SIFMA and Other Associations Submit Comments to the EC on the Enhanced Cooperation Agreement for the Financial Transaction Tax

SIFMA, the Financial Services Forum, The Financial Services Roundtable ("FSR"), the Investment Company Institute ("ICI"), and the U.S. Chamber of Commerce submitted the attached comments to the European Commission ("EC") expressing serious concerns related to the extraterritorial impact in the United States and other countries of the EC's draft Council Directive implementing enhanced cooperation in the area of financial transaction tax (links to EC page). The groups assert the Directive would introduce both a residency and issuance test for taxation, which it says are inconsistent with existing norms of international tax law and long-standing treaty commitments.

Click hereto view comment letter in full (links externally to SIFMA website).EC Materials: EC Press Release, Q&A, Proposal for a Council Decision Authorising Enhanced Cooperation in the Area of FTT (2012), and the draft Council Directive (2008). See also: "Commissioner Šemeta welcomes agreement on enhanced cooperation for Financial Transaction Tax" and his speech at the EC press conference.