Information from Reuters has brought to light the fact that five of the biggest banks operating in the UK (and worldwide) paid not a penny in corporation tax in 2014. Efforts to crack down on this kind of corporation tax avoidance have brought together Westminster’s political right and left. Deutsche… – Continue reading
Information will feed into relaunch of the revised common consolidated corporate tax base The European Commission has received more than 170 submissions on its proposal for a revised common consolidated corporate tax base (CCCTB) ahead of its re-launch later this year. The closing date for the commission’s three-month public consultation… – Continue reading
Filippo Noseda has examined the impact of the OCED’s Common Reporting Standard (CRS) on trusts at a time when they are under threat in a number of continental European jurisdictions in an article which was first published in Trust Quarterly Review, Volume 13, Issue 3 2015. Filippo concludes that these… – Continue reading
The Organisation for Economic Co-operation and Development’s base erosion and profit shifting process will not have significant implications on Luxembourg-based companies, Fitch Ratings has said. The agency on January 8 re-affirmed Luxembourg’s AAA rating, with a stable outlook. According to Luxembourg for Finance, the territory’s financial services promotional agency, the… – Continue reading
Jan. 11 — The European Union is resuming efforts to create a common system for calculating the tax base of businesses operating in the EU, and aims to adopt the OECD BEPS package by the end of the Dutch EU presidency in June, a top official said. “This is the… – Continue reading
On 10 December 2015 the remaining changes to the income tax and the capital gains tax laws aiming to improve the tax system of Cyprus and make it more attractive to both the local and international business community were voted. The changes came into effect with their publication in the… – Continue reading
BRUSSELS – Three Italian consumer organizations have urged EU antitrust regulators to investigate McDonald’s (MCD.N) franchise system in Europe, a month after the opening of an EU inquiry into the U.S. fast food company’s tax deals with Luxembourg. Codacons, Movimento Difesa del Cittadino and Cittadinanzattiva filed their complaint with the… – Continue reading
An individual who has been normally resident outside the EU for the last ten continuous years intends to import a private jet into the UK. The aircraft is owned by a BVI company and is currently based in North America. The individual is a director and majority shareholder of the… – Continue reading
ECOFIN’s latest monthly review of VAT measures includes abandoning plans for a standard VAT return across 28 countries. The Czech Republic has requested to pilot the domestic reverse charge, an anti-VAT fraud measure. The EU’s Economic and Financial Affairs Council (ECOFIN) latest update on VAT measures includes, as anticipated, abandoning… – Continue reading
AB InBev says it’s `disappointed’ and is assessing its options Vestager lashes out at `double non-taxation’ schemes BRUSSELS – The European Union ordered Belgium to recover about 700 million euros ($763 million) in illegal tax breaks given to at least 35 companies, including Anheuser-Busch InBev and BP, as regulators continued… – Continue reading
The European Union ordered Belgium to recover about 700 million euros ($762 million) in illegal tax breaks given to at least 35 companies, including Anheuser-Busch InBev NVand BP Plc, as regulators continued a crackdown on overly generous tax schemes throughout the 28-nation bloc. The European Commission told Belgium to recoup… – Continue reading
The first stage of an un-precedented worldwide crackdown on tax evasion and banking secrecy has got under way, with Irish banks this week starting to collect details of non-resident bank account holders. The collection of information follows on from the agreements brokered by the Organisation for Economic Co-operation and Development… – Continue reading
January 2016 You will find below a summary of some of the most important tax developments that have happened since the release of our last newsletter, at OECD, EU or country level, in the area of tax transparency and the fight against tax avoidance. EU – Tax transparency and anti-BEPS… – Continue reading
A law implementing the common reporting standard (CRS) in Luxembourg law has been enacted. The law was published on 24 December 2015. Accordingly, the CRS measures for the automatic exchange of financial account information in the field of taxation are enacted as of the end of 2015. The CRS law… – Continue reading
On 1 January 2016, the Common Reporting Standard (CRS) became effective. The CRS is a new, single global standard on automatic exchange of information. It replaces the EU Taxation on Savings Directive and is essentially a global form of FATCA-like reporting. Under the CRS, Irish funds are now required to… – Continue reading
World Finance spoke to Thierry Afschrift, founder of Afschrift Law Firm and university professor, about how tax lawyers can respond to a changing European environment In keeping with much of Europe, Belgium’s tax system has been subject recently to a shift of important proportions, as policymakers there look to boost… – Continue reading
Despite popular campaign and committee recommendations, tax haven restrictions will not be included in bill AN OVERDUE land reform report from the Scottish Government has categorically refused to bring back a proposal which campaigners say would have tackled the phenomenon of Scottish land being owned in offshore tax havens. Dropped… – Continue reading
Twelfth night has come and gone, the Chistmas lights are out but John Lewis has reported a set of sales figures that sparkled. The department store believes it has outperformed its rivals, once again, online in particular. And yet it’s managing director told me the fight with one rival –… – Continue reading
Changes to patent box rukes will mean that businesses must now track and trace all of their research and development (R&D) expenditure AFTER the recent government consultation on the UK’s Patent Box scheme, businesses will find it a challenge to comply with the proposed new rules. The changes will mean… – Continue reading
A striking example of the EU’s efforts to accelerate the implementation of anti-base erosion and profit shifting (BEPS) measures is the amended Parent Subsidiary Directive (PSD). Originally designed to prevent economic double taxation of profits distributed within an EU corporate, the PSD is now also being deployed to counter undesired… – Continue reading
On 14 December 2015, the Swiss Council of States discussed the legislative draft of the Corporate Tax Reform III and in principle approved the reform package. In deviation from the revised draft legislation issued by the Swiss Federal Council on 5 June 2015, the Council of States voted against the… – Continue reading
Here’s our overview of recent Belgian tax developments, including the main new Belgian tax measures adopted by the laws of 18 and 26 December 2015. Speculation tax A ‘speculation tax’ of 33 per cent is introduced on capital gains realised by Belgian resident and non-resident individuals within six months from… – Continue reading
Two more top banks getting away with paying NO corporation tax in the UK: Credit Suisse and Citigroup are latest to admit using previous losses to slash their bills Seven foreign investment banks in London now pay no corporation tax Fines and lawsuits used to slash their tax bills by… – Continue reading
Italy has already brought several cases against global technology companies that have headquarters in low-tax nations like Ireland to avoid paying higher taxes in other countries, like Italy. Tax officials won’t say what Apple has agreed to pay, but citing local reports, the Times reports it may be around $350… – Continue reading
SEATTLE — When someone in Seattle buys a copy of Office at a Microsoft Store, that cash doesn’t take the short route to the company’s area headquarters. Instead, after accounting for state taxes, the profit goes to a Microsoft sales subsidiary in Nevada. From there, much of that money begins… – Continue reading
The Luxembourg Parliament in December 2015 approved tax measures affecting both corporate and individual taxpayers. These provisions generally are effective beginning 2016, with a few measures applying retroactively as from 2015. Among the measures in the tax legislation are the following provisions: Transposition of amendments to the EU Parent-Subsidiary Directive… – Continue reading
The Administration of the Ministry of Finance has announced the upcoming amendment of the Intellectual Property tax regime. The said amendment will incorporate the recommendations of Action 5 of the Organisation for Economic Co-operation and Development (OECD), which were issued on 5 October 2015 for the Action Plan against ‘Base… – Continue reading
Multinational companies have enjoyed a sustained period of falling corporate tax rates around the world. However, with the conclusion of the OECD’s base erosion and profit shifting project earlier this year marking the start of fundamental changes to the international tax system, and with governments more determined than ever to… – Continue reading
MGA executive chairperson Joseph Cuschieri warns organised crime within gaming industry ‘has never been this sophisticated’ Malta Gaming Authority’s executive chairman insisted that the gaming industry will continue to flourish on the island, even if proposed EU legislation to clamp down on tax avoidance goes through. “The threat [of a… – Continue reading
On 18 December 2015, the Regulations implementing the OECD Common Reporting Standard (“CRS“) in Ireland were approved by the Irish Parliament. This update follows on from previous updates published by Maples and Calder Dublin on CRS and US FATCA and outlines the practical next steps for Irish investment funds and… – Continue reading
On 15 September 2015, the Dutch government released its budget for 2016, containing the Tax Plan 2016, which includes certain amendments to Dutch tax law. One of the proposed amendments was the inclusion of an anti-hybrid rule in the Dutch participation exemption regime (“PER”). On 22 December 2015, the amendments… – Continue reading
The Irish Revenue has released a new brief detailing the impact on Irish paying agents of the European Union’s decision to replace the Savings Tax Directive with legislation providing for the automatic exchange of tax information. On November 10, the European Council repealed Directive 2003/48/EC on the taxation of savings… – Continue reading
(CNS Business): Financial Services Minister Wayne Panton is still battling to get the Cayman Islands taken off the latest blacklist, maintaining that the inclusion of Cayman on the European blacklist of financial centres was completely inappropriate and misinformed. However, he said that stigma and the position taken by some nations… – Continue reading
The British government is facing a credibility crisis over its pledge to ensure multinational corporations pay their fair share of tax, after it was revealed that five of the world’s largest investment banks paid no corporation tax in Britain last year, despite making billions in profits. Analysis of the banks’… – Continue reading
THE tax status of people living in Spain has been subject to extensive debate and is still open to interpretation, particularly given taxpayers’ ability to travel freely within the EU’s borderless Schengen countries. There’s no space, here, to detail all the intricacies of this interesting topic but the ten points… – Continue reading
Fertilizer maker CF Industries and Dutch rival OCI NV, which agreed to merge in August, said they would move the tax residency of the combined company to the Netherlands from the U.K., in a move to satisfy inversion rules put in place by the U.S. Treasury. When the deal was… – Continue reading
The Irish Revenue Commissioners have confirmed that the necessary statutory instrument to bring the final common reporting standard (CRS) regulations into Irish domestic law was signed 17 December 2015 and is effective 31 December 2015. Other recent developments concerning the automatic exchange of information (AEOI) regimes, include the publication of… – Continue reading
ZURICH: Negotiators from Switzerland and neighbour Italy reached agreement on Tuesday on how to tax cross-border commuters, wrapping up months of talks that aimed to help Italy crack down on undeclared foreign wealth. The accord, which must be approved by both national governments and parliaments, would see workers paying up… – Continue reading
The Chartered Institute of Taxation (CIOT) has welcomed a change to the Government’s approach1 to improve tax compliance by large companies but remains sceptical about the effectiveness of a ‘special measures’ regime to target tax abuse. John Cullinane, Tax Policy Director, said: “We are pleased that the framework for improving… – Continue reading
A BALANCING ACT in London, folly and redemption in America’s District of Columbia and sheer hypocrisy in Brussels. And in every case, Barbados and many of its Caribbean neighbours were placed in the negative international spotlight at a time when some of the world’s major financial centres are casting about… – Continue reading
An Easy Checkoff for Global Competitiveness: The Case for a U.S. Innovation Box – Robert D. Atkinson – November 30, 2015. “Taxing corporate revenues from innovation-based activities less will not only boost U.S. global competitiveness it will help bring back IP-based corporate profits now overseas. “Within the last decade a… – Continue reading
The organization’s new ambassador in the Brazilian capital Brasília claims trade and mutual investment between Arab countries and Brazil can be worked on. São Paulo – Newly appointed to represent the Middle East and North Africa countries in Brazil, the ambassador of the League of Arab States in the national… – Continue reading
The Council of the European Union released details of a possible draft EU directive, addressing certain “anti-base erosion and profit shifting” (anti-BEPS) initiatives. The issues addressed concern certain international aspects of the proposal for an EU “common consolidated corporate tax base” (CCCTB), and reflect issues that are directly related to… – Continue reading
The European Parliament has spelt out the legal steps needed to improve corporate tax transparency, coordination and an EU-wide policy convergence in a resolution voted on this week. Parliament’s drive to persuade EU member states to act to counter aggressive corporate tax planning and evasion by multinationals in Europe was… – Continue reading
Maltese MEPs and their Cypriot counterparts have voted against a report which urges the European Union to introduce tax convergence and harmonisation among all EU member states. The vote passed with 500 votes in favour, 122 against and 81 abstentions. Head of the Maltese Labour Delegation, Alfred Sant, said that… – Continue reading
On December 8, there was a brief note in the media about the fact that Malta had managed to include a reference to flexibility into a European Council communiqué on taxation. You would be forgiven for overlooking it, assuming it was just a pedantic attempt to score political points. Think… – Continue reading
IP regime To comply with the OECD’s BEPS reports and more specifically its action plan n° 5 regarding harmful tax practices, the Luxembourg intellectual property (“IP“) regime under article 50bis of the Luxembourg income tax law (“ITL“) will be repealed as from 1 July 2016. As such, the Luxembourg 80%… – Continue reading
In the wake of the final OECD BEPS reports issued in October, the European Council adopted amendments to Directive 2011/16/EU providing for the automatic exchange of information concerning advance cross border rulings (ACBR) and advance pricing arrangements (APA) between Member States. The amendments, which will come into force from 1… – Continue reading
It has been a tough year for Russian businesses. The latest monthly forecast of the Economist Intelligence Unit (EIU) predicts a contraction in Russian real GDP of 3.8% in 2015 and another 0.5% in 2016. “Structural weaknesses will keep trend GDP growth below 2% a year in the medium term,”… – Continue reading
Given that the latest treaty was signed on 15 November 1967, the two countries felt it was appropriate to revise it in full. The new treaty, signed on Tuesday by the Spanish Ambassador to Finland, María Jesús Figa, and the Finnish Minister for Finance, Alexander Stubb, seeks to enable tax… – Continue reading
