Financial Services Tax in Tax Blog
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Deloitte’s 2020 global survey on the OECD’s Base Erosion and Profit Shifting (BEPS) initiative shines a spotlight on the next wave of the Global Tax Reset. What are the key finding and impacts on the financial services industry?
Under Australian domestic law, eligible foreign pension funds deriving Australian source interest and dividend income are eligible for Australian withholding tax exemptions. The Australian government introduced new laws in early 2019 to amend the rules in respect of Australian withholding tax exemptions for foreign pension funds.
The initial reporting of certain cross border arrangements under DAC6 was scheduled for the end of July 2020. Shortly before the DAC6 go-live date, the EU agreed on an optional six-month extension. Approximately one week after the EU agreement, some countries have communicated their position, others are silent, and at least one is not intending to provide an extension. We are here to help you keep an overview of the individual countries’ positions.
The Swiss Federal Council published the consultation draft regarding the Swiss withholding tax reform and the abolishment of Swiss securities transfer tax on debt instruments
On 3 April 2020, the Swiss Federal Council released a proposed set of amendments to the Swiss withholding tax and securities transfer tax regimes. The reform primarily aims at strengthening the Swiss debt capital market and increasing tax honesty of Swiss resident individual investors.
The consultation period runs until 10 July 2020 and the rules will become effective as early as 2023.
Listen to the webcast EU Mandatory Disclosure Regime (DAC6) - Next Steps on Wednesday 18 March, 15.30 CET.
The 6th version of the EU Directive on administrative cooperation (DAC6) implements new mandatory disclosure rules for EU intermediaries and taxpayers in relation to certain arrangements. First reports will be required from July 2020 and the requirements apply to arrangements as far back as 25 June 2018. The timeline for compliance is very short and the penalties for non-compliance are high, so what response should your organisation have in place?
A never ending story: Additional delay of Sec. 871(m) implementation and publication of final regulations for Sec. 871(m), QI and FATCA around year end
On 16 December 2019, the IRS published Notice 2020-02 extending the transitional relief with respect to certain requirements under the Sec. 871(m) regime for another two years. This is good news for all financial institutions involved in the issuance, or trade, of financial instruments referencing US stock.
In addition, certain temporary provisions in the Sec. 871(m) regulations were finalised and published in the Federal Register on 17 December 2019. Similarly, final QI and FATCA regulations were published in the Federal Register on 2 January 2020. Overall, the regulations formalized pre-announced updates and there were no surprises.
The latest amendment to the EU’s Directive on Administrative Cooperation (DAC6) requires EU intermediaries (and in some cases relevant EU taxpayers) to report to their domestic tax authorities on potentially aggressive or abusive cross-border tax arrangements (reportable cross-border arrangements or RCBAs). In parallel, certain jurisdictions are implementing the OECD’s mandatory disclosure rules (MDR), which essentially apply to arrangements coming within the hallmark D category of DAC6.
This blog discusses the impact of DAC6 and the OECD MDR on the trust and fiduciary sector and is part of a series designed to help our clients react to the new regulatory requirements.
With the 2009 protocol to the Swiss-US double tax treaty ratified (see our prior blog post), the IRS can submit group requests under FATCA and Swiss Financial Institutions (FIs) should expect to receive, at any time, production orders from the Swiss Federal Tax Administration (SFTA). All affected Swiss FIs should be preparing now to be in a position to respond within the 10-day deadline stipulated in the IGA and the Swiss FATCA Law.
In this blog, we highlight the main issues we have observed in the market, which include areas where unexpected issues can arise or the workload tends to be underestimated.