Category: Germany

Metro Vietnam found owing over $23.6mn in tax in transfer pricing inspection

The Vietnamese unit of Germany’s Metro Cash & Carry will have to pay almost US$24 million in tax arrears after its wrongdoings have been unearthed in a transfer pricing inspection that concluded Monday. Metro Cash & Carry Vietnam Co. Ltd. began coming under scrutiny on suspicions of transfer pricing in… – Continue reading

Global Law Experts distinguishes GRP Rainer Lawyers and Tax Advisors as a leading law firm in the field of tax law

The internationally recognized handbook for legal experts Global Law Experts has distinguished GRP Rainer Lawyers and Tax Advisors as one of the leading law firms in the field of tax law. GRP Rainer Lawyers and Tax Advisors in Cologne, Berlin, Bonn, Düsseldorf, Frankfurt, Hamburg, Munich, Stuttgart and London has been… – Continue reading

OECD MAP Statistics Show Pressing Need for Mandatory Binding Arbitration

The OECD Mutual Agreement Procedure Statistics for 20131 (MAP Statistics), released on November 25, 2014, show a dramatic surge in the inventory of mutual agreement procedure (MAP) cases among OECD member countries. The MAP Statistics confirm that the potential for double taxation is increasing. This is reflected most starkly in… – Continue reading

UK Firms, Economy Burdened By High Tax Rates

The UK is inhibiting its economy with a tax burden 18 percent heavier than the global average and should consider setting a specific target for lowering the overall tax take, according to research by accountants UHY Hacker Young. UHY’s findings show that tax revenue in the UK represents a third… – Continue reading

'Banks moved their evasion experts to LatAm'

UBS whistleblower Stéphanie Gibaud talks to the Herald before travelling to Argentina With tax evasion allegations against HSBC under the spotlight in Congress, a whistleblower from another banking giant famous for its secrecy, Switzerland’s UBS, says she is coming to the country to testify soon, and warns that emerging economies… – Continue reading

European Union: European M+A News, Spring 2015

EUROPEAN M&A DOS AND DON’TS FOR NON-EUROPEAN BUYERS Inbound M&A in Europe by non-European buyers increased in 2014 by 68.6% compared to 2013, representing over a third of USD 901.4 billion total European M&A.1 For non-European buyers the basic framework of transactions may be similar, but there are a number… – Continue reading

‘Constructive’ talks on US banks tax evasion row

Tensions between Swiss banks and the United States justice authorities should ease up in 2015, Finance Minister Eveline Widmer-Schlumpf has said on the sidelines of the joint International Monetary Fund and World Bank spring meetings in Washington. The minister said she had received positive signals that this year would bring… – Continue reading

First Germany, now UK objects to India ‘breach’ of secret bank data

The United Kingdom (UK) has followed Germany in lodging a formal protest with the Finance Ministry over the alleged breach of confidentiality of data and secret banking details received via diplomatic channels. While German authorities objected to the manner in which 18 names of Indian account holders in the LGT… – Continue reading

Tax waiver issue delays contract signing

KATHMANDU, APR 16 – With the selected consultant for the Tanahu Hydropower Project demanding income tax exemption during ongoing negotiations before signing a contract, the Nepal Electricity Authority (NEA) has said that the government cannot provide the facility as the current tax law does not allow it. The NEA clarified… – Continue reading

Treasurers should provide transaction documentation according to BEPS

Corporate treasury departments will have to start complying with International tax rules and provide documentation for transactions according to recent reports. G20 leaders attempted to reform the international tax system in July 2012 by setting up the Base Erosion and Profit Shifting (BEPS) project. This task was given to the… – Continue reading

Germany-France cross border real estate transactions may need to be restructured, say experts

Cross border transactions involving German entities investing in French real estate may need to be restructured as a result of proposed changes to the France/Germany double tax treaty, according to two experts. French tax expert Franck Lagorce and German tax expert Werner Geisselmeier, both of Pinsent Masons, the law firm… – Continue reading

OECD: employment tax burdens rise despite static income tax rates

Taxes have risen by around one per cent on the average worker’s wage in Organisation for Economic Co-operation and Development (OECD) countries since 2014, although the majority of governments have not increased income tax rates, the OECD has said. In its Taxing Wages 2015 report, the OECD looks at the… – Continue reading

Gang’s £10m worldwide scam selling fake viagra through mail order fishing tackle firm

TWELVE members of a counterfeit drug ring – including six from the Grimsby area – raked in more than £10 million selling fake Viagra under the cover of a mail-order fishing tackle business. The UK-wide conspiracy offered cheap erectile dysfunction pills to online and face-to-face customers around the world. The… – Continue reading

European Union: European Competition Law Newsletter – April 2015

EU’s Highest Court Rules on Information Exchange On 19 March 2015, the European Court of Justice (ECJ) handed down a significant judgment on the application of EU competition law to information exchange between competitors. The case was an appeal from the European Commission’s 2008 decision to fine banana importers Dole,… – Continue reading

Individual Tax Burdens Continued To Rise In 2014

Taxes on wages have risen by about one percent for the average worker in OECD countries between 2010 and 2014, even though the majority of governments did not increase statutory income tax rates, according to the Organisation for Economic Cooperation and Development’s (OECD’s) Taxing Wages 2015 report. According to the… – Continue reading

Worldwide: Protecting Yourself From International Tax Investigations

Who Will Be Next? How To Respond To A Tax Investigation The international political community continues to make the most threatening noises about those who they believe do not pay enough tax. Long gone it seems are the days where it was accepted that a person could properly organise his… – Continue reading

Europe slow to adopt new accounting standard despite Greek crisis

In the five years since the eurozone crisis exploded, the European Union has adopted a great number of measures to improve its fiscal governance. Yet amazingly, it still does not have a robust, harmonized way of measuring and monitoring the financial activities of its member states, reports the Wall Street… – Continue reading

France, German sign double tax treaty changes

BERLIN: The Governments of France and Germany signed an amendment to the France-German treaty dated (the “Treaty”), which will have an impact in the future for certain investments in real estate. For France, this amendment follows the amendment to France-Luxembourg signed on 5 September 2014 which also impacts foreign investments… – Continue reading

Investment in real estate: France-German double tax treaty changes

On 31 March 2015, the Governments of France and Germany signed an amendment to the France-German treaty dated (the “Treaty”), which will have an impact in the future for certain investments in real estate. For France, this amendment follows the amendment to France-Luxembourg signed on 5 September 2014 which also… – Continue reading

More Australian businesses using renminbi

The number of Australian companies using renminbi to settle cross-border business has increased substantially over the past year, according to a new business survey. HSBC surveyed companies transacting with China and found that the proportion of Australian companies using RMB for cross-border business has risen from nine per cent in… – Continue reading

More Australian businesses using renminbi

The number of Australian companies using renminbi to settle cross-border business has increased substantially over the past year, according to a new business survey. HSBC surveyed companies transacting with China and found that the proportion of Australian companies using RMB for cross-border business has risen from nine per cent in… – Continue reading

European Banking Weekly Notes: HSBC, RBS and Barclays

European bank shares showed notable improvements in prices last week, benefiting from hopes of Greece evading a crisis coupled with continued strength in the U.S. dollar. Reports that Germany is looking to adopt a new law that will boost the capital position of the country’s banks helped Deutsche Bank (NYSE:DB)… – Continue reading

$32 Trillion Stashed in Offshore Bank Accounts – Asset Protection Planners Examine the Facts

More and more Americans are opening offshore bank accounts. This article provides statistical details about why this is so, that offshore banking can be safe and legal and which banking jurisdictions are safest. Apr. 3, 2015 / PRZen / VALENCIA, Calif. — Offshore banking is growing in leaps and bounds… – Continue reading

European Competition Law Newsletter – April 2015

EU’s Highest Court Rules on Information Exchange On 19 March 2015, the European Court of Justice (ECJ) handed down a significant judgment on the application of EU competition law to information exchange between competitors. The case was an appeal from the European Commission’s 2008 decision to fine banana importers Dole,… – Continue reading

Charting the Limits of Acceptable Tax Planning in Singapore

In 2015, Singapore celebrates its 50th year of independence and also mourns the passing of its first Prime Minister Lee Kuan Yew who steered Singapore’s success for many critical years. From its origins as a British trading post in 1819, Singapore has grown into one of the busiest ports and… – Continue reading

Global Tax Transparency Goes Live in 2016

Cross border tax fraud and tax evasion by High Net Wealth Individuals (HNWI) are serious problems for many jurisdictions. For many years exchange of information between countries has been solely upon request. In practise this procedure is not efficiently working as it requires foreseeable relevance, thus ‘fishing’ for information is… – Continue reading

Greece Proposes Plans to Tackle Tax Evasion and Corruption

Greece submitted a list of economic reforms to the European Union (EU) in an effort to secure emergency financing. Greece submitted a list of economic reforms to the European Union (EU) in an effort to secure emergency financing. The reforms include proposals to raise revenue by curbing tax evasion and… – Continue reading

Around the World, America’s Taxman Cometh by way of the Foreign Account Tax Compliance Act (FATCA)

As Tax Day approaches, homeland Americans scurry to file their annual tax filing obligations. But for an estimated 7.6 million Americans working and living overseas, they have an obligation to not only pay taxes in their respective countries where they live; they need to pay the piper in homeland America… – Continue reading

Dividend imputation clears an early tax review hurdle

Government questions dividend imputation and company tax rate Australian investors appear to have dodged a bullet, with the government’s first paper on tax reform discussing the dividend imputation system but falling short of attacking it outright as an idea that has outlived its usefulness. David Murray’s inquiry into the Australian… – Continue reading

Luxembourg: Luxembourg’s Direct Tax Administration Publishes Circular On Residency Certificates For Funds

Luxembourg’s Direct Tax Administration has published a circular on February 12 clarifying issues relating to residency certificates for Luxembourg funds. These are applicable to both UCITS and non-UCITS funds regulated by Luxembourg’s investment fund legislation of December 17, 2010, which transposed the UCITS IV Directive, as well as Specialised Investment… – Continue reading

Offshore property diversification spree continues

More JSE-listed counters announce offshore opportunities. It is becoming increasingly difficult for JSE-listed property companies to find value and attractive deals in the local market, which has seen the offshore diversification spree continue. Industry players believe that the sector has turned over the last few years, with more property counters… – Continue reading

Petition Demands End to Tax Evasion in Europe

The initiative means to lobby for a harmonization of Corporation Law in Europe to tackle tax evasion and re-fund public spending. About 40,000 Spanish citizens have signed a petition demanding measures against front companies and tax heavens in Europe, explained the activists in charge of the initiative Saturday. Beyond Spain,… – Continue reading

RBS Sells Coutts International to UBP in Swiss Retreat

(Bloomberg) — Royal Bank of Scotland Group Plc agreed to sell its Coutts International private banking business to Switzerland’s Union Bancaire Privee, as the bailed-out British lender retreats from the Swiss wealth market. RBS is expected to sell Coutts for 350 million francs ($360 million) to 400 million francs, depending… – Continue reading

Italian Supreme Court rules TP irregularities must be substantiated with clear avoidance behaviour

In Ruling No. 27296, Italy’s Supreme Court rejected the tax authorities’ appeal against an Italian company’s transfer of goods and services to its German parent. The Supreme Court ruled that if there is no clear economic advantage for a company, simply proving a transaction is not at arm’s-length is insufficient… – Continue reading

Ireland: Irish Tax System – First Mover Or Last Defender Strategy

As the OECD/EU project on Base Erosion and Profit Shifting (“BEPS”) moves towards its next set of reports in autumn 2015, Ireland Inc.’s low tax offering has been, and will be, further refined. While the 12.5% corporate tax rate remains beyond approach both domestically and internationally, the BEPS initiative has… – Continue reading

Political and economic factors continue to rock the transaction boat

Transactional work varies from jurisdiction-to-jurisdiction with the ebb and flow of various economic cycles, but a prevailing theme across the EMEA region has been that more and more advisory firms are urging taxpayers to prepare for the impact of the OECD’s base erosion and profit shifting (BEPS) action plan. Joe… – Continue reading

French tax update – noteworthy tax courts decisions and Draft Macron Law

The present French Tax Update will focus on (i) certain noteworthy tax courts decisions issued in the last months of 2014 and in the first months of 2015, and (ii) the so-called projet de loi Macron (Draft Macron Law) adopted by the Assemblée Nationale in February 2015 and now discussed… – Continue reading

Dutch, German firms urge fair patent box changes

Two business federations from the Netherlands and Germany have urged the Organisation for Economic Co-operation and Development to ensure that there is a level playing field under new international rules proposed for preferential regimes for intellectual property (IP) income, reports Tax News. The two organizations’ statement concerns the development of… – Continue reading

Hungary and Luxembourg sign agreement to avoid double taxation

Representatives of the governments of Hungary and Luxembourg signed an agreement to eliminate double taxation on the sidelines of a meeting of EU finance ministers, the economy ministry said. The new agreement, signed by Economy Minister Mihály Varga and counterpart Pierre Gramegna, replaces an earlier one signed in 1990. It… – Continue reading

Switzerland to sign tax deal with Germany to exchange tax information

Switzerland expects in the future to sign a deal with Germany to automatically exchange tax information, Swiss Finance Minister Eveline Widmer-Schlumpf said, after the signing of a tax agreement with Italy, reports Customs Today. In the medium term we will sign a deal on automatic tax information sharing with Germany,”… – Continue reading

HSBC ‘not representative’ of Swiss banking

Helping tax cheats or money launderers has never been an integral strategy of the Swiss financial centre, Swiss Bankers Association (SBA) chief executive Claude-Alain Margelisch tells swissinfo.ch as the HSBC ‘Swiss Leaks’ scandal continues. The unsavoury activities of HSBC, UBS AG (NYSE:UBS) and others, brought into the public domain by… – Continue reading

Commerzbank raided over possible tax evasion

Tax investigators and police have raided commercial offices in Germany as they looked into allegations of large-scale tax evasion with regard to profits made in Luxembourg. Commerzbank was at the center of the searches. Media reports said police had raided scores of office premises across Germany on Tuesday as investigators… – Continue reading

Coutts’ Swiss operation faces German investigation over tax evasion claims

Bank’s subsidiary in Switzerland is already being investigated by US authorities about whether it helped Americans evade tax The venerable Coutts bank, home of the Queen’s personal accounts, has been drawn into the mounting controversy about private banking with an admission that its Swiss arm is under investigation for aiding… – Continue reading

RBS staff under investigation from German authorities over Swiss tax evasion

Disclosure in bank’s annual results about Coutts comes as it reports seventh consecutive loss Royal Bank of Scotland was dragged into the Swiss tax evasion scandal on Thursday when it emerged that the taxpayer-owned company’s private bank is under investigation for helping wealthy clients evade tax. The small print of… – Continue reading

Is international tax planning for contractors illegal or immoral?

The differentiation between tax avoidance, tax evasion and the moral duty to pay tax for the betterment of society has been intentionally screwed by politicians and bureaucrats. This is nothing new. I wrote an couple of articles several years ago questioning the terminology of ‘morally repugnant’ tax avoidance when it… – Continue reading