Africa
Singapore’s tax treaties with Ecuador, San Marino, and Seychelles enter into force
Singapore’s Ministry of Finance on December 18 announced that tax treaties signed by Singapore and Ecuador . . .
Europe
European Court of Justice
ECJ approves German loss recapture rule and denial of final losses in upon the intra-group sale of a foreign PE: Timac Agro Deutschland
The European Court of Justice on December 17 ruled in Timac Agro Deutschland v.Finanzamt Sankt Augustin (C‑388/14) as . . .
Asia-Pacific
Japan and Germany sign tax treaty
Japan and Germany on December 17 signed a tax treaty, wholly amending the . . .
Europe
Europe
Italy finalizes tax incentives
The Italian Parliament, on August 11, converted a series of tax incentives into law without modification, writes EY in an August 25 report. Included are increased notional interest deduction benefits, a tax credit for new plants and equipment, and an expanded withholding tax exemption for interest and substitute tax for loans. For discussion, see EY.
Europe
European Commission seeks members for new expert group on automatic exchange of information
The European Commission has launched a call for applications for a newly established expert group on automatic exchange of financial account information for direct taxation purposes. The . . .
Europe
Tax deals granted by Luxembourg to Amazon, Microsoft, and McDonald’s under EU scrutiny
The European Union’s competition commission has requested information from Luxembourg to determine if tax deals granted to Amazon violate state aid rules, according to unnamed sources interviewed for a July 3 FT report.
Meanwhile, the EU is scrutinizing Luxembourg’s taxation of Microsoft’s and McDonald’s operations, according to a July 4 Bloomberg article.
The actions appear to be part of a wider investigation into whether tax rulings
Council of the European Union
EU Council adopts directive on automatic exchange of tax rulings, reaches conclusions on BEPS
(Updated 12/10/2015) The European Council, during a December 8 meeting, formally agreed to an amended directive requiring EU States to exchange information automatically on advance cross-border tax rulings and . . .
Canada
UK and Canada agree to details of arbitration clause in tax treaty, text available
Canada and the UK have signed an agreement specifying the procedures for arbitration of tax disputes between the two nations, Canada’s Department of Finance . . .
Americas
US lawmakers to hold hearings on BEPS, EU State aid cases
(Updated 11/25/2015) The US Senate Finance Committee will consider the OECD/G20 base erosion profit shifting (BEPS) project and the European Commission’s State aid challenges to private tax rulings entered into between EU States . . .
European Court of Justice
Asia-Pacific
Switzerland’s Federal Council adopts dispatch on double taxation treaty with Oman
Switzerland’s Federal Council today announced that it has adopted a dispatch on a double taxation agreement signed with Oman on May 22. The agreement has been . . .
Asia-Pacific
Japan and Germany agree to terms of new tax treaty
Japan and Germany have reached an agreement in principle on a new tax treaty, Japan’s Ministry of Finance announced July 16. The new treaty will include an arbitration clause . . .
Americas
US and Croatia sign Model 1 FATCA IGA
The US Treasury Department has updated its FATCA website, reporting that Croatia has signed a Model 1 intergovernmental agreement (IGA) with the United States as of March 20. The text of the agreement is available. See: Model 1 IGA
Europe
European Parliament committee to investigate tax ruling practices of EU states
The European Parliament voted February 12 to establish a special committee to investigate the tax ruling practices of EU member states. The 45-member committee . . .
Europe
Switzerland consults on legislation to implement automatic exchange of tax information
Switzerland’s Federal Council on January 14 launched two consultations on legislation that would enable automatic exchange of tax information with other nations. One consultation concerns approval and implementation of the OECD/Council of Europe Convention . . .
Europe
UK diverted profits tax hits MNEs that avoid PE rules, route profits through tax havens
The UK government on December 10 proposed a new 25 percent tax on “diverted profits,” targeting MNEs that engage tax avoidance transactions, including MNEs that “exploit” permanent establishment (PE) rules and that reduce their tax liability through transactions that lack substance. The new tax, first announced in UK Autumn Statement 2014, affects only large MNEs, is . . .
Americas
US IRS gives countries with “in substance” FATCA IGAs more time to sign IGAs, adds more countries to the “in substance” list
The US IRS on December 1 released an advance copy of guidance that provides that countries that have reached FATCA intergovernmental agreements (IGAs) “in substance” that do not sign an IGA by December 31 will continue to be treated as if an IGA was in effect as long as the country displays a “firm resolve” to sign an IGA as soon as possible. The new guidance . . .
Europe
Switzerland signs agreement for automatic exchange of information
Switzerland on November 19 signed a multilateral competent authority agreement, moving the country one step closer to adopting automatic exchange of financial account information under the OECD/G-20 Common Reporting Standard beginning 2018 . . .
Asia-Pacific
Revised treaty between Australia and Switzerland enters into force
A revised tax treaty and protocol between Australia and Switzerland, signed July 30, 2013, entered into force on October 14 , Australia’s tax authority has announced. Australian legislation enforcing the revised tax treaty received royal assent on September 24. See, release, Australia-Switzerland Tax Treaty (142 KB).
Europe
European Commission releases 2014 report on EU tax reform
The European Commission on October 13 released a report “Tax Reforms in EU Member States: 2014.” See, report (7.34 MB), summary.
Isle of Man
Isle of Man signs TIEA with Swaziland
The Isle of Man has announced that it signed a tax information exchange agreement (TIEA) with the Kingdom of Swaziland on May 16.
The TIEA was signed by Eddie Teare MHK, the Isle of Man’s Treasury Minister, in the Isle of Man, and by Senator Martin G. Dlamini, Swaziland’s Minister for Finance, in Swaziland.
The Isle of Man has signed 42 tax agreements, including 32 TIEAs.
Europe
France’s National Assembly passes amendment requiring public country-by-country reporting: Eurodad→
The amendment will be taken up by the Senate this week. See: Eurodad.
Europe
Europe
The State Administration of International Tax Avoidance: Omari Y. Marian / SSRN →
Professor Omari Y. Marian of the University of California, Irvine School of Law analyzes the “Lux Leaks” tax rulings, concluding that the Luxembourg tax authority, in exchange for payment, purposefully created legal differences between the tax laws of source and residence jurisdictions for multinationals to exploit. See: SSRN.
Americas
US signs first competent authority arrangements to implement FATCA IGAs with Australia and UK
The US IRS announced November 24 that it has signed competent authority arrangements (CCAs) with Australia and the UK to establish . . .
Europe
Asia-Pacific
Hong Kong, Italy tax treaty enters into force
A tax treaty between Hong Kong and Italy signed January 2013 has entered into force as of August 10, Hong Kong’s Inland Revenue Department has . . .
Europe
Airbus and tax justice campaigner questioned by European Parliament committee
The EU needs to be mindful of tax competition from countries outside the EU and adopt policies that will allow EU companies to remain competitive, Airbus’s head of tax, Guillaume de La Villeguérin, told the European Parliament’s Special Committee . . .
Europe
Iceland amends transfer pricing rules
Iceland has revised its transfer pricing rules to no longer require documentation for domestic transactions, narrow the definition of related entities, and remove a reference to the . . .
Americas
Colombian tax reform includes wealth tax on foreign companies
Colombia’s president has signed into law a tax reform package which includes a temporary annual tax on wealth in excess of $1 billion pesos (USD 425,000) held by domestic or foreign legal entities, writes PwC in a December 28 tax alert. The tax package also includes increases in income tax withholding rates . . .
Europe
Journalists publish 35 more leaked Luxembourg tax rulings on the Internet
The International Consortium of Investigative Journalists (ICIJ) on December 9 published on the Internet 35 more leaked Luxembourg private tax rulings. The documents originated from the big four accounting firms, as well as from smaller Luxembourg-based tax firms and law . . .
Europe
Russian legislature approves CFC deoffshorization law
A Russian proposal to tax controlled foreign corporations (CFCs) was passed by the Council of the Federation on November 19 and by the State Duma the day before, Russian news agency TASS and the Russian Legal Information Agency have reported. Known as the “deoffshorization” proposal. . .
Europe
Poland to tighten thin cap rules
Poland’s President, Bronislaw Komorowski, on Sept. 17, signed into law changes to the thin capitalization rules that reduce the debt-to-equity ratio to 1:1, broaden the definition of “qualifying entity,” extend the rules to indirect relationships, and introduce new methods to determine tax deducible interest limits, writes KPMG Poland in an Oct. 2 report. For discussion of the new law, see KPMG (PDF 126 KB).
Americas
Arthur Andersen name revived as WTAS changes its name to Andersen Tax
WTAS, a firm founded 12 years ago by members of now-defunct accounting firm Arthur Andersen, has renamed itself Andersen Tax. Andersen Tax will be a member of a newly created international entity called Andersen Global.
The firm has 17 offices in the US and locations in Switzerland, Russia, France, Italy, and The Netherlands. Release
Americas
US and Czech Republic sign Model 1 FATCA IGA
US Treasury Department has updated its FATCA website, reporting that the Czech Republic has signed a Model 1 intergovernmental agreement (IGA) with the United States as of August 4. Agreement
Americas
Americas
Europe
