18 and 19 January 2017, the US signed Model 1 intergovernmental agreements (IGAs) with Bahrain and Greece respectively US to facilitate compliance with the US Foreign Account Tax Compliance Act (FATCA) by financial institutions (FIs). FATCA is intended to ensure that the US Internal Revenue Service obtains information on financial accounts held at foreign financial…
12 January 2017, a French court acquitted art dealer Guy Wildenstein and seven others in a case which the prosecution claimed was “the most sophisticated and longest” case of tax fraud in postwar France. It had requested a €250 million fine and a four-year jail sentence, two suspended. The French tax authorities launched a criminal…
10 January 2017, an opinion issued by the EU Court of Justice (CJEU) found that Luxembourg should allow a company to challenge the legality of an information order issued in support of a French exchange of information request on the grounds that the request lacks “foreseeable relevance”. In Berlioz Investment Fund SA v Directeur de…
12 January 2017, the European Court of Human Rights rejected UBS’s challenge to a €1.1 billion security which had been imposed by the French authorities in 2014 in the context of the court supervision of the Swiss bank, which has been placed under formal investigation for alleged illegal direct selling of banking products and aggravated…
1 January 2017, the UK government introduced new civil penalties for the facilitators of the tax evasion who provide planning, advice or other professional services or physically move funds offshore. HMRC will also be able to name the enabler publicly. The Treasury said the government’s new powers would see individuals or firms who take deliberate…
6 January 2017, the Financial Services and Treasury Bureau (FSTB) released for public consultation two proposals dealing with the regulation of designated non-financial businesses and professions (DNFBPs) and enhanced transparency of corporate beneficial ownership. Under the first proposal, a licensing regime is to be introduced for trust and corporate service providers (TCSPs) and the scope…
6 January 2017, the Irish Revenue issued new guidance on the disclosure of foreign income and assets, outlining changes to the voluntary disclosure rules that will prevent individuals from benefitting from lower penalty rates when the disclosure relates to “offshore matters” It noted that restrictions introduced in the Finance Act 2016 include a measure to…
5 January 2017, the Brazilian government gazetted Provisional Measure No. 766/2017 to introduce a Tax Regularisation Programme (PTR) to incentivise individuals and companies to settle their federal tax liabilities. The PTR is an opportunity for companies and individuals to pay their tax or non-tax liabilities, due on or before 30 November 2016, or charged by…
1 January 2017, Uruguay’s Law on International Tax Transparency, the Prevention of Money Laundering and Terrorist Financing was brought into force. It was approved by parliament on 29 December. The Law requires certain resident and non-resident entities to disclose the identity of their ultimate beneficial owners – defined as an individual who, directly or indirectly,…
1 January 2017, new rules obliging EU Member States to automatically exchange information on all new cross-border tax rulings that they issue were brought into force. Exchange will be facilitated through a central depository that is accessible to all EU countries. Every six months national tax authorities will send a report to the depository, listing…
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