The tax regime for foreigners who render services in South Africa for a relatively short period of time is a key area which expatriates and their employers are grappling with. These individuals (also more commonly known as ‘short-term business travellers’) are generally physically present in SA for periods ranging from… – Continue reading
Introduction In 1934 distinguished US jurist Judge Learned Hand famously opined that “one may so arrange his affairs so that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to… – Continue reading
In his summer budget the first exclusively Conservative one in 19 years British Chancellor George Osborne outlined several key changes for non-domiciled individuals or non-doms, reports MENAFN. These major modifications coming into effect in April 2017 arguably represent the biggest shake-up to the non-dom status since it was first introduced… – Continue reading
With the UK announcing new tax rules for foreigners living in the country, the government has been careful not to damage the country’s appeal to wealthy foreigners. The “non-dom” tax status “plays an important role in allowing those from abroad to contribute to our economy”, says George Osborne, the UK’s… – Continue reading
Controlled foreign companies (CFCs) that are engaged in offshore short-term insurance will be allowed to deduct reserves related to their “short-term insurance business” conducted outside South Africa, once an amendment to the Insurance Act, 2016 is promulgated. For a CFC to be eligible for this deduction (which is similar to… – Continue reading
Surprising as it may seem, most of the advantages of the Cypriot Tax Regime were, up until recently, mostly directed to non- Cypriot Tax residents. This effectively meant that in order to enjoy the full benefits of the Regime one had to be a non-resident. The idea behind this was… – Continue reading
South Africans with unauthorised funds abroad better get their affairs in order because tighter regulation in tax havens will soon become a harsh reality, a tax expert has warned. Tony Davey, director at boutique consulting firm Tony Davey and Associates, says South Africans with offshore funds (foreign inheritances, foreign earnings… – Continue reading
On May 13, 2015, Cyprus and Georgia signed a new double taxation agreement (DTA). Unlike many former members of the USSR, Georgia did not adopt the 1982 Cyprus–USSR DTA when it became independent, and the new agreement is the first between the two countries. It will come into force once… – Continue reading
One European country’s generous tax regime to entice wealthy expats is looking even more attractive thanks to pension freedom. Many dream of retirement in sunnier climes and with pension freedom the opportunity to take your savings and run is even more tempting. A reduced tax bill is even more enticing,… – Continue reading
As global efforts to close loopholes intensify. JOHANNESBURG – South Africans with unauthorised funds abroad better get their affairs in order because tighter regulation in tax havens will soon become a reality, a tax expert has warned. Speaking at a recent seminar hosted by The Wealth Corporation, Tony Davey, director… – Continue reading
On May 20, 2015, the U.S. Treasury Department (“Treasury”) released five sets of proposed revisions to the U.S. Model Income Tax Convention (“Model Treaty”) for public comment. The Model Treaty was last updated in 2006. The purpose of the proposed revisions is to ensure that the United States maintains the… – Continue reading
Law firm Edwin Coe maps out the upcoming changes to the taxation of high net worth individuals in the UK, as announced in the last two Budgets. While many commentators have focused their sympathies on those reliant on benefits following last month’s Summer Budget, law firm Edwin Coe argues that… – Continue reading
On 11 July 2015 a new Corporate Income Tax Regulation (CITR) was approved in Spain, introducing, amongst other things, amendments to the Spanish transfer pricing reporting requirements. The new requirements largely reflect the recommendations made by the OECD with respect to Action 13 of the OECD Base Erosion and Profit… – Continue reading
The IRS published a list of Information Exchange agreements it has with state agencies, a copy of which is available here IRS State Information Exchange Table.pdf The disclosure of this list may help taxpayer’s and practitioner’s determine when and possibly whether to file late or amended state or municipal returns…. – Continue reading
British expats in Cyprus could lose a host of privileges if Britain withdraws from the EU, a popular expat forum has warned. The website is urging them to register to vote in the UK’s in/out referendum, which could take place as early as the middle of next year. The vote’s… – Continue reading
India and the US recently signed a tax information sharing agreement that will facilitate exchange of information between the two countries, beginning October. Foreign Account Tax Compliance Act (Fatca) was enacted by the US government in 2010, as part of the Hiring Incentives to Restore Employment (HIRE) Act. Fatca requires… – Continue reading
Three former chief executives of major listed companies have recently moved from Finland to Portugal. Matti Halmesmäki, a 62-year-old former chief executive at Kesko, Sakari Tamminen, a 61-year-old former chief executive at Rautaruukki, and Kim Gran, a 61-year-old former chief executive at Nokian Tyres, have all transferred their residence to… – Continue reading
John Goodchild explains the tax position of non-dom clients, and their families, after the Chancellor’s Summer Budget crackdown The Budget on 8 July announced a raft of provisions designed to increase the tax paid to the Exchequer by non-domiciled individuals (non-doms) and their families. Significant changes will be made to… – Continue reading
Companies and govts have been playing the cat-and-mouse game for several decades on transfer pricing Only a naivete would think of Hilary Clinton’s proposal last week to scale up the rate of capital gains tax as a mere concept to streamline America’s tax rate structure. It is being perceived as… – Continue reading
GOVERNMENT HAS TAKEN key steps to meet the requirements of the Foreign Account Tax Compliance Act Intergovernmental Agreement (FATCA IGA), which allows for the reciprocal exchange of information between the USA and Barbados. Minister of Finance, Christopher Sinckler, outlined the key steps as amending the Income Tax Act and putting… – Continue reading
Multinationals should pay a withholding tax before moving their profits out of EU countries to ensure they are being taxed somewhere, according to a draft report from the European Parliament. The report, seen by the Irish Examiner, deals with the fallout from the Lux Leaks and follows the European Commission’s… – Continue reading
Understanding FATCA and having a comprehensive FATCA compliance program is essential for financial firms to limit non-compliance risk and meet obligations with relevant IGA’s. The US has made inroads on the Exchange of Information front and tax havens like Switzerland have declared a willingness to meet or even exceed OECD… – Continue reading
Introduction The Cyprus Government has announced a number of proposed tax incentives aimed at encouraging economic activity and attracting inward direct investment. It has also submitted a number of draft laws to the House of Representatives to implement the new provisions of the EU Parent-Subsidiary Directive, to simplify the tax… – Continue reading
In the first 100% Conservative Budget in nearly two decades, chancellor George Osborne has introduced a raft of changes, including significant revisions to UK non-dom status. On 8 July, chancellor George Osborne delivered the first Conservative Government Budget for 19 years. Many headlines had already been flagged up in advance,… – Continue reading
Globalisation has brought many benefits in terms of cross?border trade, efficiency, competition and the free movement of goods and labour. But it has also allowed multinational corporations (MNCs) much greater freedom to reconfigure the location of manufacturing, operations, sales and corporate services in ways which channel reported profits ? and… – Continue reading
With the focus of 2014 being international tax competition, 2015 shows signs of continuing this trend. The European Commission (COM) and European Parliament (EP) are starting to debate and extensively investigate Member States’ tax ruling policies, partly as a result of the LuxLeaks revelations and partly in relation to the… – Continue reading
Financial Adviser Jonathan Lachowitz of White Lighthouse Investment Management published the following editorial regarding FATCA on the The Wall Street Journal on Tuesday July 28th: Managing personal financial issues is challenging for most people. For American expats, the normal complexities and expenses are compounded by a panoply of post-financial crisis… – Continue reading
It is widely recognized that offshore banking secrecy is fast becoming a thing of the past. The signing of bi-lateral and multi-lateral agreements between jurisdictions and the fast approaching Common Reporting Standard (CRS) under which jurisdictions will automatically exchange financial information has seen to that. The UK’s voluntary disclosure program… – Continue reading
The evolving tax landscape in the MENA region was discussed at the EY MENA Tax Conference held recently in London. The conference was attended by EY Tax specialists and senior finance and tax executives from major European companies with investments in the MENA region. Sherif El-Kilany, MENA Tax Leader, EY,… – Continue reading
In order to provide the necessary legislative amendments required to implement the tax proposals that were announced in the 2015 National Budget on 25 February 2015, the National Treasury (Treasury) published the 2015 Draft Tax Administration Laws Amendment Bill (TALAB) on 22 July 2015 for public comment. One of the… – Continue reading
Introduction US tax treaty policy can be affected by pressures for tax reform from within the United States and by major developments in international taxation from without. Talk of US tax reform has been widespread for years, although it is sometimes hard to gauge how much of the talk is… – Continue reading
Moves to track offshore buyers are rushed and confusing and could increase compliance costs to taxpayers, the Government has been warned, reports the New Zealand Herald. In its submission on the Taxation (Land Information and Offshore Persons Information) Bill, EY (formerly Ernst & Young) said the proposed legislation was being… – Continue reading
The UK Government has published draft legislation on devolving certain tax matters to Scotland (the Bill). It intends that the draft legislation should implement the terms of the devolution agreement made in November 2014 between the Westminster and Holyrood governments. Having looked over the Bill, it appears that the Scottish… – Continue reading
New Zealand’s lack of overseas investment regulation is being promoted in Shanghai and Hong Kong to help sell apartments rising on the site of the country’s best-known record store. “NO stamp duties and property purchase tax, NO capital gains tax on residential property if sold after two years of holding,”… – Continue reading
A number of jurisdictions (including the US, the UK and Italy) have launched voluntary disclosure (‘VD’) programmes. A substantial number of cases involve private foundations, typically legacy structures based in Liechtenstein and Panama. As the concept of foundations is alien to common law, their tax treatment raises delicate issues in… – Continue reading
Switzerland lies in “pole position” to gain from changes to the UK tax system which could encourage high net worth individuals living there to consider moving, according to a leading tax expert, John Huber. However, Malta should be doing more to attract a share of them, he said. “Chancellor George… – Continue reading
Portugal is an increasingly desirable destination, thanks to its tax-friendly stance. Portugal may not be top of everyone’s list in terms of tax-friendliness, particularly given the recent backdrop of the recession and bail-out, but it does have a history of running successful tax-friendly programmes, for example the Madeira and Azores… – Continue reading
One of the most immediate and obvious consequences of globalisation is the impact of domestic tax policies in other countries on the economy of Tanzania. This has necessitated the continuous evaluation of the tax regime in Tanzania and brought about crucial fiscal and economic reforms in the country. Hence, the… – Continue reading
Switzerland and the EU have signed a major accord to automatically exchange information on the financial accounts of each other’s residents. EU taxpayers will no longer be able to hide undeclared funds in Swiss banks. After coming up to increased international pressure in recent years, Switzerland has signed up to… – Continue reading
As many of our readers know, the Canadian Income Tax Act (the “Act”) provides for an unlimited exemption from the imposition of Canadian income tax on the gains resulting from a disposition of a “principal residence”. Access to the principal residence exemption can be valuable, especially in cities (e.g. Vancouver,… – Continue reading
The Indo-US deal on the Act will help both fight coountries tax evasion. Here’s a primer on how you could be affected The United States and India struck a bilateral deal on Thursday that would enable them to track the assets of nationals from both countries. As per the terms… – Continue reading
Remuneration paid for employment services performed in Canada (even for short-term assignments) by non-resident employees is subject to Canadian income tax withholding, remittance and reporting requirements under subsection 153(1) and regulation 102 (Reg. 102) of the Income Tax Act (Canada) (Act). On April 21, 2015, Finance Minister Joe Oliver tabled… – Continue reading
Shipping should not panic in wake of proposed U.K. non-dom tax changes, Moore Stephens says Shipowners likely to be affected by wide-ranging changes to the taxation of non-U.K.-domiciliaries introduced in the U.K. Summer Budget have been urged not to panic by international accountant and shipping adviser Moore Stephens, which says… – Continue reading
George Osborne’s family business struck a £6m deal with a property developer based in an offshore tax haven, it has been reported. The upmarket wallpaper firm Osborne & Little is claimed to have linked up with a corporation in the British Virgin Islands to turn its former headquarters in an… – Continue reading
How should non resident or non domiciled buyers of UK residential property own or hold residential property? Overseas buyers or owners of UK residential property above £1m in value need to consider carefully in what name or legal structure they should buy or hold property for their protection and to… – Continue reading
Where Qualified Dividend Treatment Is Important, Serious Consideration Should Be Given to Ensuring the Company Is Eligible for Treaty Benefits Before Taking It Public. Dividends generally are taxed at ordinary income rates (up to 39.6 percent for individuals). Qualified dividends derived by individuals, however, are taxed at the preferential rate… – Continue reading
Agreement with Mauritius to be renegotiated. National Treasury says the abuse of double tax agreements by multinational companies is the main reason why the agreement with Mauritius has been renegotiated. National Treasury head of tax and financial sector policy Ismail Momoniat says companies have often used dual tax residence structures… – Continue reading
With a new government at India’s center and positive macroeconomic fundamentals working in its favor, the private equity industry is expected to invest more actively into India over the short to medium term. In the past year, inflation has steadily tapered, the fiscal deficit has been reduced, domestic demand has… – Continue reading
The UK Government’s goal is to make the UK the best place in the world to locate an international business; it has one of the most open economies globally, a highly skilled workforce, access to capital markets, a first-class infrastructure, and a highly competitive corporate tax system. UK tax policy… – Continue reading
There are estimated to be one million Britons living in Spain, with UK expatriates making up the largest group of European foreign nationals. Many Britons arrive with certain misconceptions around the tax and financial make-up of the country. The foreign perception of the Spanish tax system is made up of… – Continue reading
