Category: Real Estate

Cyprus: A fairer tax regime

The Cyprus government recently announced a number of tax incentives aimed at encouraging economic activity and attracting inward direct investment. At the same time it 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

Tax Free Profits to Non-Domiciled Investors to Boost Cyprus’ Investment Appeal

Dubai – Cyprus’ recently revised taxation framework make sit the only citizenship-by-investment program in Europe to offer non-domiciled investors tax free profits. Will this new tax regime and business incentives attract more foreign direct investment (FDI) into the country? Henley & Partners, the global leaders in residence and citizenship planning… – Continue reading

Worldwide: Double Tax Treaties – Ratification Update

LUXEMBOURG On September 5, 2014, the Ministers of Finance of France and Luxembourg signed an amendment (Lux Amendment) to the double tax treaty entered into between France and Luxembourg on April 1, 1958, as amended by the 1970 exchange of letters and by the 1970, 2006, and 2009 protocols (FR/Lux… – Continue reading

Use of Estonia in U.S. International Tax Planning

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

Summer Budget 2015: new rules for non-domiciled individuals

Introduction Individuals whose domicile of origin is outside United Kingdom Non-UK individuals with UK domicile of origin Consultation and legislation New inheritance tax rules for UK residential property held within offshore corporate envelopes Comment Introduction Individuals domiciled outside the United Kingdom might have been justified in thinking that they would… – Continue reading

Offshore investments in insurance, real estate

With the objective of long-term sustenance of wealth created both inside as well as outside India and continuous revenue generation, high net-worth individuals (HNIs) in India have decrypted and adopted innovative methods for asset protection and estate planning. The latest addition to the existing gamut of methods are offshore investments… – Continue reading

Private equity braced for global tax changes

The private equity industry has long been known for its ability to take advantage of tax rules. But international changes are set to have an impact on their businesses. After a string of multinationals such as Apple, Google and Starbucks came under fire for paying minimal tax on their British… – Continue reading

LUXEMBOURG: TAX TREATY UPDATE, STATUS REPORT

Luxembourg currently has 76 income tax treaties in force, and there are 29 treaties under negotiation. Tax treaties can provide a legal framework not only for the avoidance of double taxation and fiscal evasion, but also for international administrative cooperation between Luxembourg and its treaty partners in terms of mutual… – Continue reading

Britain’s non dom crackdown could affect UAE expatriates

In his summer budget the first exclusively Conservative one in 19 years British Chancellor George Osborne outlined several key changes for non-domiciled individuals or non-doms, reports MENAFN. These major modifications coming into effect in April 2017 arguably represent the biggest shake-up to the non-dom status since it was first introduced… – Continue reading

Growing trend: Islamic finance goes offshore

The rise of Islamic finance and sukuk issuances have brought with it a growing phenomenon: Shariah banking is increasingly taking advantage of offshore banking jurisdictions, and this for a number of reasons, reports the Gulf Times. Many offshore centres around the world meanwhile offer a wide range of features allowing… – Continue reading

Britain’s non dom crackdown could affect UAE expatriates

In his summer budget the first exclusively Conservative one in 19 years British Chancellor George Osborne outlined several key changes for non-domiciled individuals or non-doms, reports MENAFN. These major modifications coming into effect in April 2017 arguably represent the biggest shake-up to the non-dom status since it was first introduced… – Continue reading

EY’s On the Beam: Issue 5

Since 2013, investment institutions have started to increase their investments in private healthcare institutions in mainland China. Though there hasn’t been a real local healthcare group, the modes of investment have become diversified, including the acquisition of healthcare institutions, the establishment of new healthcare institutions and the transformation of public… – Continue reading

Treasury proposes five major changes to the U.S. Model tax treaty

On May 20, 2015, the U.S. Treasury Department (“Treasury”) released five sets of proposed revisions to the U.S. Model Income Tax Convention (“Model Treaty”) for public comment. The Model Treaty was last updated in 2006. The purpose of the proposed revisions is to ensure that the United States maintains the… – Continue reading

Vancouver airport acts as major entry port for millions in cash smuggled by mostly Chinese citizens

Vancouver International Airport is the major port of entry for millions in hidden cash being smuggled into North America by mostly Chinese citizens, a federal document investigation by The Province reveals. And according to money laundering investigators, the amounts identified in Canada Border Service Agency cash seizure data, obtained by… – Continue reading

Country-by-Country Reporting in the EU: Spain Adopts Regulations and the European Parliament Votes for Public Disclosure

On 11 July 2015 a new Corporate Income Tax Regulation (CITR) was approved in Spain, introducing, amongst other things, amendments to the Spanish transfer pricing reporting requirements. The new requirements largely reflect the recommendations made by the OECD with respect to Action 13 of the OECD Base Erosion and Profit… – Continue reading

How did London become ground zero for the global plutocracy?

The opening of Arthur Conan Doyle’s A Study in Scarlet finds Afghanistan veteran Dr John Watson pondering his future. Inevitably, he finds himself in London, “that great cesspool into which all the loungers and idlers of the Empire are irresistibly drawn”. The century that followed saw London lose much of… – Continue reading

Sebi probing UBS on round-tripping : Companies in mining, liquor, and real estate also being investigated, it appears, with ED asked to have a look

In the midst of the Special Investigative Team (SIT) on undisclosed money flagging concern on participatory notes (p-notes), the Securities and Exchange Board of India (Sebi) says it is probing a case of alleged round tripping. The term refers to transactions between companies that bolster their revenue but, in the… – Continue reading

PKF suggestions for 2016 Budget

These proposals can be implemented individually or as part of other reforms that may be in the pipeline PKF wishes to contribute its part towards the next budget implementation and for this purpose it has researched new areas which in its opinion warrant attention by the government during the public… – Continue reading

New circular introduces key corporate-income tax changes

On June 22, 2015, the finance ministry issued Circular 96/2015/TT-BTC, guiding the corporate income tax regime in Decree 12/2015/ND-CP (“Decree 12”) of the government, dated February 12, 2015. Decree 12 provides the details for the implementation of the law that amends and supplements some articles of tax laws, tax decrees… – Continue reading

Cyprus: Cyprus’s New Package Of Tax Incentives And Technical Amendments

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

Cyprus: Cyprus Funds

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

The Netherlands: Recent Financial, Regulatory and Legislative Developments

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

Cyprus: More Tax Benefits In Cyprus

The Republic of Cyprus has once again kept its promise to international investors and introduced on the 9th of July 2015 amendments to its tax legislation making the jurisdiction as attractive as never before. The purpose of these amendments is to clearly establish Cyprus as the leading tax jurisdiction in… – Continue reading

India: Indian Revenue Issues Clarifications On The Black Money Act

Black Money Act covers residents with undisclosed foreign assets and income and non-residents who have invested Indian-sourced income in offshore assets Compliance Scheme window open only till 30 September for declaring assets and until 31 December 2015 to pay tax at 30% and penalty at 30%. Revenue recommends disclosure of… – Continue reading

Guernsey: fund domicile

Guernsey’s growth shows no sign of abating Guernsey’s reputation as a major fund domicile continues to grow. Figures from Guernsey Finance testify to this with funds under management and administration in Guernsey standing at £218.7 billion at December 2014. These funds cover multiple asset classes and types including closed-ended and… – Continue reading

The intersection of US tax treaty policy, tax reform and BEPS

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

More transparency over UK prime property ownership needed to prevent fraud, campaigners say

Plans to create a public registry of the real owners of UK companies should be extended to make it clear who is behind the companies that own high-value London properties, Global Witness has said. Plans to create a public registry of the real owners of UK companies should be extended… – Continue reading

Austria – Tax legislative changes, effective January 2016

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

Tax amnesty: an opportunity to be seized or a further challenge for business to tackle?

On 8 June 2015, the Law “On optional declaration of assets and bank accounts (deposits) by individuals” (the “Capital or Tax Amnesty Law”) came into force. It was announced as part of the deoffshorisation campaign and opens a window of opportunity for the business community to declare “grey” assets without… – Continue reading

Call for greater transparency in London property

In a published report, anti-corruption organisation highlights complex structures through which swaths of UK property are owned Global Witness has called for greater transparency around the ownership of UK properties after reviewing alleged links between a former Kazakh secret police chief accused of money laundering and a London property portfolio… – Continue reading

India consults experts on allowing foreigners to directly invest in venture capital and PE funds

The government has sought the opinion of legal experts on allowing foreigners to directly invest in Indian venture capital (VC) and private equity (PE) funds. A direct access under the “automatic route” would quicken fund inflows, cut cost and do away with investment pooling vehicles in tax havens such as… – Continue reading

Colliers’ Chinese ad for Auckland apartments talks up soft rules: ‘NO stamp duties and property purchase tax, NO capital gains tax’

New Zealand’s lack of overseas investment regulation is being promoted in Shanghai and Hong Kong to help sell apartments rising on the site of the country’s best-known record store. “NO stamp duties and property purchase tax, NO capital gains tax on residential property if sold after two years of holding,”… – Continue reading

Pete McMartin: Was offshore real estate data staring us in the face all this time? : B.C. government already asks for proof of citizenship for property transfer tax exemption

The abiding complaint of those who believe offshore buyers are driving the rise in real estate prices in Metro Vancouver is the lack of data to prove it. How can you identify a problem if you can’t quantify it? The corollary to that complaint is the provincial government’s apparent inability,… – Continue reading

Dirty Dealing: China and International Money Laundering

In the midst of turmoil in the Chinese stock markets, one serious problem that may appear is increased currency outflows created by current and potential investors who would rather move their assets to foreign countries viewed as safer havens. Money laundering should be under close surveillance. Chinese involvement in money… – Continue reading

Canada: Planning Using Principal Residence Trusts For Immigrants To Canada

As many of our readers know, the Canadian Income Tax Act (the “Act”) provides for an unlimited exemption from the imposition of Canadian income tax on the gains resulting from a disposition of a “principal residence”. Access to the principal residence exemption can be valuable, especially in cities (e.g. Vancouver,… – Continue reading

US Senate’s international tax reform working group has spoken… sort of…

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