Category: Dividends

Capital gains / Capital Gains Tax / Dividends / Framework / G20 / Profit Shifting / Revenue / Royalties / Withholding Tax

Ireland: Aviation Finance & Leasing 2022

Published by: Mondaq - June 13, 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

Capital gains / Capital Gains Tax / Certification / Dividends / Residency / Royalties / Withholding Tax

Requests for confirmation, tax treaty relief applications and tax sparing applications

Published by: The Manila Times - March 3, 2022

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

Activity / Dividends / Double Tax Treaty / Double Taxation / FATCA / Hospitality / OECD / Permanent establishment / Tax Evasion / Tax Fraud

European Union: EUTA Special Edition: EU Responses To COVID-19 (Coronavirus) Crisis

Published by: Mondaq - June 7, 2021

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

Cyprus / Dividends / Double Tax Avoidance Treaty / Double Tax Treaty / Interest / Jurisdiction / Tax treaties / Withholding Tax

Cyprus: Cyprus – Russia Double Tax Treaty

Published by: Mondaq - October 8, 2020

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

Beneficial Ownership / Debt / Dividends / Interest and Royalties Directive / Parent-Subsidiary Directive / Regulatory / Tax Exempt / Withholding Tax

Italy’s Supreme Court resolves withholding tax dispute over interest paid to holding company

Published by: MNE Tax - September 10, 2020

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

Canada / Dividends / Infrastructure / Investments / Lease / Legislation / Profit Shifting / Revenue / Royalties / Tax Authority / Tax treaties / Treating Shopping / Treaty Abuse

Canada: Treaty Shopping: MIL, MLI And ALTA Things In Between

Published by: Mondaq - February 19, 2020

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

Arbitration / Banking Secrecy / Capital Gains Tax / Dividends / Double Tax Treaty / Intellectual Property / Loans / Mutual Agreement Procedure / Permanent establishment / Royalties / Tax Credit / Tax Exempt / Ukraine

Ukraine: Ukraine Ratifies Protocol Amending Double Taxation Treaty Between Ukraine And Switzerland

Published by: Mondaq - September 30, 2019

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

Arbitration / Dividends / Double Taxation / G20 / Mutual Agreement Procedure / OECD / Profit Shifting / Tax Avoidance / Tax Credit / Tax Laws / Tax Planning / Treaty Abuse

Canada: Canada Ratifies The Multilateral Instrument

Published by: Mondaq - September 6, 2019

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

Capital gains / Capital Gains Tax / Cyprus / Dividends / Immovable Property / Income Tax / Inheritance Tax / Property / Residence

Cyprus: The Cyprus Investment Programme And The Benefits

Published by: mondaq - September 5, 2019

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.
*In one specific set of circumstances as detailed below in the financial criteria, the investment required is €2.0 million. A non-Cypriot citizen who meets one of the financial criteria detailed below can apply for Cypriot citizenship ‘through naturalization by exception’.
  • 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.
... - Continue reading

Dividends / High Networth Individuals / HM Revenue & Customs / Income Tax / Revenue / Tax Avoidance / Tax Collection

HMRC collects record £191bn in income tax

Posted On: September 2, 2019

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

Bangladesh / Business / Corporate Tax / Dividends / Double Taxation / Tax Collection / Tax treaties

Tax on reserve to hit cos’ business expansion: ICAB

Posted On: June 16, 2019

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

Capital gains / Cyprus / Dividends / Double Tax Treaty / Interest / Kazakhstan / Legislation / Residence / Royalties / Withholding Tax

Cyprus: Cyprus–Kazakhstan First-Time Double Tax Treaty: Cyprus Ratifies

Posted On: May 29, 2019

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

Automatic Exchange of Information / Base Erosion & Profit Shifting / Beneficial Ownership / Brazil / Dividends / Double Tax Treaty / Financial markets / Interest / Investments / Loans / Royalties / Switzerland / Tax Laws / Withholding Tax

Switzerland: The Brazil And Switzerland Double Tax Treaty: Why Is It So Significant?

Posted On: November 23, 2018

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

Business / Common Reporting Standard / Corporates / Dividends / Double Tax Treaty / Double Taxation / Double Taxation Agreement / Employment / Exemptions / Fees / Income Tax / Interest / Loans / OECD / Permanent establishment / Residence / Royalties / Tax Authority / Tax Relief / Withholding Tax

Has the New Inland Revenue Act paralysed the Double Tax Treaty Network of Sri Lanka? Part 2

Posted On: October 3, 2018

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

Capital gains / Corporate Tax / Dividends / Exemptions / Investments / Jurisdiction / Legislation / Non-Domiciled / Offshore / Residence / Transfer pricing / United Kingdom

The use of UK holding companies in international group structures – tax considerations

Posted On: July 12, 2018

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

Anti money laundering / Automatic Exchange of Information / Common Reporting Standard / Dividends / Double Tax Treaty / Financial Institutions / Income Tax / Legislation / OECD / Regulatory / Taiwan / Tax Exempt / Tax Laws

Taiwan wealth management update

Posted On: May 15, 2018

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

China / Corporate Tax / Dividends / Hong Kong / Investments / Residence / Tax Authority / Withholding Tax

Withholding Corporate Income Tax in China

Posted On: May 9, 2018

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

Dividends / Double Tax Avoidance Treaty / Individuals / Offshore Companies / Qatar / Tax Evasion / Ukraine

Ukraine and Qatar sign agreement on avoiding double taxation

Posted On: March 23, 2018

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

Beneficial Ownership / Business / China / Dividends / Interest / Royalties / Tax Laws / Tax Treaty Abuse

China Sets Out How To Determine Beneficial Owner For Treaties

Posted On: February 13, 2018

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

Dividends / Income Tax / IRS / Jurisdiction / Starr International Company / Statute of Limitation / Switzerland / Tax Dispute / Tax Refunds / USA / Withholding tax rules

Swiss Taxpayer Wins US Tax Treaty Refund Dispute

Posted On: February 6, 2018

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

Alphabet Inc. / Amgen / Apple / CISCO / Dividends / Ernst & Young / General Electric / Income Tax / IRS / Legislation / Microsoft / Multinational Corporations / Offshore Companies / Oracle / Revenue

Apple Could Get a $4 Billion Boost From Tax-Law Quirk

Posted On: January 11, 2018

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

Base Erosion & Profit Shifting / Canada / Dividends / Gaar / Income Tax Act / OECD / Tax treaties / Withholding Tax

New PPT rule in the OECD’s Multilateral Instrument to displace Canadian GAAR?

Posted On: November 27, 2017

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

Capital gains / Dividends / France / Income Tax / Individuals / Interest / Legislation / Real Estate / Tax Laws

French Lawmakers Adopt 2018 Finance Bill

Posted On: October 25, 2017

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

Dividends / Indonesia / Shell / Tax Haven / Withholding Tax

New regulation forces Indonesians to sell their foreign shell companies

Posted On: October 2, 2017

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

Business / Corporate Tax / Dividends / Estonia / Loans / OECD / Revenue

OECD Criticizes Estonia’s Dividend Tax Measure

Posted On: September 19, 2017

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

Dividends / Double Taxation / Immovable Property / Interest / Japan / Royalties / Russia / Shares / Withholding Tax

Japan, Russia Agree New Double Tax Pact

Posted On: September 13, 2017

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

Follow:

Trending Now

Top 10 Sources