Healy Highlight – Euro Tax Update


There have been a few recent developments that could potentially impact company incorporation in Europe.

FranceThe French government isn’t about to give up on its plan to introduce a ‘Super Tax’ on its top earners, Tax-news reports, with Finance Minister Pierre Moscovici announcing that he would unveil the details of a new tax plan in the near future.  France’s Constitutional Court censured the original plan to tax 75% of annual income in excess of EUR1 million in December 2012. The court cited provisions that would tax individuals rather than households, saying that it would breach the principle of equality before public charges.  Moscovici said that the revamped law would retain the spirit of the tax but adhere to the principles defined by the Court, for example applying the tax to conjugal rather than individual income.

The plan was a pillar of President Francois Hollande’s presidential campaign, and was one of the socialist government’s efforts to ensure fiscal justice and address public finances. The original proposal angered business leaders and prompted some wealthy individuals to take up residence abroad. Government critics decried the plan as proof that Socialists were pursuing unfair tax policies.

Italy is in the news once again, with former Prime Minister Silvio Berlusconi launching his electoral bid with a plan to reduce government spending, enacting fiscal reform, and reimbursing Italians for a tax on primary residences that was imposed last year. However, Reuters reports that Berlusconi’s proposals were widely derided shortly after being announced.  The Corriere della Sera, Italy’s leading newspaper, ran a caricature of Berlusconi as a carnival clown throwing coins and banknotes, while current Prime Minister called him a “snake charmer.” Even his former allies were unimpressed, with Giulio Termonti, Berlusconi’s last economy minister saying that reimbursing the tax would create problems for public accounts. Vittorio Feltri, former editor of Il Giornale, the newspaper owned by Berlusconi’s family, said that the government wouldn’t be able to find the funds needed to reimburse the tax. Berlusconi, on the other hand, promised to save money by cutting government waste, halving the number of parliamentarians, and implementing taxes on tobacco and gambling, among other things.

Liechtenstein’s Prime Minister Klais Tschütscher recently held tax talks in Berlin with Germany’s Finance Minister Wolfgang Schäuble, discussing issues such as the eurozone debt crisis, bilateral projects, and challenges in the area of finance and taxation. Tschütscher highlighted the cornerstones of the Liechtenstein financial center, saying that financial centers can no longer be associated with tax evasion. He said that the Liechtenstein system has been recognized for combating financial center abuse and that it complies with OECD standards on tax cooperation and transparency. Liechtenstein signed a double taxation agreement (DTA) with Germany in 2012, creating what Tschütscher called a “reliable and attractive basis for mutual investments.” The DTA allows for a zero withholding tax rate to apply to certain dividends, interests, and royalties between the two countries.

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