Category: Legislation

Israel Tax Authority reintroduces voluntary disclosure

Ahead of the CRS agreement, the procedure enables Israelis to disclose unreported income without facing criminal proceedings. As reported last month by “Globes,” ahead of the anticipated implementation of the Common Reporting Standard (CRS) agreement for automatic exchanges of information between tax authorities, and given the Israel Tax Authority’s stepped...

Income tax law changes again

Tax residence gets new rules, support for R&D will increase and the spa industry gets new support instruments. The law on income tax is changing again. The Slovak parliament adopted extensive revisions on December 7, bringing changes in the definition of tax residence, new measures to support the spa industry...

17 NAMED ON EU TAX HAVEN BLACKLIST

EU ministers have issued the bloc’s “list of non-cooperative jurisdictions for tax purposes”. The blacklist was created following a November 2016 European Council decision–in the wake of the Panama Papers, Luxleaks and other revelations of multinational tax avoidance–to evaluate jurisdictions outside the EU. Territories were judged on “tax transparency”, “fair...

New PPT rule in the OECD’s Multilateral Instrument to displace Canadian GAAR?

In this Update On June 7, 2017, Canada signed the OECD’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) The MLI will modify up to 75 of Canada’s bilateral tax treaties, including adding a broad anti-avoidance rule to these treaties (the...

UK Offshore tax evaders face much higher penalties for non-compliance under new HM Revenue and Customs rules

UK Offshore tax evaders face much higher penalties for non-compliance under new HM Revenue and Customs rules. The legislation requires those with undeclared offshore tax liabilities to disclose them to HMRC before the 30th of September next year. When the Right to Correct rules come into force, offenders can expect...

Senate’s Offshore Tax Ideas Could Be a ‘Goldmine’ for Some Companies

Plan proposes 12.5% tax rate on intellectual-property income Bills ‘upend decades of U.S. tax policy’ on tight deadline U.S. companies that make billions of dollars from patents and other intellectual property held offshore would be eligible for a special 12.5 percent tax rate on those earnings under the Senate tax...

Bahamas Must ‘Get Across Line’ On Tax Automatic Exchange

THE Government has been urged to “get across the line before year-end” on global tax information exchange standards, amid hope the relevant legislation will reach Parliament tomorrow. Michael Paton, a former Bahamas Financial Services Board (BFSB) chairman, told Tribune Business that the Bahamas needed to upgrade its existing legislation to...

Bulgaria Requires CbC Reports By Year End

Bulgaria has said that multinationals covered by the country’s new transfer pricing country-by-country reporting regime should submit their first report by December 31, 2017. Through Order 3LIY-1410, Bulgaria’s National Revenue Agency has newly set out the rules concerning country-by-country documentation, including who the reporting obligations apply to and how to...

Dutch government continues with dividend withholding tax proposal and announces conditional retroactive amendment to CIT fiscal unity regime

In this Tax Alert we will briefly highlight two topical Dutch tax matters very relevant to internationally active companies: the current status of the legislative proposal regarding Dutch dividend withholding tax rules for holding cooperatives and BVs/NVs and the announcement of the Dutch Ministry of Finance that the Dutch fiscal...

Hong Kong Mulling Further Tax Breaks

The Hong Kong Government held a summit on October 23 to discuss new tax policies to boost the territory’s economy. Government officials recalled several recently announced taxation measures, including the two-tier profits tax rates regime and the enhanced deduction for research and development expenditure, and sought participants’ views on further...

“FATCA on steroids”: T&T misses 2017 deadline to become tax compliant

T&T faces possible sanctions after the Global Forum recognised this country as the only jurisdiction not considered to have made sufficient progress towards satisfactory implementation of the agreed tax transparency standards. Speaking at a media conference on Friday afternoon, Attorney General Faris Al Rawi said this has negative implications for...

Turkey: Turkey Updates Rules On Double Taxation Prevention Treaties For Independent Professional Services

Turkey has clarified rules for taxing income derived from independent professional services (and similar activities) carried out within Turkey, by residents of countries which have double taxation prevention agreements with Turkey. The number of days a company’s employees spent in Turkey will now become the only basis for calculating the...

CbCR obligations for Italian entity members of US groups

Concerns have arisen over a temporary misalignment between the US country-by-country reporting regime and Italian legislation. Antonella Della Rovere and Federico Vincenti of Valente Associati GEB Partners explain. An agreement for the automatic exchange of country-by-country reports (CbCR) between Italy and the US (Agreement) came into effect on September 27...

EU Approves Rules to Fix 900 Cross-Border Double-Tax Disputes

European Union finance ministers gave formal approval to legislation designed to dramatically reduce the 900-plus unresolved company cross-border double taxation disputes. The Oct. 10 approval for the EU Double Taxation Dispute Resolution Directivecomes amid skepticism from tax professionals that it has the resources to be effective. It includes mandatory binding...

Ireland Seeks Comment on International Tax Strategy Plans

The Irish government is inviting businesses and practitioners to provide feedback on its plans to update its international tax strategy, including how Ireland should incorporate the OECD’s transfer pricing guidelines into national law and implement the European Union’s anti-tax avoidance rules. The consultation, which runs until the end of January...