Category: Luxembourg

France, Luxembourg amend tax treaty, affecting investment structures of Luxembourg vehicles holding French real estate

The French and Luxembourg governments have signed a new amendment to the French-Luxembourg tax treaty that will significantly impact the investment structures involving Luxembourg vehicles holding French real estate assets. This amendment, signed early in September, will come into force once the ratification process by the respective parliaments of both… – Continue reading

Minecraft, Nokia, Skype: How Microsoft Buys Overseas Companies To Avoid US Taxes

Nokia, Skype and Minecraft-maker Mojang have more in common than just the fact that they are among Microsoft’s biggest acquisition targets in recent years. They are all also based outside the U.S., and that’s no coincidence. As the debate over so-called inversions heats up and critics — from President Obama… – Continue reading

Twitter accounts point to UK sales heading offshore

Twitter is funnelling much of the revenue it generates in Britain through an offshore sales structure, newly published annual accounts suggested today. Twitter UK has filed abbreviated 2013 accounts for a small company under Companies House rules, which are usually applicable to a business with an annual turnover of less… – Continue reading

International Tax Alert: OECD Releases BEPS Papers

Yesterday saw the release of the first set of deliverables under the OECD’s project on base erosion and profit shifting (BEPS).  These constitute the “building blocks” for an internationally agreed and co-ordinated response to government and media concerns in recent years about the perceived way in which shortcomings in relevant… – Continue reading

ICBC to clear RMB business in Luxembourg

BEIJING, Sept. 16 (Xinhua) — The Luxembourg branch of China’s largest lender, ICBC, has been appointed as a clearing bank for renminbi business in the European country, the Chinese central bank said on Tuesday. The People’s Bank of China (PBOC) made the decision in accordance with a memorandum of understanding… – Continue reading

Since 2010, Burger King Has Reduced Its World Wide Tax Rate by 60%

American taxpayers are being robbed by yet another giant corporation that is deserting the USA after using the country’s advantages to build untold wealth. Burger King’s recent decision to pursue a corporate inversion to Canada is the culmination of years of maneuvering to dodge paying its fair share in corporate… – Continue reading

FOURTH AMENDMENT OF THE LUXEMBOURG AND FRANCE DOUBLE TAX TREATY

The French and Luxembourg Finance Ministers signed, on 5 September 2014, a Protocol amending Article 3 (the “Protocol”) of the France-Luxembourg double tax treaty for the avoidance of double taxation and the establishment of rules of reciprocal administrative assistance with respect to taxes on income and fortune (the “Tax Treaty”)…. – Continue reading

BNY Mellon backs London to lead European race for offshore RMB

London and Singapore are fast closing the gap on Hong Kong in the race to become centres for offshore renminbi business and capitalise on Beijing’s ambition to make the RMB a global currency. Fred DiCocco, Asia-Pacific head of sales & relationship management for BNY Mellon’s Treasury Services business, says London… – Continue reading

Minister’s offshore business to be re-investigated

The offshore tax affairs of a company previously headed by the economics minister are to be re-examined by the finance department of canton Bern. The move comes after Swiss Public Television, SRF, published a memo written by the Federal Tax Authorities (FTA) which raised questions about the previous investigation. The… – Continue reading

Investment in French real estate: France-Luxembourg double tax treaty changes

On 5 September 2014, the Governments of France and Luxembourg signed an amendment to the France-Luxembourg treaty dated 1 April 1958 (the “Treaty”), which will have an impact in the future for certain investments in French real estate. Indeed, the amendment introduces new provisions under Article 3 paragraph 4, allocating… – Continue reading

Most Dutch banks are ‘vague’ about tax avoidance: fair banking report

Seven Dutch financial institutions may be involved in evading taxes and are ‘extremely vague’ about what they do to ensure this does not happen, the Dutch Fair Bank Guide said on Wednesday. ABN Amro, Aegon, Delta Lloyd, ING, NIBC, Rabobank and Van Lanschot emerge as potential tax avoiders in research… – Continue reading

Luxembourg first country to issue sovereign Sukuk in the Eurozone

On 9 July 2014, Luxembourg Parliament voted a law aimed at allowing the issuance of the first Luxembourg sovereign Sukuk in response to the recent surge in investor demand for Sharia-compliant instruments. In a nutshell, the law authorizes a sale and buy-back transaction of real estate assets to a Special… – Continue reading

Black Money issue – SIT on a Wild Goose Chase?

More to the point, extant global financial architecture facilitates transfer of illicit money through the Hawala route first to a Tax Haven, only to launder it in specialised locations like London. “There are 42,800 persons – let me repeat, only 42,800 persons – who admitted to a taxable income exceeding… – Continue reading

Premiers need to act on tax havens and the CRA

Ottawa (27 Aug. 2014)—Premiers and territorial leaders in Charlottetown for the Council of the Federation need to demand the federal government and the Canada Revenue Agency (CRA) stem the flow of Canadian money offshore because it is depleting revenues by at least $7.8 billion each year. Retrieving that money could… – 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

U.S. businesses moving overseas to dodge taxes

NEW YORK — There’s more than one way for a U.S. company to avoid taxes by claiming a foreign address. Consider the business founded in 1916 as General Plate Co., a maker of sensors and controls for everything from Fords and Frigidaires to the spaceship that first carried Americans to… – Continue reading

Review of patent tax regimes in EU has Irish support

Ireland can adopt ‘wait-and-see’ approach on tax breaks, says Department of Finance Ireland supports the EU review of all patent box regimes – under which certain member states offer tax breaks for intellectual property – and has decided to take a “wait-and-see approach” on the issue until guidance is provided… – Continue reading

Billionaire Eugene Melnyk: I’m a ‘whistleblower’ on tax allegations against Valeant

MONTREAL • Eugene Melnyk, the billionaire owner of the Ottawa Senators and founder of drug maker Biovail Corp., is waging war against the company that now controls his one-time business. Mr. Melnyk alleges that Valeant Pharmaceuticals International Inc. is masquerading as a Canadian company to make use of this country’s… – 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

Amazon’s Luxembourg taxes under scrutiny – FT

(Reuters) – European officials have asked Luxembourg to hand over documents relating to U.S. online retailer Amazon’s tax affairs in the country, the Financial Times reported on Thursday, citing official sources. The EU’s competition commission has requested information from the Grand Duchy, where the online retailer’s main European operating company… – Continue reading

Luxembourg defends tax regime

(CS) The Luxembourg Finance Ministry on Thursday published a statement defending its tax regime, following the launch of an EU probe into deals with multinationals in several members states. The investigation aims to determine whether special tax deals could amount to illegal state aid. Affected companies include Apple, Starbucks, Google,… – Continue reading

European Union is examining overseas tax breaks for Apple, Starbucks and Fiat

The European Commission raised pressure on Ireland, the Netherlands and Luxembourg over their corporate tax practices, saying it was investigating deals the countries have cut with Apple, Starbucks and Fiat. The Commission, the executive body of the European Union, is looking at whether the countries’ tax treatment of multinationals that… – Continue reading

EC launches Apple tax investigation

EC launches Apple tax investigation The European Commission has launched a formal investigation into Apple’s tax arrangements in Ireland The EC has announced three “in-depth investigations” into the transfer pricing arrangements on the corporate taxation of Apple, Starbucks in the Netherlands and Fiat in Luxembourg, as to whether they comply… – Continue reading

Apple, Starbucks Tax Deals With Irish, Dutch Probed by EU

Tax breaks for Apple Inc. (AAPL:US), Starbucks Corp. (SBUX:US) and Fiat Finance & Trade SA in three European Union countries are under investigation by EU competition regulators in a clampdown on special treatment for companies. The EU is checking whether the tax deals in Ireland, the Netherlands and Luxembourg are illegal state aid, according to… – Continue reading

EU investigates tax rulings on Apple, Starbucks, Fiat

Reuters) – The European Commission raised pressure on Ireland, the Netherlands and Luxembourg over their corporate tax practices, saying it was investigating deals the countries have cut with Apple, Starbucks and Fiat. The EU is looking at whether the countries’ tax treatment of multinationals, which help to attract investment and… – Continue reading

Amazon Facing Fresh UK Tax Avoidance Row

The internet retail giant Amazon is facing fresh claims of tax avoidance after its latest accounts showed it routed more than £11 billion through its Luxembourg-based subsidiary in 2013 – yet paid only £4 million in UK corporation tax last year. Amazon trades through the Luxembourg subsidiary, Amazon EU SARL,… – Continue reading

Luxembourg, US Sign FATCA Deal

Luxembourg and the US have signed an intergovernmental agreement (IGA) to implement the Foreign Account Tax Compliance Act (FATCA). Luxembourg and the US negotiated a Model 1 IGA, requiring the Luxembourg Tax Administration and the US Internal Revenue Service (IRS) to exchange information automatically on accounts held by US citizens… – Continue reading

KKR’s Entry Into Canadian Oil Patch Crimped by Tax Clampdown

Canada is clamping down on off-shore tax shelters used by private-equity funds, in a move that may curb investment in the oil and gas industry by KKR & Co. and Blackstone Group LP. (BX) The government has given private-equity firms and other interested parties until April 11 to respond to proposals tucked… – Continue reading

Swiss tax allies falling by the wayside

The decision by Luxembourg and Austria to automatically exchange tax data with other European Union countries has isolated Switzerland in the global crusade against banking secrecy, a Tax Justice Network (TJN) expert tells swissinfo.ch. The two European Union states caved in to demands last month by signing up to the revised… – Continue reading

Luxembourg Supports New Savings Tax Directive

Luxembourg’s Prime Minister Xavier Bettel said the conclusions adopted at the recent European Council meeting on the revised Savings Tax Directive have enabled “a green light from the Grand Duchy of Luxembourg.” He expressed his satisfaction that all 28 European Union (EU) member states reached an agreement at the latest… – Continue reading

Caterpillar to face U.S. Senate panel on offshore taxes

WASHINGTON (Reuters) – Caterpillar Inc’s offshore tax strategies will come under scrutiny on Tuesday at a U.S. Senate hearing expected to examine dealings by the world’s largest mining and construction equipment maker in Switzerland, Bermuda and Luxembourg. With many multinationals being criticized for tax avoidance, veteran tax sleuth Senator Carl Levin… – Continue reading

The plea deal of an ex-banker details tax-evasion schemes

As part of a plea agreement, an ex-Credit Suisse banker recently disclosed how U.S. customers avoided offshore account disclosure requirements. In an effort to crack down on offshore accounts, federal prosecutors have stepped up investigations of the largest Swiss banks, their bankers and account holders. The most recent bank to… – Continue reading

EU adopts landmark directive to crackdown on tax evasion

The European Union has formally adopted the Savings Tax Directive after six years of negotiations. The directive is intended to bolster the power of the EU to crackdown on tax evasion. The measure was adopted shortly after Luxembourg and Austria abandoned their opposition to the plan. EU tax commissioner Algirdas Semeta, commenting… – Continue reading