IRS 2019 – Procedures 1-7 Nº 1: Residents
A few clarifications concerning residence in Portugal. ... - Continue reading
Category: Residence
Hong Kong announces entry into force of Cambodia, Estonia tax treaties
New tax treaties into force ... - Continue reading
U.S. tax-filing requirements that Americans living in Canada should know
The Canada Revenue Agency (CRA) has sent the financial records of 900,000 dual citizens and Canadian residents to the U.S. Internal Revenue Service (IRS) for the 2018 year, according a recent news story. ... - Continue reading
How major tech companies exploit tax laws: A focus on Ghana and Nigeria
When World Trade Organisation (WTO) officials designed the territorial taxing rights back in the 1920s, not many people imagined that a century later; these guidelines would still underpin the international tax system. Today, highly digitalised companies such as Facebook and Google are able to operate internationally from their tax havens,… – Continue reading
Nigeria: FIRS Issues Information Circular On The Claim Of Tax Treaty Benefits In Nigeria
The FIRS has issued a public notice on the claim of treaty benefits in Nigeria. ... - Continue reading
The Risks of Golden Visa Schemes
An exploration into the drawbacks to the very glossy 'Golden Visa Schemes' ... - Continue reading
Tax obligations of permanent establishments
The Philippines generally follows the “source of income” rule in identifying the income that are taxable to corporations in the Philippines. ... - Continue reading
Switzerland: Tax On Inbound Investments 2020
Tax treatment of different acquisitions ... - Continue reading
Expats to lose CGT benefits
Australian property owners living and residing abroad would have to sell their properties before June 2020 to still take advantage of capital gains tax (CGT) exemption. ... - Continue reading
An Overview of Taxation on Nonresident Individuals in Kazakhstan
Individuals not resident in Kazakhstan are subject to taxation on certain Kazakhstan-source income. ... - Continue reading
HMRC considering options after tax defeat
The tax authority is considering its response after losing a case in the Court of Appeal relating to Capital Gains Tax on a residential property. ... - Continue reading
China simplifies procedure for claiming tax treaty benefits
China’s State Taxation Administration on 14 October published “Administrative Measures for Non-resident Taxpayers Claiming Tax Treaty Benefits” [Announcement (2019) No. 35]. ... - Continue reading
Applying for China’s DTA Benefits in Profit Repatriation
China’s double tax avoidance agreements (DTAs) can be used to avail lower tax rates while making outbound payments. However, DTA benefits are not automatically applicable to everyone. ... - Continue reading
Canada: Treaties Impacting On Taxation: A Canadian Tax Lawyer’s Perspective
Taxation has become an increasingly global issue as people, money and property move freely across borders. ... - Continue reading
When A New York Exempt Resident Trust Meets The Sale Of A Business
Insights into the functioning of a trust ... - Continue reading
Cyprus: Substance – From Corporate Tax Perspective And Other Factors
Substance is vital when it comes to the tax residency of companies and their management and control aspect. ... - Continue reading
Japan to tighten rules on wealthy residents with overseas assets
The government is set to tighten rules on disclosure by Japan’s wealthier residents about their overseas assets in a bid to prevent tax avoidance, sources close to the matter said Sunday. ... - Continue reading
FBR asks UAE to share details of Pakistanis hiding behind Iqama status
Chairman Federal Board of Revenue (FBR) Shabbar Zaidi on Monday wrote letter to UAE authorities and asked for devising mechanism to share details of Pakistanis who are hiding behind Iqama based residential status to evade taxes. In a letter written to Ministry of Finance UAE by the Chairman FBR Shabbar… – Continue reading
Australian expats to be hit with hefty tax
Australians living and working overseas have until June 30 to sell their family homes or face being slapped with a hefty tax after the government reversed its position for exemptions. A A$581m federal government plan to change capital gains tax arrangements for expats originaly lapsed, but the Australian government is… – Continue reading
Dutch ditching their US citizenship over tax fears
Some 1,700 ‘accidental’ Dutch Americans have applied to give up their US nationality this year, a six-fold rise on three years ago, before a new tax law is implemented next year. As FATCA is enforced, these Dutch Americans must file a tax return in the United States. If they do… – Continue reading
Ireland publishes tax guidance on tie-breaker rule for dual resident companies.
October 8, 2019- New tax guidance for dual resident companies published by the Irish Tax and Customs ... - Continue reading
‘Who is buying Seattle?’: New report issues warnings on Seattle’s luxury housing boom
Seattle’s luxury housing boom will worsen inequality and affordability in the city, according to a new report, which calls for officials to require more transparency on who is actually buying luxury real estate in the area. The report — “Who is Buying Seattle? The Perils of the Luxury Real Estate… – Continue reading
Peru tax authority guidance addresses deductibility of interest paid to non-residents
On September 20, the Peruvian tax authority issued guidance as to how to treat interest expenses on foreign debt. ... - Continue reading
Ireland Issues Guide On Dual-Resident Companies
The Irish Revenue has published guidance on dual-resident companies that explains new rules introduced under the BEPS multilateral convention on tax treaties. ... - Continue reading
Canada: TFSA Non-Residence Contribution Tax Cancellation – A Toronto Tax Lawyer Analysis
For Canadians who are planning their retirement by investing their savings, the Tax-Free Savings Account (TFSA) has become an important supplement to the Registered Retirement Savings Plan (RRSP) since its introduction in 2009. ... - Continue reading
Maldives collects over 40 million USD as Green Tax in 9 months
The Maldives Finance Ministry on Monday said the state had collected over 40 million U.S. dollars as Green Tax from foreigners and tourists in the first nine months of this year, local media reports said. According to statistics published by the Finance ministry, the Maldives government had received 42.466 million… – Continue reading
NRIs or RNORs are generally not liable to pay tax in India on foreign income
If you wish to retain the NRI status to avoid clubbing of US salary with Indian income for tax purposes, it would be advisable for you to restrict your stay in India to less than 60 days during FY20 ... - Continue reading
Imminent Changes To US Immigration Program
There has been a lot of recent media attention surrounding the EB-5 Investment Visa Program, and for good reason. South African residents are not able to emigrate for exchange control purposes (sometimes referred to as a financial emigration) unless they have a lawful right of abode in the country to… – Continue reading
Turkey: new tax audit wave focuses on non-resident digital companies
Turkey’s government has initiated a new wave of tax audits scrutinizing the taxation of non-resident taxpayers engaged in the digital economy. ... - Continue reading
US/UK tax series: US citizens moving to the UK
If you are a US citizen who is becoming UK resident you will continue to be subject to US tax and reporting obligations but will also become subject to UK tax. ... - Continue reading
Australian tax office advises on transfer pricing for offshore drilling
The Australian Taxation Office (ATO) on September 27 set out its approach to analyzing transfer pricing issues associated with the use in Australian waters of non-resident owned mobile offshore drilling units such as drill-ships, drilling rigs (including but not limited to submersibles, semi-submersible and jack-up rigs), pipe-laying vessels, and heavy-lift vessels. ... - Continue reading
Hong Kong signs tax treaty with Estonia
The Hong Kong government today announced that Hong Kong and Estonia have signed a comprehensive tax treaty. ... - Continue reading
Mexico 2020 tax reform: big changes proposed for foreign companies doing business in Mexico
On September 8, the executive branch of the Mexican government introduced Mexico 2020 tax reform, proposing far-reaching changes to the Mexican income tax, value-added tax, and Federal Tax Code. ... - Continue reading
BSP study dismisses risks of POGOs pullout
Initial results of a study conducted by the Bangko Sentral ng Pilipinas show that an immediate pullout by Philippine offshore gaming operators from the country will not have an impact on the financial stability, Governor Benjamin Diokno said Tuesday. Diokno asked the BSP’s Financial Stability team and the Anti-Money Laundering… – Continue reading
Russia may stop automatic tax data exchange with Britain, dependencies: media
MOSCOW, Sept. 20 (Xinhua) — The Russian Federal Tax Service (FTS) may stop the automatic exchange of financial information with Britain and its dependencies — the Isle of Man, Guernsey and Jersey, TASS news agency reported Friday, quoting an FTS draft order. According to the news report, the draft order… – Continue reading
UK: UK Tax On Property For Non-UK Residents – Recent Changes
From April 2019, all direct disposals of UK land and property by non-UK residents are now subject to UK tax on capital gains ... - Continue reading
FATCA blamed for one in five US expats planning to give up passport
One in five US citizens living abroad are on the verge of giving up their passports according to a survey published by US tax consultants Greenback. The Greenback survey – which was conducted by more than 3,000 US expats – studies the expat community’s opinions on taxation, citizenship renunciation, and… – Continue reading
Ireland will be the ‘big loser’ if OECD tax reform fails, Saint-Amans warns
OECD tax director also criticises State’s slow move to phase out ‘double Irish’ loophole ... - Continue reading
South Africa: Offshore Trusts: The Basic Considerations And Recent Amendments.
The world of offshore trusts is now more dynamic than ever. ... - Continue reading
Salary received abroad by ‘resident and ordinary resident’ is taxable in India
You may evaluate claiming foreign tax credits under the India-US Double Tax Avoidance Agreement, for the taxes, if any, paid in the US on the salary received during the assignment, subject to satisfaction of conditions ... - Continue reading
US-born British citizen launches crowdfunding campaign to stop FATCA
A US-born British citizen has started a crowdfunding campaign to stop HMRC sharing her personal information with the US Internal Revenue Service (IRS) under the US Foreign Account Tax Compliance Act (FATCA). Law firm Mishcon de Reya has taken on the UK case for a client who alleges HMRC is… – Continue reading
UK: Taxpayer Victory In UK Corporate Residence Case Involving Offshore SPVs
The "management and control'' test of corporate residence is a significant connecting factor for tax purposes in many common law jurisdictions. ... - Continue reading
Italy: New Tax Incentives For Attracting Human Capital: Italy As The New Eldorado For The Taxation Of Sport Stars
Tax treatment is a key factor for private individuals such as workers, executives, entrepreneurs and professional athletes who relocate to new jurisdictions. ... - Continue reading
Post Swiss Bank sharing, 100 HNIs shortlisted
The Automatic Exchange of Information mechanism between India and Switzerland is being seen as a major boost in India’s fight against suspected black money stashed abroad A joint team of officials from Central Boad of Direct Taxes (CBDT), Central Bureau of Investigation and other probe agencies, who are looking into… – Continue reading
Canada: Frozen Bank Accounts Of US Citizens In Europe – What Does It Mean For Canada
Why are French and British banks threatening to freeze or close the bank accounts of US citizens?
... - Continue readingCyprus: The Cyprus Investment Programme And The Benefits
The Cyprus Investment Programme is rapidly becoming one of the EU’s most popular residence schemes.
- Non Cypriot citizens (and their families) can acquire Cyprus Citizenship by investing €2.5 million* in Cyprus.
- Following the application, Cyprus citizenship will be granted in six months, assuming the application has been completed accurately and the correct documentation filed.
- The applicant needs to be in posession of a residence permit for a period of six months before obtaining the citizenship.
Cyprus: Cyprus And Tax Treaties
A Tax Treaty (TT), in general terms, is an agreement between two or more jurisdictions that regulates the tax amount that an individual or a company must pay, so they are not taxed twice on the same type of income. ... - Continue reading
Georgia: a low-tax European country with much to offer investors
Georgia, an Eastern European Country, was ranked 6th in the World Bank Group’s 2019 “Doing Business” survey. ... - Continue reading
