The latest developments on the country by country reporting requirements in Capital Requirements Directive IV
This Newsflash summarises the developments from the past 3 months and our current understanding of the issues and uncertainties created by Article 89. Recent developments It is now confirmed that HM Treasury (‘HMT’) will be the body responsible for transposing Article 89 into UK domestic legislation rather than the Prudential Regulatory Authority. With an implementation
The latest Italian FTT guidance – clarity at last? Don’t hold your breath…
Global FS Tax Newsflash 26 August 2°13. The Italian Financial Transaction Tax (“FTT, has now been in force since 1 March 2013. The regime comprises three taxes; a tax on equities, a tax on derivatives and a tax on high frequency trading. Following the introduction of the tax, market participants have been seeking further clarity
EU automatic exchange of information
The Feasibility Study on a simplified Relief at Source System: Purpose and Context PwC has been appointed in 2011 to carry out a feasibility study on a simplified relief at source system, implementing the principles of the European Commission’s FISCO Recommendation (C(2009)7924 of 19 October 2009). The FISCO Recommendation suggests to the Member States (MSs)
IRS opens FATCA online registration system to provide a beneficial user testing period
In brief The Internal Revenue Service (IRS) announced the opening of the Foreign Account Tax Compliance Act(FATCA) registration systemon August 19, 2013.The registration system will enable financial institutions (FIs) to register and obtain a global intermediary identification number (GIIN). FIs are requested to submit the required information online as final on or after January 1,
US government announces six-month extension to FATCA effective dates
The Internal Revenue Service (IRS) and the US Department of the Treasury (Treasury) issued Notice 2013-43 (Notice) last Friday announcing revised timelines for implementing various provisions under the Foreign Account Tax Compliance Act (FATCA). The Notice also provides additional guidance concerning financial institutions in jurisdictions that have signed an intergovernmental agreement (IGA) but have not yet enacted
New budget measures: Bill of 8 July 2013
Tax treatment of Belgian regulated investment companies The tax regime of Belgian regulated investment companies would be amended: The withholding tax levied on Belgian source dividends paid to Belgian regulated investment companies would, as a rule, constitute the final tax in their hands (no credit/refund would be possible anymore). However, by dispensation to this general
EU FTT – Will the Commission’s proposal survive?
There continues to be much press coverage around the EU Financial Transaction Tax (“EU FTT”). There has been speculation that the draft Directive issued earlier this year will be considerably diluted and that the eleven countries within the Enhanced Cooperation Procedure are struggling to reach consensus. Notably, there was no mention of the EU FTT
Belgian Law not EU compliant in relation to Downward PE adjustment to the Notional Interest Deduction basis
Under the notional interest deduction (hereafter “NID”) regime, Belgium introduced a sui generis corporate tax deduction, i.e. Belgian corporate income taxpayers are for tax purposes allowed to claim a NID reflecting the economic cost of the use of capital, equal to the cost of long-term, risk-free financing. In practice, the NID is equal to the
