Automatic exchange of tax information between G5 and partners will begin in 2017
The finance ministers of the five largest economies of Europe committed last year to arrange for the automatic exchange of tax information between them. The ministers have now confirmed that the implementation of this project is to commence from
See MoreUS: Notice 2014-32 announces amendments to recently finalized Section 367(b) regulations applying to certain cross-border triangular reorganizations
The US Treasury Department and US Internal Revenue Service have issued Notice 2014-32 revising the final regulations on certain cross-border triangular reorganizations. The Notice applies where the reorganization involves one or more foreign
See MoreSweden – Intergovernmental agreement under FATCA
The US and Sweden have reached substantial agreement on the content of an intergovernmental agreement (IGA) in relation to the US FATCA regulations. The aim of such agreements is to allow the relevant information required by FATCA to be exchange
See MoreMexico – VAT certification by maquiladoras
The maquiladora regime provides some favorable tax provisions but caution is needed with administrative procedures in respect of VAT. As a result of changes introduced in the 2014 tax reform maquiladoras must take certain actions to ensure they are
See MoreFrance and Germany- Businesses Warn Against EU FTT
Representatives of businesses throughout France and Germany have expressed their strong reservations about the planned financial transactions tax (FTT) currently under discussion among some member countries of the European Union (EU). Medef, BDI and
See MoreUS and Hong Kong- tax information exchange agreement (TIEA)
On April 25 2014 Hong Kong gazetted the tax information exchange agreement (TIEA) with the United States. The agreement will take effect after the relevant legislative procedures have been completed. The OECD has been encouraging the conclusion of
See MoreFrance: Unveils Medium Term Tax Strategy
France’s medium-term economic plan, included in the 2014-2017 Stability Program, involves measures that will help France to reach its public deficit target of 3 percent of gross domestic product (GDP) in 2015. Among the tax measures in the plan is
See MoreEU – UK challenge to financial transaction tax rejected
The Court of Justice of the European Union (CJEU) has rejected a legal action by the UK challenging the legality of the EU Council’s decision to authorize the plan for a financial transaction tax (FTT) through the mechanism of enhanced cooperation
See MoreSingapore – GST rules affecting funds management industry
The Inland Revenue Authority of Singapore (IRAS) and the Monetary Authority of Singapore have finalized a set of rules relating to the impact of the goods and services tax (GST) on the funds management industry. Rules are laid down to establish the
See MoreSingapore – Finding of tax avoidance arrangement upheld on appeal
In Singapore a decision of the High Court on a tax avoidance arrangement has been upheld by the Court of Appeal. Although the taxpayer had made an arrangement to avoid tax the Court found that the Comptroller had acted beyond the powers bestowed by
See MoreMexico – Transfer pricing implications of pro-rata expense decision
A recent decision from Mexico’s Supreme Court of Justice declared a provision of the tax law to be unconstitutional. The provision related to pro-rata expenses incurred abroad relating to natural or legal persons that are not Mexican taxpayers.
See MoreLuxembourg: Adopts 2014 Budget
Luxembourg’s 2014 Budget has been adopted by the Chamber of Deputies. The debate in parliament was concerned with the Luxembourg Government’s intention to raise taxes with effect from 2015. The government also intends to increase three of the
See MoreItaly: Small businesses consider tax cut to be insufficient
In Italy the association representing small and medium-sized enterprises, has suggested that the government’s plan to reduce the regional tax on production activities (IRAP) by 10 percent will only bring a very small measure of assistance to
See MoreTurkey: threatens 38% VAT on Twitter ads
Turkey’s Finance Ministry suggests that VAT on domestic advertising should be doubled from 18% to 36%. This would recover some local tax revenues from non-resident social networking sites that otherwise pay little tax in the country. Other
See MoreSingaporean DTA with Barbados in Force
The double taxation agreement (DTA) concluded between Singapore and Barbados came into force on April 25, 2014. The agreement which was originally signed in July 2013 provides for a nil withholding tax rate on dividends, a 12 percent withholding
See MoreRomania: Announces tax reforms
Romania is introducing a tax exemption on reinvested profit as part of an emergency ordinance. The tax exemption is to apply from 1 July 2014 and is to continue until the end of 2015. This is intended to encourage more investment in new assets in an
See MoreOECD: Issues Latest Tax Transparency Ratings
Twelve new reports have been issued by the OECD’s Global Forum, emphasizing measures that need to be taken by jurisdictions to reach the required international standard for the exchange of tax information. The “Global Forum on transparency and
See MoreMexico: Appeal procedures for certain challenges to tax reform
Mexico’s Supreme Court of Justice (Suprema Corte de Justicia de la Nación) has postponed the hearing of appeals in amparo actions, these being legal actions that challenge the constitutionality of some measures included in the 2014 tax reform.
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