Ireland’s Department of Finance on July 30 published a paper describing current thinking on the design its planned ‘knowledge development box’ legislation, which will offer a special low rate of tax on income from intellectual property. The release . . .
The UK government on July 15 published the Summer Finance Bill 2015 to tax implement tax changes announced in last week’s budget and earlier proposals. The bill implements a proposed . . .
The European Commission on July 13 released a study exploring policy options designed to make the EU VAT system fairer to business engaged in cross-border trade. The EC-commissioned study, prepared by EY, finds t . . .
The European Commission on June 17 said it is readying a proposal for an EU-wide common consolidated corporate tax base (CCCTB) that would be mandatory for multinationals. The Commission also announced plans to publish guidance on intellectual property regimes and transfer pricing; launched a public consultation on whether companies should be required to make . . .
The UK’s HM Revenue and Customs on March 26 confirmed that it has joined with tax authorities of five other nations to share information about how digital multinationals might be shifting profits to tax havens. HMRC said that information gleaned from the collaboration will assist in applying the new UK diverted profits . . .
A coalition of European and American trade unions, joined by the anti-poverty campaign group War on Want, released a report February 24 claiming that McDonald’s avoided over €1 billion (USD 1.1 billion) in European corporate taxes from 2009-2013 by shifting income from its European franchises to a Luxembourg subsidiary through use of royalty payments.The group said that McDonald’s restructured . . .
European Parliament leaders on February 5 failed to endorse the establishment of a committee of inquiry to investigate EU states’ private tax ruling practices, announcing instead that a vote will be taken in the next full house to set up a more limited special committee to handle the . . .
The European Commission will challenge Spanish laws governing the taxation of dividends distributed by a non-resident companies to Spanish companies in the European Court of Justice, the Commission announced November 26. The Commission said that Spain . . .
The requirements for the entry into force of the protocol between Japan and Sweden, signed December 5, 2013, were met on Sept. 16 and the treaty will enter into force on October 12, Japan’s Ministry of Finance has announced.
The protocol sets a zero rate of withholding on interest and royalties. The withholding rate for dividends is zero for corporate shareholders that hold at least 10 percent voting power, and is 10 percent in other cases.
The protocol also adds measures to prevent abuse of the treaty, introduces an arbitration proceeding to the mutual agreement procedure, and expands exchange of information. Release, Protocol (66KB).
The OECD’s Committee on Fiscal Affairs has approved recommendations for base erosion and profit shifting (BEPS) action plan items due to be presented to G20 finance ministers in September, according to a July 3 press release issued by the New Zealand government. Release
Switzerland and Uzbekistan, on July 1, signed a protocol to amend their double taxation agreement. The protocol brings the administrative assistance clause into line with the applicable international standard for the exchange of information upon request. The protocol must be ratified by both countries before it can enter into force. Release
A report, released by the European Commission on May 28, concludes that a special tax regime should not be adopted for the digital economy, rather modification of current VAT, corporate tax, and transfer pricing rules are needed to respond to the digitization of the economy.
The report, drafted by group of seven independent tax experts led by Victor Gaspar, Special Advisor to the Banco de Portugal, responds to
. . .
The Swiss government is working with business groups to craft rules to replace its cantonal corporate tax system, writes SWI swissinfo.ch, the international service of the Swiss Broadcasting Corporation, in a August 20 article. See: SWI swissinfo.ch
China has signed a tax treaty with Chile and a protocol to its tax treaty with Russia, China’s State Administration of Taxation said in July 3 English-language releases. The treaty with Chile, signed May 25, is is the 100th treaty signed by China, the government . . .
G7 finance ministers and central bank governors agreed at a meeting in Dresden held May 27–29 that the mechanisms used to settle tax disputes between nations need to be improved, German Finance Minister Wolfgang Schaeuble said. Schaeuble told a press conference following . . .
The European Parliament’s Legal Affairs committee, on May 7, backed a draft law that would require large firms and public-interest entities to publicly report information on a country by country basis, with a goal of strengthening transparency of tax strategies . . .
Mauritius was removed from Italy’s tax blacklist with the entry into force of the Italian Stability Law 2015, the Mauritius government announced April 15. The development follows efforts undertaken by Mauritius . . .
The European Commission on February 18 announced that it will present a tax transparency package in March which will include a legislative proposal for the automatic exchange of information on tax . . .
Switzerland and Liechtenstein have agreed to the terms of a revised double tax treaty and expect to sign the agreement this summer, Switzerland’s Federal Department of Finance (FDF) announced on February 5. The agreement, which would replace . . .
The UK on January 13 released an updated schema and supporting documents for software developers working on the FATCA service . . .
The European Commission on November 14 published its preliminary opinion that an advance pricing agreement (APA) granted by the Netherlands to a Starbucks subsidiary constitutes illegal state aid. The inquiry, first announced in June, is one of four state aid investigations recently initiated by the Commission clamping down on EU states that grant sweetheart deals to . . .
New German regulations on allocation of profit between head office and permanent establishments were published in the Federal Law Gazette on October 17, 2014, and are now applicable to tax years beginning after December 31, reports PwC. The regulations provide detailed rules on the application of the Authorized OECD Approach (AOA), which became effective in Germany in 2013. For analysis of the new regulations, see PwC.
The European Commission will publish this week the formal letter the Commission sent to Ireland in June setting out its preliminary view that Ireland violated state aid in granting private tax rulings to Apple . . .
Switzerland’s Federal Counsel. on April 30, announced that the government will prepare a consultation draft on corporate tax reform. The consultation will be based on a government report released December 2013 and will last until September 2014 . See, Press Release.
The European Commission on September 28 published its annual overview of recent tax reforms . . .
Tax justice campaigner Richard Murphy has been appointed Professor of Practice in International Political Economy at City University London. Murphy will be teaching a course titled Economics in the Real World. See: Tax Research UK.
Bermuda is seeking immediate removal the European Commission’s list of non-cooperative jurisdictions as both Latvia and Poland have now confirmed that they have taken Bermuda off their national tax blacklists. Poland and Latvia have contacted the European Commission to confirm Bermuda’s. . .
The Netherlands Supreme Court on June 5 upheld a lower court decision denying an interest deduction to a Dutch holding company for interest paid to a related Mauritius company under the Dutch base erosion rules because the company did not establish sufficient business reasons for the debt, writes Loyens & Loeff in a June 8 tax alert.
The Isle of Man was dropped from Italy’s tax blacklist regarding deductibility of costs as of April 1, the Isle of Man government announced on April 17. The change was made on account of a new Italian law which provides that jurisdictions that have exchange of information arrangements . . .
Mauritius and Austria have signed a tax information exchange agreement (TIEA) according to a release posted on a Mauritius government website March 13. The agreement was . . .
Liechtenstein and United Arab Emirates have initialed a tax treaty, Liechtenstein’s Ministry for General Government Affairs announced March 4. The treaty largely follows the OECD Model Convention and provides for cooperation on tax matters between the tax authorities. The agreement also clarifies the tax treatment of asset structures . . .
France’s 2015 Finance Act and the Rectificative Finance Act for 2014 have entered into force, reports CMS Bureau Francis Lefebvre in a January 9 tax alert. Among the new tax law changes is a broadening of the scope of tax consolidation to include . . .
Fearghus Carruthers, head of tax at Shire Pharmaceuticals, has been added to the list of witnesses scheduled to testify at a December 8 UK House of Commons Public Accounts Committee hearing on the role of large accounting firms in multinational tax avoidance. Carruthers will join . . .
The Belgian government entered into a coalition agreement October 9, agreeing to limit the notional interest deduction regime for financial institutions and insurance companies and to modify the stock exchange tax, among other tax measures, writes Alain Huyghe, Philippe Lion, Luc Meeus, and Géry Bombeke of Baker & McKenzie in an October 10 report. For details, see Baker & McKenzie.
The Isle of Man has been removed from Republic of Colombia’s blacklist as of October 7 pursuant to Decree 1966/2014, according. . .
Citing OECD pressure to reform its tax system, Switzerland is considering abolishing existing tax arrangements that no longer meet international tax standards, primarily the cantonal tax statuses for holding, domiciliary, and mixed companies. New rules would be added, however, to enhance the country’s “appeal as a tax location,” including a royalty box and. . .
The Slovak Ministry of Finance on August 20 released new guidance specifying minimum transfer pricing documentation requirements, writes EY in a Sept. 16 Global Tax Alert. For discussion, see EY.
Switzerland and Estonia, on August 25, signed a protocol to amend their double taxation agreement.
Under the agreement, interest and royalty payments are exempt from withholding tax. Dividends are also exempt from withholding tax if the company receiving the dividend holds a stake of at least 10 percent in the capital of the distributing company for at least one year. In other cases, the withholding tax rate for dividend distributions is 10 percent.
The agreement also provides for the exchange of information upon request in accordance with the currently applicable international standard.
The agreement must be approved by parliament in both countries before it can come into force. Release
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