A Bill to permit the establishment of Private Foundations in Gibraltar was passed by Parliament together with the consequential amendments to the Income Tax (2010) Act. The legislation will provide a long-awaited framework for the establishment of foundations in Gibraltar. A foundation is an entity with a separate legal personality. The foundation charter and foundation rules…
The Australian Parliament approved a new Diverted Profits Tax (DPT), which is designed to “encourage greater compliance by large multinational enterprises with their tax obligations in Australia, including with Australia’s transfer pricing rules.” The DPT will apply at a penalty tax rate of 40%, from 1 July 2017, and will be inserted into the existing…
The establishment of the European Customs Union in 1968 was a very significant step. It has an internal and external aspect. So too does direct tax policy. The internal aspect of the direct tax policy includes the Anti-Tax Avoidance Directive, containing a general anti-avoidance rule and other things. The policy aims at transparency – including…
The promise of a referendum on membership of the EU featured in the Conservative party memorandum before the last election. When the referendum took place, the “leavers” were = unexpectedly – successful. The Great Reform Act provided for the embodiment of EU law in domestic law, but it is contemplated that many of the provisions…
In some cases, onshore jurisdictions can offer much of the tax benefit of offshore trusts. The privacy of the trust is also a consideration. The New Zealand foreign trust takes advantage of what was originally an anti-avoidance provision: it and exempts trusts with foreign settlors and under some treaties is treated as New Zealand resident,…
Countries are required by the CRS to cause banks to collect and return information from reporting financial institutions, which is then exchanged with other jurisdictions. The rules can be seen as invading the individual’s right to respect for private life. In one case, a Portuguese resident was the founder and beneficiary of an Austrian private…
The crisis of 2013 has proved to be a stimulus to reform and prosperity. Cyprus has become a fully compliant jurisdiction and has introduced a number of incentives to encourage foreigners to bring their business to the country. The Emergency Loan has been repaid and banks are again lending. There has been considerable inward investment.…
Singapore signed a Competent Authority Agreement (CAA) on the automatic exchange of information (AEOI) under the Common Reporting Standard (CRS) with France. It followed the signing of CAAs with Denmark on 15 March and with Belgium and Luxembourg on 13 March. Under the CAA, the Inland Revenue Authority of Singapore (IRAS) will automatically exchange financial…
13 March 2017, the Swiss Supreme Court published its decision of 13 February permitting the Swiss Federal Tax Agency (SFTA) to comply with a French request for information about a UBS client’s bank account – despite the request for legal assistance probably being based on stolen bank client data. In 2014, the SFTA approved a…
Finance Ministers and Central Bank Governors of the world’s 20 largest economies (G20) said they remained committed to a timely, consistent and widespread implementation of the Base Erosion and Profit Shifting (BEPS) package at their meeting in Baden-Baden, Germany. In the official communiqué, they said they welcomed the growing membership of the Inclusive Framework on…
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