Category: Regulatory

Ireland Budget 2020 released

On 8 October, the Irish government announced its Budget 2020 measures. Brexit and climate change are core themes of new revenue measures and expenditure commitments. Brexit remains the foremost immediate concern for the Irish economy, whereas tackling climate change requires long-term commitments to tax and spending policies. ... - Continue reading

EU Council revises its tax blacklist, addresses “two out of three” exception and foreign source income exemption regimes

As suggested by the EU Code of Conduct Group (Business Taxation), on 4 October, the EU Council today adopted a revised EU list of non-cooperative tax jurisdictions (annex I – blacklist) removing the United Arab Emirates (UAE) and the Marshall Islands. ... - Continue reading

OECD consulting on digital tax proposal

The OECD today published for stakeholders’ comments a proposal to advance international negotiations to ensure that multinational enterprises (MNEs), including digital companies, pay tax wherever they have significant consumer-facing activities and where they generate profits. The proposal – Secretariat Proposal for a Unified Approach – would re-allocate some profits and… – Continue reading

United States: Senators Introduce Bill To Require Reporting Of Beneficial Ownership Information

A bipartisan group of senators introduced a bill which would impose federal beneficial ownership reporting requirements for legal entities established under state law, intended to assist law enforcement in fighting money laundering and terrorist financing ("AML/CFT"). ... - Continue reading

The Fiat and Starbucks state aid tax cases: an absolute loss for legal certainty.

In late September, the EU General Court released its decisions in two long-awaited state aid appeals: Fiat (cases T-755/15 Luxembourg v Commission and T-759/15 Fiat Chrysler Finance Europe v Commission) and Starbucks (cases T-760/15 Netherlands v. Commission and T-636/16 Starbucks and Starbucks Manufacturing Emea v. Commission). ... - Continue reading

Accidental Americans’ sue France over FATCA disclosure rules

A group representing French-American taxpayers  has filed a complaint against France with the European Commission over its compliance with the US Foreign Account Tax Compliance Act (FATCA), in a bid to avoid being blacklisted by French banks starting in January. France is a signatory to an agreement to give the… – Continue reading

Fiji Institute of Accountants concerned about cybercrime, money laundering

SUVA, Oct. 7 (Xinhua) — The Fiji Institute of Accountants (FIA) said Monday they are concerned about the increase in money laundering and cyber-crime activities in the island nation. According to Fiji Broadcasting Corporation (FBC), while presenting before the Standing Committee on Economic Affairs, the Fiji Institute of Accountants President… – Continue reading

Worldwide: Financial Institutions And Personal Data

Combating Tax EvasionIn recent years, there have been several high-profile prosecutions for the crime of tax evasion (for example the actor, Wesley Snipes, and the footballer, Lionel Messi). Governments around the world have been making a concerted effort in an attempt to tackle this problem. Their objective is for their respective tax administrations to work together so that taxpayers pay the correct amount of tax in the correct jurisdiction. ... - Continue reading

Bermuda: Chambers Private Wealth 2019: Bermuda (2019)

1. Tax1.1 Tax regimes In Bermuda there is no income or profits tax, withholding tax, capital gains tax, capital transfer tax or inheritance tax. There is no exit or similar such tax based on a resident's wealth when ceasing to be resident and there are no other consequences of leaving the jurisdiction. Customs duties and stamp duty are major government revenue earners, with stamp duties charged at different rates and in different manners on a variety of legal documents, excluding wills. ... - Continue reading

East Africa bloc mulls regional tax treaty framework to boost integration

NAIROBI, Oct. 1 (Xinhua) — The East Africa Community (EAC) bloc plans to develop a regional tax treaty framework to boost regional integration, an official said on Tuesday. Doris Akol, commissioner general, Uganda Revenue Authority told Xinhua in Nairobi that once the treaty is in place the trading bloc will… – Continue reading

Uganda: Don’t Make Up Losses To Avoid Tax

Conflicting interests arise for many businesses where decisions have to be made to determine how they consistently achieve profitability, while on the other hand minimise payment of tax. The temptation to minimise profits or even make a loss then becomes a tax risk management strategy. ... - Continue reading

Ukraine: Ukraine Ratifies Protocol Amending Double Taxation Treaty Between Ukraine And Switzerland

On 18 September 2019, the Parliament of Ukraine ratified a protocol (the Protocol) of amendments to the double tax treaty between Ukraine and Switzerland (the DTT) which had been signed by the states on 24 January 2019.  ... - Continue reading

Dutch government asks banks to give American expats more time to deal with FATCA

The Dutch government is urging banks to be accommodating towards American nationals who risk having their bank accounts closed because of US fiscal regulations as it calls on EU member states to campaign together for changes to American tax laws which are affecting thousands who have American nationality but no… – Continue reading

BIR padlocks main office, 2 branches of tax-dodging POGO service provider

The Bureau of Internal Revenue (BIR) padlocked simultaneously Wednesday the main office and two branches of one of the biggest Philippine Offshore Gaming Operator (POGO) service providers in the country for alleged failure to register and pay the corresponding deficiency taxes amounting to P2 billion. Shuttered were the headquarter of… – Continue reading

Australian tax office advises on transfer pricing for offshore drilling

The Australian Taxation Office (ATO) on September 27 set out its approach to analyzing transfer pricing issues associated with the use in Australian waters of non-resident owned mobile offshore drilling units such as drill-ships, drilling rigs (including but not limited to submersibles, semi-submersible and jack-up rigs), pipe-laying vessels, and heavy-lift vessels. ... - Continue reading

Armenia, Malta sign double tax treaty

YEREVAN, SEPTEMBER 25, ARMENPRESS. Armenian Foreign Minister Zohrab Mnatsakanyan on September 24 met with Malta’s Minister for Foreign Affairs and Trade Promotion Carmelo Abela on the sidelines of the 74th session of the UN General Assembly in New York, the Armenian ministry told Armenpress. The officials praised the current dynamic… – Continue reading

EU court backs use of arm’s length principle to assess Starbucks, Fiat APAs for state aid violation

The EU General Court today released long-awaited rulings in the Fiat and Starbucks tax state aid cases, concluding in both decisions that it is appropriate for the European Commission to assess whether an advance pricing agreement (APA) confers a selective advantage to a taxpayer for state aid purposes by referring to the arm’s length principle. ... - Continue reading