TAX ALERT RESTRICTION OF THE TERRITORIAL SCOPE OF THE RELIBI REGIME MARCH
|
|
- Percival Bruce
- 5 years ago
- Views:
Transcription
1 TAX ALERT RESTRICTION OF THE TERRITORIAL SCOPE OF THE RELIBI REGIME MARCH ã 2017
2 I. INTRODUCTION : THE RELIBI REGIME The RELIBI ( Retenue à la source libératoire ) law of 23 December 2005 introduced a withholding tax (of 20% as from 1 January 2017) in full discharge of personal income tax on certain interest paid by paying agents established in Luxembourg to Luxembourg resident individuals (the RELIBI Regime ), similar to the whithholding tax operated under the EU Savings Directive 2003/48/EC (the EUSD ). With the aim of increasing attractiveness of Luxembourg for high net worth individuals the RELIBI Regime was extended by the law of 17 July 2008 to interest paid by non-luxembourg resident paying agents established in either (i) an EU Member State 1, (ii) an EEA Member State 2 or (iii) a State or territory having entered into an international agreement relating directly to the EUSD. The Circular RELIBI no 1 issued by the Luxembourg direct tax authorities on 4 February 2009 enumerates all countries concerned by the RELIBI Regime. Luxembourg resident individual taxpayers may thus elect for the RELIBI Regime on interest perceived from non-resident paying agent (as above mentioned) by filing the form 931F/931D duly completed. For the purposes of the RELIBI Regime the term interest means any interest an capital gains on debt claims including interest accrued on zero coupon bonds, sale proceeds on such bonds before maturity or payment of the coupon. Any savings income not falling within the scope of the RELIBI Regime (like e.g. savings on assets allocated to a professional activity) is subject to tax at the progressive income tax rate. II. THE LAW OF 23 JULY 2016 : LIMITATION TO THE RELIBI REGIME Further to the repeal of the EUSD by EU Directive 2015/2060 of 10 November 2015, the RELIBI Regime has been slightly amended by the law of 23 July 2016 so that the optional RELIBI regime is no more available to territories having entered into an international agreement relating directly to the EUSD. Even though the main provisions of the international agreements relating directly to the EUSD should be continued through the world-wide automatic exchange of information based on the common reporting standard (the CRS ), paying agents established in States and territories having entered such international agreements were removed from the ambit of the RELIBI Regime 3. The excluded States and territories (the Excluded Jurisdictions ) encompass (i) Andorra;; (ii) Anguilla;; (iii) Aruba;; (iv) British Virgin Islands;; (v) Caribbean Netherlands (i.e. Bonaire, Sint Eustatius and Saba);; (vi) Cayman Islands;; (vii) Curaçao;; (viii) Guernsey;; (ix) Isle 1 Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark, Croatia, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Malta, Netherlands, Poland, Portugal, Slovakia, Romania, Slovenia, Spain, Sweden and United Kingdom. 2 In addition to the EU Member States, Iceland, Liechtenstein and Norway. 3 The Luxembourg Chamber of Commerce issued on 10 May 2016 its opinion on the bill of law n o 6978 giving rise to the law of 23 July 2016, where it advocates against the exclusion of these States and territories and suggests to include at least all States and territories which have effectively conferred to Luxembourg the qualification of Reporting Jurisdiction in the sense and for the purposes of the CRS. 2
3 of Man;; (x) Jersey;; (xi) Monaco;; (xii) Montserrat;; (xiii) San Marino;; (xiv) Sint Maarten;;(xv) Switzerland;; and (xvi) Turks and Caicos Islands. 4 Surprisingly enough, although the implications are quite significant, the geographic restriction to the RELIBI Regime seems to have gone largely unnoticed by practitioners and paying agents alike. III. HOW WILL THIS CHANGE IMPACT CLIENTS? As the limitation of the RELIBI Regime s scope is applicable as from 1 January , the first withholding tax declarations (form 931F/931D) that are impacted are those for the 2016 fiscal year, which must be filed by the beneficial owners at the latest on 31 March As a result, for interest paid by paying agent established in one of the Excluded Jurisdictions, the option for the RELIBI Regime is not available to the resident individual taxpayer who must include his or her interest income in the general taxable base 6. It should be highlighted that an omission to declare such interest income may not only qualify as a simple tax fraud (fraude fiscale), which is (only) subject to administrative sanctions, but could also constitute, under certain conditions, an aggravated tax fraud (fraude fiscale aggravée) or a tax swindling (escroquerie fiscale), which are both criminal offences 7 and money laundering predicate offences 8. In cases where paying agents are located in the Excluded Jurisdictions, structuring solutions remain available since insofar an economic operator established in Luxembourg or any other EU/EEA Member States may be appointed as paying agent to benefit from the RELIBI Regime. In this respect, it is worthwhile to note that an economic operator acting purely in a passive way (e.g. a bank acting only as a depository bank or only transferring the interest) is not considered as a paying agent and will simply be disregarded in the chain of payers for the purposes of the RELIBI Regime. It may therefore be required in some instances to set up an intermediary entity in Luxembourg between the paying agent and the beneficial owner, such as a private wealth management company (société de gestion de patrimoine familial). Alternative solutions have to be analysed on a case-by-case basis. 4 The Circular RELIBI n o 1 issued by the Luxembourg direct tax authorities on 27 February 2017 enumerates all countries currently concerned by the RELIBI Regime, i.e. the countries mentioned under footnotes n os 1 and 2. 5 The law of 23 July 2016 has a so-called economic retroactive effect since it entered into force on 1 January 2016 and therefore impacts interest payments made prior to its adoption. This type of retroactive effect should nonetheless not be unconstitutional nor in breach of the principle of nonretroactivity of fiscal laws. 6 Which is subject to the progressive income tax rate capped at in 2016 and 2017 at respectively 43.6% and 45.78% (including the solidarity surcharge) and may therefore be subject to a higher rate than the current 20% withholding tax rate applicable to the RELIBI Regime. 7 Punished by fines and imprisonment. 8 Taking into consideration that all professionals, including tax counsels and lawyers, are subject to the obligations set out by the law of 23 December 2016 transposing the revised Financial Action Task Force standards of 2012 and 2013 and Directive 2015/849/EC of 20 May 2015 relating to the prevention of the financial system against money laundering and terrorist financing must take into account since 1 January 2017 the two predicate tax offences within the framework of their professional obligations (e.g. KYC requirements or cooperation with Luxembourg tax authorities). 3
4 For further information feel free to contact the following persons: GAËLLE FELLY PATRICK ANDERSSON *** BONN & SCHMITT IS A FULL SERVICE COMMERCIAL LAW FIRM THAT PRACTICES ALL ASPECTS OF BUSINESS LAW, WITH SPECIAL EXPERTISE IN: CORPORATE CORPORATE LAW MERGERS AND ACQUISITIONS CORPORATE FINANCE RESTRUCTURING TAX CORPORATE AND INTERNATIONAL TAX ADVISORY INDIRECT TAXES AND VAT TAX LITIGATION ESTATE PLANNING BANKING, CAPITAL MARKETS AND REGULATION BANKING AND FINANCE FINANCIAL SERVICES AND REGULATION CAPITAL MARKETS AND SECURITIES LAWS STRUCTURED FINANCE AND DERIVATIVES INVESTMENT MANAGEMENT AND PRIVATE EQUITY ASSET MANAGEMENT AND SERVICES INVESTMENT FUNDS ALTERNATIVE INVESTMENT FUNDS PRIVATE EQUITY INSURANCE AND REINSURANCE REGULATION AND LICENSING INSURANCE POLICIES LINKED PRODUCTS PROFESSIONAL LIABILITY INSURANCE DISPUTE RESOLUTION GENERAL AND COMMERCIAL LITIGATION IP AND TRADEMARK LITIGATION CORPORATE AND FINANCIAL LITIGATION MEDIATION AND ARBITRATION REAL ESTATE REAL ESTATE ACQUISITIONS REAL ESTATE INVESTMENT STRUCTURES 4
5 IP AND IT PROJECT FINANCE ENVIRONMENTAL LAW AND REGULATION INTELLECTUAL PROPERTY AND TRADEMARKS E-COMMERCE E-MONEY DATA PROTECTION INSOLVENCY AND RESTRUCTURING LOCAL INSOLVENCY AND REORGANIZATION CROSS-BORDER PROCEEDINGS REALIZATION OF SECURITY AND COLLATERAL REFINANCING AND RESTRUCTURING OF DEBT EMPLOYMENT AND BENEFITS INDIVIDUAL EMPLOYMENT LAW COLLECTIVE EMPLOYMENT LAW PARTICIPATION AND INCENTIVE SCHEMES LITIGATION 148, AVENUE DE LA FAÏENCERIE L-1511 LUXEMBOURG B.P. 522 L-2015 LUXEMBOURG TEL: FAX: Visit us at *** 5
FACT SHEET. Automatic exchange of information (AEOI)
FACT SHEET Automatic exchange of information (AEOI) In a joint statement, a number of countries, including all major financial centres and Liechtenstein, have announced that they will introduce the new
More informationTAX ALERT NEW CIRCULAR N O 45/2 152/1 168/1 ON THE WITHHOLDING TAX OF DIRECTOR FEES FEBRUARY
TAX ALERT NEW CIRCULAR N O 45/2 152/1 168/1 ON THE WITHHOLDING TAX OF DIRECTOR FEES FEBRUARY - 2017 ã2017 I. INTRODUCTION On 14 February 2017 the Luxembourg direct tax authorities (Administration des contributions
More informationTAX ALERT NEW CIRCULAR N 56/1 56BIS/1 ON THE TAX TREATMENT OF COMPANIES ENGAGED IN INTRA-GROUP FINANCING TRANSACTIONS JANUARY
TAX ALERT NEW CIRCULAR N 56/1 56BIS/1 ON THE TAX TREATMENT OF COMPANIES ENGAGED IN INTRA-GROUP FINANCING TRANSACTIONS JANUARY - 2017 ã2017 I. INTRODUCTION On 27 December 2016, the Luxembourg tax authorities
More informationFACT SHEET. Automatic exchange of information (AEOI)
FACT SHEET Automatic exchange of information (AEOI) In a joint statement, a number of countries, including all major financial centres and Liechtenstein, have announced that they will introduce the new
More informationThe European Union Savings Tax Directive. An historic guide
The European Union Savings Tax Directive An historic guide Do you have any questions? This guide will tell you more If you are resident in an EU Member State and earn interest on deposits or investments
More informationApproach to Employment Injury (EI) compensation benefits in the EU and OECD
Approach to (EI) compensation benefits in the EU and OECD The benefits of protection can be divided in three main groups. The cash benefits include disability pensions, survivor's pensions and other short-
More informationTAXATION (IMPLEMENTATION) (CONVENTION ON MUTUAL ADMINISTRATIVE ASSISTANCE IN TAX MATTERS) (AMENDMENT OF REGULATIONS No. 3) (JERSEY) ORDER 2017
Taxation (Implementation) (Convention on Mutual Regulations No. 3) (Jersey) Order 2017 Article 1 TAXATION (IMPLEMENTATION) (CONVENTION ON MUTUAL ADMINISTRATIVE ASSISTANCE IN TAX MATTERS) (AMENDMENT OF
More informationCOMPANY DETAILS FORM
FOR USE IN MAURITIUS COMPANY DETAILS FORM IMPORTANT: ALL SECTIONS MUST BE COMPLETED Name of proposed new entity: (if known) Name of applicant company: Company type: (please tick one box) Quoted on a stock
More information- Act Nr. XXXVII of 2013 on certain regulation connected with the international administrative cooperation on tax and other public burdens.
Dear Customer, The Hungarian Parliament introduced the Common Reporting Standards, CRS on the automatic financial data exchange with the effect of 01.01.2016. The aim of the regulation is to hinder the
More informationPARTNERSHIP DETAILS FORM
FOR USE IN SINGAPORE PARTNERSHIP DETAILS FORM IMPORTANT: ALL SECTIONS MUST BE COMPLETED Name of proposed new entity (if known) Name of applicant partnership Form of applicant partnership Partnership Limited
More informationAUTOMATIC EXCHANGE OF INFORMATION (AEOI)
AUTOMATIC EXCHANGE OF INFORMATION (AEOI) As the world becomes increasingly globalised, money can be transferred from one jurisdiction to another with ease. While this may help to facilitate trade and boost
More informationRev. Proc Implementation of Nonresident Alien Deposit Interest Regulations
Rev. Proc. 2012-24 Implementation of Nonresident Alien Deposit Interest Regulations SECTION 1. PURPOSE Sections 1.6049-4(b)(5) and 1.6049-8 of the Income Tax Regulations, as revised by TD 9584, require
More informationTRUST AND SETTLEMENT DETAILS FORM
FOR USE IN CAYMAN, DUBLIN AND JERSEY TRUST AND SETTLEMENT DETAILS FORM IMPORTANT: ALL SECTIONS MUST BE COMPLETED Name of proposed new entity: (if known) Name of trust: Date trust established: Proper law
More informationWhen will CbC reports need to be filled?
Who will be subject to CbCR? Country by Country Reporting (CbCR) applies to multinational companies (MNCs) with a combined revenue of euros 750 million or more When will CbC reports need to be filled?
More informationCOMPANY DETAILS FORM
FOR USE IN JERSEY COMPANY DETAILS FORM IMPORTANT: ALL SECTIONS MUST BE COMPLETED Name of proposed new entity: (if known) Name of applicant company: Company type: (please tick one box) Quoted on a stock
More informationFATCA: Developments & perspectives
FATCA: Developments & perspectives Automatic Exchange of Information 22 May 2014 FATCA evolves into CRS a multilateral automatic exchange of information 2010 The Foreign Account Tax Compliance Act (FATCA)
More informationTAXATION (IMPLEMENTATION) (INTERNATIONAL TAX COMPLIANCE) (COMMON REPORTING STANDARD) (JERSEY) REGULATIONS 2015
Arrangement TAXATION (IMPLEMENTATION) (INTERNATIONAL TAX COMPLIANCE) (COMMON REPORTING STANDARD) (JERSEY) REGULATIONS 2015 Arrangement Regulation 1 Interpretation... 3 2 Meaning of relevant date and relevant
More informationSpain France. England Netherlands. Wales Ukraine. Republic of Ireland Czech Republic. Romania Albania. Serbia Israel. FYR Macedonia Latvia
Germany Belgium Portugal Spain France Switzerland Italy England Netherlands Iceland Poland Croatia Slovakia Russia Austria Wales Ukraine Sweden Bosnia-Herzegovina Republic of Ireland Czech Republic Turkey
More informationArgentina Tax amnesty: the day after
Argentina Tax amnesty: the day after Walter C. Keiniger December 2016 YES to amnesty: exchange of Information DTTs (Art. 26 OECD Model) Provisions or agreements signed by Argentina Bilateral Agreements
More informationConvention on Mutual Administrative Assistance in Tax Matters
Convention on Mutual Administrative Assistance in Tax Matters Strasbourg, 25.I.1988 Annex B Competent authorities (*) European Treaty Series - No. 127 States From A to F Albania Argentina Australia Austria
More informationReport Penalties and measures imposed under the UCITS Directive in 2016 and 2017
Report Penalties and measures imposed under the Directive in 206 and 207 4 April 209 ESMA34-45-65 4 April 209 ESMA34-45-65 Table of Contents Executive Summary... 3 2 Background and relevant regulatory
More informationTHE COMMON REPORTING STANDARD ("CRS") UPDATE FOR OCORIAN CLIENTS
JERSEY BRIEFING November 2015 THE COMMON REPORTING STANDARD ("CRS") UPDATE FOR OCORIAN CLIENTS At present 93 countries will implement CRS over a two year period commencing 1 January 2016. The CRS initiative
More informationIRS Reporting Rules. Reference Guide. serving the people who serve the world
IRS Reporting Rules Reference Guide serving the people who serve the world The United States has and continues to maintain a policy of not taxing the deposit interest earned by United States (US) nonresidents
More informationIntercontinental Trust Ltd COMMON REPORTING STANDARD
Intercontinental Trust Ltd COMMON REPORTING STANDARD 1 Conspectus The OECD, working in collaboration with G20 and in close co-operation with the EU, has developed a global standard for automatic exchange
More informationConvention on Mutual Administrative Assistance in Tax Matters as amended by the 2010 Protocol
European Treaty Series - No. 127 Convention on Mutual Administrative Assistance in Tax Matters as amended by the 2010 Protocol Strasbourg, 1.VI.2011 Annex B Competent authorities (*) States From A to F
More informationFATCA Update May 2014
www.pwc.com The Basics Foreign Account Tax Compliance Act Purpose of Prevent and detect offshore tax evasion by US citizens Increased information reporting Enforced by withholding tax Effective begins
More informationLEGAL ALERT LUXEMBOURG UPCOMING TAX CHANGES NOVEMBER
LEGAL ALERT LUXEMBOURG UPCOMING TAX CHANGES NOVEMBER - 2017 ã2017 I. INTRODUCTION The major tax changes expected in Luxembourg in the coming months are introduced by five different sets of legislation.
More informationEU-28 RECOVERED PAPER STATISTICS. Mr. Giampiero MAGNAGHI On behalf of EuRIC
EU-28 RECOVERED PAPER STATISTICS Mr. Giampiero MAGNAGHI On behalf of EuRIC CONTENTS EU-28 Paper and Board: Consumption and Production EU-28 Recovered Paper: Effective Consumption and Collection EU-28 -
More informationCOSTAS TSIELEPIS & CO LTD
COSTAS TSIELEPIS & CO LTD TAX UPDATE Authored By: ALEXIS TSIELEPIS, Director, Head of Taxation VOLUME 5, ISSUE 2 knowledge Facts, information and skills acquired through experience or education; the theoretical
More informationUPDATE. COMMON REPORTING STANDARD IN THE CAYMAN ISLANDS. What is CRS? Participating Jurisdictions
www.kensington-trust.com UPDATE COMMON REPORTING STANDARD IN THE CAYMAN ISLANDS The Cayman Islands Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations, 2015
More informationDG TAXUD. STAT/11/100 1 July 2011
DG TAXUD STAT/11/100 1 July 2011 Taxation trends in the European Union Recession drove EU27 overall tax revenue down to 38.4% of GDP in 2009 Half of the Member States hiked the standard rate of VAT since
More informationMEXICO - INTERNATIONAL TAX UPDATE -
TTN Conference May 2017 MEXICO - INTERNATIONAL TAX UPDATE - Arturo G. Brook Main Taxes Income Tax Value Added Tax Others Agenda DTTs and TIEAs FATCA (IGA) and CRS Choice of Vehicles Income Tax - General
More informationHow to complete a payment application form (NI)
How to complete a payment application form (NI) This form should be used for making a payment from a Northern Ireland Ulster Bank account. 1. Applicant Details If you are a signal number indemnity holder,
More informationEUROPA - Press Releases - Taxation trends in the European Union EU27 tax...of GDP in 2008 Steady decline in top corporate income tax rate since 2000
DG TAXUD STAT/10/95 28 June 2010 Taxation trends in the European Union EU27 tax ratio fell to 39.3% of GDP in 2008 Steady decline in top corporate income tax rate since 2000 The overall tax-to-gdp ratio1
More informationLowest implicit tax rates on labour in Malta, on consumption in Spain and on capital in Lithuania
STAT/13/68 29 April 2013 Taxation trends in the European Union The overall tax-to-gdp ratio in the EU27 up to 38.8% of GDP in 2011 Labour taxes remain major source of tax revenue The overall tax-to-gdp
More informationLuxembourg Country Profile
Luxembourg Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Luxembourg EU Member State Yes Double Tax Treaties With: Albania (a) Andorra
More informationSTANDARD FOR AUTOMATIC EXCHANGE OF FINANCIAL ACCOUNT INFORMATION. Philip Kerfs, OECD
STANDARD FOR AUTOMATIC EXCHANGE OF FINANCIAL ACCOUNT INFORMATION Philip Kerfs, OECD Overview Background, context and timeline The Standard: basic approach and key features Next steps: implementing the
More informationEntitlement to NHS Hospital Treatment for Non-Resident UK Citizens
Entitlement to NHS Hospital Treatment for Non-Resident UK Citizens Entitlement to Free NHS Hospital Treatment by Non-Resident UK Citizens This leaflet has been compiled to explain the entitlement requirements
More informationTax certification for Entities FATCA and CRS
Schroder Investment Management Australia Limited Level 20, Angel Place 123 Pitt Street Sydney, NSW 2000 www.schroders.com.au AFSL 226473 ABN 22 000 443 274 Tax certification for Entities FATCA and CRS
More informationWebinar: Common Reporting Standard. Game Plan for Compliance December 10, 2015
Webinar: Common Reporting Standard Game Plan for Compliance December 10, 2015 Presenters Moderator: Sara Pereda Director DMS Offshore Investment Services Roman Ipfling Director DMS International Tax Compliance
More informationTaxation trends in the European Union Further increase in VAT rates in 2012 Corporate and top personal income tax rates inch up after long decline
STAT/12/77 21 May 2012 Taxation trends in the European Union Further increase in VAT rates in 2012 Corporate and top personal income tax rates inch up after long decline The average standard VAT rate 1
More informationSummary of key findings
1 VAT/GST treatment of cross-border services: 2017 survey Supplies of e-services to consumers (B2C) (see footnote 1) Supplies of e-services to businesses (B2B) 1(a). Is a non-resident 1(b). If there is
More informationIceland Country Profile
Iceland Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Iceland EU Member State No, however, Iceland is a Member State of the European
More informationSAINT CHRISTOPHER AND NEVIS STATUTORY RULES AND ORDERS. No. 32 of 2016
1 SAINT CHRISTOPHER AND NEVIS STATUTORY RULES AND ORDERS No. 32 of 2016 Common Reporting Standard (Automatic Exchange of Financial Account Information) Regulations The Minister, in exercise of the powers
More informationEU BUDGET AND NATIONAL BUDGETS
DIRECTORATE GENERAL FOR INTERNAL POLICIES POLICY DEPARTMENT ON BUDGETARY AFFAIRS EU BUDGET AND NATIONAL BUDGETS 1999-2009 October 2010 INDEX Foreward 3 Table 1. EU and National budgets 1999-2009; EU-27
More informationEuropean Advertising Business Climate Index Q4 2016/Q #AdIndex2017
European Advertising Business Climate Index Q4 216/Q1 217 ABOUT Quarterly survey of European advertising and market research companies Provides information about: managers assessment of their business
More informationFOREIGN INSURERS AND REINSURERS DOING BUSINESS IN THE UK AND EUROPE: SETTING THE 1 RECO
FOREIGN INSURERS AND REINSURERS DOING BUSINESS IN THE UK AND EUROPE: SETTING THE RECORD STRAIGHT WTO/GATS Agreement (FORC Journal: Vol. 19 Edition 1 - Spring 2008) Richard Spiller, Esq. 011 44 20 7556
More information55/2005 and 78/2005 Convention on automatic exchange of information
INCOME TAX TREATIES AND AGREEMENTS ON THE TAXATION OF INCOME FROM SAV- INGS (IN FORCE, SIGNED, INITIALLED OR IN NEGOTIATING PROCESS, SITUATION ON 25th April 2018) Country Year of conclusion Number in the
More informationAttorneys at Law. 11th Annual International Estate Planning Institute New York City, 12 & 13 March 2015
FATCA Implementation Attorneys at Law 11th Annual International Estate Planning Institute New York City, 12 & 13 March 2015 Presenters: Anthony Cetta: Citi Trust Wealth Planner, Citigroup (New York, NY)
More informationFSMA_2017_05-01 of 24/02/2017
FSMA_2017_05-01 of 24/02/2017 This Communication is addressed to Belgian alternative investment fund managers who intend to market, to professional investors, units or shares of European Economic Area
More informationin this web service Cambridge University Press
PART I 1 Community rules applicable to the incorporation and capital of public limited liability companies dirk van gerven NautaDutilh I II III IV V VI VII VIII IX X XI XII Introduction Application Scope
More informationGENERAL ANTI AVOIDANCE RULE RECENT CASE LAW IN ARGENTINA
GENERAL ANTI AVOIDANCE RULE RECENT CASE LAW IN ARGENTINA Leandro M. Passarella Passarella Abogados TTN Conferences Latin America 2014 Buenos Aires November 17, 2014 Background Past structures Case Law
More informationTax Newsflash January 31, 2014
Tax Newsflash January 31, 2014 Luxembourg s New Double Tax Treaties As of 1 January 2014, Luxembourg further enlarged its double tax treaty network with the entry into force of the new double tax treaties
More informationEIOPA Statistics - Accompanying note
EIOPA Statistics - Accompanying note Publication references: Published statistics: [Balance sheet], [Premiums, claims and expenses], [Own funds and SCR] Disclaimer: Data is drawn from the published statistics
More informationGDPR AND THE LEGAL IMPLICATIONS
GDPR AND THE LEGAL IMPLICATIONS Thursday 22 March 2018 Speakers: Simon Franckel (Oben Law) Alexandra Ruddy (Oben Law) Q & A Chair: Henry Wickham (Bedell Cristin) STEP Jersey is sponsored by: GDPR and the
More informationOECD Common Reporting Standard Getting into the Detail STEP / GAT
OECD Common Reporting Standard Getting into the Detail STEP / GAT Jo Huxtable Martin Popplewell 11 February 2016 Agenda Introduction CRS and the wider regulatory environment CRS latest developments and
More informationEIOPA Statistics - Accompanying note
EIOPA Statistics - Accompanying note Publication reference: Published statistics: [Balance sheet], [Premiums, claims and expenses], [Own funds and SCR] Disclaimer: Data is drawn from the published statistics
More informationLENDING FACILITIES Hire Purchase (HP) 1% % on a case by case basis (fee set by AgriFinance Ltd)
Our Charges This brochure gives a brief description of tariffs as charged by AgriBank plc on some of its products and services. For tariffs on products or services which are not listed in this brochure,
More informationGlobal Forum on Transparency and Exchange of Information for Tax Purposes. Statement of Outcomes
Global Forum on Transparency and Exchange of Information for Tax Purposes Statement of Outcomes 1. On 25-26 October 2011, over 250 delegates from 84 jurisdictions and 9 international organisations and
More information2.2. Eligibility for the Service. The Client understands and agrees that in order to be able to use the Service:
SATABANK SEPA DIRECT DEBIT CREDITOR SERVICE Effective as of: 15 th June 2017 This Schedule applies to SEPA Direct Debit payments, which the Client of Satabank makes in the capacity of Creditor (payee)
More informationLive Long and Prosper? Demographic Change and Europe s Pensions Crisis. Dr. Jochen Pimpertz Brussels, 10 November 2015
Live Long and Prosper? Demographic Change and Europe s Pensions Crisis Dr. Jochen Pimpertz Brussels, 10 November 2015 Old-age-dependency ratio, EU28 45,9 49,4 50,2 39,0 27,5 31,8 2013 2020 2030 2040 2050
More informationAlter Domus LUXEMBOURG
WE RE WHERE YOU NEED US. Alter Domus is a fully integrated Fund and Corporate services provider, dedicated to international private equity & infrastructure houses, real estate firms, multinationals, private
More informationTAX TRANSPARENCY THE NEW GLOBAL REPORTING STANDARD
TAX TRANSPARENCY THE NEW GLOBAL REPORTING STANDARD 2 TAX TRANSPARENCY THE NEW GLOBAL REPORTING STANDARD A COMMON REPORTING STANDARD ACROSS THE WORLD The goalposts in international tax reporting are moving
More informationAIG Europe Limited to American International Group UK Limited and AIG Europe SA
Proposed insurance business transfer scheme by: AIG Europe Limited to American International Group UK Limited and AIG Europe SA under Part VII of the Financial Services and Markets Act 2000 Scheme Booklet
More informationTHE MULTILATERAL CONVENTION ON MUTUAL ADMINISTRATIVE ASSISTANCE IN TAX MATTERS AND THE PATH TO THE OECD-STANDARD ON AUTOMATIC EXCHANGE OF INFORMATION
THE MULTILATERAL CONVENTION ON MUTUAL ADMINISTRATIVE ASSISTANCE IN TAX MATTERS AND THE PATH TO THE OECD-STANDARD ON AUTOMATIC EXCHANGE OF INFORMATION Dr. Achim Pross Head of International Cooperation and
More informationEIOPA Statistics - Accompanying note
EIOPA Statistics - Accompanying note Publication references: and Published statistics: [Balance sheet], [Premiums, claims and expenses], [Own funds and SCR] Disclaimer: Data is drawn from the published
More information2.2. The client understands and agrees that in order to execute payments by SEPA direct debit:
SATABANK SEPA DIRECT DEBIT DEBTOR SERVICE Approved by BoD of Satabank: 9 th of August, 2016 This Schedule applies to SEPA Direct debit payments, which the Client of Satabank makes as a Debtor (payer) to
More informationPurpose of this form. If you are an Appointed Representative ( AR ) then this form must be completed by the sponsoring firm on your behalf.
FIRM NAME: FRN: Passporting Notification of intention to provide cross border services in another EEA state INSURANCE DISTRIBUTION DIRECTIVE (SUP 13 Annex 5R Notification under SUP 13.5.2R) Purpose of
More informationYou may find it useful to view the UK social and labour law summary overview (PDF, 99kb, 24 pages).
Document library In this section Cross-border schemes Relevant for: Employers - Prof essionals - T rustees Summary: This guidance sets out the application process for authorisation and approval from the
More informationAPA & MAP COUNTRY GUIDE 2017 DENMARK
APA & MAP COUNTRY GUIDE 2017 DENMARK Managing uncertainty in the new tax environment DENMARK KEY FEATURES Competent authority Danish Tax Office ( SKAT ) APA provisions/ guidance Types of APAs available
More informationREPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS
EUROPEAN COMMISSION Brussels,.4.29 COM(28) 86 final/ 2 ANNEXES to 3 ANNEX to the REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE
More informationa closer look GLOBAL TAX WEEKLY ISSUE 249 AUGUST 17, 2017
GLOBAL TAX WEEKLY a closer look ISSUE 249 AUGUST 17, 2017 SUBJECTS TRANSFER PRICING INTELLECTUAL PROPERTY VAT, GST AND SALES TAX CORPORATE TAXATION INDIVIDUAL TAXATION REAL ESTATE AND PROPERTY TAXES INTERNATIONAL
More informationInnovFin SME Guarantee
InnovFin SME Guarantee Implementation Update Reporting date: 30/09/2017 Disclaimer This presentation contains general information about the implementation results of InnovFin SME Guarantee, a facility
More informationEU State aid: Guidelines on State aid for environmental protection and energy making of -
EU State aid: Guidelines on State aid for environmental protection and energy 2014-2020 - making of - NHO Seminar Oslo, 5 November 2014 Guido Lobrano, Senior Legal Adviser Summary What is BUSINESSEUROPE?
More informationFCCC/SBI/2010/10/Add.1
United Nations Framework Convention on Climate Change Distr.: General 25 August 2010 Original: English Subsidiary Body for Implementation Contents Report of the Subsidiary Body for Implementation on its
More informationEligibility? Activities covered? Clients covered? Application or notification required? N/A N/A N/A N/A N/A N/A N/A
NO DEAL BREXIT TRACKER Governments in European Economic Area (EEA) member states are announcing domestic measures in order to prepare for the UK's withdrawal from the EEA. The table below monitors these
More informationElectricity & Gas Prices in Ireland. Annex Business Electricity Prices per kwh 2 nd Semester (July December) 2016
Electricity & Gas Prices in Ireland Annex Business Electricity Prices per kwh 2 nd Semester (July December) 2016 ENERGY POLICY STATISTICAL SUPPORT UNIT 1 Electricity & Gas Prices in Ireland Annex Business
More informationUPSTREAM SECURITY IN EUROPE. A concise overview of the issues arising in connection with the granting and taking of Upstream Security in Europe
UPSTREAM SECURITY IN EUROPE A concise overview of the issues arising in connection with the granting and taking of Upstream Security in Europe 1 Table of Contents Introduction 5 1. Increase in Cross-Border
More informationLENDING FACILITIES Hire Purchase (HP) 1% % on a case by case basis (fee set by AgriFinance Ltd)
Our Charges This brochure gives a brief description of tariffs as charged by AgriBank plc on some of its products and services. For tariffs on products or services which are not listed in this brochure,
More informationCOMMISSION OF THE EUROPEAN COMMUNITIES COMMISSION STAFF WORKING DOCUMENT. Annex to the
COMMISSION OF THE EUROPEAN COMMUNITIES Brussels, 19122006 SEC(2006) 1690 COMMISSION STAFF WORKING DOCUMENT Annex to the COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN PARLIAMENT AND THE
More informationTerms and Conditions for Payments by Direct Debit under the SEPA Core Direct Debit Scheme
Terms and Conditions for Payments by Direct Debit under the SEPA Core Direct Debit Scheme Payments which the customer makes to payees (creditors) by SEPA core direct debit through his/her account with
More informationBACKGROUND 1 ECONOMIC and FINANCIAL AFFAIRS COUNCIL Tuesday 4 March in Brussels
Brussels, 29 February 2008 BACKGROUND 1 ECONOMIC and FINANCIAL AFFAIRS COUNCIL Tuesday 4 March in Brussels The Council will be preceded as usual by a meeting of the eurogroup, on Monday, 3 March, starting
More informationA. INTRODUCTION AND FINANCING OF THE GENERAL BUDGET. EXPENDITURE Description Budget Budget Change (%)
DRAFT AMENDING BUDGET NO. 2/2018 VOLUME 1 - TOTAL REVENUE A. INTRODUCTION AND FINANCING OF THE GENERAL BUDGET FINANCING OF THE GENERAL BUDGET Appropriations to be covered during the financial year 2018
More informationDividends from the EU to the US: The S-Corp and its Q-Sub. Peter Kirpensteijn 23 September 2016
Dividends from the EU to the : The S-Corp and its Q-Sub Peter Kirpensteijn 23 September 2016 The Inc: large multinational manufacturing company residents The LLC: holding company owned by tax residents
More informationStarting a branch ESTABLISHMENT GUIDE
Starting a branch ESTABLISHMENT GUIDE Business Sweden, April 2018 STARTING A BRANCH ESTABLISHMENT GUIDE A foreign-based company can begin business activities in Sweden without opening a subsidiary by starting
More informationDefining Issues. EU Audit Reforms: The Countdown Begins. April 2016, No Key Facts for U.S. Companies
Defining Issues April 2016, No. 16-12 EU Audit Reforms: The Countdown Begins Only two months remain before the European Union (EU) audit reforms come into full effect. These reforms will affect many U.S.
More informationMalta Country Profile
Malta Country Profile EU Tax Centre June 2018 Key tax factors for efficient cross-border business and investment involving Malta EU Member State Yes. Double Tax Treaties With: Albania Andorra Australia
More informationMalta Country Profile
Malta Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Malta EU Member State Yes. Double Tax Treaties With: Albania Australia Austria
More informationRSM AND HFMWEEK CRS/FATCA SURVEY HOW DO FUNDS INTEND TO ADDRESS CRS AND FATCA COMPLIANCE CHALLENGES?
RSM AND HFMWEEK CRS/FATCA SURVEY HOW DO FUNDS INTEND TO ADDRESS CRS AND FATCA COMPLIANCE CHALLENGES? During the third quarter of 2016, RSM and Hedge Fund Management Week (HFMWeek) surveyed chief operating
More informationDefinition of Public Interest Entities (PIEs) in Europe
Definition of Public Interest Entities (PIEs) in Europe FEE Survey October 2014 This document has been prepared by FEE to the best of its knowledge and ability to ensure that it is accurate and complete.
More informationA guide to FACTA and the new Common Reporting Standard. For advisers use only.
A guide to FACTA and the new Common Reporting Standard For advisers use only. Contents 01 Introduction 01 Background 02 How are we complying with FACTA in the UK? 02 How are we complying with FACTA in
More informationVinodh & Muthu. Tax Alert. Insight. Chartered Accountants. Country by Country Reporting & Master File
Vinodh & Muthu Chartered Accountants Tax Alert Country by Country Reporting & Master File Insight The Organisation for Economic Cooperation and Development ( OECD ) report on Action 13 of Base Erosion
More information11 th Economic Trends Survey of the Impact of Economic Downturn
11 th Economic Trends Survey 11 th Economic Trends Survey of the Impact of Economic Downturn 11 th Economic Trends Survey COUNTRY ANSWERS Austria 155 Belgium 133 Bulgaria 192 Croatia 185 Cyprus 1 Czech
More informationBorderline cases for salary, social contribution and tax
Version Abstract 1 (5) 2015-04-21 Veronica Andersson Salary and labour cost statistics Borderline cases for salary, social contribution and tax (Workshop on Labour Cost Survey, Rome, Italy 5-6 May 2015)
More informationSecond SHA2011-based pilot data collection 2014
EUROPEAN COMMISSION EUROSTAT Directorate F: Social statistics Unit F-5: Education, health and social protection DOC 2013-PH-06 Annex 3 Second SHA2011-based pilot data collection 2014 Item 6.2.3 of the
More informationFiscal rules in Lithuania
Fiscal rules in Lithuania Algimantas Rimkūnas Vice Minister, Ministry of Finance of Lithuania 3 June, 2016 Evolution of National and EU Fiscal Regulations Stability and Growth Pact (SGP) Maastricht Treaty
More informationComposition of capital IT044 IT044 POWSZECHNAIT044 UNIONE DI BANCHE ITALIANE SCPA (UBI BANCA)
Composition of capital POWSZECHNA (in million Euro) Capital position CRD3 rules A) Common equity before deductions (Original own funds without hybrid instruments and government support measures other than
More informationCross-border mergers and divisions
Cross-border mergers and divisions Cross-border mergers and divisions Consultation by the European Commission, DG MARKT INTRODUCTION Preliminary Remark The purpose of this questionnaire is to collect information,
More informationLithuania Country Profile
Lithuania Country Profile EU Tax Centre June 2017 Key tax factors for efficient cross-border business and investment involving Lithuania EU Member State Yes Double Tax Treaties With: Armenia Austria Azerbaijan
More informationAudit guidelines Mini One-Stop Shop for telecom, broadcasting and electronic services
24 June 2014 Indirect Tax Alert VAT no. 524 Audit guidelines Mini One-Stop Shop for telecom, broadcasting and electronic services Audit guidelines Mini One-Stop Shop for telecom, broadcasting and electronic
More information