The DOJ’s Swiss Bank Program – Lessons Learned and the Road Ahead

Earlier this year, the US Department of Justice (DOJ) entered into its 80th, and final, non-prosecution agreement with a Swiss bank as part of its groundbreaking program to combat offshore tax evasion in Switzerland and beyond.

Tax Police Will No Longer Be Able to Institute Tax Evasion Criminal Investigations before...

The State Fiscal Service of Ukraine introduced amendments to the Order of State Fiscal Service of Ukraine with a view to reforming the procedures for instituting the tax evasion criminal investigations.

Dutch Supreme Court questions compatibility of fiscal unity regime with EU Law

The Dutch Supreme Court referred questions for a preliminary ruling to the European Court of Justice, asking whether certain elements of the Dutch fiscal unity regime should also be available to Dutch resident companies with a 95% or more EU resident parent, subsidiary or sister company which can not be part of a Dutch fiscal unity due to the geographical restrictions of the fiscal unity regime.

Tax in the Real World

The UK Supreme Court has held that HM Revenue & Customs were correct to interpret tax legislation to ignore arrangements without a "business or commercial purpose". This prevented a tax avoidance scheme involving bankers' bonuses from succeeding.

Protecting Privilege: What is Legal Privilege and how does it apply to taxpayers?

The concept of legal privilege is important to in-house tax practitioners in both stages of planning and defending an audit. Issues regarding what kind of information or documents are protected by privilege and how to assert and protect privilege should be considered carefully.

Germany: Tax Court prevents Tax Office from exchanging information with E6 countries in relation...

On September 7, 2015, the local tax court of Cologne issued an injunction against the German Federal Central Tax Office to prevent the FCTO from conducting a coordinated exchange of information with the E6 countries Canada, Great Britain, France, Australia and Japan, which aimed at gathering intelligence on companies of the digital economy to develop more efficient counter measures against BEPS strategies.

Webinar invitation: The EU Commission’s first APA State aid decisions and the larger picture

On 21 October, the European Commission issued the first two tax rulings State aid decisions finding the two rulings to violate EU...

Singapore Export Controls Updates: Strategic Goods (Control) Order 2015

A new Strategic Goods (Control) Order 2015 (“SGCO 2015”) will replace the current SGCO 2013 with effect from 2 November 2015. According to Singapore Customs, the SGCO 2015 brings Singapore’s strategic goods control list up to date with the 2014 Wassenaar Arrangement Munitions List and the 2014 European Union’s List of Dual-Use Items.

Belgium: New “Cayman Tax” published

On 9 October 2014, the new Belgian federal government announced, in its coalition agreement for the coming term, its intention to introduce a regime of tax transparency for the income of trusts and other foreign legal arrangements (the so-called Cayman Tax).

Canada: The Constitutionality of Administrative Monetary Penalties: Defining the punitive paradigm

The Supreme Court of Canada released its anticipated decision in Guindon v. Canada on July 31, 2015, which held that administrative monetary penalties ("AMPs")...

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