Category: Non-Domiciled

Temporary Work Locations in a Permanent Establishment World

The COVID-19 crisis has caused quite some chaos in the world right now. As we find ourselves homebound, there are also employees trapped in foreign countries to them. In such a case, what happens to the link between tax presence and tax residency? Here is brief discussion. ... - Continue reading

Tax from non-doms falls by £2bn as wealthy flee the UK

The number of wealthy residents who pay no UK tax on their offshore accounts has fallen to its lowest level ever, Treasury figures reveal. Last year, there were 78,300 non-domiciled taxpayers, or “non-doms”, in the UK compared with 98,500 in 2016-17. And the £9.5bn they paid to the taxman in… – Continue reading

Cyprus: The Cyprus ‘Non-Dom’ Rules

Introduction In July 2015, a number of bills relating to the Cyprus taxation system were approved by the Council of Ministers and subsequently enacted into legislation by the Parliament1. The key highlight of these new bills is the introduction for the very first time of the “non-dom” status for Cyprus… – Continue reading

Italy: Moving To Italy – The Resident Non-Domiciled Tax Regime

During 2017 the Italian Government introduced a new tax regime: The Resident Non-Domiciled Tax Regime(also known as the “Flat Tax Regime”), with the aim of attracting high net worth individuals who want to relocate to Italy. The new legislation introduced a key change to the general principle of worldwide taxation… – Continue reading

Income Tax Dept cannot probe Foreign Assets of Assessee after Six Years: Delhi High Court [Read Judgment]

The Delhi High Court, in its recent decision, quashed an order of the Income Tax department questioning the overseas earnings and assets prior to March 31, 2005. The earnings included money in tax-haven banks, overseas properties and interests in offshore trusts and applies to non-resident Indians as well. The assessee,… – Continue reading

The Hukou System in Shanghai: Benefits, Eligibility, and Application Process

Hukou (户口) is a system of household registration in China. Each citizen is issued a household register under supervision of the Ministry of Public Security, China’s police. Hukou serves as an identity proof for citizens, recording their basic information and permanent residence. The hukou registration also determines access to housing,… – Continue reading

China’s new income tax laws to bring ‘profound implications’

In June this year, the Chinese government announced much-anticipated revisions to the country’s individual income tax laws. KPMG Partner and Senior Advisor Michael Olesnicky says that these new revisions will likely have ‘profound implications’ within the wealth management community in Asia. Hubbis CEO Michael Stanhope recently spoke with him about… – Continue reading

Tax Hike ‘Shockwaves’ Hit High-End Properties

Foreign investors were yesterday said to have halted construction projects, with some threatening to sell their high-end properties, as the “shockwaves” from Budget tax changes hit home. Robert Myers, the Organisation for Responsible Governance’s (ORG) principal, told Tribune Business that much of the Bahamas’ second home market “is dead” unless… – 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

New Report Expected to Reveal Naturalized U.S. Citizens in Africa Who Failed to Disclose Their Income or File Taxes

NEW YORK —Globe Afrique Media and Communication has initiated a research on naturalized US citizens living and working abroad, especially in African countries who have either refused to file US federal and state taxes or are under-reporting their income and assets. In a recent assessment conducted by Globe Afrique, hundreds… – Continue reading

Italy’s non-domiciled tax regime to profit from UK’s changing stance

In 2017, the UK scrapped its non-dom tax regime. Consequently, an increasing number of individuals are instead relocating their tax domicile to Italy At the start of 2017, in a bid to attract more wealthy citizens and capital to Italy, Rome introduced a non-domiciled tax regime. Now, citizens can move… – Continue reading

Foreign firms allowed to re-domicile to Singapore from Oct 11

FOREIGN companies can now transfer their registration from their original jurisdiction to Singapore. This will allow foreign companies to re-domicile to Singapore, instead of having to set up a subsidiary here, reducing operational disruption to the company. Such transfers are possible under the new inward re-domiciliation regime that took effect… – Continue reading

Non-dom taxpayers account for £9.3bn of UK tax receipts

Non-domiciled taxpayers contributed £9.3 billion to the UK economy in 2014/15 through a combination of income tax, capital gains tax and National Insurance contributions (NICs), according to newly-published figures. The number of non-doms paying tax in the UK marginally increased in 2014/15, to 121,300, up from 119,800 the previous year…. – Continue reading

UK-UAE treaty means UK pension free of income tax

Denton warns people of the long-term implications of stripping down their pension A new double tax treaty (DTA) between the UK and the UAE, which becomes effective April 6, will allow UAE residents to access their UK pension free of UK income tax, according to an expert. David Denton, Head… – Continue reading

FAST FACTS: Avoiding double taxation for nonresidents

The Philippines is currently a signatory to 41 tax treaties that address double taxation situations. MANILA, Philippines – According to Philippine law, nonresidents with income sources in the Philippines are required to file taxes. For these individuals who reside in a different country but receive income from the Philippines, double… – Continue reading

UK: Offshore Trust Deadline Looming For UK Non-Doms

Individuals who will be deemed UK domicile from 6 April 2017 should be considering their options with regard to offshore trusts as a matter of priority. On 5 December 2016, the UK Government published the Reforms to the taxation of non-domiciles: further consultation outcome, which provided clarity on the following… – Continue reading

2017 Budget Law: tax relief for individuals who decide to fix their tax residence in Italy

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… – Continue reading

The favourable tax regime of new Italian residents

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… – Continue reading

Italy to target non-doms with new tax regime

Italy is to introduce a remittance-style tax regime aimed at attracting non-domiciled high net worth residents, just as the UK makes its rules in this area less attractive post the Brexit vote. The new measure in Italy’s Finance Bill for 2017 was approved by parliament last week, before its prime… – Continue reading

Italy: Italy Set To Introduce A Territorial System Of Taxation

Italy is considering a proposal to introduce a territorial system of taxation to attract high net worth individuals, including successful individuals in the sports, arts, and fashion and design sectors, who could be interested in moving to Italy to take part in these thriving sectors. The new measure is contained… – Continue reading

Final Response to Non-Dom Consultation Published

In Depth There is mixed news for affected individuals, including far-reaching changes relating to offshore trusts and a further wait (possibly until March 2017) for the rest of the draft legislation. The following are highlights from the government’s response and the draft legislation. Deeming Provisions Deemed Domiciled: Non-doms will become… – Continue reading

Here’s the latest on the non-dom reform

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… – Continue reading

UK could lose billions by making wealthy non-doms pay more tax, experts claim

Current rules allow over 100,000 wealthy residents to pay a lower rate of tax, even if they have lived in UK for many years. The Government is risking more than £6bn of tax revenue by changing rules governing non-domiciled taxpayers, an international law firm has warned. Pinsent Masons said that… – 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

Cayman Islands Automatic Exchange of Information Update – April 2016

FATCA Notification and Reporting Deadlines Extended The Cayman Islands Department for International Tax Cooperation (“DITC”) has issued an industry advisory advising that it will be adopting a soft approach to the upcoming 30 April notification deadline for US and UK FATCA and 31 May reporting deadline for both US and… – Continue reading

Birmingham Post Rich List 2016: More taxing times for non-domiciled individuals

The taxation of ‘non-UK domiciled’ individuals has been a thorny political issue as successive governments have sought to crack down on those enjoying what some have seen as an excessively benign tax regime The taxation of ‘non-UK domiciled’ individuals has been a thorny political issue as successive governments have sought… – Continue reading