France introducing new transfer pricing provisions in the 2014 Finance Law
The 2014 Finance Law was adopted by the French Parliament on 19 December 2013 and was published in the French Official Journal on 30 December 2013. Background One of the core objectives of the 2014 Finance Law is to achieve structural balance with regards to public finances and to reinforce the fight against fraud and
New Global Standard for Automatic Exchange of Tax Information
In response to a mandate from G20 leaders aimed at reinforcing action against tax avoidance and evasion as well as introduce even greater trust and transparency into the international tax system, the OECD has unveiled today a new single global standard for the automatic exchange of information between tax authorities worldwide. Developed by the OECD
Foreign Tax Credit (QFIE/FBB) System not Compliant to Belgian Constitution
Decision The Court examines two aspects of the legislation, (1) the possible refund of FTC in case of insufficient taxable profits and (2) the gross-up of the FTC to the corporate tax base (link to decision FR/ NL). 1. Excess FTC (article 285 and 292 ITC) Under domestic law, a foreign tax credit excess may
Soon to be released ‘Common Reporting Standard’ promises new FATCA-type obligations around the world
The starting date for various obligations under the Foreign Account Tax Compliance Act (FATCA) is 1 July 2014. Some associate this date with a long and weary process that started back in 2010 with the passage of the United States HIRE Act, but it also marks a milestone in the ever increasing movement towards greater
Belgian savings pension system not in line with EU law
On 23 January 2014, the Court of Justice of the European Union (the Court) issued its decision in Case C‑296/12 Commission v. Kingdom of Belgium. The Court declared that, by introducing and maintaining a tax reduction in respect of contributions paid to a savings pension (savings account or savings insurance) in so far as that reduction
Tax on savings deposits interest: Constitutional Court throws out 15% provision
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
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 …?
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
