Category: Dividends

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...

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...

[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....

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...

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...

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...

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...

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....

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...

From Israel to Canada: New Tax Treaty to Help Structure Investments

On December 21, 2016, the new Canada–Israel tax treaty entered into force. The new treaty was signed on September 21, 2016 in New York, and replaces the existing treaty that dates from 1975. For most purposes, the provisions of the new treaty took effect as of January 1, 2017. Overall,...

New Double Tax Treaty signed between Montenegro and Portugal

Montenegro has concluded double taxation treaties with more than 35 countries, and this number continues to grow. The most recently signed treaty is the one concluded with Montenegro. The agreement affects persons who are residents of one or both of the contracting states and applies to the Portuguese personal income...

Russia Removes Hong Kong From List of Offshore Tax Zones

The Russian government will no longer consider Hong Kong a Chinese-affiliated tax haven that doesn’t share tax information. Russia will strike Hong Kong from its list of offshore jurisdictions following ratification of a double tax treaty signed by the two parties last January and ratified by Russia in July, according...

The favourable tax regime of new Italian residents

The 2017 Budget Law introduced (starting from fiscal year 2017) favourable provisions for people wishing to become tax residents in Italy. It is aimed at wealthy individuals who wish to bring in new capital resources. The regime is inspired by the non-domiciled resident regime which is in force in the...

Malta denounced as tax haven as it assumes EU presidency

Malta was today (11 January) accused of being a tax haven as it took over the rotating presidency of the EU. Some companies in the EU’s smallest country pay as little as 5% tax on their profits. The small Mediterranean island would have been included in the list of tax...

In Slovakia, 2017 brings new tax legislation

The Slovak Government and Parliament made several changes to the tax system with effect from 1 January 2017. The recently adopted amendments concern – among others – corporate and personal income tax, value added tax, special levy in regulated industries, as well as social security and health insurance contributions. Here...

UK opposes planned US dividend tax for offshore investors

The US government is facing calls to delay the introduction of a new tax on foreign investors in US equity-linked derivative transactions, after the G5 group of countries signalled their opposition and the US Securities Industry and Financial Markets Association (SIFMA) indicated its members would not be ready for the...

Black money across the border: Why Pakistan’s elite are quivering as UAE demands tax information

According to unofficial estimates, more than $2 billion has flowed into Dubai real estate from Pakistanis every year for the past three years. Last week, account holders in a major UAE bank began receiving letters alerting them that soon they would be required to furnish information “with a view to...

Corporate tax-dodging in Australia costs billions

Two reports on company taxation show that more than a third of the largest companies operating in Australia paid no tax in 2014–15 and that multinational tax evasion cost an estimated $4.8 billion that year. These reports show the fraud of the claims being made by the Australian government and...

MOF rejects claim of Singapore as tax haven

A recent report has revived claims Singapore is a tax haven but the Singapore Government and experts here reject the label emphatically. They say the report contains inaccurate assertions and fails to recognise recent steps here to crack down on tax evasion. The Republic ranked fifth on a list of...

Rate Competition Is New International Tax Planning Reality

Lower corporate tax rates around the world are expected to play an important part in multinational companies’ tax planning in 2017, with a rate as low as 15 percent on the table in the U.S. and countries such as the U.K. planning to maintain or lower their current rates. A...

UK – FIRMS RESPOND WITH CONCERN OVER PUBLISHED IR35 PUBLIC SECTOR REFORMS

Draft legislation for the public sector IR35 reforms was published yesterday and several firms have responded concernedly to the publication of the documents. IR35 legislation reforms were proposed recently during the Autumn Statement. Julia Kermode, chief executive of The Freelancer & Contractor Services Association, commented on the publication of the...

Planning for the Use of the United States as a Financial Haven: Part One

The United States has not agreed to participate in the Common Reporting Standard (CRS), relying instead on the Foreign Account Tax Compliance Act (FATCA) regime enacted in 2010 and initiated in 2014. United States participation in CRS is highly unlikely. Even with a change in control of Congress, CRS may...

Implementation of Common Reporting Standard in Hong Kong – Implications for Family Trust with a Private Trust Company as Trustee

The Organization for Economic Co-operation and Development (OECD) issued the Standard for Automatic Exchange of Financial Information in Tax Matters (Standard for AEOI) in July 2014, which aims to prevent offshore tax evasion and maintain the integrity of tax systems. Over 100 jurisdictions have committed to comply with the Standard...

MEPs back automatic exchange of bank data

Tax authorities across Europe will be able to automatically share information about bank account holders, according to a Council position approved by the European Parliament on November 22. It was passed by 590 votes to 32 votes, with 64 abstentions. According to a European Parliament press release, the new rules...

Trump’s Corporate Tax Reforms: What CFOs Need to Know

While Trump wants to close loopholes, many of them stem from public policy concerns — not “special interests.” After a dramatic upset victory in one of the most bitterly contested presidential races in recent history, Donald Trump now has some serious work to do. His corporate tax policies—which are vital...

Australian Practitioners Urge Zero Withholding for Pooled Funds

Practitioners in the managed funds industry are calling for a zero-rate for withholding tax in Australia amid the government’s proposals for new tax concessions to boost it, saying the proposed measures don’t go far enough. The government released a consultation paper Nov. 3 on non-resident withholding taxes for pooled funds—or...

UK, Colombia In Double Tax Deal

The UK and Colombia signed a double tax agreement (DTA) on November 2, which is intended to support trade and investment by capping withholding tax on cross-border income. The agreement was signed by the Financial Secretary to the Treasury, Jane Ellison, and the Colombian Finance Minister, Mauricio Cardenas, during President...

Moody’s Predicts Increase In US Firms’ Offshore Cash Piles

The level of cash holdings kept in foreign jurisdictions by US multinationals will continue to increase unless changes to domestic corporate tax rules are introduced, Moody’s Investors Services has said. According to a new report from the ratings agency, US non-financial companies rated by Moody’s will increase their cash holdings...

Japan, Austria Agree MAP Arbitration

The Governments of Japan and Austria have agreed in principle to amend their double taxation avoidance agreement to further promote trade and investment between the two countries. The new agreement would enable arbitration under the mutual agreement procedure to ensure settlement of double tax disputes. The new agreement will also...

Chinese dual tax burden relieved

An extensive tax treaty that would shield Chinese businesses operating in the Kingdom from double taxation, and vice versa, has been drafted and is expected to be approved imminently, according to a senior Cambodian tax official. Experts said yesterday the double taxation agreement (DTA) would create a clear legal framework...

Ukraine and Luxembourg sign a Protocol modifying their double tax treaty

On 30 September 2016 Ukraine signed a protocol (the “Protocol”) modifying the not-yet-in-force Convention between the Government of Ukraine and the Government of the Grand Duchy of Luxembourg for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital (the “Convention”)....

Tax haven: The devil is always in the detail

In July 2016 the then Indonesian finance minister Bambang Brodjonegoro, in conjunction with the launch of the widely publicized tax amnesty program (TAP) for undeclared offshore assets, also laid out less publicized plans for a new tax haven on the islands of Bintan and Rempang (Proposed Tax Haven). A key...

Tax evasion challenge Pakistan, Switzerland moving towards greater cooperation

Pakistan and Switzerland would exchange information on tax evasion once the contracting state exhausts all regular sources of information available under the internal taxation procedure. On August 31, 2016, the Federal Cabinet approved initialed draft for revision of the Convention between Pakistan and Swiss Confederation for the avoidance of double...

Ireland: Holding Companies In Ireland – August 2016

Ireland has become a destination of choice for holding companies due to its capital gains participation exemption, generous foreign tax credit system, membership of the EU, ever expanding double tax treaty (“DTT“) network (72 signed, with 70 in effect), lack of controlled foreign companies legislation, thin capitalisation rules and the...

What is the future of corporate tax reform?

On June 7, AEI hosted two panels on how the US could reform the corporate tax code, the first focusing on business-level taxation and the second focusing on shareholder-level taxation. Christopher H. Hanna of the Senate Finance Committee delivered the symposium’s opening remarks, with a major focus on how the...

A Talk on the Benefits of Double Taxation Avoidance Agreement between Cambodia and Singapore

In May 2016, the Cambodian and Singaporean government authorities signed a new agreement to avoid double taxation with respect to taxes on income and on capital. What are the objectives and benefits of a double taxation avoidance (DTA) agreement? The “big-picture” objectives of the DTA between Singapore and Cambodia are...

CRA convicts a fraction of offshore tax evaders: Exclusive

As worldwide pressure grows to fight offshore tax evasion, new statistics obtained by the Star show the Canadian government has convicted only 49 people and levied just $13.4 million in fines for what it calls offshore activity since 2010. These numbers are far lower than in comparable countries and show...

Macau and China add protocol to the agreement to avoid double taxation

The Macau Special Administrative Region (MSAR) and China’s State Administration of Taxation in Beijing signed an additional protocol to the agreement to avoid double taxation and prevent tax evasion, officials said in Macau. The Additional Protocol, the third, according to the statement released by the Office of the Secretary for...

IMF call for ‘comprehensive reform’ of US tax system

An International Monetary Fund (IMF) review has called for a comprehensive reform of the US tax system, with the aim of removing exemptions, simplifying the system, rebalancing from direct to indirect taxes, and reducing statutory rates for individual and corporate income taxes According to its annual Article IV consultation report...

Ukraine, Austria Increase DTA Withholding Tax Rates

Ukraine and Austria have agreed to sign a protocol to their double taxation agreement to increase withholding tax rates on dividends, interest, and royalty income. The protocol increases the withholding tax rate for dividends and interest to 15 percent and five percent, respectively. Additionally, the royalty rate for patents, trademarks,...

Brexit – The UK and International Tax Consequences

The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications of Brexit, this OnPoint also considers some of the potential tax implications from the perspective of...