Federal Council objects again to Germany-Switzerland tax agreement

On 1 February 2013, the Federal Council (Bundesrat) refused again to approve the Germany-Switzerland tax agreement signed on 21 September 2011, concerning the future tax treatment of capital investment income and past undeclared funds (see Germany-3, News 27 November 2012). Previously, on 17 January 2013, the Lower House of the German parliament (Bundestag) rejected the […]

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Russia-Cyprus, Russian Appeal Court decided on applicability of beneficial owner and economic substance requirements

On 5 December 2012, the Appeal Court heard case No. ?40-60755/12-20-388 between the Russian branch of Eastern Value Partners Ltd. (EVP Co.), a company resident in Cyprus, and the tax authorities. The tax authorities denied the applicability of the Cyprus - Russia Income and Capital Tax Treaty (1998) on the grounds that the conditions regarding […]

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Italy, Iceland included in white list

On 25 January 2013, the Ministerial Decree of 11 January 2013 was published in the Official Gazette No. 21. The Decree amends article 1 of the Ministerial Decree of 4 September 1996 to include Iceland in the list of countries which fulfil the exchange of information requirements (the "white list"). The inclusion of Iceland derives […]

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France - Tax credit: Reduction of the overall amount of tax credits in 2013

According to the Finance Law for 2013 (Loi de finances pour 2013, LF 2013), the cap for the overall amount of tax credits (under article 200-0 A of the French Tax Code) for 2013 is EUR 10.000. In 2012, the cap for the overall amount of tax credits was EUR 18.000 + 4% of the […]

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UK - Non-standard treaty tie-breaker rules for company residence - guidelines published

On 14 January 2013, HM Revenue & Customs (HMRC) published new section INTM120085 of the International Manual on company residence, providing clarification on non-standard treaty tie-breaker rules. According to certain double taxation agreements, e.g. Canada - United Kingdom Income Tax Treaty (1978), Netherlands - United Kingdom Income Tax Treaty (2008) and United Kingdom - United […]

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