Switzerland and Australia have signed a joint declaration expressing their intent to begin automatically exchanging information on tax matters using internationally agreed standards beginning in 2018, the Swiss government announced March 3. Collection of the data will begin in 2017. The agreement, signed in Canberra, is the first declaration on automatic exchange of information. . .
G20 finance ministers have agreed to a plan to create a multilateral instrument to implement tax treaty-related measures under OECD/G20 the base erosion and profit shifting (BEPS) plan, the ministers said in a communique following their February 9-10 meeting in Istanbul . . .
A second man has been charged with crimes in Luxembourg for stealing and leaking confidential PwC client tax documents, including 548 private rulings, that revealed Luxembourg’s role in multinational tax . . .
The UK and Croatia on January 15 signed a tax treaty in Zagreb, the UK’s HM Revenue and Customs has announced. The treaty would replace the UK/Yugoslavia Double Taxation Convention which both countries are currently . . .
Irish Tax and Customs on December 31 released guidance notes providing section-by-section commentary on many provisions of the Irish tax code. Included are the tax administration’s views on transfer pricing, anti-avoidance, double taxation relief, tax treaties, and charging and assessing nonresidents.
See, Notes for Guidance
The Finance Committee of the German Bundesrat on October 24 proposed tax amendments that would limit cross-border hybrid financing arrangements, amend the rules for intra-group transfers, and revise the rules for the participation exemption for capital gains on portfolio shareholding, notes KPMG in a November 4 report. For discussion, see KPMG.
The European Commission has announced that it is assessing different options for a new EU VAT regime for business-to-business (B2B) supplies of goods based on taxation at destination. The work is a step toward the goal of a complete overhaul . . .
A Hungarian draft bill submitted to parliament October 22 would impose a tax on Internet service providers based on their customers’ Internet use, prompting calls for public protest. ISPs would pay a tax of Ft150 (62 U.S. cents) on each gigabyte of internet data used. The proposal may be modified to include caps on the tax. See, Wall Street Journal, Reuters, Portfolio.
An unpublished draft report written by PwC in its role as contractor for the European Commission concludes it would be good for the economy if the EU requires banks to publicly release data such as turnover, profit and loss, and taxes, on a country-by-country basis, according to an Oct. 2 article by EurActiv. The PwC report will
India is attempting to renegotiate tax treaties with Germany, France, Singapore, Italy, and South Korea to add corresponding adjustment provisions so that India can sign bilateral advance pricing agreements (APAs) involving these nations, writes Vrishti Beniwal in an August 26 Business Standard article, quoting unnamed Finance Ministry officials. See, Business Standard
Ryan, a global tax services firm, on June 3, announced that it has acquired Altus International, a Netherlands-based firm that provides transfer pricing, business restructuring, and valuation services. Release
China and Monaco have signed the multilateral competent authority agreement, moving the countries one step closer to adopting automatic exchange of financial account information for tax purposes . . .
EU lawmakers have nothing to fear from Google’s “double Irish” tax scheme because the purpose of the structure is to avoid current inclusion of US tax, not avoid EU tax, Google’s director of public policy & government affairs, Nicklas Lundblad, told a European Parliament committee investigating the tax affairs of multinationals on November 16. Lundblad was joined by representatives of Amazon, Barclays Bank, The Coca-Cola Company
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The UK on October 5 released draft regulations to implement country-by-country tax reporting to tax authorities . . .
Germany and The Netherlands have agreed to immediately begin spontaneous exchange of tax information on some advance pricing agreements (APAs) and on Dutch innovation and patent box rulings, Germany’s . . .
Ireland and Pakistan signed a tax treaty on April 16, Irish Revenue and Customs has announced. The agreement . . .
Australia and the UK have asked G20 nations to join them in an effort to stop the diversion of profits by multinational enterprises, in an initiative designed to go “further and faster” than the OECD’s base erosion and profit shifting (BEPS) plan, Australia’s . . .
The French tax administration has released a list of transactions considered to be abusive tax avoidance schemes, including some intergroup arrangements, writes KPMG in an April 6 tax alert. Included on the list are some instances where profits are relocated to a low tax jurisdiction after restructuring, unjustified payments of commissions or royalties, and abuse of tax treaties by inserting a structure to disguise the true beneficiary of a royalty, the firm writes. See, KPMG.
The UK’s HM Revenue and Customs on March 30 announced that the UK and Bulgaria signed a double tax treaty on March 26. The agreement will enter into force . . .
The US Treasury Department has updated its FATCA website, reporting that Belarus has signed a Model 1 intergovernmental agreement (IGA) with the United States as of March 18. The text of the agreement is available. See: Model 1 IGA
European Court of Justice Advocate General, Niilo Jääskinen, issued his opinion February 26 that freedom of establishment principles do not prevent Germany from imposing tax on unrealized gains inherent in assets located in Germany upon the transfer . . .
Italian firm Pirola Pennuto Zei & Associati has joined Praxity, the world’s largest alliance of independent accountancy firms, Praxity announced on February 17. Based in Milan, Pirola has offices . . .
The “Lux Leaks” documents confirm that PwC marketed tax avoidance schemes and reveal that statements made by PwC’s UK head of tax at a parliamentary hearing were “lies,” UK lawmakers charged at a House of Commons Public Accounts Committee (PAC) hearing on the role of accounting firms in multinational tax avoidance. PwC’s Kevin Nicholson was recalled before PAC MPs on December 8 to explain . . .
“Facebook pays no UK corporation tax for a second year,” by Mark Sweney, The Guardian
Switzerland’s Federal Council on October 15 adopted a dispatch on the double taxation agreement with Argentina and submitted the agreement to parliament for approval. Release.
The US Treasury Department has updated its FATCA website, reporting that Lithuania has signed a Model 1 intergovernmental agreement (IGA) with the United States as of August 26. Agreement
UK businesses that supply digital services, including broadcasting, telecoms and e-services
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Switzerland’s Federal Council on October 28 announced it has approved a new tax treaty with Liechtenstein and a tax treaty protocol with Norway . . .
Consensus is emerging among EU finance ministers that the EU Commission’s proposal for automatic exchange of private tax ruling information should be adopted with modifications providing for more limited disclosures and a shorter period of retroactive. . .
Irish Revenue on June 25 announced that, in response to industry request, it has extended the FATCA filing deadline for financial . . .
Mauritius on June 23 signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, the OECD has announced. The country is the 87th signatory to the . . .
Walmart has stashed billions in 78 subsidiaries and branches located in 15 overseas tax havens, employing well-known international tax strategies to avoid paying foreign taxes in countries where it has retail operations and US taxes on foreign earnings, writes Americans for Tax Fairness in a . . .
The EU VAT Expert Group has released an opinion welcoming the extension of an EU pilot program on cross border VAT rulings and suggesting that the rulings be made public. Under the . . .
The Spanish government on January 20 announced that it will issue regulations, expected to become effective January 1, 2016, that will require country-by-country reporting for multinationals, writes EY in a January 23 Global Tax Alert. For details, see EY.
The UK HMRC on October 18 published supplementary guidance on anti-avoidance rules that exclude some creditor loan relationships from being considered “qualifying loan relationships” for purposes of the controlled foreign companies (CFC) finance company exemption. The guidance notes that the OECD/G20 base erosion profit shifting project and potential changes in US tax laws, such as laws targeting the use of hybrid entities . . .
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