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U.K. Announces First Payment Under Swiss Tax Agreement

The U.K. government has announced that it has received a CHF 500 million (about $ 543 million) payment from Switzerland, the first such payment agreed to under the agreement reached in October 2011. Chancellor of the Exchequer George Osborne announced the January 28 payment during a House of Commons...

U.S. Government's Patience With OVDP Holdouts Has Limits, Justice Official Says

The U.S. Justice Department Tax Division and the IRS will not forever offer criminal amnesty to taxpayers who continue to avoid reporting their undeclared offshore bank accounts, Kathryn Keneally, assistant attorney general for the Tax Division, said on January 29. Account holders should disclose their...

U.K. Lawmakers Attack Big 4 Accounting Firms in Push to Halt Profit Shifting

Members of Parliament, during a January 31 U.K. hearing, did their best to publicly shame representatives of Big Four accounting firms for devising schemes that help multinational corporations avoid U.K. tax. The latest Public Accounts Committee (PAC) hearing follows two high-profile hearings conducted...

Norway-U.S. Agreement Clarifies Treaty Eligibility for Disregarded Entities

The January 31 competent authority agreement between Norway and the United States expands on the fiscal residence provisions of the existing treaty to bring the language in line with recent treaties. The 1971 Norway-U.S. tax treaty (amended by a 1980 protocol and clarified by a 2012 competent authority...

U.S., Norway Sign FATCA Agreement; Spain Clears Way for Signing Its IGA

The United States and Norway on April 15 signed a reciprocal bilateral agreement setting out the Model I government-to-government approach to implementing the Foreign Account Tax Compliance Act, while the Spanish government authorized the signing of an intergovernmental agreement with the U.S. The Norway...

Anti-Evasion Initiative Meant to Create 'Peer Pressure' Among EU Members

As part of an EU-wide action plan to crack down on tax evasion and avoidance, the European Commission on April 23 created an expert group intended to monitor EU member states' progress and "serve as a source of strong peer pressure." ... [T]he Platform for Tax Good Governance, Aggressive...

EU Downplays Leaked Document Outlining Financial Transaction Tax Concerns

The European Commission has downplayed the significance of a leaked internal document outlining the concerns of the 11 EU member states that have agreed to introduce the proposed financial transaction tax (FTT), saying that the commission will address the concerns at an upcoming technical meeting on...

U.K.'s VAT Grouping Rules Comply With EU Law, ECJ Says

The European Court of Justice on April 25 held that U.K. rules allowing nontaxable persons to be members of a VAT group comply with the EU VAT Directive. The case, European Commission v. United Kingdom (C-486/11), is one of seven the European Commission referred to the ECJ in 2010 over the implementation...

ECJ Rules Against Spanish Exit Tax

The European Court of Justice on April 25 released its decision in Commission v. Spain (C-64/11), holding that the Spanish exit tax rules, which impose immediate taxation on the unrealized gains that have accrued in the Spanish territory before an exit to another EU member state, violate EU law because...

Contractual Terms Not Decisive for Identifying Supplier and Recipient in U.K. VAT Case, ECJ Says

The European Court of Justice on June 20 held in a U.K. VAT case that contractual terms may be taken into account but are not decisive for the purpose of identifying the supplier and recipient of a supply of services within the meaning of articles 2(1) and 6(1) of the Sixth VAT Directive. The case, HM...

Swiss to Unveil Proposal for Banks to Cooperate With U.S. to Solve Tax Disputes

The Swiss Federal Council on June 21 commissioned the Federal Department of Finance (FDF) to present a "solution" on June 26 or a week later to allow Swiss banks to cooperate with U.S. authorities to resolve outstanding tax disputes without breaking domestic bank secrecy laws, an FDF spokeswoman...

U.S. and U.K. Sign Revised Annex II to FATCA Agreement

The U.S. and U.K. governments recently agreed to replace the Annex II in the parties' September 2012 intergovernmental agreement to implement the U.S. Foreign Account Tax Compliance Act. The British Embassy sent a note with the proposed new Annex II to the U.S. State Department on June 3. The State...

Swiss Court Decision Expands Admissibility of Group Information Requests

A recent decision (A-6385/2012) by the Swiss Federal Administrative Court opens the door to "group" information requests covering past tax periods under the 1996 Switzerland-U.S. tax treaty and many other Swiss tax treaties. A group request is an administrative assistance request for information...