Category: France

FRANCE: RECENT TRENDS IN TRANSFER PRICING, SURVEY

The European Commission recently published new rulings, the OECD published its base erosion and profit shifting (BEPS) final reports, and many countries are reviewing and reinforcing their transfer pricing rules—and France is no exception. Tax professionals in France have observed certain recent trends with regards to transfer pricing. The current… – Continue reading

Ireland: The taxman’s verdict

Pascal Saint-Amans sups water from a plastic cup, coughing and spluttering. There’s a weariness about him. He’s battling a cold, and is feeling “bloody sick”. The state of his health isn’t terribly surprising given his recent punishing travel schedule. New York last week preceded by Peru, where G20 finance ministers… – Continue reading

London Wants to Become the Center of Chinese Currency Trading

Three years ago, Chinese officials said U.K. Prime Minister David Cameron had “seriously damaged” relations by meeting with the Dalai Lama, the exiled Tibetan leader. As planned talks between the two countries were canceled or failed to take place, worries emerged that Britain would miss out on building deeper economic… – Continue reading

FRANCE: COUNTRY-BY-COUNTRY REPORTING; BEPS PROVISIONS

The French Finance Minister, in an October 2015 press release, welcomed the agreement reached by the EU Finance Ministers on the introduction of provisions for the automatic exchange of information on cross-border tax rulings and the publication of the OECD reports on base erosion and profit shifting (BEPS). The French… – Continue reading

BEPS: CURRENT STATUS OF IMPLEMENTATION IN VARIOUS COUNTRIES

Last week’s OECD release of the final package of measures for a coordinated international approach to the reform of the international tax system, under the OECD/G20 base erosion and profit shifting (BEPS) project, marks the end of the discussion and recommendation phase, and the start of the implementation and practical… – Continue reading

FACTA and the New Frontier in Offshore Reporting Enforcement

FATCA was passed to prevent U.S. citizens from evading tax by focusing primarily on foreign financial institutions with U.S. account holders. The Foreign Account Tax Compliance Act (FATCA) was enacted as part of the 2010 Hiring Incentives to Restore Employment Act, and its provisions became effective as of 7/1/14. FATCA… – Continue reading

Ireland, accused of giving tax breaks to multinationals, plans an even lower rate

Ireland, whose corporate tax rate of 12.5 percent is already one of the lowest in the developed world, said it would cut that rate in half for a new tax category — one covering revenue pegged to companies’ patents and other intellectual property. The Irish government, long criticized by other… – Continue reading

NBR to sign deal with Bhutan to avoid double taxation

Bangladesh is set to sign an agreement with Bhutan to avoid double taxation to boost investments, trade and facilitate information exchange between the two Saarc nations, the National Board of Revenue said in a statement. A team led by NBR Chairman Md Nojibur Rahman is now in Thimpu to take… – Continue reading

Geneva Bank Jobs Fall to Lowest Since Crisis Amid Regulatory Woe

Banking jobs in Geneva slipped to the lowest level since the 2008 financial crisis amid regulatory pressures, tax scrutiny and consolidation in the Swiss finance industry, according to lobby group Geneva Financial Center. Employees at banks in the city fell 3 percent to 18,855 in the 12 months through August,… – Continue reading

France: French Tax Update: Draft Finance Bill For 2016, New France/Germany Double Tax Treaty, And ECJ Steria Decision

This French Tax Update will focus on (i) the main provisions of the draft Finance Bill for 2016 (Projet de loi de finance pour 2016) issued by the French Government on September 30, 2015 and to be discussed before the French Parliament between October and December (“Draft Finance Bill for… – Continue reading

OECD report not the last word on Ireland’s FDI corporation tax regime

The global war on corporate tax avoidance doesn’t look like being so gruesome after all. The OECD reckons that governments are losing out on at least €213bn per year from aggressive tax planning by multinationals, reports the Irish Independent. A new book by a Berkeley University economics professor estimates that… – Continue reading

Why India should defend this whistleblower from the Swiss justice system

Hervé Falciani, who exposed the global offshore industry with the HSBC data leak, is facing prosecution under skewed Swiss laws for data theft and espionage. This is his story. Swiss justice hounds those who breach banking secrecy even if in doing so they expose rogue banks. In the past decade,… – Continue reading

Foreign allies to help Modi government dig deeper into black money data

NEW DELHI: India has found global allies in its fight against black money. Germany, France, Switzerland, Singapore, Mauritius and the British Virgin Islands are among those that are providing information, or will soon start doing so, on assets held by Indians, helping the Narendra Modi government in its campaign to… – Continue reading

OECD: countries commit to minimum standards on international tax dispute resolution

Countries should commit to minimum standards on the resolution of international tax disputes, the Organisation for Economic Co-operation and Development (OECD) said in a report published as part of its base erosion and profit shifting (BEPS) project.06 Oct 2015 The standards would include a commitment to “seek to resolve” cases… – Continue reading

Internal Revenue Service Begins Reciprocal Automatic Exchange of Tax Information Under FATCA IGAs

On October 2, 2015, the Internal Revenue Service announced that it had achieved a key milestone in implementation of the Foreign Account Tax Compliance Act (FATCA), a critical anti-tax evasion law passed by Congress in 2010 but not fully implemented until July 2014. The milestone announced by the IRS was… – Continue reading

It’s Here; The Automatic Exchange of Information Under FATCA Began September 30th

The IRS has announced that as of September 30, 2015 it will implement the automatic exchange of tax information as set forth in the Foreign Account Tax Compliance Act, (FATCA). The IRS Commissioner in announcing the implementation of the automatic exchange of information stated: “This information exchange is part of… – Continue reading

US Has World’s Third-Highest Corporate Tax Rate

Not only does the United States retain the dubious distinction of having the highest corporate tax rate in the Organisation for Economic Cooperation and Development country grouping, it now has the third-highest rate of corporate tax in the world, according to the Tax Foundation. The non-partisan tax policy think tank… – Continue reading

FM warns of action against those hiding assets abroad

Finance Minister Arun Jaitley on Sunday said that people who had not declared their undisclosed assets in the 90-day compliance window offered by the government will now face the law including penalty and sentence upto 10 years while 638 people who had made the declaration can “now sleep well.” In… – Continue reading

Global Tech Firms Brace for Tax Rules Which Could Create New Disputes

PARIS–Global tech firms such as Amazon.com Inc. are already preparing for new tax rules that could force them to pay corporate taxes in more countries where they operate, but are also girding for what some say will be more fights with–and between–national tax authorities. The Organization for Economic Cooperation and… – Continue reading

A Tax Revolution in the Making in EU

Europe’s stiff-neckedness is difficult to cure. To come to an agreement for supranational treatment of a certain issue there needs to be a large cataclysm or at least a large scandal. In the case of taxation policy the problem begins to gain urgent and most importantly European status after the… – Continue reading

Corporate tax regime to face renewed scrutiny

EU member states to reveal information on tax rulings offered to companies Ireland’s corporate tax regime is to come under renewed scrutiny next week as EU finance ministers sign off on a proposal obliging member states to reveal information on tax rulings offered to companies. EU finance ministers meeting in… – Continue reading

SA ranks above developed countries in ‘hidden’ money

SOUTH Africa has ranked higher than several developed countries in an assessment of money “hidden” in HSBC Swiss bank accounts, a report showed on Wednesday. “The money connected to SA was higher than money connected to France, eight times higher than that of the US, and 3.5 times more than… – Continue reading

Italy’s Renzi faces uphill struggle over Google Tax plan

Under pressure to find resources for his promises of sweeping tax cuts, Italian Prime Minister Matteo Renzi is hoping to raise billions of euros by forcing multinational Internet firms to pay taxes on profits generated in Italy. Treasury Undersecretary Enrico Zanetti said a so-called “Google Tax” could yield up to… – Continue reading

New SwissLeaks analysis reveals how tax haven secrecy harms developing countries

30 September 2015 -New, detailed examination of the SwissLeaks files by Christian Aid working with the US-based Financial Transparency Coalition (FTC) graphically reveals the harm tax haven secrecy does to the economies of developing countries. The SwissLeaks scandal involves thousands of secret accounts at HSBC’s Swiss subsidiary HSBC Private Bank… – Continue reading

US$7.6tn hidden in tax havens – almost half annual US GDP

Gabriel Zucman, one of 3 French economists who in recent times have published extensive research on wealth and equality, in a book, ‘The Hidden Wealth of Nations: The Scourge of Tax Havens,’ published this month, estimates that 8% of the world’s financial wealth — some US$7.6tn — is hidden in… – Continue reading

Tax Havens Are Turning The U.S. Into An Unequal Aristocracy

French economist Gabriel Zucman, a protégé of Thomas Piketty, has a new book outlining how to avoid this. To Gabriel Zucman, protégé of rock star French economist Thomas Piketty, the United States is starting to look a lot like Europe in the late 1800s. “There’s been this great reversal where,… – Continue reading

Corporate taxation system has reached its limits, say ministers and MEPs

Tax competition as such cannot be avoided, but today’s system has reached its limits and led to unwanted side effects. Small firms should not have to bear the tax burden of multinationals that pay very little. Action is needed to harmonise corporate tax practices across Europe, so as to make… – Continue reading

MEPs: Make EU Corporate Tax System ‘Fairer’

Action is needed to harmonize corporate tax practices across Europe, according to the European Parliament’s Special Committee on Tax Rulings. The committee said this was the key sentiment voiced during a meeting with finance ministers from Luxembourg, Italy, France, Spain, and Germany on September 22. According to the committee, while… – Continue reading

Eurozone heavyweights resume tax offensive on multinational companies

Finance ministers of euro zone’s major economies renewed on Tuesday their commitment to curb multinational corporations’ tax avoidance and called for more consistent rules to reduce “harmful” tax competition. Multinational companies have long been in the sights of European Union authorities because of the way they can legally reduce their… – Continue reading

New global tax crackdown could impact asset owners

A new wave of global tax compliance regulation is a game changer in the way asset owners and investment management companies report activities. Globalization of financial markets has made it increasingly simple to make, hold and manage investments outside an asset owner’s own tax domicile. A standard on automatic exchange… – Continue reading

Changing attitudes to tax reputation risk

Changing Attitudes to Tax Reputation Risk In recent years, it seems that any discussion of tax includes mention of the moral obligation taxpayers have to “pay their fair share.” Many believe this theme began to get traction in 2011 when Warren Buffett realized that he was paying proportionately less taxes… – Continue reading

Corruption in China: This will blow your mind

Is Xi Jinping (習近平)’s anti-corruption campaign crushing it or embarrassingly ineffective? You make the call. It was widely reported the year before Xi assumed office that upwards of 18,000 corrupt officials had fled China since 1990 with about US$120 billion. In early 2012, the Ministry of Supervision released figures saying… – Continue reading

FRANCE: TRANSFER PRICING ASSESSMENTS; WITHHOLDING TAX RELIEF FOR REPATRIATED PROFITS

New Article L. 62 A of the French tax procedure code (published in the official bulletin on 2 September 2015) sets forth rules that effectively regularize the tax treatment of certain profits transferred abroad by French taxpayers, and allows for the repatriation of these funds without additional tax—and in particular,… – Continue reading

The Advantages of Enacting a Patent Box Regime

Many countries have enacted a patent box regime in order to spur innovation and create domestic manufacturing jobs. Simply stated, a patent box regime provides a lower tax rate on income from the exploitation of patented goods than for other income. Among the countries that have patent box regimes are… – Continue reading

Moscovici resolute on common corporate tax base

EU commissioner urges member states to ensure fair share of tax is paid EU economics commissioner Pierre Moscovici reiterated his commitment to re-launch the Common Consolidated Corporate Tax Base yesterday, urging all EU member states to ensure that companies pay their fair share of tax. Speaking following a meeting of… – Continue reading

Italy sees progress on euro zone financial transactions tax

The finance ministers of 11 euro zone countries willing to introduce a financial transactions tax (FTT) are expected to make progress on the thorny issue in a meeting on Saturday in Luxembourg, Italy’s economy minister said. Germany and France proposed the tax in 2012, in the midst of the euro… – Continue reading

France hands Cyprus controversial list of HSBC depositors

France has handed to Cypriot authorities a controversial list of Cypriots with deposits at HSBC bank in Switzerland, Finance Minister Harris Georgiades said on Tuesday, reports the Famagusta Gazette. Cypriot parliamentarians probing the cause of the near melt-down of the economy in 2013 have repeatedly urged the government to obtain… – Continue reading

The Implications for International Tax Planning From the Looming Fiscal Crisis

The international financial sector faces a perilous future. Major challenges loom over an uncertain global economy, while a decidedly negative political climate poses an existential threat to the offshore financial community. With each passing year, thanks to demographic changes and poorly designed fiscal policies, politicians from high-tax nations will be… – Continue reading

New Swiss Banking Norms May Not Help India’s Hunt for Black Money

Switzerland will allow stolen data acquired through official means to form the basis for a request for assistance but will help India only for post-2011 bank accounts, that too as long as Swiss courts don’t interfere Geneva: Switzerland’s proposed changes on treating stolen information have generated much optimism in India… – Continue reading

EU loses 168b euros in sales tax fraud, errors

BRUSSELS: European Union (EU) countries lost 168 billion euros (US$187 billion, S$266 billion) in sales-tax revenue in 2013 mostly due to fraud and errors, the European Commission said on Thursday (Sep 3). According to a commission study which covered 26 of the EU’s current 28 members, a total 15 percent… – Continue reading

FRANCE: DIVIDENDS RECEIVED BY PARENT COMPANIES; DIFFERENT TAX TREATMENT CHALLENGED

The Court of Justice of the European Union (CJEU) today issued a judgment concluding that the different tax treatment of dividends received by parent companies of tax-integrated groups, with such treatment depending on the location where the subsidiaries are established, is contrary to EU law. The CJEU judgment therefore holds… – Continue reading