Category: Withholding tax rules

Ireland Budget 2020 released

On 8 October, the Irish government announced its Budget 2020 measures. Brexit and climate change are core themes of new revenue measures and expenditure commitments. Brexit remains the foremost immediate concern for the Irish economy, whereas tackling climate change requires long-term commitments to tax and spending policies. ... - Continue reading

Bermuda: Chambers Private Wealth 2019: Bermuda (2019)

1. Tax1.1 Tax regimes In Bermuda there is no income or profits tax, withholding tax, capital gains tax, capital transfer tax or inheritance tax. There is no exit or similar such tax based on a resident's wealth when ceasing to be resident and there are no other consequences of leaving the jurisdiction. Customs duties and stamp duty are major government revenue earners, with stamp duties charged at different rates and in different manners on a variety of legal documents, excluding wills. ... - Continue reading

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

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

Canada: Canada Ratifies The Multilateral Instrument

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

Cyprus: The Cyprus Investment Programme And The Benefits

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

Hong Kong: A Guide To Tax Regulations In Hong Kong 2019 – 2020

While considering moving a business into a new market, one of the key consideration is that country's tax regime. What are the incentives that would attract foreign investment? Are there any double tax treaties in place? What is the rate for corporate tax? ... - Continue reading

UK: Non-Resident Capital Gains Tax on United Kingdom Real Estate: A New Regime

The legislation encompassing the new regime for taxing non-residents' gains on the United Kingdom (UK) commercial real estate came into effect on 6th April 2019. Her Majesty's Revenue and Customs (HMRC) has additionally published draft guidance on this recently introduced regime. This article briefly summarizes the new rules. ... - Continue reading

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

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

Revised tax treaties usher in a new era in investment, taxation

Policy tweaks  curb evasion,  show  India  can woo investments without  sops Singapore, another major FDI contributor to India, too, enjoyed the same tax sops under a similar treaty with India NEW DELHI: For about a decade-and-a-half, revenue authorities examining foreign investment proposals received by the erstwhile Foreign Investment Promotion Board… – Continue reading

Non-resident capital gains tax on UK commercial property ‘could block overseas investment’ – expert view

The Government’s changes to the tax treatment of overseas investment in UK commercial property will increase revenues in the short term but might prove short-sighted, write Craig Hughes and Russell Dickie There is, as they say, no place like home. However, in recent years, solid and steady capital growth and… – Continue reading

PSX recommends CGT exemption for foreign investors in next fiscal year

—Says exemption to facilitate capital inflow by relaxing account opening, registration process ISLAMABAD: The Pakistan Stock Exchange (PSX) in its proposals for budget 2019-2020 has recommended exemption of capital gain tax (CGT) on disposal of securities by foreign investors. Budget proposals for next fiscal year 2019-20, available with Pakistan Today,… – Continue reading

HMRC targets wealthy families with trusts

Changes to Britain’s centuries-old trust regime are looming as HMRC is concerned that trusts are letting some families pay less inheritance tax than those who do not pay accountants to set up the complex arrangements. To look at if the law should be changed, HMRC has published wide-ranging research of… – Continue reading

Ireland Implements New Exit Tax Regime

Ireland’s 2018 Finance Bill legislates for a new exit tax regime compliant with the EU’s Anti-Tax Avoidance Directive. The exit tax charge was introduced via financial resolution on Budget night, October 9, 2018, and applies to certain events occurring on or after October 10. Finance Bill 2018 formally legislates for… – Continue reading

Walmart-Flipkart Deal: Income Tax Dept Rejects Plea For Capital Gains Exemption

Income Tax department is also inquiring into some alleged suspicious transactions and investment flow into Flipkart Authorities have demanded a valuation report from Flipkart The international taxation division of the I-T department is currently studying the valuation of Indian assets of Flipkart Singapore At the time when ecommerce company Flipkart… – Continue reading

Capital Gain Exemption can be allowed to House Property acquired in Foreign Countries: ITAT [Read Order]

The Bangalore bench of the Income Tax Appellate Tribunal (ITAT) held that the assessee is entitled for capital gain exemption under section 54F of the Income Tax Act in respect of the properties acquired outside India. In the instant case, the Revenue approached the Tribunal contending that for granting benefit… – Continue reading

Warning to declare foreign income before September deadline

UK taxpayers who receive any foreign income or profits from offshore assets have been urged to contact HMRC and disclose this income before 30th September 2018 to avoid being hit by higher penalties. David Redfern, tax preparation specialist and director of DSR Tax Claims, warned those affected to contact HMRC… – Continue reading

Corporate America now knows how to tally its repatriation taxes

U.S. companies that had been unsure of how to calculate a new tax on profits they’ve stashed offshore now have official answers. The Internal Revenue Service issued proposed regulations on Wednesday on Section 965, governing the so-called repatriation tax, detailing which corporate taxpayers are subject to the tax, which assets… – Continue reading

HMRC warn UK taxpayers it’s time to declare offshore assets

HM Revenue and Customs (HMRC) is urging UK taxpayers to come forward and declare any foreign income or profits on offshore assets before 30 September to avoid higher tax penalties New legislation called “Requirement to Correct’ requires UK taxpayers to notify HMRC about any offshore tax liabilities relating to UK… – Continue reading

BEPS Project Has Triggered Near-Global Tax Reform: OECD

The OECD has committed to providing proposals to fix the taxation of the digital economy by 2020, in an update to G20 leaders on international efforts to mitigate base erosion and profit shifting (BEPS). In the newly released Second Annual Progress Report of the OECD/G20 Inclusive Framework on BEPS, the… – Continue reading

Which Countries is The Cryptocurrency Taxed In?

The cryptocurrency industry is still at a very early stage of its development, so there are no single international rules yet. The governments of individual countries independently try to regulate digital assets. The tax on the cryptocurrency varies in different countries. Within the framework of this article, we will try… – Continue reading

US imposes reporting rules on Delaware Companies

Revamped rules for Delaware Companies create new reporting obligations for owners and eliminate any vestiges of confidentiality that once made these offshore structures attractive for many property buyers. Effective since the beginning of 2017, Delaware Limited Liability Companies (LLCs) that are wholly owned by a non-resident, now become subject to… – Continue reading

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

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

Australia to Fight Crypto Tax Avoidance with Bilateral Data Sharing

Australian Tax Authority will use bilateral data sharing agreements to collect taxes on cryptocurrency income. The Australian Tax Authority (ATO) will seek international cooperation to tackle hiding of cryptocurrency income, ATO acting deputy commissioner Martin Jacobs told local media on Friday. This year Australian traders must file tax declarations about… – Continue reading

A look at the Philippines-Mexico double taxation agreement

The Bureau of Internal Revenue (BIR) has issued Revenue Memorandum Circular (RMC) No. 58, 2018 on the Agreement for the Avoidance of Double Taxation on income tax between the Philippines and Mexico, which has entered into force last April 18, 2018. The Agreement was signed in November 17, 2015 between… – Continue reading

New Legislation impacts Offshore Property Companies

The walls continue to close in on Offshore property holding companies in Portugal. Once a popular solution for home ownership, these structures are based in low-tax jurisdictions that allow shareholders to take advantage of certain “loopholes” to avoid paying Capital Gains tax when selling. Over the past 15 years, successive… – Continue reading

Should HMRC have more time to investigate offshore tax?

A recent proposal to amend HMRC rules for offshore is about to make tax investigations even more onerous, writes Colin Senez UK tax is complicated and convoluted and in certain circumstances can be tortuous. If you then add offshore taxation to the equation then the position can be even more… – Continue reading

Walmart-Flipkart deal: Buyout liable to tax in India; I-T Dept awaits formal pact

Some advantage could be there under Double-Tax Avoidance Agreement: experts MUMBAI, MAY 8 The $15-billion buyout of e-commerce player Flipkart by US retail giant Walmart is likely to attract capital gains tax under Indian laws, similar to the tax imposed on Vodafone, even though the entities are headquartered abroad. Some… – Continue reading

Crypto Enthusiasts Demand Thailand’s Finance Ministry Revamp Taxation Guidelines

Capital gains taxes will always remain a controversial topic. This is especially true in Thailand, by the look of things, as the cryptocurrency community wants the nation’s Finance Ministry to rethink its guidelines in this regard. For most people, this is also an effort to create a more lenient ecosystem… – Continue reading

Australian Tax Office Seeks Input On Cryptocurrency Tax Obligations

The Australian Tax Office (ATO) has launched a community consultation to seek feedback on practical compliance issues arising from complying with taxation obligations in relation to cryptocurrency transactions. On March 13, the ATO updated its web guidance tax treatment of cryptocurrencies to address some of the common enquiries in relation… – Continue reading

Buhari signs double taxation agreement with Singapore

President Muhammadu Buhari on Monday signed two agreements with two countries following the approval of the Federal Executive Council (FEC). The agreements, according to a statement issued by the Special Adviser on Media and Publicity to the President, Femi Adesina, include the instrument for ratification of agreement between Nigeria and… – Continue reading

China’s Anti-tax Avoidance Rules

The general anti-avoidance rule was first introduced in China under the 2008 CIT Law. It empowers Chinese tax authorities to make reasonable adjustments where an enterprise implements an arrangement without reasonable business purposes in order to reduce its taxable income or profit. According to the CIT Law’s Implementation Guidelines, “an… – Continue reading

India Clarifies Capital Gains Tax Changes

India’s Central Board of Direct Taxes (CBDT) has released further information on the long-term capital gains tax announced in the recent budget, in the form of a list of answers to frequently asked questions. Explaining the change, the CBDT noted that, under the existing regime, long-term capital gains arising from… – Continue reading

Swiss Taxpayer Wins US Tax Treaty Refund Dispute

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

India Turns Attention to Bitcoin Exchanges to Investigate Tax Evasion

On December 13, 2017, the Indian income-tax department reportedly conducted surveys at bitcoin exchanges across the country to assess the risk of individuals who may have evaded taxes. Surveying Indian Exchanges Typically such surveys are conducted by the department without prior warning and include relatively extensive scrutiny of the assessee’s… – Continue reading

Barbados To Sign OECD Pact To Revise Its DTAs In January

Barbados says it expects to sign the new OECD BEPS Multilateral Instrument at the end of January 2018 to introduce changes to its tax treaty network to prevent base erosion and profit shifting. The “Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS)”… – Continue reading