Europe

New Irish fund vehicle permits US check-the-box election

March 11, 2015

Ireland's Minister of Finance Micheal Noonan on March 11 signed an order to commence legislation that establishes the Irish collective asset-management vehicle ("ICAV"), a new Irish corporate vehicle for investment funds. The ICAV will be a corporate entity with . . .

Private tax rulings granted by Luxembourg to Amazon under EU scrutiny

October 7, 2014

The European Commission on Oct. 7 announced that it has opened an in-depth investigation into whether Luxembourg granted private rulings to an Amazon subsidiary with too favorable terms, potentially violating EU rules on state aid. The 2003 tax ruling, which is still in force, sets a methodology for the payment of a tax deductible royalty by Luxembourg-based Amazon EU Sàrl to a related limited liability. . .

Australian official says six nations jointly investigating e-commerce firms; reviews ATO work on BEPS

May 22, 2014

An Australian Taxation Office (ATO) official, on May 22, confirmed that Australia and five other nations are collaborating to investigate the global tax planning of multinationals operating in the e-commerce industry.Mark Konza, ATO Deputy Commissioner, International, said that Australia was "currently involved in a cooperative compliance approach" with five other nations. The collaboration led to the production of an. . .

Irish government to investigate effect of its tax regime on developing nations

April 29, 2014

Responding to calls from the G-20 and civil society groups, the  Irish government, on April 29,  announced that it will undertake a ‘spillover analysis’ to research what effect Ireland’s tax system has on the economies of developing countries.  The Irish government will engage consultants to assist with the evaluation and has launched a public consultation, asking interested parties to make submissions on the topic. See Public Consultation.

UK bill’s proposed limits on double tax relief may go too far, says KPMG

April 9, 2014

An anti-avoidance rule that would limit double tax relief, under consideration in U.K. Finance Bill 2014, sweeps in too many transactions and should be modified to require a tax avoidance purpose, according to KPMG's UK office. The proposal limits double tax relief claimed with respect to loan relationships, derivatives, and intellectual property non-trading credits. KPMG

Switzerland to tweak corporate tax reform proposal

April 3, 2015

A consultation has revealed widespread support for a corporate tax reform plan, proposed last fall, to abolish the cantonal tax statuses for holding, domiciliary, and mixed companies, and to introduce a royalty box, Switzerland's Federal Council said in an April 2 release. Some modifications to the reform proposals will be . . .

OECD BEPS Eurasia regional meeting draws tax officials from only six nations

March 10, 2015

Tax officials that attended an OECD Eurasia regional meeting on base erosion and profit shifting (BEPS) welcomed the OECD's effort to involve developing nations in the BEPS project, but said that barriers prevent nations in the region from participating, according to a report released March 10. These barriers were apparent as representatives of only six nations attended the regional meeting, held in Ankara, Turkey, on March 5-6.. . .

UK and Senegal sign tax treaty

February 27, 2015

The UK and Senegal signed a tax treaty on February 26, the UK’s HM Revenue and Customs has announced. Under the agreement, taxation in the source country on dividends is 5 percent for corporate shareholders that hold at least a 25 percent interest in the company paying the dividends, is 8 percent if the beneficial owner is a pension scheme established in source country, and is 10 percent in other . . .

UK and Algeria sign tax treaty

February 19, 2015

The UK and Algeria signed a tax treaty on February 18 which provides for maximum rates of withholding tax for interest and royalty payments of 7 percent and 10 percent respectively, UK's HM Revenue and Customs has announced. The treaty also provides for withholding taxes for dividends of 5 percent . . .
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