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CROSS BORDER


Canada’s framework for the maintenance of ownership information is in place but ‘requires improvement’ in relation to nominees and bearer shares, according to the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes.

The International Mutual Administrative Assistance in Tax Matters Order, SI 2011/1079, brings into effect arrangements set out in a Protocol (signed on behalf of the UK in May 2010) to the joint Council of Europe/OECD Convention on Mutual Administrative Assistance in Tax Matters.

The Double Taxation Relief and International Tax Enforcement (Montserrat) Order, SI 2011/1083, brings into effect an arrangement between the governments of the UK and Montserrat which amends an existing arrangement for the avoidance of double taxation and the prevention of fiscal evasion.

The following statutory instruments bring into effect arrangements for the exchange of information for tax purposes between the governments of the UK and Antigua and Barbuda, Saint Lucia, Saint Christopher (Saint Kitts) and Nevis, and Saint Vincent and the Grenadines respectively.

The UK/Turks and Caicos Islands tax information exchange arrangement entered into force on 25 January 2011, HMRC announced.
 

The European Commission has proposed an optional ‘one-stop-shop’ system allowing companies to consolidate all profits and losses arising across the EU and file a single tax return.

The UK/Liechtenstein tax information exchange agreement signed in August 2009 entered into force on 2 December 2010, HMRC announced.

The European Council has adopted a directive aimed at strengthening administrative co-operation ‘to enable the member states to better combat tax fraud’.

Mark Minihane and Fiona Thomson provide practical guidance on forex gains and losses

Aurell Taussig and Isaac Zailer examine some of the tax issues that can arise in the context of European cross-border mergers

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