Category: Residence

FBR threatens to penalise RFIs

Federal Board of Revenue (FBR) will penalize Reporting Financial Institutions (RFIs), which would fail to submit Common Reporting Standard (CRS) reports pertaining to required information of financial accounts of non-resident persons and any other reportable person by May 31, 2019 to the FBR. According to an announcement of the FBR… – Continue reading

Around 152,518 financial information of Pakistan tax residents received so far

Islamabad Around 152,518 financial information of Pakistan tax residents have been received through Common Reporting Standard Exchange (CRSE) on various dates – from October-2018 onwards. This data is being analyzed from taxation point of view and it has been shifted to identify in first instance, cases which are of a… – Continue reading

HMRC vows crackdown on offshore tax evasion in Spring Statement

The UK has published a policy paper setting out the direction for HMRC’s updated strategy for offshore tax compliance, offshore tax compliance strategy: No Safe Havens 2019. In the document, published alongside the chancellor’s Spring Statement, HMRC said it will use hefty punishments for those who enable offshore tax avoidance…. – Continue reading

Cyprus: The Cyprus ‘Non-Dom’ Rules

Introduction In July 2015, a number of bills relating to the Cyprus taxation system were approved by the Council of Ministers and subsequently enacted into legislation by the Parliament1. The key highlight of these new bills is the introduction for the very first time of the “non-dom” status for Cyprus… – Continue reading

Property tax collection rises 31pc in July-Jan

KARACHI: Property tax collection by provinces surged 31.34 percent to Rs7.38 billion during the first half of the current fiscal year of 2018/19, official data showed on Friday. Finance ministry’s data showed property tax collection amounted to Rs5.624 billion during the corresponding period of the last fiscal year. Sources in… – Continue reading

Virgin Islands launch new BEPS measure

In December, the Virgin Islands implemented a new Base Erosion and Profit Shifting (BEPS) measure, according to Government Information Services. The Organisation for Economic Co-operation and Development created a BEPS “action plan” in 2013 to combat “tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift… – Continue reading

Money trail must for offshore assets’ owners: Asad

ISLAMABAD: Federal Minister for Finance Asad Umar Thursday made it abundantly clear that those having offshore properties had no option but to give the trail of their money. Addressing a post-mini budget press conference at the P-block here, he said the government had obtained assistance from friendly countries, including Saudi… – Continue reading

Italy: Moving To Italy – The Resident Non-Domiciled Tax Regime

During 2017 the Italian Government introduced a new tax regime: The Resident Non-Domiciled Tax Regime(also known as the “Flat Tax Regime”), with the aim of attracting high net worth individuals who want to relocate to Italy. The new legislation introduced a key change to the general principle of worldwide taxation… – Continue reading

Portugal: Portuguese Golden Visa – Investment Route And The Non-Habitual Residents Regime

Background Portugal is being re-discovered as a destination to relocate to, with iconic cities such as Lisbon and Porto, and stunning coastal areas, for example, the Algarve. It also offers very easy access to the rest of Europe. Portugal is increasingly recognised as an international hub with 71 Double Taxation… – Continue reading

Countdown to the amended South African Expatriate tax law

The announcement by National Treasury and SARS in 2017 that the tax exemption on South African expatriates is set to change, has resulted in the lifestyle of many South Africans, who are employed by companies abroad, to rapidly change from a South African tax liability point of view. By Claudia… – Continue reading

Government Breaking Down ‘Offshore’ Banking Divide

The Government yesterday broke down the divide between Bahamian domestic and international financial institutions to meet European Union (EU) demands. KP Turnquest, the Deputy Prime Minister, in unveiling a radical regulatory shift said the Government will “make the playing field level for all financial institutions in The Bahamas” by enabling… – Continue reading

Proportion of HNWIs investing offshore rises

The wealthy are showing a keen interest to invest offshore, as the HNWIs seek to achieve benefits from global diversification and gain tax efficiencies. The proportion of HNWIs who invest offshore has risen from 11.2% in 2014 to 16.9% by December 2018, , according to GlobalData’s HNW Offshore Investment survey…. – Continue reading

Income Tax Dept cannot probe Foreign Assets of Assessee after Six Years: Delhi High Court [Read Judgment]

The Delhi High Court, in its recent decision, quashed an order of the Income Tax department questioning the overseas earnings and assets prior to March 31, 2005. The earnings included money in tax-haven banks, overseas properties and interests in offshore trusts and applies to non-resident Indians as well. The assessee,… – Continue reading

US DOJ charges four in ‘Panama Papers’ case

The United States Department of Justice has charged four people with crimes allegedly brought to light by the International Consortium of Investigative Journalism’s Panama Papers expose, according to a DOJ announcement published earlier this month. They are the first US criminal charges stemming from the ICIJ’s 2016 investigation, which reported… – Continue reading

Isle of Man approves law to avoid EU blacklist

The Isle of Man’s parliament has approved tax legislation that will allow the jurisdiction to avoid being put on the European Union’s blacklist. Tynwald gave the green light this week to the Income Tax (Substance Requirements) Order 2018. This means that from January 2019, companies engaging in “relevant activities” will… – Continue reading

Cayman drafts law requiring substance tests for offshore businesses

The Cayman Islands government has published draft tax legislation that will have far-reaching impact for the offshore finance industry operating in the jurisdiction by demanding that certain Cayman-registered companies have an adequate level of economic substance locally. The International Tax Co-operation (Economic Substance) Bill 2018 introduces a substance test for… – Continue reading

Report: £250 billion fraud in UK tax havens greater sum than 20 years of foreign aid budget

Russia most common place of origin for fraudsters using British overseas territories A NEW report has identified over £250 billion in fraudulent funds directed through UK tax havens, more than over 20 years of the UK Government’s foreign aid budget. The report, by Transparency International, examined the UK’s overseas territories,… – Continue reading

FBR plans action against concealed property investment

KARACHI/ISLAMABAD: The Federal Board of Revenue (FBR) stepped up efforts to net undisclosed property investments as the newly-constituted authority to curb real estate tax evasion brought the amnesty for the sector to an end, sources said Saturday. They said the amnesty to whiten undocumented money used for transactions of immovable… – Continue reading

Tax transparency watchdog urges Israel to step up moves against money laundering

After global index puts Israel in top third of most financially secretive countries, NGO calls for more public scrutiny and regulations to stop rich from hiding their assets Israel must immediately move to pass regulations against tax evasion and money laundering if it is to protect its credit rating and… – Continue reading

Worldwide: UK Tax Round Up – November 2018

General UK Tax Developments Finance Bill The Finance (No 3) Bill 2018-19 (which will become the Finance Act 2019) was published on 7 November and includes legislation to enact the changes highlighted in our UK Budget blog post ( UK Budget Blog). Another key area covered by the Finance Bill… – Continue reading

Ireland, Malta Close ‘Single Malt’ Tax Avoidance Structure

Ireland and Malta have agreed to close the “Single Malt” – an aggressive tax planning structure in which some multinational corporations use a company incorporated in Ireland but tax-resident in Malta. The Competent Authority Agreement – entered into as per the provisions of Article 24 (mutual agreement procedure) of the… – Continue reading

FBR urged to clarify taxability of foreign rental income

There is confusion among taxpayers regarding taxability of foreign rental income in Pakistan and filing of income tax returns in view of avoidance of double taxation treaties signed between Pakistan and UAE, UK and Canada. A leading tax consultant Shahid Jami has approached the Federal Board of Revenue (FBR) for… – Continue reading

NRIs don’t need to reveal details of foreign bank accounts, assets to Indian tax dept: I-T Tribunal

The Income-Tax Appellate Tribunal (ITAT) has said NRIs do not need to reveal details of their foreign bank accounts and assets to Indian authorities. The tribunal has also ruled that the onus is on the I-T Department to prove an assessee has parked undeclared income arising from India in foreign… – Continue reading

Canada: Common Reporting Standard Is Now Fully In Effect – If You Have Been Hiding Funds Or Assets Offshore, Now Is The Time To Disclose

Introduction – Offshore funds and Canada Revenue Agency’ reach Gone are the days when offshore bank accounts were outside the Canada Revenue Agency (CRA)’s reach. With the advent of the Common Reporting Standard (CRS), CRA automatically receives financial information of Canadian taxpayers who own bank accounts or assets in other… – Continue reading

Barbados minister foresees OECD compliance by year-end

Barbados is to scrap its international business company (IBC) regime in response to the OECD labeling the policy as “harmful” to competition, and being in breach of rules governing international taxation. Last year the OECD included Barbados on its list of jurisdictions with a “harmful” preferential tax regime, and said… – Continue reading

Government, European Union in talks over looming blacklist

Government officials have devised what they believe is a solution to the looming European Union blacklist threat, according to Neil Smith, the executive director of government’s Office of International Business (Regulations). The EU has threatened to place the Virgin Islands on an anti-tax avoidance blacklist at the end of the… – Continue reading

Post Panama Papers: are English trusts still trusted?

Trusts still remain under public scrutiny, but can their reputation be safeguarded, asks Stuart Price A recent government consultation on the law of trusts brought out some interesting issues concerning how the status quo aligns with the principles of transparency, fairness and simplicity (the principles that, at least in the… – Continue reading

Bahamas Developers Blast Oecd’s ‘Cynical’ Targeting

Bahamas-based developers have blasted the OECD’s “cynical” attempt to “”de-legitimise” this nation’s key investment product by suggesting it threatens the global fight against tax evasion. The newly-formed Bahamas Developers Association (BDA), in a recent statement, argued that the Organisation for Economic Co-Operation and Development (OECD) was wrong to list this… – Continue reading

Canada: Tax Residence In Canada – Are Significant Residential Ties Less Significant For Immigrants To Canada Than For Emigrants From Canada? A Canadian Tax Lawyer’s Analysis

Introduction A person’s status as a tax resident determines the extent to which Canada may tax that person’s income. The test for whether an individual—i.e., a natural person—is a Canadian tax resident turns on the individual’s particular circumstances. Every detail counts. But Canadian courts and the Canada Revenue Agency both… – Continue reading

Jersey puts forth economic substance legislation

Jersey has tabled new laws to address the EU’s concerns over ‘economic substance’, the degree of real business activity carried out by companies registered in the Island. The new proposed requirements for an economic substance test for Jersey tax-resident entities have been published and are set to come into force… – Continue reading

Pakistanis pose high risk to global financial system: IMC

KARACHI: A global investment migration association on Wednesday termed Pakistanis among high-risk nationalities who could exploit loopholes in the OECD’s common reporting standard (CRS) developed to curb offshore tax evasion and avoidance. “Of those nearly one million citizenships granted by the EU each year that are not related to CBI… – Continue reading

OECD report shines a light on how the wealthy dodge tax rules

On the list of countries operating CBI/RBI schemes, that the OECD feels have the potential to be used for tax dodging, are 2 tax havens that are popular with wealthy Canadians and large Canadian companies. These are Barbados and Panama. Ottawa (19 Oct. 2018) — New information from the Organization… – Continue reading

Cyprus: Approach Of Greek Authorities In Determining A Valid Foreign Proof Of Tax Residence

In Greece, an individual who has moved abroad must file an application to the local authorities in order to demonstrate a new address should they wish to change their status from resident to non-tax resident. Such an application is typically filed by March 10th of the year following the year… – Continue reading

Singapore does not ‘indulge’ in tax agreement with Indonesia: Finance Ministry

The Lion City will not hesitate to impose action against firms with cross-border tax evasion. Singapore’s Ministry of Finance refuted a news article by CNBC Indonesia which claims that its Double Taxation Agreement (DTA) with Indonesia ‘indulges Singapore’. “Provisions under the DTA are reciprocal, like any other DTA,” the ministry… – Continue reading

Tax break seen helping Trump isn’t as sweet thanks to IRS rules

The tax law gave a last-minute windfall to commercial property owners such as President Donald Trump. But regulations proposed by the Internal Revenue Service could diminish the benefit. Under the proposals, the agency’s rules would penalize real estate investors when they make like-kind exchanges — a common practice used to… – Continue reading

NRIs can be appointed as Trustees of valid Indian Trusts under Income Tax Act: ITAT [Read Order]

The New Delhi bench of Income Tax Appellate Tribunal (ITAT) in Global Academy of Emergency Medicine versus CIT(E), held that under the Income Tax Act appointing of NRIs as trustees of valid Indian trusts are permissible. The sole issue in the instant case was CIT (E) held that the owner… – Continue reading

FIA confirms getting list of 3,550 Pakistanis having properties in Dubai

KARACHI: Dubai’s famous construction company and developers, Emaar Properties, has issued lists, containing the names of 34,000 individuals, and 3,550 of them are Pakistanis. Most of them are living in Dubai or Pakistan currently, according to the addresses given in the list. FIA Director-General Bashir Memon told The News that… – Continue reading

Has the New Inland Revenue Act paralysed the Double Tax Treaty Network of Sri Lanka? Part 2

7.What are Mutual Administrative Assistance Agreement (MAAAs) The new IRA defines the “Mutual Administrative Assistance Agreement” to mean a tax information exchange agreement or other international agreement for mutual administrative assistance in relation to taxation matters. Section 75 (5) of new IRA “Mutual administrative assistance agreement” means a tax information… – Continue reading

Has the New Inland Revenue Act paralysed the Double Tax Treaty Network of Sri Lanka? Part 1

1.Introduction Due to the influence of International Monetary Fund, the income tax law of Sri Lanka witnessed a near paradigm shift with the introduction of Inland Revenue Act No.24 of 2017 (new IRA) by repealing Inland Revenue Act No.10 of 2006 with effect from 1 April 2018. Unlike the Inland… – Continue reading

Tax amnesty ends for undeclared EU assets

The automatic exchange of information between Switzerland and the European Union came into effect on Monday. Owning property abroad without declaring it will no longer be possible. The deadline of September 30 ended the possibility of coming forward voluntarily, reported Swiss public television, RTS, on Sunday. For latecomers who have… – Continue reading

TAX MATTERS | THE TAXATION OF COMPANIES IN MACAU – WORLDWIDE OR TERRITORIAL BASIS? (CONT.)

Our previous article about the taxable basis for the taxation of companies in the Macau territory made reference to the fact that the courts in Macau, notably the Court of Second Instance (TSI) and the Tax Administration, do not seem to share the same view regarding income considered as the… – Continue reading

Govt to serve notices to 300 Pakistanis owning properties in UAE: sources

ISLAMABAD: The federal government has decided to issue notices to 300 Pakistani nationals who own properties in the United Arab Emirates, sources informed Geo News Saturday. The sources said that notices will be sent to individuals who own six or more properties in UAE. They will be inquired about their… – Continue reading

FBR to take action against tax dodgers from next week

KARACHI: The Federal Board of Revenue (FBR) is all set to launch a major crackdown against individuals with concealed and untaxed offshore assets from next week as the revenue body bets on financial information shared under an international treaty, officials said on Friday. The officials said the FBR finalised the… – Continue reading

The Hukou System in Shanghai: Benefits, Eligibility, and Application Process

Hukou (户口) is a system of household registration in China. Each citizen is issued a household register under supervision of the Ministry of Public Security, China’s police. Hukou serves as an identity proof for citizens, recording their basic information and permanent residence. The hukou registration also determines access to housing,… – Continue reading