The US Treasury Department has updated its FATCA website, reporting that Iceland has signed a Model 1 intergovernmental agreement (IGA) with the US as of May 25 and that Romania has signed a Model 1 IGA with the US as of May 28. The text of the agreements are available. See, FATCA IGA with Romania, FATCA IGA with Iceland.
The UK on May 26 updated the schema and supporting documents for Foreign Account Tax Compliance Act (FATCA) software . . .
The Swedish government, on April 22, proposed legislative amendments that would disallow a tax exemption for dividends paid to a Swedish company that can be deducted as interest by the distributing company and that would strengthen antiabuse rules pertaining to withholding taxes, writes EY in an April 24 Global Tax Alert. See, EY.
Liechtenstein Prime Minister Adrian Hasler and Italian Finance Minister Pier Carlo Padoan on February 26 signed a tax information exchange agreement (TIEA) based on the OECD model and a protocol and joint declaration on future cooperation in tax matters. The TIEA provides for exchange of information relating . . .
The European Court of Justice on February 3 ruled that a UK law that puts restrictions on the ability of group companies to offset gains with nonresident subsidiary losses is compatible with EU law, rejecting the European Commission’s claim that the law made it “virtually impossible” . . .
The Switzerland and Italy have reached an agreement in principle to sign a protocol to their double tax treaty to make provision for the OECD standard for the exchange of tax information upon request, the Swiss government announced January 16. The countries have also initialed a roadmap . . .
The European Court of Justice on November 13 ruled that UK legislation that immediately attributes gains made by non-resident closely held companies to participators of the companies that are UK residents is a restriction on the free movement of capital as defined . . .
Switzerland’s Federal Council on October 8 released final negotiation mandates for introducing automatic exchange of information in tax matters with the EU, the United States, and other countries . . .
Ewelina Stamblewska-Urbaniak has joined Crido Taxand as head of the firm’s transfer pricing practice based in Warsaw, Poland. release
Macedonia will soon release draft legislation that will create a financial zone and tax breaks to companies that locate their headquarters there, said Prime Minister Nikola Gruevski, according to a July 18 article by Sinisa Jakov Marusic of BalkanInsight. For details, see BalkanInsight.
The Council of the European Union, on July 8, formally adopted an amendment to the parent-subsidiary directive to prevent multinational groups from achieving double non-taxation from hybrid loan arrangements. A political agreement on the matter was reached on June 20. States have until December 31, 2015, to add the amendment to their laws. Press release; Amendment to Council Directive: 10996/14, 11291/14, 11291/14 ADD1; Prior coverage
French Finance Minister Michel Sapin and Swiss Finance Minister Eveline Widmer-Schlumpf, on June . . .
The VAT Expert Group, charged with assisting and advising the European Commission
The European Commission, in a June 5 announcement, has requested applications from value added tax (VAT) specialists to serve on the Commission’s VAT Expert Group . . .
Ireland resolved 9 mutual agreement procedure (MAP) cases with other nations in 2014, leaving inventory of 22 unresolved MAP cases by the end of that year, Irish Revenue said in a report, released on November 9. The report . . .
The US Treasury Department has updated its FATCA website, reporting that Portugal has signed a Model 1 intergovernmental agreement (IGA) with the United States . . .
The European Court of Justice on July 17 ruled that active holding companies may recover VAT on share acquisition costs and that German courts should determine the appropriateness of a German law that does not allow partnerships to be included in VAT groups . . .
UK clothing retailer Next owes additional £22.4m tax after a First-Tier Tribunal ruled the firm’s tax avoidance structure known as a rate-booster was artificial tax avoidance, the UK’ s . . .
The UK gained £1,137 (USD 1.7 billion) by successfully challenging multinational transfer pricing in fiscal year 2013–14, according to statistics released by HM Revenue and Customs on March 6. The goverment collected twice as much tax from transfer pricing . . .
Tax officials from 21 Asia Pacific countries and organizations attended an OECD regional network meeting on base erosion and profit shifting (BEPS) designed to give more nations a voice in the development of OECD/G20 base erosion profiting shifting (BEPS) plan output. The meeting, held February 12–13 in Seoul, also . . .
The UK government will introduce a new “diverted profits tax” to ensure that multinational corporations pay the correct about of tax, British Chancellor of the Exchequer, George Osborne, announced December 3 in his Autumn Statement. The UK also released a consultation on hybrid mismatches, and Osborne reaffirmed the UK’s intention to introduce country-by-country reporting for . . .
Advancing the common consolidated corporate tax base (CCCTB) proposal in Europe is a “high priority,” for new Commissioner for Economic Affairs, Pierre Moscovici. The CCCTB would shut off major channels of tax avoidance, ensuring a closer . . .
The Swiss Federal Council on Sept. 19 initiated a consultation on rules that would extend the flat-rate credit to permanent establishments in Switzerland that are domiciled in a country that has a direct tax agreement (DTA) with Switzerland. . .
The Polish government on Sept 10 released draft general antiavoidance legislation as well as procedures for obtaining advance tax rulings to confirm that intended transactions do not qualify as abusive, write Karina Furga-Dąbrowska and Rafał Mikulski of Dentons in a Sept. 15 post. For a detailed discussion of the tax proposal, see Dentons.
The Czech Tax Administration has announced new reporting obligations applicable to companies that engage in transactions with related parties located in foreign countries, reports PwC in an August 11 newsletter. For details, see PwC.
The U.K. and Tajikistan signed a double tax treaty on July 1 which generally follows the OECD model tax treaty. The agreement provides for reduced withholding tax rates dividends, interest, and royalties and also includes an exchange of information article and an arbitration provision. For the text, see UK/Tajikistan Double Taxation Agreement (PDF 82K)
Russia’s Ministry of Finance, on March 18, published a bill introducing controlled foreign company (“CFC”) rules to the Russian tax laws. The bill also deems a foreign company as a Russian tax resident when the company’s management is in Russia and taxes sales of shares in an entity where the entity’s assets consist of indirectly owned Russian real property. For analysis, see CMS Bureau Francis Lefebvre, Laggan & Associates Ltd, Debevoise & Plimpton LLP, EY
HM Treasury and HM Revenue and Customs have released a position paper outlining the UK’s priorities for the ongoing work with G20 and OECD taking forward the 15 point Action Plan to counter Base Erosion and Profit Shifting.
The paper includes proposals for new international rules to address cross-border business structures or finance transactions, a disclosure scheme for international tax schemes, and the creation of a single Large Business Directorate within HMRC.
The UAE and Denmark on November 3 signed a tax information exchange agreement (TIEA) in Denmark during a UAE delegation tour of Scandinavian . . .
The UK government on September 18 released a guide on automatic exchange of financial account information which focuses on the requirements of the OECD Common Reporting Standard (CRS) and . . .
The UK’s conservative party on July 8 unveiled its first budget of new the new term, proposing to reduce the 20 percent UK corporate income tax rate to 19 percent beginning April 2017 and to 18 percent . . .
The Netherlands on June 22 announced it has renegotiated tax treaties with Ethiopia, Ghana, Kenya, and Zambia to add antiabuse provisions to the treaties, and said that it hopes to add antiabuse clauses to tax treaties with 23 developing nations. Moreover, talks . . .
The UK on May 28 released a tax information and impact note on UK regulations issued March 11 that amend the worldwide debt cap. the regulations prevent changes to accounting standards from disallowing certain financing costs for investment entities. See, Corporation tax: changes to the worldwide debt cap (WWDC) provisions.
The magnitude of profit shifting by American companies “may be significant,” a US Congressional Research Service (CRS) report has concluded. The report, released April 30, found that about 50 percent of the $1.2 trillion in overseas profit reported by American . . .
Guernsey’s Director on Income Tax on April 8 issued guidance on when companies incorporated overseas are deemed to be a resident of Guernsey because they are controlled there. Guidance was also released on the filing obligations of such companies. The guidance provides that, generally, companies incorporated overseas but . . .
Luxembourg will provide the European Commission with a list of taxpayers that received private tax rulings in 2010–2012 involving cross-border dealings, as well as a list of the beneficiaries of its intellectual property regime, Prime Minister Xavier Bettel said December 18 . . .
Luxembourg’s draft budget 2015, presented to Parliament on October 15, includes provisions that formalize and charge a fee for advance tax rulings, that modify transfer pricing provisions to make an explicit reference to the arm’s length standard, and that extend documentation requirements to related party transactions, writes KPMG’s member firm in Luxembourg. For details, see KPMG.
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