Category: Residence

Ghana-Morocco double tax agreement to come into force in 2018 – (Part 2)

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...

Australia: Proposed changes to CGT main residence exemption for foreign residents

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...

Australia Announces Housing Tax Breaks

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...

‘Come to CRA before we go to you’: International deal designed to expose offshore tax cheats

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...

Draft modifications to tax provisions applicable to foreign companies with poem in India

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...

What Voters Can Learn From Tax Returns

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,...

New reporting obligations for multinational enterprise groups

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...

Memo to: real estate vendors – if the sale price is $750,000 or more you need a Tax Clearance Certificate for settlement

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...

Regulatory Issues: Financial account information exchange for increased tax compliance

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 Budget Targets Housing, Tax Compliance

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...

UK: The UK Company: A New Alternative For International Investors?

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...

ECJ Rules In Austria’s Favor In Tax Dispute With Germany

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...