Category: Property

UK To Close Property Developer Offshore Tax Loophole

The United Kingdom has legislated to stop property developers from using offshore structures in the Crown Dependencies to avoid UK tax on profits. The UK has published legislation to bring into force amendments to the tax treaties between the UK and the Crown Dependencies – Guernsey, Jersey, and the Isle… – Continue reading

LMA Updates its Standard Terms and Conditions to Incorporate FATCA Provisions

On 20 April 2016, the Loan Market Association (“LMA”) updated its Standard Terms and Conditions for Par and Distressed Trade Transactions (Bank Debt/Claims) (“Standard Terms”) to include language that covers FATCA (as defined below) tax withholding on certain payments of US source FDAP income and, potentially, sale proceeds (as described… – Continue reading

Being Named In The Panama Papers Doesn’t Mean You Broke the Law

The Panama Papers have recently drawn a great deal of investigation and public attention. Over 230,000 organizations and individuals were named as having set up offshore companies in tax haven like the British Virgin Islands, Panama, the Cayman Islands or the Bahamas. The public’s initial reaction was suspicion and anger toward… – Continue reading

Tax havens accuse US of ‘hypocrisy’ over tax avoidance

A group of tax havens have accused larger countries like the United States of “hypocrisy” when it comes to cracking down on tax avoidance. With the issue of offshore finance high on the agenda in light of the fall out from the so-called Panama Papers scandal, world leaders convened in… – Continue reading

Bank account requirement makes it tougher to pay tax in NZ: expert

A change to our tax rules aimed at foreign property investors is likely to affect many people, a tax expert says. A bill poised to be passed by Parliament this week may increase the red tape for anyone based overseas doing taxable business with this country. The Taxation (Residential Land… – Continue reading

UK: Proposed Changes To The Non-Dom Regime From April 2017

The tax treatment of non-domiciled individuals is changing again from April 2017. The changes were first announced in the 2015 Summer Budget, and a Consultation document was issued in September 2015 setting out further details. The proposed changes target three key areas: The taxation of non-domiciled individuals who have been… – Continue reading

US plans reporting requirements for foreign-owned disregarded entities

US disregarded entities owned by foreign persons would be treated as domestic corporations under regulations proposed by the US Internal Revenue Service (IRS) on Friday (REG-127199-15). The new rules would apply for purposes of the reporting, record maintenance, and other compliance requirements that apply to 25% foreign-owned domestic corporations under… – Continue reading

Benami Transactions Bill to tackle tax evasion, money laundering

Islamabad—The Benami Transactions (Prohibition) Bill, 2016 will enable the government to tackle with the problem of tax evasion and black money and transactions being carried out in other people’s names. The said bill will also to put an end to benami transactions, and to empower the government to recover such… – Continue reading

Tax Notes: Protocol Amending RP – New Zealand Tax Treaty

THE Bureau of Internal Revenue (BIR) recently issued Revenue Memorandum Circular (RMC) No. 32-2016 setting the amendments in the provisions of the Philippines-New Zealand tax treaty, which was originally entered into on Oct. 2, 2008. The Protocol includes the following changes: 1. The rate for dividends was changed to a… – Continue reading

HMRC complicite in tax avoidance with ‘Tax Haven based landlords’

HMRC complicite in tax avoidance scheme after it emerged it rents its own office from tax haven based company A day on, the world is still reeling from the revelations of the Panama Papers leak, the full repercussions of which are yet to be felt. Eleven million documents leaked from… – Continue reading

Li: Tax reform to boost vitality of real economy

Premier Li Keqiang’s message to the country’s tax and financial authorities is crystal clear: The ongoing landmark tax reform must reduce burdens on all industries. One month before the May 1 deadline of a sweeping reform that seeks to replace China’s decadeslong business tax with a value-added tax, Li visited… – Continue reading

Minn. Senator Proposes Taxing Corporations Based in Havens

March 31 — Minnesota Sen. John Marty (DFL) introduced legislation that would require corporations headquartered in 46 tax havens to be subject to the same taxation as domestic companies. While it’s still early in the legislative session—the bill was introduced March 29—a spokeswoman for the Minnesota Chamber of Commerce told… – Continue reading

UK Tax Technicians Slam SDLT Surcharge

The Association of Tax Technicians (ATT) has expressed its disappointment that the UK Government intends to press ahead with plans to introduce a stamp duty land tax (SDLT) surcharge on purchases of second homes from April 1. Higher rates of SDLT will apply to purchases in England, Wales, and Northern… – Continue reading

Canadian Budget Focuses On Tax Compliance

The first Budget tabled by Canada’s new Liberal Government provides for a major crackdown on tax evasion and avoidance, and streamlines the domestic tax credits system. The Budget was delivered by Finance Minister Bill Morneau on March 22, 2016. He told Parliament: “Today, we begin to restore hope for the… – Continue reading

‘Scrutiny assessment’ of tax returns to begin soon

The National Board of Revenue (NBR) has issued a guideline asking its income tax offices across the country to start ‘scrutiny assessment’ of the tax returns submitted for the tax year 2015-16. As per the guideline, the taxmen have to complete the scrutiny assessment known as ‘return process’ by December… – Continue reading

Southeast State & Local Tax: Important Developments – March 2016

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast. VIRGINIA CORPORATE INCOME TAX Conformity with Internal Revenue Code. Virginia Governor Terry McAuliffe signed emergency legislation on February 5, 2016 that advances the state’s… – Continue reading

International and Irish Tax Update – March 2016

Summary The pace of change in international tax is dramatic. Each month brings new initiatives and developments at both national and supra-national levels. In this update, we focus on recent changes which are relevant to our clients. The OECD Base Erosion and Profit Shifting (“BEPS”) reports were finalised in October… – Continue reading

The rich people who pay no tax

Only the little people pay taxes. For a small, select cohort of rich Australians, the famous quote of New York property billionaire Leona Helmsley rings not as an outrage but as an inspiration. In the most recent documents released by the Australian Tax Office, there were 55 people who had… – Continue reading

IRS Issues 2016 Non-Resident Withholding Tax Guide

The US Internal Revenue Service (IRS) has updated Publication 515, Withholding of Tax on Nonresident Aliens and Foreign Entities, which covers the obligations of the persons responsible for withholding tax (withholding agents). It is specified that the Publication is for withholding agents who pay income to foreign persons, including nonresident… – Continue reading

No double taxation agreement with Panama; Maltese domicile subject to tax on worldwide income

Maltese individuals resident and domiciled for tax purposes, that is people whose permanent residence is in Malta, are required to pay tax in Malta on their worldwide income, according to the Income Tax Act. This essentially means that Minister Konrad Mizzi is required to pay tax on foreign earnings. However… – Continue reading

Pakistan, Czech Republic implement convention to avoid double taxation

Pakistan and Czech Republic have implemented a convention to avoid double taxation and prevent tax evasion, the Federal Board of Revenue notified on Monday. An official said the convention on avoidance of double taxation will come into force on July 1. “This is an epoch-making event in the consolidation of… – Continue reading

Rajan Blames MNCs For Tax Controversies

‘Multinational corporations complain all the time of excessive demand about excessive taxation, but it is also true that MNCs across the world tend to find tax avoidance and sometimes tax evasion as an appropriate technique’ Blaming multinational corporations squarely for tax controversies, Reserve Bank Governor Raghuram Rajan has said their… – Continue reading

BEPS Action 7: how the OECD’s proposals to redefine a PE could affect multinationals

The OECD’s final reports on the Base Erosion and Profit Shifting (BEPS) Project aim to target aggressive tax planning strategies which have the effect of shifting profits from high tax jurisdictions to low tax jurisdictions. The BEPS Project has been divided into 15 Actions, of which one of the most… – Continue reading

Industry Expects Relief From Double Taxation For Ease Of Doing Business

While the central government is pursuing its objective to provide a certain and stable tax regime, it is critical that instances of dual levy of VAT and service tax on the same transaction are addressed urgently The levy of service tax as well as Value Added Tax (VAT) on the… – Continue reading

Irish tax advantages may be banned under new EU rules

Ireland will be forced to ban many of the tax advantages it offers multinationals under proposals to be published by the European Commission tomorrow. This is the first step in an effort to have all EU countries introduce similar tax rules to prevent companies in the 28 member states avoiding… – Continue reading

Anguilla Best Flat Tax Country for a Low Tax Lifestyle

Anguilla levies a 3% flat rate of personal income tax and is otherwise a tax haven with a stunning climate and amazing Carribean lifestyle Whilst there are various categories of flat tax, including marginal flat tax and Hall-Rabushka flat tax, in its simplest form flat tax is simply a rate… – Continue reading

How to take your UK pension pot overseas-and not be hit by a big tax bill

Once the thrill of deciding to retire overseas has subsided, you normally start to think of all the things you need to do before you go. Picking the right removal firm, a lawyer to help you buy a new home are a couple, but the tax & financial implications of… – Continue reading

The towns taking on the taxman for a fairer tax deal

A group of businesses in the Welsh town of Crickhowell have gone offshore as part of a campaign to try and get HMRC to change tax laws. The Welsh town of Crickhowell is spearheading a unique campaign to get HM Revenue & Customs (HMRC) to change the laws so companies… – Continue reading

The Cayman Islands: The world’s most infamous TAX HAVEN, no bigger than Bognor Regis

It’s a whopping four and a half thousand miles away from the UK but the Cayman Islands is a slice of British-overseas paradise. Watched over by a Governor appointed from Whitehall, the Caymans are technically British. But there’s a huge difference between that island and the UK: no-one seems to… – Continue reading