Category: Withholding tax rules

Polish Deal introduces new minimum tax for corporations

On 8 September, Poland’s government accepted a new tax bill called the “Polish Deal,” announcing after the public consultation on the bill a significant amendment to include a special anti-avoidance measure referred to as a minimum income tax for corporations. ... - Continue reading

UK: Tax Bites – June 2021

Further extension to UK Common Reporting Standard compliance rules

Regulations have been made to extend the International Tax Compliance Regulations 2015 (SI 2015/878) (the Compliance Regulations). The Compliance Regulations, among other things, require UK financial institutions to report information regarding certain non-UK account holders to HMRC for exchange under international arrangements relating to the Common Reporting Standard (CRS). ... - 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

Canada: Don’t Let Your Dream Vacation Home Become A Tax Nightmare

Renting your foreign property may require you to disclose information to the Canada Revenue Agency (the "CRA"). A Foreign Income Verification Statement is required to be filed with the CRA where the adjusted cost base of the property exceeds CDN $100,000.  ... - Continue reading

Canada: Treaty Shopping: MIL, MLI And ALTA Things In Between

On February 12, the Federal Court of Appeal (FCA) released its decision in The Queen v. Alta Energy Luxembourg S.a.r.l.1 (Alta Energy), a case that represents an attempt by the Canadian tax authority to relitigate the issue of whether Canada’s domestic general anti-avoidance rule (GAAR) can apply to curtail so-called “treaty shopping”.2   ... - Continue reading

Ireland Budget 2020 released

On 8 October, the Irish government announced its Budget 2020 measures. Brexit and climate change are core themes of new revenue measures and expenditure commitments. Brexit remains the foremost immediate concern for the Irish economy, whereas tackling climate change requires long-term commitments to tax and spending policies. ... - Continue reading

Bermuda: Chambers Private Wealth 2019: Bermuda (2019)

1. Tax1.1 Tax regimes In Bermuda there is no income or profits tax, withholding tax, capital gains tax, capital transfer tax or inheritance tax. There is no exit or similar such tax based on a resident's wealth when ceasing to be resident and there are no other consequences of leaving the jurisdiction. Customs duties and stamp duty are major government revenue earners, with stamp duties charged at different rates and in different manners on a variety of legal documents, excluding wills. ... - Continue reading

Ukraine: Ukraine Ratifies Protocol Amending Double Taxation Treaty Between Ukraine And Switzerland

On 18 September 2019, the Parliament of Ukraine ratified a protocol (the Protocol) of amendments to the double tax treaty between Ukraine and Switzerland (the DTT) which had been signed by the states on 24 January 2019.  ... - Continue reading

Canada: Canada Ratifies The Multilateral Instrument

On June 7, 2017, Canada along with numerous other jurisdictions signed the Organisation for Economic Co-operation and Development’s (“OECD”) Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “MLI” or “multilateral instrument”). The multilateral instrument is the culmination of work undertaken as part of the OECD/G20 BEPS Project to equip governments with domestic and international instruments to address tax avoidance.   ... - Continue reading

Cyprus: The Cyprus Investment Programme And The Benefits

The Cyprus Investment Programme is rapidly becoming one of the EU’s most popular residence schemes.

  • Non Cypriot citizens (and their families) can acquire Cyprus Citizenship by investing €2.5 million* in Cyprus.
*In one specific set of circumstances as detailed below in the financial criteria, the investment required is €2.0 million. A non-Cypriot citizen who meets one of the financial criteria detailed below can apply for Cypriot citizenship ‘through naturalization by exception’.
  • Following the application, Cyprus citizenship will be granted in six months, assuming the application has been completed accurately and the correct documentation filed.
  • The applicant needs to be in posession of a residence permit for a period of six months before obtaining the citizenship.
... - Continue reading

Hong Kong: A Guide To Tax Regulations In Hong Kong 2019 – 2020

While considering moving a business into a new market, one of the key consideration is that country's tax regime. What are the incentives that would attract foreign investment? Are there any double tax treaties in place? What is the rate for corporate tax? ... - Continue reading

UK: Non-Resident Capital Gains Tax on United Kingdom Real Estate: A New Regime

The legislation encompassing the new regime for taxing non-residents' gains on the United Kingdom (UK) commercial real estate came into effect on 6th April 2019. Her Majesty's Revenue and Customs (HMRC) has additionally published draft guidance on this recently introduced regime. This article briefly summarizes the new rules. ... - Continue reading

Cyprus: Cyprus–Kazakhstan First-Time Double Tax Treaty: Cyprus Ratifies

On 24 May 2019, Cyprus ratified the first-time double tax treaty it had signed with Kazakhstan on 15 May 2019 (the DTT). Certain legal procedures now need to take place in both states following which the DTT will ‘enter into force’. The DTT will be ‘in effect’ as from the… – Continue reading

Revised tax treaties usher in a new era in investment, taxation

Policy tweaks  curb evasion,  show  India  can woo investments without  sops Singapore, another major FDI contributor to India, too, enjoyed the same tax sops under a similar treaty with India NEW DELHI: For about a decade-and-a-half, revenue authorities examining foreign investment proposals received by the erstwhile Foreign Investment Promotion Board… – Continue reading

Non-resident capital gains tax on UK commercial property ‘could block overseas investment’ – expert view

The Government’s changes to the tax treatment of overseas investment in UK commercial property will increase revenues in the short term but might prove short-sighted, write Craig Hughes and Russell Dickie There is, as they say, no place like home. However, in recent years, solid and steady capital growth and… – Continue reading

PSX recommends CGT exemption for foreign investors in next fiscal year

—Says exemption to facilitate capital inflow by relaxing account opening, registration process ISLAMABAD: The Pakistan Stock Exchange (PSX) in its proposals for budget 2019-2020 has recommended exemption of capital gain tax (CGT) on disposal of securities by foreign investors. Budget proposals for next fiscal year 2019-20, available with Pakistan Today,… – Continue reading