Vancouver real estate is a Mainland Chinese buyers’ market, study says Groundbreaking study shows 70 per cent of detached homes sold in a six-month period on Vancouver’s west side went to Mainland Chinese buyers; many of them housewives or students with little income. The dominant influence of Chinese investors in… – Continue reading
Place of residence key as Holyrood prepares to unveil levy on income it will impose north of the Border from April, writes Jeff Salway HM Revenue & Customs has moved to clear up misconceptions lingering over new income tax rules taking effect in Scotland as Holyrood prepares to unveil the… – Continue reading
Pfizer’s bid for $113bn Dublin-based drug maker Allergan is the biggest merger of the year, anywhere. It’s potentially good news for the Irish exchequer, which may gain a massive new taxpayer, and for businesses here like Arthur Cox, Allergan’s adviser on Irish corporate law. But a deal that may well… – Continue reading
Possible opportunities for refund of Dutch dividend withholding tax On 17 September 2015, the Court of Justice of the European Union (“CJEU”) ruled in three distinct (yet comparable) cases that the levy of Dutch dividend withholding tax in relation to portfolio shareholdings in Dutch companies is in conflict with the… – Continue reading
The European Union (EU) is pushing ahead with its most ambitious plans to date to eliminate tax competition between member states and roll out a single market for products and services. While the commission focuses on levelling prices for products and services across the 28 member state bloc, a European… – Continue reading
Most double tax avoidance treaties between two countries attempt to repel probable abuse of benefits under the pacts. Incorporating a clause for limitation of benefits (LOB) in the treaty is the usual practice adopted for checking such abuses. LOB provisions are for denying benefits of the tax treaty to those… – Continue reading
(MENAFN – Arab Times) The US Foreign Account Tax Compliance Act (FATCA) model has spurred the rise of a global automatic exchange of information, informed Hannah Shipley, Director at Ernst & Young, while speaking about FATCA and its implications during a business panel discussion held at the Kuwait Chamber of… – Continue reading
Mexico is experiencing a rough time, economically speaking at the moment, but hopes are high for better times ahead. With new tax laws and a relatively young government, these are interesting times for this country. To find out more about how the recent tax reforms will affect Mexico and the… – Continue reading
An income tax treaty between Italy and Hong Kong has entered into force, with the exchange of instruments of ratification. The official communication of the Italian Ministry of Foreign Affairs announcing this exchange was published in the official journal on 26 October 2015. BLACK LIST, WHITE LIST Italy’s “black list”… – Continue reading
With effect from November 1, mutual fund investors will have to make additional declaration pertaining to foreign account tax compliance act (FATCA) and common reporting standards (CRS) for all new accounts opened, failing which their applications will get rejected. Under FATCA and CRS, Indian financial institutions will be required to… – Continue reading
UK tax authority HM Revenue and Customs (HMRC) has published guidance on who will be considered a Scottish taxpayer when the Scottish Rate of Income Tax (SRIT) enters into effect in April 2016. From April 1, 2016, the Scottish Parliament will have responsibility for a SRIT. Parliament will be able… – Continue reading
Come November 1, mutual fund investors will have to provide details and declaration pertaining to Foreign Account Tax Compliance Act (FATCA) and common reporting standards (CRS) for all new accounts opened, failing which fund houses are likely to reject their applications. While some fund houses have already started this process… – Continue reading
Following the recent Irish budget statement (the “Budget”), the Finance Bill 2015 (the “Bill”) has been published and it implements the changes announced by the Irish Minister for Finance (the “Minister”). The Bill includes additional detail on: the new knowledge development box (“KDB”); and Ireland’s implementation of country by country… – Continue reading
The new non-resident capital gains tax came into force in Guernsey on 6 April 2015. The rules intend to capture disposals of residential property in the United Kingdom by all non-residents. These notes provide a summary of who and which property is affected, and describe how a new UK tax… – Continue reading
Canadian snowbirds could be trading winter’s bite for a bite from the taxman starting this year. Memos show the Canada Revenue Agency and Employment and Social Development Canada plan to use a planned border exit-tracking system to avoid paying hundreds of millions of dollars in social benefits now going to… – Continue reading
THE NUMBER of Slovak companies with ownership registered in a tax haven decreased in the first half of 2015 by 112, to a total of 4,250. The biggest outflows were recorded in Monaco and the British island of Jersey. The declining trend of companies selecting a tax haven for their… – Continue reading
Taxation of Profits of Controlled Foreign Companies (CFC): Double Taxation Conventions must prevail over domestic rules The Superior Court of Justice (STJ) has recently decided a case involving the applicability of Brazilian CFC rules in cases in which the controlled company is located in a country with which Brazil has… – Continue reading
Expansion activities of companies lead to relocation of their employees to different territories, even outside the country. It goes without saying that transfer in job from one location to another comes with a baggage of issues, including the taxability of income from employment. The tax matter needs particular attention if… – Continue reading
The Regulation of the Law Regulating Transfer Pricing was published last month and is based on the principle of free competition (arm’s length) where transactions between related parties should be carried out at market prices, i.e. those used in comparable transactions between independent parties in similar conditions. The regulation determines… – Continue reading
Foreign companies with Indian shareholders won’t have to pay taxes here for their worldwide income unless they are managed from India on an everyday basis. If these foreign companies are managed from outside India, whether or not they are promoted by resident Indians, they will have to pay taxes in… – Continue reading
Major US investor Carl C. Icahn and the Chief Executive Officer of TechNet, Linda Moore, have both recently written letters to leading lawmakers pointing out that the passage of international tax reform by Congress has become a matter of extreme urgency. In his letter, Icahn announced that “the time has… – Continue reading
From 1 October 2015, all parties to transactions which include a transfer of land or an interest in land have to complete a “tax statement” as part of the registration process. We summarise how the new rules apply to trusts. New requirements in brief The tax statement is a one… – Continue reading
Announcements were made in the 2015 Summer Budget regarding proposed changes to the UK tax rules regarding individuals who are domiciled outside the UK. These included the introduction of new provisions which would deem certain foreign domiciliaries, who are or have previously been UK resident, to be domiciled in the… – Continue reading
Tunis, — The process of returning Tunisian property and assets frozen in a number of foreign banks in general and in Switzerland, in particular, has not moved an inch. More than four years have elapsed since the fall of former President Ben Ali without any hope of progress on the… – Continue reading
“He hath founded it upon the seas…” Psalm 24:2 From an ancient decree The motto on the Cayman Islands flag has profound meaning for all residents, whether indigenous or not. At 3:00am on 7 February 1794 the Royal Navy Frigate HMS Convert and its convoy of nine merchant ships were… – Continue reading
The Greek shipping community has sent a clear message to the Athens government: it is paramount a shipping community is competitive and enjoys a stable environment in which to operate. This is not the case today and hence there is so much talk about shipowners in particular, but not only… – Continue reading
Offshore companies are established for a variety of reasons including a company’s necessity to restructure, create an international business entity as well as protect the assets of the company. The United Arab Emirates (UAE) is home to three authorities that register International or offshore companies. The three UAE authorities that… – Continue reading
A retired millionaire property mogul could lose a £5.5million tax break because his domestic goddess wife’s ‘great cooking’ brought him back to the UK too often, the High Court has heard. James Glyn has insisted he was resident in Monaco when he received a £24million dividend from selling off his… – Continue reading
Panamanian officials question declared payments for Enrique Iglesias, Julio Iglesias, Alejandro Sanz and other artists Enrique Iglesias, Alejandro Sanz and Julio Iglesias are among the artists named in an investigation by Panamanian tax authorities into possible tax evasion, concerning money they received for concerts in that country. According to an… – Continue reading
When a multinational company makes a cross-border investment, the relevant tax treaty between the two countries will generally sort out which country gets to tax which part of the ensuing activity and income streams. (Read more about tax treaties here.) A key question is this: how do the ensuing taxing… – Continue reading
KEY POINTS What is the issue? Guernsey will be required to gather data for the calendar year 2016 for reporting under the Common Reporting Standard (CRS) in 2017. What does it mean for me? Practitioners should be aware that due diligence and reporting procedures are set to be amended and… – Continue reading
The Luxembourg Finance Minister Pierre Gramegna Wednesday announced a tax amnesty measure for income from Luxembourg which has not been declared, a first in the Grand Duchy, reports the Luxemburger Wort. He announced an action to “launder” tax evaders during the presentation of the draft budget 2016 before the Chamber… – Continue reading
The central government is stepping up its anti-graft drive by cracking down on illegal lending and money-laundering operations in a bid to prevent outbound flows of stolen assets. The Ministry of Public Security says “black banks” and illegal currency exchanges have facilitated the flights of a number of former government… – Continue reading
We are entering a new world of tax revenue wars, and no one can say who will emerge as the victor. All we know is that there will be tension over the next five years as governments seek to implement the global plan to end to tax havens from Luxembourg… – Continue reading
The Dutch government presented its Tax Bill 2016 on 15 September 2016. Three elements of this bill could specifically affect multinationals, international investors and investment funds with Dutch headquarters or group companies: The anti-avoidance rules in respect of non-resident taxation of foreign corporate shareholders and the dividend withholding tax treatment… – Continue reading
This summer brought some very significant amendments to the Cyprus tax laws, further enhancing Cyprus’ favourable tax regime. On 17 July 2015, the following laws were amended: The Special Defense for Contribution law No. 117(I) of 2002 as amended; The Income Tax Law No 118(I) of 2002 as amended; and… – Continue reading
Tax experts from the United States, United Kingdom, Canada, Brazil and Israel spoke at a two-day conference at Michigan Law about the challenges of the Foreign Account Tax Compliance Act (FATCA) and a multitude of other issues at the intersection of the law of taxation and citizenship. Panel discussions at… – Continue reading
After confirming that he would take part in the final round of the 2015 World Superbike Championship in Qatar, Max Biaggi’s presence at Losail this weekend is no longer a sure thing. The multiple World Champion has taken a fall from his mountain bike and sustained muscular injuries that may… – Continue reading
The National Assembly member (NAM) for Foni Bintang Karanai constituency has said that during the recent annual general meeting (AGM) of African Parliamentarian Network on Illicit Financial Flows and Tax (APNIFFT) held in Entebbe, Uganda, African parliamentarians present had applauded the Public Accounts Committee and Public Enterprises Committee (PAC/PEC) of… – Continue reading
Banking jobs in Geneva slipped to the lowest level since the 2008 financial crisis amid regulatory pressures, tax scrutiny and consolidation in the Swiss finance industry, according to lobby group Geneva Financial Center. Employees at banks in the city fell 3 percent to 18,855 in the 12 months through August,… – Continue reading
India and Israel will sign a double taxation avoidance pact and explore ways to ramp up engagement in diverse sectors during President Pranab Mukherjee’s three-day historic visit to the Jewish state, the first by an Indian Head of State, beginning tomorrow, reports NDTV. Ahead of his visit, Israel said the… – Continue reading
The Government of India, Ministry of Finance had on August 7, 2015, in order to comply with the information reporting requirements of the US’ Foreign Account Tax Compliance Act (hereinafter referred to as ‘FATCA’), made amendments in the Income-tax Rules, 1962. WHAT IS FATCA’S BACKGROUND? FATCA is a broad set… – Continue reading
The Norwegian conservative government on 7 October 2015 published both the proposed state budget for 2016 and a “white paper” containing proposals for tax reform. The proposed tax reform in the white paper is a follow-up action from a report on tax reform, presented by the Tax Commission in late… – Continue reading
Hong Kong (HKSAR) – The Government will, in the light of stakeholders’ views collected during consultation, refine the legislative proposals for implementing in Hong Kong the new international standard on Automatic Exchange of Financial Account Information in Tax Matters (AEOI), a government spokesman said today (October 12). Hong Kong pledged… – Continue reading
THE ADVANTAGES OF JERSEY For high net worth individuals considering a relocation, there are a number of factors that will be weighed up in making a choice which is right for both the head and the heart. To be a serious contender, a jurisdiction must certainly be fiscally friendly. But… – Continue reading
Historically, unlike UK residents who are generally liable to CGT on disposals of UK residential property (other than their principal residence), non-residents have been able to dispose of such property potentially free from UK CGT. The UK government sought to address this inconsistency by introducing a CGT charge in the… – Continue reading
The Government has expressed a commitment to improving levels of UK corporate transparency but a recent Private Eye article [1], documenting the extent of ownership of British Land through offshore entities, shows just how far there is to go. By far the most common reason for owning UK property through… – Continue reading
This French Tax Update will focus on (i) the main provisions of the draft Finance Bill for 2016 (Projet de loi de finance pour 2016) issued by the French Government on September 30, 2015 and to be discussed before the French Parliament between October and December (“Draft Finance Bill for… – Continue reading
The UK Government has released details of its plans to abolish the permanency of non-domicile status through the introduction of a “deemed domicile rule.”, reports Tax News. In his Summer Budget, Chancellor George Osborne announced plans to abolish the permanent non-dom tax status, meaning that anyone resident in the UK… – Continue reading
In brief On 18 September 2015, Treasury released exposure draft legislation in relation to the implementation of the Organisation for Economic Co-operation and Development’s (OECD) Common Reporting Standard (CRS) for the automatic exchange of financial account information. The CRS is intended to reduce international tax evasion and represents the next… – Continue reading
