The Dutch Ministry of Finance published a draft decree for implementing the “common reporting standard” (CRS) and that includes the identification and reporting requirements contained in the CRS for reporting financial institutions. The CRS, developed by the OECD and largely based on FATCA, is a standard that governs the exchange… – Continue reading
HONG KONG, Dec. 2, 2015 /PRNewswire — Demand for asset protection, wealth planning and funds by high net worth individuals in Asian countries will drive continued growth in the offshore industry, according to OIL’s sixth “Offshore 2020” annual market research study. OIL, the leader in international incorporations and corporate services… – Continue reading
The European Commission’s use of state aid rules to challenge corporate tax agreements is causing uncertainly for businesses in Europe, Luxembourg finance minister Pierre Gramegna has said. Gramegna told the Financial Times this week that the situation “raises so many issues about predictability and certainty”. The Commission announced in October… – Continue reading
The new Income Tax Treaty between the Netherlands and Germany has entered into force today, 1 December 2015. The new Treaty generally applies from 1 January 2016 and replaces the old treaty of 1959. In accordance with the new treaty, the following withholding taxes will apply: Dividends: 5% if the… – Continue reading
The 28 nations of the European Union lose up to $1 trillion per year in revenue thanks to multinational corporations that use a spider’s web of completely legal constructs to lower their taxes. Now, Europe’s law enforcers and lawmakers want to wipe away these intricate tax-avoidance systems. If they have… – Continue reading
The current international tax regime was developed in the last century when the internet was not yet invented. At that time, a foreign company would typically require a substantial physical presence in Australia before it could be in a position to earn significant amount of income from Australian customers. This… – Continue reading
The number of M&A transactions involving Private Equity [PE] investment in Bermuda in the first three quarters of this year has already eclipsed that seen in all of 2014, according to a report released today [Nov 30] by Appleby. “Bermuda was also the offshore jurisdiction to see the largest total… – Continue reading
Tech titans powering the economy shelter money through insane tax-avoidance havens. It’s wrong — and adding up Offshore tax havens enable not only individuals to dodge taxes—they also enable multinational corporations to do so. Often this tax avoidance is done within the letter of the law: multinational groups exploit the… – Continue reading
The European Parliament has overwhelmingly approved a suite of corporate tax reforms that will ensure multinational companies pay taxes where profits are made and increase transparency. A total of 508 MEPs voted in favour of the adoption of recommendations put forward by the Special Committee on Tax Rulings last month…. – Continue reading
The Dutch government said Friday it will appeal an EU ruling that the Netherlands gave Starbucks an illegal tax break and ordered the coffee giant to pay some 30 million euros ($34 million). “The government is of the opinion that the Commission does not convincingly demonstrate that the tax authority… – Continue reading
A recent Dutch group request for administrative assistance shows that even before the “automatic exchange of information” (AEoI) measure is effective in Switzerland in 2017, those with undeclared assets need to consider making a disclosure. The Swiss federal tax administration recently approved a Dutch group request for administrative assistance, and… – Continue reading
Irish Finance Minister Michael Noonan has said that he no longer expects that the European Commission will release its decision on the legality of a tax ruling provided to Apple before Christmas. Noonan confirmed that the Commission had requested additional information on the ruling. He said it will take the… – Continue reading
Greater China, Southeast Asia Seen as Global Leaders in Use of Offshore Vehicles, Drawn by Efficiency & Legal Frameworks Key Highlights: OIL’s sixth annual survey shows: The offshore industry will be a leaner, more resilient and confident member of the global economy by 2020, driven by demand from increasing numbers… – Continue reading
Multinationals should pay their taxes where they make their profits, according to one of the recommendations by the tax rulings committee, which were adopted by MEPs on 25 November. Report authors Elisa Ferreira (S&D, Portugal) and Michael Theurer (ALDE, Germany) told us it had been difficult for the committee to… – Continue reading
ITR Correspondent Italy has updated its rules governing transactions with parties located in tax havens. Following a legislative process which began in 2013, the Italian Government on September 14 2015 enacted a decree addressing a wide array of international tax matters, including one of the most controversial Italian tax rules… – Continue reading
Earlier we already reported that Malta and Curaçao had signed a DTA. When we wrote our earlier article we had not yet been able to locate the text of the DTA. Now however, the English version of the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal… – Continue reading
The European Commission has requested that the Netherlands amend the limitation on benefits clause in its double tax treaty with Japan. The Commission said that, on the basis of previous cases such as Gottardo (C-55/00) and Open Skies (C-466/98), a member state concluding a treaty with a third country cannot… – Continue reading
Tax Commissioner Chris Jordan has become more picky about entering agreements with multinationals aimed at giving companies certainty about their tax payment requirements in Australia in future years. Taxpayers can lock in their tax payment for a period of about three years via an “advanced pricing agreement”, or APA. Technology… – Continue reading
Now that’s what I call a Big Tax Case A long running court case that has become known as the ‘Big Tax Case’ appears to be reaching a conclusion. It involves Scottish football club Rangers, who went bust in 2012. After it failed, a new company was created. It bought… – Continue reading
On November 19, 2015 the European Commission published the key decisions of its November infringement package. One of the key decision mentioned is the Commission’s decision to request the Netherlands to amend the Limitation on Benefits (LOB) clause in the Dutch-Japanese Tax Treaty for the Avoidance of Double Taxation, which… – Continue reading
Online accommodation platform, Airbnb, appeared before the Senate Inqury into the tax avoidance of multinational companies on Wednesday, with the ANZ manager arguing the startup brings a significant amount of money into the economy. Airbnb has found itself in the spotlight on Wednesday, when a Senate inquiry into the tax… – Continue reading
Finnish companies continue to take advantage of legal tax planning to shelter their profits from taxation. According to Yle’s Ajankohtainen kakkonen current affairs programme, state-owned firms are among those that have been dragging their feet on reporting income from their foreign subsidiaries. The European Union is making an effort to… – Continue reading
Uber ANZ director of public policy appeared before the Senate inquiry into the tax avoidance of multinational companies on Wednesday, focusing on tax requirements of an individual driver, rather than the company. A Senate inquiry into the tax avoidance of multinational companies continued in Sydney on Wednesday, when Uber appeared… – Continue reading
The Isle of Man’s role as an offshore finance centre will come under the spotlight on television following a Welsh town’s experiment in how to avoid paying UK tax. Independent traders in Crickhowell, led by the salmon smokery, the local coffee shop, the adventure clothes shop, the optician, the book… – Continue reading
UPDATE 12.45pm: Bermuda has a company tax rate of zero. In Ireland its 12.5 per cent and, with the Netherlands, has given the world the term “Double Irish Dutch Sandwich”. But a trio of prominent Australian business leaders have denied the tax links of their companies to the three offshore… – Continue reading
Brussels – Google and Facebook were among US companies facing questions on Monday from European Union lawmakers about their tax-reducing techniques, a month after regional antitrust regulators raised the stakes by ordering Starbucks and a Fiat Chrysler Automobiles NV unit to repay millions of euros in back taxes. The queries… – Continue reading
A Ministry of Finance decree published on 11 November 2015 provides follow-up guidance concerning advanced tax rulings issued by the Dutch tax administration. BACKGROUND Adopted in July 2014, an amendment to the EU Parent-Subsidiary Directive addresses mismatches resulting from hybrid financing, and involves the inclusion of an anti-hybrid provision. Under… – Continue reading
On 30 October 2015, the Global Forum on Transparency and Exchange of Information for Tax Purposes published a supplementary peer review report for Luxembourg. Luxembourg, which was rated “Non-Compliant” in November 2013, has since implemented a number of recommendations made by the Global Forum, leading to an upgrade of its… – Continue reading
€1 trillion a year: that’s how much tax evasion and tax avoidance is costing European tax payers every year, according to the European Commission. Parliament set up a special committee to investigate these practices in the wake of the Luxleaks scandals and came up with plans to ensure multinationals pay… – Continue reading
What does Uber mean for Canberra? Journalist Henry Belot explains how Uber will work in the ACT and what it means for passengers and drivers. Uber and Airbnb will be dragged before the Senate inquiry into corporate tax avoidance this week to face questions about tax structures that allow them… – Continue reading
DUBLIN (Alliance News) – After the European Commission ruling that multinationals received unfair tax benefits in the Netherlands and Luxembourg, Ireland is braced for an EC ruling on whether its taxation treatment of technology company Apple constituted state aid. “I don’t know what the outcome will be, but this is… – Continue reading
Luxembourg and Netherlands must recoup unpaid tax from Fiat and Starbucks of €20m-€30 each The European Commission has ordered Luxembourg and the Netherlands to recover unpaid tax from Fiat and Starbucks in the region of €20 million to €30 million each. On October 21st, competition commissioner Margrethe Vestager condemned tax… – Continue reading
The Swiss tax office has agreed to a request from the Netherlands to hand over information about Dutch nationals with accounts at the biggest banking group in Switzerland, UBS, reports Dutch News. The request targets Dutch nationals who have had more than €1,500 on their accounts over the past two… – Continue reading
Canada is expected to join other G20 countries to sign off on an international deal in Turkey aimed at cracking down on “profit shifting” by large multinational companies seeking to reduce their tax bills. The changes, which are also aimed at exposing the corrupt use of tax havens to launder… – Continue reading
Ahead of a G20 meeting in Turkey this weekend that will tackle, among other issues, the GDP lost to global tax havens, the anti-poverty organization Oxfam is warning that it’s not just poor countries that suffer when corporations evade taxes. Julie Delahanty, Oxfam Canada’s executive director, says the only people… – Continue reading
Tax: Luxembourg among countries helping US firms cut their tax bills by more than a quarter, campaigners say. The abuse of holding company structures in the Grand Duchy, and fiscal regimes in several other countries, allows American firms to avoid paying billions of dollars in corporate profit taxes, two NGOs… – Continue reading
The final reports on the G20/OECD Base Erosion and Profit Shifting (BEPS) project were issued on 5 October (the “Reports”) after a two-year consultation period during which 62 countries and many other stakeholders (such as the World Bank, the IMF, and many trade associations) participated. These Reports, split into 15… – Continue reading
Irish corporation tax returns are behaving oddly: the Department of Finance estimates that they are running €2 billion (74 percent) ahead of forecast for the year. Economist Seamus Coffey has described these figures as “very strange”. Coincidentally (or perhaps not) the global accounts of the Apple corporation revealed an increase… – Continue reading
Apple chief executive Tim Cook said he was feeling “pretty good” ahead of the European Union’s judgement on its Irish tax arrangements, as the company announced 1,000 new jobs in Ireland on Wednesday. Ireland’s tax arrangements with the US tech giant are under investigation by the EU to see if… – Continue reading
On November 11, 2015 in the Dutch Staatscourant a Decree from the Dutch State Secretary for Finance containing an approval regarding an adjustment period for Advance Tax Rulings (ATRs) that will expire as a consequence of the entry into force of the Wet implementatie wijzigingen Moeder-dochterrichtlijn 2015 (Law implementing the… – Continue reading
As the status of professional athletes is not regulated under Czech law, there is a need for legal interpretation on this matter. The Supreme Administrative Court has ruled that athletes’ work is of such a specific nature (e.g. the method of their pay, the amount of rest and other non-compliances… – Continue reading
The New Zealand foreign trust regime – its use in international wealth planning The New Zealand “foreign trust” regime came into being over 25 years ago. It arose from a domestic initiative to make the use of offshore trusts for tax minimisation more difficult for New Zealand residents, by imposing… – Continue reading
The European Union’s top antitrust official lauded rulings ordering two companies to repay tens of millions of euros in back taxes as she considers similar decisions involving Apple Inc. and Amazon.com Inc. European Union competition chief Margrethe Vestager told lawmakers Monday that the rulings last month against Starbucks Corp. and… – Continue reading
Headline: G20 among biggest losers in large-scale tax abuse – but poor countries relatively hardest hit G20 countries are the biggest losers when US multinationals avoid paying taxes where they do business. This is the main finding of a new report on the global tax system, ‘Still Broken,’ released by… – Continue reading
U.S. companies moved $500 billion to $700 billion in profits to countries with low or no corporate tax rates in 2012 alone, according to new research published by tax reform campaigners Tuesday. Tax avoidance on such a large scale means the U.S. accounts for about 71% of profits worldwide that… – Continue reading
United States corporations avoid an estimated $US1.45 billion ($2.06b) of tax in Australia each year by shifting their profits to low or no tax countries, research shows. A joint report by advocacy and union groups Tax Justice Network, Oxfam, Global Alliance for Tax Justice and Public Services International says in… – Continue reading
Article by Patrick W Martin and Ashley Fife With a net worth of USD77.1 billion, Mexican telecoms businessman Carlos Slim Helú was ranked the second richest person in the world in a 2015 survey.1 At the end of 2014, 16 of Mexico’s citizens were on Forbes’ billionaires list.2 As for… – Continue reading
Over the weekend, German news magazine, Der Spiegel, reported that over many years EU member states such as Luxembourg and the Netherlands have sabotaged attempts to counter profit shifting to low tax jurisdictions via ‘patent boxes’ under the political leadership of current President of the European Commission, Jean Claude Juncker,… – Continue reading
FRANKFURT (The Street) — Europe’s allure as a tax haven for U.S. multinationals may be coming to an end. That’s because European Union regulators are closing up tax loopholes that U.S. companies have been enjoying for years. The first two to feel the heat are Starbucks (SBUX – Get Report)… – Continue reading
No member state of the Caribbean Community (CARICOM) ranks among the top 20 jurisdictions worldwide for financial secrecy. The United States of America (at number 3), Germany (8), Japan (12) and Britain (15), all rate as bigger tax havens than any CARICOM jurisdiction, according to the Tax Justice Network (TJN),… – Continue reading
