Portugal’s non-habitual residence (NHR) regime – 10 years of tax benefits
You may consider moving to the Algarve for a healthier, more relaxed lifestyle. ... - Continue reading
Category: Dividends
The UK and Luxembourg Signed A New Double Tax Treaty
On 7 June 2022, a new Double Tax Treaty (the “DTT”) has been signed between Luxembourg and the United Kingdom (UK) to reflect the most recent OECD tax standard. ... - Continue reading
Ireland: Aviation Finance & Leasing 2022
Financing structures involving Irish entities often employ the use of a special-purpose vehicle ("SPV"), which is a company established specifically to hold title to the aircraft subject to the financing and to lease those aircraft to the operators. Ireland is a popular jurisdiction for the establishment of SPVs due to the numerous double-tax treaties in place between Ireland and other countries, many of which specifically refer to aviation in their text. Ireland is also attractive due to the confidence in the legal and court system (which is broadly based on English common law) and the number of aviation experts and leasing companies based in Ireland. ... - Continue reading
Requests for confirmation, tax treaty relief applications and tax sparing applications
IN 2021, the Bureau of Internal Revenue (BIR) issued Revenue Memorandum Order (RMO) 14-2021 and Revenue Memorandum Circular (RMC) 77-2021, which streamlined the procedure for the availment of benefits under the applicable tax treaty. ... - Continue reading
Russia submits a proposal to revise the DTT with Switzerland
The Russian Ministry of Finance has sent a proposal to its Swiss colleagues requesting amendments to the current double taxation treaty (DTT) between Russia and Switzerland ... - Continue reading
UAE and Israel Sign Tax Treaty
According to the Israeli Government’s announcement, the treaty is based on the Organisation for Economic Co-operation and Development Model Tax Convention on Income and on Capital (OECD Model) and covers areas including double-taxation, non-discrimination, exchange of information and anti-avoidance. ... - Continue reading
European Union: EUTA Special Edition: EU Responses To COVID-19 (Coronavirus) Crisis
The COVID-19 (Coronavirus) pandemic is affecting hundreds of thousands of people and is leading, all over the world, to far-reaching health and safety measures. As a result, the COVID-19 crisis has major social and economic consequences. Measures are being adopted to limit the impact on taxpayers as much as possible. ... - Continue reading
Often Overlooked Exception to Withholding and Reporting Requirements under FATCA
An often overlooked exception to U.S. withholding taxes may result in a lower overall U.S. tax burden. ... - Continue reading
Croatia, USA start talks on avoidance of double taxation
Dividends for tax non-residents are taxed at a rate of 30%, which causes significant problems for Croatian companies and makes them uncompetitive. ... - Continue reading
Cyprus: Cyprus – Russia Double Tax Treaty
Cyprus strikes a deal on Double Tax Treaty with Russian Government The Republic of Cyprus and Russia had entered into a Double Tax Treaty (DTT) in 1998 in a joint effort to avoid the double taxing of income and capital generated in Cyprus, in order to promote the economic cooperation between the two countries. Since its introduction, the DTT has been the catalyst for Russian investment in Cyprus, being an attractive jurisdiction with regards to its tax benefits. ... - Continue reading
Income tax implications for Indian investors investing in the US Stock Market
Indian investors are now proactively looking to diversify their portfolios overseas. We have seen the resilience and the outperformance of the US markets and we want in. ... - Continue reading
Italy’s Supreme Court resolves withholding tax dispute over interest paid to holding company
The Italian Supreme Court, in a decision released 10 July, has addressed whether a sub-holding company was beneficial owner of interest payments for withholding tax purposes, applying the European Court of Justice’s holdings in the well-known Danish cases. ... - Continue reading
Finance bill passed ahead of coronavirus lockdown
Here are the amendments and clarifications concerning tax residence and dividend distribution tax. ... - Continue reading
India Budget 2020: The key takeaways
Here are some important tax proposals for India's 2020 Budget. ... - Continue reading
Canada: Treaty Shopping: MIL, MLI And ALTA Things In Between
On February 12, the Federal Court of Appeal (FCA) released its decision in The Queen v. Alta Energy Luxembourg S.a.r.l.1 (Alta Energy), a case that represents an attempt by the Canadian tax authority to relitigate the issue of whether Canada’s domestic general anti-avoidance rule (GAAR) can apply to curtail so-called “treaty shopping”.2 ... - Continue reading
Tax on dividend income grows 30pc
Pakistan's officials state 30 percent increase in tax collection on dividend income. ... - Continue reading
Ukraine: Ukraine Ratifies Protocol Amending Double Taxation Treaty Between Ukraine And Switzerland
On 18 September 2019, the Parliament of Ukraine ratified a protocol (the Protocol) of amendments to the double tax treaty between Ukraine and Switzerland (the DTT) which had been signed by the states on 24 January 2019. ... - Continue reading
Canada: Canada Ratifies The Multilateral Instrument
On June 7, 2017, Canada along with numerous other jurisdictions signed the Organisation for Economic Co-operation and Development’s (“OECD”) Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “MLI” or “multilateral instrument”). The multilateral instrument is the culmination of work undertaken as part of the OECD/G20 BEPS Project to equip governments with domestic and international instruments to address tax avoidance. ... - Continue reading
Cyprus: The Cyprus Investment Programme And The Benefits
The Cyprus Investment Programme is rapidly becoming one of the EU’s most popular residence schemes.
- Non Cypriot citizens (and their families) can acquire Cyprus Citizenship by investing €2.5 million* in Cyprus.
- Following the application, Cyprus citizenship will be granted in six months, assuming the application has been completed accurately and the correct documentation filed.
- The applicant needs to be in posession of a residence permit for a period of six months before obtaining the citizenship.
HMRC collects record £191bn in income tax
The taxman is raking in record amounts in income tax as the latest figures reveal Britons paid an extra £11bn in 2018/19. Income tax receipts have soared to a record £191bn, according to figures published, a 6% increase from the previous year. Britons are paying almost 30% more income tax… – Continue reading
Govt’s new buyback tax set to hit MF investors, shareholders alike
The new budget proposal to tax buybacks and dividends at the same rate of effectively 20% may curtail the flow of distribution—that companies undertake from time to time to give investors a share in their profits—to the shareholders. ... - Continue reading
Buyback tax: A loophole fixed or an anomaly made worse?
In the past three fiscals, Indian firms bought back shares at an average rate of ₹47,800 crore ... - Continue reading
Tax on reserve to hit cos’ business expansion: ICAB
The imposition of 15 per cent tax on reserve and retained earnings of listed companies will reduce capital and expansion scope of the companies, said the Institute of Chartered Accountants of Bangladesh on Saturday. The ICAB made the statement in its post-budget review. Finance minister AHM Mustafa Kamal placed the… – Continue reading
FBR to abolish 25 withholding taxes
“The FBR is contemplating upon options to reduce numbers of WHT by 50 percent bringing it down from existing 50 to 25 in totality in the upcoming budget,” top official sources in FBR confirmed to The News here on Wednesday. Official data shows that there are some withholding taxes where… – Continue reading
Cyprus: Cyprus Tax Residence For Physical Persons
Cyprus tax system is one of the most favorable in Europe, offering a variety of tax benefits to physical persons who have tax residence in Cyprus. A physical person is considered to be a tax resident in Cyprus for a calendar year, if the criteria of the 183- or 60-day… – Continue reading
Cyprus: Cyprus–Kazakhstan First-Time Double Tax Treaty: Cyprus Ratifies
On 24 May 2019, Cyprus ratified the first-time double tax treaty it had signed with Kazakhstan on 15 May 2019 (the DTT). Certain legal procedures now need to take place in both states following which the DTT will ‘enter into force’. The DTT will be ‘in effect’ as from the… – Continue reading
Switzerland: The Brazil And Switzerland Double Tax Treaty: Why Is It So Significant?
Background The Brazilian and Swiss Governments signed a Double Tax Treaty (DTT) on 3 May 2018. Switzerland is one of the biggest investors in the Brazilian market and Brazil and Switzerland have already signed an Automatic Exchange of Information Agreement, which came into force on 1 January 2018. This new… – 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
The use of UK holding companies in international group structures – tax considerations
From a commercial viewpoint it is important that the Holdco is located in a reputable jurisdiction when seeking to access international equity and debt capital markets. The choice of Holdco location will also be relevant in circumstances where private equity investment is envisaged or where a trade sale is planned…. – Continue reading
Shell’s dubious tax arrangements
Shell avoids the dividend tax via a tax haven, which would have cost the Dutch treasury – and therefore the taxpayer – at least € 7 billion… The intervention of a ‘trust’ on channel island of Jersey seems to underline the dubious character of the ‘deal’. Pressing Rutte to exchange… – Continue reading
The EU Impact on French Tax Law
JURIST Guest Columnist Inès Soumhi of Pitt Law, discusses the impact of European Law on the French Tax System… In January 2018, the French Parliament formalized – as part of the 2018 Finance Act – several tax changes likely to impact companies including the repeal of the 3% additional tax… – Continue reading
Taiwan wealth management update
There have been a number of recent legal and regulatory changes in Taiwan that have impact from a wealth management perspective. Tax Rates Changes effective 2018 Effective 1 January 2018, the new tax rates for Taiwan are: Local foundation tax rule tightened Effective 1 January 2018, dividend for local foundations… – Continue reading
How to get a tax refund from SARS
Individuals that are in salaried employment have limited tax benefits. There are, however, certain tax benefits that may be used by individuals in salaried employment who are aware of the South African tax laws, notes Daniel Baines, author of ‘How to Get a SARS Refund‘. These can be grouped into… – 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
PBSA proposes tax cuts to encourage investment
(Web Desk) – Pakistan Stock Brokers Association (PBSA) has proposed end of double taxation whereby abolishing tax on dividends, bonus and capital value tax as it has been discouraging foreign as well as domestic investment in the Pakistan stock exchange . Pakistan Stock Brokers Association sent budget proposals from the… – Continue reading
Ukraine and Qatar sign agreement on avoiding double taxation
Foreign Minister of Ukraine Pavlo Klimkin and Finance Minister of Qatar Ali Shareef Al-Emadi have signed an agreement on avoiding double taxation and preventing income tax evasion between the government of Ukraine and Qatar. According to a Thursday posting on the website of the Finance Ministry of Ukraine, avoiding double… – Continue reading
China Sets Out How To Determine Beneficial Owner For Treaties
On February 3, 2018, China’s State Administration of Taxation set out new rules on the disallowance of tax treaty benefits where an entity fails to demonstrate it is the beneficial owner of Chinese assets from which passive income is derived. A beneficial ownership requirement is introduced in treaties to prevent… – Continue reading
Swiss Taxpayer Wins US Tax Treaty Refund Dispute
The United States District Court for the District of Columbia on January 31 ruled in favor of Starr International Company in a case concerning an erroneous refund paid to the taxpayer, which the IRS sought to reclaim. In 2011, the IRS erroneously issued a USD21m refund to Starr International Company,… – Continue reading
Eyeing lower taxes, Accenture seeks reduction of capital
Expects to avoid the mandatory dividend distribution tax BENGALURU, JANUARY 24: Consultancy multinational Accenture Solutions expects to avoid a substantial amount of tax for its Indian operations as it seeks nod from its creditors on Thursday for reduction of its capital from ₹5,361 crore to ₹2,263 crore. It has now… – Continue reading
Apple Could Get a $4 Billion Boost From Tax-Law Quirk
Microsoft, Cisco might also benefit from GOP bill ‘loophole’ Law gives some firms edge in paring offshore cash tax tab Companies that stockpiled trillions of dollars offshore free of U.S. income tax may get one last break before paying up — provided their fiscal years don’t follow the calendar year…. – Continue reading
UAE Cabinet Approves Tax Deals With Croatia, Moldova
The United Arab Emirates Cabinet on January 7, 2018, approved two double tax agreements concluded by the territory in 2017 with Moldova and Croatia. Double tax agreements seek to facilitate trade and investment between two or more countries by setting out the taxing rights of the territories involved, to ensure… – Continue reading
New PPT rule in the OECD’s Multilateral Instrument to displace Canadian GAAR?
In this Update On June 7, 2017, Canada signed the OECD’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) The MLI will modify up to 75 of Canada’s bilateral tax treaties, including adding a broad anti-avoidance rule to these treaties (the… – Continue reading
French Lawmakers Adopt 2018 Finance Bill
French deputies have adopted at first reading the 2018 Finance Bill, which includes several of the Government’s key tax measures. The bill, adopted by the National Assembly on October 24, will reduce compulsory levies by EUR10.3bn (USD12.1bn) by the end of 2018. The bill includes the abolition of the wealth… – Continue reading
HMRC Shuts Down ‘Liberty’ Tax Avoidance Scheme
HM Revenue and Customs, the UK tax authority, has welcomed a ruling in its favor against a contrived tax avoidance scheme involving an entity in Jersey and the Cayman Islands. HMRC says it expects that the decision will recover GBP325m in unpaid tax. The decision on the scheme, known as… – Continue reading
New regulation forces Indonesians to sell their foreign shell companies
On the back of the Indonesian government’s issuance of its new controlled foreign company (CFC) regulation on July 26, many Indonesians are likely to sell their foreign shell companies because of the enforcement of double tax payments. The CFC regulation authorizes the government to charge a dividend tax on foreign… – Continue reading
