VOLUNTARY DISCLOSURE AND THE HUNT FOR UNDISCLOSED ACCOUNTS BY US AND DUTCH TAX AUTHORITIES

Propaganda machines up to speed

Publicity efforts by the US and Dutch tax authorities indicate that the hunt for undisclosed accounts in typical offshore jurisdictions is still a hot item. Although Curacao was not mentioned by the US authorities, the Dutch tax authorities announced a new search for undisclosed accounts in Curacao based on information provided by the French tax authorities. The IRS announced a new voluntary disclosure program which mitigates the risk of criminal prosecution in exchange for paying taxes, interest and a standardized penalty. Furthermore, the IRS announced that they will follow ‘new leads’ emanating from voluntary disclosures. …
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02
Feb 2011
CATEGORY

Tax

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REQUESTS FOR INFORMATION BY FOREIGN TAX AUTHORITIES

A request for information needs to contain specific information

The former Netherlands Antilles concluded several tax information exchange agreements (‘TIEA’) during recent years. These TIEAs also apply to the newly formed country Curacao. The Tax Arrangement for the Kingdom (‘TAK‘) is applicable within the Kingdom of the Netherlands, which includes Curacao. Article 37 of the TAK also contains the facilities for the exchange of information within the Kingdom.

Without a TIEA in place or a specific article in a double tax treaty facilitating the exchange of information between the treaty parties, the Curacao tax authorities would be prohibited from effectively exchanging …
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21
Dec 2010
CATEGORY

Tax

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TAX INFORMATION EXCHANGE AGREEMENTS

Tax Information Exchange Agreements (TIEA) and the Netherlands Antilles

In today’s world the ‘exchange of information’ is considered an important topic worldwide, appearing in many different areas, in local and international political discussions, international agreements including the process of implementation of these agreements, and in amendments of local laws and existing treaties. (Mainly as a follow-up to the recommendations and designated directions of the OECD).

Against this backdrop, in 2000, the TIEA (Tax Information Exchange Agreement) was developed by the OECD Global Forum Working Group on the effective exchange of information to promote international co-operation on tax matters through exchange of …
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06
Jul 2010
CATEGORY

Legal

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