Americas
US and Latvia sign Model 1 FATCA IGA
US Treasury Department has updated its FATCA website, reporting that Latvia has signed a Model 1 intergovernmental agreement (IGA) with the United States as of June 27. Agreement
Europe
Asia-Pacific
Germany and China sign tax treaty and protocol
China and Germany signed a new income tax treaty and protocol on March 28, according to a report by EY.
Europe
UK changes guidance on Dutch and Spanish VAT grouping rules under the ECJ’s Skandia ruling
The UK’s HMRC, in Customs Brief 23 issued December 11, updated its view of how UK businesses must account for VAT on intragroup supplies of services to branches that are part of VAT groups located in the Netherlands or Spain, following the European Court of Justice’s ruling in Skandia America . . .
Europe
UK publishes draft clauses for Finance Bill 2016 on hybrid mismatches, patent box, corporate transparency
The UK government on December 9 issued draft legislation for Finance Bill 2016, including measures addressing hybrid mismatch arrangements and the UK patent box, and introducing new transparency requirements for large corporations and partnerships. The government . . .
Europe
Europe
EU Court of Justice rejects French tax regime that gives greater dividend deductions to French groups
The European Court of Justice, in Groupe Steria SCA, has ruled that EU freedom of establishment principles are infringed by French laws that give only domestic companies the opportunity to join a French group and take advantage of a special tax integration regime . . .
Europe
TASS: Russia will not increase tax burden on business for 4 years says Putin
Russia will not increase tax rates or the fiscal burden on business for four years, said Russian President Vladimir Putin according to a June 19 report in TASS. Putin also said Russia will take steps to increase the transparency . . .
Americas
Irish Revenue outlines FATCA treatment of holding companies and treasury companies
Irish Revenue on June 17 released guidance on the treatment of holding companies and treasury companies for purposes of FATCA reporting, in light of updated US IRS guidance . . .
Americas
Text available of TIEA between Ireland and the Bahamas
Irish Tax and Customs on May 1 released the text of a tax information exchange agreement signed by Ireland and the Bahamas. The agreement . . .
Europe
Europe
EU Commission seeking new members for transfer pricing advisory group
The European Commission, in January 26 announcements, has requested applications from transfer pricing specialists to serve on the EU Joint Transfer Pricing Forum (JTPF). The. . .
Europe
Italy’s Parliament weighing new patent box regime
A bill introducing a patent box regime in Italy consistent with the OECD’s nexus approach was submitted to the Italian Parliament in October, writes PwC in a December 2 article. PwC notes that to be eligible for tax benefits under the bill, most taxpayers would need to enter into an advance pricing agreement with revenue authorities. For a detailed discussion of the new provisions, see PwC. See also, DLA Piper, Società Italiana Brevetti
Europe
EU court approves Spain’s tax deductions for foreign company acquisitions, annuls Commission decisions
The General Court of the European Union on October 7 ruled that a Spanish tax incentive which allows for amortization of goodwill in foreign company share acquisitions is not incompatible with EU state aid rules. As such, the Court annulled 2009 and 20011 European Commission decisions . . .
Americas
OECD official discusses “double Irish” and US reaction to BEPS with The Irish Independent
Pascal Saint-Amans, the director of the OECD Centre for Tax Policy and Administration, addressed Ireland’s recent tax announcements and his views on whether the US will implement or block the OECD/G-20 base erosion profit shifting measures during an interview with the Irish Independent. See, Irish Independent.
Europe
Switzerland and EU sign agreement on Swiss taxation of foreign revenue
Switzerland’s Federal Council and the EU member states on October 14 signed a joint statement on business taxation whereby the Federal Council reaffirmed its intention to propose abolishing tax regimes . . .
Europe
UK government pledges to combat tech company tax avoidance
The UK government intends to end tax avoidance schemes used by technology companies, Chancellor of the Exchequer George Osborne said Sept. 29, reportedly referring to plans to target double Irish tax avoidance strategies.
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Isle of Man
Isle of Man-Luxembourg tax treaty enters into force
The Isle of Man has announced that its Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital with Luxembourg, signed April 8, 2013, entered into force on August 5. Press release, treaty text.
Denmark
Ireland and Denmark sign protocol, text available
Ireland and Denmark, on July 22, signed a protocol to their 1993 tax treaty which would change the method of eliminating double taxation with respect to salaries, wages and similar remuneration. Protocol (PDF, 43KB), Treaty
Europe
European Commission paper examines bank taxation
The European Commission, on July 18, released “Taxation paper No 43: Financial Activities Taxes, Bank Levies and Systemic Risk,” written by Giuseppina Cannas, Jessica Cariboni, Massimo Marchesi, Gaëtan Nicodème, Marco Petracco Giudici, and Stefano Zedda. For the text, see Taxation paper.
Americas
Ireland releases guidance on FATCA compliance
Ireland’s Revenue Commissioners, on June 30, released guidance on compliance by Irish entities with their obligations under U.S. FATCA provisions. See, Financial Accounts Reporting (United States of America) regulations 2014 (PDF, 179KB).
Americas
Russian law permits banks to send information to US to meet FATCA requirements
A Russian law, signed June 30, gives financial institutions the right to pass information about U.S. taxpayers to the IRS to satisfy FATCA requirements, but only after first sending the information to Russian authorities and only if the taxpayer gives permission for the information transfer, reports Delphine d’Amora of The Moscow Times.
Asia-Pacific
EU Commission threatens to sue Netherlands over tax treaty with Japan
The European Commission on October 19 asked the Netherlands to amend the limitation on benefits clause in its tax treaty with . . .
Europe
Isle of Man and Romania sign tax information exchange agreement
The Isle of Man and Romania on November 4 signed a tax information exchange . . .
Asia-Pacific
Australia and Germany to commence tax treaty negotiations
Australia and Germany will soon begin negotiations to update their 1972 tax treaty, Australian Treasury announced June 16. The Australian government has requested stakeholder . . .
Europe
German exit tax on asset transfer to foreign permanent establishment compatible with EU law, says ECJ
The European Court of Justice on May 21 ruled that freedom of establishment principles do not prevent Germany from imposing tax on the unrealized gain inherent in a German partnership’s assets upon the transfer of the assets to the taxpayer’s foreign permanent establishment. The German law provides . . .
Europe
Spain approves additional Canary Island tax incentives
Spain has approved a more generous special tax regime for companies operating in the Canary Islands which includes an extension of the 4 percent corporate income tax rate to all of a company’s taxable income if conditions are met, writes PwC in an April 29 tax alert. See, PwC.
Europe
UK to modify proposed diverted profits tax notification rule, exclusion for loans
The UK government is working on modifications to the proposed diverted profits tax rules that would limit the notification requirements and broaden the exclusion for loan relationships, Mike Williams, Director, Business and International Tax, HM Treasury said January 13. The proposed 25 percent tax on diverted profits, announced in. . .
Asia-Pacific
Singapore and France sign tax treaty providing for reduced dividend withholding tax
Singapore and France have signed a revised tax treaty, Singapore’s the Ministry of Finance and France’s Ministry for Finance and Public Accounts said in a joint statement January 16. The agreement lowers . . .
Europe
Niall Cody to chair of Irish Revenue Commissioners
Niall Cody has been appointed as the new Chairman of the Irish Revenue Commissioners, Minister for Finance, Michael Noonan announced on December 16. Cody will begin work February 1, 2015. See, release.
Europe
EU Commission adopts JTPF transfer pricing guidelines, continues work on documentation and arbitration issues
The European Commission, on June 4, endorsed guidelines on secondary adjustments, transfer pricing risk management, and compensating adjustments contained
. . .
Europe
Russia’s customs increases for cross-border online sales will be minor
Despite heavy lobbying by domestic retailers, Russia will only enact minor increases to customs taxes for online cross-border sales, reports Adrien Henni, in the June 2 edition of East-West Digital News.
Europe
Government paper concludes that Irish corporate tax rate is almost 11 percent
Ireland’s Department of Finance has released a technical paper which considers eight approaches to determining the effective tax rate on company profits in Ireland. The paper concludes that the best methods were provided by the Central Statistics Office of Ireland, which determined that average tax rates in Ireland since 2003 were 10.9 percent, and Ireland’s Revenue Commissioners, which pegged the rate at 10.7 percent.
Andorra
EU and Andorra agree to automatic exchange of tax information
Andorra and the EU on October 4 agreed to automatically exchange information on the financial accounts of each . . .
European Commission
Cyprus
Cyprus-Switzerland tax treaty enters into force
A new tax treaty between Cyprus and Switzerland entered into force as of October 15, Cyprus’s Ministry of Finance announced November 2. The treaty, . . .
Europe
EU solicits businesses’ views on cross-border VAT reform for online transactions
The European Commission on September 25 launched a public consultation seeking stakeholder input on reform of the EU’s VAT system relating to . . .
Americas
G7 leaders agree to arbitration for double tax disputes, say OECD should monitor BEPS implementation
G7 leaders, in a joint declaration issued June 8, made a “commitment to establish binding mandatory arbitration to ensure that the risk of double taxation does not act as a barrier to cross-border trade and investment.” The leaders also said they support work being done on binding arbitration as part of the OECD/G20 base erosion profit shifting (BEPS) project, and encouraged others . . .
UPDATE (6/9/2015): Christian Aid sounds alarm over G7 plan for mandatory tax arbitration: Christian Aid, on June 9, called the G7 leaders’ expression of support for compulsory binding arbitration in multinational tax disputes “deeply troubling,” stating . . .
Americas
UK details treatment of holding and treasury companies for automatic exchange of financial account information
The UK’s HM Revenue and Customs on May 21 issued guidance on the treatment of holding companies and treasury companies under FATCA, the multilateral competent authority agreement implementing the common reporting standard, and the . . .
Europe
Ireland releases guidance on taxation of exchange traded funds
Irish Tax and Customs, on April 16th, released guidance on the tax treatment of investments in exchange traded funds. According to a government . . .
