The Swiss government on November 24 announced that double tax agreements signed by Switzerland and Cyprus, Iceland, Estonia, and Uzbekistan have entered into force. The goverment also announced that Switzerland signed . . .
Hong Kong’s Inland Revenue Department has announced on its website that Hong Kong signed at tax treaty with Romania . . .
Witnesses testifying before the US Senate Committee on Foreign Relations on October 29 urged the committee to recommend ratification of eight pending US tax treaties and protocols, highlighting key aspects of the . . .
European Commission President Jean-Claude Juncker told parliamentary committees January 17 that the EU should adopt rules governing private rulings . . .
Switzerland and Norway have signed protocol to amend their 1987 double taxation agreement to introduce an arbitration . . .
“Because of a change in how its Irish subsidiary is registered, Etsy no longer needs to publicly disclose basic financial information about that unit,” write Bloomberg’s Alex Barinka and Jesse Drucker. See: Bloomberg Business
The UK’s HM Revenue Customs on April 13 notified UK financial institutions that UK FATCA guidance will be amended to remove the requirement to file nil returns and to no longer require FATCA reporting by most holding and treasury companies. HMRC said the US IRS has changed its . . .
The US IRS has released on its website the text of a Model 1 FATCA intergovernmental agreement (IGA) signed with Kosovo. The agreement is effective as of January 7 . . .
Hong Kong and Germany completed their second round of tax treaty negotiations on March 6, according to Hong Kong’s Inland Revenue Department. This would be the first comprehensive double . . .
Tax arrangements that PwC promoted in Luxembourg, revealed through the “Lux Leaks” scandal, bear all the hallmarks of a mass-marketed tax avoidance scheme, according to a UK Public Accounts Committee report . . .
The European Commission on December 19 requested formal consultations with the US in the World Trade Organization (WTO) concerning recent Washington State legislation extending tax subsidies to Boeing and other aerospace firms from 2024 through 2040, estimated at USD 8.7 billion. The Commission maintains that Washington State tax subsidies, originally set to expire in 2024, have already been declared WTO inconsistent. See, EU Commission release.
Luxembourg’s Ministry of Finance on December 10 defended its tax rulings practice and its record on tax transparency, claiming that “Luxembourg is a constructive, reliable player in the move towards greater transparency in tax matters.” Though not mentioning the matter directly, the Ministry also responds allegations stemming from the “Lux leak” . . .
Alex Pham, has joined Luxembourg firm, Kleyr Grasso, to establish a new tax department there, the firm announced November 20. Pham’s experience includes international tax structuring, corporate tax, individual taxation, and VAT. See, release.
The Czech Republic Supreme Administrative Court elaborated on the burden of proof in transfer pricing and incentive regimes cases in a ruling which concluded that a taxpayer did not qualify for incentive regime tax relief because it failed to prove it priced transactions with its subsidiary at arms length, writes KPMG in a November 17 report. For discussion, see KPMG.
The Isle of Man Treasury announced on October 21 that the “Agreement for the Exchange of Information Relating to Tax Matters” signed by the Isle of Man and Switzerland on August 28, 2013, entered into force on October 14. Release.
The European Court of Justice on Oct. 2 ruled that where goods are sold by a company established in State A to a person in State B, and where the vendor does finishing work on the goods performed by a service provider in State B before the goods are transferred to the purchaser, the place of supply is State B. See, Fonderie 2A v. Ministre de l’Économie et des Finances, C-446/13.
The European Commission on Oct 1 announced that it has opened an investigation into whether Gibraltar’s tax authorities selectively favor companies in private tax rulings thereby violating EU state aid rules.
The Commission said it has has assessed 165 tax rulings
. . .
Switzerland and the European Union, on July 1, initialed an agreement outlining principles and intentions concerning Switzerland’s business taxation regime . . .
European Union finance ministers, on June 20, announced an agreement to revise the Parent-Subsidiary Directive to stop multinational entities from using hybrid instruments to achieve double nontaxation.
All 28 member states gave their full backing to the proposal at an Economic and Financial Affairs Council (ECOFIN) meeting in Luxembourg. . . .
In a May 12 press release, the Indian Ministry of Finance has asserted that it will continue to urge Switzerland to ratify the OECD Multilateral Convention on Mutual Administrative Assistance on Tax Matters. See, Press Statement
The Belgian Tax Authority, in Circular AAFisc NR 13/2014, released April 3, clarifies aspects of the Fairness Tax, but leaves unresolved issues such as how to calculate the tax on permanent establishments of non-resident companies and the issue of the potential incompatibility of the new law with the Belgian Constitution, EU law, and double tax treaties, EY writes in a report on the new tax.
Jersey and the Kingdom of Belgium signed a tax information exchange agreement on March 13. Press Release
The EU Commission announced October 12 that it has made changes to its consolidated list of non-EU countries deemed non-cooperative for tax purposes, as identified by the Member States. The updates to the list, located on the Commission’s . . .
UPDATE (10/14/2015): Hong Kong Treasury notes the removal of Hong Kong from Spain and Estonia’s blacklists: The government said that allegations that Hong Kong are a tax haven are unfounded. See, release.
Switzerland and Albania on September 9 signed a protocol to amend their November 1999 double taxation . . .
Irish Revenue on August 28 released five tax manuals on recent corporate tax law changes, including guidance on new tax residency rules that make it more difficult for multinationals to take advantage of the “Double Irish” tax loophole and rules that change capital allowances for . . .
A few changes will be made to the UK’s controversial diverted profits tax in the final version of the legislation, set to be introduced next week, according UK budget documents released March 18. Proposed legislation to add country-by-country reporting requirements for MNEs . . .
EU finance ministers have renewed their push to enact a financial transaction tax among the EU states, with some agreeing to a phased timetable for the introduction of the tax, and others expressing support for a new plan to widen the tax base, particularly with respect to derivative products. In a statement released January 22, Austrian finance minister Hans Jörg Schelling . . .
Ireland’s Department of Finance on January 14 published a consultation document on a proposed “knowledge box” tax regime that will provide for a special lower rate of tax on income from intellectual property. The government did not disclose the proposed tax rate. The Irish government also said that it will adhere to OECD and EU . . .
The European Commission on December 19 invited interested parties to comment on its investigation into whether an advance pricing agreement (APA) granted by the Netherlands to a Starbucks subsidiary constitutes illegal state aid. The Commission said it currently. . .
PwC’s Kevin Nicholson has been called to testify before the UK House of Commons Public Accounts Committee (PAC) to discuss the role of large accountancy firms in multinational tax avoidance. The hearing will give PAC committee lawmakers the opportunity to grill Nicholson, who is head of tax at PwC UK, on the “Lux leak” documents . . .
The European Commission intends to analyze leaked Luxembourg private tax rulings for evidence of illegal state aid, the European Union’s new competition chief, Margrethe Vestager, said November 20. “We consider the Lux-Leaks documents as market information. We will examine [them] and also therefore evaluate whether or not this will lead us to . . .
The German Bundesrat on November 7 approved a draft tax bill that contains a number of important proposals, including anti-hybrid and anti-double dip rules that are more strict than OECD recommendations, writes Deloitte. A welcome proposal would broaden the intragroup restructuring exception. . .
The International Consortium of Investigative Journalists (ICIJ) on November 5 published confidential tax documents of PwC clients on the Internet accompanied by a series of news stories that conclude that Luxembourg has been a long-time partner in multinational corporation tax avoidance. The leaked documents include 548 Luxembourg advance rulings, or comfort letters; corporate tax returns . . .
Luxembourg defends tax rulings: “The rulings in Luxembourg are compatible with the Luxembourg legislation, compatible with the EU-legislation, and compatible with the OECD-conventions, and any other international conventions,” Minister of Finance, Pierre Gramegna, said November 6, at the Ecofin council in Brussels. See speech.
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Jean-Claude Juncker should resign says Bloomberg: Jean-Claude Juncker, the new president of the European Commission, has a “clear conflict of interest” as head of the body investigating the tax practices he oversaw as Luxembourg’s prime minister, says Bloomberg in a November 9 opinion piece. See, Bloomberg.
The European Commission has concluded that public dissemination of country-by-country reporting by banks will not have a negative impact on the economy, paving the way for public release of the data by January 1, 2015. “At this stage, the public country-by-country reporting of information under Article 89 of Directive 2013/36/EU is not expected to have significant negative economic impact, in particular on competitiveness, investment, . . .
Monaco on October 13 because the 84th jurisdiction to sign the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. Release.
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