Category: Lease

HK’s proposed dedicated tax regime for offshore aircraft leasing

The Hong Kong Government has put forward a proposal to amend its tax laws to establish a dedicated tax regime for aircraft owners/lessors based in Hong Kong and leasing to offshore (including PRC) lessees/airlines (see Timeline / References below) (“Proposed Regime”). Assuming there are no surprises or drafting issues in...

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...

Once A Tax Haven, Gibraltar Now Says It’s Low-Tax

Gibraltar, a tiny British territory at Europe’s southern tip, is famous for its geography — a huge limestone rock — that appears on the Prudential logo. It’s a global center for offshore banking, with the trappings of wealth to prove it: Luxury high-rises tower over super yachts in Gibraltar’s marina. The...

Monitor offshore investments, IMF tells Mauritius

The International Monetary Fund (IMF) has askedMauritius to set up a ‘macro-prudential authority’ to monitor the offshore investments from the island. One of the largest destinations of such offshore investments is the Indian stock market. The proposed authority will have a central role for the banking regulator, the Bank of...

Bloomberg BNA Provides Insights into 2016 U.S and International Tax Policy

ARLINGTON, Va., Jan. 14, 2016 /PRNewswire-USNewswire/ — Bloomberg BNA today announced the publication of the Daily Tax Report’s 2016 Outlook on tax and accounting policy. Dozens of policy experts, along with current and former members of Congress, congressional staffers and federal agency officials provided insights on the year ahead regarding...

Italian groups seek EU antitrust probe into McDonald’s

BRUSSELS – Three Italian consumer organizations have urged EU antitrust regulators to investigate McDonald’s (MCD.N) franchise system in Europe, a month after the opening of an EU inquiry into the U.S. fast food company’s tax deals with Luxembourg. Codacons, Movimento Difesa del Cittadino and Cittadinanzattiva filed their complaint with the...

United States: Extenders Bill Puts An End To Tax-Free REIT Spinoffs But Includes A Number Of Favorable Changes To The Taxation Of REITs

On December 18, 2015, the President signed the Omnibus Appropriations Act (the “Act”) into law.1 Notably, the Act contains a number of substantive changes to the tax laws applicable to “real estate investment trusts” (“REITs”). Although several changes will adversely affect certain REITs, on balance REITs and their investors fared...

Tax amendments – 2015

INTRODUCTION The Taxation Laws Amendment Act, 2015 and the Tax Administration Laws Amendment Act, 2015 have both now been passed by Parliament, but await signature by the President. Once again, and now for the second year running, the number and scope of the changes to the various fiscal Acts (mainly...

Cyprus: Tax Incentives For Expatriate And High Net Worth Individuals Relocating To Cyprus (In Russian)

INTRODUCTION In the context of changes in the international system of taxation of the company in the choice of jurisdiction for the implementation of operational activities closely fit to the question of economic feasibility, to protect their interests. The strategic location of Cyprus, the presence of the country’s full membership...

Base erosion and profit shifting: limiting tax deductions for interest costs

Earlier this week the heads of state of the 20 largest global economies have agreed to adopt the 15 BEPS action points in their respective countries. Ample reason to take a closer look at the details and implications of one of the most far-reaching upcoming tax adjustments. Action 4 of...

United States: Tax Alert: G20 Leaders Approve OECD Proposals For Comprehensive Global Reform Of The International Tax System, Including Redefinition Of “Permanent Establishment”

Measures Will Impact Financial Services, Investment Fund, Aviation Leasing and Other Sectors G20 finance ministers last week finally approved the wide-ranging “BEPS” reforms to the international tax system. The measures include a proposed new OECD treaty definition of “Permanent Establishment” under which the mere negotiation of contracts could create a...

Canada: Navigating BEPS: What The Tax Function Of Today Needs To Know For Tomorrow

The Organisation for Economic Co-operation and Development (OECD) has described its newly unveiled Base Erosion and Profit Shifting (BEPS) Action Plan as a “change of paradigm.”1 A few very large global groups aside, a more apt description may be a minefield for the unwary. BEPS has received considerable air time...

Opening Bell: Ireland told not to rely on low taxes to grow, NAMA’s dispute with Dunnes, Draghi’s statement on Ireland

The Organisation for Economic Co-operation and Development’s (OECD) chief economist has warned that Ireland cannot rely on low corporation taxes to fuel growth. “Ireland is going to have to seek real investment based on comparative advantages other than tax,” Prof Catherine Mann told a conference hosted by the Irish Department...

Liberia amongst top countries operating in financial secrecy

In a report leased by the international group Financial Secrecy, the group that carries out analysis of how far the legal systems of countries facilitate financial secrecy, Liberia is ranked amongst the top 30 countries in the world that deals in secrecy. While the Government of Liberia continues to boast...

Benefits of UAE-Based Offshore Companies

Offshore companies are established for a variety of reasons including a company’s necessity to restructure, create an international business entity as well as protect the assets of the company. The United Arab Emirates (UAE) is home to three authorities that register International or offshore companies. The three UAE authorities that...

Is a Canada Revenue Agency landlord avoiding taxes via offshore havens?

The Canada Revenue Agency (CRA) rents office space from a Vancouver-based property developer – a company that exploits offshore tax havens in Liechtenstein, the British Virgin Islands and Channel Islands. Larco Investments Ltd. owns three buildings in Montreal, Calgary and Edmonton where they rent office space to the CRA. Larco...

NORWAY: BUDGET 2016; MORE ABOUT PROPOSED TAX REFORM

The Norwegian conservative government on 7 October 2015 published both the proposed state budget for 2016 and a “white paper” containing proposals for tax reform. The proposed tax reform in the white paper is a follow-up action from a report on tax reform, presented by the Tax Commission in late...

Treasury release draft law for implementation of the Common Reporting Standard

In brief On 18 September 2015, Treasury released exposure draft legislation in relation to the implementation of the Organisation for Economic Co-operation and Development’s (OECD) Common Reporting Standard (CRS) for the automatic exchange of financial account information. The CRS is intended to reduce international tax evasion and represents the next...

Some of Plymouth’s most well-known landmarks are owned by offshore companies

SOME of Plymouth best-known landmarks are owned by secretive offshore companies based in tax havens, it has been revealed. Swathes of land all over the city belongs to faceless firms based in places like Luxembourg and the Cayman Islands, The Herald can reveal. They include everything from historic former military...

Revealed: St Austell property owners registered in offshore tax havens

Tens of millions of pounds worth of property in St Austell is owned by companies based in offshore tax havens. They include large parts of Fore Street in the town centre; the beaches at Carlyon Bay, and dozens of individual buildings throughout St Austell and the clay country. NHS Kernow’s...

The Netherlands – Budget 2016

On September 15, the Dutch government released its Budget 2016, containing the Tax Plan 2016 which includes certain amendments to Dutch tax law. The government will discuss the plans the coming weeks in parliament. Further to these discussions, some elements of the Tax Plan 2016 may change. Most proposals will...

Tax rate on intellectual property profits would be cut to approximately 10% and appreciated intellectual property could be repatriated free of current tax under bipartisan innovation box proposal

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...

UK: Weekly Tax Update – Monday 20 April

1 General news 1.1 HMRC organisation chart HMRC has published its latest organisation chart showing the names of senior management. One point to note is the number of senior people now in roles such as change management as opposed to being in pure technical roles. This clearly demonstrates the direction...

Budget 2015: striking a balance in an election year

Finance Minister Joe Oliver faced formidable challenges, both economic and political, in delivering his first Budget. In a time of depressed oil prices, and mere months ahead of the next federal election, it appears he felt it was imperative to follow through with prior commitments to balance the budget, provide...

Malta: Business, Investments And Residency Opportunities!

TL: What are the main considerations and advantages for doing business in Malta? AB: Malta’s positive approach to business promotion, development and standard of living within the EU makes the island a destination of choice for relocation of business purposes. Malta offers noteworthy benefits to individuals and investors who are...

Administration Proposes to Repeal Deferral, Haircut the Foreign Tax Credit and Interest Expense Deductions, Override Treaties, and Abandon Arm’s-Length Transfer Pricing for Intangibles

As the above title indicates (it is only a modest exaggeration), the Treasury Greenbook regarding the FY 2016 budget proposes a radical restructuring of the system for U.S. taxation of foreign income of U.S. multinational enterprises (MNEs). Some Congressional players have suggested that these proposals are an opening bid in...

New tax treaty between Hong Kong and mainland China which has consequences for shipping, airline and securities trading companies

This is relevant mainly for (1) Hong Kong companies or investment funds selling securities in Chinese listed companies and (2) ship or aircraft leasing companies resident in Hong Kong who (finance) lease vessels and aircraft to lessees in mainland China. On 1 April 2015, Hong Kong and mainland China signed...

France: French Tax Update – Early 2015 Noteworthy Case Law And Tax Transparency Package

The present French Tax Update will focus on (i) several noteworthy French and European Union court decisions issued in the last months of 2014 and in the first months of 2015, and (ii) the recent presentation by the European Commission of a package of tax transparency measures. VALIDITY OF TAX...

Greens to question Foreign Investment Review Board over Adani coal venture

Senate hearings to question alleged links between firm behind Queensland’s Abbot Point coal port, a Cayman Islands company and a $1bn rorts investigation The Greens will use Senate hearings to question the Foreign Investment Review Board (Firb) about alleged links between Australia’s biggest proposed coal venture, a Cayman Islands company...

Labour advising its local parties to minimise tax

Labour is instructing local parties to “minimise” tax when buying and selling properties, the Daily Telegraph can disclose. A leaked document reveals that Labour is advising their constituency parties on how to cut their tax liability and that of the national party. The disclosure will be hugely embarrassing for Ed...