According to recent estimates, Estonia, which is situated halfway between Stockholm and St. Petersburg, currently has more than 350 start-up technology companies – one for every 3,700 citizens – and the government expects this number to reach 1,000 by the year 2020. This makes Estonia the number one start-up technology… – Continue reading
A case is pending before an appellate court in South Korea that could allow refunds of certain amounts of tax withheld on payments distributed to Luxembourg SICAVs. If the appeals are ultimately decided in favor of the SICAVs, they could be entitled to a refund of the difference between the… – Continue reading
South African companies who do direct and indirect business with US organisations, whether in South Africa, Africa, Europe or further afield, must comply with the United States Foreign Account Tax and Compliance Act (FATCA,) or risk being excluded from lucrative markets the world over, reports the Cape Business News. This… – Continue reading
HM REVENUE & CUSTOMS has published a factsheet illustrating the overhaul of the way dividends are to be taxed from 2016. The move, announced in July’s Summer Budget, wipes out the tax advantage of taking payment as a dividend. The tax credit applied to dividends is to be replaced with… – Continue reading
On 1 April 2015 Cyprus and South Africa signed a Protocol amending their existing double taxation agreement (“DTA”), which was signed in 1997 and has been in force since 8 December 1998. The Protocol amends the 1997 DTA in three areas, namely the definition of residence, withholding taxes on dividends… – Continue reading
Luxembourg has proposed major corporate tax changes which would bring the Grand Duchy into line with recent updates to the Parent-Subsidiary Directive. The Luxembourg government released Bill 6847 (the Bill) on August 5 2015, which includes proposed tax measures for corporations and follows several recent announcements from Finance Minister Pierre… – Continue reading
U.S. COMPANIES HOLDING CASH ABROAD WAITING FOR TAX REFORM. The high U.S. tax rate continues to encourage companies to stash cash and profits offshore while executives wait for tax reform. The Street has an interview with computing giant Cisco’s CFO Kelly Kramer on the company’s plans for more the more… – Continue reading
The Polish Ministry of Finance has published the text of the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income as concluded on July 13, 2015 between The Republic of Poland and the Federal Democratic Republic of Ethiopia (Hereafter: the… – Continue reading
Surprising as it may seem, most of the advantages of the Cypriot Tax Regime were, up until recently, mostly directed to non- Cypriot Tax residents. This effectively meant that in order to enjoy the full benefits of the Regime one had to be a non-resident. The idea behind this was… – Continue reading
On July 29, 2015, Charles Boustany (R-LA) and Richard Neal (D-MA) released a bipartisan discussion draft of proposed Internal Revenue Code (the “Code”) amendments that would cut the United States income tax rate on corporate profits generated from patents and certain other intellectual property to approximately 10% (the “Tax Rate… – Continue reading
On August 10, 2015 the Dutch Government published the text of a Protocol amending the Agreement between the Government of the Kingdom of the Netherlands and the Government of the Republic of Indonesia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on… – Continue reading
In order to maintain a competitive edge, Malta offers wealthy individuals and corporations advantageous tax rates, using tax breaks to attract investment or hot money, which could originate from criminal activities Malta is this year expected to register the fastest growth rate in the EU, with property prices rising year… – Continue reading
On May 13, 2015, Cyprus and Georgia signed a new double taxation agreement (DTA). Unlike many former members of the USSR, Georgia did not adopt the 1982 Cyprus–USSR DTA when it became independent, and the new agreement is the first between the two countries. It will come into force once… – Continue reading
Muscat – H E Christian Winter, Switzerland’s Ambassador to Oman has said that the recently signed Double Taxation Agreement (DTA) between his country and the sultanate reflects the broader ties Switzerland seeks with GCC. “The conclusion of the agreement takes into account the growing economic and political importance of the… – Continue reading
HMRC has won £45 million in a second tax avoidance case against Abbey National Treasury Services, a subsidiary of Santander. The tribunal ruling means £45 million is now liable to taxation in addition to another £40 million in a second case that will be decided by this ruling. The scheme… – Continue reading
Germany has the largest economy in Europe. Along with the developed infrastructure, investors will also benefit from the advanced technology that will ease integration in many industrial sectors, and the highly specialized as well as educated workforce. In terms of the taxation of foreign investment, the taxation system in Germany… – Continue reading
There is nothing in the Reliance Quant Plus Fund to attract an investor. The fund has consistently lagged its category and the benchmark Nifty in the past five years. Its past one year performance is ranked 141 out of 143 large-cap equity funds. Value Research has put it in the… – Continue reading
On July 17, 2015, the Internal Revenue Service (IRS) released three new “practice units,” each examining a particular type of transaction involving a controlled foreign corporation (CFC). The IRS develops practice units internally for use both as training materials and as job aids for examiners. Practice units are not formal… – Continue reading
Understanding FATCA and having a comprehensive FATCA compliance program is essential for financial firms to limit non-compliance risk and meet obligations with relevant IGA’s. The US has made inroads on the Exchange of Information front and tax havens like Switzerland have declared a willingness to meet or even exceed OECD… – Continue reading
Over the past year, a number of legislative measures have been adopted to ensure that the Cayman Islands remains the leading jurisdiction of choice for structured finance and capital markets transactions and for secured lending transactions generally. This article focuses on two recent key legislative developments. The first is the… – Continue reading
Over the past year, a number of legislative measures have been adopted to ensure that the Cayman Islands remains the leading jurisdiction of choice for structured finance and capital markets transactions and for secured lending transactions generally. This article focuses on two recent key legislative developments. The first is the… – Continue reading
There is a rising trend that many start-ups incorporate their ultimate holding companies abroad, especially in Singapore for various reasons with tax being one of the top 3 factors for such decisions. Some of them have restructured the holding structures after few months of direct Indian holding to accommodate requests… – Continue reading
Introduction The Cyprus Government has announced a number of proposed tax incentives aimed at encouraging economic activity and attracting inward direct investment. It has also submitted a number of draft laws to the House of Representatives to implement the new provisions of the EU Parent-Subsidiary Directive, to simplify the tax… – Continue reading
In the first 100% Conservative Budget in nearly two decades, chancellor George Osborne has introduced a raft of changes, including significant revisions to UK non-dom status. On 8 July, chancellor George Osborne delivered the first Conservative Government Budget for 19 years. Many headlines had already been flagged up in advance,… – Continue reading
Introduction The regulatory framework in Cyprus is all-encompassing but still attractive to investment funds for varied investor requirements. An investment fund may be set up in Cyprus either as an Alternative Investment Fund (“AIF”), or as an Undertaking for Collective Investment in Transferable Securities (“UCITS”). Cyprus administers all internationally recognized… – Continue reading
TORONTO, CANADA — (Marketwired) — 07/29/15 — Canadian General Investments, Limited (“CGI” or “the Company”) (TSX:CGI)(TSX:CGI.PR.C)(TSX:CGI.PR.D)(LSE:CGI) has declared a quarterly dividend of $0.14 per share payable on September 15, 2015 to common shareholders of record at the close of business on August 31, 2015 (“the Dividend”). The Dividend is a… – Continue reading
This article deals with the manner in which Canada has complicated, and rendered controversial, what in most other countries is straightforward — the deductibility of business related interest expense. The reasons to write about it are threefold: the almost-concurrent issuance of the Canada Revenue Agency’s administrative views on the matter… – Continue reading
With the focus of 2014 being international tax competition, 2015 shows signs of continuing this trend. The European Commission (COM) and European Parliament (EP) are starting to debate and extensively investigate Member States’ tax ruling policies, partly as a result of the LuxLeaks revelations and partly in relation to the… – Continue reading
NEWS DELHI: It has consistently lagged the large-cap equity fund category and the benchmark Nifty in the past five years. Its past one year performance is ranked 141 out of 143 large-cap equity funds. Mutual fund tracker Value Research has put it in the doghouse with a two-star rating. Yet,… – Continue reading
Introduction US tax treaty policy can be affected by pressures for tax reform from within the United States and by major developments in international taxation from without. Talk of US tax reform has been widespread for years, although it is sometimes hard to gauge how much of the talk is… – Continue reading
July 22: Tax legislative changes in Austria were passed by the parliament, and the effective date for most changes is 1 January 2016. Among the provisions are the following items. Withholding tax on dividend distributions, capital gains The withholding tax rate for dividends and capital gains will be increased to… – Continue reading
Mexico on July 17, 2015, published the text of its agreement with Turkey to avoid double taxation between the two countries and prevent tax evasion. The double tax agreement (DTA) was signed in 2013 and is valid from July 23, 2015. Under the agreement, dividends will be subject to a… – Continue reading
Irish people investing in other countries often lose up to a fifth of dividends Irish tax refund specialists Taxback. com have introduced an online service to help people recover tax withheld on share dividends in other countries. *Irish people investing abroad often lose up to a fifth of their dividends… – Continue reading
July 17: The Japanese Ministry of Finance on 16 July 2015 announced that the governments of Japan and Germany reached an “agreement in principle” for a new income tax treaty. The new treaty would replace the existing agreement signed in 1966, and subsequently amended in 1979 and in 1983. According… – Continue reading
Guernsey has for some time been the domicile of choice for non-UK companies listing on the main market of the London Stock Exchange (“LSE”), the Alternative Investment Market (“AIM”) and the Specialist Funds Market (“SFM”). The Island has developed expertise in the set up and administration of a range of… – Continue reading
About 700,000 taxpayers are likely to face tax rises as a result of George Osborne’s “major and long overdue reform” of dividend taxation that is set to raise £2.5bn next year, the Financial Times reports. It will push up the tax bills of top-rate taxpayers receiving more than £25,250 in… – Continue reading
Over the past few months, several foreign portfolio investors registered in India have received notices from the Indian tax authorities demanding payment of Minimum Alternate Tax in respect of transactions which took place over the course of prior assessment years. The Indian Government has indicated that it could raise several… – Continue reading
Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely questioned whether this tax is compliant with the provisions of the EU treaties and the double tax treaties signed by France. French subsidiaries whose parent… – Continue reading
In a recent case involving Next Brand Ltd, the First-Tier Tribunal ruled in favor of HM Revenue & Customs (HMRC), finding that double tax relief was not available for dividends that in effect represented loan repayments. Background Prior to the introduction of the dividend exemption, when a UK parent company… – Continue reading
European Commission to issue decisions on four test cases, including Apple in Ireland, Until a few months ago, the medieval town of Athenry in County Galway owed its fame mainly to a song. Irish rugby and football fans often burst into stirring renditions of “The Fields of Athenry”, a ballad… – Continue reading
On 07th July 2015, the United States and Vietnam signed an income tax treaty with Vietnam, the first ever between the two countries. The Double Taxation Agreement applies to personal income tax and enterprise income tax in the case of Vietnam. What is a permanent establishment? Under the Double Taxation… – Continue reading
Portugal is an increasingly desirable destination, thanks to its tax-friendly stance. Portugal may not be top of everyone’s list in terms of tax-friendliness, particularly given the recent backdrop of the recession and bail-out, but it does have a history of running successful tax-friendly programmes, for example the Madeira and Azores… – Continue reading
Over the past few months, several foreign portfolio investors registered in India have received notices from the Indian tax authorities demanding payment of Minimum Alternate Tax in respect of transactions which took place over the course of prior assessment years. The Indian Government has indicated that it could raise several… – Continue reading
On 10 July 2015, Liechtenstein and Switzerland signed a new Income and Capital Tax Treaty. Once in force and effective, the new treaty will replace the old one of 1995. The new treaty will come into force after the two countries exchange ratification instruments. The provisions of the new treaty… – Continue reading
One of the most immediate and obvious consequences of globalisation is the impact of domestic tax policies in other countries on the economy of Tanzania. This has necessitated the continuous evaluation of the tax regime in Tanzania and brought about crucial fiscal and economic reforms in the country. Hence, the… – Continue reading
A “tax allowance”. That’s what the Government calls the new £5,000 tax-free band of dividend income announced in the Budget. In other words, it’s a favour they are doing us – offering a tax perk, akin to the breaks on Isas or the tax-free personal allowance. By introducing a dividend… – Continue reading
On July 8, 2015, the International Tax Reform Working Group, which is co-chaired by Senators Rob Portman (R-OH) and Chuck Schumer (D-NY), released its long-awaited report that Senate Finance Committee Chairman Orrin Hatch (R-UT) has said is the precursor to comprehensive tax reform in the United States. What does the… – Continue reading
Around £60m earmarked for serious and complex tax-crime investigations, while £300m will target small businesses, public bodies and affluent individuals Stretched HMRC tax investigators are to be armed with £800m of extra funding over the next five years to combat tax evasion and non-compliance, the chancellor has promised, as part… – Continue reading
On 17 June 2015, the Income Tax Treaty between Malta and Moldova entered into force and will come into effect on 1 January 2016. The Treaty was signed on 10 April 2014. In accordance with the treaty, the following withholding taxes will apply: Dividends: where the dividends are paid by… – Continue reading
Where Qualified Dividend Treatment Is Important, Serious Consideration Should Be Given to Ensuring the Company Is Eligible for Treaty Benefits Before Taking It Public. Dividends generally are taxed at ordinary income rates (up to 39.6 percent for individuals). Qualified dividends derived by individuals, however, are taxed at the preferential rate… – Continue reading
