Category: Capital gains

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

End capital gains tax exemption to curb money laundering: BSE

MUMBAI: The Bombay Stock Exchange (BSE) today called for ending exemption of capital gains tax on securities to contain various entities using capital markets to evade taxes and launder money. The government should re-think the exemption on capital gains taxes on traded securities, which listed companies enjoy, in order to… – Continue reading

Australia To Introduce Foreign Resident Capital Gains WHT

The Australian Government will introduce a withholding tax obligation to ensure that foreign investors comply with Australia’s tax laws. The Government has released exposure draft legislation that provides for the application of a ten percent non-final withholding obligation on the disposal by foreign residents of taxable Australian property. If passed,… – Continue reading

ATO warns multinationals over use of Singapore, Swiss and other offshore hubs

The Australian Taxation Office has warned companies it will be focusing on money attributed to offshore marketing hubs and will use its stronger transfer pricing powers to go after them, reports the Sydney Morning Herald. Australian companies sent more than AU$100 billion to related parties in the low-tax nation of… – Continue reading

How non UK residents should buy or own residential property

How should non resident or non domiciled buyers of UK residential property own or hold residential property? Overseas buyers or owners of UK residential property above £1m in value need to consider carefully in what name or legal structure they should buy or hold property for their protection and to… – Continue reading

United Kingdom: Overview of Tax Regime

The UK Government’s goal is to make the UK the best place in the world to locate an international business; it has one of the most open economies globally, a highly skilled workforce, access to capital markets, a first-class infrastructure, and a highly competitive corporate tax system. UK tax policy… – Continue reading

Cyprus: Cyprus’s New Double Taxation Agreement With Bahrain

Taxes covered The agreement applies to taxes on income imposed by either country. In Bahrain these are currently the income tax payable under Legislative Decree No. 22/1979 (“the Oil Tax”); in Cyprus they are income tax, corporate income tax, Special Contribution for Defence (known as SDC tax) and capital gains… – Continue reading

Cyprus: Major tax reforms aimed at ‘non-doms’, FDIs, property

The Cyprus government has introduced radical tax reforms that aim to attract foreign direct investments and non-domiciled individuals, simplify levies for properties, return tax-collection to local municipalities and encourage tax-breaks for direct injections where local companies are strained for cash-flow, reports the Financial Mirror. Finance Minister Haris Georghiades said that… – Continue reading

Jeb Bush Made $29 Million After Leaving Office, Tax Returns Show

Florida governor releases 33 years of tax returns. Jeb Bush made $29 million in the first seven years after he left public office, dramatically increasing his wealth during a recession, a financial crisis and the Obama presidency he has criticized. Bush’s tax returns, released Tuesday, show how the former Florida… – Continue reading

Tax treaty with Mauritius blocks outflow

A new treaty makes it more difficult for companies to take advantage of tax loopholes to avoid their financial obligations. Globally, initiatives are afoot to close tax loopholes and South Africa is one of the frontrunners – its new treaty with Mauritius removes the allure for tax-shy corporates doing business… – Continue reading

Capital gains tax for non-residents disposing of UK residential property: final rules

Introduction The UK Finance Act 2015 received royal assent on March 26 2015. This included final legislation for the introduction of a capital gains tax charge on non-residents who dispose of UK residential property. The new charge applies to such disposals made on or after April 6 2015. This update… – Continue reading

Mauritius to act against black money: Finance Minister Seetanah Lutchmeenaraidoo

NEW DELHI: Mauritius has offered to put in place stringent conditions for investors seeking benefits under its tax treaty with India to weed out post-box operations, addressing a key concern of New Delhi that has been attempting to amend the agreement for years. “We don’t want investors to open shell… – Continue reading

Cyprus: The New Cyprus-Iceland Double Taxation Agreement

With less than seven weeks between signature on 13 November 2014 and entry into force on 22 December, the new DTA between Cyprus and Iceland set a new standard for timeliness. Like most of Cyprus’s recent double taxation agreements, the DTA closely follows the form of the 2010 OECD Model… – Continue reading

Cyprus: The Potential Impact Of Russian De-Offshorization Legislation On Cyprus Holding And Finance Structures

Abstract Over the past 25 years, Cyprus has become the portal of choice for investment into and out of Russia and Central and Eastern Europe. The new Russian de-offshorization law, which took effect on 1 January 2015, will have significant implications for users of overseas structures. This article examines the… – Continue reading

Maximise tax revenues

Britain’s taxing question is whether to maximise revenues or face more austerity. Given the scale of state spending that’s the stark choice facing chancellor George Osborne if he wants to balance the books in this parliament, says James Sproule We are once again considering the tax options facing the chancellor… – Continue reading

ETVEs (Spanish foreign-securities holding companies)

A special scheme is provided for foreign-securities holding companies or ETVEs (Entidades de Tenencia de Valores Extranjeros) in the Corporate Income Tax (“CIT”) Act 27/2014. ETVEs are regular limited liability companies (S.L., S.A. or other company forms), subject to the normal CIT on its income, but exempt from taxation on… – Continue reading

Recent Tax Treaty Developments In Cyprus

Proposed Amendments To Cyprus’s Assessment And Collection Of Taxes Law The Cyprus Government has published a draft law amending the Assessment and Collection of Taxes Law (Law 4 of 1978) in order to facilitate implementation of agreements for automatic exchange of information with other countries. When it is enacted, the… – Continue reading

Modi’s goal of a tax-friendly India faces the hurdle of manpower

New Delhi/Mumbai: India’s goal of a friendlier tax regime for global companies to help power China-beating economic growth is hitting a manpower hurdle. Fewer than 20 officials face the complex task of working with hundreds of multinational companies (MNCs) on pacts to avert tax rows, people familiar with the matter… – Continue reading

London based Investment Association, ASIFMA seeks to be party in Castleton case over MAT

MUMBAI: Two associations representing foreign portfolio investors are seeking to join the battle over minimum alternate tax in the Supreme Court, although analysts are unclear if entities without a tax treaty will benefit. Investment Association, based in London, and Hong Kong-based Asia Securities Industry & Financial Markets Association (ASIFMA) plan… – Continue reading

Bonus shares: SECP suggests FBR to withdraw 5 percent tax, apply 12.5 percent CGT

The Securities and Exchange Commission of Pakistan (SECP) has proposed to the Federal Board of Revenue (FBR) to withdraw 5 percent tax on bonus shares and apply current capital gains tax (CGT) rate of 12.5 percent irrespective of its holding period. According to the budget proposals of the SECP received… – Continue reading

New Argentina­Chile tax treaty creates fresh structuring opportunities

Argentina and Chile have signed a new double tax treaty to replace the treaty unilaterally terminated by Argentina in 2012. Ignacio Rodriguez and Andres Edelstein of PwC in Argentina outline the new structuring opportunities that are available for taxpayers. Argentina and Chile signed a new double tax treaty on May… – Continue reading

FIIs get another small dose of relief, fresh tax notices on hold

The announcement marks an attempt to defuse the raging controversy over MAT payouts, which has dented the outlook of foreign institutional investors toward the country’s stock and bond markets. The government on Monday announced it had stayed the issue of fresh notices to foreign institutional investors regarding the alleged non-payment… – Continue reading

China Clarifies Tax Treatment of Indirect Asset Transfers

The Chinese government has been paying close attention recently to the effects of offshore entities having ownership or control of Chinese companies or assets. Following the release of the draft Foreign Investment Law in January 2015, the State Administration of Taxation (SAT) issued a Bulletin on the tax treatment of… – Continue reading