Category: Europe

Automatic Exchange of Information / Double Taxation / G20 / Multilateral Competent Authority Agreement / Switzerland / Tax Evasion / Tax Fraud / Tax Laws / Voluntary Disclosure Program

Switzerland: Italian Tax Authorities Request Information From Switzerland On UBS Bank Customers

Published by: mondaq - September 10, 2019

In the past ten years, Switzerland has undertaken significant efforts to combat international tax fraud and tax evasion and to fight for the strict observance of foreign tax laws. In order to do so, a number of tax laws were enacted, allowing Switzerland to comply with international standards issued by the OECD (acting on behalf of the G20). In this respect, Switzerland ratified the Multilateral Convention on Administrative Assistance originally issued by the CoE and the OECD in 1988 and amended in 2011 ("OECD MC"), and it renegotiated numerous Double Taxation Conventions ("DTC"), amongst them also the DTC with Italy, in order to comply with the international standard introduced by the OECD MC in the version of July 2010. ... - Continue reading

Capital gains / Capital Gains Tax / Cyprus / Dividends / Immovable Property / Income Tax / Inheritance Tax / Property / Residence

Cyprus: The Cyprus Investment Programme And The Benefits

Published by: mondaq - September 5, 2019

The Cyprus Investment Programme is rapidly becoming one of the EU’s most popular residence schemes.

  • Non Cypriot citizens (and their families) can acquire Cyprus Citizenship by investing €2.5 million* in Cyprus.
*In one specific set of circumstances as detailed below in the financial criteria, the investment required is €2.0 million. A non-Cypriot citizen who meets one of the financial criteria detailed below can apply for Cypriot citizenship ‘through naturalization by exception’.
  • Following the application, Cyprus citizenship will be granted in six months, assuming the application has been completed accurately and the correct documentation filed.
  • The applicant needs to be in posession of a residence permit for a period of six months before obtaining the citizenship.
... - Continue reading

Base Erosion & Profit Shifting / Canada / Hybrids / Jurisdiction / Multinational Enterprises ("MNEs") / OECD / Permanent establishment / Switzerland / Tax Avoidance

Canada, Switzerland ratify instrument to tackle tax avoidance

Posted On: August 31, 2019

Canada and Switzerland on August 8 deposited with the OECD their instruments of ratification for the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS MLI). The BEPS MLI, negotiated by over 100 countries and jurisdictions, updates the existing network of tax treaties and… – Continue reading

Cayman Islands / Country-by-Country (CbyC) Reporting / Intellectual Property / Jurisdiction / OECD / Tax Reform

OECD’s minimum tax to apply by jurisdiction

Posted On: August 30, 2019

The Organisation for Economic Co-operation and Development is going to propose a global minimum tax that would apply country by country before the next meeting of G‑20 finance ministers and central bankers set for 17 Oct. in Washington, DC. G7 leaders announced at their Biarritz summit meeting this week a… – Continue reading

Americans / Banking / Belgium / Britain / Citizenship / FATCA / Internal Revenue Service (IRS) / Tax Authority / Tax Laws / USA

British citizens born in America face having bank accounts frozen

Posted On: August 28, 2019

Tens of thousands of British citizens born in the US but only lived there for a few months or years face having their bank accounts frozen as part of a crackdown by the US tax authorities.    The Internal Revenue Service (IRS) is ordering British banks to hand over the… – Continue reading

Double Tax Treaty / EU / European Commission / Luxembourg / Tax Authority / Tax Laws / USA

European Union: The Increasing Link Drawn By Regulators Between State Aid & Taxation Systems

Published by: Mondaq - August 26, 2019

In 2018, the European Commission (EC) concluded two more investigations into whether the tax ruling practices of Member States breached European Union (EU) State aid rules: the first, a finding of unlawful State aid resulting from tax rulings by Luxembourg in favor of Engie; the second, a rare finding of no aid in respect of the treatment by Luxembourg of McDonald's under the Luxembourg-U.S. double taxation treaty. These decisions are discussed below. ... - Continue reading

Anti money laundering / Banking / Bermuda / Financial Institutions / Framework / Investments / Legislation / Regulatory / Tax Authority

Bermuda Monetary Authority: 50 Years Later

Posted On: August 23, 2019

As the Bermuda Monetary Authority [BMA] celebrates 50 years in 2019, we take a look back at the last five decades. From providing sound policy advice to pushing Bermuda forward as a reputable place to conduct business, the BMA has had an incredible impact on Bermuda’s financial landscape. 1990-1999 Exchange… – Continue reading

Business / Croatia / Double Taxation / Gaming / Lease / Pandora / Revenue

Gaming Companies Call for Reaching USA-Croatia Double Taxation Avoidance Deal

Posted On: August 21, 2019

ZAGREB, August 21, 2019 – Computer gaming is the most propulsive segment of the IT industry worldwide, and this trend is present in Croatia, too, where local gaming companies export all their products, however the biggest challenge in doing business is the absence of a Croatia-USA double taxation avoidance agreement,… – Continue reading

Berlin / Business / Corporate Tax / Education / Interest / Tax competition

German economics minister sees SMEs as “secret weapon”: report

Posted On: August 21, 2019

German Minister for Economic Affairs and Energy Peter Altmaier had developed a strategy for the “Mittelstand” or small and medium-sized enterprises (SMEs), the newspaper Handelsblatt reported on Wednesday. “In the eyes of foreigners, SMEs are Germany’s secret weapon and, unlike the Dax 30 companies, SMEs are proving to be extremely… – Continue reading

EU / Hybrids / Jurisdiction / Luxembourg / OECD / Tax Avoidance / Tax Laws

Luxembourg: Luxembourg Starts The Implementation Of ATAD 2

Published by: Mondaq - August 19, 2019

On 8 August, the draft law (the "draft law") implementing the EU Directive 2017/952 of 29 May 2017 ("ATAD 2") amending Directive (EU) 2016/1164 laying down rules against tax avoidance practices that directly affect the functioning of the internal market (the so-called Anti-Tax-Avoidance-Directive, "ATAD") was presented to Parliament. ... - Continue reading

Amazon / Business / Internal Revenue Service (IRS) / Luxembourg / Revenue / Tax Dispute / Tax evasion investigations / Transfer pricing / USA

US appeals court sides with Amazon in $1.5 billion transfer pricing dispute

Published by: MNE Tax - August 17, 2019

A US federal appeals court on Friday affirmed the Tax Court’s decision in Amazon, ruling that cost sharing buy-in payments made by Amazon’s Luxembourg subsidiary in exchange for Amazon’s transfer of intangible property should not include compensation for transferred residual business assets such as workforce in place, goodwill, and going concern value. ... - Continue reading

Anti-Tax Avoidance Package / Banking / Double Tax Treaty / Individuals / Jurisdiction / Luxembourg / Tax Avoidance / Tax Credit / Tax Relief

Luxembourg: Luxembourg Government Submits Bill To Parliament Implementing The EU Anti-Tax Avoidance Directive 2 Into Domestic Law

Published by: mondaq - August 16, 2019

Luxembourg corporate income taxpayers, including Luxembourg permanent establishments of foreign entities, will be subject to the Draft Law as from 1 January 2020. In addition, provisions targeting reverse hybrid mismatches will be applicable to Luxembourg transparent partnerships that would be treated as opaque by their nonresident owners as from 1 January 2022. ... - Continue reading

Britain / HMRC / Non-Domiciled / Offshore Accounts / Residence / Revenue / Tax Avoidance / United Kingdom

Tax from non-doms falls by £2bn as wealthy flee the UK

Posted On: August 12, 2019

The number of wealthy residents who pay no UK tax on their offshore accounts has fallen to its lowest level ever, Treasury figures reveal. Last year, there were 78,300 non-domiciled taxpayers, or “non-doms”, in the UK compared with 98,500 in 2016-17. And the £9.5bn they paid to the taxman in… – Continue reading

Australia / Base Erosion & Profit Shifting / Finland / France / Malta / Tax treaties

Australia publishes synthesized text of tax treaties with France, Finland, Malta as altered by MLI

Published by: MNE Tax - August 9, 2019

The Australian government on August 9 published the synthesized texts of Australia’s bilateral tax treaties with France, Finland, and Malta as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). ... - Continue reading

Base Erosion & Profit Shifting / Double Taxation Agreement / Multinationals / New Zealand / OECD / Switzerland / Tax Avoidance / Tax Dodging / Tax treaties / Withholding Tax

New Zealand-Swiss tax agreement tightens net on avoidance

Posted On: August 8, 2019

WELLINGTON, Aug. 8 (Xinhua) — Opportunities to dodge tax are shrinking with the completion of a new tax agreement between New Zealand and Switzerland, New Zealand’s Revenue Minister Stuart Nash said on Thursday. Nash and Swiss Ambassador to New Zealand David Vogelsanger signed documents to update the Double Tax Agreement… – Continue reading

Base Erosion & Profit Shifting / Luxembourg / Singapore / Tax Reform / Tax treaties

MLI amendments to Singapore-Luxembourg tax treaty enter into effect

Published by: MNE Tax - August 2, 2019

The government of Singapore has announced that amendments made to the Singapore-Luxembourg tax treaty as a result of the two countries’ ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered into effect on August 1. ... - Continue reading

Advance Pricing Agreement / Europe / European Commission / G20 / Mutual Agreement Procedure / OECD / Profit Shifting / Tax Authority / Transfer pricing

The latest APA and MAP figures in Europe: what are the implications for multinational group taxpayers?

Published by: MNE Tax - August 2, 2019

Statistics published earlier this week by the European Commission on member state advance pricing agreement (APA) and mutual agreement procedure (MAP) programs suggest that the OECD/G20 base erosion profit shifting (BEPS) project has increased the scope for differences of opinion between tax authorities of different countries. ... - Continue reading

Anti money laundering / Business / Compliant / Cyprus / Framework / Legislation / Tax Evasion

Cyprus: Country Update-Cyprus: AML

Published by: Mondaq - July 30, 2019

The financial services and international business sector in Cyprus is one of the vital pillars of the Cyprus economy. That said, Cyprus aims to be in full compliance with the AML European framework, and in this respect constantly implements changes in its local laws to align with EU Directives and Regulations. ... - Continue reading

Anti-Tax Avoidance Package / Controlled Foreign Corporation / Denmark / EU / European Commission / Legislation / Tax Laws

Denmark must adopt EU controlled foreign company tax rules, Commission says

Published by: MNE Tax - July 30, 2019

The EU Commission on July 25 decided to send a reasoned opinion to Denmark for its failure to communicate to Commission rules implementing controlled foreign company (CFC) rules required by the EU anti-tax avoidance directive (Council Directive (EU) 2016/1164 or ATAD). ... - Continue reading

Capital Gains Tax / Double Tax Treaty / Exemptions / HM Revenue & Customs / Legislation / Luxembourg / Real Estate / Residence / Tax Laws / Tax Transparency / United Kingdom

UK: Non-Resident Capital Gains Tax on United Kingdom Real Estate: A New Regime

Published by: Mondaq - July 24, 2019

The legislation encompassing the new regime for taxing non-residents' gains on the United Kingdom (UK) commercial real estate came into effect on 6th April 2019. Her Majesty's Revenue and Customs (HMRC) has additionally published draft guidance on this recently introduced regime. This article briefly summarizes the new rules. ... - Continue reading

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