Category: France

French real estate holdings through Luxembourg vehicles may need to be revisited, says expert

Structures for investments from overseas investors in French real estate that involve Luxembourg vehicles may need to be restructured if an expected change to the double tax treaty between France and Luxembourg takes effect, an expert has said.09 Mar 2015 Property tax Property Tax Structured real estate Specialist property investment… – Continue reading

France’s Hollande presses Luxembourg on tax avoidance

Luxembourg: French President Francois Hollande urged Luxembourg on Friday to “go as far as possible” in tackling tax avoidance in the wake of the Luxleaks scandal. Investigative journalists last year found top international companies including Disney, Microsoft and Heinz benefiting from sweetheart tax deals with Luxembourg. “Luxembourg has committed to… – Continue reading

Continued crackdown on tax evasion by French authorities to yield additional 2 billion euros in 2015

PARIS: A continued crackdown on tax evasion could rake in two billion euros (US$2.2 billion) this year, similar to the amount raised in 2014, French Finance Minister Michel Sapin said. Looking to shore up fragile state accounts, France has launched a campaign to encourage taxpayers to come clean on previously… – Continue reading

Corporate aristocracy holding out against tax revolution

Smaller companies, which innovate and create jobs, carry an unfair share of the burden In pre-revolutionary France aristocrats were exempt from direct taxation. On present trends the world’s elite corporations may soon find themselves similarly privileged. In the larger advanced countries the corporate tax base is eroding, partly because the… – Continue reading

The Quiet Man Who Made Big Trouble for Little Luxembourg

Antoine Deltour sees himself as “just a little auditor” who copied some tax files. Now he may face jail after those documents helped send a shock wave through Luxembourg that is reverberating across the European Union. (Bloomberg) — Antoine Deltour sees himself as “just a little auditor” who copied some… – Continue reading

TRANSFER PRICING LITIGATION ISSUES NEED TO BE ADDRESSED:PWC

Certainty and reduced litigation on transfer pricing (TP) issues will be the cornerstone of creating a non-adversarial tax regime in India. The authors believe that Budget 2015 ought to lay out a roadmap to achieve this goal for TP issues – Recent positive progress on the Advance Pricing Agreement (APA)… – Continue reading

HSBC whistle-blower: You have to know how banks work to understand the size of this scandal

Hervè Falciani, the former HSBC employee who became a whistle-blower by handing over details of client bank accounts to French authorities, triggering investigations into money laundering and tax evasion, believes many other banks are involved in similar practises. In an interview with the Italian newspaper La Stampa, Falciani said that… – Continue reading

Offshore decumulation opportunities with Old Mutual International

David Denton, technical expert at Old Mutual International, explores the new decumulation opportunities which are emerging in the offshore market, looking at how they compare to traditional drawdown or annuity options. International annuities targeted at retail investors are emerging in the offshore market which allow QROPS or QNUPS when crystallized… – Continue reading

Singapore, France sign pact for Avoidance of Double Taxation

PARIS: Singapore and France signed an amended Agreement for the Avoidance of Double Taxation (DTA) to lower withholding tax rates for dividends and new anti-abuse provisions. The most notable changes are the following: Withholding tax rate for dividends is reduced to 5 percent (from 10 percent previously) if the beneficial… – Continue reading

Ukraine suddenly 40% more interested in UK tax info – HMRC

Growing trend of chasing ‘high net worth foreign nationals’? Cooperation between HM Revenue and Customs (HMRC) and foreign tax authorities will only increase as more countries sign up to automatic tax information exchange agreements. This is according to Pinsent Masons, the law firm behind Out-Law.com, which obtained figures showing a… – Continue reading

Jump In Foreign Requests For UK Tax Information

The number of requests from foreign governments for tax information from the UK rose by 45 percent in 2013, according to international law firm Pinsent Masons. 2,466 requests were received by HM Revenue and Customs (HMRC) in the year to December 31, 2013, up from 1,701 recorded in 2012. James… – Continue reading

Switzerland opens money-laundering probe of HSBC after tax evasion reports

BERLIN – Geneva prosecutors searched the premises of HSBC’s Swiss subsidiary on Wednesday after launching a money-laundering investigation over a report that the bank helped hide millions of dollars for drug traffickers, arms dealers and celebrities. Prosecutors said they were investigating HSBC Private Bank (Suisse) SA and persons unknown for… – Continue reading

Revenue collects €1bn from special investigations

Probes since 2001 into offshore accounts include €4.6m from Irish HSBC customers The Revenue Commissioners has collected just more than €1 billion since 2001 from various special investigations of offshore bank accounts held by Irish residents. This includes the €4.6 million received to date from the holders of offshore accounts… – Continue reading

Leaked Documents Reveal HSBC Bank’s Dirty Dealings with Tax Dodgers, Drug Traffickers and Arms Dealers

A team of journalists from 45 nations who investigated documents leaked by a former systems engineer working for banking giant HSBC’s Geneva, Switzerland branch, found HSBC managed secret bank accounts for criminals, drug traffickers, tax dodgers, politicians and celebrities. The documents, covering the period from 2005 to 2007 revealed, according… – Continue reading

Singapore and France revise their tax convention

Singapore and France signed a revised Agreement for the Avoidance of Double Taxation (DTA) on 15 January 2015, which is not yet in force. The new DTA provides for lower withholding tax rates for dividends and new anti-abuse provisions. The most notable changes are the following: 1. Withholding Tax Withholding… – Continue reading

France denies restricting UK pursuit of HSBC tax evaders

Feb 13 (Reuters) – France’s finance minister said on Friday Paris had not restricted the use of HSBC client data it passed on to UK authorities to help pursue tax evaders, contradicting comments by a senior British official. Britain’s Financial Secretary to the Treasury David Gauke said in parliament this… – Continue reading

Singapore inks tax agreements with France and Uruguay

SINGAPORE: Singapore has signed agreements with France and Uruguay for avoidance of double taxation (DTA). In the agreement with France, the revised DTA offers improved terms for businesses, such as lower withholding tax rates for dividends and includes anti-abuse provisions. The signing took place in Singapore between Singapore Deputy Prime… – Continue reading

HSBC admits its Swiss private bank may have been involved in tax avoidance

HSBC is under fire, after a large cache of leaked bank files revealed that it helped clients evade taxes and conceal millions of dollars. The files, which cover the period 2005-07, amount to the biggest banking leak in history, shedding light on some 30,000 accounts holding almost $120bn. HSBC was… – Continue reading

Venezuela Outdoes All LatAm Nations in HSBC Tax-Evasion Scheme

Latin-American politicians Horacio Cartes (president of Paraguay), Álvaro Noboa (former president of Ecuador), and Alejandro Andrade (Venezuela’s ex-national treasurer) have one thing in common: they all possessed, until at least 2007, secret accounts with HSBC’s private Swiss bank. This according to the Swissleaks report published on Sunday, February 8, which… – Continue reading

Newspaper headlines: Tax evasion, bonds ‘bribe’ and ‘Twitter asbos’

The Guardian’s very “word-heavy” front page is entirely taken up with details about what the paper calls “questionable practices” at a subsidiary of HSBC – one of the world’s largest banks. The paper says the financial institution’s private Swiss bank “helped wealthy customers dodge taxes and conceal millions of dollars… – Continue reading

French tax update: new China – France double tax treaty, amendment to Singapore – France double tax treaty, noteworthy tax courts decisions and administrative publications

The present French Tax Update will focus on (i) the most salient features of the new double tax treaty signed by the People’s Republic of China (China) and France on November 26, 2013 (New DTT), (ii) the new double tax treaty signed by Singapore and France on January 15, 2015,… – Continue reading

BEPS Action Plan 5: Countering harmful tax practices

IN LAST WEEK’S column we talked about the OECD’s BEPS Action Plan on Hybrid Mismatch Arrangements. This week’s column focuses on the OECD’s Action Plan on Harmful Tax Practices (HTP). As the world economy continues the process of globalization and technological advances, tax authorities from various jurisdictions are inevitably faced… – Continue reading

Transfer Pricing Leaders To Address Latest Trends At Bloomberg BNA-Baker McKenzie Global Conference In Paris March 30-31

ARLINGTON, Va., Jan. 28, 2015 /PRNewswire-USNewswire/ — Bloomberg BNA today announced that its Global Transfer Pricing Conference: Paris, held in conjunction with Baker & McKenzie and in association with the Tax Management Education Institute, will occur on March 30-31 immediately after the Organisation for Economic Co-operation and Development (OECD) Global… – Continue reading

‘The age of financial privacy is over’

Jonathan Weiss hasn’t lived in the US for 25 years. But that didn’t keep his foreign bank account from being frozen in the wake of new US tax laws. Find out how you can avoid the same fate at the hands of FATCA. “I had been living in Switzerland for… – Continue reading

Techie fee thorn in US ties

New Delhi, Jan. 23: India and the US have failed to make much progress in the totalisation pact that addresses the the problem of the double payment of social security taxes by Indian software professionals in America, dampening expectations surrounding President Barack Obama’s visit this weekend. Top officials said discussions… – Continue reading

Tax Agreements with France and Uruguay will benefit Singapore companies looking to Expand, says Singaporecompanyincorporation.sg

With the city-state revising its earlier avoidance of double taxation agreement with France and signing a new one with Uruguay recently, a boost in cross-border trade is inevitable. Singapore (PRWEB) January 22, 2015 In what can be termed as two important milestones in Singapore’s trade relations with Europe and Latin… – Continue reading

The World Wide Tax Web: FATCA Data Sharing Goes Online

The IRS has unveiled a secure web application, the International Data Exchange Service (IDES), for cross-border data sharing. IDES will allow Foreign Financial Institutions (FFIs) and tax authorities from other countries to transmit financial data on U.S. taxpayers’ accounts, via an encrypted pathway, to the IRS. The tool is part… – Continue reading

North East business and airport leaders concerned region to be made guinea pig for tax reforms

SUCCESSFUL INTERNATIONAL STRUCTURES in most cases begin with choosing the right jurisdiction to host a company that will form part of an international business. Depending on the company’s activities, the choice will depend on the range of double taxation treaties and the availability of tax reliefs followed by a host… – Continue reading

U.S. and China Team Up to Launch Global Tax System

In the world of offshore asset protection and personal finance, you regularly come across the claim that there are only two countries that actively tax their residents’ worldwide income: the United States and Eritrea. All other countries only tax income earned at home. That’s apparently no longer true. It turns… – Continue reading

Singapore, France revise agreement to avoid double taxation

SINGAPORE: A revised Agreement for the Avoidance of Double Taxation (DTA) was signed between the Republic and France on Thursday (Jan 16). The revised DTA offers improved terms for businesses such as lower withholding tax rates for dividends and includes anti-abuse provisions, according to a joint press release on Friday…. – Continue reading

HSBC’s tax evasion scandal: Public Accounts Committee to grill HMRC boss Lin Homer

HMRC chief executive Lin Homer will face questions today before the Public Accounts Committee (PAC) about the HSBC tax evasion scandal. The agenda of the scheduled meeting between Homer and the PAC has been overtaken by this week’s revelations about HSBC “assisting” over 7,000 UK nationals with their tax affairs…. – Continue reading

Swiss banks target Israeli tax evaders

Swiss banks are training their crosshairs on Israeli customers. Legal sources said that in the past two weeks, the large banks in Switzerland have begun sending many queries to their Israeli customers demanding confirmation either that the assets deposited with the banks were reported to the Israeli tax authorities, or… – Continue reading

Luxembourg Supports EU Tax Ruling Reforms

The Luxembourg Government is to provide the European Commission with a list of the tax rulings issued by its tax authorities, along with a list of the beneficiaries of its concessionary tax regime for intellectual property (IP) income. Luxembourg Prime Minister Xavier Bettel announced that the decision had been made… – Continue reading

The Year of Transparency’s Tipping Point

More countries are requiring an exchange of client information In 2014, we saw a marked increase in transparency regarding foreign assets. The United States took the lead, and other countries followed suit. It looks like we’ve reached the tipping point, that is, “the magic moment when an idea, trend, or… – Continue reading

uncker turns tax debate away from Luxembourg and on to entire EU

Debate on multinational tax avoidance widens The surprise announcement by the European Commission that it is to extend its request for information on tax rulings to all European Union member states has the potential to significantly shift the terms of the debate on multinational tax avoidance. The timing of the… – Continue reading