EU Commission adopts its new proposal for an EU Financial Transaction Tax: further details
On 14 February 2013 the European Commission has presented its “new” draft proposal for a Council Directive implementing a financial transaction tax (FTT) in 11 countries. The draft is largely the same as the original proposal released in September 2011 but contains some important changes. The draft Directive continues to have a very broad scope
Germany – New legislation on taxation of portfolio dividends and introduction of refund procedure – impact on Fokus Bank claims
Background In October 2011 (case C-284/09) the CJEU held that the German taxation of portfolio dividends paid to non-resident shareholders was not in line with the free movement of capital (see NA 2011-013). The judgment left Germany the choice between rendering all portfolio dividends (i.e. those paid to residents and non-residents) chargeable to corporation tax
EU Financial Transaction Tax: new proposal for a Directive published today
On 22 January 2013 the ECOFIN Council (EU Finance Ministers) adopted a decision by qualified majority authorising 11 of the 27 EU Member States to proceed with the introduction of a harmonised EU FTT through Enhanced Cooperation in their countries. Today, the European Commission adopted a proposal for a Council Directive implementing enhanced cooperation in
Basel III & beyond: revised Liquidity Coverage Ratio (LCR)
Background to the changes The key changes High Quality Liquid Assets Cash outflows and run-off rates Cash inflows Application of the metric Monitoring tools PwC preliminary assessment Introduction On 7 January 2013 the Basel Committee on Banking Supervision (BCBS) issued a finalised standard on the Liquidity Coverage Ratio (LCR). The LCR forms one of
Tax issues around interest from fixed-income securities: new circular letter
On 25 January 2013, the Belgian tax administration published a circular letter on the Belgian tax regime of structured products characterised by an uncertain return on investment given the variation of the coupons or the modalities of reimbursement at term. Are in scope of this circular the securities whose return is linked to the evolution
Final FATCA regulations issued: let the compliance begin
In brief Stakeholders patiently waiting for guidance regarding the Foreign Account Tax Compliance Act (FATCA) need not wait any longer – final regulations were issued along with a press release on January 17, 2013. FATCA was enacted as part of the Hiring Incentives to Restore Employment Act (HIRE Act) on March 18, 2010 to serve
AIFMD: the finer details take shape
The European Commission (EC) finally published its delegated acts (the Level 2 Regulation) under the Alternative Investment Fund Managers Directive (AIFMD) on 19 December 2012. The EU Parliament and the Council have three months to scrutinise the Regulation but the likelihood of rejection by them seems quite low. The Level 2 Regulation has had a
Belgian legislative changes to withholding tax
Over the last weeks, the legislator made some major changes to the withholding tax system. The latest tax measures have been implemented by the Act of 13 December 2012 and the Program Act of 27 December 2012 into the Belgian Income Tax Code (“BITC”). In addition, the Royal Decrees of 20 December 2012 and 27
