Financial Services Tax in Tax and Legal blog
Same but different: a comparison of the OECD CARF and the EU DAC8 proposal
The emergence and rise of alternative methods of payment and investments such as crypto-assets and e-money has heightened global regulators’ interest. This has prompted the publication of various proposals and frameworks to ensure that the recent gains on tax transparency do not get lost and due taxes are paid.
Deloitte Finance Day 2023 - The colours of finance - design your future capability - 1 June 2023 in Zurich
Join our OECD Pillar II webinar on 15 February 2023, 4.00pm
The implementation of the Global Minimum Tax (“OECD Pillar II”) experienced a significant push towards reality in late December 2022, which included:
- The European Union adopting the directive requiring members to transpose it into domestic legislation
- Switzerland completing the parliamentary process on its change of constitution
- The OECD`s publishing a number of papers to guide the GloBE implementation (in particular: safe harbours, information return and tax certainty)
To navigate these developments we are organising a keynote webinar on Wednesday 15, February 2023 from 4.00 to 5.30pm to discuss these and other topics.
South Korea: First Country to pass the domestic Global Minimum Tax legislation
On 23 December 2022, the Korean National Assembly officially passed the 2022 Tax Revision Bill originally announced by the Ministry of Economy and Finance back in July 2022.
This is a pivotal moment in the advancement of the global minimum tax “Pillar Two” as South Korea is the first country to codify the GloBE Rules into domestic legislation. The newly passed law provides that a global minimum tax will be introduced from fiscal years beginning on or after 1 January 2024.
Proposed changes to the Qualified Intermediary agreement introduce burdensome requirements to collect US TINs
This blog is the second of a two-part series and discusses the due diligence challenge linked to a Qualified Intermediary (QI) holding Publicly Traded Partnership (PTP) interests in custody for non-US investors as of 1 January 2023 when the new PTP withholding regulations come into force: the collection of non-US investors’ US TINs for purposes of §1446(a) and §1446(f).
You can access here our first blog in this series which addressed QI difficulties in complying with electronic reporting obligations via FIRE due to new US TIN requirements introduced for identity verification purposes.
Deloitte's Tax practice strengthens its capabilities for financial services, banking and insurance clients with two new key partners
Deloitte Switzerland is delighted to announce that two new partners, Ilan Rom and Petrit Ismajli, will join its Financial Services Tax team on 1 December. This intake marks the continued strategic expansion of Deloitte`s tax-related services and capabilities for clients across the banking, insurance and investment management sectors.
First EU member state issues Pillar II draft legislation
On Monday 24 October 2022 the Netherlands published draft legislation, including commentary, relating to the domestic implementation of the global minimum tax (“Pillar II”). Essentially the draft legislation closely follows the OECD’s Pillar II Model Rules as well as the EU’s Pillar II directive proposal, containing the Income Inclusion Rule (“IIR”), Undertaxed Profits Rule (“UTPR”) and a Qualified Domestic Minimum Top-up Tax (“QDMTT”). It is expected that the IIR and QDMTT will come into effect for in-scope groups that have financial years starting on or after 31 December 2023. The draft legislation is open for public consultation until 5 December 2022.
Join our Financial Services tax webinar on 9 November 2022 at 08:30 to discuss legislative developments, court cases and practice
We would like to invite you to our half yearly webinar where we provide key updates and discuss recent tax developments that are important for the financial services industry on Wednesday 9 November 2022 at 08:30.
Swiss withholding tax - status quo, or is it?
On Sunday, 25 September 2022, the Swiss population rejected the withholding tax reform that sought to
- abolish withholding tax on Swiss bond interest payments
- partially abolish withholding tax on interest on bank accounts
- abolish securities transfer tax on the trading of Swiss bonds
The intention of the reform was to promote the Swiss debt capital market. Though the rejection of the reform means no legislative change, the current environment is rapidly changing with rising interest rates around the globe. In our view, it is therefore time to remind market players of what they need to consider with regard to withholding tax when issuing or trading Swiss bonds. A particular focus is made in this blog on the relevance of withholding tax in derivative transactions with notional Swiss bonds.
Public Vote Confirmed Swiss VAT Rate Increase and Rejected the Reform of Withholding Tax – What’s ahead?!
VAT rate changes in Switzerland are quite common, mainly to finance “governmental projects”. The last VAT rate change took place in 2018. Based on our past experiences, we would generally expect the Swiss Federal Tax Administration (“SFTA”) to set transition rules covering both the tax point and resulting invoicing, as well as reporting rules. The key aspects mentioned hereinafter (subject to final publication and confirmation) will have to be considered from VATable persons in Switzerland.