Category: France

Ireland making ‘little or no’ effort to curb corruption – report

Ireland has made “little or no” effort over the past four years to create a corruption-free playing field for global trade, violating its “obligation to combat cross-border bribery”, reports the Irish Times. The Transparency International Exporting Corruption report, released on Thursday, found that Ireland, along with countries such as Russia,… – Continue reading

Worldwide: Double Tax Treaties – Ratification Update

LUXEMBOURG On September 5, 2014, the Ministers of Finance of France and Luxembourg signed an amendment (Lux Amendment) to the double tax treaty entered into between France and Luxembourg on April 1, 1958, as amended by the 1970 exchange of letters and by the 1970, 2006, and 2009 protocols (FR/Lux… – Continue reading

LUXEMBOURG: TAX TREATY UPDATE, STATUS REPORT

Luxembourg currently has 76 income tax treaties in force, and there are 29 treaties under negotiation. Tax treaties can provide a legal framework not only for the avoidance of double taxation and fiscal evasion, but also for international administrative cooperation between Luxembourg and its treaty partners in terms of mutual… – Continue reading

Worldwide: Governments Continue To Welcome Wealthy Foreigners

With the UK announcing new tax rules for foreigners living in the country, the government has been careful not to damage the country’s appeal to wealthy foreigners. The “non-dom” tax status “plays an important role in allowing those from abroad to contribute to our economy”, says George Osborne, the UK’s… – Continue reading

Gov’t, Denmark reach double taxation deal

The Danish government is hopeful ratification of the convention for avoidance of Double Taxation agreements (DTA) with Ghana — and the Prevention of Fiscal Evasion with respect to taxes on income and capital gains between the two countries — will help to double Denmark’s investment in the country. This brings… – Continue reading

OECD likely to recommend fixed ratio cap on interest tax deductibility, says expert

The Organisation for Economic Co-Operation and Development (OECD) is likely to recommend that restrictions on interest deductibility should mainly involve a cap calculated as a percentage of EBITDA, an expert has said.07 Aug 2015 Corporate tax Tax International tax Energy Infrastructure However Heather Self of Pinsent Masons, the law firm… – Continue reading

Luxembourg’s Euro Note Love Affair Raises Eyebrows Over Taxes

While the European single currency’s existential crisis drags on in Athens, it turns out Luxembourg likes its euros — a lot — as foreigners with accounts in the Grand Duchy try to stay one step ahead of the taxman. Luxembourg’s central bank issued 15 percent more euro notes in 2013,… – Continue reading

EC Will Not Challenge Member States On Royalties Tax

Tax Commissioner Pierre Moscovici has said that European Commission law was not breached in the case of a French professional association taxing royalty payments earned by UK musicians in France. In a written question to the European Commission, Julie Girling, a UK Member of the European Parliament (MEP), alleged that… – Continue reading

OECD Common Reporting Standard to come into effect in Canada on July 1, 2017

Canadian financial institutions will be subject to the Organisation for Economic Co-operation and Development’s (OECD) Common Reporting Standard as of July 1, 2017 with the first exchanges of financial account information beginning in 2018. The CRS, known formally as the Standard for Automatic Exchange of Financial Account Information in Tax… – Continue reading

Canada: Interest Deductibility In Canada: What’s The Fuss?

This article deals with the manner in which Canada has complicated, and rendered controversial, what in most other countries is straightforward — the deductibility of business related interest expense. The reasons to write about it are threefold: the almost-concurrent issuance of the Canada Revenue Agency’s administrative views on the matter… – Continue reading

EDF hit with £1bn tax bill

EDF is now an global player in providing electricity, relying on France’s 58 nuclear reactors, as well as developing new plants, notably the controversial Hinkley Point project in Britain. The European Commission’s investigation found the energy company, which is the main electricity provider in France, benefited from tax breaks that… – Continue reading

EU orders France to recover state aid from EDF

BRUSSELS–European Union regulators ordered France to recover 1.37 billion euros ($1.5 billion) in state funds from Electricite de France SA (EDF.FR) after concluding the French electricity supplier had benefited from illegal tax breaks. The decision, which follows an annulment of a similar 2003 decision by the EU’s top court, comes… – Continue reading

New online service to help recover tax paid on share dividends abroad

Irish people investing in other countries often lose up to a fifth of dividends Irish tax refund specialists Taxback. com have introduced an online service to help people recover tax withheld on share dividends in other countries. *Irish people investing abroad often lose up to a fifth of their dividends… – Continue reading

The French 3 Percent Distribution Tax: Claiming a Refund

Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely questioned whether this tax is compliant with the provisions of the EU treaties and the double tax treaties signed by France. French subsidiaries whose parent… – Continue reading

Cabinet approves co­op agreements with several countries

KUWAIT, July 13 (KUNA) ¬¬ The cabinet, under the chairmanship of His Highness the Prime Minister Sheikh Jaber Al¬Mubarak Al¬Hamad Al¬Sabah, approved Monday a number of agreements to boost cooperation with several friendly countries. The endorsed agreements included a memorandum of understanding for cooperation in social insurance with Bahraini government,… – Continue reading

OECD establishes roadmap for membership with Lithuania

10/07/2015 – The OECD set out a clear path for Lithuania’s accession to the Organisation, reinforcing the OECD’s commitment to further extend its global membership. On 8 July 2015 the 34 OECD Members adopted the Roadmap for the Accession of Lithuania to the OECD Convention setting out the terms, conditions… – Continue reading

France: French Tax Update – Recently Published Noteworthy Decisions – July 2015

The present French Tax Update will focus on an overview of several noteworthy French tax court decisions issued during the past few months. BUYBACK AND CANCELLATION OF OWN SHARES The tax treatment of buybacks, from the shareholders’ point of view, has now been simplified through a change of legislation, i.e.,… – Continue reading

BEPS Action 3: How Not to Engage with CFC Rules

Action 3 of the OECD’s Base Erosion and Profit Shifting (BEPS) agenda promised to address how countries could use controlled foreign corporation (CFC) rules to combat BEPS. Unfortunately (or fortunately, depending upon one’s vantage point), as is pretty much universally agreed, the OECD’s draft report on CFC rules (the “draft”)1… – Continue reading

UK ratification of UPC Agreement won’t happen in 2015, IPO confirms

The Unified Patent Court (UPC) Agreement will not be ratified in the UK this year, the Intellectual Property Office (IPO) has confirmed. In a statement sent to Out-Law.com, the IPO ruled out ratification of the Agreement this year but said that it intends to complete the “domestic preparations” for ratification… – Continue reading

FATCA – Which Countries Are In And Out

FATCA – Which Countries Are In And Out The controversial US Foreign Account Tax Compliance Act (FATCA) law is set to start from July 1, 2014, so with less than 21 days to go, here’s a look at which countries are in and who is outside of the tax network…. – Continue reading

St. Kitts-Nevis Among 30 Countries On EU’s Tax Evasion Blacklist

St. Kitts and Nevis is one of 30 countries placed on the European Union’s black list for not doing enough to fight tax evasion. The EU’s executive Commission published the list Wednesday (June 17). The blacklisted countries figure on at least ten of the EU’s 28 member nations’ lists of… – Continue reading

Cyprus: The Potential Impact Of Russian De-Offshorization Legislation On Cyprus Holding And Finance Structures

Abstract Over the past 25 years, Cyprus has become the portal of choice for investment into and out of Russia and Central and Eastern Europe. The new Russian de-offshorization law, which took effect on 1 January 2015, will have significant implications for users of overseas structures. This article examines the… – Continue reading

EU Seeks Transaction Tax as 11 States Meet in Bid to Choose Path

The 11 European nations seeking a financial-transactions tax will meet Thursday in Luxembourg in a bid to decide how to design the measure, according to European Union officials. Participating states are wrangling over which trades to tax and who should collect revenue, according to planning documents obtained by Bloomberg News…. – Continue reading

Bermuda named on EU tax haven list

The European Union: Labelled Bermuda as a tax haven Bermuda has been named by the European Union as a country that is not doing enough to crack down on tax avoidance. The Island was one of 30 countries on the list published by the EU’s executive Commission today. “These tax… – Continue reading

Can The United States Kill BEPS?

The United States is through trying to needle the OECD’s base erosion and profit-shifting project with pinpricks. Last week, Robert Stack, U.S. Treasury deputy assistant secretary (international tax affairs), abandoned the subtle digs Treasury had been using to attack BEPS and flat-out said the United States is extremely disappointed in… – Continue reading

Brussels to announce measures against corporations’ ‘sweetheart’ tax deals

Politically incendiary proposals will set sights on multinationals’ tax planning with EU states and 30 worst offending havens could be officially blacklisted Officials in Brussels will on Wednesday announce a series of measures designed to stamp out the toxic culture of secret, sweetheart tax deals for multinationals which prevails in… – Continue reading

Airbnb, Amazon Land on French Senators’ Tax Radar as Sales Soar

France is trying to squeeze more out of web businesses like EBay Inc., Amazon.com Inc. and Airbnb Inc. Soaring online sales and the use of the Internet giants by smaller businessses as a marketplace for goods and services is prompting the French Senate to look for ways to collect more… – Continue reading

Secret Swiss accounts bring 540 million into Belgian treasury

There’s been a preliminary investigation into the amount of money that secret bank accounts Belgians have in Switzerland can yield for the Belgian treasury. It turns out the answer is EUR 540 million. Finance Minister Johan Van Overtveldt (Flemish Nationalists) revealed the figures to financial newspaper De Tijd. “However, the… – Continue reading

India joins the Multilateral Competent Authority Agreement (MCAA) on Automatic Exchange of Information (AEOI)

India joined the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information on 3rd June, 2015, in Paris, France, alongwith Australia, Canada, Costa Rica, Indonesia and New Zealand. On our behalf, the Declaration to comply with the provisions of the MCAA was signed by H.E. Mr. Mohan Kumar,… – Continue reading

deVere: Presidential candidates owe it to America to explain their stance on controversial FATCA

Presidential candidates must come clean on America’s highly controversial global tax law – and more must urgently be done to repeal it, not least because it is “a blue print for worse to come”, warns the boss of one of the world’s largest independent financial advisory organisations. Nigel Green, founder… – Continue reading

French tax updates – recently published noteworthy publications

The present French Tax Update will focus on an overview of several noteworthy French tax court decisions issued during the past few months, in particular in relation with double tax treaty conditions to benefit from a tax credit, abuse of law challenges, increased amortization rates, and priority preliminary ruling requests… – Continue reading

After Switzerland Names 7 Indians, More Expected, Say Officials

Bern, Switzerland: As India tries to uncover who has stashed untaxed money abroad, Switzerland is, in an unusual deviation from its super-secretive banking rules, releasing the names of people who are being investigated for alleged tax evasion in their countries of origin. Among the seven Indians named so far by… – Continue reading

France and Germany behind plans for ‘common EU corporation tax’

France and Germany want to see common basic corporation tax rates across the EU, according to reports France and Germany are pushing plans to introduce a minimum corporation tax rate across the continent, it was reported today, in a move that could result in higher taxes on British companies. European… – Continue reading

Lux Leaks Scandal. Juncker Gets A Step Closer to Hot Seat

Jean-Claude Juncker, President of the European Commission, just got a step closer to explaining his role in the Lux Leaks scandal. Speaking after an official visit to Luxembourg, German Member of the European Parliament, Fabio De Masi said: “It is becoming increasingly clear that powerful EU member states like Germany… – Continue reading

OECD says countries won’t be able to game tax system

Short cuts, loopholes and other forms of skulduggery will not be tolerated when the automatic exchange of tax information comes into force, a top official from the Organisation for Economic Co-operation and Development (OECD) has promised Swiss bankers, reports FinFacts. Grace Perez-Navarro, second in command at the OECD’s tax policy… – Continue reading

UK: Non-UK Domiciliaries: Inheritance Tax Issues And Opportunities

This note is intended as an introduction to inheritance tax (IHT) issues that need to be covered where a “non-dom” (an individual domiciled outside the UK) is planning on becoming resident in, or is already resident in, the UK. It should be emphasised that this is a complex subject, and… – Continue reading

Chairman Royce, Rep. Pallone welcome US-Amenia Trade & Investment Framework Agreement

House Foreign Affairs Committee Chairman Ed Royce (R-CA) and Congressional Armenian Caucus Co-Chair Frank Pallone (D-NJ) were among the first Congressional leaders to welcome the May 7th signing of the U.S.-Armenia Trade and Investment Framework Agreement (TIFA), a longstanding policy priority for the Armenian National Committee of America (ANCA). Chairman… – Continue reading

Estimating the illicit funds in global tax havens

The total “development finance” loss – counting both revenues and reinvested earnings – is estimated in the range of $250 to $300 billion. This prevents developing countries from stopping the outflow of money, which thus bleeds them of essential resources The financial crisis of 2008 had an interesting collateral benefit… – Continue reading

Falciani: all banks help evade taxes

All the world’s major banks have connections between each other and work together in a secret network to help people evade taxes, whistleblower and former HSBC IT engineer Hervé Falciani said yesterday, warning that illegal offshore transactions can’t be carried out through one single bank but only with the help… – Continue reading