Over 90 jurisdictions have committed to the OECD’s Common Reporting Standard (CRS), creating comprehensive global automatic information exchange for financial assets and the entities through which such assets may be held. Over 70 jurisdictions have signed the OECD’s Multilateral Competent Authority Agreement, which implements the CRS. The CRS is scheduled… – Continue reading
40% of licenses to frack in the UK are held by companies which are wholly or partly owned in offshore tax havens, a Greenpeace investigation has found. Analysis also shows that Cuadrilla, one of the UK’s leading shale gas firms, is majority owned by entities based in offshore tax havens…. – Continue reading
The common reporting standard framework was first released by the Organisation for Economic Co-operation and Development (the “OECD”) in February 2014 as a result of significant political will demonstrated by the G20 members to endorse a global model of automatic exchange of information and increase international tax transparency. On 21… – Continue reading
The Luxembourg Parliament unanimously passed legislation that would transpose into domestic law an EU directive concerning the automatic exchange of information in the field of taxation (a directive known as “DAC 2”). The DAC 2 provides that EU Member States are to require financial institutions to implement reporting and due… – Continue reading
The European Commission has extended its investigation into a tax ruling provided by the Irish Government to Apple. The Commission has asked the Irish authorities for additional information on the case. Irish media reports that the Government does not anticipate a decision until 2016. In late November, Finance Minister Michael… – Continue reading
A review of the application of EU State Aid rules is crucial for determining if a national tax incentive scheme for IPs is being implemented lawfully. The result of such a compatibility analysis is not certain. In some decisions, the Commission considered ‘Tax Box’ regimes as not being State aid… – Continue reading
Re-launching the Common Consolidated Corporate Tax Basis (CCCTB) Corporate taxation in the EU needs to be fundamentally reformed. Today’s corporate tax systems in EU Member States were conceived in the 1930s, when cross-border trade was more limited, business models were simpler and products were tangible. But as business evolves, so… – Continue reading
Action on tax avoidance could see €600m go from the pharma sector, says report International moves on multinational tax could threaten Ireland, with a potential annual loss of corporate tax revenue of €600 million or more from the pharma sector alone, according to a new report from Chartered Accountants Ireland…. – Continue reading
On 22 December 2014, the Italian Parliament approved the Budget for 2015.40 Among other measures, the Law introduces the possibility of an exemption from corporate income tax (IRES, generally levied at 27,5%) and local tax (IRAP, generally levied at 3,9%) on income derived from qualifying intangible assets (such as patents,… – Continue reading
Latvian President Raimonds Vejonis on December 15th accepted the credentials of the Japanese Ambassador to Latvia, Mariko Fujii, and noted an increase in Latvia-Japan trade recently but said there was still room for growth in economic cooperation, the Latvian president’s press service reported LETA. He said that a treaty for… – Continue reading
The Organisation for Economic Co-operation and Development (OECD) announced that the OECD has responded to a request from the European Commission to include additional fields in the common reporting standard (CRS) XML schema. The EC request was made so as to further the work of the European Commission and the… – Continue reading
Journal: The EU’s ongoing investigation into Luxembourg’s tax agreements with multinational corporations is threatening to leave a black mark on the Grand Duchy at the end of its six-month European presidency. Luxembourg’s finance ministry could face legal action from the European Commission, as the EU authority continues its probe into… – Continue reading
For the Socialist Senator Roberto Zanetti, the reform is an open-heart surgery, which must be done with great accuracy. Under pressure from the EU, G20 and the OECD, also Switzerland is obliged to give up his special tax regimes for holding companies and management companies. After years of negotiations with… – Continue reading
The Belgian Minister of Finance has just shared new insights on how Belgium will be addressing the outcome of the OECD/G20 project in relation to Base Erosion and Profit Shifting (“BEPS”). He opted to do so via the “Plan to combat tax fraud”. The title of his policy note is… – Continue reading
Executive summary On 9 December 2015, the UK released draft clauses for Finance Bill 2016 as well as consultation documents. The key items released include: A new requirement for large businesses to publish their tax strategies as they relate to or affect UK taxation. This sits alongside new ‘special measures’… – Continue reading
According to Baroness Neville-Rolfe, Parliamentary Under Secretary of State at the Department for Business, Innovation and Skills, the United Kingdom “is at the forefront of a dramatic increase in transparency about company ownership” in developed countries. However, it is the UK which is going to provide the testing ground for… – Continue reading
On December 15, 2015 the European Commission issued a media release announcing that on that same date it adopted new rules to make it easier for EU Member States’ tax authorities to exchange financial information so that they can ensure full tax transparency and cooperation. According to the media release… – Continue reading
More good news for Hong Kong before the end of 2015: Italy decided to remove Hong Kong from its national blacklist on November 30, 2015. Italy ratified a comprehensive agreement for the avoidance of double taxation (CDTA) signed with Hong Kong on June 18, 2015. Facilitating an early removal of… – Continue reading
European evaluators urged Vatican prosecutors on Tuesday to move ahead and bring charges in some of the 25 money-laundering investigations they have opened over the past few years as part of beefed-up measures to prevent illicit activity at the Vatican’s scandal-marred bank. The Council of Europe’s Moneyval committee issued the… – Continue reading
Coffee chain Starbucks said it paid £8 million in corporation tax last year after posting record UK profits. The UK arm of the US-based chain said pre-tax profits jumped to £34.2 million in the year to September 27, compared with less than £2 million a year ago – as it… – Continue reading
Main principles of Direct Taxation – Double Tax Treaties In our third article in a series of articles on the tax challenges of the digital economy, we shall be providing you hereunder with a brief overview of the principles of direct taxation, with a focus primarily on the taxation of… – Continue reading
Phillip Paulwell’s response to a question from opposition member Gregory Mair about when a bill to amend the Access to Information Act (ATI) will be taken to Parliament is, at the very least, unsatisfactory and should not be accepted. Paulwell, the leader of government business in the House of Representatives,… – Continue reading
Something unusual is happening with the Irish corporation tax in 2015 — so unusual that Ireland’s top tax man felt obliged to write to the parliament to explain what is going on. But the explanation left a lot to be desired. According to government data, Ireland received 57.7 percent more… – Continue reading
A European Union investigation into whether Apple’s bespoke tax arrangement with the Irish government amounts to illegal state aid has been delayed again, as officials in Brussels continue to gather more information. “We do not expect any decision until after the new year,” a spokesperson for the European Commission told… – Continue reading
You have probably read about the OECD’s comprehensive base erosion and profit shifting (or BEPS) action plan aimed at tackling undesirable international tax planning by corporates. In recent years, the EU, particularly the European Commission, has put substantial effort into accelerating BEPS-like measures in an EU context. A striking example… – Continue reading
The European Commission asked the Netherlands on 19 November to amend the limitation on benefits (LOB) provision in the existing Dutch-Japanese tax treaty. The LOB provision may be detrimental to Dutch companies held by residents of certain EU/EEA countries when they receive interest, royalties and dividends from Japan. They may… – Continue reading
The company that owns the Queen‘s jeweller Mappin & Webb has paid no corporation tax for five years – despite profits of £66million. The allegations made against Mappin & Webb owners Aurum Holdings came as the conduct of firms holding royal warrants was scrutinised amid revelations about their tax arrangements…. – Continue reading
Tax evasion costs the EU €1 trillion a year in lost tax revenue, according to the European Commission. The Lux leaks scandal showed that EU countries sometimes court multinationals with advantageous tax schemes. These practices were investigated by the Parliament’s special committee on tax rulings. MEPs adopted its report last… – Continue reading
Each year the elected leaders of Britain’s overseas territories (OTs) gather from around the world to meet with British Ministers in London. Their objective is to discuss the continuing partnership with the UK, to establish priorities and to try to resolve differences. For the most part the issues covered at… – Continue reading
Outgoing Deloitte Malta chairman and senior partner Andrew Manduca speaks to Anthony Manduca about the future of the financial services sector in Malta, his 36 years in the profession and the need for more accountants. Andrew Manduca is very confident about the future of Malta as a leading international financial… – Continue reading
Cash doesn’t flow directly from buyers’ pockets to Microsoft’s headquarters in Redmond, Wash. Instead, the company operates through three regional sales units, centered in Ireland, Singapore and Puerto Rico. These groups control the rights to profit from Microsoft products around the world. By conducting sales from places with small populations… – Continue reading
The Isle of Man has signed a tax information exchange agreement with Spain, reports the Isle of Man Today. It’s part of what the Manx government calls its ‘continuing commitment to meet international standards in tax co-operation and transparency’. The agreement was signed by Mr José Manuel Gutiérrez Delgado, Financial… – Continue reading
After the LuxLeaks affair in November 2014, the European Parliament established a special committee “on tax rulings and other measures similar in nature or effect” (TAXE) in February 2015. The committee’s report was adopted in a plenary session of the European Parliament on 25 November 2015. The Conference of Presidents… – Continue reading
New legislation brings the possibility of jail sentences for those who aren’t upfront with HMRC about assets held overseas A new criminal offence is due to hit the statute book next year under which people who engage in tax evasion abroad could get a criminal record, fines and a jail… – Continue reading
There are a variety of benefits to moving offshore, yet few would argue the assertion that tax neutrality is paramount among them. As anyone familiar with the phrase “tax haven” would surely recognize, many countries offer strongly favorable tax terms as an incentive to draw new business. Written by CT… – Continue reading
The Department of Justice announced today that Cornèr Banca SA (Cornèr) and Bank Coop AG (Bank Coop) reached resolutions under the department’s Swiss Bank Program. The Swiss Bank Program, which was announced on Aug. 29, 2013, provides a path for Swiss banks to resolve potential criminal liabilities in the United… – Continue reading
As the EU prepares for country-by-country tax reporting requirements, businesses would do well to understand the minutiae of the upcoming regulations October 2015 was a busy month for announcements regarding base erosion profit shifting (BEPS) and country-by-country reporting. The OECD issued the last of the guidelines on BEPS, the various… – Continue reading
Chisinau, 10 December /MOLDPRES/-The parliament today ratified a Moldovan-American intergovernmental cooperation agreement to facilitate the implementation of the provisions of the Foreign Account Tax Compliance Act (FATCA). According to the chairman of the parliamentary commission for international relations and EU integration, Valentina Buliga, the ratified document sees that U.S. authorities… – Continue reading
Two tax compliance agreements with Liechtenstein and Switzerland have received the seal of approval from the EU council of ministers today, reports Economia. And a third – with San Marino – was approved and signed today. They herald the start of a new era of tax transparency with three countries… – Continue reading
Changes to the tax law in Sweden reflect additions of anti-avoidance provisions to the EU Parent/Subsidiary Directive and are intended to bring Swedish tax law into compliance with the directive. The new anti-avoidance provisions will be effective 1 January 2016—which is also the timeframe for EU implementation of the directive’s… – Continue reading
It is time for re-regulation; Europe is strengthening its AML/CFT measures in order to lower current terrorist financing (TF) risks. “Money is the lifeblood of terrorist operations,” declared George Bush after the 9/11 attacks. French finance minister Michel Sapin has beaten the same drum when he recently claimed that “the… – Continue reading
The present French Tax Update contains (i) an overview of the main provisions proposed by the draft amending finance bill for 2015 (loi de finances rectificative pour 2015, 2015 Draft Amending Finance Bill), (ii) an update of the parliamentary amendments adopted in respect of the draft finance bill for 2016… – Continue reading
The European Union’s Economic and Financial Affairs Council agreed a work plan in response to the OECD’s base erosion and profit shifting recommendations at its meeting on December 8. Following the meeting, ECOFIN – comprised of finance and economy ministers from all member states – released a list of agreed… – Continue reading
The Cabinet has submitted a bill to the Parliament Speaker’s Office for presentation and approval by the legislature of an agreement with the US that concerns the sharing of information between the countries to prevent tax fraud. A letter accompanying the legislation sent to the speaker’s office on Nov. 19… – Continue reading
On 8 December 2015, the Council adopted a directive aimed at improving transparency on tax rulings given by member states to companies in specific cases about how taxation will be dealt with. The directive is one of a number of initiatives aimed at preventing corporate tax avoidance. It will require… – Continue reading
Following persistent demands from the United Kingdom that its Offshore Territories include beneficial ownership information on public central registers, it was agreed at the Overseas Territories Joint Ministerial Council (JMC) that “similarly effective systems” are a permissible alternative. A joint statement after the JMC meeting said: “We agreed to hold… – Continue reading
WASHINGTON Illicit financial flows or black money from developing and emerging economies surged to US$1.1 trillion or a staggering 4 percent of the developing world’s GDP in 2013, according to a study released Wednesday by Global Financial Integrity (GFI), a Washington, DC-based research and advisory organization. The cumulative illicit outflows… – Continue reading
The EU Council has adopted a new transparency directive aimed at preventing corporate tax avoidance The directive, which was proposed by the European Commission (EC), is aimed at improving transparency on tax rulings given by member states to companies about how their taxes are calculated. Under the new directive, member… – Continue reading
The new agreement marks the end of bank secrecy between San Marino and the EU. As of 2017, San Marino and EU Member States will automatically exchange information on the financial accounts of one another’s residents. Pierre Moscovici, Commissioner for Economic and Financial Affairs, Taxation and Customs, said: “This agreement… – Continue reading
Finance Minister Edward Scicluna pushes for ‘flexibility’ during today’s meeting of EU finance ministers in Brussels Malta has come out strongly against applying “rigid rules”, urging the European Commission to adopt a more flexible approach as it drafts legislation on taxation. Corporate tax was high on the agenda of EU… – Continue reading
