“Any retroactive tax would be borne by US taxpayers in the form of a credit,” notes US deputy assistant secretary, Robert Stack. See: Financial Times
Switzerland’s Federal Council on September 11 proposed to extend the temporary withholding tax exemption for interest paid on contingent convertible bonds (CoCos) and write-off bonds of systematically important banks and to establish a similar . . .
The US Treasury Department has updated its FATCA website, reporting that the Slovak Republic has signed a Model 1 intergovernmental agreement (IGA) with the US as . . .
A European Parliament committee has published letters from EU member state officials describing tax ruling practices, efforts to combat tax avoidance, and compliance with EU spontaneous exchange of information directives. The letters, published by. . .
Switzerland’s Federal Council announced June 24 that it will no longer pursue reforming the withholding tax system applicable to bond interest switching from the debtor principle to the paying agent . . .
Sami Tuominen has joined Bird & Bird as a partner to head of its Finnish tax group based in Helsinki, the firm announced June 1. Tuominen joins from local law firm, Borenius. Tuominen, an author of tax treatises and a regular . . .
The Italian government on January 24 passed a law that significantly expands its new patent box regime, allowing additional categories of intellectual property and outsourced activities to qualify, and dispensing with the requirement to obtain a ruling to determine income attributed to IP in many cases, writes EY in a January 27 tax alert. See, EY.
The Luxembourg tax authorities released a tax circular January 9 detailing the tax treatment of income from Luxembourg limited partnerships and Luxembourg special limited partnerships, including specific guidance on entities whose activities that fall within the definition of an alternative investment fund, writes PwC in a January 14 tax alert. For details, see PwC.
The European Commission has enlarged its state aid investigation into private tax ruling practices to cover all 28 European Union states. “The Commission will ask Member States to provide information about their tax ruling practice, in particular to confirm whether they provide tax rulings, and, if they do, to request a list of all companies that have received a tax ruling from 2010 to 2013,” the Commission said December 17 in a press release . . .
The EU Council on December 9 announced an agreement to add an antiabuse provision to the parent-subsidiary directive to stop multinational tax avoidance. The antiabuse rule will be a minimum standard; countries may adopt stricter national laws if they choose . . .
Spain and Canada have signed a protocol their update their tax treaty, the Spanish government announced on November 18. The new protocol would update . . .
The Irish government on October 23 published Finance Bill 2014, which gives effect to the taxation-related measures previously announced in the government’s 2015 budget.
Included are changes to Ireland’s company residence rules which slowly close the “double Irish” corporate tax loophole. Beginning January 1, 2015, all . . .
Irish tax proposal will not eliminate “double Irish,” say attorneys: Even if Ireland eliminates the Irish incorporated non-resident company, the tax benefits of the “double Irish Dutch sandwich,” can still be achieved by setting up a Irish company managed and controlled in Malta or the UAE instead of a Caribbean nation under Ireland’s existing tax treaties with those nations, write Jeffrey L. Rubinger and Summer Ayers LePree of Bilzin Sumberg Baena Price & Axelrod LLP in an October 23 website post. See, Bilzin Sumberg.
China and Russia on October 13 signed an agreement for the avoidance of double taxation. The agreement would replace a tax treaty signed by the countries in May 1994. Under the new agreement, dividends . . .
The US Treasury Department has updated its FATCA website, reporting that Poland has signed a Model 1 intergovernmental agreement (IGA) with the United States as of October 7. Agreement
Germany’s Federal Ministry of Finance, in guidance released June 4, has provided definitions of terms used in transfer pricing, including the arm’s length principle, transfer prices, and business relationships, according to a July 2 KPMG article. See, KPMG.
The European Commission’s inquiry into whether Ireland granted illegal state aid to Apple by granting the company favorable tax rulings could turn into a long-running court battle, said Finance Minister Michael Noonan on July 3.
“We will provide a detailed, technical, legal rebuttal to the Commission’s position and, if necessary, defend our position in the European courts,” said Noonan, in comments before the Dáil. He added that if the matter goes to court, it could remain unresolved for three to five years . . .
The EU and Liechtenstein on October 28 agreed to automatically exchange tax information on the financial accounts of each other’s residents beginning . . .
The financial results tax is now expected to go effect in 2017. See: TASS.
Data suggests that while the existence of a patent box regime incentivizes multinationals to shift the location of their patents, the shift is usually not accompanied by an increase in research activities or . . .
Amazon has confirmed that as of May 1 it began booking profits from sales in the UK, Italy, Spain, and Germany in the country where the sale actually took place rather than in low-tax Luxembourg. See, New York Times, Wall Street Journal, Financial Times, The Independent, International Business Times, The Guardian, Tim Scott – Tax is an Accrual Business, Out-Law.com
German firm Roever Broenner Susat has joined Mazars’ international integrated partnership, Mazars announced April 21. As a result of the merger, Mazars will have 12 offices in Germany with 1,000 staff members, including 68 partners. The firm . . .
The Spanish government has published draft regulations, effective January 1, 2016, that require country-by-country reporting for multinationals consistent with guidance released under the OECD/G20 base erosion and profit shifting plan, writes PwC in an April 9 tax alert. For details, see PWC.
Italy’s parliament, on December 22, passed a law introducing a patent box regime and adding a new research and development (R&D) tax credit, among other measures, writes EY in January 2 tax alert. For discussion, see EY.
EU finance ministers on December 9 adopted a directive to extend mandatory automatic exchange of information between tax administrations to interest, dividends, and other income, and to account balances and sales proceeds from financial . . .
European Court of Justice Advocate General Juliane Kokott in an October 23 opinion advised the ECJ to abandon the Marks & Spencer exception for loss relief for foreign group members and sanction UK legislation that restricts such loss relief.
Kokott said the . . .
The governments of Luxembourg and Estonia, on July 7, signed an agreement for the avoidance of double taxation. Text (PDF 1.05MB)
In a July 2 report, Deloitte analyzes significant corporate tax proposals in a tax reform package released by the Spanish government on June 20. The corporate tax reforms include a reduction in corporate tax rates for 2015 and 2016; new anti-hybrid rules; changes to controlled foreign company rules; loss of deductions for intragroup profit participating loan interest; modifications to net operating loss carryforward rules, and changes to transfer pricing definitions, documentation, and valuation method hierarchies, writes Deloitte. For more details, see Deloitte.
Malta and Curaçao signed a tax treaty on November 18, Malta’s Ministry for Finance . . .
The US Treasury Department has updated its FATCA website, reporting that San Marino and the US signed a Model 2 intergovernmental . . .
Decisions on the advance pricing agreements may be released as soon as next Wednesday, writes Tom Fairless of The Wall Street Journal. See: The Wall Street Journal. More: Bloomberg. Related: MNE Tax.
The EU Commission on October 8 launched a public consultation on an EU-wide common consolidated corporate tax base (CCCTB). Through the . . .
Switzerland’s Federal Department of Finance on May 21 announced that Switzerland and Grenada have signed a tax information exchange agreement (TIEA). The agreement, signed . . .
The Netherlands and Malawi have signed a revised tax treaty that includes antiabuse provisions preventing the benefits of the treaty from being used solely to avoid tax, The Netherlands government said on April 23. Dutch Minister for Foreign Trade and Development Cooperation Lilianne Ploumen said that the antiabuse provisions, which relate to taxes on dividends, interest and royalties . . .
Switzerland and the European Union on March 19 initialed an agreement to commence automatic exchange of information from 2018 once the necessary legal basis has been created, Switzerland’s Federal Department of Finance has . . .
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