The European Commission on Sept. 30 published non-confidential versions of its decisions to open state aid investigations into private rulings granted to Apple in Ireland and Fiat in Luxembourg. . .
Hong Kong signed tax information exchange agreements with six jurisdictions on August 22: Denmark, the Faroe Islands, Greenland, Iceland, Norway, and Sweden, according to . . .
French tax authorities have opened a consultation on a draft transfer pricing information return which would implement transfer pricing requirements adopted November 2013, writes KPMG in a June 5 report. For details, see KPMG
Russia and Malta have ratified a double tax treaty signed on April 24. For analysis of the treaty, see Boston Trust Company Isle of Man, EMCS,
Starbucks will move its European, Middle East, and African headquarters from Amsterdam to London by the end of 2014, according to a post on the company’s website. The move appears designed to quell public outrage over the Starbucks’ creative tax structures, which were brought into the spotlight last winter, as the U.K. House of Commons Public Accounts Committee investigated why Starbucks, along with Google and Amazon, paid such little tax in the U.K. despite having large sales there. The company states that the move will cause it to pay more tax in the U.K. According to Heather Self, Pinset Masons, however, the move is not likely to make much of a difference in Starbucks’ tax bill.
The European Parliament on December 2 voted to create a new committee to investigate tax rulings, specifying that the new committee will have the . . .
Singapore and Russia have signed a protocol amending to their tax treaty . . .
Guernsey and Spain on November 10 signed an agreement on exchange of information . . .
The European Parliament’s special committee on tax rulings on Monday approved its final report, which will be released to the public sometime . . .
The EU Commission has appointed 34 organizations and 12 individuals . . .
Tax information exchange agreements (TIEAs) between Switzerland and Andorra, Greenland, San Marino, and the Seychelles have been ratified and came into force in July and August, Switzerland’s Federal Department of Finance announced on September 9. All the . . .
OECD tax officials have expressed dissatisfaction with a blacklist of 30 tax havens prepared by the European Commission, as have several countries on the list . . .
Belgium will add Luxembourg to its tax haven blacklist, writes Luxemberger Wort in June 2 article, quoting Belgian media sources. Such a listing would create hassles for Luxembourg and Belgian companies engaged in cross-border business, as all transactions over 100,000 euros must be reported. See, Luxemburger Wort.
The EU Commission may propose a mandatory common consolidated corporate tax base (CCCTB) in its action plan to be released next month, Commission Vice-President for the Euro and Social Dialogue, Valdis Dombrovskis, said May 27. Speaking to reporters after a meeting of the EU College of Commissioners, Dombrovskis confirmed that the CCCTB . . .
The UK on April 20 corrected an errors in its interim guidance on the diverted profits tax. Language was modified in DPT2010 on page 66 concerning the duty to notify and a factual description . . .
The UK on December 23 released a consultation on draft regulations for double taxation relief for groups and entities within the charge to the UK bank levy and the Netherlands bank tax, where the Netherlands is the home state of the entity or group. See, consultation.
Tax authorities from 51 jurisdictions have signed a multilateral competent authority agreement, laying the groundwork for automatic exchange of financial account information under the OECD/G-20 Common Reporting Standard beginning 2017 . . .
The European Commission announced on October 16 that it is referring Belgium to the European Court of Justice for discriminatory taxation of collective investment undertakings
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An agreement for the avoidance of double taxation between Singapore and Liechtenstein, signed June 27, entered into force on July 25. The treaty provides for exchange of tax information on request, and lowers withholding taxes on dividends to zero, on interest to 12 percent, and on royalties to eight percent. Treaty
Steve Labrum has joined KPMG’s Canary Wharf office in London as a financial services transfer pricing partner. Labrum is former Global Head of Transfer Pricing at Alvarez and Marsal. Release
The UK’s HM Revenue and Customs on October 2 released four sets proposed regulations governing taxation of corporate debt and derivative . . .
If the ECJ follows the opinion of the AG in the case, Timac Agro Deutschland, “the possibility to obtain cross-border loss relief would be significantly narrowed in cases where the PE country allows foreign taxpayers to pick up losses incurred by a sold or wound up PE,” EY writes in a September 8 tax alert. See: EY. See, also: Timac Agro Deutschland GmbH v. Finanzamt Sankt Augustin (in German).
Switzerland’s Federal Council on August 26 announced that it will recommend that Parliament reject a move to heighten bank client confidentiality through the “Yes to the protection of privacy” initiative . . .
The UK’s financial secretary to the Treasury, David Gauke, told German MEP Michael Theurer on June 18 that the UK will oppose an EU-wide common consolidated corporate tax base (CCCTB) because the UK prefers tax competition, The Guardian reports. See. The Guardian.
A US district court, in the case of Lehman Brothers Holdings Inc. v. US decided May 8, disallowed a US taxpayer’s claim for a foreign tax credit under the US-UK tax treaty for withholding taxes imposed on substitute dividend payments received by its wholly owned US subsidiary from its UK subsidiary pursuant to back-to-back stock loan transactions, EY writes in a May 19 tax alert. See: EY .
The European Court of Justice in an April 22 ruling, Drukarnia Multipress sp. z o.o. v Minister Finansów, (C‑357/13) has concluded that a Polish partnership limited by shares (‘PLS’) is a capital company within the meaning of Article 2(1)(b) and (c) of Council Directive 2008/7/EC concerning indirect taxes on the raising of capital, even though only . . .
The European Court of Justice on April 16 ruled, in European Commission v. Federal Republic of Germany, that Germany violated freedom of establishment principles through its tax scheme which allows deferral of taxation of the capital gains realized on the sale of a capital asset forming part of the assets of a permanent establishment . . .
The European Commission on February 6 invited interested parties to comment on its state aid investigation into whether an advance pricing agreement (APA) granted by Luxembourg to Amazon that set the price of intra-group royalties. . .
Russian President Vladimir Putin on November 3 signed a law ratifying the Convention on Mutual Administrative Assistance in Tax Matters, Russian news . . .
The Swiss Federal Counsel on October 22 launched a consultation on a proposed law that would . . .
Switzerland and Iceland, on July 10, signed a double taxation agreement which includes exchange of information provisions and an arbitration clause. The agreement replaces a 1988 double tax agreement. Under the new agreement, royalties are subject to no more than 5 percent tax in the source state. The parties agreed to a withholding tax exemption for divided payments from significant holdings of at least 10 percent and for divided payments to pension funds and national banks. The agreement specifies that pension contributions in the other country are deductible. For more details, see press release.
Portugal’s Corporate Income Tax Reform and State Budget Law for 2012 includes a few changes to transfer pricing laws. See, report by KPMG.
The US government is trying to persuade the EU Commission that it is inappropriate to require EU States to recover “retroactive” tax from multinationals upon a finding that illegal State aid was provided through overly-generous private tax rulings, Robert Stack . . .
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