13 December 2016, the Luxembourg parliament passed a law on non-public country-by-country (CbC) reporting to transpose the EU Directive 2016/881 of 25 May 2016 into domestic law. The law, when gazetted, will apply from 1 January 2016. CbC reporting applies to multinational enterprises (MNEs) whose total consolidated group revenue exceeds €750 million during the previous…
13 December 2016, the US Treasury Department and the IRS released final regulations governing the treatment of domestic disregarded entities (DREs) that are wholly owned by a foreign person for the limited purposes of the reporting, record maintenance and associated compliance requirements that apply to 25% foreign-owned domestic corporations under Code Sec. 6038A. In order…
7 December 2016, the Italian parliament approved the Finance Act 2017, which introduces a special tax status for non-domiciled residents who pay a ‘flat-rate tax’ on income produced abroad. The law, which is intended to attract capital investment to Italy, was one of the last acts of outgoing Prime Minister Matteo Renzi before his resignation.…
1 December 2016, the Federal Department of Finance (FDF) initiated a consultation on introducing the automatic exchange of information (AEOI) in tax matters with 21 other countries. The AEOI with these countries should enter into force on 1 January 2018 so that data can start to be exchanged in 2019. The consultation will last until…
26 September 2016, Switzerland ratified the multilateral Convention on Mutual Administrative Assistance in Tax Matters. The Convention, which provides for all forms of administrative assistance in tax matters, will enter into force for Switzerland on 1 January 2017. The OECD said ratification reaffirmed Switzerland’s commitment to greater tax transparency and marked an important step in…
13 September 2016, the Swiss Supreme Court ruled that a request from the Netherlands for information on Dutch account holders at Swiss banks was valid, overturning the decision of a lower court to refuse the order. Last November, the Dutch tax authority requested information about Dutch nationals who had more than €1,500 in their accounts…
13 September 2016, the Cyprus government approved a revised citizenship-by-investment scheme designed to further encourage investments in the island’s economy by non-Cypriot entrepreneurs and investors. The revised scheme abolishes the provision for collective investment of €12 million. This is to be replaced by an individual investment of €2 million and the purchase of a residence…
6 September 2016, the Inland Revenue Authority of Singapore (IRAS) and the Australian Taxation Office (ATO) entered into a Competent Authority Agreement on the automatic exchange of financial account information based on the Common Reporting Standard (CRS). They will commence exchange under the CRS by September 2018. Under the agreement, IRAS will automatically exchange with…
5 September 2016, HMRC launched the Worldwide Disclosure Facility (WDF), an online portal to enable taxpayers to correct past irregularities in their tax affairs by disclosing a UK tax liability that relates wholly or in part to an offshore issue. The new facility follows closure of all other disclosure opportunities at the end of 2015,…
5 September 2016, G20 leaders meeting at the Hangzhou Summit reiterated their call for all relevant countries, including all financial centres and jurisdictions, that have not yet committed to implementing the standard of automatic exchange of information to do so without delay and by 2018 at the latest, as well as to sign and ratify…
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