Category: Denmark

Just how dirty is offshore money?

David Cameron threw the proverbial cat among the pigeons in July when, with a steely glare at the UK property industry, he warned that the UK must not become “a safe haven for corrupt money from around the world” and that “there is no place for dirty money in Britain”…. – Continue reading

BEPS: CURRENT STATUS OF IMPLEMENTATION IN VARIOUS COUNTRIES

Last week’s OECD release of the final package of measures for a coordinated international approach to the reform of the international tax system, under the OECD/G20 base erosion and profit shifting (BEPS) project, marks the end of the discussion and recommendation phase, and the start of the implementation and practical… – Continue reading

NBR to sign deal with Bhutan to avoid double taxation

Bangladesh is set to sign an agreement with Bhutan to avoid double taxation to boost investments, trade and facilitate information exchange between the two Saarc nations, the National Board of Revenue said in a statement. A team led by NBR Chairman Md Nojibur Rahman is now in Thimpu to take… – Continue reading

NORWAY: BUDGET 2016; MORE ABOUT PROPOSED TAX REFORM

The Norwegian conservative government on 7 October 2015 published both the proposed state budget for 2016 and a “white paper” containing proposals for tax reform. The proposed tax reform in the white paper is a follow-up action from a report on tax reform, presented by the Tax Commission in late… – Continue reading

Gaming the System: Underlying Problems of the U.S. Tax Code Must be Addressed

Last year at this time, news about “tax inversions” was grabbing headlines – cases where large U.S. multinationals would buy a foreign company in a tax-friendly jurisdiction, and then relocate its headquarters to reap the tax arbitrage benefits. The Obama administration responded to the rash of high-profile inversions with new… – Continue reading

Internal Revenue Service Begins Reciprocal Automatic Exchange of Tax Information Under FATCA IGAs

On October 2, 2015, the Internal Revenue Service announced that it had achieved a key milestone in implementation of the Foreign Account Tax Compliance Act (FATCA), a critical anti-tax evasion law passed by Congress in 2010 but not fully implemented until July 2014. The milestone announced by the IRS was… – Continue reading

It’s Here; The Automatic Exchange of Information Under FATCA Began September 30th

The IRS has announced that as of September 30, 2015 it will implement the automatic exchange of tax information as set forth in the Foreign Account Tax Compliance Act, (FATCA). The IRS Commissioner in announcing the implementation of the automatic exchange of information stated: “This information exchange is part of… – Continue reading

A Tax Revolution in the Making in EU

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

Orders on tax information exchange agreements with Nordic jurisdictions and protocol on avoidance of double taxation arrangement with the Mainland gazetted

Hong Kong (HKSAR) – Six orders for implementing the tax information exchange agreements (TIEAs) with six Nordic jurisdictions (i.e. Denmark, the Faroes, Greenland, Iceland, Norway and Sweden), and an order for implementing the Fourth Protocol to the Comprehensive Arrangement for the Avoidance of Double Taxation with the Mainland (the Arrangement)… – Continue reading

Denmark Legislates For CbC Reporting

On September 18, 2015, the Danish Ministry of Taxation published draft legislation to introduce a new country-by-country reporting obligation for multinational corporations. The draft Bill would introduce the new three-tiered approach to transfer pricing documentation that is to be proposed formally by the OECD as part of the BEPS deliverables… – Continue reading

Gov’t, Denmark reach double taxation deal

The Danish government is hopeful ratification of the convention for avoidance of Double Taxation agreements (DTA) with Ghana — and the Prevention of Fiscal Evasion with respect to taxes on income and capital gains between the two countries — will help to double Denmark’s investment in the country. This brings… – Continue reading

OECD establishes roadmap for membership with Lithuania

10/07/2015 – The OECD set out a clear path for Lithuania’s accession to the Organisation, reinforcing the OECD’s commitment to further extend its global membership. On 8 July 2015 the 34 OECD Members adopted the Roadmap for the Accession of Lithuania to the OECD Convention setting out the terms, conditions… – Continue reading

FATCA – Which Countries Are In And Out

FATCA – Which Countries Are In And Out The controversial US Foreign Account Tax Compliance Act (FATCA) law is set to start from July 1, 2014, so with less than 21 days to go, here’s a look at which countries are in and who is outside of the tax network…. – Continue reading

St. Kitts-Nevis Among 30 Countries On EU’s Tax Evasion Blacklist

St. Kitts and Nevis is one of 30 countries placed on the European Union’s black list for not doing enough to fight tax evasion. The EU’s executive Commission published the list Wednesday (June 17). The blacklisted countries figure on at least ten of the EU’s 28 member nations’ lists of… – Continue reading

Bermuda named on EU tax haven list

The European Union: Labelled Bermuda as a tax haven Bermuda has been named by the European Union as a country that is not doing enough to crack down on tax avoidance. The Island was one of 30 countries on the list published by the EU’s executive Commission today. “These tax… – Continue reading

Switzerland: Total Return Swaps – Swiss Federal Supreme Court Sides With Federal Tax Authority (FTA) By Denying Reimbursement Of WHT

On 5 May 2015 the Federal Supreme Court rendered its long awaited decision on a withholding tax (WHT) reimbursement claim related to Total Return Swaps. The case was based on essentially the following facts: a Danish bank entered into swap contracts with clients in England, Germany, France and the US…. – Continue reading

Those Gruelling U.S. Tax Rates: A Global Perspective

The Tax Foundation released its inaugural “International Tax Competitiveness Index” (ITCI) on September 15th, 2014. The United States was ranked an abysmal 32nd out of the 34 OECD member countries for the year 2014. (See accompanying Table 1.) The European welfare states such as Norway, Sweden and Denmark, with their… – Continue reading

Ireland: Private Client Tax Ireland

1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins The legal system of the Republic of Ireland is a common law system. In order to ensure consistency, a legal principle developed whereby courts were generally required to follow earlier relevant decisions. This doctrine of… – Continue reading

UK Firms, Economy Burdened By High Tax Rates

The UK is inhibiting its economy with a tax burden 18 percent heavier than the global average and should consider setting a specific target for lowering the overall tax take, according to research by accountants UHY Hacker Young. UHY’s findings show that tax revenue in the UK represents a third… – Continue reading

Global Tax Transparency Goes Live in 2016

Cross border tax fraud and tax evasion by High Net Wealth Individuals (HNWI) are serious problems for many jurisdictions. For many years exchange of information between countries has been solely upon request. In practise this procedure is not efficiently working as it requires foreseeable relevance, thus ‘fishing’ for information is… – Continue reading

Dividend imputation clears an early tax review hurdle

Government questions dividend imputation and company tax rate Australian investors appear to have dodged a bullet, with the government’s first paper on tax reform discussing the dividend imputation system but falling short of attacking it outright as an idea that has outlived its usefulness. David Murray’s inquiry into the Australian… – Continue reading

Luxembourg: Luxembourg’s Direct Tax Administration Publishes Circular On Residency Certificates For Funds

Luxembourg’s Direct Tax Administration has published a circular on February 12 clarifying issues relating to residency certificates for Luxembourg funds. These are applicable to both UCITS and non-UCITS funds regulated by Luxembourg’s investment fund legislation of December 17, 2010, which transposed the UCITS IV Directive, as well as Specialised Investment… – Continue reading

Erin Go Bragh! American Companies See Green in Ireland

Irish eyes are smiling in corporate America. The Emerald Isle has emerged as the world’s top recipient of U.S. foreign direct investment, according to a report from the American Chamber of Commerce Ireland. In the first nine months of 2014, Ireland beat the likes of Canada, Mexico, the U.K. and… – Continue reading

Things just got worse for HSBC: Here’s what you need to know

Things just got worse for HSBC. Its private banking arm faces new criminal charges after a French magistrate officially requested that the Swiss bank be brought to trial over a suspected tax-dodging scheme for wealthy customers, the Guardian reports. The request for trial comes after a series of allegations against… – Continue reading

Hungary and Luxembourg sign agreement to avoid double taxation

Representatives of the governments of Hungary and Luxembourg signed an agreement to eliminate double taxation on the sidelines of a meeting of EU finance ministers, the economy ministry said. The new agreement, signed by Economy Minister Mihály Varga and counterpart Pierre Gramegna, replaces an earlier one signed in 1990. It… – Continue reading

‘The age of financial privacy is over’

Jonathan Weiss hasn’t lived in the US for 25 years. But that didn’t keep his foreign bank account from being frozen in the wake of new US tax laws. Find out how you can avoid the same fate at the hands of FATCA. “I had been living in Switzerland for… – Continue reading

Techie fee thorn in US ties

New Delhi, Jan. 23: India and the US have failed to make much progress in the totalisation pact that addresses the the problem of the double payment of social security taxes by Indian software professionals in America, dampening expectations surrounding President Barack Obama’s visit this weekend. Top officials said discussions… – Continue reading

EU shines light on dirty money with central registers

The European Union has agreed rules to stamp out tax evasion and stop dirty money from criminal gangs or terrorism finance being channelled through anonymous companies. EU states and the European Parliament struck the agreement on Tuesday evening to update the bloc’s anti-money laundering rules, a statement from parliament’s economic… – Continue reading

Leading financial centres ‘must act on corruption’, says watchdog

China and Turkey have fallen in international rankings of perceived corruption, according to a new report released by the Berlin-based anti-corruption watchdog Transparency International (TI).09 Dec 2014 Regulatory Europe Asia Pacific Gulf Africa According to the latest edition of TI’s Corruption Perceptions Index for 2014, which scores countries on a… – Continue reading

International Collection Efforts by the IRS – Expanding the Number of Treaties in which We Have Collection Language

The United States has treaty language that allows us to work with the taxing authorities in other countries to collect U.S. taxes owed from U.S. Citizens or their property located in those countries and to allow those countries to have IRS collect from their citizens or property located in the… – Continue reading

Denmark – Withholding tax on dividends distributed to investment funds

November 12: Danish companies subject to Danish corporate income tax generally must withhold tax at a rate of 27% on dividend distributions, but the rate of the withholding tax may be reduced to 15% when dividends are distributed to Danish domiciled investments funds that are known as “IMBs” (i.e., investment… – Continue reading

Min4ister wants to stop country from being used as a tax haven

Government intends to crack down on misuse of Danish companies The minister for business and growth, Henrik Sass Larsen, announced yesterday a new set of law proposals designed to stop Denmark being used as a tax haven. The move comes in the wake of a wave of media attention around… – Continue reading

Commission’s Tax Drive Unsettles Multinationals

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

Wealth Inequality Accelerates Worldwide on Inheritance, Tax Avoidance

Wealth inequality is growing worldwide, according to a new report by Credit Suisse. A greater share of wealth is being held by a smaller number of ultra-rich families worldwide as larger inheritances, family trusts, and similar arrangements to avoid taxes help the ultra-wealthy gain a greater portion of total capital… – Continue reading

Facing up to Fatca

This article was first published in the 2nd quarter 2014 edition of Personal Finance magazine. Most people accept that they have to pay taxes in their country of residence. But citizens of the United States and green card holders who live outside that country – even if they have never… – Continue reading

101 Countries Sign Up For FATCA Network

Foreign Account Tax Compliance Act (FATCA) has been in force for a month and still more countries are joining the tax network. So far, 101 countries and financial jurisdictions have either signed or agreed to join FATCA. FATCA is aimed at identifying US taxpayers with offshore bank accounts and investments. Overseas… – Continue reading

Corporation tax: Rate cut likely as Prime Minister David Cameron set to let Northern Ireland go it alone

Northern Ireland looks set to be handed the power to slash corporation tax in a move with the potential to significantly boost our stuttering economy. In a development which could transform international investment, senior sources in London and Belfast predict that an announcement will be made no later than October… – Continue reading

Denmark – A Tax Haven?

Artur Bugsgang, partner at leading Danish law firm LETT looks at Denmark’s tax advantages. Denmark currently ranks fifth in the world in their ease of doing business index. The country is significantly less bureaucratic than the majority of its European neighbours, especially in regard to establishing and operating companies. Despite… – Continue reading