Japan and the UK have exchanged notes on a new article on business profits under the Japan-UK tax treaty, the Japanese government announced July 22. New Article 7 introduces provisions concerning . . .
All EU states support the main objectives of the EU Commission proposal for mandatory automatic exchange of information on tax rulings, according to a report of the outcome of a June 19 ECOFIN meeting in Luxembourg. At the meeting, EU finance ministers also . . .
Multinationals asked to testify about their private tax ruling practices before the European Parliament’s Special Committee on tax Rulings on June 13 have mostly declined the invitation. According to . . .
The OECD/G20 base erosion profit shifting (BEPS) project work should not be used to adopt protectionist measures, Josephine Teo, Singapore Minister of State for Finance and Transport . . .
A consultation has revealed widespread support for a corporate tax reform plan, proposed last fall, to abolish the cantonal tax statuses for holding, domiciliary, and mixed companies, and to introduce a royalty box, Switzerland’s Federal Council said in an April 2 release. Some modifications to the reform proposals will be . . .
The British Virgin Islands International Tax Authority on March 20 released guidance notes designed to provide practical assistance entities and their directors, officers, and advisers in complying with obligations under FATCA. See, FATCA Guidance, Version 2.0
Tax officials that attended an OECD Eurasia regional meeting on base erosion and profit shifting (BEPS) welcomed the OECD’s effort to involve developing nations in the BEPS project, but said that barriers prevent nations in the region from participating, according to a report released March 10. These barriers were apparent as representatives of only six nations attended the regional meeting, held in Ankara, Turkey, on March 5-6.. . .
US Senator Marco Rubio (R., Fla.), a likely 2016 Republican presidential candidate, and Senator Mike Lee (R., Utah) on March 4 released a tax plan that includes a proposal to adopt a territorial tax system. The Rubio-Lee plan would also . . .
Diana L. Wollman, former IRS director of international strategy in the Large Business and International Division, will join Cleary Gottlieb’s tax practice in New York as a partner where she will focus on tax controversy . . .
The UK and Senegal signed a tax treaty on February 26, the UK’s HM Revenue and Customs has announced. Under the agreement, taxation in the source country on dividends is 5 percent for corporate shareholders that hold at least a 25 percent interest in the company paying the dividends, is 8 percent if the beneficial owner is a pension scheme established in source country, and is 10 percent in other . . .
The UK and Algeria signed a tax treaty on February 18 which provides for maximum rates of withholding tax for interest and royalty payments of 7 percent and 10 percent respectively, UK’s HM Revenue and Customs has announced. The treaty also provides for withholding taxes for dividends of 5 percent . . .
The UK’s HMRC on January 30 published a consultation paper entitled “Strengthening Sanctions for Tax Avoidance,” setting out proposals to address the serial use of tax avoidance schemes and proposing to introduce additional penalties . . .
The UK government on January 8 published a bill that would give Northern Ireland the power to set its own corporation tax rate beginning April 2017. If the bill is passed, it is expected that Northern Ireland will lower its . . .
The Canadian government on January 7 announced that launch of the Canada Revenue Agency’s (CRA) Electronic Funds Transfer (EFT) initiative, which effective January 1, requires financial intermediaries, including banks, to report to the CRA incoming and outgoing international EFTs of $10,000 or more. The. . .
The Isle of Man on December 15 published revised Guidance Notes relating to intergovernmental agreements to improve international tax compliance signed in 2013 with the UK and US. Release.
Materials that accompany a UK draft law suggest that OECD/G20 base erosion profit shifting (BEPS) guidance will recommend that country-by-country reporting data be disseminated using a tax treaty mechanism, vastly limiting the scope of the reform, tax campaigners say . . .
“China will comprehensively monitor the profit levels of foreign companies to make sure there is no base erosion and profit shifting,” Zhang Zhiyong, deputy director of the State Administration of Taxation (SAT) said December 1, the government’s news agency, Xinhua, has reported. Zhang also said that China intends to . . .
The OECD on November 25 released 2013 statistics on the mutual agreement procedure (MAP) caseload of OECD member counties and partner economies of Argentina, China, Latvia, and South Africa. According to an accompanying OECD . . .
A protocol and exchange of notes between the UK and Japan, signed December 17, 2013, will enter into force on December 12, the UK government announced November 12.The protocol . . .
The US IRS on October 27 released new questions and answers on the FATCA International Data Exchange Services (IDES) system on its website and listed approved certificate authorities.
The new Q&As are as . . .
The Slovak Ministry of Finance has modified is rules on transfer pricing documentation, writes Zuzana Blažejová of KPMG in an October 22 report. For discussion of the new provisions, see KPMG.
The UK on Sept. 30 issued guidance explaining the conditions that must be met for holding companies to recover VAT. The guidance describes . . .
The US Treasury Department has updated its FATCA website, reporting that Brazil has signed a Model 1 intergovernmental agreement (IGA) with the United States as of Sept. 23. Agreement
A European Court of Justice (ECJ) judgment, released Sept. 17, will result in large VAT bills for banks, insurers, and other businesses considered VAT-exempt.
The decision, Skandia America Corp. v. Sweden, concludes that supplies of services from a non-EU company to its EU branch are subject to VAT when the branch belongs to a VAT group. Previously, provision of these services . . .
Update: For UK government’s October 14 reaction to Skandia, see HM
Revenue and Customs Brief 37 (2014) – VAT grouping rules
The European Court of Justice, in Kronos International Inc. released Sept 11, has ruled that a US registered company resident in Germany may assert that German tax rules violate free movement of capital, but the company may not claim freedom of establishment rights. The ECJ went on to reject the company’s contention that Germany’s tax rules in effect at the time, which permitted a set off for . . .
Kirill Roubalsky has joined the Moscow office of Dentons as a senior associate in the Tax and Customs practice. Roubalsky, fomerly with Pepeliaev Group, Schekin & Partners and Muranov, Chernyakov & Partners, specializes in tax litigation, general corporate and international tax law and tansfer pricing issues. Release
Hein & Associates LLP, on August 12, announced that Stephen T. Williams will be joining the firm’s Denver office as National Director of International Tax Services. Williams is formerly with PwC, Calgary. Release
The government of Gibraltar, on July 24, opened a consultation on a proposal to establish a registry of the ultimate beneficial owners of Gibraltar companies. Input is requested on topics such as whether the registry should made available publicly or only to select users, and what type of information, beyond names and addresses, should be required. Submissions are due September 30. Consultation Paper (PDF 386KB)
The European Commission, on June 11, announced that it is investigating whether individual transfer pricing rulings granted to Apple in Ireland, Starbucks in the Netherlands, and Fiat in Luxembourg sanctioned the allocation of too little profit to activities in those countries, thereby amounting to illegal state aid. The Commission has also initiated an infringement action against Luxembourg in connection with the matter.
The decision is part of a wider investigation into whether tax rulings and
. . .
-Update: The Luxembourg Finance Ministry, in a June 12 statement, said it would continue to defend against the Commission’s charges of illegal state aid, and said it still has doubts about the legality Commission requests for information, see statement.
Finance ministers from the UK, France, Germany, Italy and Spain, on 28 April, agreed to sign new global standards of automatic exchange of tax information at the October Global Forum meeting in Berlin. The countries will begin to automatically exchange information in 2017, with respect to data collected from 31 December 31, 2015. UK Press Release, German Press Release, French Press Release
The OECD BEPS project is not delivering promised international tax reform, and the result may be a breakdown of tax cooperation as countries abandon the project and take matters into their own hands, warns Richard Murphy, in an April 22 blog post.
Singapore and Sri Lanka signed a revised income tax treaty on April 3. Among other changes, the treaty lowers withholding tax rates for dividends and royalties and modifies provisions for determining permanent establishments. The treaty will enter into force after ratification by both countries. Treaty
The Netherlands announced November 27 that it will appeal the EU Commission’s October 21 ruling that an advance pricing agreement (APA) granted by the Netherlands to a Starbucks subsidiary amounted to illegal State aid because it sanctioned the allocation of too little taxable profit . . .
For a WSJ interview of House Ways and Means Chairman Kevin Brady, see: The Wall Street Journal.
For discussion of the October 15 decision, 9 Afs 57/2015 – 120, see, EY.
The US Treasury Department has updated its FATCA website, reporting that Montserrat has signed a Model 1 intergovernmental . . .
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