Russia: MoF clarifies extra requirements that must be satisfied by tax resident certificate
The Ministry of Finance (MoF) has issued Letter No. ОА-4-13/5288 on March 21, 2014. It describes the rules that US certificates of tax residence should complete with a view to claiming remuneration under the Russia - United States Income and
See MoreRussia: Application on Participation exemption in case the subsidiary is reorganized
The Ministry of Finance has issued Letter No. 03-03-РЗ-15941 on April 8, 2014 clarifying the application of the participation exemptions in the case where the subsidiary is subject matter to reorganization. Pursuant to general rule, for qualifying
See MoreSwitzerland-Hungary: Signed Double Taxation Agreement
Switzerland and Hungary signed a double taxation agreement on 4 June 2014. Switzerland's lower house of parliament has approved the DTA after ratification by both
See MoreRussian Parliament adopts Law to permit FATCA Disclosures
The Russian parliament has allowed a bill to permit financial institutions to observe with the United States’ Foreign Account Tax Compliance Act (FATCA). US Congress has passed FATCA in 2010, which will be effective on July 1, 2014 and it is
See MoreFrance: Withdraws IHT Agreement with Switzerland
The government of France has announced to withdraw the 1953 inheritance tax (IHT) agreement with Switzerland effective from 31 December 2014. Accordingly from 1 January 2015 in the absence of a treaty domestic inheritance tax rules will be
See MoreRussian banks help IRS after new FATCA law passed
The State passes legislation allowing Russian banks to pass information on their U.S. clients to the IRS, as demanded by the Foreign Account Tax Compliance Act (FATCA). FATCA will come into force on July 1, 2014, and by this time the law that
See MoreSwitzerland–Australia: approved double taxation agreements
The lower house of parliament approved the nation’s double taxation agreement on 4 June 2014. The DTA will enter in to force after both countries have completed their respective domestic requirements and ratification by both
See MoreSwitzerland: Approved Law To Maintain FATCA
The Federal Council of Switzerland has determined to bring together the Foreign Account Tax Compliance Act (FATCA) Act and the regulation of disclosure obligations, which came into effect on 30 June of 2014. The Swiss parliament approved the FATCA
See MoreSwitzerland and United States FATCA agreement enters into force
The Federal Council decided, on June 6, 2014, that the FATCA agreement between Switzerland and the United States came into force on June 2, 2014. This agreement was approved by the parliament in September 2013. The FATCA execution in Switzerland is
See MoreRussia: Clarification of tax treatment of income derived from alienation of immovable property
The Ministry of Finance has issued Letter No. 03-08-05/13287 on March 26, 2014 describing the income tax treatment derived by an Israeli individual from alienation of an immovable property situated in Russia. Article 6 of the Israel - Russia Income
See MoreRussia: Draft law on information exchange with foreign tax authorities
The Russian government has allowed a draft law initiating the process of information exchange with foreign tax authorities on May 14, 2014. The law introduces the responsibility of Russian credit organizations, brokers, depositaries, insurance
See MoreNew Russian CFC and anti-avoidance legislation
The amended draft law regarding controlled foreign companies and other anti-offshore measures has done most valuable changes in the field of foreign tax structures and tax avoidance. This law has publicly available on 27 May, 2014. It highlights
See MoreSwitzerland – San Marino: Signes TIEA
Switzerland and San Marino signed a tax information exchange agreement (TIEA) on May 16, 2014. The agreement provides for the exchange of tax information on request on specific tax matters. The conclusion of agreements for the exchange of tax
See MoreSwitzerland and Singapore sign OECD agreement against tax evasion though banking secrecy
Forty seven countries participated in the Declaration on Automatic Exchange of Information in Tax Matters, adopted by the OECD on 6 May 2014. These countries included Switzerland and Singapore, two financial centers that have in the past been
See MoreSwiss Discuss Banking Sector Tax Disputes With The US
Recent discussions between the US and Switzerland have centered on a US tax dispute settlement program for category two, three, and four banks and the current US criminal investigations into category one banks that are domiciled in Switzerland. The
See MoreNorway: Regulations regarding exemptions to the interest
On 24 April 2014, Norway’s Ministry of Finance issued regulations regarding exemptions to the interest deduction limitation rules. Under regulations issued in April 2014 certain securities transactions are exempt from the interest restriction
See MoreEuropean Inheritance Tax Burdens Compared
A recent examination of inheritance tax systems in European countries suggests that there is no consistency in the way that the taxes are applied to family business transfers. The way the tax operates is greatly influenced by the tax relief that can
See MoreSwitzerland to Retain Flat Tax For Wealthy Expatriates
Switzerland’s National Council has voted against the proposed withdrawal of the flat tax regime for high wealth foreigners. The Council supported that argument that the flat tax makes Switzerland an attractive location for high wealth individuals
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