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Bulletin 49

SWITZERLAND: European Union finance ministers agreed to white-list Switzerland as compliant with all required tax cooperation commitments. The United Arab Emirates has also been removed from the EU blacklist, having enacted satisfactory economic substance legislation. Nine jurisdictions remain on …

Bulletin 48

INTERNATIONAL TAXATION: The Organisation for Economic Co-operation and Development (OECD) has released a detailed work plan to develop a consensus solution to the tax challenges arising from the digitalisation of the global economy. The 129 countries participating in …

Bulletin 47

CRYPTOCURRENCIES: Social media company Facebook plans to launch its own virtual currency, GlobalCoin, next year. It will be used as a worldwide digital payments system, and will be available initially in around a dozen countries by the first quarter of …

Bulletin 46

BENEFICIAL OWNERSHIP: The UK Minister for the Commonwealth and the United Nations, Lord Ahmad, has assured British Overseas Territories (OTs) that they have until 2023 to establish publicly available registers of beneficial ownership, during which time the UK will be campaigning to have …

Bulletin 45

SPAIN: The European Commission has requested Spain to impose equal taxes on rental income received by resident and non-resident individuals. Landlords receive a 60 per cent tax exemption for renting their properties out as a tenant’s main residence, but non-resident individuals with real estate properties in …

Bulletin 44

IRELAND: The Irish government has again postponed its plans to revalue domestic property for the purposes of local property tax (LPT), this time from 1 November 2019 to 1 November 2020. Property prices have increased sharply but unevenly across the Republic of Ireland since the last valuation in …

Permanent Establishment

(1) For the purposes of this convention the term “permanent establishment” means a fixed place of business through which the business of an enterprise is wholly or partly carried on.
(2) The term “permanent establishment” includes especially…

Bulletin 43

CYPRUS: The finance ministry has circulated a draft Bill to transpose the EU directive on the mandatory disclosure and exchange of cross-border tax arrangements (DAC 6) into national law by the end of 2019. The Bill includes no additional provisions beyond those required by the directive. It exempts …

Bulletin 42

PORTUGAL: Law No. 17/2019 was formally enacted in Portugal, requiring banks to report residents’ financial accounts above EUR50,000 by 31 July of each year. Transitional deadlines allow 60 days for reporting of accounts existing before …

Bulletin 41

BRITISH OVERSEAS TERRITORIES: MPs on the UK House of Commons Foreign Affairs Committee have urged the UK government to stick to the original date of December 2020 for the publication of public registers of beneficial ownership in each British Overseas Territory (OTs), as set by the …

Bulletin 40

LITHUANIA: The Council of Europe’s MONEYVAL anti-money laundering compliance committee has applied its enhanced follow-up procedure to Lithuania, ordering it to mitigate some ‘significant vulnerabilities’ regarding investigation and prosecution of money laundering, and the supervision of …

Bulletin 39

TAX POLICY: Most of the world’s financial centres have kept their promises to abolish preferential tax regimes in 2018, says the OECD in its latest review of harmful tax practices. Only seven regimes are still recognised as ‘harmful’ or ‘potentially harmful’ by encouraging …

Bulletin 38

UK: The UK government has set out its plans for EU, EEA and Swiss nationals arriving in the UK after a ‘no-deal’ UK exit from the EU on 29 March. In the event, free movement will end immediately, although there will be a transition period until 31 December 2020 during which …

Bulletin 37

TAX TRANSPARENCY: Fifteen jurisdictions are at risk of being identified by the OECD as failing to implement its tax transparency standards, OECD secretary-general Angel Gurriá told the G20 Leaders’ Summit in Buenos Aires last week. The OECD plans to report the results of talks with these jurisdictions to …

Bulletin 36

UK: From April 2020, the UK government will introduce a new 2 per cent tax on the revenues of digital businesses that derive profits from their UK users, it was confirmed in the 2018 Autumn Budget statement. It will apply to UK annual revenues of more than GBP25 million generated from …