My research work ("Direct taxpayer's participation in international dispute resolution mechanisms") has been selected for this year's Poster Program.
View my Poster Presentation at IFA Paris 2011
This year's IFA Congress is held in Paris from 11 to 16 September (www.ifaparis2011.com).
My research work ("Direct taxpayer's participation in international dispute resolution mechanisms") has been selected for this year's Poster Program. View my Poster Presentation at IFA Paris 2011
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Form E9 is the form in which taxpayers declare any changes in their real property. Form E9 for 2010 was initially set to be submitted, by using the electronic database of the Ministry of Finance, in June 2011. This deadline was moved to September 2011 and now it is moved again to December 2011.
The Ministry in its announcement states that the system is being currently upgraded and it will be able to offer many more options to the taxpayers in helping them accurately declare any changes in their rights on real property in Greece. Source: Announcement of the Ministry of Finance (in Greek). On 4 November 2010 Greece and Switzerland signed a revised double taxation agreement in the area of taxes on income and capital.
The Protocol contains provisions on the exchange of information which are in accordance with the OECD standards. In addition, the protocol specifies, amongst other things, that the dividend payments to occupational benefits schemes and public bodies will be exempt from withholding tax. Moreover, the rate of the tax that the source state is entitled to levy on interest payments has been lowered from 10% to 7%. Last but not least an arbitration clause has also been adopted, which is expected to contribute to the definitive avoidance of double taxation. The Protocol is currently not in force; it will enter into force after the necessary procedures in both countries have been completed. Source: The Federal Authorities of the Swiss Confederation (www.admin.ch) - you can see the relevant announcement here. The Ministry of Finance issued a circular (Pol. 1156/21-7-2011) providing guidance on the form that is to be used for the 2011 declaration of the Special Tax on Real Property and the list of documents that the non-resident legal entities owning real property in Greece must file.
The provisions of the income tax code that impose an obligation on the buyer of real property in Greece to justify the amount spent in purchasing the property and, in case of failure to do so, to pay income taxes on the amount that is considered as unreported income, are temporarily suspended. By a recent provision included in Law 3986/2011, the parliament, in an effort to support the real estate market in Greece, adopted the suspension of the application of these provisions, not only for the acquisition of first residential property, but for the acquisition of any kind of real property in Greece. The suspension applies as from 17-12-2010 and it will last until 31-12-2013.
The Tax on Real Property (Foros Akinitis Periousias - FAP) was imposed by Law 3842/2010 on real property in Greece that is owned by individuals or companies and applied from 2010 and forth. The relevant provisions were recently amended resulting in higher tax liability for the owners of real property in Greece.
By a recent circular (Pol. 1155/21-7-2011) the Ministry of Finance provides guidance on the tax treatment of foreign individuals that are employed in Greece by a company established in Greece according to the provisions of Law 89/1967. The circular clarifies that such foreign employees are subject to Greek income tax only for their Greek sourced income and not for their global income.
The concept of "wholly artificial arrangements" and their use by the tax authorities as indicators of tax avoidance schemes are the subject of my article (in Greek) published in the Bulletin of Fiscal Documentation (Deltion Forologikis Nomothesias - DFN) issue Number 1470/2011.
The Ministry of Finance has issued a circular (pol. 1024/2011) providing guidance on the interpretation and application of Article 12 of the Double Tax Convention between Greece and Finland, on the tax treatment of royalties.
According to Article 13 of L. 3943/2011, the list of non-cooperative states that applies for 2011 for the purposes of Article 51A of the Greek Income Tax Code is the list included in the Ministerial Decision No. 1150236/DOS/2010 (OJ B’ 1805). Articles 51A and 51B of the Greek Income Tax Code provide for anti-tax avoidance measures.
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