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the European Union Savings Directive will be creditableand credited against any UK tax due under[the] disclosure facility."The text of the Isle of Man agreement provides for avoluntary disclosure scheme that will likely be replicatedin future agreements with other territories. Itprovides for a minimum penalty rate of 10 percent,mirroring that on offer under the LiechtensteinDisclosure Facility, providing a disclosure is madeby September 30, 2016. Manx financial intermediarieswill be required to contact relevant persons toadvise them of the facility, and ensure adherence toregulations preventing money laundering.Article 10 of the Isle of Man's agreement providesfor a "bespoke service" that allows initial anonymouscontact by a professional adviser (including a financialintermediary) to discuss with HM Revenue andCustoms (HMRC) the circumstances of a person ona "no names" basis. It will be possible for a person orprofessional adviser acting on behalf of that person tohave a single point of contact with a discrete HMRCteam to ensure consistency of treatment. The optionwill be available in cases where a liability is disputeddue to residence or domicile claims made by an individual,with full supporting evidence, the text states.The Cayman Government has confirmed that seniorofficials have attended recent meetings withthe UK tax authority, HM Revenue and Customsin London to discuss the US Foreign Account TaxCompliance Act, and how the territory can supportthe UK's efforts to implement a similar regime.The Cayman Islands' Premier, Juliana O'Connor-Connolly told UK Prime Minister David Cameronthat the territory will join the G5 automatic tax informationexchange pilot being spearheaded by theUK, in partnership with France, Germany, Italy andSpain. In a letter to Cameron, O'Connor-Connollysaid that by joining the G5 pilot, Cayman is continuingto demonstrate its global commitment onthe exchange of information for tax purposes.Regarding the pilot, she wrote: "We welcome theseefforts to promote an effective global mechanismfor automatic exchange of information for tax purposes,in which all jurisdictions participate andwhere a common approach will not only ensure efficienciesof cost and resources, but will also avoidthe risk of multiple competing standards.""Accordingly, we would call on other jurisdictionsto commit to this initiative, which will take us toa new level of tax transparency and remove hidingplaces for those who would seek to evade tax anddodge their responsibilities."O'Connor-Connolly added in her letter that, in linewith revised Financial Action Task Force recommendationsand the recently issued methodologyfor assessing compliance with its standards on tacklingmoney laundering and countering the financingof terrorism, the Cayman Islands is committedto reviewing its legal and regulatory framework.""The Cayman Islands has always taken a leadingrole in the fight against money laundering, terrorist14
financing and all forms of financial crime, as is evidencedby [our] consistent compliance with thestandards," she wrote. Adding that Cayman remains"committed and determined to remain at the forefrontof jurisdictions in respect of information andenforcement of standards, such as those on availabilityof beneficial ownership information."The Bahamas' Minister for Financial Services RyanPinder has said that the local financial services industrymust be prepared to accept and adapt to automaticinformation exchange under the ForeignAccount Tax Compliance Act, and similar regimes,as it becomes the "new normal."Speaking at a "Complying with FATCA" one-dayregional conference on April 9, 2013, Pinder pointedout that FATCA is shaping up to be the "mostsignificant matter facing the international financialservices industry today.""The global paradigm is shifting to an expectation oftransparency globally," Pinder said. "We have beenwitnessing this evolution over the last 15 years fromwhen legislative changes were made for anti-moneylaundering purpose since the early 2000s, to the implementationof Tax Information Exchange Agreements,to the imposition of Organization for Economic Cooperationand Development and Financial ActionTask Force recommendations, and now FATCA.""We, however, have developed a significant level oflocal expertise; we must be committed to competingin this new normal. We can be industry leaders."Pinder said, in recognizing the importance of theinitiative: "We in the Ministry of Financial Servicesthought it wise, even before engaging the UnitedStates, to create a FATCA Task Force representativeof some of the most progressive minds in the privatesector of our financial services industry.""This FATCA Advisory Group had the mandateto review FATCA requirements and make recommendationsfor research and ultimate discussionand negotiation on matters particularly sensitiveand relevant to the financial services sector of theBahamas," Pinder noted. "It was this FATCA advisorygroup of private sector representatives whowould partner with my Ministry to prepare for thebeginning of negotiations on FATCA. Having recognizedthe areas of FATCA that have particularrelevance to our financial services industry, we areprepared to address them," he concluded.LuxembourgIn the context of its FATCA negotiations with theUS, Luxembourg has chosen the Model I agreement,which will provide for the automatic exchange ofinformation between Luxembourg and US tax authorities,on accounts held in Luxembourg financialinstitutions by citizens and residents of the US. Itis not yet clear whether the IGA will be reciprocal.According to the Luxembourg Government, thisdecision will put Luxembourg's relations with theUS in line with its declaration of April 10, 2013.On this date, Luxembourg announced that it willintroduce, on January 1, 2015, within the scope of15
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Page 5 and 6: FEATURED ARTICLESISSUE 30 | JUNE 6,
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NEWS ROUND-UP: FTTISSUE 30 | JUNE 6
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NEWS ROUND-UP: ENVIRONMENTAL TAXESI
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Finally, the Federal Council veheme
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Singapore Plugs Benefits For SMEsOf
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TAX TREATY ROUND-UPISSUE 30 | JUNE
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CONFERENCE CALENDARISSUE 30 | JUNE
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Key speakers: John Capasso (Alvarez
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Key speakers: TBA6/27/2013 - 6/27/2
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6/14/2013 - 6/14/2013http://www.con
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THE CYPRUS BAIL-OUT ANDFOREIGN CLIE
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Chair: Jonathan Levy (Partner, Reyn
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IN THE COURTSISSUE 30 | JUNE 6, 201
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on including the profit from the do
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een paid in the destination State.
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that Spain has gone its own way fir
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