Category: Capital gains

Gov’t, Denmark reach double taxation deal

The Danish government is hopeful ratification of the convention for avoidance of Double Taxation agreements (DTA) with Ghana — and the Prevention of Fiscal Evasion with respect to taxes on income and capital gains between the two countries — will help to double Denmark’s investment in the country. This brings… – 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

Tax Horror Defying Modi Causes AIG to Shun Cover for India Deals

Prime Minister Narendra Modi needs to offer much more than just his best intentions to clean up India’s whimsical tax regime to help convince insurers. Companies from Allianz SE to American International Group Inc. are avoiding offering tax-liability coverage in India’s cross-border mergers and acquisitions market because of a relatively… – Continue reading

Cyprus: The New Double Taxation Agreement Between Cyprus And Georgia

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

Foreign investors not liable to pay MAT, says AP Shah panel

The recommendations of Justice AP Shah-led three-member committee on minimum alternative tax (MAT) has come in for big relief to foreign investors. The 64-page report, exclusively accessed by dna, says a foreign investor is not liable to pay MAT prior to April 1, 2015. The report, however, is silent on… – Continue reading

Germany: Taxation of Foreign Investment in Germany

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

HSBC cautious on persons with political connections, refraining from opening accounts of US-based Indians

MUMBAI: HSBC has been asking all “politically exposed persons” (PEP) having accounts with the bank to disclose their source of fund and income. The bank is also refraining from opening accounts of US-based non-resident Indians and persons of India origin in the wake of the Foreign Account Tax Compliance Act… – Continue reading

South Africa: Taxation Of Trusts Revisited

The Davis Tax Committee’s First Interim Report on Estate Duty (“DTC Report”) was released for public comment on 13 July 2015. In essence, the DTC Report proposes that “a highly progressive tax that patches loopholes, helps provide equality of opportunity and reduces the concentration of wealth, must be implemented”. The… – Continue reading

Two women challenge law allowing Ottawa to give info to U.S. tax collectors

Two Canadian women begin their Federal Court case in Vancouver on Tuesday, seeking to have a judge declare that Canada’s cooperation in supplying financial information to U.S. tax collectors is unconstitutional. Gwen Deegan, 53, a Toronto graphic designer, and Ginny Hillis, 68, a retired lawyer living in Windsor, were both… – Continue reading

Mauritius introduces new form for tax residency with more disclosure

MUMBAI: The Financial Services Commission (FSC) of Mauritius, which is the regulatory body for the Mauritian non-banking financial services sector, has introduced a new application form for obtaining a tax residency certificate (TRC). FSC verifies these applications and recommends issue of the Mauritius tax residency certificate by the Mauritius revenue… – Continue reading

United States: Tax Policy Update – July 29, 2015

First it was three years, now it’s three months. The Senate’s attempt to pass a multiyear highway bill ran off the road this week after House Republicans announced they will adjourn one day early for the month-long August recess. The House’s early departure forced the Senate to acquiesce to a… – Continue reading

Advising non-doms after the Summer Budget clampdown

John Goodchild explains the tax position of non-dom clients, and their families, after the Chancellor’s Summer Budget crackdown The Budget on 8 July announced a raft of provisions designed to increase the tax paid to the Exchequer by non-domiciled individuals (non-doms) and their families. Significant changes will be made to… – Continue reading

Consultation on offshore marketing and IP hubs

Consultation on the ATO’s practical guide for offshore marketing hub arrangements is kicking off in August. The guide may also assist taxpayers with offshore intellectual property (IP) hubs. Here is what you need to know if you market Australian produced goods offshore or have centralised your IP offshore. Do you… – Continue reading

Mauritius & P-notes: Any proposed change in rules may spook Dalal Street

Just as every new government fiddles around with high school history text books, it also dabbles in Mauritius and P-notes. Both actions have a sharp, short-lived impact, leaving behind a trail of conspiracy theories. Mauritius and P-notes are ghosts that New Delhi and regulators could never quite exercise. They unfailingly… – Continue reading

Tax implications of setting up overseas subsidiaries

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

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

Technical Special: A Budget In Blue With Old Mutual Int’l

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

Canadian General Investments, Limited Declares Dividend on Common Shares

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

Canada: Interest Deductibility In Canada: What’s The Fuss?

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

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

Japan – Article 7 (Business profits) under UK tax treaty

July 27: Japan’s Ministry of Finance announced the exchange of diplomatic notes concerning application of Article 7 (Business profits) under the new income tax treaty between Japan and the United Kingdom. Background Provisions of the amended Japan-UK income tax treaty (signed 17 December 2013) generally were effective 1 January 2015…. – Continue reading

Loeb Faulted for ‘Unconscionable’ Tax Scheme by Teachers

Hedge fund manager Daniel Loeb was singled out for criticism by labor leaders who are urging the U.S. to limit investors’ ability to lower tax obligations through offshore reinsurance ventures. “When just one hedge fund takes advantage of this loophole, it means hundreds of millions of dollars are lost that… – Continue reading

Khalifa ratifies UAE agreements

ABU DHABI: President His Highness Sheikh Khalifa Bin Zayed Al Nahyan has issued a number of federal decrees with respect to ratifying agreements between the UAE and a number of friendly countries and transferring, appointing and promoting a group of diplomatic corps members. The decrees have been published in the… – Continue reading

Japan and the UK exchange notes concerning article 7 (“business profits”) of the Japan-UK Tax Convention

On July 23, 2015 the Japanese Ministry of Finance issued a press release announcing that on July 22, 2015 the Government of Japan and the Government of the United Kingdom exchanged notes concerning Article 7 of the Convention between Japan and the United Kingdom of Great Britain and Northern Ireland… – 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

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

UK To Introduce Tougher Regime On Tax Evasion

HM Revenue and Customs (HMRC) has launched four consultations on the UK Government’s proposed new approach to tackling offshore tax evasion. Under the proposals, corporates who are deemed to have failed to prevent tax evasion or the facilitation of tax evasion would face a criminal offence. A separate strict liability… – Continue reading

Bracket creep will cost taxpayers $45 billion through higher income taxes: PwC

Treasurer Joe Hockey has reaffirmed his commitment to addressing bracket creep in the upcoming tax review, but has refused to include changes to politically sensitive areas like superannuation concessions, negative gearing and GST, pushing back the onus on the states for GST reform. When it comes to the GST, Mr… – Continue reading

Big changes to India-Mauritius DTAA?

Mauritius’ former finance minister claims that his country has given up the right to tax capital gains. This has raised questions regarding the scope of the renegotiation of the India-Mauritius Double Tax Avoidance Treaty (DTAA) Former finance minister of Mauritius says renegotiated tax treaty with India will have devastating effect… – Continue reading

Unicredit’s German unit in talks to strike tax deal with authorities – sources

HypoVereinsbank, the German arm of Italy’s UniCredit, is in talks with German prosecutors to pay a fine to put two tax probes behind it, two people familiar with the matter said. HypoVereinsbank and the Cologne prosecutors declined to comment on the development, which was first reported by German daily Sueddeutsche… – Continue reading

Worldwide: Privacy: What’s Left?

A seismic change in the international private wealth arena is under way. Over 90 jurisdictions have committed to automatically exchange comprehensive financial information on an annual basis under the OECD’s Common Reporting Standard (CRS). The CRS will start in 2016 in over 55 jurisdictions. This article comments on the CRS… – Continue reading

India: recent developments regarding Minimum Alternate Tax

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

Negotiations on DTAA between India and Mauritius in advanced stages: Revenue Secretary

Finance Ministry has informed that the negotiations on the double taxation avoidance agreement (DTAA) between India and Mauritius are in advanced stage and the pact would be revised soon. Revenue Secretary Shaktikanta Das has said that “DTAA treaty (with Mauritius) is in very advanced stage of negotiation. It is progressing… – Continue reading