News articles written by Olivier Hermand

Tax on savings deposits interest: Constitutional Court throws out 15% provision

24 January 2014

The Constitutional Court quashed the tax provisions providing for a reduced withholding tax of 15 % on interest arising from Belgian regulated savings deposits exceeding the threshold of EUR 1,250 per annum (read: EUR 1,880 for tax year 2014). As a reminder, below this threshold, interest on Belgian savings deposits is tax exempt. With the

FATCA – Final Regulations

15 January 2014

On 17 January 2013, the US Department of the Treasury and Internal Revenue Service (IRS) issued final comprehensive regulations implementing the information reporting and withholding tax provisions commonly known as the Foreign Account Tax Compliance Act (FATCA). The final regulations provide additional clarity for financial institutions and governments by finalising the processes for US account

EU FTT: the long and winding road to …?

19 December 2013

After a number of months in which the proposal for an EU Financial Transaction Tax (FTT) has been on hold, the meeting of the FTT Council Working Party held on 12 December provided a clear opportunity for the process to move forward. Ahead of the meeting, there had been reports in some parts of the

The EU FTT: a “non-starter” or “just an issue of how”?

9 December 2013

In this Newsflash we take stock of the very latest position on the EU FTT, including what institutions can expect to happen next Background Earlier this month, Christian Noyer, the Head of the French Central Bank, was quoted in an interview with the Financial Times as saying that “the Commission’s proposal [for an EU FTT]

EC proposed amendment of the Parent-Subsidiary Directive

2 December 2013

On 25 November 2013, the European Commission (hereafter: EC) proposed amendments to the Parent Subsidiary Directive (2011/96/EU; hereafter: PSD) in the context of the fight against tax fraud and evasion and aggressive tax planning/BEPS in the EU. The proposal seeks to tackle hybrid financial mismatches within the scope of application of the PSD and to introduce a general

France and the US sign bilateral agreement on the implementation of FATCA

25 November 2013

FATCA milestone reached after signing of tenth IGA with France On 14 November 2013, French Minister of Economy and Finance Pierre Moscovici and US Ambassador to France Charles H. Rivkin signed a bilateral Intergovernmental Agreement (IGA) intended to implement the Foreign Account Tax Compliance Act (FATCA). FATCA was enacted by the US in 2010 to

PwC comments on the draft ‘FFI agreement’ and related guidance

5 November 2013

Notice 2013-69 (the Notice) was released on October 29, 2013 by the Internal Revenue Service (IRS) and covers: Guidance to FFIs and branches of FFIs; Guidance for stakeholders, but it also contains some surprising twists; A draft version of the FFI agreement and describes an FFI’s general responsibilities; Miscellaneous guidance such as the application of

FATCA FFI Agreement Released

30 October 2013

The IRS released today Notice 2013-69, providing guidance for foreign financial institutions (FFIs) entering into an FFI agreement with the IRS to be treated as a participating FFI or Reporting Model 2 FFI under the provisions commonly referred to as FATCA. This notice includes a draft copy of the FFI agreement, which will be finalized