Int'l Tax News
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Liechtenstein, Monaco Sign Tax Treaty
Officials from Liechtenstein and Monaco signed an income and capital tax treaty in Bern on June 28, the Liechtenstein government has announced.
The treaty reportedly conforms to the OECD standard on information exchange and transparency and takes into account the October 2015 final reports of the OECD's base erosion and profit-shifting project, designed to combat tax avoidance in the cross-border context. Negotiations began in May 2015 and a treatywas initialed last November.
The treaty reportedly conforms to the OECD standard on information exchange and transparency and takes into account the October 2015 final reports of the OECD's base erosion and profit-shifting project, designed to combat tax avoidance in the cross-border context. Negotiations began in May 2015 and a treatywas initialed last November.
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UN must defend target to curtail multinational companies tax abuse
The Tax Justice Network, ICRICT and the Global Alliance for Tax Justice havewritten to the new UN Secretary General António Guterres urging him to make sure that the commitment to tackle multinational tax abuse is not eliminated from the UN Sustainable Development Goals (SDGs).
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At Your Service! The Role of Tax Havens in International Trade with Services
This paper provides the first comprehensive study of profit shifting through mispriced service trade inside multinational firms. The analysis employs a unique firm-level datasetwith detailed information about service trade and foreign affiliates for virtually all multinational firms in Germany.
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Corporate Taxation and Location of Intangible Assets: Patents vs. Trademarks
Numerous empirical studies have analysed the influence of corporate taxation on the location of intangible assetswithin a company group. However, the previous literature has rather focused on studying the impact of taxation on patent location choices assuming that these assets represent the rest of intangibles aswell. This paper complements previous studies by estimating and comparing the tax elasticities of two different types of intangibles – patents and trademarks.we employ data on European and US patent and trademark applications in the period of 1996-2012 and estimate a multinomial logit model that incorporates various observed and unobserved factors of the intangible's location choice. According to our main findings, trademarks are more sensitive to changes in taxation as compared to patents. This implies that firms use trademarks more eagerly for tax planning purposes than patents.
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Effectiveness of Fiscal Incentives for R&D: Quasi-Experimental Evidence
With growing academic and policy interest in research and development (R&D) tax incentives, the question about their effectiveness has become ever more relevant. In the absence of an exogenous policy reform, the simultaneous determination of companies' tax positions and their R&D spending causes an identification problem in evaluating tax incentives. To overcome this identification challenge,we exploit a U.K. policy reform and use the population of corporation tax records that provide precise information on the amount of firm-level R&D expenditure. Using difference-in-differences and other panel regression approaches,we find a positive and significant impact of tax incentives on R&D spending, and an implied user cost elasticity estimate of around -1.6. This translates to more than a pound in additional private R&D for each pound foregone in corporation tax revenue.
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Bonus Taxes and International Competition for Bank Managers
We analyze the competition in bonus taxationwhen banks compensate their managers by means of fixed and incentive pay and bankers are internationally mobile. Banks choose bonus payments that induce excessive managerial risk-taking to maximize their private benefits of existing government bailout guarantees. In this setting the international competition in bonus taxes may feature a 'race to the bottom' or a 'race to the top', depending onwhether bankers are a source of net positive tax revenue or inflict net fiscal losses on taxpayers as a result of incentive pay. A 'race to the top' becomes more likelywhen governments' impose only lax capital requirements on banks,whereas a 'race to the bottom' is more likelywhen bank losses are partly collectivized in a banking union.
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Accounting for Business Income in Measuring Top Income Shares: Integrated Accrual Approach Using Individual and Firm Data from Norway
Business income is important in the upper tail of the personal income distribution, but the extent towhich it is captured by measures of personal income varies substantially across tax regimes. Using linked individual and firm data from Norway,we are able to attribute business income to personal owners as it accrues rather thanwhen it is realized. This adjustment leads to an increase in top income shares, and the size of this effect varies dramatically depending on the tax regime in place.
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IRS Attention
We study how public and private disclosure requirements interact to influence both tax regulator enforcement and firm disclosure. To capture IRS enforcement activities,we introduce a novel data set of IRS acquisition of firms' public financial disclosures,whichwe label IRS attention.we examine the implementation of two new disclosure requirements that potentially alter IRS attention: FIN 48,which increased public tax disclosure requirements, and Schedule UTP,which increased private tax disclosure.we find that IRS attention increased following FIN 48 but subsequently decreased following Schedule UTP, consistentwith public and private disclosure interacting to influence tax enforcement.
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Bank of China Settles Italy Tax Dispute Over Cash Transfers
The Bank of China paid 20 million euros ($22.4 million) to resolve a tax disputewith Italy over thousands of money transfers the bank orchestrated between Chinese nationals in Italy and their home country, the Italian government said June 21.
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OECD to Release Updated Transfer Pricing Guidelines, Branch Mismatches Report
The OECD is set to release an updated version of its transfer pricing guidelines, aswell as a report on branch mismatches, in July, according to top OECD officials.
Speaking during the OECD's sixth installment of the Tax Talkswebcast series June 26, Pascal Saint-Amans, director of the OECD's Centre for Tax Policy and Administration (CTPA), confirmed that the new version of the transfer pricing guidelines,whichwere last updated in 2010 and amended in 2016 based on the final base erosion and profit-shifting reports on actions 8-10 (transfer pricing) and action 13 (transfer pricing documentation),will be published soon.
Speaking during the OECD's sixth installment of the Tax Talkswebcast series June 26, Pascal Saint-Amans, director of the OECD's Centre for Tax Policy and Administration (CTPA), confirmed that the new version of the transfer pricing guidelines,whichwere last updated in 2010 and amended in 2016 based on the final base erosion and profit-shifting reports on actions 8-10 (transfer pricing) and action 13 (transfer pricing documentation),will be published soon.
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Lets talk about the tax reform in the Philippines
There are a lot of those previously exempt from value-added tax (VAT) or zero-rated VAT transactions that are being disallowed under the Tax Reform for Acceleration and Inclusion. However, these transactions are usually not applicable anyway to business enterprises. Though these proposed changes in the VAT law are quite significant, let me just skip these and go to one change closer to the heart of start-up businesses.
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The British Virgin Islands is trying to prove it's not a tax haven campaigners aren't buying it
Transparency and tax campaigners are clashingwith officials from the British Virgin Islands (BVI) over a new report claiming the Caribbean islands are not a tax haven.
The report,written by Capital Economics and commissioned by BVI Finance,which promotes the country's financial sector, said the islands are strong contributors to the global economy and help facilitate international trade and investment.
The report,written by Capital Economics and commissioned by BVI Finance,which promotes the country's financial sector, said the islands are strong contributors to the global economy and help facilitate international trade and investment.
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Austrian Parliamentary Committee Approves for Ratification MLI, Tax Treaty With Israel
The Austrian parliament's Finance Committee on June 21 approved for ratification the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) and the pending tax treatywith Israel, according to information published on the Parliament'swebsite.
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Bribes, Borders and Middlemen: Why India's GST Is a Game Changer
Seized vehicles. Bribes. Days-long delays. Moving goods across Indian states isn't exactly easy -- and that's a major barrier to economic growth.
Rolling a truck of vegetables into Gujarat, the state once governed by Prime Minister Narendra Modi, requires a bribe of 500 rupees to 2,000 rupees evenwith your papers in order, according to Rakesh Kaul, vice-president of Caravan Roadways Ltd.,which has about 400 trucks plying India's pot-holed roads.
Rolling a truck of vegetables into Gujarat, the state once governed by Prime Minister Narendra Modi, requires a bribe of 500 rupees to 2,000 rupees evenwith your papers in order, according to Rakesh Kaul, vice-president of Caravan Roadways Ltd.,which has about 400 trucks plying India's pot-holed roads.
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Disappointed by Failed VAT Proposal, Scicluna Reviews Maltas EU Presidency
The lack of agreement on an e-book VAT proposalwas both a surprise and a disappointment, Edward Scicluna, president of the Economic and Financial Affairs Council, told members of the European Parliament (MEPs) during a June 19 meeting of the Committee on Economic and Monetary Affairs.
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$1.5 trillion of assets move through the British Virgin Islands twice as much as previously thought
Assets held offshore in the British Virgin Islands (BVI) areworth $1.5 trillion (£1.19 trillion), double the International Monetary Fund's 2010 estimate. That's according to a new report by Capital Economics, seen by the Financial Times.
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EU Fails to Agree on Reduced VAT Rates, Reverse Charge Mechanism
European finance ministers failed to reach an agreement on two important VAT files that the Maltese presidency of the Council of the EU had hoped to close on June 16. Aswas expected, the Czechs blocked an agreement on reduced VAT rates on e-books because they didn't getwhat theywanted on a proposal thatwould allow them to apply a general reverse charge mechanism.
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Nigeria Ratifies Treaties to Curb Tax Evasion by Multinationals
Nigeria has ratified multilateral conventions on tax related treaties to end profit shifting and tax evasion by multinational companies.
The ratification of the treatieswednesday followed the approval of a memo submitted by the Minister of Finance, Kemi Adeosun,who said thiswas part of government's plan towiden its tax base and improve revenue generation.
The ratification of the treatieswednesday followed the approval of a memo submitted by the Minister of Finance, Kemi Adeosun,who said thiswas part of government's plan towiden its tax base and improve revenue generation.
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India Signals Tax Overhaul on Track as Timing Questioned
Indian officials are signaling a sweeping tax reformwill go ahead as scheduled on July 1, pushing back against speculation the governmentwill delay amid predictions of chaos from some business groups.
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New tax treaty will close loopholes that allow multinationals to avoid tax
Australia,with another 70 countries, has signed a multilateral treaty to create more coherence in fighting tax avoidance by large multinational corporations. The Multilateral Convention to Implement Treaty Measures to Prevent Base Erosion and Profit Shifting, or BEPS Convention, aims to close loopholes in the international tax system that result from differences in individual country tax systems.
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U.K. Vote Adds to Uncertainty Over Tax and Brexit
U.K. Prime Minister Theresa Maywill form a governmentwith the support of Northern Ireland's Democratic Unionist Party (DUP) to "provide certainty and lead Britain forward," after the June 8 general election that May had hopedwould deliver "strong and stable" government but instead produced a hung Parliament.
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Concessions given to selected sectors as India ploughs ahead with major tax reform
A series of last-minute concessions to critics of the incoming nationwide goods and services tax (GST)will see rates lowered on 66 different items, ranging from school bags and cinema tickets to levies on labour in industries like textiles.
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CCCTB Would Cost Ireland Billions, Business Association Claims
An EU common consolidated corporate tax base (CCCTB)would cost Ireland ÔøΩ4 billion a year in tax revenue, according to a projection by the Irish business association Ibec.
Member states are considering a proposal for a common corporate tax base, advocated by EU Tax Commissioner Pierre Moscovici, as a first step toward greater tax harmonization.
Member states are considering a proposal for a common corporate tax base, advocated by EU Tax Commissioner Pierre Moscovici, as a first step toward greater tax harmonization.
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India Signs Tax Super-Treaty With Some Reservations
India June 7 entered into a super-treaty thatwill overhaul the global tax ecosystem, but indicated reservations over recently negotiated tax treatieswith Mauritius, Singapore and Cyprus.
The multilateral instrumentwill swiftly modify more than 2,000 active tax treaties to incorporate the action items from the Organization for Economic Cooperation and Development's Base Erosion and Profit Shifting initiative,which is aimed at expanding the global tax net, easing the flow of information between countries, and curbing tax avoidance by multinational corporations.
The multilateral instrumentwill swiftly modify more than 2,000 active tax treaties to incorporate the action items from the Organization for Economic Cooperation and Development's Base Erosion and Profit Shifting initiative,which is aimed at expanding the global tax net, easing the flow of information between countries, and curbing tax avoidance by multinational corporations.
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EU to Shed Light on Tax Planning Schemes
Therewill soon be no more place to hide in the EU. On June 21 the European Commissionwill unveil new plans to require tax advisers to disclose to tax authorities the tax planning arrangements they design.
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Ukraine Clarifies Transfer Pricing, Corporate Tax, and VAT Matters
The Ukrainian State Fiscal Service (SFS) has released three Guidance Letters inwhich it clarified transfer pricing, corporate tax, and VAT matters.
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David Cameron vowed to crack down on offshore tax evasion so why has it disappeared from the Tory manifesto?
In all the election noise, you are unlikely to have heard anything about a paragraph appearing on the 124th page of the Labour Manifesto – even though it is a manifesto pledge that could transform theworld in a truly fundamentalway.
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40 Countries to Adopt New Permanent Establishment Provision in MLI
Approximately 40 of the countries that sign onto the OECD's multilateral instrument (MLI)will reportedly adopt the revised permanent establishment standard, Tax Analysts has learned.
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India struggles to agree one nation, one tax, one rate
When he came to power three years ago, Narendra Modi pledged to unlock India's untapped economic potential ÔøΩ and ensure an acceleration of the country's then sluggish growth.
Indiawill take its biggest leap yet in that questwithinweeks,when a long-awaited tax reform is supposed to turn a highly fragmented marketwith an unwieldywelter of taxes into a true single market for manufactured goods,with a single, unified value added tax regime.
Indiawill take its biggest leap yet in that questwithinweeks,when a long-awaited tax reform is supposed to turn a highly fragmented marketwith an unwieldywelter of taxes into a true single market for manufactured goods,with a single, unified value added tax regime.
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China Extends Preferential Tax Treatment of Advertising Expenses
China's Ministry of Finance and State Administration of Taxation on June 2 issued Caishui [2017] 41 (Circular 41),which extends a preferential tax deduction for advertising and business promotion expenses to the manufacturing and sales sector, the pharmaceutical manufacturing sector, and the beverage manufacturing sector (excluding alcoholic beverages).
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Europe inches closer to a plan for fixing its financial flaws
Donald Trump and Theresa May may have done more to push Europeans together, and open up an opportunity for reform of its institutions, than any pro-European American president or British prime minister could ever have dreamt. The Commission's "Reflection paper on the deepening of the Economic and Monetary Union", issued on May 31st, points theway towards a package deal that could be acceptable to Northern and Southern euro area countries. But some key elements are still missing.
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New VAT Threshold for Shipments to Swiss Customers to Start January 1
A previously approved amendment to a Swiss law extending the country's VAT to all services provided by foreign companies and abolishing the de minimis threshold belowwhich imports of goods are exempt from VATwill go into effect January 1, 2018, the Swiss Federal Council said June 2.
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Spain's Lower House Approves Protocol to Tax Treaty With Mexico
Spain's Congress of Deputies (lower house of parliament) on May 11 approved the pending protocol to the Mexico-Spain income and capital tax treaty, according to information published on itswebsite.
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The 1000 richest families in Scandinavia evade a third of their taxes, finds a new bombshell study
A new study indicates that Scandinavia'swealthiest families are moving their money abroad to avoid paying taxes.
The study estimates that the 1000 richest families in Scandinavia havewithheld as much as 32 procent of the taxes theywould otherwise be required to pay.
The study estimates that the 1000 richest families in Scandinavia havewithheld as much as 32 procent of the taxes theywould otherwise be required to pay.
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Juncker survives Parliaments tax hot seat
A relaxed European Commission President Jean-Claude Juncker calmly dismissed allegations that he helped foster corporate tax avoidance in Luxembourg, during a hearing before MEPs in Brussels on Tuesday.
He instead proclaimed his ignorance over the Grand Duchy's suspect tax dealingswith corporations as he deflected critical questioning in the European Parliament's committee of inquiry into money laundering, tax avoidance and tax evasion (PANA).
He instead proclaimed his ignorance over the Grand Duchy's suspect tax dealingswith corporations as he deflected critical questioning in the European Parliament's committee of inquiry into money laundering, tax avoidance and tax evasion (PANA).
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Kosovo, Switzerland Sign Tax Treaty
Officials from Kosovo and Switzerland signed a tax treaty and accompanying protocol in Pristina on May 26, according to information published on the Swiss government'swebsite.
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OECD releases peer review document for assessment of the BEPS Action 6 minimum standard
Today the OECD released the key document, approved by the Inclusive Framework on BEPS,whichwill form the basis of the peer review of the Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate circumstances.
The Action 6 minimum standard is one of the four BEPS minimum standards. Each of the four BEPS minimum standards is subject to peer review in order to ensure timely and accurate implementation and thus safeguard the level playing field. All members of the Inclusive Framework on BEPS commit to implementing the minimum standards and participating in the peer reviews.
The Action 6 minimum standard is one of the four BEPS minimum standards. Each of the four BEPS minimum standards is subject to peer review in order to ensure timely and accurate implementation and thus safeguard the level playing field. All members of the Inclusive Framework on BEPS commit to implementing the minimum standards and participating in the peer reviews.
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Italy offers multinationals voluntary "webtax" to avoid wrangles
Italy sought to boost revenue from multinational internet companies on Monday by offering them the chance to agree on their future tax bills rather than risk disputes.
For years, Italy has argued that companies such as Amazon, Apple and Google avoid taxes by maintaining that they do not have a "stable presence" in Italy, even though they generate huge revenues there.
For years, Italy has argued that companies such as Amazon, Apple and Google avoid taxes by maintaining that they do not have a "stable presence" in Italy, even though they generate huge revenues there.
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U.S. Company Seeks Treasury's Help in Tax Brawl With Georgia
A private company based in Miami is seeking the Department of Treasury's support for a disputewith the country of Georgia involving tax assessments of more than $82.45 million and a review process it said is unjust.
Georgian American Alloys Inc. (GAA) urged the U.S. competent authority, in a May 4 letter released under the Freedom of Information Act, to acknowledge the possibility of its claim that Georgia's tax measures have expropriated the company's investments in Georgia.
Georgian American Alloys Inc. (GAA) urged the U.S. competent authority, in a May 4 letter released under the Freedom of Information Act, to acknowledge the possibility of its claim that Georgia's tax measures have expropriated the company's investments in Georgia.
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The U.S. Border Tax and Its Implications for the EU
In summer 2016 the Republican majority of the U.S. House of Representatives unveiled its plan to launch the biggest tax reform effort in more than 30 years. The blueprint's core elements are income tax cuts; a low, nonrecurring tax on undistributed foreign earnings; and a fundamental reform of business taxation. The plans for the last item are revolutionary in that House Republicans do not seek only to reduce the corporate tax rate to 20 percent; they alsowant to convert the classical system of business taxation to a destination-based cash flow tax (DBCFT)with a border tax adjustment.
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A 'Tax Revolution' Set to Sweep India's $2 Trillion Economy
Prime Minister Narendra Modi's government is set to dramatically reshape Asia's third-largest economywith the biggest tax reform since independence in 1947.
After finding common ground among India's 29 states, the finance ministry on Friday released detailed rates for the incoming goods and services tax, slotting more than 1,200 items -- from sugar to steel pipes and motorcycles -- into five tax brackets between zero and 28 percent.with that done, India is almost ready to implement a tax code that unifies more than a dozen separate levies, effectively creating a single marketwith a population greater than the U.S., Europe, Brazil, Mexico and Japan combined.
After finding common ground among India's 29 states, the finance ministry on Friday released detailed rates for the incoming goods and services tax, slotting more than 1,200 items -- from sugar to steel pipes and motorcycles -- into five tax brackets between zero and 28 percent.with that done, India is almost ready to implement a tax code that unifies more than a dozen separate levies, effectively creating a single marketwith a population greater than the U.S., Europe, Brazil, Mexico and Japan combined.
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News Analysis: Will International Tax Regulations Survive Executive Orders?
Since taking office, President Trump has issued three executive orders directing Treasury to review existing tax regulations. The stated purpose of the orders is to ensure that tax rules promulgated by the government aren't unduly burdensome to the public. Evaluating regulations under the vague standards of the executive orders ÔøΩ particularly the regs affecting cross-border taxation ÔøΩwill require Treasury to make judgment calls that involve balancing the goals of regulations and the tax code against the burdens they impose.
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German Central Bank Warns Trumps Tax Reform Would Hurt U.S. Economy
Germany's central bank Monday said President Donald Trump's tax planswould likely hurt the U.S. economy and lead to a 30 percentage-point increase U.S. debt-to-gross domestic product ratiowithin a decade.
The comments, published in the Bundesbank's monthly report, represent a rare critique by the central bank of US economic policy, but come amid tensions between Berlin and the new administration inwashington,which has attacked Germany's persistent trade surpluses.
The comments, published in the Bundesbank's monthly report, represent a rare critique by the central bank of US economic policy, but come amid tensions between Berlin and the new administration inwashington,which has attacked Germany's persistent trade surpluses.
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The impact of Swiss corporate tax reform III on your company
The abolishing of preferential tax regimes and the implementation of the expected corporate tax reform IIIwill challenge many Swiss operations of multinational enterprises. Holdings should not be affected on a large scale. However, IP and financing activities require review and amendment to the future Swiss tax landscape. This how your companywill be impacted by Swiss corporate tax reform.
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Irelands biggest growth risks are Brexit and U.S. tax reform
Irelandwill likely continue to enjoy robust growth thanks to a flexible, competitive and open economy,while efforts by the government to get its public finances in order have generated a significant reduction of the budget deficit.
That's the verdict of Moody's Investors Service,which on Tuesday published its annual credit analysis of the country, finding plenty of evidence to support Ireland's A3 rating and stable outlook.
That's the verdict of Moody's Investors Service,which on Tuesday published its annual credit analysis of the country, finding plenty of evidence to support Ireland's A3 rating and stable outlook.
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EU Pushing European Investment Bank to Avoid Tax Havens
The European Parliament (EP) is pushing hard to make sure the European Investment Bank (EIB) doesn't use public money in tax havens. Last year, the European Commission vetoed projectsworth up to ÔøΩ1 billion because it thought the financing arrangements linked to those projectswere dubious.
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U.K.s Labour Party Pledges Broad Tax Increases to Pay for New Benefits
Its election manifesto already leaked, Britain's opposition Labour Party sought on Tuesday to explain how its pledgeswould be financed and in the process slew another sacred cow of the party's recent, centrist past: low taxes for the moderatelywealthy, aswell as for the rich.
Tuesday's official release of Labour's manifestowas dominated by the cost implications of the party's most left-wing program in three decades,which includes plans to scrap university tuition fees, build more homes and increase spending on health and social care.
Tuesday's official release of Labour's manifestowas dominated by the cost implications of the party's most left-wing program in three decades,which includes plans to scrap university tuition fees, build more homes and increase spending on health and social care.
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U.S. Negotiating New Tax Treaty With Ireland: Official
The U.S. is negotiating a new tax treatywith Ireland, according to a Treasury official.
The U.S. is "at the table"with Luxembourg, Ireland, the Netherlands, Argentina and Colombia, using a new model tax treaty Treasury released in 2016 as a basis for negotiations, said Elena Virgadamo, attorney-adviser in Treasury's Office of International Tax Counsel.
The U.S. is "at the table"with Luxembourg, Ireland, the Netherlands, Argentina and Colombia, using a new model tax treaty Treasury released in 2016 as a basis for negotiations, said Elena Virgadamo, attorney-adviser in Treasury's Office of International Tax Counsel.
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Mnuchin Weaves in Tax Reform, With Trade Talk at G7 Italy
A Group of Seven communique issued on Saturday said officialswere "working to strengthen the contribution of trade to our economies" – aweaker pledge than the statement from the Group of 20 leaders a year ago to avoid protectionism in all its forms.
Finance ministers meeting in the Italian port of Bari, including Germany'swolfgang Schaeuble, sought to draw in the US Treasury Secretary toward the previous consensus on free trade, despite a formal agenda that avoided pursuing that too explicitly by focusing on "inclusive growth".
Finance ministers meeting in the Italian port of Bari, including Germany'swolfgang Schaeuble, sought to draw in the US Treasury Secretary toward the previous consensus on free trade, despite a formal agenda that avoided pursuing that too explicitly by focusing on "inclusive growth".
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OECD Chief Champions Multilateral Instrument
OECD Secretary-General Angel Gurria, speaking May 12 on the sidelines of a meeting of G-7 finance ministers in Bari, Italy, said the OECD's new multilateral instrument (MLI)will prevent large multinational companies from shifting profits to low-tax countries, according to an Associated Press report.
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