Латвийский надзор оштрафовал SEB Bank почти на 2 млн евро
Комиссия рынка финансов и капитала Латвии (КРФК) в минувшую пятницу оштрафовала SEB Bank на 1 793 824 евро за нарушения в области борьбы с легализацией преступно нажитых средств и недостатками в контроле за исполнением международных санкций. К примеру, в банке был обнаружен...
Nature, purpose and effect of controlled foreign corporation rules. Their compatibility with the principles of international tax law
Increase in globalization and foreign trade in the last century led to aggressive tax planning. Though these planning measures are legitimate, they are designed for shifting profits to low tax jurisdictions. There is a number of measured to deal with this tax abuse. In particular, some jurisdictions apply controlled foreign corporation (CFC) rules.
Historically, the CFC concepts were created to help prevent tax evasion achieved by setting up offshore companies in tax havens, such as Bermuda...
The concept of Non-Discrimination as expounded in Article 24 of the OECD Model Tax Convention on Income and on Capital
Non-discrimination articles have been used in tax treaties over a number of years, they are designed to place non-discrimination requirements on the source country rather than on the residence state.
There may arise cases where a country provides favourable treatment to its nationals and discriminates against foreigners. To circumvent such cases tax treaties provide a clause which restricts contracting states from offering discriminatory treatment to foreign nationals as compared to its...
Main Aspects of Automatic Exchange of Financial Information under the CRS
In September 2017, a significant event for financial institutions around the world took place - the first automatic exchange of information for tax purposes in accordance with the CRS (Common Reporting Standard). The source of information exchange were banks, as well as other financial institutions (pension funds, investment and insurance companies, etc.). The second large group of countries is also joining the process of automatic information exchange in 2018.
CRS provides for an annual...
