The US Treasury Department released proposed revisions to the US Model Income Tax Treaty (the ‘Model Treaty’); the proposed changes are intended to combat treaty abuse and deny treaty benefits in certain situations. The revisions to the Model Treaty include: (i) changes to the Limitation on Benefits provision which most… – Continue reading
Draft regulations in Guernsey for implementing the common reporting standard (CRS) for the automatic exchange of information are expected to be published in final form in early 2016. Guernsey has indicated its commitment for adopting the CRS, with effect from 1 January 2016, so that the first reporting would take… – Continue reading
BRASILIA, Nov 11 (Reuters) – The lower house of Brazil’s Congress approved amnesty for undeclared offshore assets on Wednesday despite criticism from opposition lawmakers who said it would allow the laundering of illegally gained money. To reduce its budget deficit, President Dilma Rousseff’s government is hoping to raise 11 billion… – Continue reading
In a surprising development, the US Senate Committee on Foreign Relations on November 10 approved without amendment eight pending US tax treaties and protocols. Proposed income tax treaties with Chile, Hungary, and Poland; proposed tax protocols with Japan, Luxembourg, Spain, and Switzerland; and a proposed protocol amending the multilateral mutual… – Continue reading
The Swiss Federal Council has adopted a dispatch on a protocol to the double tax agreement (DTA) with Albania. The protocol was signed on September 9 and the dispatch was adopted on November 11. Its aim is to bring the DTA into line with Switzerland’s current policy on tax agreements…. – Continue reading
A rout in pharmaceutical and biotech stocks has altered the equation for chief executives thinking about big-ticket mergers and acquisitions. On one hand, target companies are much cheaper than they were: roughly $130 billion has been wiped off the Nasdaq biotech index since Hillary Clinton, the Democratic presidential front-runner, pledged… – Continue reading
Some time ago we wrote an article on the Foreign Account Tax Compliance Act (‘FATCA’) which says that although the FATCA tentacles are fairly intrusive, at the end of the day, it represents just another form for tax payers to complete. Rather to my surprise this article elicited a threat… – Continue reading
The final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) project were issued on 5 October (the “Reports”) after a two-year consultation period during which 62 countries and many other stakeholders (such as the World Bank, the IMF, and many trade associations) participated. These Reports, split into 15… – Continue reading
Thanks to the FiTAX tax reporting solution, some 2,000 financial institutions successfully met the reporting requirements of tax authorities. FiTAX FATCA covers more than 45 countries. ZURICH, SWITZERLAND—(Marketwired – Nov. 12, 2015) – 2015 marks a turning point in the FATCA timeline: for the first time, Financial Foreign Institutions (FFIs)… – Continue reading
The Department of Justice announced today that Banque Internationale à Luxembourg (Suisse) SA (BIL Switzerland) and Zuger Kantonalbank (ZGKB) have reached resolutions under the department’s Swiss Bank Program. These banks will collectively pay penalties totaling more than $13 million and continue to cooperate with the department. “The agreements reached today… – Continue reading
The canton of Zug is planning to make it a lot easier for wealthy foreigners to settle in the area. It will mean one rule for the rich and one for the poor. (SRF/swissinfo.ch) Foreigners applying for “C” residence permits in a German-speaking canton normally have to prove they can… – Continue reading
Edward Troup says the tax authority is doing its job well The amount of tax going uncollected in the Britain is no worse than in other countries around the world, a senior official at the tax authority has said. Edward Troup, HMRC’s tax assurance commissioner, told the House of Commons… – Continue reading
On September 16, 2015, the Australian government introduced into Parliament Tax Laws Amendment (Combating Multinational Tax Avoidance) Bill 2015, which contains, among other items (including the implementation of country-by-country reporting), the proposed legislative language to implement Australia’s version of the United Kingdom’s diverted profits tax. The bill was accompanied by… – Continue reading
While the United States works to get tax dollars from corporations hiding assets elsewhere, they offer the same opportunity in U.S. states to businesses from other countries. To some, “tax haven’’ is a dirty word, describing as it does a place where wealthy people and large corporations can hide assets… – Continue reading
Introduction On September 30 2015 Her Majesty’s Treasury published its long-awaited consultation on two of three proposed changes to the taxation of individuals domiciled outside the United Kingdom. The three measures – announced by Chancellor George Osborne in the 2015 Summer Budget published on July 8 – are intended to… – Continue reading
Irish corporation tax returns are behaving oddly: the Department of Finance estimates that they are running €2 billion (74 percent) ahead of forecast for the year. Economist Seamus Coffey has described these figures as “very strange”. Coincidentally (or perhaps not) the global accounts of the Apple corporation revealed an increase… – Continue reading
The “heads up” for Reporting Financial Institutions on foreign investors’ limited voluntary disclosure opportunities Nearly one hundred jurisdictions (Participating Jurisdictions) have already committed to participate in the CRS promulgated by the Organisation for Economic Cooperation and Development (OECD). Most of them have committed to be “early adopters” of the CRS… – Continue reading
Australian motor racing legend Alan Jones has become embroiled in the collapse of an online gambling company operated by notorious conman Peter Foster which owes $11.5 million to about 150 investors. The 69-year-old former winner of the Formula One Drivers’ Championship was named in a writ to be lodged in… – Continue reading
THE world appears to be getting much smaller. Rapid technological advances, increased people mobility, and changes in the international political climate have all helped to break down many of the traditional barriers to global and regional trade. For dynamic, fast-growing businesses, this increased globalisation represents an excellent opportunity for businesses… – Continue reading
Bern, 11.11.2015 – During its meeting today, the Federal Council adopted the Anti-Money Laundering Ordinance (AMLO). It will enter into force on 1 January 2016. In February 2012, the Financial Action Task Force (FATF) published the revised international standards concerning the combating of money laundering and terrorist financing (FATF recommendations)…. – Continue reading
Azerbaijan’s participation in G20 (the Group of Twenty) summit is of special importance for Turkey, a source in Turkey’s presidential administration told Trend Nov.11. The 2015 G-20 Antalya summit will be the tenth annual meeting of the G-20 heads of government. It will be held Nov.15-16 in Antalya, Turkey. Azerbaijan… – Continue reading
The nine-month old Team Unity administration has been pursuing quiet diplomacy to recalibrate international relationships for the benefit of the people of St. Kitts and Nevis, reports SKN Vibes. So said St. Kitts and Nevis Prime Minister Dr. the Hon. Timothy Harris at last week’s press conference at government headquarters…. – Continue reading
Austria’s legislative implementation of the common reporting standard (CRS) requires the exchange of information beginning in 2018 (instead of 2017 as in most EU Member States). DUE DILIGENCE Austria has voluntarily agreed to apply the new financial account “due diligence” requirement for accounts opened on or after 1 October 2016,… – Continue reading
Apple chief executive Tim Cook said he was feeling “pretty good” ahead of the European Union’s judgement on its Irish tax arrangements, as the company announced 1,000 new jobs in Ireland on Wednesday. Ireland’s tax arrangements with the US tech giant are under investigation by the EU to see if… – Continue reading
On November 11, 2015 in the Dutch Staatscourant a Decree from the Dutch State Secretary for Finance containing an approval regarding an adjustment period for Advance Tax Rulings (ATRs) that will expire as a consequence of the entry into force of the Wet implementatie wijzigingen Moeder-dochterrichtlijn 2015 (Law implementing the… – Continue reading
European Union lawmakers have called 13 multinational companies to a meeting next week to talk about the low-tax deals they have struck with EU jurisdictions, reports CBC News. Among the companies to be questioned on Nov. 16 will be Amazon.com, Disney, Coca-Cola Co, Anheuser-Busch InBev NV, HSBC Holdings, Ikea Group… – Continue reading
Following the October 2015 release of the OECD’s base erosion and profit shifting (BEPS) deliverables, some consultations in the UK have already been opened—including one on the UK’s rules concerning the deductibility of corporate interest expense and how this treatment would be affected by BEPS Action 4 (which seeks to… – Continue reading
The National Association of Estate Agents is awaiting a response from the government to its demand for four changes to sale and purchase processes in a bid to combat money-laundering. In one of the association’s first major statements on the issue since the Channel 4 From Russia With Cash documentary,… – Continue reading
The Caribbean island says its financial system is all aboveboard, yet it remains a gateway to less scrupulous offshore havens like the Cayman Islands. BRIDGETOWN — Is there “dirty” money strewn across the pristine sands of Barbados? Does something sinister hide beneath the glistening coral reefs of this former pirate… – Continue reading
Double Taxation Treaty Network UK’s Key Strength in Attracting Tax- Transparent Funds LONDON, Nov 11, 2015 (BUSINESS WIRE) — The value of UK Authorised Contractual Scheme (ACS) funds under management in the UK is likely to exceed GBP250 billion by 2017, according to a Northern Trust survey of UK based… – Continue reading
As the status of professional athletes is not regulated under Czech law, there is a need for legal interpretation on this matter. The Supreme Administrative Court has ruled that athletes’ work is of such a specific nature (e.g. the method of their pay, the amount of rest and other non-compliances… – Continue reading
LONDON – Both developed countries and developing countries are loosing out on tax revenues due to a continued lack of progress in fighting international tax avoidance. Large multinational businesses are still using international tax rules to avoid paying taxes in the countries where they raise profits, according to information contained… – Continue reading
Presidency sent to Congress ratification of treaties with Jersey, Guernsey, the Cayman Islands and Uruguay; text follows the G20 guidelines The Presidency referred for evaluation of Congress four agreements for the exchange of tax information (TIEA, which stands for the English term “Tax Information Exchange Agreement”) entered into with Uruguay,… – Continue reading
Britain has done more to tackle secretive company ownership practices which facilitate corruption than other leading economies, while the United States and China are falling short of their promises, a leading anti-corruption group said. Britain has made good progress on making beneficial ownership information accessible, having legislated for a central… – Continue reading
The Common Reporting Standard (“CRS”) will impose new investor due diligence and reporting obligations on funds and other financial institutions based in “early adopter” participating jurisdictions, with effect from January 1, 2016. According to the OECD, all major financial centres have now signed up to the standard. Financial institutions should… – Continue reading
Clare Maurice, Arabella Murphy and Sophie Mazzier, Maurice Turnor Gardner LLP For better or worse, the concept of “fairness” is here to stay in relation to taxation, whether domestic or international. Politicians of all persuasions like to insist that their respective policies will ensure that everyone pays his or her… – Continue reading
Finland’s Minister for Foreign Trade and development, Lenita Toivakka, has admitted being involved in a scheme to reduce tax liabilities on a multi-million euro shopping centre development in Mikkeli. She insisted that the arrangement was legal as well as commonplace for international property investors. Finland’s Minister for Foreign Trade and… – Continue reading
In this edition we also include the leading trustees, private bankers and accountants serving the private client industry. RBC Wealth Management leads our research in trust and advisory services with an impressive 18 names recommended. Alan Binnington specialises in establishing and administering trust and fiduciary structures for high net worth… – Continue reading
The New Zealand foreign trust regime – its use in international wealth planning The New Zealand “foreign trust” regime came into being over 25 years ago. It arose from a domestic initiative to make the use of offshore trusts for tax minimisation more difficult for New Zealand residents, by imposing… – Continue reading
On November 10, 2015 the European Commission published a brochure titled “Did you know… Facts and figures about the European Union and the G20 – 2015 Turkey G20 Antalya, 15>16 November 2015”. According to the European Commission, the brochure sets out the European Commission’s aims for the G20 summit. The… – Continue reading
DID you hear the story about the Queen, tax evasion, a nationalised British bank for the rich and famous, a whistleblower and a £7bn under sale to ‘reward cronies and cheat the taxpayer’? Sounds like a pretty big deal, right? But last Thursday’s damning testimony from Helen Goodman MP –… – Continue reading
Irish Prime Minister Enda Kenny has defended his country’s low rate of corporation tax, currently set at 6.25 per cent, and Dublin’s arrangements with global corporations which house subsidiaries in the country, reports Digital Look. Over the last decade, major corporations such as Google and Dell have created corporate subsidiaries… – Continue reading
The European Union’s top antitrust official lauded rulings ordering two companies to repay tens of millions of euros in back taxes as she considers similar decisions involving Apple Inc. and Amazon.com Inc. European Union competition chief Margrethe Vestager told lawmakers Monday that the rulings last month against Starbucks Corp. and… – Continue reading
Headline: G20 among biggest losers in large-scale tax abuse – but poor countries relatively hardest hit G20 countries are the biggest losers when US multinationals avoid paying taxes where they do business. This is the main finding of a new report on the global tax system, ‘Still Broken,’ released by… – Continue reading
France wants an agreement on a financial transactions tax (FTT) struck on Monday after a meeting of euro zone finance ministers, Finance Minister Michel Sapin said, reports Reuters. “We have done most of the technical work. I think the time has come to make a decision,” Sapin told reporters. “We… – Continue reading
The Council of European Union has revoked Directive 2003/48/EC, which has allowed tax administrations better access to information on private savers since 2005. By revoking the directive, which is part of a tax transparency package presented by the Commission in March this year, the Council says it strengthens measures to… – Continue reading
Think tank says Ireland has ‘robust’ growth and Budget 2016 was ‘reasonable’ The Organisation for Economic Co-operation and Development has warned of big threats to Ireland’s “robust” growth, among them the risk of another property bubble. Amid anxiety in the EU/IMF troika about Government moves to loosen the fiscal stance,… – Continue reading
The Powys tax rebellion, led by traders including the town’s salmon smokery, local coffee shop, book shop, optician and bakery, could spread nationwide When independent traders in a small Welsh town discovered the loopholes used by multinational giants to avoid paying UK tax, they didn’t just get mad. Now local… – Continue reading
U.S. companies moved $500 billion to $700 billion in profits to countries with low or no corporate tax rates in 2012 alone, according to new research published by tax reform campaigners Tuesday. Tax avoidance on such a large scale means the U.S. accounts for about 71% of profits worldwide that… – Continue reading
Where the likes of Google and Starbucks avoid paying huge amounts of tax in the UK by being registered in tax havens, this town is using the same accountancy loophole A whole town of independent traders in Wales are turning the tables on tax loopholes used by the world’s largest… – Continue reading
