Category: Withholding Tax

Ireland: Aviation Finance & Leasing 2022

Financing structures involving Irish entities often employ the use of a special-purpose vehicle ("SPV"), which is a company established specifically to hold title to the aircraft subject to the financing and to lease those aircraft to the operators. Ireland is a popular jurisdiction for the establishment of SPVs due to the numerous double-tax treaties in place between Ireland and other countries, many of which specifically refer to aviation in their text. Ireland is also attractive due to the confidence in the legal and court system (which is broadly based on English common law) and the number of aviation experts and leasing companies based in Ireland. ... - Continue reading

Q&A: tax issues for private equity funds in Cayman Islands

Under current Cayman Islands law, there are no Cayman Islands taxes on income or gains of the private equity fund (PE fund) or on gains on dispositions of shares or partnership interests, and distributions made by a PE fund will not be subject to withholding tax in the Cayman Islands. ... - Continue reading

Requests for confirmation, tax treaty relief applications and tax sparing applications

IN 2021, the Bureau of Internal Revenue (BIR) issued Revenue Memorandum Order (RMO) 14-2021 and Revenue Memorandum Circular (RMC) 77-2021, which streamlined the procedure for the availment of benefits under the applicable tax treaty.  ... - Continue reading

Ten-year tax incentives granted to special technology zones

The government has granted a comprehensive duty and tax incentives for a period of 10 years to investors operating in the proposed special technology zones (STZs), sources in the Federal Board of Revenue (FBR) said on Monday. The incentives also include immunity from explaining the source of funds to be… – Continue reading

Cyprus: Cyprus – Russia Double Tax Treaty

Cyprus strikes a deal on Double Tax Treaty with Russian Government The Republic of Cyprus and Russia had entered into a Double Tax Treaty (DTT) in 1998 in a joint effort to avoid the double taxing of income and capital generated in Cyprus, in order to promote the economic cooperation between the two countries. Since its introduction, the DTT has been the catalyst for Russian investment in Cyprus, being an attractive jurisdiction with regards to its tax benefits. ... - Continue reading

Italy’s Supreme Court resolves withholding tax dispute over interest paid to holding company

The Italian Supreme Court, in a decision released 10 July, has addressed whether a sub-holding company was beneficial owner of interest payments for withholding tax purposes, applying the European Court of Justice’s holdings in the well-known Danish cases. ... - Continue reading

EU Advocate General considers Bulgaria’s refusal to exempt dividends paid to a Gibraltar companies from withholding tax

The Advocate General (AG) in an opinion issued 24 October (Case C-458/18) stated that a company incorporated in Gibraltar and subject to Gibraltar corporation tax cannot be considered to be a “company of a Member State” within the meaning of the parent-subsidiary directive (Directive 2011/96). ... - Continue reading

POGOs’ tax compliance improves

The tax compliance of online gaming operators and their service providers continue to show improvements every month amid the strict enforcement activities of the government, a tax official said. The Bureau of Internal Revenue (BIR) initially reported that its preliminary income tax collection from Philippine offshore gaming operators (POGO) foreign… – Continue reading

BIR Officials: Congress not inclined to lift Bank Secrecy

“The suggestion has been brought up many times before and lawmakers with the support of the business community rejected it,” said a revenue regional director who declined to be named. He recalled that many congressmen even protested when the BIR in 2014 tried to require taxpayers to include in their… – Continue reading

Worldwide: Financial Institutions And Personal Data

Combating Tax EvasionIn recent years, there have been several high-profile prosecutions for the crime of tax evasion (for example the actor, Wesley Snipes, and the footballer, Lionel Messi). Governments around the world have been making a concerted effort in an attempt to tackle this problem. Their objective is for their respective tax administrations to work together so that taxpayers pay the correct amount of tax in the correct jurisdiction. ... - Continue reading

Uganda: Don’t Make Up Losses To Avoid Tax

Conflicting interests arise for many businesses where decisions have to be made to determine how they consistently achieve profitability, while on the other hand minimise payment of tax. The temptation to minimise profits or even make a loss then becomes a tax risk management strategy. ... - Continue reading

BIR padlocks main office, 2 branches of tax-dodging POGO service provider

The Bureau of Internal Revenue (BIR) padlocked simultaneously Wednesday the main office and two branches of one of the biggest Philippine Offshore Gaming Operator (POGO) service providers in the country for alleged failure to register and pay the corresponding deficiency taxes amounting to P2 billion. Shuttered were the headquarter of… – Continue reading