Category: Europe

HMRC updates common reporting standard guidance

The move comes after HM Revenue & Customs received representations from the Association of Charitable Foundations and the Charity Finance Group HM Revenue & Customs has updated its guidance on the forthcoming common reporting standard after receiving concerns from charities. The CRS is an international standard for the automatic exchange… – Continue reading

BEPS – Germany on the way to limit the tax deductibility of royalties

A new legislative approach of the German tax authorities leaked last December 19 will have a significant impact on the tax deductibility of royalties owed to related persons being subject to a preferential back end tax regime for IP not being in compliance with the Organisation for Economic Co-operation and… – Continue reading

Multilateral Instrument: The new dilemma of foreign investors

MUMBAI: The Multilateral Instrument (MLI), a new global tax avoidance agreement, that is in the process of being signed by 100 countries, is now causing a lot of anxiety among foreign portfolio investors (FPIs). MLI is an agreement put out by OECD, the intergovernmental economic organisation, to stop Base Erosion… – Continue reading

Senators tell new US treasury secretary nominee to eliminate Cayman Islands and other tax havens

WASHINGTON, USA — Members of the United States Senate, questioning the new Trump administration nominee for Treasury Secretary on Thursday, asked Steve Mnuchin how he intends to close down Caribbean tax havens, specifically naming the Cayman Islands. The Senate panel demanded details on how the new secretary expects to close… – Continue reading

Bahamas Will ‘Do All It Can’ To Avoid Eu Blacklisting

The Bahamian financial services industry “will do all we can” to ensure this nation does not appear on a threatened European Union (EU) ‘blacklist’, Tribune Business was told yesterday. Tanya McCartney, the Bahamas Financial Services Board’s (BFSB) chief executive, said this nation’s implementation of the Common Reporting Standard (CRS) for… – Continue reading

2017 Budget Law: tax relief for individuals who decide to fix their tax residence in Italy

The 2017 Italian Budget Law introduces a tax relief for individuals transferring their tax residence to Italy, in accordance with similar regimes adopted by other countries such as the United Kingdom, Switzerland and Portugal. The relief is part of a package of measures intended to facilitate investment in Italy and… – Continue reading

Davos 2017: Oxfam attacks failing global tax avoidance battle

World Economic Forum debate hears how fight to make companies ‘pay their fair share’ is being undermined by race to cut corporation tax rates Efforts to tackle global tax avoidance are being undermined by a “race to the bottom” on corporate tax rates led by Britain and the US, the… – Continue reading

International tax-avoidance rules may override GAAR, other tax treaties

There is a possibility that the General Anti-Avoidance Rules (GAAR, on taxes) and the tax treaties signed by the government with those of Mauritius, Singapore and Cyprus, and even other nations such as Netherlands, could be overtaken by another event. These could, say experts, be partially or fully overridden by… – Continue reading

New tax regime for Ukrainian loan participation notes issued on international capital markets

January 2017 – On 21 December 2016, Ukraine’s parliament adopted the Law “On Amendments to the Tax Code of Ukraine Concerning Improvement of the Investment Climate in Ukraine” No. 1797-19. With effect from 1 January 2017, the legislation introduces new rules for the taxation of interest payable by Ukrainian economic… – Continue reading

Latvia and Japan sign agreement intended to promote investment and make investors’ work easier

RIGA – Latvian Finance Minister Dana Reizniece-Ozola (Greens/Farmers) and Motome Takisawa, Parliamentary Vice-Minister for Foreign Affairs of Japan, today signed a convention for the elimination of double taxation with respect to taxes on income and the prevention of tax evasion and avoidance, BNS was told at the Finance Ministry. The… – Continue reading

German Multinationals Fear Disclosure of Global Tax Reports

Multinational companies headquartered in Germany worry that when they report their global tax and profits for 2016, some countries will leak their country-by-country reports to the press. German parents of multinational groups with annual consolidated group revenue of at least 750 million euros ($797 million) are required to file, with… – Continue reading

U.S. tax reform plan “not likely” to badly impact Canada: Expert

WASHINGTON — An American tax authority who helped champion a reform now being considered by the U.S. Congress says Canada would not be among the countries hardest hit by the introduction of so-called border adjustments. Alan Auerbach is among the leading proponents of the push to restructure corporate taxes so… – Continue reading

UK suggests economic body to help tackle tax evasion along Irish border after Brexit

An inter-governmental economic organisation could help tackle tax evasion across the Irish border following Brexit, the UK’s Treasury has suggested. The UK’s only land border with an EU state is in Northern Ireland. Without the European institutions, the Organisation for Economic Co-operation and Development (OECD) could help facilitate dialogue with… – Continue reading

Austria: Ministry Of Finance Issues Guidance On The Alienation Of A Partnership Stake In A Trilateral Setting

On 29 October 2016, the Austrian Ministry of Finance provided interesting guidance on the tax consequences of an alienation of a participation in a Hungarian partner- ship by an Austrian partnership consisting of German partners. The case revolved around an operative Austrian partnership (GmbH & Co KG) with German resident… – Continue reading

New Double Tax Treaty signed between Montenegro and Portugal

Montenegro has concluded double taxation treaties with more than 35 countries, and this number continues to grow. The most recently signed treaty is the one concluded with Montenegro. The agreement affects persons who are residents of one or both of the contracting states and applies to the Portuguese personal income… – Continue reading

Register of people with significant control will not affect Crown territories

The government has quashed calls to look at extending the requirement to publish a public register of people with significant control to companies incorporated in the Crown dependencies and overseas territories, as part of a bid to increase tax transparency, saying new rules on the automatic exchange of information are… – Continue reading

Inland Revenue audits Microsoft NZ over transfer pricing practices

Microsoft New Zealand is bracing for possible action from the taxman. The company said in its annual accounts that Inland Revenue was auditing payments charged to it by Microsoft companies overseas over the two years to June 2015. Microsoft NZ listed the Inland Revenue audit as a “contingent liability” for… – Continue reading

Israel and U.S. Begin Sharing Data in Crackdown on Tax Evasion

The Israel Tax Authority says Americans have provided information on 35,000 accounts held by Israelis in the U.S. and on an unspecified number of American accounts in Israel. The Israel Tax Authority said Monday it had begun passing on data on Israeli bank accounts held by American citizens and Green… – Continue reading

ATO warns energy giants over offshore profit hubs

The Australian Taxation Office has its sights on a $30 billion-a-year natural gas export bonanza expected over the next few years, warning oil and gas giants not to follow the lead of the big miners and “inappropriately shift profits” by selling through tax haven Singapore. At the same time, it… – Continue reading

Plans for Australia to adopt a ‘Google tax’ welcomed by advocacy group

Coalition’s proposed diverted profits tax could capture billions in revenue from multinationals using profit-shifting practices, says Tax Justice Network One of the biggest critics of multinational tax avoidance has welcomed the Coalition’s proposed “Google tax”, saying a similar tax in the UK looks likely to increase corporate tax payments by… – Continue reading

Bloggers could face hefty tax bill or jail for non-disclosure

Bloggers and celebrities who receive undisclosed gifts or payment to flog products and services under the guise of celebrity endorsement could ultimately wind up in jail for tax evasion. The rise of ‘Instagram celebrities’ and ‘Influencers’ who post endorsements of everything from their clothes and make-up to where they spent… – Continue reading

Budget 2017: Tax Reform For Financial Services

Given the recent developments in the Indian economy, the upcoming Union Budget will certainly be critical and important in determining the future outlook of the economy. The financial services industry has been one of the key drivers of growth due to its strong cause and effect relationship with the economy…. – Continue reading

Belarus, China’s Hong Kong sign double taxation avoidance agreement

Belarus and Hong Kong Special Administrative Region of the People’s Republic of China signed an agreement on the avoidance of double taxation and prevention of income and capital tax evasion on 16 January, BelTA learned from the Belarusian embassy in China. Specialists believe that the agreement on the avoidance of… – Continue reading

Moving towards a simplified tax regime

As per the Economic Survey 2016, the ratio of Indian taxpayers to voters is 4%; ideally it should be roughly 23% at existing levels of economic and political development. The tax to GDP ratio at 16.6% is well below the emerging market economy norm of 21% and OECD average of 34%…. – Continue reading

Britain may become tax haven after hard Brexit, Hammond says

British chancellor Philip Hammond has infuriated German politicians for implying a “hard” Brexit would see London adopt a new role as a tax haven before the gates of the EU. Driving speculation ahead of Tuesday’s Brexit address by prime minister Teresa May, Mr Hammond said he preferred seeing Britain remain… – Continue reading

Hammond threatens EU with aggressive tax changes after Brexit

Chancellor tells German newspaper if Britain were closed off from markets it may abandon European-style social model The chancellor, Philip Hammond, has suggested Britain could transform its economic model into that of a corporate tax haven if the EU fails to provide it with an agreement on market access after… – Continue reading

Netherlands ‘will block UK-EU deal without tax avoidance measures’

Trade agreement would have to include strict rules to prevent Britain becoming offshore haven, Dutch deputy PM says The Netherlands will block any EU trade deal with the UK unless it signs up to tough tax avoidance regulations preventing it from becoming an attractive offshore haven for multinationals and the… – Continue reading

Panama not cooperating with Malta tax authorities

Authorities unable to access leaked e-mails from Mossack Fonseca Panama is not cooperating with the Maltese tax authorities in their investigations into the Panama Papers leak, according to Finance Minister Edward Scicluna. Prof. Scicluna made his comments to Malta Today. Inland Revenue Commissioner Marvin Gaerty told this paper last year… – Continue reading

Russia Removes Hong Kong From List of Offshore Tax Zones

The Russian government will no longer consider Hong Kong a Chinese-affiliated tax haven that doesn’t share tax information. Russia will strike Hong Kong from its list of offshore jurisdictions following ratification of a double tax treaty signed by the two parties last January and ratified by Russia in July, according… – Continue reading

UK/Uruguay double taxation convention takes effect

The comprehensive Double Taxation Convention between Uruguay and the United Kingdom has taken effect from 1 January 2017. The United Kingdom and Uruguay signed a convention to avoid double taxation and prevent fiscal evasion related to taxes on income and on capital on 24 February 2016 in Montevideo. The document… – Continue reading

Expose the true beneficiaries

THE Panama Papers, the world’s biggest leak, highlighted the complex ways used by companies and individuals to conceal who the actual beneficiaries of a company are. Some of them put their money into offshore accounts such as in Labuan, which is also an off-shore financial centre and tax haven. One… – Continue reading

Special tax regime for Non-Habitual Portuguese Resident individuals

Portuguese income tax law provides for a 20% reduced rate and, in respect to income obtained abroad, a full tax exemption, for certain types of income derived by individuals having the status of Non-Habitual Portuguese Residents (NHPR). Any individual that in a certain year becomes tax resident in Portugal will… – Continue reading

The favourable tax regime of new Italian residents

The 2017 Budget Law introduced (starting from fiscal year 2017) favourable provisions for people wishing to become tax residents in Italy. It is aimed at wealthy individuals who wish to bring in new capital resources. The regime is inspired by the non-domiciled resident regime which is in force in the… – Continue reading

Cayman Islands: Cayman Islands AEOI Update – Second Tranche of CRS Regulations Released

The Cayman Islands Government issued the second tranche of the Common Reporting Standard (“CRS”) regulations at the end of December 2016. Updated Guidance Notes will be issued in Q1 2017 by the Cayman Islands Tax Information Authority (“TIA”) to assist with the implementation of the regulations. Furthermore, TIA stated in… – Continue reading

Malta denounced as tax haven as it assumes EU presidency

Malta was today (11 January) accused of being a tax haven as it took over the rotating presidency of the EU. Some companies in the EU’s smallest country pay as little as 5% tax on their profits. The small Mediterranean island would have been included in the list of tax… – Continue reading

India may leave tax treaty with Netherlands unchanged

India is unlikely to amend its tax treaty with the Netherlands as it did with Mauritius, Singapore and Cyprus and this could shape the investment strategy of foreign portfolio investors (FPI) and private equity (PE) funds investing in India, said three people in the know. “There were talks to amend… – Continue reading

In Slovakia, 2017 brings new tax legislation

The Slovak Government and Parliament made several changes to the tax system with effect from 1 January 2017. The recently adopted amendments concern – among others – corporate and personal income tax, value added tax, special levy in regulated industries, as well as social security and health insurance contributions. Here… – Continue reading

Snapchat opts for London over Dublin for international HQ

Move could be a worrying indicator of investment trends post-Brexit, post-Beps Snap, the company behind Snapchat, has opted to open its new new international headquarters in London, rather than Dublin, Amsterdam or Luxembourg, bucking a trend which for decades has seen US multinationals book their international sales in one of… – Continue reading

Cyprus: Country-By-Country Reporting Under Base Erosion And Profit Shifting Action 13

Cyprus signed the Organisation for Economic Co-operation and Development’s Multilateral Competent Authority Agreement for the Automatic Exchange of Country-by Country Reports between its member states on 1 November 2016 after approval by the Council of Ministers at its meeting held on 28 September 2016. Following publication in the government gazette… – Continue reading

Swedish Bank Merger Rules Aim to Limit Risk of Tax Imbalance

A plan by Nordea Bank AB to merge with subsidiaries in Denmark, Finland and Norway has prompted Sweden to revise its laws to minimize the risk of a tax imbalance when a foreign company’s shares and other financial instruments are merged with those of domestic company. Effective Jan. 1, the… – Continue reading

Worldwide: The OECD’s Conquest Of Domestic Tax Codes: Understanding The Costs And Consequences Of The BEPS Project

Authored by IFC Media Recent global events from the release of the Panama Papers to a series of high-profile inversions have given international tax regulators both rhetorical ammunition and public support to execute a global crackdown on multinational tax planning. The goal is to increase total taxes paid by global… – Continue reading

Three More Nations Commit To BEPS Minimum Standards

A further three countries have committed to participate in international base erosion and profit shifting discussions and implement minimum standards, under the OECD’s new “inclusive framework” for countries. The OECD confirmed on January 6 that the three territories are: Bermuda, Côte d’Ivoire, and Kazakhstan. This brings the total number of… – Continue reading

Amended tax treaty with the Isle of Man comes into force

The amended double taxation agreement between the UK and the Isle of Man has entered into force, effective from 5 January 2017, following the latest arrangements signed on 8 March 2016. The bilateral agreements between the UK and the Isle of Man concern cooperation in tax matters through the exchange… – Continue reading

Switzerland: Federal Council Adopts Dispatch On Exchange Of Country-By-Country Reports

On 23 November 2016, the Swiss Federal Council adopted the dispatch on the Multilateral Agreement on the exchange of Country-by-Country Reports (CbCRs) and draft federal implementing legislation. The proposal is aimed at implementing the minimum standard of the G20 countries and the OECD to combat base erosion and profit shifting… – Continue reading

Malta’s stand on anti-money-laundering rules is ‘in line with EU’ – OPM

Centralised company registers will now detail who ultimate beneficiaries are. Malta’s stand on amendments seen as ‘watering down’ anti-money-laundering rules are in line with the EU’s position, a spokesman for the Office of the Prime Minister told the Times of Malta. EU governments have just agreed to create centralised company… – Continue reading

Curbs on black money abroad: Govt revising tax treaties to share data with ED, CBI

Sources said this amendment will allow speedy prosecution and imprisonment of account holders as enumerated in the Panama Papers, Liechtenstein and HSBC Geneva lists. Moving to register criminal charges and impose stricter penalties against those who have stashed black money abroad, India has started revising tax treaties with partner countries… – Continue reading