Ireland: Irish Budget 2020 – A Roadmap For Irish And International Business
A guide to the Irish Budget 2020 ... - Continue reading
Category: Europe
Airbnb probed by UK tax authorities
A note in newly filed accounts for Airbnb UK said it had been contacted by HMRC over "tax laws or regulations impacting the company's business". ... - Continue reading
UBA head speaks about legislative changes relating to bank secrecy
On September 12, the Armenian government approved a set of amendments to the laws on Criminal Procedure and Bank Secrecy, which implies the disclosure of customers bank information. ... - Continue reading
European Union: UAE Removed From EU Tax Haven Blacklist Along With Switzerland
The United Arab Emirates and Switzerland removed from European Union's list of non-cooperative jurisdictions for tax purposes on October 10. ... - Continue reading
Disclosure of cross-border arrangements
HMRC has recently been consulting on how the UK will implement new EU disclosure rules contained in the latest Directive on Administrative Cooperation (DAC6). ... - Continue reading
SoftBank’s billions-saving tax route to be shut by Tokyo
Finance Ministry targets deliberate losses designed to slash bill ... - Continue reading
Ireland Issues Guide On Dual-Resident Companies
The Irish Revenue has published guidance on dual-resident companies that explains new rules introduced under the BEPS multilateral convention on tax treaties. ... - Continue reading
First Look: Ireland publishes finance bill with international tax and transfer pricing changes
The Irish government today published Finance Bill 2019, which contains legislation to enact tax measures taking effect primarily from January 1, 2020. ... - Continue reading
Luxembourg 2020 Budget requires all older tax rulings to expire
Luxembourg’s Budget Bill published on 14 October comes up with new laws surrounding advance pricing agreements and other advance tax confirmations (so-called tax rulings) ... - Continue reading
Switzerland: Amended Protocol Of Double Taxation Agreement Between Switzerland And USA
On 20 September 2019, Switzerland and the USA ratified the protocol of amendment of their double taxation treaty ("DTA"). ... - Continue reading
Ireland Budget 2020 released
On 8 October, the Irish government announced its Budget 2020 measures. Brexit and climate change are core themes of new revenue measures and expenditure commitments. Brexit remains the foremost immediate concern for the Irish economy, whereas tackling climate change requires long-term commitments to tax and spending policies. ... - Continue reading
India: No Withholding Tax Applicable On Arbitral Award
The Delhi High Court ("Court") in Glencore International AG v. Dalmia Cement (Bharat) Limited has held that amounts paid to a non-resident pursuant to an international arbitration award would not be subject to withholding tax in India. ... - Continue reading
Ireland Transfer Pricing Feedback Statement Explained
The Irish Government recently published a Transfer Pricing Rules Feedback Statement which is explained in this article. ... - Continue reading
OECD consulting on digital tax proposal
The OECD today published for stakeholders’ comments a proposal to advance international negotiations to ensure that multinational enterprises (MNEs), including digital companies, pay tax wherever they have significant consumer-facing activities and where they generate profits. The proposal – Secretariat Proposal for a Unified Approach – would re-allocate some profits and… – Continue reading
Citizenship, residency and tax liability
Is it true that if I become Italian I have to pay taxes in Italy? “I am a U.S. citizen and I plan to move my residency to Italy. I will continue working remotely for my U.S.-based company and will continue paying my taxes in the U.S. What should I… – Continue reading
The Fiat and Starbucks state aid tax cases: an absolute loss for legal certainty.
In late September, the EU General Court released its decisions in two long-awaited state aid appeals: Fiat (cases T-755/15 Luxembourg v Commission and T-759/15 Fiat Chrysler Finance Europe v Commission) and Starbucks (cases T-760/15 Netherlands v. Commission and T-636/16 Starbucks and Starbucks Manufacturing Emea v. Commission). ... - Continue reading
Accidental Americans’ sue France over FATCA disclosure rules
A group representing French-American taxpayers has filed a complaint against France with the European Commission over its compliance with the US Foreign Account Tax Compliance Act (FATCA), in a bid to avoid being blacklisted by French banks starting in January. France is a signatory to an agreement to give the… – Continue reading
EU to remove UAE and Switzerland from tax blacklist
The United Arab Emirates and Switzerland are set to be removed from a European Union blacklist of countries deemed to be tax havens, according to a Reuters report citing an official document. Switzerland has delivered on its commitments, the document said, acknowledging that a tax reform passed last year –… – Continue reading
Bermuda: Chambers Private Wealth 2019: Bermuda (2019)
1. Tax1.1 Tax regimes In Bermuda there is no income or profits tax, withholding tax, capital gains tax, capital transfer tax or inheritance tax. There is no exit or similar such tax based on a resident's wealth when ceasing to be resident and there are no other consequences of leaving the jurisdiction. Customs duties and stamp duty are major government revenue earners, with stamp duties charged at different rates and in different manners on a variety of legal documents, excluding wills. ... - Continue reading
Cyprus: Convention Between The Republic Of Cyprus And The Netherlands For The Avoidance Of Double Taxation
Last week saw Cyprus add The Netherlands to the long list of countries with which it has signed double taxation agreements. ... - Continue reading
UK: Ways For UK Businesses And Foreign Investors To Mitigate Uncertainty Around Brexit
The UK remains in the international spotlight in 2019 as the first member of the European Union to signal its intention to exit irrevocably from the Union. ... - Continue reading
Turkey: new tax audit wave focuses on non-resident digital companies
Turkey’s government has initiated a new wave of tax audits scrutinizing the taxation of non-resident taxpayers engaged in the digital economy. ... - Continue reading
Switzerland moves to end bearer shares
The Swiss government will begin to phase out bearer shares on 1 November in a bid to curb tax avoidance by bearer shareholders. Under the new rules companies no longer issue bearer shares—equity in a company that is owned by whoever holds a physical stock certificate—unless they are a listed… – Continue reading
Ireland must prepare for international tax turbulence
It looks like the world’s leading economies are determined to claim a bigger slice of the global corporate tax pie which will lead to tricky times ahead for Ireland, according to PwC tax policy leader Peter Reilly ... - Continue reading
Jersey: Capital Markets: Listing Jersey Holding Companies
With £184 billion market capitalisation held by Jersey listed companies on global exchanges as of 30 June 2019, this briefing explores why Jersey vehicles remain such a popular choice for taking international businesses to market. ... - Continue reading
Ukraine: Ukraine Ratifies Protocol Amending Double Taxation Treaty Between Ukraine And Switzerland
On 18 September 2019, the Parliament of Ukraine ratified a protocol (the Protocol) of amendments to the double tax treaty between Ukraine and Switzerland (the DTT) which had been signed by the states on 24 January 2019. ... - Continue reading
Dutch government asks banks to give American expats more time to deal with FATCA
The Dutch government is urging banks to be accommodating towards American nationals who risk having their bank accounts closed because of US fiscal regulations as it calls on EU member states to campaign together for changes to American tax laws which are affecting thousands who have American nationality but no… – Continue reading
US/UK tax series: US citizens moving to the UK
If you are a US citizen who is becoming UK resident you will continue to be subject to US tax and reporting obligations but will also become subject to UK tax. ... - Continue reading
Iceland joins BEPS MLI tax pact
Iceland on September 27 became a party to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS MLI) by depositing its instrument of acceptance of the agreement with the OECD. Iceland is the 89th jurisdiction to join the tax agreement. ... - Continue reading
Portugal: Portuguese Tax Law – New Provisions To Meet The EU Anti-Tax Avoidance Directive (ATAD)
On 3 May 2019, Portugal introduced amendments to Portuguese Taw Law, in accordance with the European Union (EU) Anti-Tax Avoidance Directive (ATAD). ... - Continue reading
Hong Kong signs tax treaty with Estonia
The Hong Kong government today announced that Hong Kong and Estonia have signed a comprehensive tax treaty. ... - Continue reading
Armenia, Malta sign double tax treaty
YEREVAN, SEPTEMBER 25, ARMENPRESS. Armenian Foreign Minister Zohrab Mnatsakanyan on September 24 met with Malta’s Minister for Foreign Affairs and Trade Promotion Carmelo Abela on the sidelines of the 74th session of the UN General Assembly in New York, the Armenian ministry told Armenpress. The officials praised the current dynamic… – Continue reading
Denmark tax bill clarifies timing rules for transfer pricing documentation
Denmark’s Ministry of Taxation on 12 September published a draft bill proposing a number of changes to Denmark’s international tax provisions including a requirement to submit transfer pricing documentation together with the corporate income tax return. ... - Continue reading
Taxation of the digital economy, future of debt, and other OECD updates during the IFA Congress 2019 in London
The IFA Congress 2019, held 8-12 September in London, brought together leading international tax and transfer pricing experts from around the world. ... - Continue reading
Netherlands: The Netherlands: Tax Plan 2020
On September 17, 2019, the Dutch government released the Budget 2020 containing its Tax Plan 2020 with certain amendments to Dutch tax law. ... - Continue reading
Russia may stop automatic tax data exchange with Britain, dependencies: media
MOSCOW, Sept. 20 (Xinhua) — The Russian Federal Tax Service (FTS) may stop the automatic exchange of financial information with Britain and its dependencies — the Isle of Man, Guernsey and Jersey, TASS news agency reported Friday, quoting an FTS draft order. According to the news report, the draft order… – Continue reading
Apple to challenge EU over record $14 billion tax dodging case
A panel of judges in Luxembourg on Tuesday will begin hearing arguments concerning the US tech giant Apple and the world’s biggest tax case. The EU General Court (EGC) will begin hearing the appeals lodged by Ireland and Apple against the EU tax ruling. It has to weigh up whether… – Continue reading
UK: UK Tax On Property For Non-UK Residents – Recent Changes
From April 2019, all direct disposals of UK land and property by non-UK residents are now subject to UK tax on capital gains ... - Continue reading
The 2020 Dutch budget and tax plan: key takeaways for multinational enterprises
The Dutch government on September 17 presented the 2020 Dutch budget and tax plan, proposing modifications to the taxation of multinational firms. ... - Continue reading
France joins ICAP pilot to jointly assess MNE tax positions
France has joined the International Compliance Assurance Programme (ICAP) pilot program, the OECD announced September 16, bringing the total number of tax administrations participating to 18. ... - Continue reading
Ireland will be the ‘big loser’ if OECD tax reform fails, Saint-Amans warns
OECD tax director also criticises State’s slow move to phase out ‘double Irish’ loophole ... - Continue reading
German finance minister endorses public country-by-country reporting of MNE tax information
German finance minister Olaf Scholz is in the midst of a campaign tour for the social democrats (SPD) presidency. ... - Continue reading
EU Commission to investigate 39 Belgium “excess profit” tax rulings for potential State aid violations
The European Commission today announced that it has opened 39 in-depth investigations to assess whether Belgian “excess profit” tax rulings granted to multinationals between 2005 and 2014 provided benefits that are contrary to EU State aid rules. ... - Continue reading
Tax avoidance drives nearly 40% of global FDI: IMF
Nearly 40% of worldwide foreign direct investment (FDI), amounting to $15trn, “passes through empty corporate shells” with “no real business activities”, a study by the IMF and the University of Copenhagen reveals. According to the report, ten economies including Luxembourg, the Netherlands, Hong Kong, BVI, Switzerland, Singapore, Ireland, the Cayman… – Continue reading
US-born British citizen launches crowdfunding campaign to stop FATCA
A US-born British citizen has started a crowdfunding campaign to stop HMRC sharing her personal information with the US Internal Revenue Service (IRS) under the US Foreign Account Tax Compliance Act (FATCA). Law firm Mishcon de Reya has taken on the UK case for a client who alleges HMRC is… – Continue reading
Cyprus aims to become the bridge between Kazakhstan and Europe
Services sector professionals in Cyprus are monitoring Kazakhstan’s emerging market economy for some time now and they have set an ambitious goal. This is no other than turning the Mediterranean island into the bridge between the booming Central Asia country and Europe. This is what Costas Markides of KPMG Cyprus… – Continue reading
UK: Taxpayer Victory In UK Corporate Residence Case Involving Offshore SPVs
The "management and control'' test of corporate residence is a significant connecting factor for tax purposes in many common law jurisdictions. ... - Continue reading
Netherlands destination of choice for tax-dodging multinationals – report
Multinational companies channel more than $3 trillion a year in “phantom” foreign investment through the Netherlands in order to bring down their corporate tax bills, according to research published in the Financial Times. ... - Continue reading
Ukrainian government approves bill ratifying FATCA
The Cabinet of Ministers has approved a bill to ratify the Agreement between the governments of Ukraine and the United States to improve tax compliance and application of provisions of the U.S. Foreign Account Tax Compliance Act (FATCA) and related bills, the Ukrainian Finance Ministry’s press service reported. “On September… – Continue reading
US AND LUXEMBOURG RATIFY DOUBLE TAXATION PROTOCOL
Luxembourg and the US have amended their double taxation convention, updating the exchange of information article to harmonise it with that of the US model income tax treaty and the OECD. US ambassador to Luxembourg Randy Evans and Luxembourg finance minister Pierre Gramegna (DP) on Monday announced the ratification of… – Continue reading
