The UK does still have one significant disadvantage namely the 20% withholding tax imposed by UK domestic law on “yearly interest” that arises in the UK is paid to persons whose “usual place of abode” is outside the UK. The UK is normally regarded as an attractive location for the… – Continue reading
The OECD has welcomed efforts by the Dutch Government to tackle base erosion and profit shifting but called for the overall tax regime to be simplified, including in area of value-added tax. In its latest Economic Report on the Netherlands, the OECD said that the Government is attempting to change… – Continue reading
HMRC has formed an alliance with tax enforcement bodies in 4 countries to share intelligence and expertise in the battle against international tax crime. The UK has joined forces with Canada, the Netherlands, the United States and Australia to launch the Joint Chiefs of Global Tax Enforcement (J5) – a… – Continue reading
Royalty taxation shall be set at 5% and 10%. The tax rate is being raised from 2% to 5%, while the zero taxation of dividends and royalty payments are being abolished. Such are the main changes in the Convention between Ukraine and the Kingdom of the Netherlands on double taxation… – Continue reading
The Government of the Netherlands has announced a comprehensive package of tax anti-avoidance proposals designed to bring the jurisdiction’s rules into line with new European Union anti-avoidance laws and fulfill its obligations under the international BEPS agenda. The plans were detailed in a parliamentary paper sent by State Secretary for… – Continue reading
The Netherlands will seek to resume discussions towards double taxation avoidance treaties with several countries in 2018, including the United States, the Government has said. The Dutch Government will attempt to begin tax treaty talks with at least seven countries this year, including Australia, Colombia, Costa Rica, Ecuador, Morocco, Austria,… – Continue reading
Viet Nam News HCM City – The Netherlands-based ride-hailing firm Uber International Services Holding B.V has filed a lawsuit against the HCM City tax department after it decided to forcibly collect tax, Người Lao Động (Labourer) newspaper reported. Earlier the department had sent a notice to Uber that it had… – Continue reading
Part of the supplementary pension of Belgian workers, previously working in the Netherlands, will be taxed by the Dutch Tax Administration (the “DTA”). The DTA confirmed this on Thursday. The Belgian and Dutch government treasuries are engaged in a tug of war around the second pillar of the pension. This… – Continue reading
The European Commission is launching an investigation into Ikea’s tax construction in the Netherlands. European Commissioner on competition Margrethe Vestager is expected to officially announce the investigation on Tuesday, British newspaper the Financial Times reports. The Swedish furniture company is suspected of evading nearly a billion euros in taxes between… – Continue reading
Vietnam has lost thousands of billions of dong in taxes as foreign enterprises, especially large-scale ones, refuse to pay based on the Double Taxation Avoidance Agreement. Massive revenue without having to pay taxes The Ho Chi Minh City Department of Taxation has recently issued an ultimatum for Uber B.V Netherlands… – Continue reading
Luxury yachts built in Dutch shipyards are being sold to suspect buyers around the world through tax havens, Trouw and the Financieele Dagblad reported on Friday. The dubious yacht transactions were revealed through an investigation being carried out into the Paradise Papers by the two Dutch newspapers . The documents… – Continue reading
In this Tax Alert we will briefly highlight two topical Dutch tax matters very relevant to internationally active companies: the current status of the legislative proposal regarding Dutch dividend withholding tax rules for holding cooperatives and BVs/NVs and the announcement of the Dutch Ministry of Finance that the Dutch fiscal… – Continue reading
The abolition of a scheme allowing Dutch taxpayers to fess up to their tax sins and avoid criminal charges is likely to discourage high-net worth individuals from ever disclosing money hidden abroad to local authorities, practitioners say. Deputy Minister of Finance Eric Wiebes announced that it was time to draw… – Continue reading
The European Commission is preparing a new directive on the cross-border transfer of company headquarters, a move that could have far-reaching implications for other areas of corporate governance, including tax planning and cross-border mergers, EURACTIV has learned. With Brexit on the horizon, UK companies are busy weighing their options for… – Continue reading
On 19 September 2017, the Dutch government released the State’s Budget for the year 2018. The Budget includes a draft bill to expand the dividend withholding tax exemption to tax treaty countries, to introduce a withholding tax obligation for holding cooperatives and to limit the taxation of non-resident investors. If… – Continue reading
The caretaker government may make the Netherlands a less attractive location for international business because of changes to the corporate tax system, the employers’ organisation VNO-NCW and tax advisers have warned, the Financieele Dagblad said on Monday. The employers and Dutch Order of Tax Advisors say the government is choosing… – Continue reading
Computer scientists have worked to uncover the way the Netherlands, the UK, Ireland, Singapore and Switzerland, in particular, are used by multinationals to channel investments onto well-known offshore centres (OFCs). According to the research which was first reported by online journal Quartz, the five countries are used by multinationals to… – Continue reading
The Government of the Netherlands has announced that it has concluded an agreement with Indonesia on the taxation of investment funds. The Dutch Ministry of Finance announced on July 11 that the new competent authority agreement was signed by the two sides on June 23, 2017. The agreement clarifies the… – Continue reading
France wants Brussels to take a tougher stance on American multinationals working inside the European Union (EU) and force them to pay an appropriate amount of tax. “I can tell you that the times we live in are not for the weak,” French Finance Minister, Bruno Le Maire said in… – Continue reading
Dutch tax authorities will publicly disclose the type and number of rulings awarded to corporations every year, the country’s deputy finance minister pledged. Eric Wiebes said during a June 1 plenary debate in the House of Representatives that he would require the country’s tax administration to issue an annual report… – Continue reading
The Government of the Netherlands has said that it will take a step forward in its fight against tax evasion and money laundering by introducing a registry of ultimate beneficial owners of companies registered in the Netherlands. Draft legislation for the introduction of a registry of beneficial ownership was published… – Continue reading
For the second time in 14 months, Brazil’s state oil company Petrobras has lost a dispute over Brazil’s recognition of tax treaties. On March 24, a federal revenue service appeals court ruled against Petrobras in a $510 million case (16682.721067/2014-01) involving the company’s profits in the Netherlands for 2010. Although… – Continue reading
The Netherlands is slowly but surely steering away from facilitating the use of its corporate income tax system by companies that are set up merely to obtain tax benefits. These companies, which often do not actually carry out activities in the Netherlands, have contributed to the perception among policy makers… – Continue reading
Uber is simply providing a taxi service and all its drivers must therefore register to pay goods and services tax, Australia’s Federal Court ruled. The Feb. 17 decision, which could yet be appealed to the full bench of the Federal Court, is “one step in the journey of the tax… – Continue reading
The Netherlands has signed a protocol to its double tax avoidance treaty with Uzbekistan, designed to prevent the treaty from being inappropriately used to avoid taxes. The anti-abuse provision was signed by the Netherlands and Uzbekistan on February 7, 2017, and “prevents the benefits of the treaty only [being] used… – Continue reading
Following Moody’s Investors Service affirmation of Indonesia’s sovereign credit rating at Baa3 with a stable outlook in January 2016, there has been renewed interest in the international bond market for Indonesian credits. This bulletin seeks to summarise the regulatory changes in Indonesia over the last 24 months as well as… – Continue reading
Germany’s BDI industry group has come out against a government plan to unilaterally close so-called ‘patent box’ tax loopholes used by foreign companies to avoid paying full taxes on profits earned in Germany. The Association of German Industrialists, BDI, said Tuesday that the government’s unilateral move would send a negative… – Continue reading
There is a possibility that the General Anti-Avoidance Rules (GAAR, on taxes) and the tax treaties signed by the government with those of Mauritius, Singapore and Cyprus, and even other nations such as Netherlands, could be overtaken by another event. These could, say experts, be partially or fully overridden by… – Continue reading
WASHINGTON — An American tax authority who helped champion a reform now being considered by the U.S. Congress says Canada would not be among the countries hardest hit by the introduction of so-called border adjustments. Alan Auerbach is among the leading proponents of the push to restructure corporate taxes so… – Continue reading
Trade agreement would have to include strict rules to prevent Britain becoming offshore haven, Dutch deputy PM says The Netherlands will block any EU trade deal with the UK unless it signs up to tough tax avoidance regulations preventing it from becoming an attractive offshore haven for multinationals and the… – Continue reading
India is unlikely to amend its tax treaty with the Netherlands as it did with Mauritius, Singapore and Cyprus and this could shape the investment strategy of foreign portfolio investors (FPI) and private equity (PE) funds investing in India, said three people in the know. “There were talks to amend… – Continue reading
Move could be a worrying indicator of investment trends post-Brexit, post-Beps Snap, the company behind Snapchat, has opted to open its new new international headquarters in London, rather than Dublin, Amsterdam or Luxembourg, bucking a trend which for decades has seen US multinationals book their international sales in one of… – Continue reading
The Central Board of Direct Taxes in India issued Circular Number 41 on December 21, 2016 providing clarifications on applicability of ‘indirect transfer’ provisions under the Indian Income Tax Act, 1961 to investors of Foreign Portfolio Investors (FPIs) – earlier known as Foreign Institutional Investors (FIIs) in India. The circular… – Continue reading
Alphabet Inc.’s Google managed to save $3.6 billion in 2015 by shifting its profits to a Bermuda shell company, according to filings in the Netherlands. Google used Ireland and the Netherlands as intermediaries. According to files obtained by Bloomberg, Google used the so-called “Double Irish” and a “Dutch Sandwich” tax… – Continue reading
Two reports on company taxation show that more than a third of the largest companies operating in Australia paid no tax in 2014–15 and that multinational tax evasion cost an estimated $4.8 billion that year. These reports show the fraud of the claims being made by the Australian government and… – Continue reading
Ireland’s Ministry of Finance, the EU and several other governments have emphatically rejected claims by Oxfam International that the countries are tax havens, with Ireland insisting its corporate tax laws are “fully compliant” with international best practices when it comes to transparency and information exchange. The Irish government said the… – Continue reading
Lower corporate tax rates around the world are expected to play an important part in multinational companies’ tax planning in 2017, with a rate as low as 15 percent on the table in the U.S. and countries such as the U.K. planning to maintain or lower their current rates. A… – Continue reading
The NGO’s report exposes the worst offenders in the ‘race to the bottom on corporate tax.’ Luxembourg, Ireland, Cyprus, and the Netherlands are among the world’s 10 worst tax havens, despite an ongoing EU crackdown on tax avoidance and profit shifting across the bloc. The findings come in a report… – Continue reading
The Netherlands is still making secret tax deals with multinational companies, according to an European report on which Dutch research foundation SOMO worked. The Netherlands remains one of the ost important countries in Europe when it comes to tax evasion, the report states according to ANP. Last year the Netherlands… – Continue reading
Following pressure from the Finnish government and public opinion in the Scandinavian country, Helsinki has announced a deal which will allow it to come after expat pensioners, who are residing in Portugal, for income tax payments from which they were previously exempt. Other EU states have also expressed their aversion… – Continue reading
Following British Prime Minister Theresa May’s visit to India last week, Patricia Hewitt, chair of the UK-India Business Council, said that Britain is looking to re-balance its commercial links with countries like India post-Brexit. She suggested that the two governments should look at a bilateral tax treaty to boost trade…. – Continue reading
Multinational companies will still be able to use the controversial “double Irish” tax arrangement after the final end date of 2020, Sinn Féin MEP Matt Carthy has said. A number of tax experts have confirmed this is the case, though they have disputed whether the terms of which they will… – Continue reading
European Union finance ministers agreed on Tuesday how to screen countries for a blacklist of tax havens across the world, officials said, and said applying zero-rate taxes was not necessarily a factor, prompting an outcry. The bloc committed in May to agree on a common list of tax offenders by… – Continue reading
Network of foreign subsidiaries reported key to €923 million windfall over five years German chemicals manufacturer BASF has been accused of avoiding close to €1 billion of tax. In a report published on Monday, the company is alleged to have used aggressive tax-planning strategies in the Netherlands, Belgium, Switzerland and… – Continue reading
Global governments battling tax avoidance increasingly are pushing multinational corporations for a bigger picture of how and where they pay taxes, leading to increasingly narrow questions from company tax officers. “We have a number of entities that are disregarded for U.S. tax purposes. When I fill out the country-by-country form,… – Continue reading
The OECD has started to review how effectively the U.S. and five other countries handle cases in which multinational companies assert double taxation under the mutual agreement procedure of bilateral tax treaties. As part of the review, the Organization for Economic Cooperation and Development is inviting multinationals to answer a… – Continue reading
A new EU corporate tax proposal could fundamentally change how multinationals pay their tax bills in Ireland. It comes at a sensitive time for the State, following so closely after the commission ruled phone giant Apple tapped illegal tax breaks worth around €13bn. In proposals to be unveiled tomorrow, the… – Continue reading
A United Nations human rights expert has urged the next UN secretary-general to make the elimination of tax havens a priority to ensure that corporations, billionaires and ‘kleptocrats’ pay their fair share of taxes. Speaking on Friday, American law professor Alfred de Zayas also urged Antonio Guterres, who will succeed… – Continue reading
On 30 September 2016 Ukraine signed a protocol (the “Protocol”) modifying the not-yet-in-force Convention between the Government of Ukraine and the Government of the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital (the “Convention”)…. – Continue reading
For years, strict Swiss bank secrecy laws helped the world’s super-rich keep their money hidden from the taxman. Spain has asked Switzerland for help on tax matters, UBS said on Friday, making it the latest European country to look into foreign account holders at Swiss banks. For years, strict Swiss… – Continue reading
