Financial Services Tax in Tax and Legal blog

New rules impacting foreign fund withholding tax exemption in Australia

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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.

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Posted on 8/10/2020 | 0 Comments

Are you relying on a consistent deferral of DAC6 reporting deadlines?

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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.

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Posted on 9/07/2020 | 0 Comments

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

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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.

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Posted on 28/04/2020 | 0 Comments

Recording available: Webcast on EU Mandatory Disclosure Regime (DAC6) – Next Steps

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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?

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Posted on 27/02/2020 | 0 Comments

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

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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.

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Posted on 3/01/2020 | 0 Comments

DAC6: Another regulatory headache for the trust and fiduciary industry?

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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.

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Posted on 26/11/2019 | 0 Comments

Doing FATCA Group Requests right: lessons learned and pitfalls to avoid

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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.

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Posted on 4/11/2019 | 0 Comments

Swiss Federal Council gives shape to the new Swiss withholding tax regime and proposes the abolishment of Swiss securities transfer tax on debt instruments

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After having informed about the key parameters of the planned Swiss withholding tax reform in June (see our prior blog post), the Swiss Federal Council agreed on further details during its meeting on 27 September 2019.

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Posted on 7/10/2019 | 0 Comments

BREAKING NEWS: Swiss-US double tax treaty protocol ratified and FATCA group requests expected at any time

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On 20 September 2019, the final step to bring the 2009 protocol to the Swiss-US double tax treaty into force was executed when government representatives exchanged the instruments of ratification. The protocol is applicable with immediate effect and among other things allows the IRS to make group requests under FATCA concerning non-consenting US accounts and non-consenting NPFFIs.

In this blog, we highlight the top 5 challenges and top 5 tips for a Swiss financial institution (FI) in anticipation of the FATCA group requests.

See our prior blog post to find out what other changes the protocol has brought.

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Posted on 23/09/2019 | 0 Comments

Global Trade Events in October 2019

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Our Global Trade Events - digitising customs documents and preference management were hosted on Thursday, 10 October 2019, Geneva and Tuesday, 29 October 2019, Zurich.

About the event:

Do you struggle to keep track of your customs documents such as proof of delivery or certificates of origin?

Many of you know the situation. Whenever there is an audit or the need to collect proof of delivery for a specific shipment or even worse, all shipments within a certain period, a cumbersome searching process begins. The complexity of product flows increases every day and the ability to manage the paperwork can not be neglected anymore.

Considering this, we designed Blockchain and SAP GTS based solutions to help you address and manage global trade-related documentary requirements. In a quick and streamlined way, you will have access to the respective documents, no matter how complex your sourcing, production or export processes are.

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Posted on 12/09/2019 | 0 Comments