In our last publication, we discussed the signing of the Ghana-Morocco Double Tax Agreement (“DTA”) and the provisions of the DTA in relation to the taxation of permanent establishments and business income. In the concluding part of the article, we will discuss the taxation of investment, employment and service incomes...
ANALYSIS: Companies are likely to receive a preliminary notice under the new diverted profits tax (DPT) regime between now and the end of 2017. They should treat the issue of a notice as potential litigation and should immediately involve their legal advisers. For many companies the time limit for the...
Huge numbers of the 9 million US expats living around the world are fed up with the IRS and resent tax filing from their new homes. A poll suggests two-thirds of expats feel they should not have to tell the IRS about their finances if they do not live in...
In its latest policy paper to target the cross-border financial services sector, the UK government today unveiled proposed legislation that seeks to prevent the use of offshore trusts to avoid tax. The measure ensures that payments from an offshore trust intended for a UK-resident individual “don’t escape tax when they...
Romanians who leave the country for more than six months need to fill in a form at the Tax Agency (ANAF) starting January 1 next year. Otherwise they will receive fines ranging between RON 50-100 (EUR 11-22), according to the Finance Ministry. The obligation to notify the authorities on leaving...
THE CABINET yesterday gave the green light to a draft agreement on the exemption of double taxation between Thailand and Cambodia. It aims to back this up with a similar deal with Brunei as part of Thailand’s effort to complete cooperation on this and other economic initiatives with all the...
Non-domiciled taxpayers contributed £9.3 billion to the UK economy in 2014/15 through a combination of income tax, capital gains tax and National Insurance contributions (NICs), according to newly-published figures. The number of non-doms paying tax in the UK marginally increased in 2014/15, to 121,300, up from 119,800 the previous year....
The Treasurer has recently released exposure draft legislation (Treasury Laws Amendment (Housing Tax Integrity) Bill 2017) in relation to removal of the CGT main residence exemption for foreign residents. The changes are part of the Commonwealth Government’s ‘housing affordability’ reforms announced in the 2017-18 Budget. This will affect both Australian...
According to China Merchants Bank and Bain & Company, a global business consulting firm, nearly 60 percent of China’s high net worth individuals have assets overseas in 2017, while in 2011 this ratio was only 20 percent. In 2015 and 2016, China’s annual financial assets exported overseas amounted to more...
South Africans face a tax crackdown on offshore earnings under a new government proposal. The measure will scrap the current rules that allow South Africans to work in another country for half the year without paying tax on income. If the change is adopted, South Africa will become one of...
INTRODUCTION HMRC have successfully challenged the offshore residence of Jersey companies holding UK real estate. In the case of Development Securities, the First Tier Tribunal held that Jersey companies set up to hold UK real estate were resident in the UK for tax purposes. This case serves as a timely...
Every individual has a nil rate band of £325,000 after which any assets above this threshold become taxable at 40% unless they are passing to an exempt beneficiary such as a charity or spouse/civil partner. This threshold has been frozen until the end of the 2020/21 tax year. The government...
I am a trustee of an offshore trust settled by a UK resident, non-UK domiciled settlor (with no UK origins) for the benefit of himself and his family. He previously opted to be taxed on the remittance basis. The trust holds only offshore investments. The settlor lent monies to the...
HM Revenue & Customs’ new online Trusts Registration Service is now up and running, and beginning to get the attention of trust providers in a big way. Here, tax commentator Gerry Brown looks at the new regulations, and what they will mean for those in the trusts industry. The UK...
Italy has granted non-domiciled status to a taxpayer for the first time, after introducing a new non-dom regime at the start of the year. Withers LLP represented the taxpayer, a high net worth individual who was formerly registered as a non-dom in the UK, and who has decided to move...
The Act currently provides for income taxable as ‘capital gains’ to be computed after taking into account the full value of consideration received or accrued on transfer of a capital asset “A person doesn’t know how much he has to be thankful for until he has to pay taxes on...
Reader M wrote to Lifelines about Japan’s inheritance tax law, which he calls “one of the most punitive in the world”: I’ve read with interest a number of articles in The Japan Times recently about the Japanese government’s efforts to make it easier for foreigners to obtain permanent residence in...
The Gupta family sought advice on how to move tens of billions of rands to the United Arab Emirates, revealing the enormous size of their empire, according to a report by the Sunday Times. The treaty which came into effect in March this year, stops the South African Revenue Service...
The Australian Government has unveiled a package of housing tax breaks, including a new scheme for first-time buyers, a superannuation incentive for downsizers, and tighter rules for foreign residents. In a joint release, Treasurer Scott Morrison and his Assistant Minister, Michael Sukkar, said: “Housing affordability is a major issue affecting...
The Irish Parliament’s arts committee has recommended the introduction of a “foreign artists’ withholding tax (WHT) scheme.” The committee has released a report on the Government’s Culture 2025 initiative, which is intended to provide a framework for the development of Irish arts, culture, and heritage over the next eight years....
THE BENEFITS OF NON-DOMICILE STATUS An individual who is resident but not domiciled in the UK does not pay tax on overseas income and gains, as long as they are kept outside the UK and are not used to provide benefits in the UK. This is called the remittance basis...
Canada and dozens of other countries will automatically share banking information of non-residents Canadians with secret overseas bank accounts could soon find themselves at risk of being exposed by a new international agreement designed to help catch tax cheats. Under the Common Reporting Standard, dozens of countries will share information...
Tax liability under the Income-tax Act, 1961 (‘the Act’) of any person is determined based upon his residential status. A person resident of India is taxable on his income accruing across the globe [see End Note 1] while a non-resident is taxable only on the income accruing or arising or...
Expats can claim pension tax relief as long as they are still resident in the UK. Residence is a matter of fact rather than choice and depends on the result of the statutory residence test. Expats who are not resident in the UK cannot claim pension tax relief How do...
France will cut taxes on businesses and individuals by roughly 11 billion euros ($12.6 billion) next year, faster than the government had originally intended, Prime Minister Edouard Philippe has said. The goal is to create incentives for investment, hiring and economic growth, Philippe told Les Echos daily in an interview...
Passing on your inheritance and your place of residence – the tax minefield QUESTION: I was born in Belfast and now live in Dublin. I have 2 children who both live in Dublin and I am contemplating retiring to Northern Ireland. Is there a difference between the Inheritance tax systems...
Banks will have to share customer information after a new tax law took effect Saturday, according to New Zealand Bankers’ Association. The new law requires banks and other financial institutions to identify accounts held by foreign tax residents. This customer information will be provided to Inland Revenue, which will in...
Introduction Finance Act 2016 replaced the test for corporate residency of foreign companies from “control and management being situated wholly in India” to “place of effective management (POEM) in India”. POEM has been defined to mean a place where key management and commercial decisions that are necessary for conduct of...
Tax returns and annual financial disclosures contain different information Candidates and members of Congress are required by law to file personal financial disclosures that are designed to shed a light on their potential conflicts of interest. These documents show a lawmakers’ assets and liabilities, reported in broad ranges. Tax returns,...
Indian immigrants in Saudi Arabia are set to be hit by the Kingdom’s newly introduced ‘family tax’ that will come into effect starting from July 1. The tax requires employed persons to pay a fee of 100 riyals (Rs 1,700 approx) per dependent each month. So, an Indian expat living...
The Government Emergency Ordinance no. 42/2017 amending Law no. 207/2015 regarding the Fiscal Procedure Code (“GEO 42/2017“), entered into force on 13 June 2017, transposes within the Romanian legislation the EU Directive 2016/881 which provides the mandatory automatic exchange of information from reports that multinational enterprise groups (“MNE Groups“) must...
In Federal Budget 2017, the Government is clamping down on tax avoidance by foreign investors in real estate, by tightening the foreign resident capital gains tax withholding regime. The new laws apply to both Australian resident and foreign resident vendors: Australian resident vendors of real property of $750,000 or more...
Italy June 30 will apply OECD guidelines for “patent box” rules, a new version of the tax break for intangible property that will remove protections for brand identities originally put in place to protect iconic Italian fashion brands, observers told Bloomberg BNA. The new regime is substantially similar to the...
Transferring wealth to a spouse who isn’t a U.S. citizen can create complex gift, estate and generation-skipping transfer tax challenges. Such transfer tax issues require careful planning, as well as a clear understanding of the differences in how citizens and non-citizens are taxed. Unlike citizens and resident aliens, a non-resident...
KARACHI: The rate of withholding tax for non-filers against the winning amount on prize bonds has been increased to 25 percent from the existing 20 percent. The government through the Finance Bill, 2017 has proposed stern measures for non-filers in order to broaden the tax base and generate revenue. In...
You may be liable for capital gains tax. Here’s how. There is a common misconception that the sale of a person’s primary residence will never result in capital gains tax being payable; this is incorrect. For most taxpayers the sale of a primary residence will not result in a taxable...
Apartment construction is booming as the wealthy rush to invest in rental housing as a way to reduce inheritance tax and banks hand out easy mortgages, but concerns are mounting that excessive supply paired with a shrinking population could soon lead to the bursting of the bubble. New starts on...
For approximately 7,000 tax-evading individuals and businesses in Detroit, it may be time to pay up. Detroit tax collectors are conducting a large scale litigation campaign against tax evading individuals and businesses operating at 33 properties within the city’s downtown and midtown areas, the Associated Press reports. The team behind...
The American Institute of CPAs has sent a list of six tax regulations to Treasury Secretary Steven Mnuchin that it wants the Treasury Department to review under an executive order from President Trump calling for reducing overly burdensome tax regulations. Trump signed an executive order last month on identifying such...
Malaysian individuals and entities that have bank accounts overseas will soon see their financial information being shared with other countries and tax authorities in an effort to boost global transparency and tax compliance. This requirement is part of the automatic exchange of financial account information set out by the Organisation...
Australian Treasurer Scott Morrison’s 2017 Budget focused on measures to cool the housing market and crack down on tax avoidance. Morrison handed down the Budget on May 9. He said the the budget would return to a surplus in 2020-21 and remain in surplus over the medium term. The Budget...
The United States continues to be a magnet for immigration, with nearly 8 million new immigrants settling here between 2008 to 2014 — and some of these new immigrants are high-net-worth individuals who are unprepared for the intricacies of the U.S. tax law, according to Seth Entin, a shareholder at...
Foreign ownership of new developments will be restricted, there will be steeper charges applied to purchases, less favourable tax treatment and charges on those with empty properties, in a raft of measures in the federal budget aimed at taking the sting out of the housing market. One measure to be...
This article is the first of a series of articles that looks at tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors. An essential feature of...
Income tax has long been a progressive talking point in Seattle. Washington is one of just seven states without any income tax, and it relies heavily on sales and property taxes to fill the state coffers. As such, Washington earns the dubious honor of having the most regressive tax system...
KARACHI: The Federal Board of Revenue (FBR) has initiated audit of all those taxpayers who have made offshore transactions during the last six years, sources said on Tuesday. “All corporate and individual taxpayers, who have made offshore investments, have been selected for audit to check the tax concealment,” an official...
(Second of two parts) In last week’s article, we discussed the revised procedure to avail of tax treaty benefits for dividend, interest, and royalty payments under Revenue Memorandum Order (RMO) No. 8-2017. Under the amended rules, a tax treaty relief application (TTRA) is no longer required and withholding agents can...
The European Court of Justice (ECJ) has ruled in favor of Austria in its dispute with Germany relating to the taxation of interest from profit-participation certificates received by an Austrian bank from a German bank. The case involved the interpretation and application of Article 11 of the 2000 double tax...
In early April 2017, an important taxation agreement between Monaco and Italy came into force… As a direct result, Monaco now appears on the Italian ‘White List’ of tax compliant jurisdictions. The Agreement creates both opportunities and challenges for companies or individuals that fall within its scope, and is an...
Overview of the Tax As expected, the Government of Ontario has introduced a new non-resident speculation tax (“NRST”) that takes effect on April 21, 2017. The NRST is a 15% tax payable on the purchase of an interest in residential property located in the “Greater Golden Horseshoe” area (which includes...
