Exchange of Confidential Tax-Payer Information: No Name? No Problem

  The Swiss Supreme Court has provided some guidance on the ambit of a ‘fishing expedition’ under OECD provisions related to exchange of information; and set out in Article 26 of the OECD Model Tax Agreement. Since 2012, when the OECD Model was amended to reflect the current formulation of Article 26 on Exchange of … More Exchange of Confidential Tax-Payer Information: No Name? No Problem

OP-ED: Why Europe is Ill-Suited For The Business of Blacklisting So-Called ‘Non-Cooperative’ Jurisdictions.

I AM  NOT  A FAN OF THE  USE  OF UNILATERAL MEASURES IN international  diplomacy;  including the use of tax haven or other types of blacklists related  to  compliance  with global  norms   on   transparency  and information   exchange.  Although   we often think of this kind of state action in the context of armed conflict where there are … More OP-ED: Why Europe is Ill-Suited For The Business of Blacklisting So-Called ‘Non-Cooperative’ Jurisdictions.

ALERT: EU Issues Tax Haven Blacklist of 81 Countries Highly Likely to Facilitate Tax Avoidance

  The European Commission published on Thursday a list of 81 countries and jurisdictions that have a higher chance of facilitating tax avoidance and may be subject to further screening and even sanctions if all EU states agree. The “scoreboard” is the first step in a process that should be concluded next year with the first European … More ALERT: EU Issues Tax Haven Blacklist of 81 Countries Highly Likely to Facilitate Tax Avoidance

Ireland Must Recover 13 Billion Euros in Illegal State Aid to Apple.

The European Commission has today issued a press release confirming their finding that Ireland, granted undue tax benefits of up to €13 billion to Apple. This is illegal under EU state aid rules, because it allowed Apple to pay substantially less tax than other businesses. Ireland must now recover the illegal aid. Commissioner Margrethe Vestager, … More Ireland Must Recover 13 Billion Euros in Illegal State Aid to Apple.

FHA TAX ALERT – Barbados 2016 Budget

FRANHENDY ATTORNEYS TAX ALERT Growth Returns to the Barbados Economy. Trajectory is Not Assured. No Additional Direct Tax Measures to Support the International Business and Financial Services Sector (IBFSS). Emphasis on Public-Private Sector Partnership to Spur Growth in the IBFSS Summary of the  2016 Budgetary Proposals:  Removal of the imposition of duty on yachts remaining in Barbados … More FHA TAX ALERT – Barbados 2016 Budget