Countries should commit to minimum standards on the resolution of international tax disputes, the Organisation for Economic Co-operation and Development (OECD) said in a report published as part of its base erosion and profit shifting (BEPS) project.06 Oct 2015 The standards would include a commitment to “seek to resolve” cases… – Continue reading
The 500 largest American companies hold more than $2.1 trillion in accumulated profits offshore to avoid U.S. taxes and would collectively owe an estimated $620 billion in U.S. taxes if they repatriated the funds, according to a study released on Tuesday. The study, by two left-leaning non-profit groups, found that… – Continue reading
The Irish government is set to make further changes to the country’s corporate tax regime as it seeks to align itself with a global initiative to clamp down on corporate tax avoidance, reports the Financial Times. The change being considered will oblige companies that have global headquarters in Ireland to… – Continue reading
Last year at this time, news about “tax inversions” was grabbing headlines – cases where large U.S. multinationals would buy a foreign company in a tax-friendly jurisdiction, and then relocate its headquarters to reap the tax arbitrage benefits. The Obama administration responded to the rash of high-profile inversions with new… – Continue reading
On October 2, 2015, the Internal Revenue Service announced that it had achieved a key milestone in implementation of the Foreign Account Tax Compliance Act (FATCA), a critical anti-tax evasion law passed by Congress in 2010 but not fully implemented until July 2014. The milestone announced by the IRS was… – Continue reading
The IRS has announced that as of September 30, 2015 it will implement the automatic exchange of tax information as set forth in the Foreign Account Tax Compliance Act, (FATCA). The IRS Commissioner in announcing the implementation of the automatic exchange of information stated: “This information exchange is part of… – Continue reading
Wealthy Dutch people are abusing tax havens abroad to prevent from being taxed on 129 billion euros in deposits, a former tax inspector told television show Nieuwsuur. The money is held in the accounts of shell companies based in the Cayman Islands, Seychelles and Virgin Islands, among other locations, the… – Continue reading
Pharmaceuticals group defends use of legal avoidance scheme, after paying no UK corporation tax over two years despite global profits of £3bn AstraZeneca, one of Britain’s largest businesses, is using a multimillion-pound tax avoidance scheme in the Netherlands, set up months after the UK relaxed its tax laws for multinationals… – Continue reading
On Monday (5 Oct) the Paris-based Organisation for Economic Cooperation and Development (OECD) will present its final Base Erosion and Profit Shifting (Beps) project corporate tax reform proposals and on Tuesday the Ecofin council of EU finance ministers, is expected to agree on the exchange of tax rulings between member… – Continue reading
The world’s richest nations will launch a huge crackdown on multinational tax avoidance on Monday as part of the biggest shake-up of international tax rules for decades. The move could lead to a multi- billion pound gain for Chancellor George Osborne and higher tax bills for a raft of blue-chip… – Continue reading
EU member states to reveal information on tax rulings offered to companies Ireland’s corporate tax regime is to come under renewed scrutiny next week as EU finance ministers sign off on a proposal obliging member states to reveal information on tax rulings offered to companies. EU finance ministers meeting in… – Continue reading
SEOUL/SEJONG, Oct. 1 (Yonhap) — A professor of international business law at Boston University has been tapped to represent South Korea in a tax dispute case involving a Netherlands-based company, the government said Thursday. Hanocal Holding B.V., a Dutch paper company belonging to the International Petroleum Investment Company (IPIC) of… – Continue reading
Secret Luxembourg document discussed risks of special tax deals, but Jean-Claude Juncker says he cannot remember discussing it with its author The president of the European Commission faces fresh questions about his role in designing Luxembourg’s controversial system of “sweetheart” tax deals after he released an 18-year old document that… – Continue reading
The Dutch Lower House (2e Kamer) approved earlier this month the new bilateral rules for the avoidance of double taxation between the Netherlands and Curacao. This new tax arrangement replaces the current tax arrangement for the Kingdom of The Netherlands. Next step will be approval by the Upper House (1e… – Continue reading
The Netherlands have requested information on a large number of Swiss bank accounts held by residents of its country in connection with a tax probe, Swiss authorities confirmed at the weekend, reports the Swiss Local. Swiss tax authorities received a request from their Dutch counterparts in July for access to… – Continue reading
ATO to force Uber drivers to pay GST Uber is to mount a legal challenge against the Australian Tax Office after a decision to force drivers to register and pay GST. Prime Minister Malcolm Turnbull has praised ride-sharing company Uber as part of the “agile” economy he envisages for Australia…. – Continue reading
Tax avoidance is a key problem for European countries, with the EU taking several steps to try and limit the ability of businesses to shift their profits to low-tax jurisdictions. Peter Dietsch writes on the nature of the problem and what can be done to tackle it. He argues that… – Continue reading
Finance ministers of euro zone’s major economies renewed on Tuesday their commitment to curb multinational corporations’ tax avoidance and called for more consistent rules to reduce “harmful” tax competition. Multinational companies have long been in the sights of European Union authorities because of the way they can legally reduce their… – Continue reading
About 30 percent of foreign investors in Korea are from overseas tax havens, a lawmaker said Tuesday. Citing data from the Financial Services Commission and the Korea Customs Service, Rep. Park Kwang-on of the main opposition New Politics Alliance for Democracy (NPAD) said that the number of corporate or individual… – Continue reading
Marginal rate ninth highest in 34 OECD countries, pre-budget submission claims Ireland risks deterring high- calibre foreign executives from moving here because of its relatively high tax rates, the Irish Tax Institute has warned. In a pre-budget submission, the institute said Ireland’s marginal tax rate of 52 per cent was… – Continue reading
As discussed in the previous edition, due to current worldwide developments including the OECD’s move to curb tax Base Erosion and Profit Shifting (BEPS), tax policy is changing significantly. In Ghana for example, a Transfer Pricing Regulations was passed in 2012 which aimed to ensure that the tax base of… – Continue reading
(Corrects first and sixth paragraphs to make clear Intertrust does not provide tax advice) (Reuters) – Intertrust, which provides tax and regulatory compliance services to 17,000 companies, said on Monday it will seek an initial public offering (IPO) of shares on the Euronext stock exchange. The Amsterdam-based company did not… – Continue reading
European Commission president Jean-Claude Juncker has denied involvement in sweetheart deals that allowed hundreds of multinationals to slash their tax bills by locating to Luxembourg, despite being prime minister of the country for almost 20 years, reports the Financial Times. Facing questions from a committee of EU lawmakers set up… – Continue reading
Since 2011, €5.5bn held in secret bank accounts abroad has been ‘legalised’ by the tax office, generating over €600m for the treasury, according to the tax office’s latest report, according to Dutch News. Seven out of 10 people who had illicit savings in foreign accounts were over the age of… – Continue reading
Speed read On 15 September 2015 the Dutch government published its Tax Plan 2016. In this e-alert we discuss the legislative proposals in the Tax Plan which are of interest for companies. 1 INTRODUCTION Today, the Dutch Ministry of Finance published its Tax Plan 2016. In fact, the government sent… – Continue reading
Through Wetsvoorstel Overige Fiscale Maatregelen 2016, released on September 15, the Netherlands has confirmed the introduction of a new country-by-country (CbC) reporting obligation for multinational corporations. These regulations provide for the implementation of the recommendations of the Organisation for Economic Co-operation and Development (OECD) on transfer pricing documentation under Action… – Continue reading
More than 90 jurisdictions, including all 34 member countries of the Organisation for Economic Co-operation and Development (“OECD”) and the G20 members, have committed to implement the Common Reporting Standard for automatic exchange of tax information (“CRS”). Building on the model created by FATCA, the CRS creates a global standard… – Continue reading
On September 15, the Dutch government released its Budget 2016, containing the Tax Plan 2016 which includes certain amendments to Dutch tax law. The government will discuss the plans the coming weeks in parliament. Further to these discussions, some elements of the Tax Plan 2016 may change. Most proposals will… – Continue reading
The Government should reduce the rate of capital gains tax (CGT) and expand corporation tax relief for start-up companies in next month’s budget to boost growth in the financial technology sector, Financial Services Ireland (FSI), a unit within employers’ group Ibec, has urged, reports the Irish Times. In a 10-page… – Continue reading
The tax arrangement for the Kingdom (BRK) will be replaced by a new tax system in relation to the Netherlands and Curaçao. The new tax arrangement was adopted by the Dutch House of Representatives on September 10 of this year, reports the Curacao Chronicle. The tax arrangement between Curaçao and… – Continue reading
Note: This article was published by Bloomberg BNA in Tax Planning International European Tax Service Vol. 17 No. 7 July 2015 Introduction The recent LuxLeaks scandal has once again focused political attention on tax planning practices of multinationals (“MNEs”). It comes in the wake of the European Commission investigation of… – Continue reading
Luxembourg recently published a bill to implement the new anti-hybrid rule and the general anti-abuse rule (GAAR) of the EU Parent Subsidiary Directive (PSD). The bill closely follows the wording of the PSD. A similar Dutch bill is expected on 15 September 2015. While the Dutch bill may differ from… – Continue reading
Many countries have enacted a patent box regime in order to spur innovation and create domestic manufacturing jobs. Simply stated, a patent box regime provides a lower tax rate on income from the exploitation of patented goods than for other income. Among the countries that have patent box regimes are… – Continue reading
EU commissioner urges member states to ensure fair share of tax is paid EU economics commissioner Pierre Moscovici reiterated his commitment to re-launch the Common Consolidated Corporate Tax Base yesterday, urging all EU member states to ensure that companies pay their fair share of tax. Speaking following a meeting of… – Continue reading
Multinationals have come under fire yet again over their tax arrangements in some European countries, as the continent moves closer to a pan-European regime to combat tax avoidance. On Friday, European economy and finance ministers and central bankers (known as an ECOFIN meeting) gathered in Luxembourg to discuss what the… – Continue reading
All eyes are on how much taxes the British retailer Tesco Group will pay to the South Korean government after its profit of more than 5 trillion won (US$4.21 billion) with the sale of Homeplus. Industry sources say that the company will not have to pay taxes at all, or… – Continue reading
On July 30, 2015, the Netherlands and Indonesia signed a protocol (the “Protocol”) amending an agreement between the Government of the Kingdom of the Netherlands and the Government of the Republic of Indonesia for the avoidance of double taxation and the prevention of fiscal evasion, originally signed on January 29,… – Continue reading
Tax Commissioner Pierre Moscovici has urged European Union (EU) member states to “take the steps needed to fight tax evasion and tax fraud,” after new figures showed that the value-added tax (VAT) gap did not narrow in 2013. According to a new Commission report, the total amount of VAT lost… – Continue reading
The European Commission is refusing to hand over documents to MEPs investigating whether EU member states are using special tax regimes that favour large multinational corporations such as Facebook and Amazon. EU economics commissioner Pierre Moscovici wrote to the European Parliament’s special committee on tax rulings (TAXE) this week claiming… – Continue reading
In addition to its main function to eliminate double taxation, a tax treaty is also intended to promote foreign direct investment (FDI). Investors normally consider the treaty networks of a targeted investment country in deciding their investments. The more extensive the treaty networks, the more attractive for the investors. Extensive… – Continue reading
Proposals for consistent global rules on company tax cause worries all round CLARITY or chaos? Supporters of the Base Erosion and Profit-Shifting (BEPS) project, being worked on by the OECD, argue that it will bind multinationals to a consistent set of global tax rules, providing them with less licence than… – Continue reading
On July 28, 2015 the Dutch Government published the English text of the Convention between the Kingdom of the Netherlands and the Republic of Zambia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (hereafter: the DTA) and a relating Protocol,… – Continue reading
On July 28, 2015 the Dutch Government published the English text of the Convention between the Kingdom of the Netherlands and the Republic of Kenya for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income (hereafter: the DTA) and a relating Protocol,… – Continue reading
This month’s feature examines proposals for new tax information reporting requirements for large multinational businesses as part of wider and ongoing changes to the international tax system – proposals which have been described by international tax experts as the most significant development in the field of transfer pricing since TP… – Continue reading
THE African continent has been under the surveillance for Illicit Financial Flows (IFF) for quite some time now. The report prepared by the former South African President, Mr Thabo Mbeki, who chaired the AU High Level Panel on IFF in early February 2015, clearly states that the multinational companies (MNCs)… – Continue reading
Luxembourg has proposed major corporate tax changes which would bring the Grand Duchy into line with recent updates to the Parent-Subsidiary Directive. The Luxembourg government released Bill 6847 (the Bill) on August 5 2015, which includes proposed tax measures for corporations and follows several recent announcements from Finance Minister Pierre… – Continue reading
Introduction In 1934 distinguished US jurist Judge Learned Hand famously opined that “one may so arrange his affairs so that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to… – Continue reading
On August 10, 2015 the Dutch Government published the text of a Protocol amending the Agreement between the Government of the Kingdom of the Netherlands and the Government of the Republic of Indonesia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on… – Continue reading
The $100 billion is flowing across borders in search of takeovers and start-up ventures. Developing countries are losing around $100 billion a year in revenues because foreign investors are channelling profits through offshore zones to avoid tax, a study by U.N. think-tank UNCTAD said. “Tax avoidance practices therefore are responsible… – Continue reading
SEOUL, Aug. 6 (Yonhap) — The top court ruled Thursday against an oil company of the United Arab Emirates, headed by a member of the Abu Dhabi royal family, saying that it must pay millions of dollars in stock trading tax to South Korea. IPIC International B.V. (IPIC), a state-run… – Continue reading
