Category: Europe

Tax laws of 12 low-tax countries including BVI, Bermuda, Cayman don’t harm other countries, 131-country group concludes

An OECD-led 131-country coalition, known as the “Inclusive Framework on BEPS,” has approved an assessment which concludes that 12 low or zero-tax countries do not have “harmful” tax regimes, the OECD today announced. ... - Continue reading

Taxpayers given six months to challenge Denmark transfer pricing assessments based on insufficient documentation

A Danish tax administration decree, published 12 July in response to the Supreme Court’s decision in the Microsoft case, establishes a new practice for determining whether transfer pricing documentation must be available at the time the taxpayer is required to file its tax return. ... - Continue reading

European Union: Dutch Implementation Proposal On EU Anti-Hybrid Measures

On July 2, 2019, the Dutch government published the legislative proposal implementing the EU Anti-Tax Avoidance Directive II (ATAD II) that was adopted on May 29, 2017. The ATAD II mandates EU Member States to implement rules that target hybrid mismatches by January 1, 2020 (specific sections by January 1, 2022). ... - Continue reading

Netherlands draft law requires disclosure of cross-border transactions to tax authorities

On July 12 the Netherlands government published a legislative proposal implementing the EU mandatory disclosure directive. This follows an internet consultation on a draft legislative proposal which ran from December 19, 2018 — February 1, 2019. ... - Continue reading

Gibraltar and UK Open Negotiations to Enter into a Double Tax Agreement

The Government of Gibraltar has said it is delighted to welcome Robert Jenrick, Exchequer Secretary to Her Majesty’s Treasury, to Gibraltar to announce that HMGoG and Her Majesty’s Government have opened negotiations to enter into a Double Tax Agreement. It is anticipated that with hard work on both sides a… – Continue reading

Portugal: Central bank to disclose public report on large debtors

The Bank of Portugal (BdP) is to publicly disclose aggregated information about large bank debtors by 17 July, announced the chair of the Budget and Finance Committee. On 23 May, the central bank sent parliament an extraordinary report on the problematic loans and other assets that caused banking problems and… – Continue reading

Tensions between the drive for transparency and the right to protection of privacy

Update on the UK government’s proposal to improve transparency with a new register of persons with significant control of companies which hold UK property. In our last article (https://hubbis.com/article/transparency-enhanced-in-the-uk) we looked at the UK government’s proposal to improve transparency with a new register of persons with significant control of companies… – Continue reading

Experts convene in the City of London to call out ‘pin stripe mafia enablers of tax abuse’

Researchers and campaigners from around the world have been presenting radical solutions on tackling tax abuse and financial crime at the Tax Justice Network’s annual conference held in the heart of London’s finance centre, on 2 – 3 July 2019. With over 200 attendees including prominent politicians, whistleblowers and economists,… – Continue reading

Uzbekistan: Karimova says she returned $1.2Bln to state coffers

The fate of funds in foreign accounts remain in the balance, however.The imprisoned daughter of Uzbekistan’s late president has reportedly published a statement tentatively admitting responsibility for years of larceny and said that she has paid $1.2 billion into the state coffers. Gulnara Karimova’s statement was posted on an Instagram… – Continue reading

HMRC defeated as Jersey companies deemed not UK-resident

The UK’s Upper Tribunal has decided that three special purpose vehicles (SPVs) incorporated in Jersey as part of a tax planning arrangement were not tax resident in the UK for tax purposes, overturning a 2017 decision from the First-tier Tax Tribunal. Development Securities, a property and investment group based in… – Continue reading

Chief of the economy for tax cuts

The head of the economic experts, Christoph Schmidt, has spoken out for tax cuts. “Other countries such as the United States have reduced business taxes. Germany has fallen back in the international tax competition,” said Schmidt of the German press Agency in Berlin. The tax burden had increased in the… – Continue reading

Luxembourg: Tax Dispute Resolution Mechanism

The Bill of Law 7431 (“Bill”) introduced by the Luxembourg government on 11 April 2019 implements the European Union (“EU”) Directive 2017/1852 dated 17 October 2017 on tax dispute resolution mechanisms in the EU (the “Directive”). The Directive meets the BEPS Action Plan 14 minimum standards and is a subsidiary… – Continue reading

Canada: With Recent Regulatory Developments, Canadian Business Interest In Cayman Will Grow

Canada is home to some of the largest multinational corporations in the world, a bustling pension fund and private equity industry, and growing numbers of alternative investment, real estate, and insurance shops. With dynamic industry and growth in the region, Canadian business leaders are leveraging Cayman as a financial centre to help… – Continue reading

Cyprus: The True Impact Of BEPS On International Business Structures

In the last decade, OECD officials have recommended measures to combat tax avoidance, culminating first in the BEPS (Base Erosion and Profit Shifting) initiative in 2015 and then the MLI (Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS) effective from July 2018 – yet have all their… – Continue reading

British overseas territories top corporate tax loophole index

Governments are stepping up efforts to recoup more tax from multinationals, with the European Commission forcing iPhone maker Apple to repay 13 billion euros after it used Ireland to cut its tax on European profits to almost zero. The Tax Justice Network, a group campaigning for transparency, said its study… – Continue reading

Cyprus: Cyprus–Kazakhstan First-Time Double Tax Treaty: Cyprus Ratifies

On 24 May 2019, Cyprus ratified the first-time double tax treaty it had signed with Kazakhstan on 15 May 2019 (the DTT). Certain legal procedures now need to take place in both states following which the DTT will ‘enter into force’. The DTT will be ‘in effect’ as from the… – Continue reading