Allan Cinnamon (Cintax the Word Ltd) reports on recent global tax treaty news, including cases involving the India/Switzerland, UK/India and Australia/Canada treaties, as well as one utilising the OECD Model Treaty non-discrimination article.
Criticism of HMRC’s failure to prosecute HSBC Swiss tax evaders has been quite unfair, writes Jonathan Fisher QC (Devereux Chambers). There are problems with criminal prosecution and the decision to focus on tax collection through civil settlement is the right one. It makes little sense to criminally prosecute these cases.
Stephen Camm reports on the ending of traditional Swiss banking secrecy
Chris Morgan reviews recent developments in international tax
Chris Morgan reviews recent developments in the international arena, including Italy’s ‘Google tax’, the Swiss government’s report on ‘corporate tax reform III’ and Austria’s group tax proposals
Helen Adams answers a query on HMRC’s follow-up letters to Swiss account holders under the UK/Swiss tax agreement.
Will we ever see automatic exchange of information across the world, asks Jason Collins
The G8 summit at Lough Erne leads the month's summary from Chris Morgan