Tax attorney Graham Iversen will join the global tax practice of Greenberg Traurig LLP in London. Iversen will leave Slaughter and May, where he worked for 14 years on tax issues associated with mergers and acquisitions, structured finance, private equity, corporate reconstructions, and public debt and equity. Release
Germany and Israel, on August 21, signed a revised and modernized double taxation convention, updating their agreement which was last modified in 1977.
The agreement reduces withholding tax on interest and . . .
The Netherlands Ministry of Finance, on June 12, published five decrees updating guidance on advance pricing agreements (APAs), advance tax rulings (ATRs), and minimum substance requirements to obtain an APA or ATR, according to a report by Loyens & Loeff. Minimum substance requirements are also provided for service companies that do not have an APA that wish to apply the Dutch treaty network or the EU Interest & Royalty Directive. For details and analysis, see a June 12 report by Loyens & Loeff
Luxembourg Finance Minister, Pierre Gramegna, and Jordi Cinca Mateos, Finance Minister of the Principality of Andorra, signed an agreement for the avoidance of double taxation and prevention of fiscal evasion between the two countries, according to a June 2 Luxembourg Ministry of Finance press release.
Switzerland and San Marino, on May 16, signed a tax information exchange agreement. Press Release
A Scottish government proposal to introduce a general anti avoidance rule (GAAR) has gained the support of the Scottish Parliament’s Finance Committee. In a report released May 2, the Committee said . . .
For an analysis of a March 25 Denmark National Tax Board ruling concluding that a partnership structure did not create a permanent establishment in Denmark and that anti-avoidance rules did not apply, see Deloitte.
Aisling Donohue, a tax partner with mgpartners, Dublin, discusses Ireland’s unexpectedly large 2015 corporation tax receipts and the country’s likely response to the OECD/20 base erosion profit shifting (BEPS) recommendations and the EU proposals for a common consolidated corporate tax base (CCCTB) and a financial transactions tax.
The Netherlands should consider adopting new tax provisions to counterbalance the increased tax burdens placed on companies from OECD/G20 base erosion and profit shifting (BEPS) plan, State Secretary of Finance Eric Wiebes said. . .
Members of the European Parliament Economic and Monetary Affairs Committee have expressed disappointment with a deal struck October 6 for a EU directive on automatic exchange of tax ruling i. . .
Irish Revenue on June 23 published three FATCA user guides . . .
The Netherlands goverment supports expanding public release of country-by-country data beyond the extractive and banking industries to all companies, Eric Weibes, State Secretary of Finance . . .
The European Union and Switzerland on May 27 signed an agreement to commence automatic exchange of bank account information from 2018. Switzerland also launched a consultation
. . .
The European Commission on March 26 made a formal request to Belgium to amend dividend taxation rules to comply with the parent-subsidiary directive. The Belgian law does not allow . . .
The European Commission on March 16 released the first report of the Expert Group on Automatic Exchange of Financial Account . . .
taly and Switzerland on February 23 signed a protocol to their double tax treaty agreeing to the OECD standard for the exchange of information on request, the Swiss government has announced. The countries also signed a roadmap for continued dialog on financial and tax matters . . .
Spain has enacted major tax reform, including corporate tax reform, effective January 1, 2015, writes Deloitte in a December 2 alert. The corporate tax changes include a reduction in tax rates for 2015 and 2016, anti-hybrid rules and . . .
Russian President Vladimir Putin on November 24 signed the “deoffshorization” law, requiring Russian companies and individuals to pay tax on undistributed controlled foreign corporation (CFC) profits. The new law, effective January 1, also contains provisions clarifying the tax residency status of foreign legal entities, adds new rules on indirect transfers of immovable property through share transfers, and requires that a recipient of treaty benefits be the beneficial owner of the income.
UPDATE (11/28/2014): The new law contains a few changes from earlier drafts, writes EY in its Russian Tax Brief, released November 27. For analysis of the changes, see EY.
The UK’s HMRC has released a revenue and customs brief concerning the impact in the UK of the European Court of Justice judgment in the Skandia America Corp. case . . .
The UK on Sept. 29 released the FATCA schema and supporting documents in advance of the availability of the FATCA service. See, release.
The European Commission, on August 22, took another step toward addressing concerns that the Netherlands’ corporate tax exemption for Dutch public enterprises violates state aid, asking . . .
DLA Piper has announced that Hervé Israël has joined DLA Piper’s Paris office as a tax partner.
Hervé was previously partner and head of the international tax group at Holman Fenwick Willan. Release
Influential chair of the UK Public Accounts Committee, Margaret Hodge, has urged British shoppers to boycott Amazon following revelations that the online retailer paid only £4.2m in tax last year on sales of £4.3bn, according to an article by Juliette Garside, The Guardian. See also, Peter Campbell, Daily Mail; Sarah Shaffi, The Bookseller; Gideon Spanier The Independent; Sean Martin International Business Times UK
The European Union’s Joint Transfer Pricing Pricing Forum has published profiles of the transfer pricing policies of all EU member states, including competent authorities’ contact details and other information. JTPF Country Profiles
The EU Joint Transfer Pricing Forum has released statistics for 2014 on EU nation advance pricing agreements (APAs) and on pending . . .
The EU Commission will address the tax bias that favors debt over equity as a part of its proposal for an EU-wide common consolidated corporate. . .
The Isle of Man signed a tax information exchange agreement (TIEA) with the Cayman Islands on September 22 . . .
Australia’s Treasurer Joe Hockey on September 17 announced that Australia intends to commence tax treaty negotiations . . .
The European Commission has announced that its current view is that Belgium’s excess profits tax ruling system provides for a selective advantage tantamount to State aid, and has requested stakeholder comments on this determination by July 5. According to the Commission, about 50 companies have used the program to reduce . . .
The UK and Kosovo on June 4 signed an agreement for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital. See:, Treaty.
Switzerland’s Federal Council, on April 22, announced that it has instructed the Federal Department of Finance to create the legal basis for rules that would provide a flat-rate tax credit for foreign companies’ permanent establishments in Switzerland which have their registered office in a country with which Switzerland has a double taxation agreement. The credit would alleviate double . . .
The India expects to sign an agreement with the US on Sunday that sets out a framework to resolve mutual agreement procedure disputes concerning the appropriate markup to apply to related-party transactions, and hopes to sign similar agreements with the UK, France, and other European nations, writes Jayshree P. Upadhyay of Business Standard in a January 24 article, quoting an unnamed tax official. See, Business Standard.
Irish Tax and Customs on January 13 released updated guidelines on calculating the research and development (R&D) tax credit that take into account new rules, effective tax years beginning January 1, which no longer require companies to subtract base year expenditures . . .
The UK’s proposed diverted profits tax has been drafted to withstand legal challenges and will complement, rather than conflict with, ongoing OECD work on base erosion and profit shifting (BEPS), a Treasury official said January 7 during a parliamentary debate on the new tax. The official also said that while some MNE profit shifting involving loans is excepted from the diverted profits tax, Treasury is working on the issue in . . .
The Swiss Federal Council on November 28 issued a dispatch discussing proposed changes to the taxation of residents and nonresidents currently subject to withholding tax on earned income. See, release.
Russia will begin automatic exchange of financial account information under the OECD/G20 Common Reporting Standard in 2018, Finance Minister Anton Siluanov told reporters November 17, Russian news agency TASS. . .
UAE and Luxembourg on October 26 signed a protocol to amend the countries’ 2005 agreement on the avoidance of double taxation and prevention of fiscal evasion on income and capital. Release.
Copyright © 2021. DISCLAIMER: The information provided herein is general and may not be applicable in all situations. It should not be acted upon without legal advice accounting for a particular situation.
