ECJ rules that intragroup services provided by US company to Swedish branch are subject to VAT, hitting global financial firms

September 19, 2014

A European Court of Justice (ECJ) judgment, released Sept. 17, will result in large VAT bills for banks, insurers, and other businesses considered VAT-exempt.  The decision, Skandia America Corp. v. Sweden, concludes that supplies of services from a non-EU company to its EU branch are subject to VAT when the branch belongs to a VAT group. Previously, provision of these services . . .

Update: For UK government's October 14 reaction to Skandia, see HM Revenue and Customs Brief 37 (2014) - VAT grouping rules

ECJ rejects US company’s assertion that Germany’s differing treatment of foreign and domestic dividends violates free movement of capital

September 11, 2014

The European Court of Justice, in Kronos International Inc. released Sept 11, has ruled that a US registered company resident in Germany may assert that German tax rules violate free movement of capital, but the company may not claim freedom of establishment rights. The ECJ went on to reject the company's contention that Germany's tax rules in effect at the time, which permitted a set off for . . .

Roubalsky joins Denton’s Moscow office

September 5, 2014

Kirill Roubalsky has joined the Moscow office of Dentons as a senior associate in the Tax and Customs practice. Roubalsky, fomerly with Pepeliaev Group, Schekin & Partners and Muranov, Chernyakov & Partners, specializes in tax litigation, general corporate and international tax law and tansfer pricing issues. Release

Gibraltar consults on proposed register of beneficial ownership of companies

July 31, 2014

The government of Gibraltar, on July 24, opened a consultation on a proposal to establish a registry of the ultimate beneficial owners of Gibraltar companies. Input is requested on topics such as whether the registry should made available publicly or only to select users, and what type of information, beyond names and addresses, should be required. Submissions are due September 30. Consultation Paper (PDF 386KB)

EU probes whether tax rulings granted to Apple in Ireland, Starbucks in Netherlands, and Fiat in Luxembourg violate state aid

June 11, 2014

The European Commission, on June 11, announced that it is investigating whether individual transfer pricing rulings granted to Apple in Ireland, Starbucks in the Netherlands, and Fiat in Luxembourg sanctioned the allocation of too little profit to activities in those countries, thereby amounting to illegal state aid. The Commission has also initiated an infringement action against Luxembourg in connection with the matter.The decision is part of a wider investigation into whether tax rulings and . . .

-Update: The Luxembourg Finance Ministry, in a June 12 statement, said it would continue to defend against the Commission's charges of illegal state aid, and said it still has doubts about the legality Commission requests for information, see statement.

UK and Monaco sign TIEA

January 28, 2015

The UK's HMRC on January 28 published the text of a tax information exchange agreement (TIEA) signed recently by the UK and Monaco . . .

Former PwC auditor charged in Lux Leaks theft

December 16, 2014

Former PwC auditor, Antoine Deltour, was charged with multiple crimes in Luxembourg on December 12 for stealing and leaking confidential PwC client advance tax rulings and other documents that were later placed on the Internet by the International Consortium of Investigative Journalists (ICIJ). He has admitted his involvement, but says that he did not provide all the material released on the ICIJ website. See, Blomberg, The Guardian, Luxemburger Wort, The Irish Times.

Richard Asquith joins Avalara

October 21, 2014

Richard Asquith has joined Avalara in the UK as VP of Global Tax Compliance, Avalara announced on October 21. Asquith was previously with the TMF Group. Release.

Switzerland and Cyprus sign tax treaty

July 25, 2014

Switzerland and Cyprus, on July 25, signed an agreement for the avoidance of double taxation with respect to taxes on income and on capital. It is the first tax treaty to be signed between the countries. The agreement includes a provision for the exchange of tax information on request.
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