721.8 kB - Poledna | Boss | Kurer

More documents

Recommendations

Info

arbitrary, and given the large disparities between theSwiss cantons in terms of the tax rates applied. TheSPBA therefore advocates instead that the amountof tax evaded should be used as a qualifying element.SpainSpain's Finance Minister Cristóbal Montoro andUS Ambassador to Spain Alan Solomont have recentlysigned an agreement between Spain and theUS, designed to improve international fiscal complianceand implementing FATCA.Approved at the end of last year, the accord betweenSpain and the US is reciprocal, providing that financialinstitutions in both countries must provide theirtax authorities with information relating to taxpayersof the other signatory state. This information willsubsequently be exchanged automatically betweenthe tax authorities through a standardized procedure.Defending the treaty, the Spanish Finance Ministryhighlighted the fact that "the agreement constitutesa milestone in the exchange of tax information atan international level, by laying the foundationsfor a new automatic, recurrent and standardizedframework of international information exchange."Th e Ministry stated: "In a context of economicand financial globalization, and with the proliferationof transactions involving goods and servicesbetween countries, it is essential to strengthen theexchange of information and administrative assistancebetween states and increase efforts in thefight against tax havens."It added: "In this regard, efforts by tax authoritiesin both countries is important for increasing internationalpressure on tax havens through a networkof agreements on the exchange of information inline with international efforts being made with theother OECD countries."Spain, the UK, Germany, France, and Italy aim toensure that the model agreed with the US is adoptedmultilaterally by a majority of countries inorder to thus strengthen efforts against tax fraudand so-called "tax havens."The ministers therefore sent a letter to the EuropeanCommissioner for Taxation, Algirdas Šemeta, announcingplans to work together on a pilot schemefor the multilateral exchange of tax informationbetween the five countries, based on the FATCAmodel, having invited the other European Unionmember states to participate.The launch of such an initiative is intended to enableEurope and the US to spearhead the promotionof a global system of automatic informationexchange.New ZealandLast October, New Zealand announced its intentionto lodge an expression of interest in negotiating aFATCA intergovernmental agreement with the US.At the time, Revenue Minister Peter Dunne saidthat a deal would materially reduce FATCA compliance,and mean that financial institutions wouldnot have to provide information directly to the IRS.18
Talks are now underway. The TIEA will authorizeNew Zealand businesses to provide the Inland RevenueDepartment (IRD) with the required information,which will then be passed on to the US.The New Zealand Government has said that it isaware of compliance concerns regarding FATCAtax information exchange agreement currently beingnegotiated with the US.According to Dunne, New Zealand is negotiatingthe agreement on the same basis as its double taxand tax information exchange agreements. However,he did stress that the Government is "very awareof compliance cost issues and looking at how wecan minimize any burden."The agreement will be reciprocal, with the resultthat the US will also supply information aboutNew Zealand investments in the US."FATCA is part of New Zealand's commitment asa good global citizen to doing its bit to clamp downon tax evasion and an important way of doing thatis through tax information exchange agreementsthat we regularly enter into," Dunne said.AustriaFollowing a recent Council of Ministers meeting,Chancellor Werner Faymann revealed that the AustrianGovernment has adopted two resolutions designedto strengthen the fight against internationaltax evasion. Austria intends to sign an agreementwith the US tax authorities, implementing theForeign Account Tax Compliance Act (FATCA),and to sign the OECD Convention on mutual assistancein tax matters, the Chancellor emphasized.Underlining the fact that the Austrian Governmentis united in its stance and plans to negotiate together,Faymann stressed that Austria is pursuing "aclear, constructive path in the fight against tax evasion."Austria is determined to ensure that both taxhavens, such as the Channel Islands, and hiddenownership structures, such as trusts, are transparent,the Chancellor made clear.Highlighting the fact that Austria firmly supportsnegotiations between the European Commissionand third states, Faymann concluded by underscoringthat Austria is playing a pivotal, constructive,and clear role in combating tax flight.At the time, Faymann and Spindelegger underlinedthat Austria is not a tax haven and highlighted theGovernment's commitment to ensuring that theinternational fight against tax fraud is successfuland to ensuring that Austria plays a committed partin this fight.FATCA's ProblemsBack in the US, Treasury and the IRS express themselveshappy with the progress being made towardsthe implementation of FATCA. But the path is notstrewn with roses, due mostly to the reciprocal natureof many of the IGAs. Indeed, a plan to impose a reciprocalobligation on domestic financial institutionswas included in President Obama's April budget.19
Page 1 and 2: GLOBAL TAX WEEKLYa closer lookISSUE
Page 3 and 4: GLOBAL TAX WEEKLYa closer lookISSUE
Page 5 and 6: FEATURED ARTICLESISSUE 30 | JUNE 6,
Page 7 and 8: taxation treaties concluded by Swit
Page 13 and 14: UK, its offshore dependencies, and
Page 15 and 16: financing and all forms of financia
Page 17: Th e Government pointed out in part
Page 21 and 22: through which they can clamber in o
Page 23 and 24: fi nally, and most egregiously, the
Page 25 and 26: office space, or own tangible asset
Page 27 and 28: extended for 2 years in December 20
Page 29 and 30: Financial transactions ( e.g. inter
Page 31 and 32: OECD Section E - Redraft On Safe Ha
Page 33 and 34: suggests that the following items m
Page 37 and 38: State Interest And IntangibleExpens
Page 39 and 40: States generally define "intangible
Page 41 and 42: Code Sec. 1563(controlledgroup)Stat
Page 43 and 44: ConnecticutGeorgiaIllinoisIndianaRe
Page 45 and 46: Rhode IslandTennesseeVirginiaWest V
Page 47 and 48: Table 4. Comprehensive Income Tax T
Page 49 and 50: include federal interest income, st
Page 51 and 52: Recurring IssuesRestructuring of th
Page 53 and 54: M&A. Nick has extensive experience
Page 55 and 56: and consumers." As Germany and Chin
Page 57 and 58: on many levels. The panel found tha
Page 59 and 60: equirements placed on the states, i
Page 61 and 62: NEWS ROUND-UP: COUNTRY FOCUS - ITAL
Page 63 and 64: NEWS ROUND-UP: REAL ESTATE AND PROP
Page 65 and 66: ates - such that, in 2014, the 4 pe
Page 67 and 68: NEWS ROUND-UP: FTTISSUE 30 | JUNE 6
Page 69 and 70:
NEWS ROUND-UP: ENVIRONMENTAL TAXESI
Page 71 and 72:
Finally, the Federal Council veheme
Page 73 and 74:
Singapore Plugs Benefits For SMEsOf
Page 75 and 76:
TAX TREATY ROUND-UPISSUE 30 | JUNE
Page 77 and 78:
CONFERENCE CALENDARISSUE 30 | JUNE
Page 79 and 80:
Key speakers: John Capasso (Alvarez
Page 81 and 82:
Key speakers: TBA6/27/2013 - 6/27/2
Page 83 and 84:
6/14/2013 - 6/14/2013http://www.con
Page 85 and 86:
THE CYPRUS BAIL-OUT ANDFOREIGN CLIE
Page 87 and 88:
Chair: Jonathan Levy (Partner, Reyn
Page 89 and 90:
IN THE COURTSISSUE 30 | JUNE 6, 201
Page 91 and 92:
on including the profit from the do
Page 93 and 94:
deduct VAT as a result of incomplet
Page 95 and 96:
where the taxpayer had somehow offs
Page 97 and 98:
een paid in the destination State.
Page 99 and 100:
that Spain has gone its own way fir
show all

721.8 kB - Poledna | Boss | Kurer

You also want an ePaper? Increase the reach of your titles

Delete template?

Save as template?