Finance bill passed ahead of coronavirus lockdown
Here are the amendments and clarifications concerning tax residence and dividend distribution tax. ... - Continue reading
Category: Dividends
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
OECD Criticizes Estonia’s Dividend Tax Measure
The OECD has taken issue with the Estonian Government’s plans to reduce the rate of tax on distributed dividends for established companies, warning that the measure could complicate the tax system and discriminate against small firms. Under recently enacted legislation, tax on distributed dividends will be reduced from 20 percent… – Continue reading
Japan, Russia Agree New Double Tax Pact
The governments of Japan and Russia signed a new convention on the elimination of double taxation on September 7. The convention replaces the 1986 agreement between Japan and the former Soviet Union. It lowers withholding tax rates on cross-border income from trade and investment – in most cases to zero… – Continue reading
Switzerland, Belgium To Begin Exchanging Tax Info
The Swiss Federal Council has announced that an information exchange amendment to the double tax agreement with Belgium has entered into force. On August 7, the Council said the additional agreement to amend the DTA had entered into force on July 19. It contains an administrative assistance clause in accordance… – Continue reading
US government delays Obama earnings-stripping rule deadline
The change converts tax-deductible interest payments employed by the schemes into taxable stock dividends. The U.S. government on Friday gave companies an extra year to comply with an Obama-era regulation meant to crack down on corporations that try to minimize their U.S. tax bills by shifting profits abroad to countries… – Continue reading
Australia Changes Tax Stance on Employee Share Schemes
The Australian Taxation Office has reversed its stance on the tax treatment of trustee dividend-equivalent payments to participants in employee share schemes. The ATO’s June 8 draft guidance, Draft determination TD 2017/D2, deals with circumstances in which an employer establishes a trust to provide shares to employees under an employee… – Continue reading
UK: The UK Company: A New Alternative For International Investors?
This article is the first of a series of articles that looks at tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors. An essential feature of… – Continue reading
Withholding tax on dividends – A bagful of uncertainties and complexities?
Muscat: One of the many changes that the Royal Decree 9 of 2017 (RD) has made in the Oman Income tax law is the introduction of withholding tax (WHT) on payment of ‘dividends on shares’ by Omani companies. This amendment requires Omani companies distributing dividends on shares to foreign persons… – Continue reading
[News Focus] Multinational firms using royalties to avoid tax: expert
Multinational firms in South Korea tend to transfer much higher proportions of their revenues to their headquarters overseas in dividends and royalties than their Korean counterparts, an expert said Monday. Payments in royalties and dividends are categorized as expenses, which in turn lowers their reported earnings to the Korean authorities…. – Continue reading
UK Budget Anti-Avoidance Measure Will Fail, CIOT Says
A significant cut to the dividend tax allowance announced in the UK Budget will not deter people from incorporating their own business to take advantage of lower corporation tax rates, the Chartered Institute of Taxation (CIOT) has said. The Government will reduce the tax-free dividend allowance, which affects owner managers… – Continue reading
Russian Federation: Confirmation Of Direct Investment In Capital To Apply A Reduced Tax Rate On Payment Of Dividends
On 30 December 2016 the Commercial Court of Voronezh Oblast delivered a judgement in case No. А14-10190/2014 (the “Decision”) under the claim of Ilyushin Finance Co. Open Joint Stock Company (the “Company”). The case is an example of a broad interpretation of the list of documents confirming entitlement to a… – Continue reading
Netherlands: Trends I Netherlands Moves Away From Fiscal Offshore Industry
The Netherlands is slowly but surely steering away from facilitating the use of its corporate income tax system by companies that are set up merely to obtain tax benefits. These companies, which often do not actually carry out activities in the Netherlands, have contributed to the perception among policy makers… – Continue reading
New tax measure takes aim at Offshore Trusts
A bombshell hidden in the detail of the 2017 Budget review relates to the taxation of offshore trusts. It refers to the 2015 Budget review in which it was announced that measures would be introduced to the tax treatment of foreign companies held by interposed trusts. No specific countermeasures were… – Continue reading
RF Supreme Court consolidates court practice on the application of transfer pricing and thin capitalization rules
On February 16, 2017, the Presidium of the Supreme Court of the Russian Federation approved the Review of Court Practice in the Consideration of Cases Involving the Application of Certain Provisions of Section V.1 and Article 269 of the Tax Code of the Russian Federation (the “Review”). There is no… – Continue reading
Opportunity for Refund of Late Interest charged on Failed Withholding Tax Notifications
Background Switzerland levies federal withholding tax at the rate of 35% on certain capital income, including dividend distributions of Swiss corporations. The federal withholding tax is fully refundable for Swiss resident recipients, provided that they (i) are beneficially entitled to and (ii) correctly declare respectively account for the taxable income…. – Continue reading
Republican Group Proposes US Carbon Tax
A new paper that calls for the introduction of a US carbon tax has been released by a group of former Republican administration members and economic advisers and leading business representatives. Issued under the auspices of the Climate Leadership Council, the paper proposes that the tax might begin at USD40… – Continue reading
Private but not secret
‘Private Banking’ is a term that usually conjures up images of secret banking transactions being carried out on behalf Royal families, the landed gentry and wealthy individuals. That’s how private banking started, but is not a fair reflection of private banking today. Today, it’s not your family tree that matters… – Continue reading
Abusive Tax Structures, Make Way For Budget 2017’s Transfer Pricing Combat Weapons
Among other things, Union Budget 2017 will be remembered for two firsts – the introduction of secondary adjustment and thin capitalisation rules. Both are transfer pricing provisions which will have a far-reaching impact on corporates. Secondary Adjustment Since the concept of secondary adjustment is introduced for the first time in… – Continue reading
