Category: Capital gains

Who gains, who loses in new tax pact with Mauritius? Will FIIs run away?

India and Mauritius have signed a protocol amending the double tax avoidance arrangement between the two countries. The protocol is the outcome of an extensive and long-drawn-out negotiation process that has been going for more than a year and a half. While the text of the protocol is yet to… – Continue reading

Australia Moves to Remove ‘Double Taxation’ on Digital Currency

For a month starting May 3, The Treasury of the Australian government will be accepting submissions from interested parties to comment on a newly-released discussion paper entitled ‘GST treatment of digital currency’ as part of the 2016-17 Budget. The Treasury says the government has realized that consumers are ‘double taxed’… – Continue reading

UK: Proposed Changes To The Non-Dom Regime From April 2017

The tax treatment of non-domiciled individuals is changing again from April 2017. The changes were first announced in the 2015 Summer Budget, and a Consultation document was issued in September 2015 setting out further details. The proposed changes target three key areas: The taxation of non-domiciled individuals who have been… – Continue reading

Residence-Based Taxation Put Forward For Americans Abroad

With regard to the increasing talk in the US Congress on tax reform, American Citizens Abroad (ACA) has provided the House of Representatives Ways and Means Committee with a full reform proposal for the enactment of residence-based taxation (RBT) for American expatriates. ACA has said lawmakers should enact RBT instead… – Continue reading

Key features of new Thai-Indian DTA

THE DOUBLE taxation treaty (DTA) between India and Thailand has been successfully renegotiated and agreed to by both states and will come into force in January next year. The key highlights include a reduction of withholding tax on dividends, interest and royalties. Article 10 reduces the dividend withholding tax to… – Continue reading

Why We Should Be Really Worried About the Panama Papers

History shows us that tax evasion can have terrible effects, from economic inequality to societal collapse. In a world seemingly inured to financial scandals, the Panama Papers leak has reminded us of their capacity to shock. This huge document dump, which has revealed thousands of offshore accounts held in the… – Continue reading

France Hits McDonald’s With $341 Million Tax Demand : Possibly Unfairly

The French taxman, Le Fisc, has apparently decided to send McDonald’s MCD -0.24% France a tax bill for €300 million ($341 million). It’s not entirely obvious that this is a correct demand: nor, in fact, necessarily a legal one. If there were no European Union and no rules about the… – Continue reading

Once A Tax Haven, Gibraltar Now Says It’s Low-Tax

Gibraltar, a tiny British territory at Europe’s southern tip, is famous for its geography — a huge limestone rock — that appears on the Prudential logo. It’s a global center for offshore banking, with the trappings of wealth to prove it: Luxury high-rises tower over super yachts in Gibraltar’s marina. The… – Continue reading

International tax update- April 2016

United Kingdom Budget The United Kingdom (UK) Budget: was handed down on 16 March 2016. Some of the key measures announced include: a reduction in the corporation tax rate to 17 per cent by 2020 (previously due to fall to 18 per cent) more details on the implementation of Base… – Continue reading

Canadian Budget Focuses On Tax Compliance

The first Budget tabled by Canada’s new Liberal Government provides for a major crackdown on tax evasion and avoidance, and streamlines the domestic tax credits system. The Budget was delivered by Finance Minister Bill Morneau on March 22, 2016. He told Parliament: “Today, we begin to restore hope for the… – Continue reading

PE Panorama: Is the UK Budget 2016 really PE-friendly?

Private equity (PE) populism looks to be in the news again – though in a context that’s unlikely to win too many votes for the instigators. This time it’s the UK, and Chancellor George Osborne’s latest budget. The UK Budget 2016 (the Budget) includes a significant reduction in the UK… – Continue reading

Income tax cuts will benefit 31 million workers

The amount people can earn before being hit by income tax will rise to £11,500 in April 2017, benefiting millions of workers. The move will cut taxes for 31 million people, according to the Treasury, and will mean 1.3 million low-wage workers are taken out of paying income tax altogether…. – Continue reading

The rich people who pay no tax

Only the little people pay taxes. For a small, select cohort of rich Australians, the famous quote of New York property billionaire Leona Helmsley rings not as an outrage but as an inspiration. In the most recent documents released by the Australian Tax Office, there were 55 people who had… – Continue reading

Mauritius Eyes Asia, Far East for Its Financial Services

Mauritius plans to sell itself as a world class financial-services hub to investment companies in Asia and the Far East to win new business, an official said. The island-nation’s Financial Services Promotional Agency plans to market the country as an international financial center, or IFC, and is already collaborating with… – Continue reading

A closer look at the flat tax

Another form of taxation that has gotten greater attention during the last two presidential election campaigns is the flat tax. A flat tax is a plan that will apply the same rate to every taxpayer, regardless of the income they have earned. At present, federal taxes are calculated on a… – Continue reading

Pakistan, Czech Republic implement convention to avoid double taxation

Pakistan and Czech Republic have implemented a convention to avoid double taxation and prevent tax evasion, the Federal Board of Revenue notified on Monday. An official said the convention on avoidance of double taxation will come into force on July 1. “This is an epoch-making event in the consolidation of… – Continue reading

Budget 2016: 9% tax rate regime for India’s first International Financial Centre

The pet project of Prime Minister Narendra Modi – the International Financial Services Centre (IFSC) – housed in the Gujarat International Finance Tec City – has received a boost in the Union Budget 2016/17. The long pending tax issue has been decided with 9 per cent minimum alternate tax (MAT),… – Continue reading

Double taxation avoidance treaty with Qatar: What is in it for Nigeria?

The federal government of Nigeria and Qatar have signed an agreement for the avoidance of double taxation on income and capital gains for investments between the two countries. In addition to the elimination of double taxation on business income, similar treaties between Nigeria and other countries provide for a lower… – Continue reading

Clampdown on tax avoidance

“We are clear. We will not stand for a minority of taxpayers continuing to seek out unacceptable ways to reduce the amount of tax they pay, and we will ensure HMRC has the tools to robustly tackle such activity.” So said David Gauke, Exchequer Secretary to the Treasury. A clampdown… – Continue reading

UK tops global table of damaging tax deals with developing countries

Treaties limit the tax poorer nations can place on British companies doing business within their borders, says ActionAid. The UK has signed a high number of tax deals with some of the world’s poorest countries, potentially depriving those states of millions in tax revenues every year, according to an analysis… – Continue reading

Start-ups Hope Budget Will Follow up on Modi’s Promises

NEW DELHI: With Prime Minister Narendra Modi promising tax cuts and a $1.5-billion fund for India’s start-up eco-system, young entrepreneurs hope that the Budget 2016-17 will have some concrete steps to foster new businesses. “Implementation of nationwide GST (Goods and Services Tax) will help in simplifying the entire tax structure,… – Continue reading

Taxation reform has to be holistic

The government reportedly wants to extend to three years the holding period for investments in listed shares to qualify for capital gains tax exemption. This accepts the need to change the present capital gains tax regime but might not be the best way to go about it. It would discriminate… – Continue reading

What effect will Vodafone tax dispute have on global investors?

Free-market advocates say retrospective tax claim on the British telecom major sends a negative message to global investors. It seems to be a weak argument Like all tax disputes, the one that involves Vodafone and the government is quite a tangled one. The company has been absolved of tax liability… – Continue reading

A New Set of Amendments to the Russian CFC and Beneficial Ownership Rules

On February 15, 2016, the President of the Russian Federation signed Federal Law No. 32-FZ “On Amendments to the First and Second Parts of the Russian Tax Code (with Respect to the Taxation of Controlled Foreign Companies and the Income of Foreign Organizations)”, introducing a new set of amendments to… – Continue reading

Buyback Transaction Taxable As Capital Gains

Mumbai Tribunal rules buyback transaction taxable as capital gains, exempt under India-Mauritius Tax Treaty; even if considered as dividend, tax withholding does not apply This EY Tax Alert summarizes a recent ruling of the Mumbai Income Tax Appellate Tribunal (Tribunal) in the case of Goldman Sachs (India) Securities Pvt. Ltd…. – Continue reading

Getting to the crux of Ncell buyout deal

CAN NEPAL IMPOSE CAPITAL GAINS TAX ON NCELL BUYOUT DEAL? This question has been making rounds ever since TeliaSonera, the largest shareholder in Nepali telecom operator, Ncell, announced its decision to sell 60.4 per cent of its stake in the telecom company to Malaysian giant, Axiata, for $1.03 billion. Divergent… – Continue reading

States Targeting Snowbirds Fleeing to Tax-Friendlier Climates

Wealthy taxpayers who split time between states should be prepared to prove where their true home lies. You’re lounging by the pool of your second home in Florida, chuckling as you think of your friends back home braving the blizzard in Massachusetts. And you’re musing: Perhaps it’s time to escape… – Continue reading

Automatic exchange of financial account information

The Government recently introduced into the Legislative Council a bill to provide a legal framework for the implementation of automatic exchange of financial account information in tax matters (“AEOI”). This would have significant implications both for financial institutions and, in a cosmopolitan city like Hong Kong, for many of their… – Continue reading

TTIP could block Governments from cracking down on tax avoidance, study warns

Similar trade agreements have been used to facilitate apparent tax avoidance in the past A controversial new trade deal between the EU and the United States could make it more difficult to fight tax avoidance, a new report has warned. TTIP, the Transatlantic Trade and Investment Partnership, is expected to… – Continue reading

Big corporations will always cheat (yep, I said cheat) on their taxes. Here’s how to deal with it

Let me give you a heads up: First, I’m going to tell you some things that will make you ill. Then I’m going to present a cure. It will make you feel better—until, of course, you realize that knowing the cure brings us as close to implementing it as buying an… – Continue reading

Tax competition – that would be something to thank the Scots for

A 30% tax bracket. A rise in the standard rate, with a rebate for lower earners. Higher taxes all round to finance more spending. In Scotland, ahead of May’s elections for the devolved parliament, a fascinating debate on tax and spending is under way, with the main parties setting out… – Continue reading

Why Is Monaco A Haven For Tax Defaulters?

If Swiss banking secrecy laws gave Switzerland the world banking capital status, Monaco’s residence policy gives its realtors a thriving business. What is common between the Canadian Raonic who lost in the Australian Open semifinals and the Serbian Djokovic who won it? Well, they are both residents of Monaco, and… – Continue reading

Canada: Insight – In Search Of Better Tax Outcomes

Taxing decisions With highly efficient labour markets, a solid institutional environment and a strong banking system, Canada has long been considered one of the most competitive nations in the world. In fact, in its most recent rankings in 2014, Bloomberg declared Canada the second best country in the world for… – Continue reading

Indian tax authority clears air on investments via Mauritius

The Authority for Advance Rulings, a quasi-judicial tax body under the finance ministry, has reaffirmed that capital gains earned by a Mauritius-registered company from transfer of shares of an Indian firm shall not be taxable in the country if the foreign corporation doesn’t have a local permanent establishment. In doing… – Continue reading

Kenya: Treasury Defends Controversial Mauritius Tax Agreement

Treasury is still fighting to keep a tax agreement out of parliament after a lobby group sued them over a pact it signed with Mauritius back in 2012. The double taxation avoidance agreement allows firms registered in the two countries to pay taxes in only one country. It also allows… – Continue reading

French Tax Update – Recent Case Law and Other Noteworthy Publications

The present French Tax Update will focus on an overview of several noteworthy publications, including decisions issued during the past few months by the French Administrative Supreme Court (Conseil d’Etat) and French Constitutional Court (Conseil Constitutionnel), as well as the European Commission decision in respect of the Belgian Excess Profit… – Continue reading

Tax Injustice Is Systemic

COMMUNIST trade union leader Ken Gill famously referred to taxation as “the price we pay for civilisation.” If so last week gave further evidence of just how uncivilised a country Britain has become after decades of neoliberalism. Google’s deal with HMRC has rightly prompted outrage and consternation at the sheer… – Continue reading

Subsidies will not be eliminated but better targeted, says Modi

Modi promised efficiency in allocation of resources as well as creation of opportunities for citizens to progress. New Delhi: Promising reforms that will transform lives, Prime Minister Narendra Modi on Friday said the government will not eliminate all subsidies but will rationalise and target them to the needy. He said… – Continue reading

The Italian Patent Box and Its (Non-) Compliance with OECD Recommendations

The Italian Patent Box regime largely complies with the OECD recommendations to prevent base erosion and profit shifting. Its non-compliant features offer a brief window of opportunity for companies able to take swift advantage of its wide range of qualifying intangible assets. Many countries have implemented specific IP regimes through… – Continue reading

If you are looking for tax-free residency or citizenship, consider these countries

The UAE is one of the few places in the world where expats can live, earn and keep those well-earned dirhams, as income tax is still not in sight. This benefit has earned the country many rankings as one of the best immigration destinations in the world. Apart from good… – Continue reading

Anguilla Best Flat Tax Country for a Low Tax Lifestyle

Anguilla levies a 3% flat rate of personal income tax and is otherwise a tax haven with a stunning climate and amazing Carribean lifestyle Whilst there are various categories of flat tax, including marginal flat tax and Hall-Rabushka flat tax, in its simplest form flat tax is simply a rate… – Continue reading

Anguilla Best Flat Tax Country for a Low Tax Lifestyle

Whilst there are various categories of flat tax, including marginal flat tax and Hall-Rabushka flat tax, in its simplest form flat tax is simply a rate of tax that remains consistent with a constant marginal rate. What this means is, as an income tax payer in a country with such… – Continue reading

How to take your UK pension pot overseas-and not be hit by a big tax bill

Once the thrill of deciding to retire overseas has subsided, you normally start to think of all the things you need to do before you go. Picking the right removal firm, a lawyer to help you buy a new home are a couple, but the tax & financial implications of… – Continue reading

Can new guidelines get Nigerians into tax net?

The Federal Inland Revenue Service (FIRS) which is now saddled with the onerous task of getting alternative sources of revenue for the federal government has since adopted a stick and carrot approach to bringing tax payers into the tax net. Assistant Editor, Nduka Chiejina looks at the issues contained in… – Continue reading

Uncompetitive tax?

Generally, if a South African taxpayer sells shares in a foreign company, he will be hit with South African capital gains tax (CGT) on any gain realised on that sale. However, South Africa provides exemptions from this CGT in certain circumstances, one of which relates to the sale of foreign… – Continue reading

5 Tax Deductions Homeowners Won’t Want to Miss

One of the biggest financial benefits of owning a home is qualifying for the tax breaks that homeowners are eligible to receive. Many of the tax deductions for home-related expenses are well-known, but others often slip under the radar. Below, we’ll run through the list of deductions for homeowners that… – Continue reading