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...
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...
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...
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...
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....
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...
A new tax treaty between Finland and Spain, which will broaden the Finnish Government’s taxing rights with respect to pension income, will be effective from 2019, according to the Finnish Ministry of Finance. The ministry said in a release issued on May 17 that under the existing tax treaty, pension...
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...
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...
Virtual currencies exploded onto the investment scene last year, due in large part to the astronomical rise in the popularity of Bitcoin and its many successors. Interest in this exciting new investment shows no signs of slowing, and soon cryptocurrency will be as ubiquitous as the other traditional securities traded...
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...
Expects to avoid the mandatory dividend distribution tax BENGALURU, JANUARY 24: Consultancy multinational Accenture Solutions expects to avoid a substantial amount of tax for its Indian operations as it seeks nod from its creditors on Thursday for reduction of its capital from ₹5,361 crore to ₹2,263 crore. It has now...
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...
The Canada Revenue Agency’s recently announced “postal code project” targets Canada’s richest neighbourhoods, to identify non-compliance apparent from discrepancies between residents’ tax reporting with their apparent wealth. Even prior to the postal code project, which focuses on any potential high net worth individual, the CRA had enhanced audit activity on...
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...
The Canadian Government is pressing ahead with plans to cut the small business tax rate. The Government has tabled a Notice of Ways and Means Motion in the House of Commons that proposes phased reductions in the small business tax rate. Under the changes, the rate will fall from 10.5...
International pension plans involve complex questions of structuring and compliance International Pension Plans (IPPs) are pension plans sponsored and funded by an employer, for employees assigned to work outside their home country, who are expected to receive IPP benefits while they are resident in their home country, or in another...
ECONOMYNEXT – Foreign investors in Sri Lanka’s rupee bonds may not have to pay taxes after April 2018, Deputy Central Bank Governor Nandalal Weerasinghe said, amid some uncertainty in markets how a new Inland Revenue law will be interpreted. Sri Lanka lifted a 10 percent withholding tax government bonds from...
Securities regulator SEBI has lifted the trading ban on 14 entities which were alleged to have misused the stock market platform for money laundering and tax evasion as it did not find any “adverse evidence” against them. The Securities and Exchange Board of India order was in the case related...
ECONOMYNEXT – Sri Lanka will charge a 10 percent capital gains tax on investments other than listed shares, under a new inland revenue bill to be effective from April 2018. The principle residence of a person, which has been owned for more than three years and in which a person...
Stock analysts in South Korea played down the possible impact of the government’s decision Wednesday to impose taxes on foreign investors holding over 5 percent of a company, but warned of widening volatility prompted by foreign investors’ sell-offs over the past couple of weeks. Starting January 2018, a broader scope...
The Act currently provides for income taxable as ‘capital gains’ to be computed after taking into account the full value of consideration received or accrued on transfer of a capital asset “A person doesn’t know how much he has to be thankful for until he has to pay taxes on...
Business group Ibec has said that the Irish Government must “Brexit proof” its 2018 Budget, improve its foreign direct investment model, and implement a range of tax reforms to compete with the UK. Publishing the group’s pre-Budget submission, Ibec Director of Policy and Public Affairs, Fergal O’Brien said: “The Irish...
THE BENEFITS OF NON-DOMICILE STATUS An individual who is resident but not domiciled in the UK does not pay tax on overseas income and gains, as long as they are kept outside the UK and are not used to provide benefits in the UK. This is called the remittance basis...
The Australian Government has moved to clarify the tax treatment of foreign investors, following concerns over the practical operation of the Investment Manager Regime (IMR) and the new tax system for managed investment trusts (MITs). The aim of the IMR is to attract foreign investment to Australia and the promote...
Regulator Sebi is mulling tightening its investigation and enforcement mechanism to check misuse of stock market platform for generating “bogus” long-term capital gains to launder black money. The markets watchdog has also come across cases wherein fraudulent tax benefits have been claimed through trades in some blue-chip stocks, as against...
Grandfathering is term for alteration of rules that apply to a certain investment technique Foreign portfolio investors (FPIs) based in Mauritius and Singapore had, it now appears, rushed to take advantage of the ‘grandfathering’ clause in the new Double Tax Avoidance Agreement signed between both the governments of the two...
Indian tax authorities have initiated a $4.75 billion penalty charge against Cairn Energy for failing to pay a capital gains tax demand of $1.58 billion on a 2006 transaction. Under Section 271(1)(c) of the Income Tax Act, Indian tax authorities can levy a maximum 200 percent penalty against transactions after...
Tax residency certificate is required from the resident country tax authorities to claim applicable relief under the DTAA What is the purpose of a tax residency certificate? —Srivats Typically, source of income lies where the services are performed, or where the asset, from which the income arises, is located. Residential...
Venture capitalists, investors left unfazed Both President Trump and Capitol Hill Democrats head into negotiations over tax reform vowing to put the squeeze on hedge fund managers by closing the carried interest tax loophole — a point of agreement that held out promise for becoming a foundation for a once-in-a-generation...
On December 21, 2016, the new Canada–Israel tax treaty entered into force. The new treaty was signed on September 21, 2016 in New York, and replaces the existing treaty that dates from 1975. For most purposes, the provisions of the new treaty took effect as of January 1, 2017. Overall,...
The 2017 Italian Budget Law introduces a tax relief for individuals transferring their tax residence to Italy, in accordance with similar regimes adopted by other countries such as the United Kingdom, Switzerland and Portugal. The relief is part of a package of measures intended to facilitate investment in Italy and...
There is a possibility that the General Anti-Avoidance Rules (GAAR, on taxes) and the tax treaties signed by the government with those of Mauritius, Singapore and Cyprus, and even other nations such as Netherlands, could be overtaken by another event. These could, say experts, be partially or fully overridden by...
On 29 October 2016, the Austrian Ministry of Finance provided interesting guidance on the tax consequences of an alienation of a participation in a Hungarian partner- ship by an Austrian partnership consisting of German partners. The case revolved around an operative Austrian partnership (GmbH & Co KG) with German resident...
Portuguese income tax law provides for a 20% reduced rate and, in respect to income obtained abroad, a full tax exemption, for certain types of income derived by individuals having the status of Non-Habitual Portuguese Residents (NHPR). Any individual that in a certain year becomes tax resident in Portugal will...
The 2017 Budget Law introduced (starting from fiscal year 2017) favourable provisions for people wishing to become tax residents in Italy. It is aimed at wealthy individuals who wish to bring in new capital resources. The regime is inspired by the non-domiciled resident regime which is in force in the...
India is unlikely to amend its tax treaty with the Netherlands as it did with Mauritius, Singapore and Cyprus and this could shape the investment strategy of foreign portfolio investors (FPI) and private equity (PE) funds investing in India, said three people in the know. “There were talks to amend...
The Central Board of Direct Taxes in India issued Circular Number 41 on December 21, 2016 providing clarifications on applicability of ‘indirect transfer’ provisions under the Indian Income Tax Act, 1961 to investors of Foreign Portfolio Investors (FPIs) – earlier known as Foreign Institutional Investors (FIIs) in India. The circular...
Starting April 1, 2017, India will have the right to tax capital gains arising on Indian equity shares sold by a Singapore resident. The governments of India and Singapore have amended the double taxation avoidance treaty between the two countries, in line with the changes India recently made to a...
New Delhi– India on Friday signed a revised double taxation avoidance agreement (DTAA) with Cyprus, an official statement said here. “A revised agreement between India and Cyprus for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion (DTAA) with respect to taxes on income, along with its protocol,...
Mumbai: The government plans to withdraw tax exemption on long-term capital gains (LTCG) made on the sale of penny stocks to end the use of stock markets for tax evasion as part of a series of steps to eradicate black money, two people familiar with the development said. “The government...
While Trump wants to close loopholes, many of them stem from public policy concerns — not “special interests.” After a dramatic upset victory in one of the most bitterly contested presidential races in recent history, Donald Trump now has some serious work to do. His corporate tax policies—which are vital...
India has notified the revised double tax avoidance agreement with South Korea under which capital gains tax will be levied at the source with effect from April 1, 2017. The existing Double Taxation Avoidance Convention, which has been in vogue for three decades, provides for residence-based taxation of capital gains...
Expats who have money or assets outside Britain can expect to start receiving letters from the UK tax man soon. Hundreds of thousands of letters are being drafted for expats who have returned to the country after spells abroad and for expats considered UK taxpayers who have had overseas assignments....
Tough rules to regulate tax advisers, banks and lawyers who help companies avoid tax are set to be advanced by European Union finance ministers. The Council of Economic and Financial Affairs Oct. 11 also will likely move toward a system of automatic exchange of beneficial ownership registers to better target...
Singapore is seeking more time to revise the two-decade old tax treaty with India, saying its investors need more time to shift to source-based taxation. India has, however, rejected any deferment in the revision of the treaty that will help prevent Singapore, which is the top source of FDI into...
What will happen to clean capital, tainted trusts and enveloped assets under the new tax regime? John Goodchild reports. The UK government has at last disclosed further details of the tax changes for UK resident non-domiciled individuals first announced in July 2015. The government remains determined to implement all the...
Five months after the Panama Papers exposed the offshore dealings of government leaders and influential people, a new leak of 1.3 million files has revealed the names of individuals associated with companies registered in the Bahamas, a notorious tax haven. The files – received by the German newspaper Süddeutsche Zeitung...
Mauritius, the island nation that accounts for the second-largest FDI, has sought a line of credit and more investments from India as it gets ready for implementation of the revised tax treaty from April 2017. Mauritian Minister of Finance and Economic Development Pravind Kumar Jugnauth yesterday met Finance Minister Arun Jaitley...
Top officials from India and Mauritius will meet in Port Louis this week to discuss revival of free trade agreement (FTA) negotiations that were suspended three years ago by New Delhi. The talks were suspended to build pressure on Mauritius to expedite the double taxation avoidance agreement. Deliberations on two-way...
