Category: Germany

Foreign allies to help Modi government dig deeper into black money data

NEW DELHI: India has found global allies in its fight against black money. Germany, France, Switzerland, Singapore, Mauritius and the British Virgin Islands are among those that are providing information, or will soon start doing so, on assets held by Indians, helping the Narendra Modi government in its campaign to… – Continue reading

OECD: countries commit to minimum standards on international tax dispute resolution

Countries should commit to minimum standards on the resolution of international tax disputes, the Organisation for Economic Co-operation and Development (OECD) said in a report published as part of its base erosion and profit shifting (BEPS) project.06 Oct 2015 The standards would include a commitment to “seek to resolve” cases… – 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

Global Tech Firms Brace for Tax Rules Which Could Create New Disputes

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

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

Corporate tax regime to face renewed scrutiny

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

China tax cut on small cars seen lifting sales, VW to benefit

BEIJING/SHANGHAI (Reuters) – China has halved sales tax on small cars to revive growth in the world’s biggest automobile market, a move likely to provide a limited boost to carmakers including Volkswagen AG (VOWG_p.DE), the company embroiled in a global diesel emissions scandal. The cut in sales tax on cars… – Continue reading

US$7.6tn hidden in tax havens – almost half annual US GDP

Gabriel Zucman, one of 3 French economists who in recent times have published extensive research on wealth and equality, in a book, ‘The Hidden Wealth of Nations: The Scourge of Tax Havens,’ published this month, estimates that 8% of the world’s financial wealth — some US$7.6tn — is hidden in… – Continue reading

Crunchtime for OECD global tax-avoidance push

Efforts to amend details of new rules on corporate profits raise questions, reports the Wall Street Journal. Nearly 50 governments are set to agree this fall to a new set of rules to clamp down on tax avoidance among multinational corporations. Their chance of success, however, is unclear. If the… – Continue reading

Common Rules (Not Rates) Should Be The Answer To Tax Competition In The EU

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

Corporate taxation system has reached its limits, say ministers and MEPs

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

MEPs: Make EU Corporate Tax System ‘Fairer’

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

Eurozone heavyweights resume tax offensive on multinational companies

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

High tax rate may deter global talent, warns Irish Tax Institute

Marginal rate ninth highest in 34 OECD countries, pre-budget submission claims Ireland risks deterring high- calibre foreign executives from moving here because of its relatively high tax rates, the Irish Tax Institute has warned. In a pre-budget submission, the institute said Ireland’s marginal tax rate of 52 per cent was… – Continue reading

New global tax crackdown could impact asset owners

A new wave of global tax compliance regulation is a game changer in the way asset owners and investment management companies report activities. Globalization of financial markets has made it increasingly simple to make, hold and manage investments outside an asset owner’s own tax domicile. A standard on automatic exchange… – Continue reading

Worldwide: Countering Harmful Tax Practices: BEPS Action 5 – Global Tax Update

Past Progress and Prospects Harmful tax practices (e.g., tax havens, preferential tax regimes, tax rulings) are characterised by the propensity to erode tax bases of other countries which allegedly leads to an undesirable race-to-the-bottom on taxation rates. Action 5 of the OECD Action Plan on Base Erosion and Profit Shifting… – Continue reading

Changing attitudes to tax reputation risk

Changing Attitudes to Tax Reputation Risk In recent years, it seems that any discussion of tax includes mention of the moral obligation taxpayers have to “pay their fair share.” Many believe this theme began to get traction in 2011 when Warren Buffett realized that he was paying proportionately less taxes… – Continue reading

The Changing Face of Luxembourg Finance

“Luxembourg is famous for two things: its steel industry and its rose cultivation industry”. This quote from an Italian guidebook of the 1930s was uttered by Luxembourg’s Finance Minister Pierre Gramegna at the annual conference of the Luxembourg Directors’ Association on 17 June 2015[1]. The economic outlook of the tiny… – Continue reading

Moscovici resolute on common corporate tax base

EU commissioner urges member states to ensure fair share of tax is paid EU economics commissioner Pierre Moscovici reiterated his commitment to re-launch the Common Consolidated Corporate Tax Base yesterday, urging all EU member states to ensure that companies pay their fair share of tax. Speaking following a meeting of… – Continue reading

Italy sees progress on euro zone financial transactions tax

The finance ministers of 11 euro zone countries willing to introduce a financial transactions tax (FTT) are expected to make progress on the thorny issue in a meeting on Saturday in Luxembourg, Italy’s economy minister said. Germany and France proposed the tax in 2012, in the midst of the euro… – Continue reading

The Case For A Territorial Tax Regime For Curaçao

Recently the Curaçao Minister of Justice, Mr. Nelson Navarro, approved the so-called Investor’s Permit to accommodate bonafide high net worth persons and entrepreneurs who seek admission to Curaçao. The purpose of the Investor’s Permit is for the investor to provide real economic benefit to Curaçao by increasing employment opportunities and… – Continue reading

The Implications for International Tax Planning From the Looming Fiscal Crisis

The international financial sector faces a perilous future. Major challenges loom over an uncertain global economy, while a decidedly negative political climate poses an existential threat to the offshore financial community. With each passing year, thanks to demographic changes and poorly designed fiscal policies, politicians from high-tax nations will be… – Continue reading

Private Eye data shows nearly £400 million of property in Milton Keynes bought by offshore companies

More than £375 million of land and property in Milton Keynes was bought by offshore companies between 2005 and 2014, according to research by Private Eye. The purchases are registered in a number of different countries, some of which are often described as tax havens. The countries buying the most… – Continue reading

German businesses criticise changes to investment fund taxation

German business groups have hit out at Berlin’s plan to reform how it taxes investment funds, warning on Thursday that the proposed changes would hurt pension provisions and reduce the attractiveness of Europe’s largest economy as a place to invest. The finance ministry announced plans in July to reform the… – Continue reading

Latest Central Bank move on banking oversight will help reduce risk

Lack of information about ‘opaque’ special purpose vehicles make it difficult to assess financial stability implications The legendary Warren Buffett once described some shadow banking activities as “financial weapons of mass destruction”. By that he meant they pose a huge threat to the global financial system, as these investment structures… – Continue reading

Taxing multinationals: Patently problematic

Proposals for consistent global rules on company tax cause worries all round CLARITY or chaos? Supporters of the Base Erosion and Profit-Shifting (BEPS) project, being worked on by the OECD, argue that it will bind multinationals to a consistent set of global tax rules, providing them with less licence than… – Continue reading

India, Germany to resume talks on DTAA revision

India and Germany have agreed to resume negotiations on partial revision of double taxation avoidance agreement (DTAA), the government said on Friday. The two countries have agreed to explore possibilities of enhancing tax related information while continuing to share information on the basis of existing agreements, the ministry of finance… – Continue reading

Five German-speaking finance ministers reaffirm common approach in the field of taxation, banking union and Greece

At their meeting in Salzburg, Pierre Gramegna, Austrian Finance Minister Hans Jörg Schelling, Liechtenstein Prime Minister and Finance Minister Adrian Hasler, the Swiss Finance Minister Eveline Widmer-Schlumpf and Germany’s Finance Minister Wolfgang Schaeuble employed in particular with international tax policy, the fight against tax optimization models overlooking the BEPS Initiative… – Continue reading

Ireland making ‘little or no’ effort to curb corruption – report

Ireland has made “little or no” effort over the past four years to create a corruption-free playing field for global trade, violating its “obligation to combat cross-border bribery”, reports the Irish Times. The Transparency International Exporting Corruption report, released on Thursday, found that Ireland, along with countries such as Russia,… – Continue reading

Worldwide: Double Tax Treaties – Ratification Update

LUXEMBOURG On September 5, 2014, the Ministers of Finance of France and Luxembourg signed an amendment (Lux Amendment) to the double tax treaty entered into between France and Luxembourg on April 1, 1958, as amended by the 1970 exchange of letters and by the 1970, 2006, and 2009 protocols (FR/Lux… – Continue reading

Bank pays €22 mn for Luxembourg tax evasion activities

(CS) German financial institution HSH Nordbank reportedly reached a 22-million-euro settlement with prosecutors in Cologne over setting up offshore companies through Luxembourg to hide client assets from tax authorities. Newspaper “Süddeutsche Zeitung” and broadcasters NDR and WDR first reported on the deal on Tuesday. Allegedly, HSH Nordbank approached the prosecutor’s… – Continue reading

Aircraft overhaul expenses continue to be “fees for technical services” but not taxable absent source in India

In DIT vs. M/s. Lufthansa Cargo India: TS- 299-HC-2015, the Delhi High Court held that payment made by assessee (an Indian company) to German company for carrying out overhaul repairs to aircrafts was fees for technical services (“FTS”) under section 9(1)(vii) of the Income Tax Act, 1961 (“the IT Act”)… – Continue reading

Private equity braced for global tax changes

The private equity industry has long been known for its ability to take advantage of tax rules. But international changes are set to have an impact on their businesses. After a string of multinationals such as Apple, Google and Starbucks came under fire for paying minimal tax on their British… – 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

Tax Horror Defying Modi Causes AIG to Shun Cover for India Deals

Prime Minister Narendra Modi needs to offer much more than just his best intentions to clean up India’s whimsical tax regime to help convince insurers. Companies from Allianz SE to American International Group Inc. are avoiding offering tax-liability coverage in India’s cross-border mergers and acquisitions market because of a relatively… – Continue reading

OECD likely to recommend fixed ratio cap on interest tax deductibility, says expert

The Organisation for Economic Co-Operation and Development (OECD) is likely to recommend that restrictions on interest deductibility should mainly involve a cap calculated as a percentage of EBITDA, an expert has said.07 Aug 2015 Corporate tax Tax International tax Energy Infrastructure However Heather Self of Pinsent Masons, the law firm… – Continue reading

Luxembourg’s Euro Note Love Affair Raises Eyebrows Over Taxes

While the European single currency’s existential crisis drags on in Athens, it turns out Luxembourg likes its euros — a lot — as foreigners with accounts in the Grand Duchy try to stay one step ahead of the taxman. Luxembourg’s central bank issued 15 percent more euro notes in 2013,… – Continue reading

Germany: Taxation of Foreign Investment in Germany

Germany has the largest economy in Europe. Along with the developed infrastructure, investors will also benefit from the advanced technology that will ease integration in many industrial sectors, and the highly specialized as well as educated workforce. In terms of the taxation of foreign investment, the taxation system in Germany… – Continue reading

OECD Common Reporting Standard to come into effect in Canada on July 1, 2017

Canadian financial institutions will be subject to the Organisation for Economic Co-operation and Development’s (OECD) Common Reporting Standard as of July 1, 2017 with the first exchanges of financial account information beginning in 2018. The CRS, known formally as the Standard for Automatic Exchange of Financial Account Information in Tax… – Continue reading

Huddersfield ‘mastermind’ behind one of Europe’s biggest tax frauds expected to face justice in Germany

A Huddersfield tycoon, accused of masterminding one of Europe’s biggest tax frauds, is expected to be extradited from the USA to Germany. Mohammad Safdar Gohir has been in a Las Vegas jail for more than a year and is now awaiting deportation to Germany following a US court’s decision. Gohir,… – Continue reading

Canada: Interest Deductibility In Canada: What’s The Fuss?

This article deals with the manner in which Canada has complicated, and rendered controversial, what in most other countries is straightforward — the deductibility of business related interest expense. The reasons to write about it are threefold: the almost-concurrent issuance of the Canada Revenue Agency’s administrative views on the matter… – Continue reading

The Netherlands: Recent Financial, Regulatory and Legislative Developments

With the focus of 2014 being international tax competition, 2015 shows signs of continuing this trend. The European Commission (COM) and European Parliament (EP) are starting to debate and extensively investigate Member States’ tax ruling policies, partly as a result of the LuxLeaks revelations and partly in relation to the… – Continue reading

Britain’s favourite retailer is… Amazon! Poll reveals how much shoppers love online giant branded a tax avoider

Amazon has topped a poll to find Britain’s favourite retailer – despite being dogged by allegations of tax avoidance and not paying staff well. The online retailer, which is also embroiled in a row over authors’ rights, came first in a huge survey of British consumers carried out by media… – Continue reading

Switzerland, Germany agree deal on cross-border banking

Switzerland and Germany have reached an agreement on the provision of cross-border banking services, reports Tax News. The agreement clarifies issues regarding the delayed implementation of the 2013 bilateral Memorandum on the cross-border provision of financial services. As a result, Swiss banks are now eligible to apply under the simplified… – Continue reading