Among the presented agreements, the DTA with Canada is the most significant and unique, being a product of almost 25 years of continued bilateral negotiations. Within the standard stipulations characteristic for DTAs, the most attention has been drawn to the provisions regulating the tax treatment of Canadian pensions received by Greek nationals living outside of Canada. Taking into consideration the large worldwide Greek diaspora and almost 280,000 Greeks living permanently in Canada, the inclusion of regulatory processes for pension funds, unresolved for numerous years, will prove to be of great importance to both governments.

The other five DTAs which will be presented for ratification to the Greek Parliament are with the governments of Azerbaijan, Qatar, Saudi Arabia, Serbia and Morocco. If ratified, the six new agreements may bring the number of DTAs held by Greece to 50. Statements by Greek officials indicate that as a developed country and active member of OECD, the government is continuing DTA’s negotiations with a few other countries and dedicated to initiating negotiations with additional nations in the near future.

Photo by Aster-oid

At the G20 Summit on November 7th, in St. Andrews, Scotland, the UK Prime Minister suggested banks be levied with a tax on their financial transactions. Gordon Brown made it clear that he wishes to see the burden of bank bailouts shifted from the tax payers to the institutions themselves and that this tax was one form of doing that. Other suggestions voiced by the PM included raising insurance premiums for banks to reflect their risk levels, creating bank financed investment pools which will fund bailouts, or instating upfront fees for banks, which will give them a right to request government help.

An early form of the proposed tax was put forward by James Tobin in an effort to create currency stability, after the 1971 announcement that the US Dollar would no longer convert to gold. It was originally created as 1% levy on all foreign currency trades by a bank, though modern discussion has lowered this figure to between 0.1% and 0.25%. James Tobin envisioned that the tax would reign in bank’s speculative activity and bring a higher level of stability to the economy by lowering both fluctuations in currencies and bank risk. The name Tobin has been used on modern incarnations of taxation systems that bare resemblance to the original Tobin Tax, though they might differ slightly in reality.

Quick response to the suggestion came from Timothy Geithner, US Treasury Secretary, who made it clear that the US government would not support the the creation of a Tobin Tax, or any form of “day-to-day financial transaction tax”, though he did not rule out the creation of some form of fiscal incentive to lower bank risk. The view of the US Treasury Secretary was supported by officials from Canada and Russia. Gordon Brown, meanwhile, had the backing of France and Germany.

The London G20 Summit, held on the 2nd of April this year, heralded an unprecedented wave of Tax Information Exchange Agreement (TIEA). In what was described as “revolutionary” by Angel Gurría, OECD Secretary-General, the number of completed TIEAs has almost doubled since their inception in late 2000.
Since the G20 summit, and subsequent global push for greater tax transparency and compliance, the following 53 agreements have been signed.

United States – Monaco (8 September 2009)
Denmark – Turks & Caicos Islands (7 September 2009)
Netherlands – Antigua & Barbuda (2 September 2009)
Denmark – Gibraltar (2 September 2009)
Denmark – Anguilla (2 September 2009)
Germany – Liechtenstein (2 September 2009)
Netherlands – St Vincent & the Grenadines (1 September 2009)
Denmark – St Vincent & Grenadines (1 September 2009)
Denmark – St Kitts & Nevis (1 September 2009)
Netherlands – St Kitts & Nevis (1 September 2009)
Canada – Netherlands Antilles (29 August 2009)
United Kingdom – Gibraltar (27 August 2009)
Australia – Gibraltar (25 August 2009)
New Zealand – British Virgin Islands (14 August 2009)
New Zealand – Cayman Islands (14 August 2009)
New Zealand – Gibraltar (13 August 2009)
Germany – Gibraltar (13 August 2009)
United Kingdom – Liechtenstein (11 August 2009)
Monaco – San Marino (29 July 2009)
Bermuda – Ireland (28 July 2009)
New Zealand – Isle of Man (27 July 2009)
New Zealand – Jersey (27 July 2009)
United Kingdom – Turks & Caicos (23 July 2009)
Netherlands – Turks & Caicos (22 July 2009)
Netherlands – Anguilla (22 July 2009)
Ireland – Turks & Caicos (22 July 2009)
Ireland – Anguilla (22 July 2009)
New Zealand – Guernsey (21 July 2009)
UK – Anguilla (20 July 2009)
Belgium – Monaco (15 July 2009)
New Zealand – Cook Islands (9 July 2009)
Netherlands – Cayman Islands (8 July 2009)
Germany – Bermuda (3 July 2009)
Ireland – Gibraltar (24 June 2009)
Ireland – Cayman Islands (23 June 2009)
France – British Virgin Islands (17 June 09)
Australia – Jersey (10 June 2009)
The Netherlands – Bermuda (8 June 2009)
Denmark – British Virgin Islands (19 May 2009)
Faroes – British Virgin Islands (19 May 2009)
Finland – British Virgin Islands (19 May 2009)
Greenland – British Virgin Islands (19 May 2009)
Iceland – British Virgin Islands (19 May 2009)
Norway – British Virgin Islands (19 May 2009)
Sweden – British Virgin Islands (19 May 2009)
New Zealand – Bermuda (17 April 2009)
Denmark – Bermuda (16 April 2009)
Faroes – Bermuda (16 April 2009)
Finland – Bermuda (16 April 2009)
Greenland – Bermuda (16 April 2009)
Iceland – Bermuda (16 April 2009)
Norway – Bermuda (16 April 2009)
Sweden – Bermuda (16 April 2009)

Previous to these, 63 agreements had been signed, bringing the total at the 10th of September to 116.

Following swiftly upon news that the US Government and UBS had reached a settlement in their offshore account tax evasion dispute, the Canadian Revenue Agency (CRA) has announced that they too will engage in discussions with UBS in regards to divulging information about Canadian national tax evaders.

On the 21st of August it was announced by Jean-Pierre Blackburn, Canadian National Revenue Minister, that the Canadian Government will approach UBS in an effort to uncover information about Canadians using offshore accounts with UBS to evade their tax liability. The meetings have been scheduled for the 2nd of September. According to Jean-Pierre Blackburn, Canada will pursue this information through legal action if UBS is unwilling to cooperate. Further comments indicated that Jean-Pierre Blackburn will be petitioning Jim Flaherty, Canadian Finance Minister, to allow an alteration of Canadian law which would create easier legal pathways for the pursuit of such information.

According to the Canadian Revenue Agency there have been seven Canadian nationals who have come forward with information about their offshore accounts during the legal action between the US and UBS. Caitlin Workman, a spokeswoman for the CRA, has stated that Canada will bring to the discussion two specific cases of Canadians using UBS for tax evasion through offshore accounts, although no further details on the perpetrators was given.