Concerns have arisen over a temporary misalignment between the US country-by-country reporting regime and Italian legislation. Antonella Della Rovere and Federico Vincenti of Valente Associati GEB Partners explain. An agreement for the automatic exchange of country-by-country reports (CbCR) between Italy and the US (Agreement) came into effect on September 27… – Continue reading
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
A Federal Court judge has approved at least one court order that will require a British Columbia developer to turn over information to tax officials about people who bought and flipped condo units before or during construction. And several similar applications are under way, reflecting the federal government’s efforts to… – Continue reading
The government’s planned changes to the tax law for South Africans working abroad – either permanently or on a long-term contracts – has brought financial emigration into sharp focus. Financial emigration is a formal process with the South African Reserve Bank (SARB) to change your tax status from “resident” to… – Continue reading
Move on multinational tax arrangements expected to be announced in the Budget An important change to multinational tax arrangements is expected to be announced in Budget 2018, limiting the tax write-offs big companies can take up front on movements of valuable intellectual property to Ireland. The move could provide a… – Continue reading
The latest changes in Australia’s housing affordability laws are likely to have an effect on property sales tax liabilities for Australian citizens and associated property taxes for expats living and working in the country as well as property investors. Firstly, Aussie citizens living overseas may lose their Capital Gains Tax… – Continue reading
If you live in Nigeria and you have a foreign bank account; you should read this.If things go as planned, the FIRS will soon have access to information on the money and other financial investments that you have in your foreign bank account. This will happen when the Common Reporting… – Continue reading
BRUSSELS (Reuters) – The European Union’s plans to increase taxes on digital firms risks undermining the bloc’s growth and stifle global efforts to find common solutions, U.S. companies operating in the EU said on Tuesday. Critics say online firms such as Google (GOOGL.O) or Facebook (FB.O) pay too little tax… – Continue reading
ECONOMYNEXT – Foreign investors in Sri Lanka’s rupee bonds may not have to pay taxes after April 2018, Deputy Central Bank Governor Nandalal Weerasinghe said, amid some uncertainty in markets how a new Inland Revenue law will be interpreted. Sri Lanka lifted a 10 percent withholding tax government bonds from… – Continue reading
The Swiss Federal Department of Finance is consulting on proposals to amend the Withholding Tax (WHT) Ordinance, to more clearly define the rules for non-resident taxpayers. Under the proposed reforms, “quasi-residents” will be permitted to request a subsequent ordinary tax assessment. “Quasi-residents” are employees who are not domiciled in Switzerland… – Continue reading
On 19 September 2017, the Dutch government released the State’s Budget for the year 2018. The Budget includes a draft bill to expand the dividend withholding tax exemption to tax treaty countries, to introduce a withholding tax obligation for holding cooperatives and to limit the taxation of non-resident investors. If… – Continue reading
The World Bank has released French and Spanish translations of its Toolkit on the taxation of offshore indirect transfers and extended the deadline for feedback to October 20. The tax treatment of “offshore indirect transfers” (OITs) – in essence, the sale of an entity owning an asset located in one… – Continue reading
In our last publication, we discussed the signing of the Ghana-Morocco Double Tax Agreement (“DTA”) and the provisions of the DTA in relation to the taxation of permanent establishments and business income. In the concluding part of the article, we will discuss the taxation of investment, employment and service incomes… – Continue reading
ANALYSIS: Companies are likely to receive a preliminary notice under the new diverted profits tax (DPT) regime between now and the end of 2017. They should treat the issue of a notice as potential litigation and should immediately involve their legal advisers. For many companies the time limit for the… – Continue reading
Huge numbers of the 9 million US expats living around the world are fed up with the IRS and resent tax filing from their new homes. A poll suggests two-thirds of expats feel they should not have to tell the IRS about their finances if they do not live in… – Continue reading
In its latest policy paper to target the cross-border financial services sector, the UK government today unveiled proposed legislation that seeks to prevent the use of offshore trusts to avoid tax. The measure ensures that payments from an offshore trust intended for a UK-resident individual “don’t escape tax when they… – Continue reading
Romanians who leave the country for more than six months need to fill in a form at the Tax Agency (ANAF) starting January 1 next year. Otherwise they will receive fines ranging between RON 50-100 (EUR 11-22), according to the Finance Ministry. The obligation to notify the authorities on leaving… – Continue reading
THE CABINET yesterday gave the green light to a draft agreement on the exemption of double taxation between Thailand and Cambodia. It aims to back this up with a similar deal with Brunei as part of Thailand’s effort to complete cooperation on this and other economic initiatives with all the… – Continue reading
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
The Treasurer has recently released exposure draft legislation (Treasury Laws Amendment (Housing Tax Integrity) Bill 2017) in relation to removal of the CGT main residence exemption for foreign residents. The changes are part of the Commonwealth Government’s ‘housing affordability’ reforms announced in the 2017-18 Budget. This will affect both Australian… – Continue reading
According to China Merchants Bank and Bain & Company, a global business consulting firm, nearly 60 percent of China’s high net worth individuals have assets overseas in 2017, while in 2011 this ratio was only 20 percent. In 2015 and 2016, China’s annual financial assets exported overseas amounted to more… – Continue reading
South Africans face a tax crackdown on offshore earnings under a new government proposal. The measure will scrap the current rules that allow South Africans to work in another country for half the year without paying tax on income. If the change is adopted, South Africa will become one of… – Continue reading
INTRODUCTION HMRC have successfully challenged the offshore residence of Jersey companies holding UK real estate. In the case of Development Securities, the First Tier Tribunal held that Jersey companies set up to hold UK real estate were resident in the UK for tax purposes. This case serves as a timely… – Continue reading
Every individual has a nil rate band of £325,000 after which any assets above this threshold become taxable at 40% unless they are passing to an exempt beneficiary such as a charity or spouse/civil partner. This threshold has been frozen until the end of the 2020/21 tax year. The government… – Continue reading
I am a trustee of an offshore trust settled by a UK resident, non-UK domiciled settlor (with no UK origins) for the benefit of himself and his family. He previously opted to be taxed on the remittance basis. The trust holds only offshore investments. The settlor lent monies to the… – Continue reading
HM Revenue & Customs’ new online Trusts Registration Service is now up and running, and beginning to get the attention of trust providers in a big way. Here, tax commentator Gerry Brown looks at the new regulations, and what they will mean for those in the trusts industry. The UK… – Continue reading
Italy has granted non-domiciled status to a taxpayer for the first time, after introducing a new non-dom regime at the start of the year. Withers LLP represented the taxpayer, a high net worth individual who was formerly registered as a non-dom in the UK, and who has decided to move… – Continue reading
The Act currently provides for income taxable as ‘capital gains’ to be computed after taking into account the full value of consideration received or accrued on transfer of a capital asset “A person doesn’t know how much he has to be thankful for until he has to pay taxes on… – Continue reading
Reader M wrote to Lifelines about Japan’s inheritance tax law, which he calls “one of the most punitive in the world”: I’ve read with interest a number of articles in The Japan Times recently about the Japanese government’s efforts to make it easier for foreigners to obtain permanent residence in… – Continue reading
The Gupta family sought advice on how to move tens of billions of rands to the United Arab Emirates, revealing the enormous size of their empire, according to a report by the Sunday Times. The treaty which came into effect in March this year, stops the South African Revenue Service… – Continue reading
The Australian Government has unveiled a package of housing tax breaks, including a new scheme for first-time buyers, a superannuation incentive for downsizers, and tighter rules for foreign residents. In a joint release, Treasurer Scott Morrison and his Assistant Minister, Michael Sukkar, said: “Housing affordability is a major issue affecting… – Continue reading
The Irish Parliament’s arts committee has recommended the introduction of a “foreign artists’ withholding tax (WHT) scheme.” The committee has released a report on the Government’s Culture 2025 initiative, which is intended to provide a framework for the development of Irish arts, culture, and heritage over the next eight years…. – Continue reading
THE BENEFITS OF NON-DOMICILE STATUS An individual who is resident but not domiciled in the UK does not pay tax on overseas income and gains, as long as they are kept outside the UK and are not used to provide benefits in the UK. This is called the remittance basis… – Continue reading
Canada and dozens of other countries will automatically share banking information of non-residents Canadians with secret overseas bank accounts could soon find themselves at risk of being exposed by a new international agreement designed to help catch tax cheats. Under the Common Reporting Standard, dozens of countries will share information… – Continue reading
Tax liability under the Income-tax Act, 1961 (‘the Act’) of any person is determined based upon his residential status. A person resident of India is taxable on his income accruing across the globe [see End Note 1] while a non-resident is taxable only on the income accruing or arising or… – Continue reading
Expats can claim pension tax relief as long as they are still resident in the UK. Residence is a matter of fact rather than choice and depends on the result of the statutory residence test. Expats who are not resident in the UK cannot claim pension tax relief How do… – Continue reading
France will cut taxes on businesses and individuals by roughly 11 billion euros ($12.6 billion) next year, faster than the government had originally intended, Prime Minister Edouard Philippe has said. The goal is to create incentives for investment, hiring and economic growth, Philippe told Les Echos daily in an interview… – Continue reading
Passing on your inheritance and your place of residence – the tax minefield QUESTION: I was born in Belfast and now live in Dublin. I have 2 children who both live in Dublin and I am contemplating retiring to Northern Ireland. Is there a difference between the Inheritance tax systems… – Continue reading
Banks will have to share customer information after a new tax law took effect Saturday, according to New Zealand Bankers’ Association. The new law requires banks and other financial institutions to identify accounts held by foreign tax residents. This customer information will be provided to Inland Revenue, which will in… – Continue reading
Introduction Finance Act 2016 replaced the test for corporate residency of foreign companies from “control and management being situated wholly in India” to “place of effective management (POEM) in India”. POEM has been defined to mean a place where key management and commercial decisions that are necessary for conduct of… – Continue reading
Tax returns and annual financial disclosures contain different information Candidates and members of Congress are required by law to file personal financial disclosures that are designed to shed a light on their potential conflicts of interest. These documents show a lawmakers’ assets and liabilities, reported in broad ranges. Tax returns,… – Continue reading
Indian immigrants in Saudi Arabia are set to be hit by the Kingdom’s newly introduced ‘family tax’ that will come into effect starting from July 1. The tax requires employed persons to pay a fee of 100 riyals (Rs 1,700 approx) per dependent each month. So, an Indian expat living… – Continue reading
The Government Emergency Ordinance no. 42/2017 amending Law no. 207/2015 regarding the Fiscal Procedure Code (“GEO 42/2017“), entered into force on 13 June 2017, transposes within the Romanian legislation the EU Directive 2016/881 which provides the mandatory automatic exchange of information from reports that multinational enterprise groups (“MNE Groups“) must… – Continue reading
In Federal Budget 2017, the Government is clamping down on tax avoidance by foreign investors in real estate, by tightening the foreign resident capital gains tax withholding regime. The new laws apply to both Australian resident and foreign resident vendors: Australian resident vendors of real property of $750,000 or more… – Continue reading
Italy June 30 will apply OECD guidelines for “patent box” rules, a new version of the tax break for intangible property that will remove protections for brand identities originally put in place to protect iconic Italian fashion brands, observers told Bloomberg BNA. The new regime is substantially similar to the… – Continue reading
Transferring wealth to a spouse who isn’t a U.S. citizen can create complex gift, estate and generation-skipping transfer tax challenges. Such transfer tax issues require careful planning, as well as a clear understanding of the differences in how citizens and non-citizens are taxed. Unlike citizens and resident aliens, a non-resident… – Continue reading
KARACHI: The rate of withholding tax for non-filers against the winning amount on prize bonds has been increased to 25 percent from the existing 20 percent. The government through the Finance Bill, 2017 has proposed stern measures for non-filers in order to broaden the tax base and generate revenue. In… – Continue reading
You may be liable for capital gains tax. Here’s how. There is a common misconception that the sale of a person’s primary residence will never result in capital gains tax being payable; this is incorrect. For most taxpayers the sale of a primary residence will not result in a taxable… – Continue reading
Apartment construction is booming as the wealthy rush to invest in rental housing as a way to reduce inheritance tax and banks hand out easy mortgages, but concerns are mounting that excessive supply paired with a shrinking population could soon lead to the bursting of the bubble. New starts on… – Continue reading
For approximately 7,000 tax-evading individuals and businesses in Detroit, it may be time to pay up. Detroit tax collectors are conducting a large scale litigation campaign against tax evading individuals and businesses operating at 33 properties within the city’s downtown and midtown areas, the Associated Press reports. The team behind… – Continue reading
