Category: Residence

Gibraltar—Marbella. Russian oligarchs hide their Spanish assets offshore

It emerged that Russian oligarchs, members of ‘Russian mafia’, and many other owners of real estate in Spain have neither Spanish citizenship nor residential permit and successfully evade national taxes. Mansions in Marbella purchased by Russians officially belong to offshore companies incorporated in Gibraltar, a tiny British Overseas Territory. The… – Continue reading

Update on Portugal’s Non-Habitual Residence Program

Concerned about the tax implications of buying property in Portugal? Good news! Foreigners who want to buy in Portugal and meet certain criteria may be exempt from paying tax on most forms of overseas income. Here’s how! In a bid to bounce back from the 2008 financial crisis, Portugal has… – Continue reading

Regulator nods GEN Singapore domicile switch to home

Genting Singapore Ltd has gained formal approval from the Accounting and Corporate Regulatory Authority of Singapore to transfer its legal domicile from the offshore tax jurisdiction of the Isle of Man, to Singapore. Genting Singapore runs the Resorts World Sentosa casino resort (pictured) in Singapore. The company made a net… – Continue reading

Tax Competitiveness in India: Changing Rules, Trends in Taxation

Ease of doing business and tax reforms are at the center of India’s growth agenda as the country pitches itself as the leading investment destination among global emerging markets. Yet, India’s tax competitiveness record remains mixed. At a time when the U.S., U.K., and Japan have slashed their corporate tax… – Continue reading

Banks given 15 days to share foreigners’ data with FBR under OECD obligations

KARACHI: The Federal Board of Revenue (FBR) has given a 15-day timeline to banks and brokerages to furnish financial data of foreign customers as the country signed in an international convention for information exchange to curb tax evasion, officials said on Wednesday. The officials said FBR directed financial institutions, including… – Continue reading

Withholding Corporate Income Tax in China

In China, withholding Corporate Income Tax (CIT) is applied to the following China-sourced incomes derived by non-resident enterprises without establishments in China, or to that derived by non-resident enterprises with establishments in China but whose income is not related to these establishments: Dividends, bonuses, and other equity investment proceeds; Interests,… – Continue reading

LUX-FRANCE DTT: CLARIFY BEFORE YOU RATIFY

Alfi speaks out on the double taxation treaty signed between Luxembourg and France on 20 March 2018. Although it appreciates that it is the product of bilateral negotiation, it calls for more clarity before it is ratified. The Association of the Luxembourg Funds Industry (Alfi) has added its voice to… – Continue reading

Government spots 645 firms to probe tax issues of non-residents

KARACHI: Authorities have spotted more than 600 local firms to investigate the tax status and gather other financial information of non-residents, as new rules on data sharing, under an international treaty, kicked in to fight tax evasion, officials said on Friday. The officials said the Federal Board of Revenue (FBR)… – Continue reading

People await budget to declare assets under amnesty scheme: KTBA

KARACHI: People are awaiting budget announcement for the next fiscal year of 2018/19 to declare their local and foreign assets and benefit from the new amnesty scheme, a senior tax practitioner said on Wednesday. Khalid Mahmood, president of the Karachi Tax Bar Association (KTBA) said bar members are receiving a… – Continue reading

Singapore activates three new Automatic Exchange of Financial Account Information relationships

AEOI deals with the challenge of taxpayers operating cross-border but tax administrations remaining confined to their national borders, by providing an open international architecture. Singapore has activated three new Automatic Exchange of Financial Account Information (AEOI) relationships under the Multilateral Competent Authority Agreement (MCAA) on Automatic Exchange of Financial Account… – Continue reading

UK property tax changes affect GCC nationals

  PROPERTY in the UK, particularly London, has always been popular with GCC investors for many years. It has remained a safe haven and an attractive destination for investors and their families from the GCC region perhaps more than any other major city. Depending on the level of investment, well… – Continue reading

New Report Expected to Reveal Naturalized U.S. Citizens in Africa Who Failed to Disclose Their Income or File Taxes

NEW YORK —Globe Afrique Media and Communication has initiated a research on naturalized US citizens living and working abroad, especially in African countries who have either refused to file US federal and state taxes or are under-reporting their income and assets. In a recent assessment conducted by Globe Afrique, hundreds… – Continue reading

Kazakhstan ratifies double taxation protocol with Belarus

ASTANA, 29 March (BelTA-Kazinform) – The Senate (upper house) of the Parliament of Kazakhstan passed the law on the ratification of the protocol between the Government of the Republic of Kazakhstan and the Government of the Republic of Belarus on amendments and additions to the agreement on the avoidance of… – Continue reading

Foreign groups in India have to provide country-by-country report, clarifies govt

All international groups operating in the country will have to provide a country-by-country (CbC) report as per the revised Income tax Act, the government clarified in a finance ministry release issued today. The CbC report is to be furnished by the ultimate parent entity of an international group in the… – Continue reading

Ibcs Face ‘Much Damage’ Through Blacklisting Bill

THE Bahamas’ ‘blacklisting’ response threatens to “cause a lot of damage” to its IBC business and create “much less certainty” for the financial services industry, a top attorney is warning. Michael Paton, a former Bahamas Financial Services Board (BFSB) chairman, told Tribune Business that the proposed Multinational Entities Reporting Bill… – Continue reading

FG to Name, Shame, Prosecute Tax Evaders From March 31 ― Adeosun

The Federal Government is ready to prosecute, name and shame tax evaders that fail to utilise the tax amnesty programme, the Voluntary Assets and Income Declaration Scheme (VAIDS), to regularise their tax profiles, Minister of Finance, Mrs Kemi Adeosun, declared on Thursday. She also disclosed that the Federal Government would… – Continue reading

OECD Consults On Tackling Common Reporting Standard Circumvention

The OECD has recently launched a consultation on tackling the circumvention of its latest international tax transparency standard, the Common Reporting Standard, through the use by individuals of residency by investment (RBI), or citizenship by investment (CBI) schemes. These schemes typically entitle individuals to reside or gain citizenship through making… – Continue reading

Island tax haven firms own 23,000 UK properties

A quarter of property in England and Wales owned by overseas firms is held by entities registered in the British Virgin Islands, BBC analysis has found. The Caribbean archipelago is the official home of companies that own 23,000 properties – more than any other country. They are owned by 11,700… – Continue reading

India Clarifies Capital Gains Tax Changes

India’s Central Board of Direct Taxes (CBDT) has released further information on the long-term capital gains tax announced in the recent budget, in the form of a list of answers to frequently asked questions. Explaining the change, the CBDT noted that, under the existing regime, long-term capital gains arising from… – Continue reading

Digital firms with ‘big presence’ in India will have to pay taxes here

Finance Ministry’s move under BEPS treaty will impact Google, Facebook, Amazon MUMBAI, FEBRUARY 5 Digital players such as Google, Facebook and mobile application services providers must pay taxes in India on income generated from Indian consumers even if the companies’ infrastructure is physically located abroad. According to a new proposal… – Continue reading

Ukraine updates transfer pricing rules for 2018: key takeaways

Ukraine’s Law No. 2245-VIII “On Introduction of Changes to the Tax Code of Ukraine and Some Legislative Acts of Ukraine on Ensuring the Balance of Budget Revenues in 2018,” which came into effect on January 1, 2018, includes important changes to transfer pricing (TP) regulations. These changes are outlined below…. – Continue reading

Italy’s non-domiciled tax regime to profit from UK’s changing stance

In 2017, the UK scrapped its non-dom tax regime. Consequently, an increasing number of individuals are instead relocating their tax domicile to Italy At the start of 2017, in a bid to attract more wealthy citizens and capital to Italy, Rome introduced a non-domiciled tax regime. Now, citizens can move… – Continue reading

The tide continues to turn for offshore companies.

The case of Development Securities (No. 9) Ltd and other v HMRC [2017] UKFTT 0565 is the latest in a line of cases concerning the UK corporate tax residence of offshore companies. The case once again highlights the difficulties in preserving an offshore company’s non-UK tax resident status, whilst giving… – Continue reading

Report: French tax authority targets Jews; France denies allegation

‘Globes Israel’ claims that a secret department was set up in France’s tax authority specifically to investigate French Jews for tax evasion. The French have set up a secret department within their tax authority that employs 20 Hebrew speakers in order to find out if Jews are trying to evade… – Continue reading

Digital residency pays off big for Estonia

Estonia is expected to get a 100-to-one-euro return on investment for its e-Residency program, which lets anybody start a business from afar. It is even planning to launch ‘estcoins,’ its own cryptocurrency. Becoming a ‘digital resident’ of Estonia, Michael M. Richardson says, was “as easy as getting a fishing license… – Continue reading

Cayman Islands Country-By-Country Reporting Regulations Issued

As part of the Cayman Islands’ ongoing commitment to international tax transparency, the Tax Information Authority (International Tax Compliance) (Country-By-Country Reporting) Regulations, 2017 (the “CBCR Regulations“) were issued on 15 December 2017. The CBCR Regulations essentially implement in the Cayman Islands the model legislation published pursuant to the OECD’s Base… – Continue reading

Proposed new UK royalty withholding tax will apply from April 2019

A new royalty withholding tax will apply from April 2019 where a non-UK resident entity making sales in the UK pays a royalty to a connected party in a low tax jurisdiction, according to a consultation document which sets out further details of the proposal, which was first announced in… – Continue reading

Ten important Canadian Tax compliance considerations for new Canadians

The Canada Revenue Agency’s recently announced “postal code project” targets Canada’s richest neighbourhoods, to identify non-compliance apparent from discrepancies between residents’ tax reporting with their apparent wealth. Even prior to the postal code project, which focuses on any potential high net worth individual, the CRA had enhanced audit activity on… – Continue reading

India to accept mutual agreement process in transfer pricing cases

NEW DELHI The Indian Income Tax Department will accept applications for Mutual Agreement Procedure (MAP) in transfer pricing disputes, as well as for bilateral Advance Pricing Agreements (APAs), even for entities resident in countries with which India has double taxation avoidance agreements (DTAA), minus the provision to claim corresponding tax… – Continue reading

Tracking Noxious Funds: Strategies And Techniques For Whistleblowing By Kayode Oladele

Africa is estimated to have lost over $1 trillion in illicit financial flows (IFFs) within the past 50 years, with drainage of over $50 billion annually. These outflows, according to the African Union and Economic Commission for Africa (AU/ECA) High Level Panel on Illicit Financial Flows (IFFs), refer to “money… – Continue reading

Autumn Budget 2017: Hidden Tax Blow to Real Estate Sector

Summary: The Chancellor unexpectedly announced a U-turn to tax gains made by non-residents on UK commercial property with effect from April 2019. This will have a significant impact on overseas investors into UK real estate and creates additional uncertainty during an already volatile time as Brexit negotiations continue. Overseas investors… – Continue reading

The Italian “temporary web tax”

The Italian government has introduced a “temporary web tax” which will be in force until the long-awaited OECD/EU strategy for the reshaping of traditional taxation systems based on the residence of companies (or on the location of permanent establishments) has been defined. Said reshaping is aimed at introducing taxation principles… – Continue reading

Virtual Currency Exchanges and US Customers Beware, IRS is Coming: Expert Blog

In the aftermath of Satoshi Nakamoto’s groundbreaking paper in 2009, money began travelling via a new financial route – virtual currencies. The first Bitcoin exchange was established on February 6, 2010 where Bitcoin traded for the first time for 0.3 cents. Last June, the American Institute of Certified Public Accountants… – Continue reading

Senate’s Offshore Tax Ideas Could Be a ‘Goldmine’ for Some Companies

Plan proposes 12.5% tax rate on intellectual-property income Bills ‘upend decades of U.S. tax policy’ on tight deadline U.S. companies that make billions of dollars from patents and other intellectual property held offshore would be eligible for a special 12.5 percent tax rate on those earnings under the Senate tax… – Continue reading

TOKYO PUSHES BACK ON ‘BIZARRE’ DEATH TAX THAT DETERS EXPATS

Considering a work stint in Japan? You’d better make it short, and you’d better stay alive. That’s because the government subjects long-term foreign residents to inheritance tax of up to 55 percent on their worldwide assets – meaning heirs could be forced to give up their family homes or businesses,… – Continue reading

Ghana leveraging technology to enhance tax collection: VP

ACCRA, Nov. 10 (Xinhua) — Ghana’s Vice-President Mahamudu Bawumia said on Friday Ghana was leveraging technology to broaden the tax base and enhance tax collection. He believes that Ghana has reached a stage in its development where it must adopt appropriate, current and improved technology to make tax administration convenient… – Continue reading

Goa emerging as a haven of tax evasion

The investigation wing of the income-tax department in Goa probing money laundering and black money has uncovered more than Rs 1,000 crore worth of tax evasion in recent months. The tax evasion cases came to light between April and October 2017 following the post-demonetisation crackdown on undisclosed income, a senior… – Continue reading

Republicans Reveal US Tax Reform Law

On October 2 the US Government released the Tax Cuts and Jobs Act, setting out in legislation its plans for comprehensive reform of the US tax code. For businesses, the bill will bring about a landmark shift to a territorial corporate tax system, replacing the current worldwide tax basis regime… – Continue reading

Turkey: Turkey Updates Rules On Double Taxation Prevention Treaties For Independent Professional Services

Turkey has clarified rules for taxing income derived from independent professional services (and similar activities) carried out within Turkey, by residents of countries which have double taxation prevention agreements with Turkey. The number of days a company’s employees spent in Turkey will now become the only basis for calculating the… – Continue reading