21 December 2016, the German cabinet adopted a bill to impose more stringent reporting obligations on German taxpayers with foreign financial interests and financial institutions managing foreign investment structures for their clients. If the bill is approved by parliament, the changes will be introduced on 1 January 2018. Under the proposals, taxpayers must disclose a…
22 December 2016, the Cayman Islands government issued the Tax Information Authority (Amendment) Law 2016 (Commencement) Order and the Tax Information Authority (International Tax Compliance) (Common Reporting Standard) (Amendment) Regulations. This represents the second tranche of regulations “to ensure effective implementation” of the OECD Common Reporting Standard (CRS), which is the global standard for automatic…
22 December 2016, the double tax treaty between Switzerland and Liechtenstein entered into force. It was signed on 10 July 2015 and is the first comprehensive tax treaty between the two countries. The provisions of the treaty will apply from 1 January 2017. The new treaty replaces the current agreement of 22 June 1995 between…
16 December 2016, India’s Central Board of Direct Taxes announced that the notification of Cyprus under section 94A of the Income Tax Act 1961 as a notified jurisdictional area for lack of effective exchange of information, had been rescinded with effect from 1 November 2013. It followed the signing on 18 November of a revised…
14 December 2016, Monaco deposited its instrument of ratification for the Convention on Mutual Administrative Assistance in Tax Matters. By doing so, the OECD said, it had taken another important step in implementing the Standard for Automatic Exchange of Financial Account Information in Tax Matters as well as automatic exchange of Country-by-Country Reports under the…
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…
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