paris-based Organisation for Economic Cooperation and Development (OECD), told the… – Continue reading
The Organisation for Economic Cooperation and Development (OECD) has recommended a number of direct tax reforms to build on the French Government’s efforts to improve the nation’s competitiveness in Europe. The report points out that the tax wedge (the cumulative burden of taxes on workers) in France is among the… – Continue reading
BERN/NEW DELHI: To comply with global norms, Switzerland today began consultation process for unilaterally amending bilateral tax treaties to allow exchange of information when there is a request from another country. Amid rising international pressure, including from India, Switzerland has been taking steps to share tax information as well as… – Continue reading
On October 15th, 2014 the Minister for Finance announced the Luxembourg Budget 2015. The announcement followed the presentation made the day before by the Prime Minister Xavier Bettel who presented a policy statement entitled “Package for the Future” which provides some overall public finances policy statements for the period 2015… – Continue reading
A new survey by E&Y released at its 33rd Annual International Tax Conference, titled “Connecting the dots” uncovered the issues of navigating multiple challenges, led by increased scrutiny and the effects of the Organisation for Economic Co-operation and Development’s (OECD) base erosion and profit shifting (BEPS) project. “Tax directors need… – Continue reading
ITR Correspondent • • • The G20 and OECD’s Base Erosion and Profit Shifting (BEPS) project has rarely been out of the headlines during 2014. At the heart of the BEPS project is the assumption international tax rules make it possible for profits to be taxed in countries that are… – Continue reading
JPMorgan Chase & Co. (JPM) agreed to pay 72.2 million euros ($92 million) in fines to European Union regulators for attempting to rig the Swiss franc Libor rate and fixing spreads with rivals, the EU said today. UBS AG (UBSN) was fined 12.7 million euros by the EU and Credit… – Continue reading
21/10/14-Tax administrations will play a central role as governments move to implement the measures they have agreed to counter offshore evasion and combat tax avoidance by multinational enterprises. Global initiatives like the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project and the move toward automatic exchange of financial account account… – Continue reading
Estonia will issue identity cards allowing access to its digital services to people residing outside the Baltic nation as it seeks to boost foreign investment. Lawmakers in the capital Tallinn voted unanimously with no abstentions to let foreigners seek e-residence status to be able to set up a company in… – Continue reading
Foreign structures are tempting targets for governments, says Vanessa Houlder. When governments around the world embarked on a drive to plug tax loopholes in 2012, the urgency of the move was underpinned by rising tensions over austerity and inequality. Widespread public outrage over alleged tax-dodging by wealthy individuals and multinationals… – Continue reading
A Residence Programme (“TRP Rules”) has been introduced with effect from 1 July 2013 for individuals who are nationals of the EU, EEA or Switzerland (but not Maltese nationals) in terms of Legal Notice 270 of 2014 and Articles 56(23) and 96 of the (Malta) Income Tax Act, Chapter 123… – Continue reading
Unprecedented international collaboration is needed to overcome a single-, isolated-country view to tackling base erosion and profit shifting (BEPS) issues, Andrew Mills, Second Commissioner of Australian Taxation Office (ATO) for Law Design and Practice, has said. In a speech delivered at the Second Annual Tax Forum organized by the Tax… – Continue reading
Switzerland and Italy may agree amendments to their existing double tax agreement by spring 2015, Vieri Ceriani, Italy’s chief negotiator, has said. With the appointment of a new Government in Italy, Ceriani said that the provisions being sought by Italy, in particular on the division of taxes collected from Italian… – Continue reading
The Organization for Economic Cooperation and Development’s (OECD) plan for base erosion and profit shifting (BEPS) is already affecting corporations, according to speakers participating in a Captive Insurance Companies Association (CICA) transfer pricing webinar. Polling results during the webinar revealed attendees’ opinions were in line with tax industry surveys indicating… – Continue reading
The energy company has published retrospective accounts and pledges to stay away from tax havens Energy company SSE has become the first FTSE 100 business to be awarded the Fair Tax Mark, a scheme that aims to hold companies to account over their tax affairs. SSE, which has nine million… – Continue reading
On 16 October, the Saeima (Parliament), in its final reading, passed the “Public Persons Enterprises and Capital Shares Governance Law” in order to promote more effective governance of companies owned by the state and local governments. The Secretary-General of the Organisation for Economic Cooperation and Development (OECD), Angel Gurría, has… – Continue reading
European Union finance ministers have reached a breakthrough agreement that will make it more difficult for tax cheats to hide their money. The new legislation, which had been blocked for years by countries with a reputation as tax havens, was approved last week after Luxembourg and Austria agreed to lift… – Continue reading
On July 15th 2014, the OECD published its 2014 update of the Model Tax Convention (“2014 OECD Update”). This update is the outcome of the work accomplished between 2010 and the end of 2013. It does not however take into account the OECD conclusions of the “Action Plan on Base… – Continue reading
The revenue implications for South Africa of ‘base erosion and profit shifting’ by corporate taxpayers are firmly in the crosshairs of the Davis Tax Committee (DTC) and Judge Dennis Davis hinted on Monday that recommendations were being considered to “detect and deter” tax-avoiding financial flows. Speaking at a G20 study… – Continue reading
The Council agreed last tuesday, at a meeting of the Economic and Financial Affairs Council , on a draft directive extending the scope for the mandatory automatic exchange of information between tax administrations, enabling them to better combat tax evasion and to improve the efficiency of tax collection. The proposal… – Continue reading
There has been a lot of press coverage recently around the pricing and tax arrangements of multinationals, in particular Apple, Starbucks and Amazon. In this respect, the EU is undertaking in-depth investigates into these companies to establish whether the companies’ tax arrangements have breached EU State Aid rules. These cases… – Continue reading
Non-EU investment firms’ access to EU investors under MiFID 2 The recast Markets in Financial Instruments Directive (MiFID 2), along with its accompanying Regulation (MiFIR), were published in the Official Journal of the EU in June. The new legislation is currently expected to come into effect in January 2017. The… – Continue reading
The Irish government decided last week to get rid of a tax loophole that has helped big multinational companies like Apple and Google avoid paying billions in taxes to any government at all. But hold the champagne: Ireland could well replace one problematic tax policy with another, leaving aggressive tax… – Continue reading
IMF President Christine Lagarde (right) poses with OECD Secretary General Angel Gurria, prior to a meeting with International economic organisations at the OECD in Paris. PARIS: The moribund French economy could get a sharp boost each year over a decade if highly controversial reforms to help businesses are enacted, predictions… – Continue reading
These crimes hinder the development of societies, prevent strengthening the legitimacy of democracy SANTIAGO — Corruption and tax evasion are flagrant violations of human rights in Latin America, where they contribute to inequality and injustice in the countries of the region, according to studies and experts consulted by IPS. “Tax… – Continue reading
A number of American corporations are making news, and not in a good way. They have announced mergers with foreign companies so they can avoid paying U.S. taxes. They are seeking what is called a “tax inversion” and it allows an American corporation to merge with a foreign corporation, move… – Continue reading
Some 19 British firms are at the center of an investigation into in a mammoth global money-laundering operation. The scheme was allegedly contrived to make $20bn (£12.5bn) worth of ill-gotten gains appear legitimate. The illicit funds are thought to have originated from criminal gangs and corrupt officials across the globe,… – Continue reading
IrishTonnageTax – The Irish Maritime Development Office (IMDO) has released a report Irish Tonnage Tax: Opportunities for the International Shipping Industry. The Irish tonnage tax regime has been established for over 10 years and offers one of the most competitive on-shore corporate tax rates to international shipping companies. The tonnage… – Continue reading
17/10/2014 – Full implementation of the structural reforms adopted and announced in France would boost potential annual economic growth by one third, or 0.4 percentage points per year over ten years, according to the OECD. In a report entitled Structural reforms in France: Impact on growth and options for the… – Continue reading
Ireland puts an end to a tax loophole that saved Google, Apple, Microsoft, and Facebook billions in taxes “Double Irish” might sound like a drink that corporate tax lawyers reach for at the prospect of paying higher tax bills, but it’s actually the name of a controversial — albeit legal… – Continue reading
Our Reaction The Irish Minister for Finance delivered his Budget 2015 (the “Budget”) speech this week. There was considerable domestic and international anticipation in advance of the Budget against a backdrop of significant recovery in the Irish economy and also international focus (including, in particular, under the OECD BEPS project)… – Continue reading
The European Union expanded its crackdown on illegal tax breaks, ordering Spain to recover money from companies that benefited from rules encouraging merger activity outside of the country. The European Commission said the Spanish measures unfairly rewarded companies for buying stakes in foreign competitors. Telefonica SA (TEF) last year lost… – Continue reading
The European Commission has published a new report detailing key tax reforms implemented by European Union member states during 2014 and identifies the main policy challenges they are said to face. The report notes that the tax burden on labor in the EU is relatively high. It suggests that member… – Continue reading
Romania wants to become a full-fledged member of the Organization for Economic Co-operation and Development (OECD), according to Romanian officials, Prime Minister Victor Ponta and Foreign Affairs Minister Titus Corlățean. The message has been sent to – and received by –the OECD secretary general William Danvers, who was on a… – Continue reading
n this second part of our overview of current transfer pricing regulations on the African continent, we focus on relevant provisions in, amongst others, Ghana, Nigeria and Uganda. The Ghanaian Transfer Pricing Regulations, 2012 (L.I.2188) (the Ghanaian Regulations) were introduced by the Ghana Revenue Authority (GRA) on 27 July 2012,… – Continue reading
Europe’s antitrust regulator is encroaching on what has been the preserve of national governments. There’s a new tax sheriff in town. Europe’s top antitrust regulator, the Brussels-based European Commission, has launched an unexpected assault on what it suspects are sweetheart tax deals for multinational companies, plowing into an area traditionally… – Continue reading
AMONG several proposals for tax reform, the director-general of the Revenue Department has said the agency would propose an amendment to the Revenue Code concerning transfer pricing, aiming to provide greater clarity on the determination of fair transfer prices. The director-general has indicated that in past years many multinational companies,… – Continue reading
